North East Cambridge Area Action Plan Issues and Options 2019

Introduction

Cambridge City Council and South Cambridgeshire District Council is consulting on Issues & Options for the North East Cambridge AAP. The consultation deadline is 25th March 2019. The draft response on behalf of U+I Group PLC ('U+I') is set out below. U+I have been selected by the landowners Anglian Water and Cambridge City Council as Master Developer for land outlined in red in the accompanying Site Plan ('the Site'). It is noted that Cambridge City Council also own other land beyond the Site, which may be the subject of other representations.

The representations contained herein relate primarily to the development intentions for the Site, but also in the context of the wider AAP area (as sites within the AAP boundary are largely intrinsically linked).

Representations

Question 1: Do you agree with changing the name of the plan to the 'North East Cambridge Area Action Plan'?

It is recognised that there is a need for a collective reference for the AAP area. This will provide consistency and clearer definition as the process evolves. Whilst it is inevitable that sub-areas of the AAP will emerge with different branding names and strategies, this will have more relevance to the individual sub-area concerned, in creating identity when publicising forthcoming planning applications through to marketing/sales disposals.

Question 2: Is the proposed boundary the most appropriate one for the AAP?

Generally, we support the proposed boundary for the AAP area. We would, however, make two observations/comments.

Firstly, it seems logical to include the site of Cambridge Regional College ('CRC') within the boundary. It is noted that in paragraph 3.5 comment is made that it is not expected to undergo major change in the way other sites across NEC are. However, CRC considers itself to be 'one of the best Further Education Colleges in the country for 16-18 year old level 3 achievement and a leading apprenticeship provider, with thousands of full time students and apprentices currently in training'. The significant range of vocational courses it offers could be positively utilised to support the long-term construction process around NEC (e.g. architectural technology, mechanical engineering, electrical, carpentry, bricklaying courses and apprenticeships), and then the on-going operational phases of the different sub-areas of NEC (e.g. from courses relating to biological science for industry, laboratory technicians and computing technologies, to business and catering and hospitality). It therefore has the potential to play an important learning and development role in the future NEC area. The built form of the current campus appears to be relatively low density, with large areas of used for surface level car parking. Buildings are predominantly 2-3 storeys in height. With the transformation of NEC, recognising the different approaches to internalised trips/reduced car parking, and taller buildings, it would seem likely that the estate management of CRC might change in the future, and if so, it should be included in the AAP.

Secondly, we would comment that, owing to the nature of NEC, development is likely to be high density, optimising the use of all land to work efficiently and effectively. The strategy for on-site Public Open Space is likely to focus on qualitative provision, than quantitative, with a stronger emphasis on formal recreational and leisure space than informal open space. Access to the latter however, is likely to be facilitated through new and improved connections to the east (potentially including land to the east of the railway line north of Cambridge North Train Station, to the river) and north (potentially including land to the north of the A14, such as Land to the south of Cambridge Road, and land including/extending Milton Country Park) of NEC. We would therefore simply pose the question about whether there is a need to include within the AAP boundary additional land that could provide informal open space, biodiversity and drainage functions, which might otherwise not be achievable within the single control of the NEC boundary. It is considered that land to the north and east of the current AAP boundary would primarily be used to facilitate access to green infrastructure for NEC.

Question 3: In this chapter have we correctly identified the physical characteristics of the North East Cambridge area and its surroundings?

Generally, yes. However, we consider it might be beneficial to include more information about the composition of site areas. For instance, on the employment parks, providing details about site area, total floorspace of buildings on the park (including extant planning consents) and the range of authorised planning uses e.g. % B1a uses, %B1b uses, estimated no. of employees, audit of authorised car parking spaces, audit of public open space (estimated total hectares). This would help to inform a baseline of land use within NEC, and then contribute in developing future strategy e.g. highway trip budget, employment strategy, connectivity and green infrastructure etc.
We would also note that it would be beneficial to have mapping information available relating to the environmental constraints identified e.g. noise, air quality, odour, important habitats.
Finally, it would be beneficial to show the broader extents of key infrastructure for NEC, including the full Chisholm Trail link (connecting NEC to Cambridge City, and the south of Cambridge (Addenbrookes), committed routes for other new cycle, pedestrian and public transport in and around the City, and the proposed Greenways link to Waterbeach).

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

In general, yes. However, we note that there is no reference to Archaeology and Heritage, and would suggest that comment is given about this, even if it is considered that NEC has limited archaeological significance. In terms of heritage, whilst we believe that there are no listed buildings, conservation areas, or other notable heritage constraints within NEC, the intention for taller buildings in NEC will need to be more widely considered in respect of longer-distant views and townscape issues (historic core of Cambridge). Taller buildings may also have potential implications for Air Safeguarding Zones (consultation required with Marshall Airport and the Ministry of Defence on structures over 15m in height), and the Mullard Radio Astronomy Observatory (consultation with the University of Cambridge). We acknowledge that the issue of building heights and taller buildings is likely to be assessed as part of the on-going Landscape Character and Visual Impact Assessment that is being undertaken by Cambridge City Council (it is understood that a 'Stage 1' exercise has already been commissioned), and that the findings are then likely to inform future stages of this AAP process.

We would also suggest consideration be given to the inclusion of Green Belt boundaries around NEC. This will help provide clarity to interested parties that all land envisaged for development and associated physical infrastructure will be accommodated on non-Green Belt land. It will also help to provide reassurance that the development aspirations for NEC will not automatically lead to further development beyond the identified boundaries, unless it is deemed to be 'appropriate development' (i.e. not 'inappropriate' as defined in the National Planning Policy Framework'), or that exceptional circumstances are demonstrated in future Local Plans, or a Very Special Circumstances argument is made to support development via a planning application process. In all cases, strict mechanisms for controlling additional future development beyond NEC will apply.

Reference should also be made to the presence of UKPN's overhead power cables (132KV) that span across the AAP boundary. In terms of ensuring optimum reuse of the Site (and indeed other sites, including Cambridge Science Park), we would support a policy seeking their diversion underground.

Question 5: Do you agree with the proposed Vision for the future of the North East Cambridge area? If not, what might you change?

Yes, we support the proposed Vision for NEC. The addition of the word 'culturally' might benefit this Vision further (in the context of 'North East Cambridge - a socially, culturally, and economically inclusive....)

Question 6: Do you agree with the overarching Objectives? If not, what might you change?

Generally, we support the overarching Objectives. The addition of the words 'Natural Capital' might benefit Objective 7 further (in the context of '...connecting and improving biodiversity to achieve a Natural Capital net gain....)

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

It is noted that the Concept Plan can only be treated as indicative at this stage in the AAP process, until the outcomes of the various Supporting Studies are known (notably Landscape Character and Visual Impact Assessment, Development Capacity Study, NEC AAP Transport Assessment, NEC Development Viability Assessment, NEC Infrastructure Delivery Plan), and wider consultation with relevant interested parties (e.g. landowners, developers, local communities, local authority bodies etc) has been carried out.

We support the residential-led mixed use allocation for the Site. We support the aspiration to create high quality pedestrian, cycle and public transport connectivity across the AAP area. We support the indication that a Mixed Use District Centre will be provided on the Site though we would suggest that its optimal location can only be determined after further study and masterplanning work. There may also be a need to include an additional Mixed Use Local Centre in the northern half of the Site (subject to further Masterplanning and an assessment on accessibility). We support the intention to provide and integrate Green Infrastructure throughout the AAP boundary, but what provision is made (and how/where it will be provided) will need to be determined following further studies/assessment and Masterplanning. Further consideration will need to be given to the suggested Industrial Development Sites in the north east corner of the Site, to understand what the rationale is for proposing to relocate existing industrial land at Nuffield Road and Cowley Road, to another part of the AAP site. It is assumed that the suggestion is made on the basis that it will provide noise abatement from the A14 to the new residential elements of the Site. However, we consider that there may be other more preferable solutions for controlling noise and, in Masterplanning terms it is less desirable bringing industrial-related traffic through a predominantly residential site. In the absence of clear justification for seeking relocation of industrial uses, we cannot support the industrial element of the proposal.

We aren't yet persuaded that the proposed location and quantum of industrial use is optimal. In particular we have concerns that this is currently shown at the furthest point from strategic highway connections. We also believe that different models and formats of industrial development should be further explored, specifically whether this should be concentrated in a single location, or whether it might be incorporated within a mixed-use approach throughout the Site.

We do not necessarily agree that the Site represents the best opportunity with the overall AAP area to accommodate a significant concentration of industrial uses in a single location.

We would suggest that the Cambridge Business Park is shaded as an Opportunity for Employment Intensification.

In addition to our response for Question 2, we would suggest that the CRC land we would suggest that this land is included within the AAP boundary, and that a new shading is applied that refers to an Opportunity for Education Intensification.

Question 8: Do you agree that outside of the existing business areas, the eastern part of the North East Cambridge AAP area (i.e. the area east of Milton Road) should provide a higher density mixed use residential led area with intensified employment, relocation of existing industrial uses and other supporting uses?

Generally, we support the initial development intentions for the area east of Milton Road. It is considered that this area could accommodate a high density mixed use residential-led development following the relocation of the existing Cambridge Water Recycling Centre and other industrial uses (subject to viability and finding suitable relocation site(s)) from the Site. A comprehensive, design-led, approach across the AAP will help maximise the redevelopment potential of a significant brownfield site in a highly sustainable location.

Question 9: Should Nuffield Road Industrial Estate be redeveloped for residential mixed use development?

Yes, we agree that consideration should be given to relocating existing industrial uses on the Nuffield Road Industrial Estate, in preference for higher density residential-led mixed use redevelopment. Consideration should be given to the viability of doing so (industrial land values are currently relatively high), and where existing businesses will be relocated. An Industrial Relocation Strategy might be appropriate, in order to understand what factors are important to businesses e.g. last mile strategies and what alternative sites might be available to accommodate relocation requirements. ]

As outlined in Question 7, the suggestion to relocate industrial uses from Nuffield Road Industrial Estate to the north east corner of the Site needs to be explained and justified. At this stage we do not support the suggestion to relocate industrial uses to the north-east corner of the Site.

Question 10: Do you agree that opportunities should be explored to intensify and diversify existing business areas? If so, with what sort of uses?

Yes, we broadly support this suggestion, subject to the establishment of a robust and equitable approach to Highways Trip Budget apportionment and s106 tariff system across the wider AAP area. The Cambridge Science Park was first established on the principle of accommodating 1-2 storey, low density commercial buildings within an attractive strategic landscape/parkland setting. Whilst much of the strategic landscaping remains, latter phases of the Science Park have sought to intensify development density, with taller buildings, lower car parking provision, and limited on-plot landscaping (other than to lessen/soften the impact of new development). This approach has been complemented by the introduction of Cambridge North Station Interchange, which has significantly improved accessibility via non-car modes. The growth aspirations now anticipated for the AAP area signals a radical change in approach to new development. New residential communities will be supported by existing and intensified employment and educational opportunities, potentially providing live and work/learning opportunities within walking/cycling distance of each other. Furthermore, access to inter alia Cambridge North, the Guided Busway, and the Chisholm Trail will support accessibility to existing business areas from a much wider catchment, therefore helping to improve the means of accessing work without the need to do so by car.

Opportunities to provide a greater quantum and diversity of employment should be encouraged. This will consolidate and strengthen the concept of the Cambridge Phenomenon, by creating a greater range and quantum of high quality accommodation for new businesses, in close proximity to a critical mass of similar businesses, thereby helping to support knowledge sharing and collaboration through co-location.

In order to promote diversity of employment types, planning policy consideration might be given to encouraging a certain percentage of 'affordable employment', to support the growth of new start-up businesses that require the same close links with similar businesses but cannot afford (and do not currently need) accommodation that becomes available.

Question 11: Are there any particular land uses that should be accommodated in the North East Cambridge area?

The North East Cambridge area should support any use that demonstrably contributes to the Vision and Objectives of the AAP area.
The AAP provides a significant opportunity to create thousands of new homes in a highly sustainable location. The growth of housing in this area will be supported by the economic benefits derived from the long-established science, innovation and business parks (many of which will be intensified), that have collectively grown from the success of clustering knowledge-based industries in close proximity of one another. The housing element of the Site will improve supply and affordability of high quality new homes to the many thousands of employees on these parks, helping to reduce the number of car movements on Milton Road. New homes and jobs on the scale envisage will need to be served by a number of social, retail, community, health, education, leisure and recreation facilities,

Question 12: What uses or activities should be included within the North East Cambridge AAP area which will create a district of culture, creativity and interest that will help create a successful community where people will choose to live and work and play?

It is considered that the inclusion of schools, community facilities, retail and leisure uses, open space, and transport services, in conjunction with walking and cycling connections to neighbouring areas will provide the attributes of a successful community.

The NEC AAP must recognise the wider role it plays in creating opportunities for surrounding communities, of which two neighbouring wards - East Chesterton and Kings Hedges - currently suffer from high levels of deprivation (included in the top three of most deprived wards in Cambridgeshire). The benefits of the AAP area should extend to these areas, to create new employment, education, social, leisure and recreation, health and community opportunities. Where new facilities are introduced to areas experiencing deprivation, a key challenge for optimising use of such facilities is affordability. Free or subsidised charging mechanisms should therefore be considered when providing new facilities for instance e.g. hire of sports pitches, meeting rooms etc.

It should, however, be recognised (and indeed it is in Question 79) that the ambitious development aspirations for the Site and wider AAP area will take a number of years to comprehensively plan and deliver. Certain elements will be possible to deliver early. Notwithstanding this, there is the opportunity to introduce 'meanwhile/worthwhile' uses the area as the transition progresses. Meanwhile/worthwhile uses offer creative and innovative ways of optimising sites on a stop-gap basis, creating a temporary opportunity to capture economic and/or social benefits for the wider area in the period between the closure/or reduction of an existing site operation and the commencement of the intended new development.

Question 13: Should the AAP require developments in the North East Cambridge AAP area to apply Healthy Towns principles?

NEC will provide a considerable opportunity for creating a healthy new community, and supporting neighbouring communities, through access to high quality housing, a design approach founded on sustainable modes of travel (walkable neighbourhoods), and improved employment, shopping, health, education, leisure and recreational opportunities. We also support the intended preparation of the Health Impact and Needs Assessment for NEC, which will take account of the wider deprivation challenges faced in the neighbouring wards of East Chesterton and Kings Hedges.

Question 14: How should the AAP recognise and make best use of the existing and potential new links between the AAP area and the CRC (Cambridge Regional College)?

Please see our response to Question 2.

Question 15: Should clusters of taller buildings around areas of high accessibility including district and local centres and transport stops form part of the design-led approach to this new city district?

We strongly support the principle that the greatest development densities should be located in the areas of greatest accessibility and public amenity. This maximises the potential for sustainable travel patterns and establishes a critical weight of local demand for leisure, cultural and retail uses.

It is important to note that 'high-density' does not automatically mean 'tall' and that compact mid-rise development can often be denser than taller development, particular where the latter is compensated for by a smaller overall development footprint. Compact mid-rise also typically enables a wider range of dwelling types and external amenity space, meeting a wider range housing needs.

We favour a 'transect' based approach to masterplanning which will ensure the density, scale, typology, and uses of development are allocated across the site as a whole and within each neighbourhood in a coordinated way, following the accessibility principle described above and responding to the opportunities and constraints of the Site. This may not mean 'clusters' - it could for example mean that the highest densities are located in 'corridors' along the primary streets, and/or at edges where having denser development acts to shelter lower-scale development from adjacent visual or noise intrusion. The masterplan will be backed up by a design code that will identify/mandate appropriate typologies for achieving the requisite densities in ways that are acceptable in other respects.

In addition to accessibility and other local factors, it is important to note that the extent and location of denser development will be affected by a range of detailed studies and appraisals (including Landscape Character and Visual Impact Assessment), that will recognise - and then balance - the challenges of creating areas of higher density and taller buildings in a highly sustainable location that is, nonetheless, on the edge of Cambridge with areas of open countryside beyond. This may also militate against achieving density through height.

Question 16: Should the AAP include any or a combination of the options below to improve pedestrian and cycling connectivity through the site and to the surrounding area?

A - Create a strong east-west axis to unite Cambridge North Station with Cambridge Science Park across Milton Road. This pedestrian and cycle corridor would be integrated into the wider green infrastructure network to create a pleasant and enjoyable route for people to travel through and around the site. The route could also allow other sustainable forms of transport to connect across Milton Road.

Yes. A strong east-west axis should be included to connect the different parts and proposed uses within NEC, and to encourage movement within the site by sustainable modes of transport.

B - Improve north-south movement between the Cowley Road part of the site and Nuffield Road. Through the redevelopment of the Nuffield Road area of NEC, it will be important that new and existing residents have convenient and safe pedestrian and cycle access to the services and facilities that will be provided as part of the wider North East Cambridge area proposals.

Yes.
C - Upgrade connections to Milton Country Park by both foot and cycle. This would include improving access to the Jane Coston Bridge over the A14, the Waterbeach Greenway project including a new access under the A14 (see Transport Chapter), as well as the existing underpass along the river towpath.

Yes. It is considered that improvements to connections with Milton Country Park and with existing and proposed pedestrian and cycle routes will be important for the success of development within the AAP. It is anticipated that NEC will provide a high density residential development, to take advantage of the close proximity of employment areas and public transport services, but which might limit opportunities for large scale open space/recreation areas. Therefore, it will be important to ensure that any proposal for an underpass will maximise connectivity through the Site, capitalising on permeability and wider Green Infrastructure initiatives (e.g. Waterbeach Greenway, Chisholm Trail, improving the public realm function of the 1st Drain etc).

D - Provide another Cambridge Guided Bus stop to serve a new District Centre located to the east side of Milton Road.

We support the suggestion to improve public transport accessibility around NEC but further work should be undertaken to determine whether an additional 'guided' busway stop is required or whether a 'normal' bus service, which could feasibly use the same buses as those on the Busway, could deliver the same benefits.

E - Increase ease of movement across the sites by opening up opportunities to walk and cycle through areas where this is currently difficult, for example Cambridge Business Park and the Cambridge Science Park improving access to the Kings Hedges and East Chesterton areas as well as the City beyond.

We very much support opportunities to increase the ease and convenience of walking and cycling movements across sites in NEC, as this will strengthen the concept of promoting internalised trips and reduce the reliance on travel by car.

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

It is noted that the River Cam towpath is identified as a route within the Waterbeach Greenway project, and it would be appropriate to take the opportunity to provide a pedestrian and cycling connection from this route into NEC, subject to the availability of funding.

The high density redevelopment of NEC is unlikely to achieve the level of Public Open Space that might otherwise be required under local plan policy. The focus is instead likely to be on securing high quality, flexible-use open space on-site, and improving/providing new connections to informal open space networks to the north and east of the AAP area (including the Waterbeach Greenway). Accordingly, an appropriate means of accessing off-site Green Infrastructure for NEC will be required, and the suggestion of a pedestrian/cycle bridge would facilitate this.

Please see our responses to Questions 2 and 7.

Question 18: Which of the following options would best improve connectivity across Milton Road between Cambridge North Station and Cambridge Science Park?
A - One or more new 'green bridges' for pedestrians and cycles could be provided over Milton Road. The bridges could form part of the proposed green infrastructure strategy for NEC, creating a substantial green/ecological link(s) over the road.
B - Subject to viability and feasibility testing, Milton Road could be 'cut-in' or tunnelled below ground in order to create a pedestrian and cycle friendly environment at street level. This option would allow for significant improvements to the street which would be more pleasurable for people to walk and cycle through.
C - Milton Road could be significantly altered to rebalance the road in a way that reduces the dominance of the road, including rationalising (reducing) the number of junctions between the Guided Busway and the A14 as well as prioritising walking, cycling and public transport users.
D - Connectivity across Milton Road could be improved through other measures. We would welcome any other suggestions that would improve the east-west connectivity through the site.
E - Other ways of improving connections (please specify)

In response to all five options listed above, we generally support the principle for securing high quality east-west connectivity. However, the means of crossing Milton Road will involve a range of complex issues, which cannot be determined at this stage. The crossing solution(s) should not ultimately be compromised by concerns about short-term disruption and inconvenience. The east-west axis will be fundamental in the overall success of NEC, and the justification for internalising trips will be partly made on the basis that pedestrian and cycle connectivity across NEC will be safe and convenient (and therefore likely to be commonly used as a means of travel).

Option A is considered to be the preferred option as it provides the opportunity to create a substantial green link over the road without adversely affect the flow of traffic on Milton Road, which has existing network capacity issues. It will also limit the impact on the operation of the Milton Road during construction when compared with either Option B and C.

Option B would likely result in significant disruption to the road network during construction and would likely require the lowering or redirecting or Statutory Undertakers Utilities. Both Option B and C would result in alterations to the access junctions into the Science Park and the Site, both of which have limited access opportunities for their respective sizes.

Question 19: Should development within the North East Cambridge area be more visible from Milton Road, and provide a high quality frontage to help create a new urban character for this area?

We generally support the suggestion of making new development within NEC more visible from Milton Road and providing a high quality frontage to create a new urban character for the area. Milton Road is currently a highly car dominated environment, with a number of confusing junctions serving Cambridge Science Park and Cowley Road. However, it is noted that Milton Road acts as a key north / southbound route into and out of Cambridge, and the Milton Interchange forms part of the Strategic Road Network and connects Cambridge to the A14 (a major east to west route, which has recently been upgraded to improve capacity). Given the level of traffic using this stretch of the Milton Road to access the Strategic Road Network at this location, the potential to reduce traffic to provide a high quality new urban character for the area may be limited in the short term. Notwithstanding this, where Milton Road runs southwards the nature of the road starts to change and becomes more urban in nature, potentially becoming more conducive to active frontage and activity on the footway.

Question 20: Do you agree with proposals to include low levels of parking as part of creating a sustainable new city district focusing on non-car transport?

Yes, we generally support this principle NEC provides an opportunity to reduce levels of parking, as part of a package of transport measures including new and additional walking and cycling routes, public transport services, and car share schemes. However, we would also suggest that interim car parking strategies might need to be considered, to support 'pioneer' uses/development during transitional phases of NEC i.e. until the full package of transport infrastructure and initiatives can be fully realised. As new infrastructure/initiatives are introduced, interim car parking can be gradually phased out.

Question 21a: In order to minimise the number of private motor vehicles using Milton Road, should Cambridge Science Park as well as other existing employment areas in this area have a reduction in car parking provision from current levels?

We very much support opportunities to reduce the reliance on travel by car in and around NEC, and instead increase the ease and convenience of walking and cycling movements across sites in NEC, as this will strengthen the concept of promoting internalised trips.

Question 21b: Should this be extended to introduce the idea of a reduction with a more equitable distribution of car parking across both parts of the AAP area?

Yes, as part of a package of transport measures to encourage travel by sustainable modes of transport.

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

Yes, subject to further understanding of the requirements of businesses and the needs of residents. The North East Cambridge area could include a number of delivery/collection hubs.

Question 23: Should development within the North East Cambridge area use car barns for the storage of vehicles?

We support the idea of using car barns, as part of a wider package of parking solutions across NEC. Whilst it is recognised that private on-plot parking is unlikely to be widely encouraged, there will inevitably be demand from some residents to have access to the use of a car/secure car parking but this should be priced accordingly to the end user. Car barns provide communal access to parking, and are typically located in less convenient locations in order to discourage frequent use. As an example, if a car was needed to do a weekly shop, the resident would park outside their property to unload their car and then move the car to a car barn. Car barns can also be used by 'car clubs', so that a resident can book a car for a certain period of time but not have the long-term cost and use commitment to owning a private car. The versatility of car barns should also be recognised, as parking can be let on a temporary basis and, as trends change, can be converted into alternative uses to reduce car usage further.

Question 24: Within the North East Cambridge area green space can be provided in a number of forms including the following options. Which of the following would you support?
A - Green space within the site could be predominately provided through the introduction of a large multi-functional district scale green space. Taking inspiration from Parker's Piece in Cambridge, a new large space will provide flexible space that can be used throughout the year for a wide range of sport, recreation and leisure activities and include a sustainable drainage function. The sustainable drainage element would link into a system developed around the existing First Public Drain and the drainage system in the Science Park. The green space could be further supported by a number of smaller neighbourhood block scale open spaces dispersed across the site.
B - Green spaces within the site could be provided through a series of green spaces of a neighbourhood scale that will be distributed across the residential areas. These green spaces will also be connected to the green infrastructure network to further encourage walking and cycling. Again, these spaces will include a sustainable drainage function and link into the existing First Public Drain and the Science Park drainage system.
C - Enhanced connections and corridors within and beyond the site to improve the biodiversity and ecological value as well as capturing the essential Cambridge character of green fingers extending into urban areas. These corridors could also be focussed around the green space network and sustainable drainage and would reflect the NPPF net environmental gain requirement.
D - Green fingers to unite both sides of Milton Road and capitalise on the existing green networks.
E - Consideration of the site edges - enhancement of the existing structural edge landscape and creating new structural landscape at strategic points within and on the edge of NEC. This would also enhance the setting to the City on this important approach into the City.
F - Creation of enhanced pedestrian and cycle connectivity to Milton Country Park and the River Cam corridor.

In response to all six options listed above, we support the principle for securing high quality green infrastructure across NEC. Subject to further capacity testing and Masterplanning, on-site provision might feasibly take the form of a larger green space for the whole NEC and complemented by smaller 'neighbourhood scale' spaces and enhanced connections and corridors to off-site green infrastructure. We aren't persuaded that Parkers Piece is an appropriate comparable for the size and function of this space but do consider that the green space should draw lessons from existing green spaces in Cambridge. However, in supporting the theme of innovation at all stages of the development it will be important to consider smart solutions for the open space strategy, maximising flexibility across all areas of on-site open space. For instance, playing fields associated with on-site school provision should be available to the wider community, at times when it is not required by the school. Management and security issues will need to be carefully considered in this regard. Landscape vegetation should encourage biodiversity, whilst also performing softening/screening functions. Formal playspace should be able to accommodate multi-use activities during the day and evening and throughout the year. Green infrastructure might incorporate elements of food growing e.g. fruit trees, herbs, and vegetables, enabling free access to foods that help promote healthier lifestyles.

In terms of the suggestion of how open space will be provided (and in what format and amount), this cannot be determined at this stage of the process. A series of studies and assessments have been or are being commissioned by Cambridge City Council, which will help inform development principles and Masterplanning. Consultation will also need to be carried out with a number of interested parties, including landowners, developers, local communities and local authority bodies. Therefore, we are neither supporting nor objecting to any of the suggested options at this stage.

Question 25: As set out in this chapter there are a range of public transport, cycling and walking schemes planned which will improve access to the North East Cambridge area. What other measures should be explored to improve access to this area?

We generally support the suggested options for improving public transport, cycling and walking accessibility around NEC. The proposed Waterbeach Greenway should be directed through the Site, to create a coherent route from Waterbeach to the station. This will allow future residents of the Site to cycle to the station helping to providing a means of travel for the 'first mile / last mile' of the journey to / from the station.

A new route for a busway from the proposed Waterbeach development should be routed through the Site down to Cambridge North Station. Stops on the route could form transport interchanges linking to other bus routes and cycle routes. High quality cycle links should be implemented to connect into existing infrastructure such as the Chisholm Trail.

The route of these two transport spines through the Site will help develop a single coherent sustainable transport corridor down to the station allowing seamless interchanges between transport modes where the routes intersect with one another. The interchanges will be located within a high-quality urban environment close to high density district centres and attractive locations encouraging linked trips and improving access to the district centres by public transport.
It will important to ensure that consideration is always given to promoting access beyond the AAP boundary (as currently shown), such as recognising the education/social role that CRC plays in the west, the retail and leisure/recreational/biodiversity roles of Tesco and Milton Country Park in the north, the leisure/recreational/biodiversity role of the river and green corridors in the east, and the existing Cambridge communities in the south.

Question 26: Do you agree that the AAP should be seeking a very low share of journeys to be made by car compared to other more sustainable means like walking, cycling and public transport to and from, and within the area?

We support the concept of encouraging a greater share of non-car modes of travel for NEC, but note that it is a concept that will need to be accepted by all landowners/occupiers in the AAP boundary in order for it to be successfully implemented. This is broadly in accordance with the advice from the Ely to Cambridge Transport Study, and will be further tested in the NEC AAP Transport Assessment work (due to be commissioned).

Question 27: Do you have any comments on the highway 'trip budget' approach, and how we can reduce the need for people to travel to and within the area by car?

We support the principle of a 'trip budget' as there is limited scope for large scale engineering interventions to create more capacity on the road network. However, the trip budget must be carefully considered and tested to ensure that it is both suitable and realistic. Appropriate measures will need to be employed if the trip budget is exceeded. The monitoring process will need to be carefully considered, as various land uses across the AAP site will be allocated a share of the trip budget.

Question 28: Do you agree that car parking associated with new developments should be low, and we should take the opportunity to reduce car parking in existing developments (alongside the other measures to improve access by means other than the car)?

We generally support the concept of encouraging a greater share of non-car modes of travel for NEC. This is broadly in accordance with the advice from the Ely to Cambridge Transport Study, and will be further tested in the NEC AAP Transport Assessment work (due to be commissioned). It is recognised that many existing employment uses, such as those in Cambridge Science Park, St John's Innovation Park and Cambridge Business Park, will have authorised car parking at significantly higher levels than what is now intended for NEC. We would support the Councils working with various landowners in exploring innovative/incentivised ways of reducing car usage from those sites.

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

We support the suggestion of requiring high levels of cycle parking from new developments. This approach will be supported by the new cycling infrastructure that is planned for Cambridge, including the Chisholm Trail and Waterbeach Greenways. Cycling helps support healthy lifestyles, and is a viable means of travelling around a compact city, assuming that safe and convenient routes and secure/covered parking can be provided. New and existing workplaces can be encouraged to provide showers, changing facilities and lockers to encourage staff to cycle into work.

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

Cycling is key to achieving a mode split and demand must be met, and therefore we support the suggestion of innovative solutions to cycle parking. As part of further capacity testing, Masterplanning and detailed design, consideration will be given to innovative storage solutions (using domestic and international examples) that enables cycle parking to be integrated appropriately into the public realm. The concept of micromobility should also be embraced, with provision made for parking dockless bikes to ensure that they are not left in inconsiderate locations such as the footway.

Question 31: What additional factors should we also be considering to encourage cycling use (e.g. requiring new office buildings to include secure cycle parking, shower facilities and lockers)?

New office buildings should include covered, secure cycle storage, showers and lockers. The cycle parking should also be conveniently located at basement/ground floor level or within easy access of lifts capable of transferring bikes between levels. Where possible segregated access for cyclists should be provided to minimise the conflict with pedestrians and vehicles accessing buildings.

Question 32: How do we design and plan for a place that makes the best use of current technologies and is also future proofed to respond to changing technologies over time?

Energy strategies
We will expect development on the Site to have a very low 'in use' energy demand, through robust design of built fabric and services. This will make it easier to meet more of the scheme's energy demand from renewable and low carbon energy sources - and in some case may allow a 'net positive' energy balance to be achieved. Implications for wider energy networks should also be considered, with consideration of energy storage and demand control options at building and community level.

Form and fabric

Development within the Site will be designed, at both masterplan and building scale, to result in minimal energy use through sensitive consideration of site conditions and a robust approach to fabric performance, using passive design strategies to achieve good comfort, day-lighting and air-quality.

Building services

Developments should ensure they build on high quality design of form and fabric by specifying robust and efficient building services. If care has been taken in the design of the built fabric, it should be simpler for efficient building services to meet the needs of those who live and work in a building.

Energy generation and supply

Once the gross energy demand for the proposed development has been reduced through efficient built form and services, it will become possible to evaluate how a greater proportion of its needs can be met through renewable and low carbon energy sources.

Provision for electric charging points for vehicles should be implemented to ensure that both residents and workers have access to electric car charging points. Way-finding points and real time journey time information should be implemented across the Site to ensure people have accurate up to date travel information.

Delivery hubs should be provided on the periphery of the site to intercept large delivery vehicles from accessing the site. This will also help to consolidate deliveries and reduce the need for large vehicles to enter the Site, with smaller electric vehicles providing the final leg of the journey to the front door of the residence or workplace.

Subterranean bins should be provided on the Site to minimise space requirements for waste storage and provide a secure location for the bins.

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

It is considered unlikely that an at grade crossing can be located to link the Science Park with the station due to capacity constraints on Milton Road. A well-designed overpass for pedestrians and cyclists may provide the best option to effectively reduce severance caused by Milton Road and link the station with the Science Park. The journey from the station to the Science Park, will be the last / first mile of commuter journey and micromobility solutions such as dockless e-bikes should be provided to support the movement on this link.

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

The knowledge-based cluster around Cambridge Science Park, St John's Innovation Park, and Cambridge Business Park is internationally recognised, and the significant economic role that it offers to NEC must be fully harnessed to encourage complementary industries (Artificial Intelligence, R+D and laboratories for smaller emerging businesses that need the cluster benefits, maker-space etc) and optimise further employment opportunities. We would therefore expect a range (in terms of use and size) of employment spaces across NEC, including Science, Research & Development and Technology-related employment. However, in advocating innovation throughout NEC, policy limitations should not be imposed that unduly restrict any particular use at this stage.

Question 35: In particular, should the plan require delivery of:
A - a flexible range of unit types and sizes, including for start-ups and Small and Medium Sized Enterprises (SMEs);
B - Specialist uses like commercial laboratory space;
C - hybrid buildings capable of a mix of uses, incorporating offices and manufacturing uses.
D - shared social spaces, for example central hubs, cafes.
E - Others (please specify).

We generally support all of the suggested options at this stage, and would seek inclusion of corporate headquarters within category A. These options should equally be applied to proposals for meanwhile/worthwhile uses, in order to optimise economic development benefits and promote innovation at the earlier stages of the development process for NEC.

Question 36: Which of the following approaches should the AAP take to existing industrial uses in the North East Cambridge area?
A - seek to relocate industrial uses away from the North East Cambridge area?
NEC represents a significant and unique opportunity to create a new and innovative high-density, high quality, mixed use Quarter for Cambridge and its surrounding area. The opportunity is dependent on Housing Infrastructure Funding that will facilitate the relocation of the Water Treatment Works, and optimise the quantum of new housing across the Site. Whilst it is recognised that other, non-residential uses, will also be needed in NEC in order to promote multi-functioning mixed communities and internalised trips, capacity testing and Masterplanning will need to carefully identify what uses (and how much) will be appropriate. Whilst the prospect of utilising some of the Site for industrial use has not, at this stage, been discounted, justification for the need and location of such a use will need to be very carefully considered. A greater understanding of industrial need is therefore required, and in particular how essential it is for certain businesses to be in Cambridge. Consideration should also be given to whether existing businesses are compatible with residential neighbourhoods, as if so, there may be scope to incorporate industrial (i.e. b1c) accommodation within a mixed use development. This might, for instance, include ground floor workshops/maker spaces where noise, odour, other forms of pollution, and type of deliveries will not give rise to unacceptable living conditions for neighbouring properties. For existing businesses where there is not a demonstrable need to be in Cambridge, relocation options outside the NEC should be considered.

B - seek innovative approaches to supporting uses on site as part of a mixed use City District?
See response to A, above.

Question 37: Are there particular uses that should be retained in the area or moved elsewhere?

See response to A, above. The AAP should set out the strategy for determining the needs of individual businesses (and whether there is an operational imperative to be closely related to Cambridge, and how the relocation of existing industrial uses can be appropriately implemented..

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

The residential ambitions and opportunities in NEC (and particularly the Site) will need to be fully understood and embraced in order for the Vision and Objectives of the AAP to be realised. For the high density levels of new housing envisaged, innovation will be essential at all stages and in all forms. Traditional approaches to housing in Cambridge are unlikely to be appropriate. Housing will be made available for a much wider market than might otherwise be expected for a new settlement/strategic urban extension elsewhere in the county (e.g. Northstowe, Waterbeach, Cambourne), including that which is more aligned to smaller household sizes e.g. students, post-graduates, young professionals, and older persons looking to downsize. Where family housing is to be provided, it will require 'smarter-space' solutions to reflect the Site-wide high density approach.
A greater understanding of need and demand, market trends and viability will be needed to define housing requirements for NEC in later stages of the AAP process.

Question 39: Should the AAP seek provision for housing for essential local workers and/or specific housing provided by employers (i.e. tethered accommodation outside of any affordable housing contribution)?

Yes, see response to Question 38.

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

We generally support the suggestion of having a challenging target for the provision of affordable housing. There is a chronic shortfall of affordable housing in South Cambridgeshire and Cambridge City, and the residential growth aspirations of NEC could make a significant contribution in reducing housing shortfall. It is also important to ensure that there are a range of homes of different sizes and tenures to achieve mixed and balanced communities. However, it is also important to ensure that the policy is sufficiently flexible to address viability challenges, and takes a pragmatic approach when recognising how different types of housing are provided and thereafter managed and maintained e.g. less reliance on traditional approaches of 'pepper-potting' etc. There is a significant cost in delivering the level and type of development envisaged and it will be essential to ensure that delivery of the development can be secured on a viable basis. Consideration must also be given to exploring other means of making housing more widely accessible, such as through PRS for instance.

Question 41: Should an element of the affordable housing provision be targeted at essential local workers?

We generally support this suggestion, but a more detailed understanding of housing need and demand in the area, and indeed an understanding of what key employers in the area require, should be undertaking before developing an AAP-specific affordable housing policy.

Question 42: Should the AAP require a proportion of development to provide custom build opportunities?

We generally support this suggestion, but again a greater understanding of demand, need and viability is required. Consideration should be given to examples where successful custom-build housing has been delivered, such as Marmalade Lane, Cambridge's first co-housing community made up of 42 custom build homes.

Question 43: Should the AAP allow a proportion of purpose built HMOs and include policy controls on the clustering of HMOs?

We support the suggestion of creating more shared living and co-living housing opportunities, as these can help improve variety and access to more affordable, good quality accommodation. This type of housing typically incorporates shared services and facilities and can benefit both younger and older aged groups. However, again a greater understanding of demand, need and viability is required.

Question 44: Should the AAP include Private Rented Sector (PRS) as a potential housing option as part of a wider housing mix across the North East Cambridge area?

We generally support this suggestion, as it typically lends itself to earlier delivery, it can be part of an affordable housing mix, and may suit the needs of the adjoining employment base. Similar to HMO's, PRS development needs to be well-managed to integrate successfully. Again a greater understanding of demand, need and viability is required.

Question 45: if PRS is to be supported, what specific policy requirements should we consider putting in place to manage its provision and to ensure it contributes towards creating a mixed and sustainable community?

We would suggest that this needs to be considered in greater detail, including need and demand, management of facilities, services, and amenities should be well defined and required.

Question 46: Should PRS provide an affordable housing contribution?

Subject to viability, policy requirements will need to reflect the distinct economics of this tenure. In most cases (as in London) this is acknowledging that a form of Discounted Market Rent (capped at 80% of Open Market Rents) is most applicable, as this can be managed by a non-Registered Provider and therefore enables tenure blind blocks to be delivered by PRS operators.

Question 47: What 'clawback' mechanisms should be included to secure the value of the affordable housing to meet local needs if the homes are converted to another tenure?

Typically a profit sharing mechanism up to an agreed cap (cap to be reflective of the affordable housing contribution possible for open market sale units - i.e. the value difference between a private for sale scheme at 40% and a PRS scheme at 30%)

Question 48: What would be a suitable period to require the retention of private rented homes in that tenure and what compensation mechanisms are needed if such homes are sold into a different tenure before the end of the period?

We would suggest a period of 15 years with clawback as outlined in Questions 46 and 47. This period is proposed in the London Plan and is generally accepted by institutional investors

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

We consider that this should be agreed with each operator, and should be brief and relevant to planning matters. This could ensure all prospective tenants are offered the option of a three year tenancy.

Question 50: Should the area provide for other forms of specialist housing (including older people, students & travellers), either onsite or through seeking contributions for off-site provision?

We generally support this suggestion, but again a greater understanding of demand, need and viability is required. A comprehensive analysis of the demographic portrait of Cambridge and its surrounding environs over the next 25 years should be undertaken to assess how new policy interventions - such as NEC (intensified housing and employment uses; new housing 'products' to promote affordability and variety), new transport initiatives to improve access to employment, shopping, leisure and recreation etc, may affect demand and supply of different forms of housing for the local population catchment. In terms of 'housing mix', this might then manifest into redefining 'mainstream' housing, to expand into other groups such as students/graduates, first-time buyers, those requiring good quality rental properties, downsizers, elderly care.

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

We generally support this suggestion. This is a standard that ensures appropriate homes are delivered that meet the needs of the occupants. However, there may be some formats where exceptions may be appropriate - for example co-living formats including student and young professional accommodation, housing for 'downsizers' etc. These groups may prefer smaller homes with greater shared space and it may be appropriate to provide for this need in the context of a balanced housing offer. However, in these cases we would expect there to be clear requirements around the nature and quality of shared space. We would also encourage pilot testing (on a smaller scale) of more innovative solutions to housing, which might include other micro-living models that have not yet been used in Cambridge but have proved successful in other UK/international cities.

Question 52: Should the AAP develop space standards for new purpose built HMOs?

All new housing should meet the Technical Housing Standards and offer adequate shared spaces to not only provide adequate space in a HMOs scenario but above all provide homes that are future proofed as people's lifestyle changes and needs such as working from home also emerge. Future-proofed housing is to offer adequate space for a wide range of scenarios, not only HMOs. A specifically-developed space standards for new purpose built HMOs may prove unnecessary or irrelevant if HMOs within the AAP is then not delivered through a purpose-built type. Please see our response to Question 51.

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

We support the principle of ensuring that all homes have adequate and appropriate access to outdoor space and support the aspiration for most homes to have some private outdoor space. We would, at this stage, question whether it is realistic to expect that 100% of dwellings will have direct access to an area of private amenity space, given the quantum of development envisaged and the range of different housing typologies that will be necessary to deliver this quantum. In situations where it isn't appropriate to deliver private outdoor space, convenient access to high quality communal and public spaces would be provided. Ultimately, a flexible approach to residential amenity space must be taken, incorporating elements such as roof gardens and balconies as well as elements such as private gardens.

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

We generally support this suggestion in principle. This standard is meeting Part M of the Building Regulations, however due to the requirements of meeting a higher than normal housing number target on the Site, we require flexibility on how the standard is applied. It is important that the Cambridge Local Plan accessibility standards offers flexibility on how the standards are achieved across the many elements of the new masterplanned scheme. While designing for and incorporating accessibility standards is also accepted as a progressive way to future-proof new housing, it is important the standards do not affect the ability of the scheme to meet the density and the target housing required. Currently the Cambridge Local Plan has adopted the optional standard Part M4(2) and has also adopted M4(3) based on a percentage, which is still higher than the national standards, this may have an adverse impact on our scheme.

Question 55: Do you agree with the range of considerations that the AAP will need to have regard to in planning for new retail and town centre provision in the North East Cambridge area? Are there other important factors we should be considering?

The ambitious intentions for NEC are likely to see the creation of thousands of new homes and intensified employment opportunities forming part of new mixed, balanced and prosperous new communities. This new 'Quarter' will therefore require district and local centres to help support and sustain it. Non-residential uses will help create vitality and vibrancy to NEC.

Question 56: Should the Councils be proposing a more multi-dimensional interpretation of the role of a town centre or high street for the North East Cambridge area, where retail is a key but not solely dominant element?

We generally support this suggestion. We would highlight the importance of seeking innovative, creative and flexible solutions across the Site and this will be applied when considering how a District or Local Centre is planned and delivered. Longer term trends (national, regional and local) relating to retail and leisure uses will need to be carefully considered in arriving at a strategy that will support the long term vitality and vibrancy of NEC.

Question 57: What community facilities are particularly needed in the North East Cambridge area?

Opportunities will exist to provide access to new services and facilities for residents of NEC and existing surrounding local communities. In terms of the latter, where there are higher levels of deprivation, the cost of using new facilities will need to take account of affordability issues to ensure the cost of use is not prohibitive to those on no/low incomes.
Provision will need to be informed by the NEC Community Facilities Audit, whilst also taking account of the growth assumptions of NEC (including sizes and tenures of housing, as this will have potentially very different outcomes on need). Provision of facilities should offer flexibility and multi-functional spaces.

Question 58: It is recognised that maximising the development potential of the North East Cambridge area may require a different approach to meeting the sport and open space needs of the new community. How might this be achieved?

See our response to Question 24. Owing to the ambitious development aspirations of the Site (and NEC) it will be necessary to consider a comprehensive package of solutions (on and off-site) for open space and recreational strategy. This strategy will be complemented by the various improvements to green infrastructure provision in and beyond the AAP boundary, facilitating greater access opportunities by walking and cycling.

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

See our response to Question 24.

Question 60: Should open space provision within the North East Cambridge area seek to provide for the widest variety of everyday structured and unstructured recreational opportunities, including walking, jogging, picnics, formal and informal play, casual sports, games, dog walking and youth recreation?

We generally support this suggestion. It will be important to ensure that all spaces within the Site are fully optimised, and creative/innovative solutions should be considered to allow for flexible/multi-functional uses.

Question 61: Where specific uses are required to provide of open space as part of the development, should the AAP allow for these to be met through multiple shared use (for example school playing fields & playing pitches for the general public)?

See our response to Question 24.

Question 62: Within this overall approach, in particular, which option do you prefer in relation to carbon reduction standards for residential development?
A - a 19% improvement on 2013 Building Regulations (the current Cambridge Local Plan standard); or
B - a requirement for carbon emissions to be reduced by a further 10% through the use of on-site renewable energy (the current South Cambridgeshire Local Plan standard); or
C - a 19% improvement on 2013 Building Regulations plus an additional 10% reduction through the use of on-site renewable energy (combining the current standards in the Local Plans); or
D - consider a higher standard and develop further evidence alongside the new joint Local Plan.

At this stage we support Option D. This is a complex area of policy setting due to the current grid decarbonisation and emerging guidance from different bodies such as the UKGBC task force, and the GLA London Plan. The context of the electricity grid decarbonisation should be considered to ensure that any targets set do not create perverse outcomes in the future over the timescales of the development and should consider the appropriateness of energy efficiency targets as well as carbon targets.

The AAP should aim to be exemplar while also drawing on the most up to date emerging evidence.

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

Yes, we generally support the AAP sustainable design and construction approaches set out. However with regard to water recycling we think that while water recycling can be an important part of reducing water consumption if used inappropriately can be unsustainable. Therefore we would expect a rounded view to be taken as to when it is most appropriate to apply the highest levels of water recycling (as required by the maximum BREEAM credits for water efficiency), including an understanding of maintenance and carbon efficiency.
Question 64: Do you support the proposal for the AAP to be clear that review mechanisms should be built into any planning permissions in order to reflect changes in policy regarding sustainable design and construction standards in local and national policy? What other mechanisms could be used?

Yes we think it is important to recognise that not all future scenarios are foreseeable and that in order to avoid perverse outcomes in future it may be necessary to reappraise the policy requirements so that the most up to date and relevant standards are applied where necessary, reasonable and practicable.

It may also be advisable to follow guidance from notable charities and NGOs (e.g. UKGBC)

Question 65: Do you support the plan requiring delivery of site wide approaches to issues such as energy and water, as well as the use of BREEAM Communities International Technical Standard at the masterplanning stage?

Subject to further Masterplanning, technical assessment and feasibility testing, we generally support the approach to site wide water proposed and support the approach to innovate energy infrastructure such as smart energy grids. We support the view that infrastructure necessary for decentralised energy should be explored early on in consultation with relevant parties and that consideration should be given to a range of technologies and approaches to ensure the approach with the lowest carbon overall can be identified and supported.

We fully support the principles in BREEAM Communities and believe that while certification often brings a certainty of outcomes it does not always. The effective outcomes of applying BREEAM communities at this stage should be subject to further consideration.

Question 66: Are there additional issues we should consider in developing the approach to deliver an exemplar development?

Consideration should be given to the embodied impacts of buildings and infrastructure installed as well as opportunities to support the circular economy. Consideration should also be given to embracing and supporting innovative smart-tech and infra-tech initiatives where feasible and viable to do so.

Question 67: What approach should the AAP take to ensure delivery of a net gain in biodiversity?

In terms of the Site, owing to the on-going uses of land e.g. Water Recycling Centre, driving range, former Park and Ride site, it is considered likely that it will have limited biodiversity value. It will be necessary, at the relevant stage in the process, to carry out site specific investigations on the potential suitability of habitat for protected species, and to consider mitigation where appropriate. If the assumption is correct, it seems reasonable to believe that the Site can deliver net gains in biodiversity. Notwithstanding this, sites within NEC may be asked to consider biodiversity collectively, to show how habitat mosaics and corridors can be delivered on a more strategic basis. In this event, the AAP will need to provide greater clarity on what process is likely to be followed, and how this will be applied to individual development schemes.

Consideration will also need to be given to increasing the amount of tree canopy cover in NEC.

Consideration should be given to where biodiversity enhancements opportunities exist in nearby areas as well so that the best opportunities for linkages beyond the site boundary are identified as well as ensuring the best opportunities locally can be realised if necessary to meet the net gain requirements.

Question 68: Should the AAP require developments in the area to integrate SMART technologies from the outset?

We generally support the suggestion that NEC should seek to integrate SMART technologies from the outset. As we have previously noted, we will seek to encourage innovative, creative and adaptable solutions throughout all elements of development on the Site. It will be important to consider preparation of a digital strategy for NEC, to seek optimum speeds for broadband/fibre, opportunities to integrate SMART technology in homes, businesses and other development around NEC.

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

We support innovation throughout all elements of development on the Site (and indeed NEC). Rather than committing to any specific type of solution at this stage, it will be necessary to understand whether innovative systems used on other sites, such as North West Cambridge, can be applied on the Site.

Question 70: Do you agree that the AAP should prioritise land that can feasibly be developed early? Are there any risks associated with this proposed approach?

The obvious challenge with sites seeking early release/delivery is how they demonstrate that development will not prejudice the wider delivery aspirations of NEC. Where landowners/developers can explain how development can be carried out in a coordinated/comprehensive manner, it seems reasonable to expect that early delivery can be achieved. A coordinated/comprehensive approach must fully ensure that all development complies with s106 tariff/highways trips budgets, in an equitable manner.

As discussed later in Questions 79 and 80, we would encourage a positive policy approach be taken in supporting temporary/meanwhile uses in order to activate the Site in its earlier development phases, and to optimise economic and social benefits in the local area.

Question 71: Should the AAP include a relocation strategy in preference to leaving this to the market to resolve?

The representations of landowners and occupiers will inform the approach. It is considered that the AAP will need to identify and define a strategy for key sites/uses to be relocated, but maintain flexibility for others. Notwithstanding this the NEC has significant potential to deliver economic, social and environmental benefits, and whilst there are a relatively small number of landowners, the strategic opportunities must not be compromised by one or more parties that are unwilling to support the delivery of the NEC. Accordingly, the Councils cannot discount the possibility of using their CPO powers if required.

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

An infrastructure delivery plan should be prepared for the North East Cambridge Area to identify the infrastructure required and the costs associated with those projects, in order to inform discussions on planning obligations. It would be reasonable to expect all development within the area to contribute towards the required infrastructure, where it benefits the AAP area as a whole rather than individual sites/landownerships

Question 73: What approach do you consider the most appropriate basis on which to apportion the cost of the infrastructure requirements arising from different land uses to ensure an equitable outcome?

We consider that this should form part of a specific study that includes, inter alia, the following considerations:
*Identify the infrastructure required across the AAP area that is necessary to delivering the comprehensive vision. This might include key routes, connections, bridges / underpasses, transport, education, energy/utilities, social etc.
*Identify where these are most appropriately located to meet the AAP vision.
*Establish a cost base for these, including appropriate cost of land recognising that in some cases it would be otherwise used for residential or other development
*Establish an appropriate equalisation formula across the AAP, levied on all new development. This could be one or a combination of a tariff per m2, per net acre etc and may be varied by use class.
*Set this out in a policy / legal framework with an appropriate indexing mechanism

Question 74: How should the AAP take into account potential changes over time, both positive and negative, that might affect development viability?

We consider that this should form part of a specific study that includes, inter alia, the following considerations
*ensuring that development continues steadily over potentially a number of economic cycles - this possibility should be acknowledged and planned for at the outset
*Any viability test whereby s106 or AH requirements would be reduced would need to be carefully calibrated to ensure that infrastructure is protected.
*A review mechanism within the S106 Agreement would allow viability to be reassessed if circumstances change.

Question 75: Do you agree with the proposal to require land assembly where it can be demonstrated that this is necessary for delivering the agreed masterplan for the North East Cambridge area and/or the proper planning of development?

Yes. This does not directly affect U+I. Land assembly will help to ensure the delivery of comprehensive redevelopment of NEC.

Question 76: Should the AAP state that the Councils will consider use of their Compulsory Purchase powers? If so, should the AAP also set out the circumstances under which this would appropriate?

The NEC has significant potential to deliver economic, social and environmental benefits, and whilst there are a relatively small number of landowners, the strategic opportunities must not be compromised by one or more parties that are unwilling to support the delivery of the NEC. It therefore seems appropriate for the AAP to specify how the Councils will use their CPO powers if required, and the circumstances for doing so. This will need to include the viability and timescales of pursuing a CPO process.

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

Yes. There are a range of stakeholders and landowners involved in the development at the North East Cambridge area, and the successful delivery of NEC will require a coordinated approach. This will need to consider a range of issues including connectivity, infrastructure locations, parking/trip budget, smart-city coordination, delivery programmes, design principles, energy/utilities and waste etc.

Question 78: Do you agree with the Councils' proposed approach to dealing with planning applications made ahead of the AAP reaching a more formal stage of preparation?

Yes. It is agreed that a coordinated approach is required and decisions on applications should be made against the AAP with appropriate, equitable contributions made.

Question 79: What types of 'meanwhile uses' should the AAP support for the North East Cambridge area?

We would suggest a range of 'meanwhile uses' could be appropriate for NEC, and would not expect policy to impose any particular restriction on types of use. The emphasis should be on promoting innovation and creativity, with meanwhile uses serving to provide early foundations for the new Quarter that will emerge and subsequently replace the meanwhile uses in the coming years. Meanwhile uses could therefore provide start-up/incubator accommodation for emerging/expanding sectors, pop-up/small-scale A class uses, community space to begin community cohesion with surrounding neighbourhoods etc. A positive policy approach to obligations and planning requirements will be needed to encourage temporary/meanwhile activation, helping to avoid onerous situations that might otherwise render creative initiatives unviable.

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

It seems unnecessary to impose a limitation on the scale of a proposed 'meanwhile use', as the purpose of a meanwhile use is, fundamentally, to make optimum use of a site that will otherwise be under-utilised for many years. This can have many short-term economic and social benefits. A policy limitation may stifle innovation and creativity. It is considered likely that many of the meanwhile use proposals will require formal planning consent, which will provide the Local Planning Authority with the ability to control and enforce development that is deemed inappropriate.

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

No. A minimum period should be based on the need and timetable for the permanent development. For the most successful meanwhile initiatives a reasonable period of operation is required in order to recoup the initial capital investment.

Question 82: Should the AAP also include a requirement for 'meanwhile uses' to demonstrate how they will add vibrancy and interest and/or deliver on the wider development outcomes and vision for the North East Cambridge area?

No. 'Meanwhile' uses are temporary in nature and an approach that seeks to make efficient use of land, in a compatible manner with surrounding uses, should be encouraged.

Question 83: What negative or positive impacts might the proposed plans have on residents or visitors to Cambridge with low incomes or who have particular characteristics protected under the Equality Act 2010? (The protected characteristics are age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex, and sexual orientation.)

We strongly support the intention of the Vision for NEC and Objective 5, to ensure social and economic inclusion, and as stated in our response to Question 5, would seek the addition of the word 'culturally' within the Vision i.e. 'North East Cambridge - a socially, culturally, and economically inclusive...'

It is recognised that NEC lies within close proximity of two highly deprived wards in Cambridgeshire, and that regeneration on the scale envisaged will create significant socio-economic opportunities for a wider catchment beyond the AAP boundary. Development on the Site, for instance, will create long term employment across a multitude of sectors and skill ranges, improved connectivity around the NEC and access to new services and facilities. We support the intention of the Councils to undertake a Health Needs and Impact Assessment, across an appropriate study area for the NEC, in order to better understand the challenges and issues faced in neighbouring wards, so as to link into opportunities that will arise in NEC.

As stated within our response to Question 5 we generally support the application of local plan accessibility in the NEC. This standard is meeting Part M of the Building Regulations, however due to the requirements of meeting a higher than normal housing number target on the Site, we require flexibility on how the standard is applied. It is important that the Cambridge Local Plan accessibility standards offers flexibility on how the standards are achieved across the many elements of the new masterplanned scheme. While designing for and incorporating accessibility standards is also accepted as a progressive way to future-proof new housing, it is important the standards do not affect the ability of the scheme to meet the density and the target housing required. Currently the Cambridge Local Plan has adopted the optional standard Part M4(2) and has also adopted M4(3) based on a percentage, which is still higher than the national standards, this may have an adverse impact on our scheme.

Question 84: Do you have any other comments about the North East Cambridge area and/or AAP? Are there other issues and alternatives that the councils should consider? If you wish to make suggestions, please provide your comments.

We would encourage a specific section on education and health provision within the NEC, noting the likelihood that if on-site provision is required, it may require different formats/approaches on how such provision is made i.e. traditional forms of provision in Cambridgeshire are unlikely to be suitable in a high density urban regeneration scheme of this nature.

If off-site provision is considered to be more appropriate, comment should be given on how and where need is expected to be accommodated (for instance it may be more appropriate to extend existing or proposed schools in Cambridge, to create additional Forms of Entry, rather than have a lower number of Forms of Entry on-site that falls below the recommended minimum sizes).

Introduction

Cambridge City Council and South Cambridgeshire District Council is consulting on Issues & Options for the North East Cambridge AAP. The consultation deadline is 25th March 2019. The draft response on behalf of U+I Group PLC ('U+I') is set out below. U+I have been selected by the landowners Anglian Water and Cambridge City Council as Master Developer for land outlined in red in the accompanying Site Plan ('the Site'). It is noted that Cambridge City Council also own other land beyond the Site, which may be the subject of other representations.

The representations contained herein relate primarily to the development intentions for the Site, but also in the context of the wider AAP area (as sites within the AAP boundary are largely intrinsically linked).

Representations

Question 1: Do you agree with changing the name of the plan to the 'North East Cambridge Area Action Plan'?

It is recognised that there is a need for a collective reference for the AAP area. This will provide consistency and clearer definition as the process evolves. Whilst it is inevitable that sub-areas of the AAP will emerge with different branding names and strategies, this will have more relevance to the individual sub-area concerned, in creating identity when publicising forthcoming planning applications through to marketing/sales disposals.

Question 2: Is the proposed boundary the most appropriate one for the AAP?

Generally, we support the proposed boundary for the AAP area. We would, however, make two observations/comments.

Firstly, it seems logical to include the site of Cambridge Regional College ('CRC') within the boundary. It is noted that in paragraph 3.5 comment is made that it is not expected to undergo major change in the way other sites across NEC are. However, CRC considers itself to be 'one of the best Further Education Colleges in the country for 16-18 year old level 3 achievement and a leading apprenticeship provider, with thousands of full time students and apprentices currently in training'. The significant range of vocational courses it offers could be positively utilised to support the long-term construction process around NEC (e.g. architectural technology, mechanical engineering, electrical, carpentry, bricklaying courses and apprenticeships), and then the on-going operational phases of the different sub-areas of NEC (e.g. from courses relating to biological science for industry, laboratory technicians and computing technologies, to business and catering and hospitality). It therefore has the potential to play an important learning and development role in the future NEC area. The built form of the current campus appears to be relatively low density, with large areas of used for surface level car parking. Buildings are predominantly 2-3 storeys in height. With the transformation of NEC, recognising the different approaches to internalised trips/reduced car parking, and taller buildings, it would seem likely that the estate management of CRC might change in the future, and if so, it should be included in the AAP.

Secondly, we would comment that, owing to the nature of NEC, development is likely to be high density, optimising the use of all land to work efficiently and effectively. The strategy for on-site Public Open Space is likely to focus on qualitative provision, than quantitative, with a stronger emphasis on formal recreational and leisure space than informal open space. Access to the latter however, is likely to be facilitated through new and improved connections to the east (potentially including land to the east of the railway line north of Cambridge North Train Station, to the river) and north (potentially including land to the north of the A14, such as Land to the south of Cambridge Road, and land including/extending Milton Country Park) of NEC. We would therefore simply pose the question about whether there is a need to include within the AAP boundary additional land that could provide informal open space, biodiversity and drainage functions, which might otherwise not be achievable within the single control of the NEC boundary. It is considered that land to the north and east of the current AAP boundary would primarily be used to facilitate access to green infrastructure for NEC.

Question 3: In this chapter have we correctly identified the physical characteristics of the North East Cambridge area and its surroundings?

Generally, yes. However, we consider it might be beneficial to include more information about the composition of site areas. For instance, on the employment parks, providing details about site area, total floorspace of buildings on the park (including extant planning consents) and the range of authorised planning uses e.g. % B1a uses, %B1b uses, estimated no. of employees, audit of authorised car parking spaces, audit of public open space (estimated total hectares). This would help to inform a baseline of land use within NEC, and then contribute in developing future strategy e.g. highway trip budget, employment strategy, connectivity and green infrastructure etc.
We would also note that it would be beneficial to have mapping information available relating to the environmental constraints identified e.g. noise, air quality, odour, important habitats.
Finally, it would be beneficial to show the broader extents of key infrastructure for NEC, including the full Chisholm Trail link (connecting NEC to Cambridge City, and the south of Cambridge (Addenbrookes), committed routes for other new cycle, pedestrian and public transport in and around the City, and the proposed Greenways link to Waterbeach).

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

In general, yes. However, we note that there is no reference to Archaeology and Heritage, and would suggest that comment is given about this, even if it is considered that NEC has limited archaeological significance. In terms of heritage, whilst we believe that there are no listed buildings, conservation areas, or other notable heritage constraints within NEC, the intention for taller buildings in NEC will need to be more widely considered in respect of longer-distant views and townscape issues (historic core of Cambridge). Taller buildings may also have potential implications for Air Safeguarding Zones (consultation required with Marshall Airport and the Ministry of Defence on structures over 15m in height), and the Mullard Radio Astronomy Observatory (consultation with the University of Cambridge). We acknowledge that the issue of building heights and taller buildings is likely to be assessed as part of the on-going Landscape Character and Visual Impact Assessment that is being undertaken by Cambridge City Council (it is understood that a 'Stage 1' exercise has already been commissioned), and that the findings are then likely to inform future stages of this AAP process.

We would also suggest consideration be given to the inclusion of Green Belt boundaries around NEC. This will help provide clarity to interested parties that all land envisaged for development and associated physical infrastructure will be accommodated on non-Green Belt land. It will also help to provide reassurance that the development aspirations for NEC will not automatically lead to further development beyond the identified boundaries, unless it is deemed to be 'appropriate development' (i.e. not 'inappropriate' as defined in the National Planning Policy Framework'), or that exceptional circumstances are demonstrated in future Local Plans, or a Very Special Circumstances argument is made to support development via a planning application process. In all cases, strict mechanisms for controlling additional future development beyond NEC will apply.

Reference should also be made to the presence of UKPN's overhead power cables (132KV) that span across the AAP boundary. In terms of ensuring optimum reuse of the Site (and indeed other sites, including Cambridge Science Park), we would support a policy seeking their diversion underground.

Question 5: Do you agree with the proposed Vision for the future of the North East Cambridge area? If not, what might you change?

Yes, we support the proposed Vision for NEC. The addition of the word 'culturally' might benefit this Vision further (in the context of 'North East Cambridge - a socially, culturally, and economically inclusive....)

Question 6: Do you agree with the overarching Objectives? If not, what might you change?

Generally, we support the overarching Objectives. The addition of the words 'Natural Capital' might benefit Objective 7 further (in the context of '...connecting and improving biodiversity to achieve a Natural Capital net gain....)

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

It is noted that the Concept Plan can only be treated as indicative at this stage in the AAP process, until the outcomes of the various Supporting Studies are known (notably Landscape Character and Visual Impact Assessment, Development Capacity Study, NEC AAP Transport Assessment, NEC Development Viability Assessment, NEC Infrastructure Delivery Plan), and wider consultation with relevant interested parties (e.g. landowners, developers, local communities, local authority bodies etc) has been carried out.

We support the residential-led mixed use allocation for the Site. We support the aspiration to create high quality pedestrian, cycle and public transport connectivity across the AAP area. We support the indication that a Mixed Use District Centre will be provided on the Site though we would suggest that its optimal location can only be determined after further study and masterplanning work. There may also be a need to include an additional Mixed Use Local Centre in the northern half of the Site (subject to further Masterplanning and an assessment on accessibility). We support the intention to provide and integrate Green Infrastructure throughout the AAP boundary, but what provision is made (and how/where it will be provided) will need to be determined following further studies/assessment and Masterplanning. Further consideration will need to be given to the suggested Industrial Development Sites in the north east corner of the Site, to understand what the rationale is for proposing to relocate existing industrial land at Nuffield Road and Cowley Road, to another part of the AAP site. It is assumed that the suggestion is made on the basis that it will provide noise abatement from the A14 to the new residential elements of the Site. However, we consider that there may be other more preferable solutions for controlling noise and, in Masterplanning terms it is less desirable bringing industrial-related traffic through a predominantly residential site. In the absence of clear justification for seeking relocation of industrial uses, we cannot support the industrial element of the proposal.

We aren't yet persuaded that the proposed location and quantum of industrial use is optimal. In particular we have concerns that this is currently shown at the furthest point from strategic highway connections. We also believe that different models and formats of industrial development should be further explored, specifically whether this should be concentrated in a single location, or whether it might be incorporated within a mixed-use approach throughout the Site.

We do not necessarily agree that the Site represents the best opportunity with the overall AAP area to accommodate a significant concentration of industrial uses in a single location.

We would suggest that the Cambridge Business Park is shaded as an Opportunity for Employment Intensification.

In addition to our response for Question 2, we would suggest that the CRC land we would suggest that this land is included within the AAP boundary, and that a new shading is applied that refers to an Opportunity for Education Intensification.

Question 8: Do you agree that outside of the existing business areas, the eastern part of the North East Cambridge AAP area (i.e. the area east of Milton Road) should provide a higher density mixed use residential led area with intensified employment, relocation of existing industrial uses and other supporting uses?

Generally, we support the initial development intentions for the area east of Milton Road. It is considered that this area could accommodate a high density mixed use residential-led development following the relocation of the existing Cambridge Water Recycling Centre and other industrial uses (subject to viability and finding suitable relocation site(s)) from the Site. A comprehensive, design-led, approach across the AAP will help maximise the redevelopment potential of a significant brownfield site in a highly sustainable location.

Question 9: Should Nuffield Road Industrial Estate be redeveloped for residential mixed use development?

Yes, we agree that consideration should be given to relocating existing industrial uses on the Nuffield Road Industrial Estate, in preference for higher density residential-led mixed use redevelopment. Consideration should be given to the viability of doing so (industrial land values are currently relatively high), and where existing businesses will be relocated. An Industrial Relocation Strategy might be appropriate, in order to understand what factors are important to businesses e.g. last mile strategies and what alternative sites might be available to accommodate relocation requirements. ]

As outlined in Question 7, the suggestion to relocate industrial uses from Nuffield Road Industrial Estate to the north east corner of the Site needs to be explained and justified. At this stage we do not support the suggestion to relocate industrial uses to the north-east corner of the Site.

Question 10: Do you agree that opportunities should be explored to intensify and diversify existing business areas? If so, with what sort of uses?

Yes, we broadly support this suggestion, subject to the establishment of a robust and equitable approach to Highways Trip Budget apportionment and s106 tariff system across the wider AAP area. The Cambridge Science Park was first established on the principle of accommodating 1-2 storey, low density commercial buildings within an attractive strategic landscape/parkland setting. Whilst much of the strategic landscaping remains, latter phases of the Science Park have sought to intensify development density, with taller buildings, lower car parking provision, and limited on-plot landscaping (other than to lessen/soften the impact of new development). This approach has been complemented by the introduction of Cambridge North Station Interchange, which has significantly improved accessibility via non-car modes. The growth aspirations now anticipated for the AAP area signals a radical change in approach to new development. New residential communities will be supported by existing and intensified employment and educational opportunities, potentially providing live and work/learning opportunities within walking/cycling distance of each other. Furthermore, access to inter alia Cambridge North, the Guided Busway, and the Chisholm Trail will support accessibility to existing business areas from a much wider catchment, therefore helping to improve the means of accessing work without the need to do so by car.

Opportunities to provide a greater quantum and diversity of employment should be encouraged. This will consolidate and strengthen the concept of the Cambridge Phenomenon, by creating a greater range and quantum of high quality accommodation for new businesses, in close proximity to a critical mass of similar businesses, thereby helping to support knowledge sharing and collaboration through co-location.

In order to promote diversity of employment types, planning policy consideration might be given to encouraging a certain percentage of 'affordable employment', to support the growth of new start-up businesses that require the same close links with similar businesses but cannot afford (and do not currently need) accommodation that becomes available.

Question 11: Are there any particular land uses that should be accommodated in the North East Cambridge area?

The North East Cambridge area should support any use that demonstrably contributes to the Vision and Objectives of the AAP area.
The AAP provides a significant opportunity to create thousands of new homes in a highly sustainable location. The growth of housing in this area will be supported by the economic benefits derived from the long-established science, innovation and business parks (many of which will be intensified), that have collectively grown from the success of clustering knowledge-based industries in close proximity of one another. The housing element of the Site will improve supply and affordability of high quality new homes to the many thousands of employees on these parks, helping to reduce the number of car movements on Milton Road. New homes and jobs on the scale envisage will need to be served by a number of social, retail, community, health, education, leisure and recreation facilities,

Question 12: What uses or activities should be included within the North East Cambridge AAP area which will create a district of culture, creativity and interest that will help create a successful community where people will choose to live and work and play?

It is considered that the inclusion of schools, community facilities, retail and leisure uses, open space, and transport services, in conjunction with walking and cycling connections to neighbouring areas will provide the attributes of a successful community.

The NEC AAP must recognise the wider role it plays in creating opportunities for surrounding communities, of which two neighbouring wards - East Chesterton and Kings Hedges - currently suffer from high levels of deprivation (included in the top three of most deprived wards in Cambridgeshire). The benefits of the AAP area should extend to these areas, to create new employment, education, social, leisure and recreation, health and community opportunities. Where new facilities are introduced to areas experiencing deprivation, a key challenge for optimising use of such facilities is affordability. Free or subsidised charging mechanisms should therefore be considered when providing new facilities for instance e.g. hire of sports pitches, meeting rooms etc.

It should, however, be recognised (and indeed it is in Question 79) that the ambitious development aspirations for the Site and wider AAP area will take a number of years to comprehensively plan and deliver. Certain elements will be possible to deliver early. Notwithstanding this, there is the opportunity to introduce 'meanwhile/worthwhile' uses the area as the transition progresses. Meanwhile/worthwhile uses offer creative and innovative ways of optimising sites on a stop-gap basis, creating a temporary opportunity to capture economic and/or social benefits for the wider area in the period between the closure/or reduction of an existing site operation and the commencement of the intended new development.

Question 13: Should the AAP require developments in the North East Cambridge AAP area to apply Healthy Towns principles?

NEC will provide a considerable opportunity for creating a healthy new community, and supporting neighbouring communities, through access to high quality housing, a design approach founded on sustainable modes of travel (walkable neighbourhoods), and improved employment, shopping, health, education, leisure and recreational opportunities. We also support the intended preparation of the Health Impact and Needs Assessment for NEC, which will take account of the wider deprivation challenges faced in the neighbouring wards of East Chesterton and Kings Hedges.

Question 14: How should the AAP recognise and make best use of the existing and potential new links between the AAP area and the CRC (Cambridge Regional College)?

Please see our response to Question 2.

Question 15: Should clusters of taller buildings around areas of high accessibility including district and local centres and transport stops form part of the design-led approach to this new city district?

We strongly support the principle that the greatest development densities should be located in the areas of greatest accessibility and public amenity. This maximises the potential for sustainable travel patterns and establishes a critical weight of local demand for leisure, cultural and retail uses.

It is important to note that 'high-density' does not automatically mean 'tall' and that compact mid-rise development can often be denser than taller development, particular where the latter is compensated for by a smaller overall development footprint. Compact mid-rise also typically enables a wider range of dwelling types and external amenity space, meeting a wider range housing needs.

We favour a 'transect' based approach to masterplanning which will ensure the density, scale, typology, and uses of development are allocated across the site as a whole and within each neighbourhood in a coordinated way, following the accessibility principle described above and responding to the opportunities and constraints of the Site. This may not mean 'clusters' - it could for example mean that the highest densities are located in 'corridors' along the primary streets, and/or at edges where having denser development acts to shelter lower-scale development from adjacent visual or noise intrusion. The masterplan will be backed up by a design code that will identify/mandate appropriate typologies for achieving the requisite densities in ways that are acceptable in other respects.

In addition to accessibility and other local factors, it is important to note that the extent and location of denser development will be affected by a range of detailed studies and appraisals (including Landscape Character and Visual Impact Assessment), that will recognise - and then balance - the challenges of creating areas of higher density and taller buildings in a highly sustainable location that is, nonetheless, on the edge of Cambridge with areas of open countryside beyond. This may also militate against achieving density through height.

Question 16: Should the AAP include any or a combination of the options below to improve pedestrian and cycling connectivity through the site and to the surrounding area?

A - Create a strong east-west axis to unite Cambridge North Station with Cambridge Science Park across Milton Road. This pedestrian and cycle corridor would be integrated into the wider green infrastructure network to create a pleasant and enjoyable route for people to travel through and around the site. The route could also allow other sustainable forms of transport to connect across Milton Road.

Yes. A strong east-west axis should be included to connect the different parts and proposed uses within NEC, and to encourage movement within the site by sustainable modes of transport.

B - Improve north-south movement between the Cowley Road part of the site and Nuffield Road. Through the redevelopment of the Nuffield Road area of NEC, it will be important that new and existing residents have convenient and safe pedestrian and cycle access to the services and facilities that will be provided as part of the wider North East Cambridge area proposals.

Yes.
C - Upgrade connections to Milton Country Park by both foot and cycle. This would include improving access to the Jane Coston Bridge over the A14, the Waterbeach Greenway project including a new access under the A14 (see Transport Chapter), as well as the existing underpass along the river towpath.

Yes. It is considered that improvements to connections with Milton Country Park and with existing and proposed pedestrian and cycle routes will be important for the success of development within the AAP. It is anticipated that NEC will provide a high density residential development, to take advantage of the close proximity of employment areas and public transport services, but which might limit opportunities for large scale open space/recreation areas. Therefore, it will be important to ensure that any proposal for an underpass will maximise connectivity through the Site, capitalising on permeability and wider Green Infrastructure initiatives (e.g. Waterbeach Greenway, Chisholm Trail, improving the public realm function of the 1st Drain etc).

D - Provide another Cambridge Guided Bus stop to serve a new District Centre located to the east side of Milton Road.

We support the suggestion to improve public transport accessibility around NEC but further work should be undertaken to determine whether an additional 'guided' busway stop is required or whether a 'normal' bus service, which could feasibly use the same buses as those on the Busway, could deliver the same benefits.

E - Increase ease of movement across the sites by opening up opportunities to walk and cycle through areas where this is currently difficult, for example Cambridge Business Park and the Cambridge Science Park improving access to the Kings Hedges and East Chesterton areas as well as the City beyond.

We very much support opportunities to increase the ease and convenience of walking and cycling movements across sites in NEC, as this will strengthen the concept of promoting internalised trips and reduce the reliance on travel by car.

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

It is noted that the River Cam towpath is identified as a route within the Waterbeach Greenway project, and it would be appropriate to take the opportunity to provide a pedestrian and cycling connection from this route into NEC, subject to the availability of funding.

The high density redevelopment of NEC is unlikely to achieve the level of Public Open Space that might otherwise be required under local plan policy. The focus is instead likely to be on securing high quality, flexible-use open space on-site, and improving/providing new connections to informal open space networks to the north and east of the AAP area (including the Waterbeach Greenway). Accordingly, an appropriate means of accessing off-site Green Infrastructure for NEC will be required, and the suggestion of a pedestrian/cycle bridge would facilitate this.

Please see our responses to Questions 2 and 7.

Question 18: Which of the following options would best improve connectivity across Milton Road between Cambridge North Station and Cambridge Science Park?
A - One or more new 'green bridges' for pedestrians and cycles could be provided over Milton Road. The bridges could form part of the proposed green infrastructure strategy for NEC, creating a substantial green/ecological link(s) over the road.
B - Subject to viability and feasibility testing, Milton Road could be 'cut-in' or tunnelled below ground in order to create a pedestrian and cycle friendly environment at street level. This option would allow for significant improvements to the street which would be more pleasurable for people to walk and cycle through.
C - Milton Road could be significantly altered to rebalance the road in a way that reduces the dominance of the road, including rationalising (reducing) the number of junctions between the Guided Busway and the A14 as well as prioritising walking, cycling and public transport users.
D - Connectivity across Milton Road could be improved through other measures. We would welcome any other suggestions that would improve the east-west connectivity through the site.
E - Other ways of improving connections (please specify)

In response to all five options listed above, we generally support the principle for securing high quality east-west connectivity. However, the means of crossing Milton Road will involve a range of complex issues, which cannot be determined at this stage. The crossing solution(s) should not ultimately be compromised by concerns about short-term disruption and inconvenience. The east-west axis will be fundamental in the overall success of NEC, and the justification for internalising trips will be partly made on the basis that pedestrian and cycle connectivity across NEC will be safe and convenient (and therefore likely to be commonly used as a means of travel).

Option A is considered to be the preferred option as it provides the opportunity to create a substantial green link over the road without adversely affect the flow of traffic on Milton Road, which has existing network capacity issues. It will also limit the impact on the operation of the Milton Road during construction when compared with either Option B and C.

Option B would likely result in significant disruption to the road network during construction and would likely require the lowering or redirecting or Statutory Undertakers Utilities. Both Option B and C would result in alterations to the access junctions into the Science Park and the Site, both of which have limited access opportunities for their respective sizes.

Question 19: Should development within the North East Cambridge area be more visible from Milton Road, and provide a high quality frontage to help create a new urban character for this area?

We generally support the suggestion of making new development within NEC more visible from Milton Road and providing a high quality frontage to create a new urban character for the area. Milton Road is currently a highly car dominated environment, with a number of confusing junctions serving Cambridge Science Park and Cowley Road. However, it is noted that Milton Road acts as a key north / southbound route into and out of Cambridge, and the Milton Interchange forms part of the Strategic Road Network and connects Cambridge to the A14 (a major east to west route, which has recently been upgraded to improve capacity). Given the level of traffic using this stretch of the Milton Road to access the Strategic Road Network at this location, the potential to reduce traffic to provide a high quality new urban character for the area may be limited in the short term. Notwithstanding this, where Milton Road runs southwards the nature of the road starts to change and becomes more urban in nature, potentially becoming more conducive to active frontage and activity on the footway.

Question 20: Do you agree with proposals to include low levels of parking as part of creating a sustainable new city district focusing on non-car transport?

Yes, we generally support this principle NEC provides an opportunity to reduce levels of parking, as part of a package of transport measures including new and additional walking and cycling routes, public transport services, and car share schemes. However, we would also suggest that interim car parking strategies might need to be considered, to support 'pioneer' uses/development during transitional phases of NEC i.e. until the full package of transport infrastructure and initiatives can be fully realised. As new infrastructure/initiatives are introduced, interim car parking can be gradually phased out.

Question 21a: In order to minimise the number of private motor vehicles using Milton Road, should Cambridge Science Park as well as other existing employment areas in this area have a reduction in car parking provision from current levels?

We very much support opportunities to reduce the reliance on travel by car in and around NEC, and instead increase the ease and convenience of walking and cycling movements across sites in NEC, as this will strengthen the concept of promoting internalised trips.

Question 21b: Should this be extended to introduce the idea of a reduction with a more equitable distribution of car parking across both parts of the AAP area?

Yes, as part of a package of transport measures to encourage travel by sustainable modes of transport.

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

Yes, subject to further understanding of the requirements of businesses and the needs of residents. The North East Cambridge area could include a number of delivery/collection hubs.

Question 23: Should development within the North East Cambridge area use car barns for the storage of vehicles?

We support the idea of using car barns, as part of a wider package of parking solutions across NEC. Whilst it is recognised that private on-plot parking is unlikely to be widely encouraged, there will inevitably be demand from some residents to have access to the use of a car/secure car parking but this should be priced accordingly to the end user. Car barns provide communal access to parking, and are typically located in less convenient locations in order to discourage frequent use. As an example, if a car was needed to do a weekly shop, the resident would park outside their property to unload their car and then move the car to a car barn. Car barns can also be used by 'car clubs', so that a resident can book a car for a certain period of time but not have the long-term cost and use commitment to owning a private car. The versatility of car barns should also be recognised, as parking can be let on a temporary basis and, as trends change, can be converted into alternative uses to reduce car usage further.

Question 24: Within the North East Cambridge area green space can be provided in a number of forms including the following options. Which of the following would you support?
A - Green space within the site could be predominately provided through the introduction of a large multi-functional district scale green space. Taking inspiration from Parker's Piece in Cambridge, a new large space will provide flexible space that can be used throughout the year for a wide range of sport, recreation and leisure activities and include a sustainable drainage function. The sustainable drainage element would link into a system developed around the existing First Public Drain and the drainage system in the Science Park. The green space could be further supported by a number of smaller neighbourhood block scale open spaces dispersed across the site.
B - Green spaces within the site could be provided through a series of green spaces of a neighbourhood scale that will be distributed across the residential areas. These green spaces will also be connected to the green infrastructure network to further encourage walking and cycling. Again, these spaces will include a sustainable drainage function and link into the existing First Public Drain and the Science Park drainage system.
C - Enhanced connections and corridors within and beyond the site to improve the biodiversity and ecological value as well as capturing the essential Cambridge character of green fingers extending into urban areas. These corridors could also be focussed around the green space network and sustainable drainage and would reflect the NPPF net environmental gain requirement.
D - Green fingers to unite both sides of Milton Road and capitalise on the existing green networks.
E - Consideration of the site edges - enhancement of the existing structural edge landscape and creating new structural landscape at strategic points within and on the edge of NEC. This would also enhance the setting to the City on this important approach into the City.
F - Creation of enhanced pedestrian and cycle connectivity to Milton Country Park and the River Cam corridor.

In response to all six options listed above, we support the principle for securing high quality green infrastructure across NEC. Subject to further capacity testing and Masterplanning, on-site provision might feasibly take the form of a larger green space for the whole NEC and complemented by smaller 'neighbourhood scale' spaces and enhanced connections and corridors to off-site green infrastructure. We aren't persuaded that Parkers Piece is an appropriate comparable for the size and function of this space but do consider that the green space should draw lessons from existing green spaces in Cambridge. However, in supporting the theme of innovation at all stages of the development it will be important to consider smart solutions for the open space strategy, maximising flexibility across all areas of on-site open space. For instance, playing fields associated with on-site school provision should be available to the wider community, at times when it is not required by the school. Management and security issues will need to be carefully considered in this regard. Landscape vegetation should encourage biodiversity, whilst also performing softening/screening functions. Formal playspace should be able to accommodate multi-use activities during the day and evening and throughout the year. Green infrastructure might incorporate elements of food growing e.g. fruit trees, herbs, and vegetables, enabling free access to foods that help promote healthier lifestyles.

In terms of the suggestion of how open space will be provided (and in what format and amount), this cannot be determined at this stage of the process. A series of studies and assessments have been or are being commissioned by Cambridge City Council, which will help inform development principles and Masterplanning. Consultation will also need to be carried out with a number of interested parties, including landowners, developers, local communities and local authority bodies. Therefore, we are neither supporting nor objecting to any of the suggested options at this stage.

Question 25: As set out in this chapter there are a range of public transport, cycling and walking schemes planned which will improve access to the North East Cambridge area. What other measures should be explored to improve access to this area?

We generally support the suggested options for improving public transport, cycling and walking accessibility around NEC. The proposed Waterbeach Greenway should be directed through the Site, to create a coherent route from Waterbeach to the station. This will allow future residents of the Site to cycle to the station helping to providing a means of travel for the 'first mile / last mile' of the journey to / from the station.

A new route for a busway from the proposed Waterbeach development should be routed through the Site down to Cambridge North Station. Stops on the route could form transport interchanges linking to other bus routes and cycle routes. High quality cycle links should be implemented to connect into existing infrastructure such as the Chisholm Trail.

The route of these two transport spines through the Site will help develop a single coherent sustainable transport corridor down to the station allowing seamless interchanges between transport modes where the routes intersect with one another. The interchanges will be located within a high-quality urban environment close to high density district centres and attractive locations encouraging linked trips and improving access to the district centres by public transport.
It will important to ensure that consideration is always given to promoting access beyond the AAP boundary (as currently shown), such as recognising the education/social role that CRC plays in the west, the retail and leisure/recreational/biodiversity roles of Tesco and Milton Country Park in the north, the leisure/recreational/biodiversity role of the river and green corridors in the east, and the existing Cambridge communities in the south.

Question 26: Do you agree that the AAP should be seeking a very low share of journeys to be made by car compared to other more sustainable means like walking, cycling and public transport to and from, and within the area?

We support the concept of encouraging a greater share of non-car modes of travel for NEC, but note that it is a concept that will need to be accepted by all landowners/occupiers in the AAP boundary in order for it to be successfully implemented. This is broadly in accordance with the advice from the Ely to Cambridge Transport Study, and will be further tested in the NEC AAP Transport Assessment work (due to be commissioned).

Question 27: Do you have any comments on the highway 'trip budget' approach, and how we can reduce the need for people to travel to and within the area by car?

We support the principle of a 'trip budget' as there is limited scope for large scale engineering interventions to create more capacity on the road network. However, the trip budget must be carefully considered and tested to ensure that it is both suitable and realistic. Appropriate measures will need to be employed if the trip budget is exceeded. The monitoring process will need to be carefully considered, as various land uses across the AAP site will be allocated a share of the trip budget.

Question 28: Do you agree that car parking associated with new developments should be low, and we should take the opportunity to reduce car parking in existing developments (alongside the other measures to improve access by means other than the car)?

We generally support the concept of encouraging a greater share of non-car modes of travel for NEC. This is broadly in accordance with the advice from the Ely to Cambridge Transport Study, and will be further tested in the NEC AAP Transport Assessment work (due to be commissioned). It is recognised that many existing employment uses, such as those in Cambridge Science Park, St John's Innovation Park and Cambridge Business Park, will have authorised car parking at significantly higher levels than what is now intended for NEC. We would support the Councils working with various landowners in exploring innovative/incentivised ways of reducing car usage from those sites.

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

We support the suggestion of requiring high levels of cycle parking from new developments. This approach will be supported by the new cycling infrastructure that is planned for Cambridge, including the Chisholm Trail and Waterbeach Greenways. Cycling helps support healthy lifestyles, and is a viable means of travelling around a compact city, assuming that safe and convenient routes and secure/covered parking can be provided. New and existing workplaces can be encouraged to provide showers, changing facilities and lockers to encourage staff to cycle into work.

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

Cycling is key to achieving a mode split and demand must be met, and therefore we support the suggestion of innovative solutions to cycle parking. As part of further capacity testing, Masterplanning and detailed design, consideration will be given to innovative storage solutions (using domestic and international examples) that enables cycle parking to be integrated appropriately into the public realm. The concept of micromobility should also be embraced, with provision made for parking dockless bikes to ensure that they are not left in inconsiderate locations such as the footway.

Question 31: What additional factors should we also be considering to encourage cycling use (e.g. requiring new office buildings to include secure cycle parking, shower facilities and lockers)?

New office buildings should include covered, secure cycle storage, showers and lockers. The cycle parking should also be conveniently located at basement/ground floor level or within easy access of lifts capable of transferring bikes between levels. Where possible segregated access for cyclists should be provided to minimise the conflict with pedestrians and vehicles accessing buildings.

Question 32: How do we design and plan for a place that makes the best use of current technologies and is also future proofed to respond to changing technologies over time?

Energy strategies
We will expect development on the Site to have a very low 'in use' energy demand, through robust design of built fabric and services. This will make it easier to meet more of the scheme's energy demand from renewable and low carbon energy sources - and in some case may allow a 'net positive' energy balance to be achieved. Implications for wider energy networks should also be considered, with consideration of energy storage and demand control options at building and community level.

Form and fabric

Development within the Site will be designed, at both masterplan and building scale, to result in minimal energy use through sensitive consideration of site conditions and a robust approach to fabric performance, using passive design strategies to achieve good comfort, day-lighting and air-quality.

Building services

Developments should ensure they build on high quality design of form and fabric by specifying robust and efficient building services. If care has been taken in the design of the built fabric, it should be simpler for efficient building services to meet the needs of those who live and work in a building.

Energy generation and supply

Once the gross energy demand for the proposed development has been reduced through efficient built form and services, it will become possible to evaluate how a greater proportion of its needs can be met through renewable and low carbon energy sources.

Provision for electric charging points for vehicles should be implemented to ensure that both residents and workers have access to electric car charging points. Way-finding points and real time journey time information should be implemented across the Site to ensure people have accurate up to date travel information.

Delivery hubs should be provided on the periphery of the site to intercept large delivery vehicles from accessing the site. This will also help to consolidate deliveries and reduce the need for large vehicles to enter the Site, with smaller electric vehicles providing the final leg of the journey to the front door of the residence or workplace.

Subterranean bins should be provided on the Site to minimise space requirements for waste storage and provide a secure location for the bins.

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

It is considered unlikely that an at grade crossing can be located to link the Science Park with the station due to capacity constraints on Milton Road. A well-designed overpass for pedestrians and cyclists may provide the best option to effectively reduce severance caused by Milton Road and link the station with the Science Park. The journey from the station to the Science Park, will be the last / first mile of commuter journey and micromobility solutions such as dockless e-bikes should be provided to support the movement on this link.

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

The knowledge-based cluster around Cambridge Science Park, St John's Innovation Park, and Cambridge Business Park is internationally recognised, and the significant economic role that it offers to NEC must be fully harnessed to encourage complementary industries (Artificial Intelligence, R+D and laboratories for smaller emerging businesses that need the cluster benefits, maker-space etc) and optimise further employment opportunities. We would therefore expect a range (in terms of use and size) of employment spaces across NEC, including Science, Research & Development and Technology-related employment. However, in advocating innovation throughout NEC, policy limitations should not be imposed that unduly restrict any particular use at this stage.

Question 35: In particular, should the plan require delivery of:
A - a flexible range of unit types and sizes, including for start-ups and Small and Medium Sized Enterprises (SMEs);
B - Specialist uses like commercial laboratory space;
C - hybrid buildings capable of a mix of uses, incorporating offices and manufacturing uses.
D - shared social spaces, for example central hubs, cafes.
E - Others (please specify).

We generally support all of the suggested options at this stage, and would seek inclusion of corporate headquarters within category A. These options should equally be applied to proposals for meanwhile/worthwhile uses, in order to optimise economic development benefits and promote innovation at the earlier stages of the development process for NEC.

Question 36: Which of the following approaches should the AAP take to existing industrial uses in the North East Cambridge area?
A - seek to relocate industrial uses away from the North East Cambridge area?
NEC represents a significant and unique opportunity to create a new and innovative high-density, high quality, mixed use Quarter for Cambridge and its surrounding area. The opportunity is dependent on Housing Infrastructure Funding that will facilitate the relocation of the Water Treatment Works, and optimise the quantum of new housing across the Site. Whilst it is recognised that other, non-residential uses, will also be needed in NEC in order to promote multi-functioning mixed communities and internalised trips, capacity testing and Masterplanning will need to carefully identify what uses (and how much) will be appropriate. Whilst the prospect of utilising some of the Site for industrial use has not, at this stage, been discounted, justification for the need and location of such a use will need to be very carefully considered. A greater understanding of industrial need is therefore required, and in particular how essential it is for certain businesses to be in Cambridge. Consideration should also be given to whether existing businesses are compatible with residential neighbourhoods, as if so, there may be scope to incorporate industrial (i.e. b1c) accommodation within a mixed use development. This might, for instance, include ground floor workshops/maker spaces where noise, odour, other forms of pollution, and type of deliveries will not give rise to unacceptable living conditions for neighbouring properties. For existing businesses where there is not a demonstrable need to be in Cambridge, relocation options outside the NEC should be considered.

B - seek innovative approaches to supporting uses on site as part of a mixed use City District?
See response to A, above.

Question 37: Are there particular uses that should be retained in the area or moved elsewhere?

See response to A, above. The AAP should set out the strategy for determining the needs of individual businesses (and whether there is an operational imperative to be closely related to Cambridge, and how the relocation of existing industrial uses can be appropriately implemented..

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

The residential ambitions and opportunities in NEC (and particularly the Site) will need to be fully understood and embraced in order for the Vision and Objectives of the AAP to be realised. For the high density levels of new housing envisaged, innovation will be essential at all stages and in all forms. Traditional approaches to housing in Cambridge are unlikely to be appropriate. Housing will be made available for a much wider market than might otherwise be expected for a new settlement/strategic urban extension elsewhere in the county (e.g. Northstowe, Waterbeach, Cambourne), including that which is more aligned to smaller household sizes e.g. students, post-graduates, young professionals, and older persons looking to downsize. Where family housing is to be provided, it will require 'smarter-space' solutions to reflect the Site-wide high density approach.
A greater understanding of need and demand, market trends and viability will be needed to define housing requirements for NEC in later stages of the AAP process.

Question 39: Should the AAP seek provision for housing for essential local workers and/or specific housing provided by employers (i.e. tethered accommodation outside of any affordable housing contribution)?

Yes, see response to Question 38.

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

We generally support the suggestion of having a challenging target for the provision of affordable housing. There is a chronic shortfall of affordable housing in South Cambridgeshire and Cambridge City, and the residential growth aspirations of NEC could make a significant contribution in reducing housing shortfall. It is also important to ensure that there are a range of homes of different sizes and tenures to achieve mixed and balanced communities. However, it is also important to ensure that the policy is sufficiently flexible to address viability challenges, and takes a pragmatic approach when recognising how different types of housing are provided and thereafter managed and maintained e.g. less reliance on traditional approaches of 'pepper-potting' etc. There is a significant cost in delivering the level and type of development envisaged and it will be essential to ensure that delivery of the development can be secured on a viable basis. Consideration must also be given to exploring other means of making housing more widely accessible, such as through PRS for instance.

Question 41: Should an element of the affordable housing provision be targeted at essential local workers?

We generally support this suggestion, but a more detailed understanding of housing need and demand in the area, and indeed an understanding of what key employers in the area require, should be undertaking before developing an AAP-specific affordable housing policy.

Question 42: Should the AAP require a proportion of development to provide custom build opportunities?

We generally support this suggestion, but again a greater understanding of demand, need and viability is required. Consideration should be given to examples where successful custom-build housing has been delivered, such as Marmalade Lane, Cambridge's first co-housing community made up of 42 custom build homes.

Question 43: Should the AAP allow a proportion of purpose built HMOs and include policy controls on the clustering of HMOs?

We support the suggestion of creating more shared living and co-living housing opportunities, as these can help improve variety and access to more affordable, good quality accommodation. This type of housing typically incorporates shared services and facilities and can benefit both younger and older aged groups. However, again a greater understanding of demand, need and viability is required.

Question 44: Should the AAP include Private Rented Sector (PRS) as a potential housing option as part of a wider housing mix across the North East Cambridge area?

We generally support this suggestion, as it typically lends itself to earlier delivery, it can be part of an affordable housing mix, and may suit the needs of the adjoining employment base. Similar to HMO's, PRS development needs to be well-managed to integrate successfully. Again a greater understanding of demand, need and viability is required.

Question 45: if PRS is to be supported, what specific policy requirements should we consider putting in place to manage its provision and to ensure it contributes towards creating a mixed and sustainable community?

We would suggest that this needs to be considered in greater detail, including need and demand, management of facilities, services, and amenities should be well defined and required.

Question 46: Should PRS provide an affordable housing contribution?

Subject to viability, policy requirements will need to reflect the distinct economics of this tenure. In most cases (as in London) this is acknowledging that a form of Discounted Market Rent (capped at 80% of Open Market Rents) is most applicable, as this can be managed by a non-Registered Provider and therefore enables tenure blind blocks to be delivered by PRS operators.

Question 47: What 'clawback' mechanisms should be included to secure the value of the affordable housing to meet local needs if the homes are converted to another tenure?

Typically a profit sharing mechanism up to an agreed cap (cap to be reflective of the affordable housing contribution possible for open market sale units - i.e. the value difference between a private for sale scheme at 40% and a PRS scheme at 30%)

Question 48: What would be a suitable period to require the retention of private rented homes in that tenure and what compensation mechanisms are needed if such homes are sold into a different tenure before the end of the period?

We would suggest a period of 15 years with clawback as outlined in Questions 46 and 47. This period is proposed in the London Plan and is generally accepted by institutional investors

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

We consider that this should be agreed with each operator, and should be brief and relevant to planning matters. This could ensure all prospective tenants are offered the option of a three year tenancy.

Question 50: Should the area provide for other forms of specialist housing (including older people, students & travellers), either onsite or through seeking contributions for off-site provision?

We generally support this suggestion, but again a greater understanding of demand, need and viability is required. A comprehensive analysis of the demographic portrait of Cambridge and its surrounding environs over the next 25 years should be undertaken to assess how new policy interventions - such as NEC (intensified housing and employment uses; new housing 'products' to promote affordability and variety), new transport initiatives to improve access to employment, shopping, leisure and recreation etc, may affect demand and supply of different forms of housing for the local population catchment. In terms of 'housing mix', this might then manifest into redefining 'mainstream' housing, to expand into other groups such as students/graduates, first-time buyers, those requiring good quality rental properties, downsizers, elderly care.

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

We generally support this suggestion. This is a standard that ensures appropriate homes are delivered that meet the needs of the occupants. However, there may be some formats where exceptions may be appropriate - for example co-living formats including student and young professional accommodation, housing for 'downsizers' etc. These groups may prefer smaller homes with greater shared space and it may be appropriate to provide for this need in the context of a balanced housing offer. However, in these cases we would expect there to be clear requirements around the nature and quality of shared space. We would also encourage pilot testing (on a smaller scale) of more innovative solutions to housing, which might include other micro-living models that have not yet been used in Cambridge but have proved successful in other UK/international cities.

Question 52: Should the AAP develop space standards for new purpose built HMOs?

All new housing should meet the Technical Housing Standards and offer adequate shared spaces to not only provide adequate space in a HMOs scenario but above all provide homes that are future proofed as people's lifestyle changes and needs such as working from home also emerge. Future-proofed housing is to offer adequate space for a wide range of scenarios, not only HMOs. A specifically-developed space standards for new purpose built HMOs may prove unnecessary or irrelevant if HMOs within the AAP is then not delivered through a purpose-built type. Please see our response to Question 51.

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

We support the principle of ensuring that all homes have adequate and appropriate access to outdoor space and support the aspiration for most homes to have some private outdoor space. We would, at this stage, question whether it is realistic to expect that 100% of dwellings will have direct access to an area of private amenity space, given the quantum of development envisaged and the range of different housing typologies that will be necessary to deliver this quantum. In situations where it isn't appropriate to deliver private outdoor space, convenient access to high quality communal and public spaces would be provided. Ultimately, a flexible approach to residential amenity space must be taken, incorporating elements such as roof gardens and balconies as well as elements such as private gardens.

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

We generally support this suggestion in principle. This standard is meeting Part M of the Building Regulations, however due to the requirements of meeting a higher than normal housing number target on the Site, we require flexibility on how the standard is applied. It is important that the Cambridge Local Plan accessibility standards offers flexibility on how the standards are achieved across the many elements of the new masterplanned scheme. While designing for and incorporating accessibility standards is also accepted as a progressive way to future-proof new housing, it is important the standards do not affect the ability of the scheme to meet the density and the target housing required. Currently the Cambridge Local Plan has adopted the optional standard Part M4(2) and has also adopted M4(3) based on a percentage, which is still higher than the national standards, this may have an adverse impact on our scheme.

Question 55: Do you agree with the range of considerations that the AAP will need to have regard to in planning for new retail and town centre provision in the North East Cambridge area? Are there other important factors we should be considering?

The ambitious intentions for NEC are likely to see the creation of thousands of new homes and intensified employment opportunities forming part of new mixed, balanced and prosperous new communities. This new 'Quarter' will therefore require district and local centres to help support and sustain it. Non-residential uses will help create vitality and vibrancy to NEC.

Question 56: Should the Councils be proposing a more multi-dimensional interpretation of the role of a town centre or high street for the North East Cambridge area, where retail is a key but not solely dominant element?

We generally support this suggestion. We would highlight the importance of seeking innovative, creative and flexible solutions across the Site and this will be applied when considering how a District or Local Centre is planned and delivered. Longer term trends (national, regional and local) relating to retail and leisure uses will need to be carefully considered in arriving at a strategy that will support the long term vitality and vibrancy of NEC.

Question 57: What community facilities are particularly needed in the North East Cambridge area?

Opportunities will exist to provide access to new services and facilities for residents of NEC and existing surrounding local communities. In terms of the latter, where there are higher levels of deprivation, the cost of using new facilities will need to take account of affordability issues to ensure the cost of use is not prohibitive to those on no/low incomes.
Provision will need to be informed by the NEC Community Facilities Audit, whilst also taking account of the growth assumptions of NEC (including sizes and tenures of housing, as this will have potentially very different outcomes on need). Provision of facilities should offer flexibility and multi-functional spaces.

Question 58: It is recognised that maximising the development potential of the North East Cambridge area may require a different approach to meeting the sport and open space needs of the new community. How might this be achieved?

See our response to Question 24. Owing to the ambitious development aspirations of the Site (and NEC) it will be necessary to consider a comprehensive package of solutions (on and off-site) for open space and recreational strategy. This strategy will be complemented by the various improvements to green infrastructure provision in and beyond the AAP boundary, facilitating greater access opportunities by walking and cycling.

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

See our response to Question 24.

Question 60: Should open space provision within the North East Cambridge area seek to provide for the widest variety of everyday structured and unstructured recreational opportunities, including walking, jogging, picnics, formal and informal play, casual sports, games, dog walking and youth recreation?

We generally support this suggestion. It will be important to ensure that all spaces within the Site are fully optimised, and creative/innovative solutions should be considered to allow for flexible/multi-functional uses.

Question 61: Where specific uses are required to provide of open space as part of the development, should the AAP allow for these to be met through multiple shared use (for example school playing fields & playing pitches for the general public)?

See our response to Question 24.

Question 62: Within this overall approach, in particular, which option do you prefer in relation to carbon reduction standards for residential development?
A - a 19% improvement on 2013 Building Regulations (the current Cambridge Local Plan standard); or
B - a requirement for carbon emissions to be reduced by a further 10% through the use of on-site renewable energy (the current South Cambridgeshire Local Plan standard); or
C - a 19% improvement on 2013 Building Regulations plus an additional 10% reduction through the use of on-site renewable energy (combining the current standards in the Local Plans); or
D - consider a higher standard and develop further evidence alongside the new joint Local Plan.

At this stage we support Option D. This is a complex area of policy setting due to the current grid decarbonisation and emerging guidance from different bodies such as the UKGBC task force, and the GLA London Plan. The context of the electricity grid decarbonisation should be considered to ensure that any targets set do not create perverse outcomes in the future over the timescales of the development and should consider the appropriateness of energy efficiency targets as well as carbon targets.

The AAP should aim to be exemplar while also drawing on the most up to date emerging evidence.

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

Yes, we generally support the AAP sustainable design and construction approaches set out. However with regard to water recycling we think that while water recycling can be an important part of reducing water consumption if used inappropriately can be unsustainable. Therefore we would expect a rounded view to be taken as to when it is most appropriate to apply the highest levels of water recycling (as required by the maximum BREEAM credits for water efficiency), including an understanding of maintenance and carbon efficiency.
Question 64: Do you support the proposal for the AAP to be clear that review mechanisms should be built into any planning permissions in order to reflect changes in policy regarding sustainable design and construction standards in local and national policy? What other mechanisms could be used?

Yes we think it is important to recognise that not all future scenarios are foreseeable and that in order to avoid perverse outcomes in future it may be necessary to reappraise the policy requirements so that the most up to date and relevant standards are applied where necessary, reasonable and practicable.

It may also be advisable to follow guidance from notable charities and NGOs (e.g. UKGBC)

Question 65: Do you support the plan requiring delivery of site wide approaches to issues such as energy and water, as well as the use of BREEAM Communities International Technical Standard at the masterplanning stage?

Subject to further Masterplanning, technical assessment and feasibility testing, we generally support the approach to site wide water proposed and support the approach to innovate energy infrastructure such as smart energy grids. We support the view that infrastructure necessary for decentralised energy should be explored early on in consultation with relevant parties and that consideration should be given to a range of technologies and approaches to ensure the approach with the lowest carbon overall can be identified and supported.

We fully support the principles in BREEAM Communities and believe that while certification often brings a certainty of outcomes it does not always. The effective outcomes of applying BREEAM communities at this stage should be subject to further consideration.

Question 66: Are there additional issues we should consider in developing the approach to deliver an exemplar development?

Consideration should be given to the embodied impacts of buildings and infrastructure installed as well as opportunities to support the circular economy. Consideration should also be given to embracing and supporting innovative smart-tech and infra-tech initiatives where feasible and viable to do so.

Question 67: What approach should the AAP take to ensure delivery of a net gain in biodiversity?

In terms of the Site, owing to the on-going uses of land e.g. Water Recycling Centre, driving range, former Park and Ride site, it is considered likely that it will have limited biodiversity value. It will be necessary, at the relevant stage in the process, to carry out site specific investigations on the potential suitability of habitat for protected species, and to consider mitigation where appropriate. If the assumption is correct, it seems reasonable to believe that the Site can deliver net gains in biodiversity. Notwithstanding this, sites within NEC may be asked to consider biodiversity collectively, to show how habitat mosaics and corridors can be delivered on a more strategic basis. In this event, the AAP will need to provide greater clarity on what process is likely to be followed, and how this will be applied to individual development schemes.

Consideration will also need to be given to increasing the amount of tree canopy cover in NEC.

Consideration should be given to where biodiversity enhancements opportunities exist in nearby areas as well so that the best opportunities for linkages beyond the site boundary are identified as well as ensuring the best opportunities locally can be realised if necessary to meet the net gain requirements.

Question 68: Should the AAP require developments in the area to integrate SMART technologies from the outset?

We generally support the suggestion that NEC should seek to integrate SMART technologies from the outset. As we have previously noted, we will seek to encourage innovative, creative and adaptable solutions throughout all elements of development on the Site. It will be important to consider preparation of a digital strategy for NEC, to seek optimum speeds for broadband/fibre, opportunities to integrate SMART technology in homes, businesses and other development around NEC.

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

We support innovation throughout all elements of development on the Site (and indeed NEC). Rather than committing to any specific type of solution at this stage, it will be necessary to understand whether innovative systems used on other sites, such as North West Cambridge, can be applied on the Site.

Question 70: Do you agree that the AAP should prioritise land that can feasibly be developed early? Are there any risks associated with this proposed approach?

The obvious challenge with sites seeking early release/delivery is how they demonstrate that development will not prejudice the wider delivery aspirations of NEC. Where landowners/developers can explain how development can be carried out in a coordinated/comprehensive manner, it seems reasonable to expect that early delivery can be achieved. A coordinated/comprehensive approach must fully ensure that all development complies with s106 tariff/highways trips budgets, in an equitable manner.

As discussed later in Questions 79 and 80, we would encourage a positive policy approach be taken in supporting temporary/meanwhile uses in order to activate the Site in its earlier development phases, and to optimise economic and social benefits in the local area.

Question 71: Should the AAP include a relocation strategy in preference to leaving this to the market to resolve?

The representations of landowners and occupiers will inform the approach. It is considered that the AAP will need to identify and define a strategy for key sites/uses to be relocated, but maintain flexibility for others. Notwithstanding this the NEC has significant potential to deliver economic, social and environmental benefits, and whilst there are a relatively small number of landowners, the strategic opportunities must not be compromised by one or more parties that are unwilling to support the delivery of the NEC. Accordingly, the Councils cannot discount the possibility of using their CPO powers if required.

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

An infrastructure delivery plan should be prepared for the North East Cambridge Area to identify the infrastructure required and the costs associated with those projects, in order to inform discussions on planning obligations. It would be reasonable to expect all development within the area to contribute towards the required infrastructure, where it benefits the AAP area as a whole rather than individual sites/landownerships

Question 73: What approach do you consider the most appropriate basis on which to apportion the cost of the infrastructure requirements arising from different land uses to ensure an equitable outcome?

We consider that this should form part of a specific study that includes, inter alia, the following considerations:
*Identify the infrastructure required across the AAP area that is necessary to delivering the comprehensive vision. This might include key routes, connections, bridges / underpasses, transport, education, energy/utilities, social etc.
*Identify where these are most appropriately located to meet the AAP vision.
*Establish a cost base for these, including appropriate cost of land recognising that in some cases it would be otherwise used for residential or other development
*Establish an appropriate equalisation formula across the AAP, levied on all new development. This could be one or a combination of a tariff per m2, per net acre etc and may be varied by use class.
*Set this out in a policy / legal framework with an appropriate indexing mechanism

Question 74: How should the AAP take into account potential changes over time, both positive and negative, that might affect development viability?

We consider that this should form part of a specific study that includes, inter alia, the following considerations
*ensuring that development continues steadily over potentially a number of economic cycles - this possibility should be acknowledged and planned for at the outset
*Any viability test whereby s106 or AH requirements would be reduced would need to be carefully calibrated to ensure that infrastructure is protected.
*A review mechanism within the S106 Agreement would allow viability to be reassessed if circumstances change.

Question 75: Do you agree with the proposal to require land assembly where it can be demonstrated that this is necessary for delivering the agreed masterplan for the North East Cambridge area and/or the proper planning of development?

Yes. This does not directly affect U+I. Land assembly will help to ensure the delivery of comprehensive redevelopment of NEC.

Question 76: Should the AAP state that the Councils will consider use of their Compulsory Purchase powers? If so, should the AAP also set out the circumstances under which this would appropriate?

The NEC has significant potential to deliver economic, social and environmental benefits, and whilst there are a relatively small number of landowners, the strategic opportunities must not be compromised by one or more parties that are unwilling to support the delivery of the NEC. It therefore seems appropriate for the AAP to specify how the Councils will use their CPO powers if required, and the circumstances for doing so. This will need to include the viability and timescales of pursuing a CPO process.

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

Yes. There are a range of stakeholders and landowners involved in the development at the North East Cambridge area, and the successful delivery of NEC will require a coordinated approach. This will need to consider a range of issues including connectivity, infrastructure locations, parking/trip budget, smart-city coordination, delivery programmes, design principles, energy/utilities and waste etc.

Question 78: Do you agree with the Councils' proposed approach to dealing with planning applications made ahead of the AAP reaching a more formal stage of preparation?

Yes. It is agreed that a coordinated approach is required and decisions on applications should be made against the AAP with appropriate, equitable contributions made.

Question 79: What types of 'meanwhile uses' should the AAP support for the North East Cambridge area?

We would suggest a range of 'meanwhile uses' could be appropriate for NEC, and would not expect policy to impose any particular restriction on types of use. The emphasis should be on promoting innovation and creativity, with meanwhile uses serving to provide early foundations for the new Quarter that will emerge and subsequently replace the meanwhile uses in the coming years. Meanwhile uses could therefore provide start-up/incubator accommodation for emerging/expanding sectors, pop-up/small-scale A class uses, community space to begin community cohesion with surrounding neighbourhoods etc. A positive policy approach to obligations and planning requirements will be needed to encourage temporary/meanwhile activation, helping to avoid onerous situations that might otherwise render creative initiatives unviable.

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

It seems unnecessary to impose a limitation on the scale of a proposed 'meanwhile use', as the purpose of a meanwhile use is, fundamentally, to make optimum use of a site that will otherwise be under-utilised for many years. This can have many short-term economic and social benefits. A policy limitation may stifle innovation and creativity. It is considered likely that many of the meanwhile use proposals will require formal planning consent, which will provide the Local Planning Authority with the ability to control and enforce development that is deemed inappropriate.

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

No. A minimum period should be based on the need and timetable for the permanent development. For the most successful meanwhile initiatives a reasonable period of operation is required in order to recoup the initial capital investment.

Question 82: Should the AAP also include a requirement for 'meanwhile uses' to demonstrate how they will add vibrancy and interest and/or deliver on the wider development outcomes and vision for the North East Cambridge area?

No. 'Meanwhile' uses are temporary in nature and an approach that seeks to make efficient use of land, in a compatible manner with surrounding uses, should be encouraged.

Question 83: What negative or positive impacts might the proposed plans have on residents or visitors to Cambridge with low incomes or who have particular characteristics protected under the Equality Act 2010? (The protected characteristics are age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex, and sexual orientation.)

We strongly support the intention of the Vision for NEC and Objective 5, to ensure social and economic inclusion, and as stated in our response to Question 5, would seek the addition of the word 'culturally' within the Vision i.e. 'North East Cambridge - a socially, culturally, and economically inclusive...'

It is recognised that NEC lies within close proximity of two highly deprived wards in Cambridgeshire, and that regeneration on the scale envisaged will create significant socio-economic opportunities for a wider catchment beyond the AAP boundary. Development on the Site, for instance, will create long term employment across a multitude of sectors and skill ranges, improved connectivity around the NEC and access to new services and facilities. We support the intention of the Councils to undertake a Health Needs and Impact Assessment, across an appropriate study area for the NEC, in order to better understand the challenges and issues faced in neighbouring wards, so as to link into opportunities that will arise in NEC.

As stated within our response to Question 5 we generally support the application of local plan accessibility in the NEC. This standard is meeting Part M of the Building Regulations, however due to the requirements of meeting a higher than normal housing number target on the Site, we require flexibility on how the standard is applied. It is important that the Cambridge Local Plan accessibility standards offers flexibility on how the standards are achieved across the many elements of the new masterplanned scheme. While designing for and incorporating accessibility standards is also accepted as a progressive way to future-proof new housing, it is important the standards do not affect the ability of the scheme to meet the density and the target housing required. Currently the Cambridge Local Plan has adopted the optional standard Part M4(2) and has also adopted M4(3) based on a percentage, which is still higher than the national standards, this may have an adverse impact on our scheme.

Question 84: Do you have any other comments about the North East Cambridge area and/or AAP? Are there other issues and alternatives that the councils should consider? If you wish to make suggestions, please provide your comments.

We would encourage a specific section on education and health provision within the NEC, noting the likelihood that if on-site provision is required, it may require different formats/approaches on how such provision is made i.e. traditional forms of provision in Cambridgeshire are unlikely to be suitable in a high density urban regeneration scheme of this nature.

If off-site provision is considered to be more appropriate, comment should be given on how and where need is expected to be accommodated (for instance it may be more appropriate to extend existing or proposed schools in Cambridge, to create additional Forms of Entry, rather than have a lower number of Forms of Entry on-site that falls below the recommended minimum sizes).

Introduction

Cambridge City Council and South Cambridgeshire District Council is consulting on Issues & Options for the North East Cambridge AAP. The consultation deadline is 25th March 2019. The draft response on behalf of U+I Group PLC ('U+I') is set out below. U+I have been selected by the landowners Anglian Water and Cambridge City Council as Master Developer for land outlined in red in the accompanying Site Plan ('the Site'). It is noted that Cambridge City Council also own other land beyond the Site, which may be the subject of other representations.

The representations contained herein relate primarily to the development intentions for the Site, but also in the context of the wider AAP area (as sites within the AAP boundary are largely intrinsically linked).

Representations

Question 1: Do you agree with changing the name of the plan to the 'North East Cambridge Area Action Plan'?

It is recognised that there is a need for a collective reference for the AAP area. This will provide consistency and clearer definition as the process evolves. Whilst it is inevitable that sub-areas of the AAP will emerge with different branding names and strategies, this will have more relevance to the individual sub-area concerned, in creating identity when publicising forthcoming planning applications through to marketing/sales disposals.

Question 2: Is the proposed boundary the most appropriate one for the AAP?

Generally, we support the proposed boundary for the AAP area. We would, however, make two observations/comments.

Firstly, it seems logical to include the site of Cambridge Regional College ('CRC') within the boundary. It is noted that in paragraph 3.5 comment is made that it is not expected to undergo major change in the way other sites across NEC are. However, CRC considers itself to be 'one of the best Further Education Colleges in the country for 16-18 year old level 3 achievement and a leading apprenticeship provider, with thousands of full time students and apprentices currently in training'. The significant range of vocational courses it offers could be positively utilised to support the long-term construction process around NEC (e.g. architectural technology, mechanical engineering, electrical, carpentry, bricklaying courses and apprenticeships), and then the on-going operational phases of the different sub-areas of NEC (e.g. from courses relating to biological science for industry, laboratory technicians and computing technologies, to business and catering and hospitality). It therefore has the potential to play an important learning and development role in the future NEC area. The built form of the current campus appears to be relatively low density, with large areas of used for surface level car parking. Buildings are predominantly 2-3 storeys in height. With the transformation of NEC, recognising the different approaches to internalised trips/reduced car parking, and taller buildings, it would seem likely that the estate management of CRC might change in the future, and if so, it should be included in the AAP.

Secondly, we would comment that, owing to the nature of NEC, development is likely to be high density, optimising the use of all land to work efficiently and effectively. The strategy for on-site Public Open Space is likely to focus on qualitative provision, than quantitative, with a stronger emphasis on formal recreational and leisure space than informal open space. Access to the latter however, is likely to be facilitated through new and improved connections to the east (potentially including land to the east of the railway line north of Cambridge North Train Station, to the river) and north (potentially including land to the north of the A14, such as Land to the south of Cambridge Road, and land including/extending Milton Country Park) of NEC. We would therefore simply pose the question about whether there is a need to include within the AAP boundary additional land that could provide informal open space, biodiversity and drainage functions, which might otherwise not be achievable within the single control of the NEC boundary. It is considered that land to the north and east of the current AAP boundary would primarily be used to facilitate access to green infrastructure for NEC.

Question 3: In this chapter have we correctly identified the physical characteristics of the North East Cambridge area and its surroundings?

Generally, yes. However, we consider it might be beneficial to include more information about the composition of site areas. For instance, on the employment parks, providing details about site area, total floorspace of buildings on the park (including extant planning consents) and the range of authorised planning uses e.g. % B1a uses, %B1b uses, estimated no. of employees, audit of authorised car parking spaces, audit of public open space (estimated total hectares). This would help to inform a baseline of land use within NEC, and then contribute in developing future strategy e.g. highway trip budget, employment strategy, connectivity and green infrastructure etc.
We would also note that it would be beneficial to have mapping information available relating to the environmental constraints identified e.g. noise, air quality, odour, important habitats.
Finally, it would be beneficial to show the broader extents of key infrastructure for NEC, including the full Chisholm Trail link (connecting NEC to Cambridge City, and the south of Cambridge (Addenbrookes), committed routes for other new cycle, pedestrian and public transport in and around the City, and the proposed Greenways link to Waterbeach).

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

In general, yes. However, we note that there is no reference to Archaeology and Heritage, and would suggest that comment is given about this, even if it is considered that NEC has limited archaeological significance. In terms of heritage, whilst we believe that there are no listed buildings, conservation areas, or other notable heritage constraints within NEC, the intention for taller buildings in NEC will need to be more widely considered in respect of longer-distant views and townscape issues (historic core of Cambridge). Taller buildings may also have potential implications for Air Safeguarding Zones (consultation required with Marshall Airport and the Ministry of Defence on structures over 15m in height), and the Mullard Radio Astronomy Observatory (consultation with the University of Cambridge). We acknowledge that the issue of building heights and taller buildings is likely to be assessed as part of the on-going Landscape Character and Visual Impact Assessment that is being undertaken by Cambridge City Council (it is understood that a 'Stage 1' exercise has already been commissioned), and that the findings are then likely to inform future stages of this AAP process.

We would also suggest consideration be given to the inclusion of Green Belt boundaries around NEC. This will help provide clarity to interested parties that all land envisaged for development and associated physical infrastructure will be accommodated on non-Green Belt land. It will also help to provide reassurance that the development aspirations for NEC will not automatically lead to further development beyond the identified boundaries, unless it is deemed to be 'appropriate development' (i.e. not 'inappropriate' as defined in the National Planning Policy Framework'), or that exceptional circumstances are demonstrated in future Local Plans, or a Very Special Circumstances argument is made to support development via a planning application process. In all cases, strict mechanisms for controlling additional future development beyond NEC will apply.

Reference should also be made to the presence of UKPN's overhead power cables (132KV) that span across the AAP boundary. In terms of ensuring optimum reuse of the Site (and indeed other sites, including Cambridge Science Park), we would support a policy seeking their diversion underground.

Question 5: Do you agree with the proposed Vision for the future of the North East Cambridge area? If not, what might you change?

Yes, we support the proposed Vision for NEC. The addition of the word 'culturally' might benefit this Vision further (in the context of 'North East Cambridge - a socially, culturally, and economically inclusive....)

Question 6: Do you agree with the overarching Objectives? If not, what might you change?

Generally, we support the overarching Objectives. The addition of the words 'Natural Capital' might benefit Objective 7 further (in the context of '...connecting and improving biodiversity to achieve a Natural Capital net gain....)

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

It is noted that the Concept Plan can only be treated as indicative at this stage in the AAP process, until the outcomes of the various Supporting Studies are known (notably Landscape Character and Visual Impact Assessment, Development Capacity Study, NEC AAP Transport Assessment, NEC Development Viability Assessment, NEC Infrastructure Delivery Plan), and wider consultation with relevant interested parties (e.g. landowners, developers, local communities, local authority bodies etc) has been carried out.

We support the residential-led mixed use allocation for the Site. We support the aspiration to create high quality pedestrian, cycle and public transport connectivity across the AAP area. We support the indication that a Mixed Use District Centre will be provided on the Site though we would suggest that its optimal location can only be determined after further study and masterplanning work. There may also be a need to include an additional Mixed Use Local Centre in the northern half of the Site (subject to further Masterplanning and an assessment on accessibility). We support the intention to provide and integrate Green Infrastructure throughout the AAP boundary, but what provision is made (and how/where it will be provided) will need to be determined following further studies/assessment and Masterplanning. Further consideration will need to be given to the suggested Industrial Development Sites in the north east corner of the Site, to understand what the rationale is for proposing to relocate existing industrial land at Nuffield Road and Cowley Road, to another part of the AAP site. It is assumed that the suggestion is made on the basis that it will provide noise abatement from the A14 to the new residential elements of the Site. However, we consider that there may be other more preferable solutions for controlling noise and, in Masterplanning terms it is less desirable bringing industrial-related traffic through a predominantly residential site. In the absence of clear justification for seeking relocation of industrial uses, we cannot support the industrial element of the proposal.

We aren't yet persuaded that the proposed location and quantum of industrial use is optimal. In particular we have concerns that this is currently shown at the furthest point from strategic highway connections. We also believe that different models and formats of industrial development should be further explored, specifically whether this should be concentrated in a single location, or whether it might be incorporated within a mixed-use approach throughout the Site.

We do not necessarily agree that the Site represents the best opportunity with the overall AAP area to accommodate a significant concentration of industrial uses in a single location.

We would suggest that the Cambridge Business Park is shaded as an Opportunity for Employment Intensification.

In addition to our response for Question 2, we would suggest that the CRC land we would suggest that this land is included within the AAP boundary, and that a new shading is applied that refers to an Opportunity for Education Intensification.

Question 8: Do you agree that outside of the existing business areas, the eastern part of the North East Cambridge AAP area (i.e. the area east of Milton Road) should provide a higher density mixed use residential led area with intensified employment, relocation of existing industrial uses and other supporting uses?

Generally, we support the initial development intentions for the area east of Milton Road. It is considered that this area could accommodate a high density mixed use residential-led development following the relocation of the existing Cambridge Water Recycling Centre and other industrial uses (subject to viability and finding suitable relocation site(s)) from the Site. A comprehensive, design-led, approach across the AAP will help maximise the redevelopment potential of a significant brownfield site in a highly sustainable location.

Question 9: Should Nuffield Road Industrial Estate be redeveloped for residential mixed use development?

Yes, we agree that consideration should be given to relocating existing industrial uses on the Nuffield Road Industrial Estate, in preference for higher density residential-led mixed use redevelopment. Consideration should be given to the viability of doing so (industrial land values are currently relatively high), and where existing businesses will be relocated. An Industrial Relocation Strategy might be appropriate, in order to understand what factors are important to businesses e.g. last mile strategies and what alternative sites might be available to accommodate relocation requirements. ]

As outlined in Question 7, the suggestion to relocate industrial uses from Nuffield Road Industrial Estate to the north east corner of the Site needs to be explained and justified. At this stage we do not support the suggestion to relocate industrial uses to the north-east corner of the Site.

Question 10: Do you agree that opportunities should be explored to intensify and diversify existing business areas? If so, with what sort of uses?

Yes, we broadly support this suggestion, subject to the establishment of a robust and equitable approach to Highways Trip Budget apportionment and s106 tariff system across the wider AAP area. The Cambridge Science Park was first established on the principle of accommodating 1-2 storey, low density commercial buildings within an attractive strategic landscape/parkland setting. Whilst much of the strategic landscaping remains, latter phases of the Science Park have sought to intensify development density, with taller buildings, lower car parking provision, and limited on-plot landscaping (other than to lessen/soften the impact of new development). This approach has been complemented by the introduction of Cambridge North Station Interchange, which has significantly improved accessibility via non-car modes. The growth aspirations now anticipated for the AAP area signals a radical change in approach to new development. New residential communities will be supported by existing and intensified employment and educational opportunities, potentially providing live and work/learning opportunities within walking/cycling distance of each other. Furthermore, access to inter alia Cambridge North, the Guided Busway, and the Chisholm Trail will support accessibility to existing business areas from a much wider catchment, therefore helping to improve the means of accessing work without the need to do so by car.

Opportunities to provide a greater quantum and diversity of employment should be encouraged. This will consolidate and strengthen the concept of the Cambridge Phenomenon, by creating a greater range and quantum of high quality accommodation for new businesses, in close proximity to a critical mass of similar businesses, thereby helping to support knowledge sharing and collaboration through co-location.

In order to promote diversity of employment types, planning policy consideration might be given to encouraging a certain percentage of 'affordable employment', to support the growth of new start-up businesses that require the same close links with similar businesses but cannot afford (and do not currently need) accommodation that becomes available.

Question 11: Are there any particular land uses that should be accommodated in the North East Cambridge area?

The North East Cambridge area should support any use that demonstrably contributes to the Vision and Objectives of the AAP area.
The AAP provides a significant opportunity to create thousands of new homes in a highly sustainable location. The growth of housing in this area will be supported by the economic benefits derived from the long-established science, innovation and business parks (many of which will be intensified), that have collectively grown from the success of clustering knowledge-based industries in close proximity of one another. The housing element of the Site will improve supply and affordability of high quality new homes to the many thousands of employees on these parks, helping to reduce the number of car movements on Milton Road. New homes and jobs on the scale envisage will need to be served by a number of social, retail, community, health, education, leisure and recreation facilities,

Question 12: What uses or activities should be included within the North East Cambridge AAP area which will create a district of culture, creativity and interest that will help create a successful community where people will choose to live and work and play?

It is considered that the inclusion of schools, community facilities, retail and leisure uses, open space, and transport services, in conjunction with walking and cycling connections to neighbouring areas will provide the attributes of a successful community.

The NEC AAP must recognise the wider role it plays in creating opportunities for surrounding communities, of which two neighbouring wards - East Chesterton and Kings Hedges - currently suffer from high levels of deprivation (included in the top three of most deprived wards in Cambridgeshire). The benefits of the AAP area should extend to these areas, to create new employment, education, social, leisure and recreation, health and community opportunities. Where new facilities are introduced to areas experiencing deprivation, a key challenge for optimising use of such facilities is affordability. Free or subsidised charging mechanisms should therefore be considered when providing new facilities for instance e.g. hire of sports pitches, meeting rooms etc.

It should, however, be recognised (and indeed it is in Question 79) that the ambitious development aspirations for the Site and wider AAP area will take a number of years to comprehensively plan and deliver. Certain elements will be possible to deliver early. Notwithstanding this, there is the opportunity to introduce 'meanwhile/worthwhile' uses the area as the transition progresses. Meanwhile/worthwhile uses offer creative and innovative ways of optimising sites on a stop-gap basis, creating a temporary opportunity to capture economic and/or social benefits for the wider area in the period between the closure/or reduction of an existing site operation and the commencement of the intended new development.

Question 13: Should the AAP require developments in the North East Cambridge AAP area to apply Healthy Towns principles?

NEC will provide a considerable opportunity for creating a healthy new community, and supporting neighbouring communities, through access to high quality housing, a design approach founded on sustainable modes of travel (walkable neighbourhoods), and improved employment, shopping, health, education, leisure and recreational opportunities. We also support the intended preparation of the Health Impact and Needs Assessment for NEC, which will take account of the wider deprivation challenges faced in the neighbouring wards of East Chesterton and Kings Hedges.

Question 14: How should the AAP recognise and make best use of the existing and potential new links between the AAP area and the CRC (Cambridge Regional College)?

Please see our response to Question 2.

Question 15: Should clusters of taller buildings around areas of high accessibility including district and local centres and transport stops form part of the design-led approach to this new city district?

We strongly support the principle that the greatest development densities should be located in the areas of greatest accessibility and public amenity. This maximises the potential for sustainable travel patterns and establishes a critical weight of local demand for leisure, cultural and retail uses.

It is important to note that 'high-density' does not automatically mean 'tall' and that compact mid-rise development can often be denser than taller development, particular where the latter is compensated for by a smaller overall development footprint. Compact mid-rise also typically enables a wider range of dwelling types and external amenity space, meeting a wider range housing needs.

We favour a 'transect' based approach to masterplanning which will ensure the density, scale, typology, and uses of development are allocated across the site as a whole and within each neighbourhood in a coordinated way, following the accessibility principle described above and responding to the opportunities and constraints of the Site. This may not mean 'clusters' - it could for example mean that the highest densities are located in 'corridors' along the primary streets, and/or at edges where having denser development acts to shelter lower-scale development from adjacent visual or noise intrusion. The masterplan will be backed up by a design code that will identify/mandate appropriate typologies for achieving the requisite densities in ways that are acceptable in other respects.

In addition to accessibility and other local factors, it is important to note that the extent and location of denser development will be affected by a range of detailed studies and appraisals (including Landscape Character and Visual Impact Assessment), that will recognise - and then balance - the challenges of creating areas of higher density and taller buildings in a highly sustainable location that is, nonetheless, on the edge of Cambridge with areas of open countryside beyond. This may also militate against achieving density through height.

Question 16: Should the AAP include any or a combination of the options below to improve pedestrian and cycling connectivity through the site and to the surrounding area?

A - Create a strong east-west axis to unite Cambridge North Station with Cambridge Science Park across Milton Road. This pedestrian and cycle corridor would be integrated into the wider green infrastructure network to create a pleasant and enjoyable route for people to travel through and around the site. The route could also allow other sustainable forms of transport to connect across Milton Road.

Yes. A strong east-west axis should be included to connect the different parts and proposed uses within NEC, and to encourage movement within the site by sustainable modes of transport.

B - Improve north-south movement between the Cowley Road part of the site and Nuffield Road. Through the redevelopment of the Nuffield Road area of NEC, it will be important that new and existing residents have convenient and safe pedestrian and cycle access to the services and facilities that will be provided as part of the wider North East Cambridge area proposals.

Yes.
C - Upgrade connections to Milton Country Park by both foot and cycle. This would include improving access to the Jane Coston Bridge over the A14, the Waterbeach Greenway project including a new access under the A14 (see Transport Chapter), as well as the existing underpass along the river towpath.

Yes. It is considered that improvements to connections with Milton Country Park and with existing and proposed pedestrian and cycle routes will be important for the success of development within the AAP. It is anticipated that NEC will provide a high density residential development, to take advantage of the close proximity of employment areas and public transport services, but which might limit opportunities for large scale open space/recreation areas. Therefore, it will be important to ensure that any proposal for an underpass will maximise connectivity through the Site, capitalising on permeability and wider Green Infrastructure initiatives (e.g. Waterbeach Greenway, Chisholm Trail, improving the public realm function of the 1st Drain etc).

D - Provide another Cambridge Guided Bus stop to serve a new District Centre located to the east side of Milton Road.

We support the suggestion to improve public transport accessibility around NEC but further work should be undertaken to determine whether an additional 'guided' busway stop is required or whether a 'normal' bus service, which could feasibly use the same buses as those on the Busway, could deliver the same benefits.

E - Increase ease of movement across the sites by opening up opportunities to walk and cycle through areas where this is currently difficult, for example Cambridge Business Park and the Cambridge Science Park improving access to the Kings Hedges and East Chesterton areas as well as the City beyond.

We very much support opportunities to increase the ease and convenience of walking and cycling movements across sites in NEC, as this will strengthen the concept of promoting internalised trips and reduce the reliance on travel by car.

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

It is noted that the River Cam towpath is identified as a route within the Waterbeach Greenway project, and it would be appropriate to take the opportunity to provide a pedestrian and cycling connection from this route into NEC, subject to the availability of funding.

The high density redevelopment of NEC is unlikely to achieve the level of Public Open Space that might otherwise be required under local plan policy. The focus is instead likely to be on securing high quality, flexible-use open space on-site, and improving/providing new connections to informal open space networks to the north and east of the AAP area (including the Waterbeach Greenway). Accordingly, an appropriate means of accessing off-site Green Infrastructure for NEC will be required, and the suggestion of a pedestrian/cycle bridge would facilitate this.

Please see our responses to Questions 2 and 7.

Question 18: Which of the following options would best improve connectivity across Milton Road between Cambridge North Station and Cambridge Science Park?
A - One or more new 'green bridges' for pedestrians and cycles could be provided over Milton Road. The bridges could form part of the proposed green infrastructure strategy for NEC, creating a substantial green/ecological link(s) over the road.
B - Subject to viability and feasibility testing, Milton Road could be 'cut-in' or tunnelled below ground in order to create a pedestrian and cycle friendly environment at street level. This option would allow for significant improvements to the street which would be more pleasurable for people to walk and cycle through.
C - Milton Road could be significantly altered to rebalance the road in a way that reduces the dominance of the road, including rationalising (reducing) the number of junctions between the Guided Busway and the A14 as well as prioritising walking, cycling and public transport users.
D - Connectivity across Milton Road could be improved through other measures. We would welcome any other suggestions that would improve the east-west connectivity through the site.
E - Other ways of improving connections (please specify)

In response to all five options listed above, we generally support the principle for securing high quality east-west connectivity. However, the means of crossing Milton Road will involve a range of complex issues, which cannot be determined at this stage. The crossing solution(s) should not ultimately be compromised by concerns about short-term disruption and inconvenience. The east-west axis will be fundamental in the overall success of NEC, and the justification for internalising trips will be partly made on the basis that pedestrian and cycle connectivity across NEC will be safe and convenient (and therefore likely to be commonly used as a means of travel).

Option A is considered to be the preferred option as it provides the opportunity to create a substantial green link over the road without adversely affect the flow of traffic on Milton Road, which has existing network capacity issues. It will also limit the impact on the operation of the Milton Road during construction when compared with either Option B and C.

Option B would likely result in significant disruption to the road network during construction and would likely require the lowering or redirecting or Statutory Undertakers Utilities. Both Option B and C would result in alterations to the access junctions into the Science Park and the Site, both of which have limited access opportunities for their respective sizes.

Question 19: Should development within the North East Cambridge area be more visible from Milton Road, and provide a high quality frontage to help create a new urban character for this area?

We generally support the suggestion of making new development within NEC more visible from Milton Road and providing a high quality frontage to create a new urban character for the area. Milton Road is currently a highly car dominated environment, with a number of confusing junctions serving Cambridge Science Park and Cowley Road. However, it is noted that Milton Road acts as a key north / southbound route into and out of Cambridge, and the Milton Interchange forms part of the Strategic Road Network and connects Cambridge to the A14 (a major east to west route, which has recently been upgraded to improve capacity). Given the level of traffic using this stretch of the Milton Road to access the Strategic Road Network at this location, the potential to reduce traffic to provide a high quality new urban character for the area may be limited in the short term. Notwithstanding this, where Milton Road runs southwards the nature of the road starts to change and becomes more urban in nature, potentially becoming more conducive to active frontage and activity on the footway.

Question 20: Do you agree with proposals to include low levels of parking as part of creating a sustainable new city district focusing on non-car transport?

Yes, we generally support this principle NEC provides an opportunity to reduce levels of parking, as part of a package of transport measures including new and additional walking and cycling routes, public transport services, and car share schemes. However, we would also suggest that interim car parking strategies might need to be considered, to support 'pioneer' uses/development during transitional phases of NEC i.e. until the full package of transport infrastructure and initiatives can be fully realised. As new infrastructure/initiatives are introduced, interim car parking can be gradually phased out.

Question 21a: In order to minimise the number of private motor vehicles using Milton Road, should Cambridge Science Park as well as other existing employment areas in this area have a reduction in car parking provision from current levels?

We very much support opportunities to reduce the reliance on travel by car in and around NEC, and instead increase the ease and convenience of walking and cycling movements across sites in NEC, as this will strengthen the concept of promoting internalised trips.

Question 21b: Should this be extended to introduce the idea of a reduction with a more equitable distribution of car parking across both parts of the AAP area?

Yes, as part of a package of transport measures to encourage travel by sustainable modes of transport.

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

Yes, subject to further understanding of the requirements of businesses and the needs of residents. The North East Cambridge area could include a number of delivery/collection hubs.

Question 23: Should development within the North East Cambridge area use car barns for the storage of vehicles?

We support the idea of using car barns, as part of a wider package of parking solutions across NEC. Whilst it is recognised that private on-plot parking is unlikely to be widely encouraged, there will inevitably be demand from some residents to have access to the use of a car/secure car parking but this should be priced accordingly to the end user. Car barns provide communal access to parking, and are typically located in less convenient locations in order to discourage frequent use. As an example, if a car was needed to do a weekly shop, the resident would park outside their property to unload their car and then move the car to a car barn. Car barns can also be used by 'car clubs', so that a resident can book a car for a certain period of time but not have the long-term cost and use commitment to owning a private car. The versatility of car barns should also be recognised, as parking can be let on a temporary basis and, as trends change, can be converted into alternative uses to reduce car usage further.

Question 24: Within the North East Cambridge area green space can be provided in a number of forms including the following options. Which of the following would you support?
A - Green space within the site could be predominately provided through the introduction of a large multi-functional district scale green space. Taking inspiration from Parker's Piece in Cambridge, a new large space will provide flexible space that can be used throughout the year for a wide range of sport, recreation and leisure activities and include a sustainable drainage function. The sustainable drainage element would link into a system developed around the existing First Public Drain and the drainage system in the Science Park. The green space could be further supported by a number of smaller neighbourhood block scale open spaces dispersed across the site.
B - Green spaces within the site could be provided through a series of green spaces of a neighbourhood scale that will be distributed across the residential areas. These green spaces will also be connected to the green infrastructure network to further encourage walking and cycling. Again, these spaces will include a sustainable drainage function and link into the existing First Public Drain and the Science Park drainage system.
C - Enhanced connections and corridors within and beyond the site to improve the biodiversity and ecological value as well as capturing the essential Cambridge character of green fingers extending into urban areas. These corridors could also be focussed around the green space network and sustainable drainage and would reflect the NPPF net environmental gain requirement.
D - Green fingers to unite both sides of Milton Road and capitalise on the existing green networks.
E - Consideration of the site edges - enhancement of the existing structural edge landscape and creating new structural landscape at strategic points within and on the edge of NEC. This would also enhance the setting to the City on this important approach into the City.
F - Creation of enhanced pedestrian and cycle connectivity to Milton Country Park and the River Cam corridor.

In response to all six options listed above, we support the principle for securing high quality green infrastructure across NEC. Subject to further capacity testing and Masterplanning, on-site provision might feasibly take the form of a larger green space for the whole NEC and complemented by smaller 'neighbourhood scale' spaces and enhanced connections and corridors to off-site green infrastructure. We aren't persuaded that Parkers Piece is an appropriate comparable for the size and function of this space but do consider that the green space should draw lessons from existing green spaces in Cambridge. However, in supporting the theme of innovation at all stages of the development it will be important to consider smart solutions for the open space strategy, maximising flexibility across all areas of on-site open space. For instance, playing fields associated with on-site school provision should be available to the wider community, at times when it is not required by the school. Management and security issues will need to be carefully considered in this regard. Landscape vegetation should encourage biodiversity, whilst also performing softening/screening functions. Formal playspace should be able to accommodate multi-use activities during the day and evening and throughout the year. Green infrastructure might incorporate elements of food growing e.g. fruit trees, herbs, and vegetables, enabling free access to foods that help promote healthier lifestyles.

In terms of the suggestion of how open space will be provided (and in what format and amount), this cannot be determined at this stage of the process. A series of studies and assessments have been or are being commissioned by Cambridge City Council, which will help inform development principles and Masterplanning. Consultation will also need to be carried out with a number of interested parties, including landowners, developers, local communities and local authority bodies. Therefore, we are neither supporting nor objecting to any of the suggested options at this stage.

Question 25: As set out in this chapter there are a range of public transport, cycling and walking schemes planned which will improve access to the North East Cambridge area. What other measures should be explored to improve access to this area?

We generally support the suggested options for improving public transport, cycling and walking accessibility around NEC. The proposed Waterbeach Greenway should be directed through the Site, to create a coherent route from Waterbeach to the station. This will allow future residents of the Site to cycle to the station helping to providing a means of travel for the 'first mile / last mile' of the journey to / from the station.

A new route for a busway from the proposed Waterbeach development should be routed through the Site down to Cambridge North Station. Stops on the route could form transport interchanges linking to other bus routes and cycle routes. High quality cycle links should be implemented to connect into existing infrastructure such as the Chisholm Trail.

The route of these two transport spines through the Site will help develop a single coherent sustainable transport corridor down to the station allowing seamless interchanges between transport modes where the routes intersect with one another. The interchanges will be located within a high-quality urban environment close to high density district centres and attractive locations encouraging linked trips and improving access to the district centres by public transport.
It will important to ensure that consideration is always given to promoting access beyond the AAP boundary (as currently shown), such as recognising the education/social role that CRC plays in the west, the retail and leisure/recreational/biodiversity roles of Tesco and Milton Country Park in the north, the leisure/recreational/biodiversity role of the river and green corridors in the east, and the existing Cambridge communities in the south.

Question 26: Do you agree that the AAP should be seeking a very low share of journeys to be made by car compared to other more sustainable means like walking, cycling and public transport to and from, and within the area?

We support the concept of encouraging a greater share of non-car modes of travel for NEC, but note that it is a concept that will need to be accepted by all landowners/occupiers in the AAP boundary in order for it to be successfully implemented. This is broadly in accordance with the advice from the Ely to Cambridge Transport Study, and will be further tested in the NEC AAP Transport Assessment work (due to be commissioned).

Question 27: Do you have any comments on the highway 'trip budget' approach, and how we can reduce the need for people to travel to and within the area by car?

We support the principle of a 'trip budget' as there is limited scope for large scale engineering interventions to create more capacity on the road network. However, the trip budget must be carefully considered and tested to ensure that it is both suitable and realistic. Appropriate measures will need to be employed if the trip budget is exceeded. The monitoring process will need to be carefully considered, as various land uses across the AAP site will be allocated a share of the trip budget.

Question 28: Do you agree that car parking associated with new developments should be low, and we should take the opportunity to reduce car parking in existing developments (alongside the other measures to improve access by means other than the car)?

We generally support the concept of encouraging a greater share of non-car modes of travel for NEC. This is broadly in accordance with the advice from the Ely to Cambridge Transport Study, and will be further tested in the NEC AAP Transport Assessment work (due to be commissioned). It is recognised that many existing employment uses, such as those in Cambridge Science Park, St John's Innovation Park and Cambridge Business Park, will have authorised car parking at significantly higher levels than what is now intended for NEC. We would support the Councils working with various landowners in exploring innovative/incentivised ways of reducing car usage from those sites.

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

We support the suggestion of requiring high levels of cycle parking from new developments. This approach will be supported by the new cycling infrastructure that is planned for Cambridge, including the Chisholm Trail and Waterbeach Greenways. Cycling helps support healthy lifestyles, and is a viable means of travelling around a compact city, assuming that safe and convenient routes and secure/covered parking can be provided. New and existing workplaces can be encouraged to provide showers, changing facilities and lockers to encourage staff to cycle into work.

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

Cycling is key to achieving a mode split and demand must be met, and therefore we support the suggestion of innovative solutions to cycle parking. As part of further capacity testing, Masterplanning and detailed design, consideration will be given to innovative storage solutions (using domestic and international examples) that enables cycle parking to be integrated appropriately into the public realm. The concept of micromobility should also be embraced, with provision made for parking dockless bikes to ensure that they are not left in inconsiderate locations such as the footway.

Question 31: What additional factors should we also be considering to encourage cycling use (e.g. requiring new office buildings to include secure cycle parking, shower facilities and lockers)?

New office buildings should include covered, secure cycle storage, showers and lockers. The cycle parking should also be conveniently located at basement/ground floor level or within easy access of lifts capable of transferring bikes between levels. Where possible segregated access for cyclists should be provided to minimise the conflict with pedestrians and vehicles accessing buildings.

Question 32: How do we design and plan for a place that makes the best use of current technologies and is also future proofed to respond to changing technologies over time?

Energy strategies
We will expect development on the Site to have a very low 'in use' energy demand, through robust design of built fabric and services. This will make it easier to meet more of the scheme's energy demand from renewable and low carbon energy sources - and in some case may allow a 'net positive' energy balance to be achieved. Implications for wider energy networks should also be considered, with consideration of energy storage and demand control options at building and community level.

Form and fabric

Development within the Site will be designed, at both masterplan and building scale, to result in minimal energy use through sensitive consideration of site conditions and a robust approach to fabric performance, using passive design strategies to achieve good comfort, day-lighting and air-quality.

Building services

Developments should ensure they build on high quality design of form and fabric by specifying robust and efficient building services. If care has been taken in the design of the built fabric, it should be simpler for efficient building services to meet the needs of those who live and work in a building.

Energy generation and supply

Once the gross energy demand for the proposed development has been reduced through efficient built form and services, it will become possible to evaluate how a greater proportion of its needs can be met through renewable and low carbon energy sources.

Provision for electric charging points for vehicles should be implemented to ensure that both residents and workers have access to electric car charging points. Way-finding points and real time journey time information should be implemented across the Site to ensure people have accurate up to date travel information.

Delivery hubs should be provided on the periphery of the site to intercept large delivery vehicles from accessing the site. This will also help to consolidate deliveries and reduce the need for large vehicles to enter the Site, with smaller electric vehicles providing the final leg of the journey to the front door of the residence or workplace.

Subterranean bins should be provided on the Site to minimise space requirements for waste storage and provide a secure location for the bins.

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

It is considered unlikely that an at grade crossing can be located to link the Science Park with the station due to capacity constraints on Milton Road. A well-designed overpass for pedestrians and cyclists may provide the best option to effectively reduce severance caused by Milton Road and link the station with the Science Park. The journey from the station to the Science Park, will be the last / first mile of commuter journey and micromobility solutions such as dockless e-bikes should be provided to support the movement on this link.

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

The knowledge-based cluster around Cambridge Science Park, St John's Innovation Park, and Cambridge Business Park is internationally recognised, and the significant economic role that it offers to NEC must be fully harnessed to encourage complementary industries (Artificial Intelligence, R+D and laboratories for smaller emerging businesses that need the cluster benefits, maker-space etc) and optimise further employment opportunities. We would therefore expect a range (in terms of use and size) of employment spaces across NEC, including Science, Research & Development and Technology-related employment. However, in advocating innovation throughout NEC, policy limitations should not be imposed that unduly restrict any particular use at this stage.

Question 35: In particular, should the plan require delivery of:
A - a flexible range of unit types and sizes, including for start-ups and Small and Medium Sized Enterprises (SMEs);
B - Specialist uses like commercial laboratory space;
C - hybrid buildings capable of a mix of uses, incorporating offices and manufacturing uses.
D - shared social spaces, for example central hubs, cafes.
E - Others (please specify).

We generally support all of the suggested options at this stage, and would seek inclusion of corporate headquarters within category A. These options should equally be applied to proposals for meanwhile/worthwhile uses, in order to optimise economic development benefits and promote innovation at the earlier stages of the development process for NEC.

Question 36: Which of the following approaches should the AAP take to existing industrial uses in the North East Cambridge area?
A - seek to relocate industrial uses away from the North East Cambridge area?
NEC represents a significant and unique opportunity to create a new and innovative high-density, high quality, mixed use Quarter for Cambridge and its surrounding area. The opportunity is dependent on Housing Infrastructure Funding that will facilitate the relocation of the Water Treatment Works, and optimise the quantum of new housing across the Site. Whilst it is recognised that other, non-residential uses, will also be needed in NEC in order to promote multi-functioning mixed communities and internalised trips, capacity testing and Masterplanning will need to carefully identify what uses (and how much) will be appropriate. Whilst the prospect of utilising some of the Site for industrial use has not, at this stage, been discounted, justification for the need and location of such a use will need to be very carefully considered. A greater understanding of industrial need is therefore required, and in particular how essential it is for certain businesses to be in Cambridge. Consideration should also be given to whether existing businesses are compatible with residential neighbourhoods, as if so, there may be scope to incorporate industrial (i.e. b1c) accommodation within a mixed use development. This might, for instance, include ground floor workshops/maker spaces where noise, odour, other forms of pollution, and type of deliveries will not give rise to unacceptable living conditions for neighbouring properties. For existing businesses where there is not a demonstrable need to be in Cambridge, relocation options outside the NEC should be considered.

B - seek innovative approaches to supporting uses on site as part of a mixed use City District?
See response to A, above.

Question 37: Are there particular uses that should be retained in the area or moved elsewhere?

See response to A, above. The AAP should set out the strategy for determining the needs of individual businesses (and whether there is an operational imperative to be closely related to Cambridge, and how the relocation of existing industrial uses can be appropriately implemented..

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

The residential ambitions and opportunities in NEC (and particularly the Site) will need to be fully understood and embraced in order for the Vision and Objectives of the AAP to be realised. For the high density levels of new housing envisaged, innovation will be essential at all stages and in all forms. Traditional approaches to housing in Cambridge are unlikely to be appropriate. Housing will be made available for a much wider market than might otherwise be expected for a new settlement/strategic urban extension elsewhere in the county (e.g. Northstowe, Waterbeach, Cambourne), including that which is more aligned to smaller household sizes e.g. students, post-graduates, young professionals, and older persons looking to downsize. Where family housing is to be provided, it will require 'smarter-space' solutions to reflect the Site-wide high density approach.
A greater understanding of need and demand, market trends and viability will be needed to define housing requirements for NEC in later stages of the AAP process.

Question 39: Should the AAP seek provision for housing for essential local workers and/or specific housing provided by employers (i.e. tethered accommodation outside of any affordable housing contribution)?

Yes, see response to Question 38.

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

We generally support the suggestion of having a challenging target for the provision of affordable housing. There is a chronic shortfall of affordable housing in South Cambridgeshire and Cambridge City, and the residential growth aspirations of NEC could make a significant contribution in reducing housing shortfall. It is also important to ensure that there are a range of homes of different sizes and tenures to achieve mixed and balanced communities. However, it is also important to ensure that the policy is sufficiently flexible to address viability challenges, and takes a pragmatic approach when recognising how different types of housing are provided and thereafter managed and maintained e.g. less reliance on traditional approaches of 'pepper-potting' etc. There is a significant cost in delivering the level and type of development envisaged and it will be essential to ensure that delivery of the development can be secured on a viable basis. Consideration must also be given to exploring other means of making housing more widely accessible, such as through PRS for instance.

Question 41: Should an element of the affordable housing provision be targeted at essential local workers?

We generally support this suggestion, but a more detailed understanding of housing need and demand in the area, and indeed an understanding of what key employers in the area require, should be undertaking before developing an AAP-specific affordable housing policy.

Question 42: Should the AAP require a proportion of development to provide custom build opportunities?

We generally support this suggestion, but again a greater understanding of demand, need and viability is required. Consideration should be given to examples where successful custom-build housing has been delivered, such as Marmalade Lane, Cambridge's first co-housing community made up of 42 custom build homes.

Question 43: Should the AAP allow a proportion of purpose built HMOs and include policy controls on the clustering of HMOs?

We support the suggestion of creating more shared living and co-living housing opportunities, as these can help improve variety and access to more affordable, good quality accommodation. This type of housing typically incorporates shared services and facilities and can benefit both younger and older aged groups. However, again a greater understanding of demand, need and viability is required.

Question 44: Should the AAP include Private Rented Sector (PRS) as a potential housing option as part of a wider housing mix across the North East Cambridge area?

We generally support this suggestion, as it typically lends itself to earlier delivery, it can be part of an affordable housing mix, and may suit the needs of the adjoining employment base. Similar to HMO's, PRS development needs to be well-managed to integrate successfully. Again a greater understanding of demand, need and viability is required.

Question 45: if PRS is to be supported, what specific policy requirements should we consider putting in place to manage its provision and to ensure it contributes towards creating a mixed and sustainable community?

We would suggest that this needs to be considered in greater detail, including need and demand, management of facilities, services, and amenities should be well defined and required.

Question 46: Should PRS provide an affordable housing contribution?

Subject to viability, policy requirements will need to reflect the distinct economics of this tenure. In most cases (as in London) this is acknowledging that a form of Discounted Market Rent (capped at 80% of Open Market Rents) is most applicable, as this can be managed by a non-Registered Provider and therefore enables tenure blind blocks to be delivered by PRS operators.

Question 47: What 'clawback' mechanisms should be included to secure the value of the affordable housing to meet local needs if the homes are converted to another tenure?

Typically a profit sharing mechanism up to an agreed cap (cap to be reflective of the affordable housing contribution possible for open market sale units - i.e. the value difference between a private for sale scheme at 40% and a PRS scheme at 30%)

Question 48: What would be a suitable period to require the retention of private rented homes in that tenure and what compensation mechanisms are needed if such homes are sold into a different tenure before the end of the period?

We would suggest a period of 15 years with clawback as outlined in Questions 46 and 47. This period is proposed in the London Plan and is generally accepted by institutional investors

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

We consider that this should be agreed with each operator, and should be brief and relevant to planning matters. This could ensure all prospective tenants are offered the option of a three year tenancy.

Question 50: Should the area provide for other forms of specialist housing (including older people, students & travellers), either onsite or through seeking contributions for off-site provision?

We generally support this suggestion, but again a greater understanding of demand, need and viability is required. A comprehensive analysis of the demographic portrait of Cambridge and its surrounding environs over the next 25 years should be undertaken to assess how new policy interventions - such as NEC (intensified housing and employment uses; new housing 'products' to promote affordability and variety), new transport initiatives to improve access to employment, shopping, leisure and recreation etc, may affect demand and supply of different forms of housing for the local population catchment. In terms of 'housing mix', this might then manifest into redefining 'mainstream' housing, to expand into other groups such as students/graduates, first-time buyers, those requiring good quality rental properties, downsizers, elderly care.

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

We generally support this suggestion. This is a standard that ensures appropriate homes are delivered that meet the needs of the occupants. However, there may be some formats where exceptions may be appropriate - for example co-living formats including student and young professional accommodation, housing for 'downsizers' etc. These groups may prefer smaller homes with greater shared space and it may be appropriate to provide for this need in the context of a balanced housing offer. However, in these cases we would expect there to be clear requirements around the nature and quality of shared space. We would also encourage pilot testing (on a smaller scale) of more innovative solutions to housing, which might include other micro-living models that have not yet been used in Cambridge but have proved successful in other UK/international cities.

Question 52: Should the AAP develop space standards for new purpose built HMOs?

All new housing should meet the Technical Housing Standards and offer adequate shared spaces to not only provide adequate space in a HMOs scenario but above all provide homes that are future proofed as people's lifestyle changes and needs such as working from home also emerge. Future-proofed housing is to offer adequate space for a wide range of scenarios, not only HMOs. A specifically-developed space standards for new purpose built HMOs may prove unnecessary or irrelevant if HMOs within the AAP is then not delivered through a purpose-built type. Please see our response to Question 51.

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

We support the principle of ensuring that all homes have adequate and appropriate access to outdoor space and support the aspiration for most homes to have some private outdoor space. We would, at this stage, question whether it is realistic to expect that 100% of dwellings will have direct access to an area of private amenity space, given the quantum of development envisaged and the range of different housing typologies that will be necessary to deliver this quantum. In situations where it isn't appropriate to deliver private outdoor space, convenient access to high quality communal and public spaces would be provided. Ultimately, a flexible approach to residential amenity space must be taken, incorporating elements such as roof gardens and balconies as well as elements such as private gardens.

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

We generally support this suggestion in principle. This standard is meeting Part M of the Building Regulations, however due to the requirements of meeting a higher than normal housing number target on the Site, we require flexibility on how the standard is applied. It is important that the Cambridge Local Plan accessibility standards offers flexibility on how the standards are achieved across the many elements of the new masterplanned scheme. While designing for and incorporating accessibility standards is also accepted as a progressive way to future-proof new housing, it is important the standards do not affect the ability of the scheme to meet the density and the target housing required. Currently the Cambridge Local Plan has adopted the optional standard Part M4(2) and has also adopted M4(3) based on a percentage, which is still higher than the national standards, this may have an adverse impact on our scheme.

Question 55: Do you agree with the range of considerations that the AAP will need to have regard to in planning for new retail and town centre provision in the North East Cambridge area? Are there other important factors we should be considering?

The ambitious intentions for NEC are likely to see the creation of thousands of new homes and intensified employment opportunities forming part of new mixed, balanced and prosperous new communities. This new 'Quarter' will therefore require district and local centres to help support and sustain it. Non-residential uses will help create vitality and vibrancy to NEC.

Question 56: Should the Councils be proposing a more multi-dimensional interpretation of the role of a town centre or high street for the North East Cambridge area, where retail is a key but not solely dominant element?

We generally support this suggestion. We would highlight the importance of seeking innovative, creative and flexible solutions across the Site and this will be applied when considering how a District or Local Centre is planned and delivered. Longer term trends (national, regional and local) relating to retail and leisure uses will need to be carefully considered in arriving at a strategy that will support the long term vitality and vibrancy of NEC.

Question 57: What community facilities are particularly needed in the North East Cambridge area?

Opportunities will exist to provide access to new services and facilities for residents of NEC and existing surrounding local communities. In terms of the latter, where there are higher levels of deprivation, the cost of using new facilities will need to take account of affordability issues to ensure the cost of use is not prohibitive to those on no/low incomes.
Provision will need to be informed by the NEC Community Facilities Audit, whilst also taking account of the growth assumptions of NEC (including sizes and tenures of housing, as this will have potentially very different outcomes on need). Provision of facilities should offer flexibility and multi-functional spaces.

Question 58: It is recognised that maximising the development potential of the North East Cambridge area may require a different approach to meeting the sport and open space needs of the new community. How might this be achieved?

See our response to Question 24. Owing to the ambitious development aspirations of the Site (and NEC) it will be necessary to consider a comprehensive package of solutions (on and off-site) for open space and recreational strategy. This strategy will be complemented by the various improvements to green infrastructure provision in and beyond the AAP boundary, facilitating greater access opportunities by walking and cycling.

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

See our response to Question 24.

Question 60: Should open space provision within the North East Cambridge area seek to provide for the widest variety of everyday structured and unstructured recreational opportunities, including walking, jogging, picnics, formal and informal play, casual sports, games, dog walking and youth recreation?

We generally support this suggestion. It will be important to ensure that all spaces within the Site are fully optimised, and creative/innovative solutions should be considered to allow for flexible/multi-functional uses.

Question 61: Where specific uses are required to provide of open space as part of the development, should the AAP allow for these to be met through multiple shared use (for example school playing fields & playing pitches for the general public)?

See our response to Question 24.

Question 62: Within this overall approach, in particular, which option do you prefer in relation to carbon reduction standards for residential development?
A - a 19% improvement on 2013 Building Regulations (the current Cambridge Local Plan standard); or
B - a requirement for carbon emissions to be reduced by a further 10% through the use of on-site renewable energy (the current South Cambridgeshire Local Plan standard); or
C - a 19% improvement on 2013 Building Regulations plus an additional 10% reduction through the use of on-site renewable energy (combining the current standards in the Local Plans); or
D - consider a higher standard and develop further evidence alongside the new joint Local Plan.

At this stage we support Option D. This is a complex area of policy setting due to the current grid decarbonisation and emerging guidance from different bodies such as the UKGBC task force, and the GLA London Plan. The context of the electricity grid decarbonisation should be considered to ensure that any targets set do not create perverse outcomes in the future over the timescales of the development and should consider the appropriateness of energy efficiency targets as well as carbon targets.

The AAP should aim to be exemplar while also drawing on the most up to date emerging evidence.

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

Yes, we generally support the AAP sustainable design and construction approaches set out. However with regard to water recycling we think that while water recycling can be an important part of reducing water consumption if used inappropriately can be unsustainable. Therefore we would expect a rounded view to be taken as to when it is most appropriate to apply the highest levels of water recycling (as required by the maximum BREEAM credits for water efficiency), including an understanding of maintenance and carbon efficiency.
Question 64: Do you support the proposal for the AAP to be clear that review mechanisms should be built into any planning permissions in order to reflect changes in policy regarding sustainable design and construction standards in local and national policy? What other mechanisms could be used?

Yes we think it is important to recognise that not all future scenarios are foreseeable and that in order to avoid perverse outcomes in future it may be necessary to reappraise the policy requirements so that the most up to date and relevant standards are applied where necessary, reasonable and practicable.

It may also be advisable to follow guidance from notable charities and NGOs (e.g. UKGBC)

Question 65: Do you support the plan requiring delivery of site wide approaches to issues such as energy and water, as well as the use of BREEAM Communities International Technical Standard at the masterplanning stage?

Subject to further Masterplanning, technical assessment and feasibility testing, we generally support the approach to site wide water proposed and support the approach to innovate energy infrastructure such as smart energy grids. We support the view that infrastructure necessary for decentralised energy should be explored early on in consultation with relevant parties and that consideration should be given to a range of technologies and approaches to ensure the approach with the lowest carbon overall can be identified and supported.

We fully support the principles in BREEAM Communities and believe that while certification often brings a certainty of outcomes it does not always. The effective outcomes of applying BREEAM communities at this stage should be subject to further consideration.

Question 66: Are there additional issues we should consider in developing the approach to deliver an exemplar development?

Consideration should be given to the embodied impacts of buildings and infrastructure installed as well as opportunities to support the circular economy. Consideration should also be given to embracing and supporting innovative smart-tech and infra-tech initiatives where feasible and viable to do so.

Question 67: What approach should the AAP take to ensure delivery of a net gain in biodiversity?

In terms of the Site, owing to the on-going uses of land e.g. Water Recycling Centre, driving range, former Park and Ride site, it is considered likely that it will have limited biodiversity value. It will be necessary, at the relevant stage in the process, to carry out site specific investigations on the potential suitability of habitat for protected species, and to consider mitigation where appropriate. If the assumption is correct, it seems reasonable to believe that the Site can deliver net gains in biodiversity. Notwithstanding this, sites within NEC may be asked to consider biodiversity collectively, to show how habitat mosaics and corridors can be delivered on a more strategic basis. In this event, the AAP will need to provide greater clarity on what process is likely to be followed, and how this will be applied to individual development schemes.

Consideration will also need to be given to increasing the amount of tree canopy cover in NEC.

Consideration should be given to where biodiversity enhancements opportunities exist in nearby areas as well so that the best opportunities for linkages beyond the site boundary are identified as well as ensuring the best opportunities locally can be realised if necessary to meet the net gain requirements.

Question 68: Should the AAP require developments in the area to integrate SMART technologies from the outset?

We generally support the suggestion that NEC should seek to integrate SMART technologies from the outset. As we have previously noted, we will seek to encourage innovative, creative and adaptable solutions throughout all elements of development on the Site. It will be important to consider preparation of a digital strategy for NEC, to seek optimum speeds for broadband/fibre, opportunities to integrate SMART technology in homes, businesses and other development around NEC.

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

We support innovation throughout all elements of development on the Site (and indeed NEC). Rather than committing to any specific type of solution at this stage, it will be necessary to understand whether innovative systems used on other sites, such as North West Cambridge, can be applied on the Site.

Question 70: Do you agree that the AAP should prioritise land that can feasibly be developed early? Are there any risks associated with this proposed approach?

The obvious challenge with sites seeking early release/delivery is how they demonstrate that development will not prejudice the wider delivery aspirations of NEC. Where landowners/developers can explain how development can be carried out in a coordinated/comprehensive manner, it seems reasonable to expect that early delivery can be achieved. A coordinated/comprehensive approach must fully ensure that all development complies with s106 tariff/highways trips budgets, in an equitable manner.

As discussed later in Questions 79 and 80, we would encourage a positive policy approach be taken in supporting temporary/meanwhile uses in order to activate the Site in its earlier development phases, and to optimise economic and social benefits in the local area.

Question 71: Should the AAP include a relocation strategy in preference to leaving this to the market to resolve?

The representations of landowners and occupiers will inform the approach. It is considered that the AAP will need to identify and define a strategy for key sites/uses to be relocated, but maintain flexibility for others. Notwithstanding this the NEC has significant potential to deliver economic, social and environmental benefits, and whilst there are a relatively small number of landowners, the strategic opportunities must not be compromised by one or more parties that are unwilling to support the delivery of the NEC. Accordingly, the Councils cannot discount the possibility of using their CPO powers if required.

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

An infrastructure delivery plan should be prepared for the North East Cambridge Area to identify the infrastructure required and the costs associated with those projects, in order to inform discussions on planning obligations. It would be reasonable to expect all development within the area to contribute towards the required infrastructure, where it benefits the AAP area as a whole rather than individual sites/landownerships

Question 73: What approach do you consider the most appropriate basis on which to apportion the cost of the infrastructure requirements arising from different land uses to ensure an equitable outcome?

We consider that this should form part of a specific study that includes, inter alia, the following considerations:
*Identify the infrastructure required across the AAP area that is necessary to delivering the comprehensive vision. This might include key routes, connections, bridges / underpasses, transport, education, energy/utilities, social etc.
*Identify where these are most appropriately located to meet the AAP vision.
*Establish a cost base for these, including appropriate cost of land recognising that in some cases it would be otherwise used for residential or other development
*Establish an appropriate equalisation formula across the AAP, levied on all new development. This could be one or a combination of a tariff per m2, per net acre etc and may be varied by use class.
*Set this out in a policy / legal framework with an appropriate indexing mechanism

Question 74: How should the AAP take into account potential changes over time, both positive and negative, that might affect development viability?

We consider that this should form part of a specific study that includes, inter alia, the following considerations
*ensuring that development continues steadily over potentially a number of economic cycles - this possibility should be acknowledged and planned for at the outset
*Any viability test whereby s106 or AH requirements would be reduced would need to be carefully calibrated to ensure that infrastructure is protected.
*A review mechanism within the S106 Agreement would allow viability to be reassessed if circumstances change.

Question 75: Do you agree with the proposal to require land assembly where it can be demonstrated that this is necessary for delivering the agreed masterplan for the North East Cambridge area and/or the proper planning of development?

Yes. This does not directly affect U+I. Land assembly will help to ensure the delivery of comprehensive redevelopment of NEC.

Question 76: Should the AAP state that the Councils will consider use of their Compulsory Purchase powers? If so, should the AAP also set out the circumstances under which this would appropriate?

The NEC has significant potential to deliver economic, social and environmental benefits, and whilst there are a relatively small number of landowners, the strategic opportunities must not be compromised by one or more parties that are unwilling to support the delivery of the NEC. It therefore seems appropriate for the AAP to specify how the Councils will use their CPO powers if required, and the circumstances for doing so. This will need to include the viability and timescales of pursuing a CPO process.

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

Yes. There are a range of stakeholders and landowners involved in the development at the North East Cambridge area, and the successful delivery of NEC will require a coordinated approach. This will need to consider a range of issues including connectivity, infrastructure locations, parking/trip budget, smart-city coordination, delivery programmes, design principles, energy/utilities and waste etc.

Question 78: Do you agree with the Councils' proposed approach to dealing with planning applications made ahead of the AAP reaching a more formal stage of preparation?

Yes. It is agreed that a coordinated approach is required and decisions on applications should be made against the AAP with appropriate, equitable contributions made.

Question 79: What types of 'meanwhile uses' should the AAP support for the North East Cambridge area?

We would suggest a range of 'meanwhile uses' could be appropriate for NEC, and would not expect policy to impose any particular restriction on types of use. The emphasis should be on promoting innovation and creativity, with meanwhile uses serving to provide early foundations for the new Quarter that will emerge and subsequently replace the meanwhile uses in the coming years. Meanwhile uses could therefore provide start-up/incubator accommodation for emerging/expanding sectors, pop-up/small-scale A class uses, community space to begin community cohesion with surrounding neighbourhoods etc. A positive policy approach to obligations and planning requirements will be needed to encourage temporary/meanwhile activation, helping to avoid onerous situations that might otherwise render creative initiatives unviable.

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

It seems unnecessary to impose a limitation on the scale of a proposed 'meanwhile use', as the purpose of a meanwhile use is, fundamentally, to make optimum use of a site that will otherwise be under-utilised for many years. This can have many short-term economic and social benefits. A policy limitation may stifle innovation and creativity. It is considered likely that many of the meanwhile use proposals will require formal planning consent, which will provide the Local Planning Authority with the ability to control and enforce development that is deemed inappropriate.

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

No. A minimum period should be based on the need and timetable for the permanent development. For the most successful meanwhile initiatives a reasonable period of operation is required in order to recoup the initial capital investment.

Question 82: Should the AAP also include a requirement for 'meanwhile uses' to demonstrate how they will add vibrancy and interest and/or deliver on the wider development outcomes and vision for the North East Cambridge area?

No. 'Meanwhile' uses are temporary in nature and an approach that seeks to make efficient use of land, in a compatible manner with surrounding uses, should be encouraged.

Question 83: What negative or positive impacts might the proposed plans have on residents or visitors to Cambridge with low incomes or who have particular characteristics protected under the Equality Act 2010? (The protected characteristics are age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex, and sexual orientation.)

We strongly support the intention of the Vision for NEC and Objective 5, to ensure social and economic inclusion, and as stated in our response to Question 5, would seek the addition of the word 'culturally' within the Vision i.e. 'North East Cambridge - a socially, culturally, and economically inclusive...'

It is recognised that NEC lies within close proximity of two highly deprived wards in Cambridgeshire, and that regeneration on the scale envisaged will create significant socio-economic opportunities for a wider catchment beyond the AAP boundary. Development on the Site, for instance, will create long term employment across a multitude of sectors and skill ranges, improved connectivity around the NEC and access to new services and facilities. We support the intention of the Councils to undertake a Health Needs and Impact Assessment, across an appropriate study area for the NEC, in order to better understand the challenges and issues faced in neighbouring wards, so as to link into opportunities that will arise in NEC.

As stated within our response to Question 5 we generally support the application of local plan accessibility in the NEC. This standard is meeting Part M of the Building Regulations, however due to the requirements of meeting a higher than normal housing number target on the Site, we require flexibility on how the standard is applied. It is important that the Cambridge Local Plan accessibility standards offers flexibility on how the standards are achieved across the many elements of the new masterplanned scheme. While designing for and incorporating accessibility standards is also accepted as a progressive way to future-proof new housing, it is important the standards do not affect the ability of the scheme to meet the density and the target housing required. Currently the Cambridge Local Plan has adopted the optional standard Part M4(2) and has also adopted M4(3) based on a percentage, which is still higher than the national standards, this may have an adverse impact on our scheme.

Question 84: Do you have any other comments about the North East Cambridge area and/or AAP? Are there other issues and alternatives that the councils should consider? If you wish to make suggestions, please provide your comments.

We would encourage a specific section on education and health provision within the NEC, noting the likelihood that if on-site provision is required, it may require different formats/approaches on how such provision is made i.e. traditional forms of provision in Cambridgeshire are unlikely to be suitable in a high density urban regeneration scheme of this nature.

If off-site provision is considered to be more appropriate, comment should be given on how and where need is expected to be accommodated (for instance it may be more appropriate to extend existing or proposed schools in Cambridge, to create additional Forms of Entry, rather than have a lower number of Forms of Entry on-site that falls below the recommended minimum sizes).

Introduction

Cambridge City Council and South Cambridgeshire District Council is consulting on Issues & Options for the North East Cambridge AAP. The consultation deadline is 25th March 2019. The draft response on behalf of U+I Group PLC ('U+I') is set out below. U+I have been selected by the landowners Anglian Water and Cambridge City Council as Master Developer for land outlined in red in the accompanying Site Plan ('the Site'). It is noted that Cambridge City Council also own other land beyond the Site, which may be the subject of other representations.

The representations contained herein relate primarily to the development intentions for the Site, but also in the context of the wider AAP area (as sites within the AAP boundary are largely intrinsically linked).

Representations

Question 1: Do you agree with changing the name of the plan to the 'North East Cambridge Area Action Plan'?

It is recognised that there is a need for a collective reference for the AAP area. This will provide consistency and clearer definition as the process evolves. Whilst it is inevitable that sub-areas of the AAP will emerge with different branding names and strategies, this will have more relevance to the individual sub-area concerned, in creating identity when publicising forthcoming planning applications through to marketing/sales disposals.

Question 2: Is the proposed boundary the most appropriate one for the AAP?

Generally, we support the proposed boundary for the AAP area. We would, however, make two observations/comments.

Firstly, it seems logical to include the site of Cambridge Regional College ('CRC') within the boundary. It is noted that in paragraph 3.5 comment is made that it is not expected to undergo major change in the way other sites across NEC are. However, CRC considers itself to be 'one of the best Further Education Colleges in the country for 16-18 year old level 3 achievement and a leading apprenticeship provider, with thousands of full time students and apprentices currently in training'. The significant range of vocational courses it offers could be positively utilised to support the long-term construction process around NEC (e.g. architectural technology, mechanical engineering, electrical, carpentry, bricklaying courses and apprenticeships), and then the on-going operational phases of the different sub-areas of NEC (e.g. from courses relating to biological science for industry, laboratory technicians and computing technologies, to business and catering and hospitality). It therefore has the potential to play an important learning and development role in the future NEC area. The built form of the current campus appears to be relatively low density, with large areas of used for surface level car parking. Buildings are predominantly 2-3 storeys in height. With the transformation of NEC, recognising the different approaches to internalised trips/reduced car parking, and taller buildings, it would seem likely that the estate management of CRC might change in the future, and if so, it should be included in the AAP.

Secondly, we would comment that, owing to the nature of NEC, development is likely to be high density, optimising the use of all land to work efficiently and effectively. The strategy for on-site Public Open Space is likely to focus on qualitative provision, than quantitative, with a stronger emphasis on formal recreational and leisure space than informal open space. Access to the latter however, is likely to be facilitated through new and improved connections to the east (potentially including land to the east of the railway line north of Cambridge North Train Station, to the river) and north (potentially including land to the north of the A14, such as Land to the south of Cambridge Road, and land including/extending Milton Country Park) of NEC. We would therefore simply pose the question about whether there is a need to include within the AAP boundary additional land that could provide informal open space, biodiversity and drainage functions, which might otherwise not be achievable within the single control of the NEC boundary. It is considered that land to the north and east of the current AAP boundary would primarily be used to facilitate access to green infrastructure for NEC.

Question 3: In this chapter have we correctly identified the physical characteristics of the North East Cambridge area and its surroundings?

Generally, yes. However, we consider it might be beneficial to include more information about the composition of site areas. For instance, on the employment parks, providing details about site area, total floorspace of buildings on the park (including extant planning consents) and the range of authorised planning uses e.g. % B1a uses, %B1b uses, estimated no. of employees, audit of authorised car parking spaces, audit of public open space (estimated total hectares). This would help to inform a baseline of land use within NEC, and then contribute in developing future strategy e.g. highway trip budget, employment strategy, connectivity and green infrastructure etc.
We would also note that it would be beneficial to have mapping information available relating to the environmental constraints identified e.g. noise, air quality, odour, important habitats.
Finally, it would be beneficial to show the broader extents of key infrastructure for NEC, including the full Chisholm Trail link (connecting NEC to Cambridge City, and the south of Cambridge (Addenbrookes), committed routes for other new cycle, pedestrian and public transport in and around the City, and the proposed Greenways link to Waterbeach).

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

In general, yes. However, we note that there is no reference to Archaeology and Heritage, and would suggest that comment is given about this, even if it is considered that NEC has limited archaeological significance. In terms of heritage, whilst we believe that there are no listed buildings, conservation areas, or other notable heritage constraints within NEC, the intention for taller buildings in NEC will need to be more widely considered in respect of longer-distant views and townscape issues (historic core of Cambridge). Taller buildings may also have potential implications for Air Safeguarding Zones (consultation required with Marshall Airport and the Ministry of Defence on structures over 15m in height), and the Mullard Radio Astronomy Observatory (consultation with the University of Cambridge). We acknowledge that the issue of building heights and taller buildings is likely to be assessed as part of the on-going Landscape Character and Visual Impact Assessment that is being undertaken by Cambridge City Council (it is understood that a 'Stage 1' exercise has already been commissioned), and that the findings are then likely to inform future stages of this AAP process.

We would also suggest consideration be given to the inclusion of Green Belt boundaries around NEC. This will help provide clarity to interested parties that all land envisaged for development and associated physical infrastructure will be accommodated on non-Green Belt land. It will also help to provide reassurance that the development aspirations for NEC will not automatically lead to further development beyond the identified boundaries, unless it is deemed to be 'appropriate development' (i.e. not 'inappropriate' as defined in the National Planning Policy Framework'), or that exceptional circumstances are demonstrated in future Local Plans, or a Very Special Circumstances argument is made to support development via a planning application process. In all cases, strict mechanisms for controlling additional future development beyond NEC will apply.

Reference should also be made to the presence of UKPN's overhead power cables (132KV) that span across the AAP boundary. In terms of ensuring optimum reuse of the Site (and indeed other sites, including Cambridge Science Park), we would support a policy seeking their diversion underground.

Question 5: Do you agree with the proposed Vision for the future of the North East Cambridge area? If not, what might you change?

Yes, we support the proposed Vision for NEC. The addition of the word 'culturally' might benefit this Vision further (in the context of 'North East Cambridge - a socially, culturally, and economically inclusive....)

Question 6: Do you agree with the overarching Objectives? If not, what might you change?

Generally, we support the overarching Objectives. The addition of the words 'Natural Capital' might benefit Objective 7 further (in the context of '...connecting and improving biodiversity to achieve a Natural Capital net gain....)

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

It is noted that the Concept Plan can only be treated as indicative at this stage in the AAP process, until the outcomes of the various Supporting Studies are known (notably Landscape Character and Visual Impact Assessment, Development Capacity Study, NEC AAP Transport Assessment, NEC Development Viability Assessment, NEC Infrastructure Delivery Plan), and wider consultation with relevant interested parties (e.g. landowners, developers, local communities, local authority bodies etc) has been carried out.

We support the residential-led mixed use allocation for the Site. We support the aspiration to create high quality pedestrian, cycle and public transport connectivity across the AAP area. We support the indication that a Mixed Use District Centre will be provided on the Site though we would suggest that its optimal location can only be determined after further study and masterplanning work. There may also be a need to include an additional Mixed Use Local Centre in the northern half of the Site (subject to further Masterplanning and an assessment on accessibility). We support the intention to provide and integrate Green Infrastructure throughout the AAP boundary, but what provision is made (and how/where it will be provided) will need to be determined following further studies/assessment and Masterplanning. Further consideration will need to be given to the suggested Industrial Development Sites in the north east corner of the Site, to understand what the rationale is for proposing to relocate existing industrial land at Nuffield Road and Cowley Road, to another part of the AAP site. It is assumed that the suggestion is made on the basis that it will provide noise abatement from the A14 to the new residential elements of the Site. However, we consider that there may be other more preferable solutions for controlling noise and, in Masterplanning terms it is less desirable bringing industrial-related traffic through a predominantly residential site. In the absence of clear justification for seeking relocation of industrial uses, we cannot support the industrial element of the proposal.

We aren't yet persuaded that the proposed location and quantum of industrial use is optimal. In particular we have concerns that this is currently shown at the furthest point from strategic highway connections. We also believe that different models and formats of industrial development should be further explored, specifically whether this should be concentrated in a single location, or whether it might be incorporated within a mixed-use approach throughout the Site.

We do not necessarily agree that the Site represents the best opportunity with the overall AAP area to accommodate a significant concentration of industrial uses in a single location.

We would suggest that the Cambridge Business Park is shaded as an Opportunity for Employment Intensification.

In addition to our response for Question 2, we would suggest that the CRC land we would suggest that this land is included within the AAP boundary, and that a new shading is applied that refers to an Opportunity for Education Intensification.

Question 8: Do you agree that outside of the existing business areas, the eastern part of the North East Cambridge AAP area (i.e. the area east of Milton Road) should provide a higher density mixed use residential led area with intensified employment, relocation of existing industrial uses and other supporting uses?

Generally, we support the initial development intentions for the area east of Milton Road. It is considered that this area could accommodate a high density mixed use residential-led development following the relocation of the existing Cambridge Water Recycling Centre and other industrial uses (subject to viability and finding suitable relocation site(s)) from the Site. A comprehensive, design-led, approach across the AAP will help maximise the redevelopment potential of a significant brownfield site in a highly sustainable location.

Question 9: Should Nuffield Road Industrial Estate be redeveloped for residential mixed use development?

Yes, we agree that consideration should be given to relocating existing industrial uses on the Nuffield Road Industrial Estate, in preference for higher density residential-led mixed use redevelopment. Consideration should be given to the viability of doing so (industrial land values are currently relatively high), and where existing businesses will be relocated. An Industrial Relocation Strategy might be appropriate, in order to understand what factors are important to businesses e.g. last mile strategies and what alternative sites might be available to accommodate relocation requirements. ]

As outlined in Question 7, the suggestion to relocate industrial uses from Nuffield Road Industrial Estate to the north east corner of the Site needs to be explained and justified. At this stage we do not support the suggestion to relocate industrial uses to the north-east corner of the Site.

Question 10: Do you agree that opportunities should be explored to intensify and diversify existing business areas? If so, with what sort of uses?

Yes, we broadly support this suggestion, subject to the establishment of a robust and equitable approach to Highways Trip Budget apportionment and s106 tariff system across the wider AAP area. The Cambridge Science Park was first established on the principle of accommodating 1-2 storey, low density commercial buildings within an attractive strategic landscape/parkland setting. Whilst much of the strategic landscaping remains, latter phases of the Science Park have sought to intensify development density, with taller buildings, lower car parking provision, and limited on-plot landscaping (other than to lessen/soften the impact of new development). This approach has been complemented by the introduction of Cambridge North Station Interchange, which has significantly improved accessibility via non-car modes. The growth aspirations now anticipated for the AAP area signals a radical change in approach to new development. New residential communities will be supported by existing and intensified employment and educational opportunities, potentially providing live and work/learning opportunities within walking/cycling distance of each other. Furthermore, access to inter alia Cambridge North, the Guided Busway, and the Chisholm Trail will support accessibility to existing business areas from a much wider catchment, therefore helping to improve the means of accessing work without the need to do so by car.

Opportunities to provide a greater quantum and diversity of employment should be encouraged. This will consolidate and strengthen the concept of the Cambridge Phenomenon, by creating a greater range and quantum of high quality accommodation for new businesses, in close proximity to a critical mass of similar businesses, thereby helping to support knowledge sharing and collaboration through co-location.

In order to promote diversity of employment types, planning policy consideration might be given to encouraging a certain percentage of 'affordable employment', to support the growth of new start-up businesses that require the same close links with similar businesses but cannot afford (and do not currently need) accommodation that becomes available.

Question 11: Are there any particular land uses that should be accommodated in the North East Cambridge area?

The North East Cambridge area should support any use that demonstrably contributes to the Vision and Objectives of the AAP area.
The AAP provides a significant opportunity to create thousands of new homes in a highly sustainable location. The growth of housing in this area will be supported by the economic benefits derived from the long-established science, innovation and business parks (many of which will be intensified), that have collectively grown from the success of clustering knowledge-based industries in close proximity of one another. The housing element of the Site will improve supply and affordability of high quality new homes to the many thousands of employees on these parks, helping to reduce the number of car movements on Milton Road. New homes and jobs on the scale envisage will need to be served by a number of social, retail, community, health, education, leisure and recreation facilities,

Question 12: What uses or activities should be included within the North East Cambridge AAP area which will create a district of culture, creativity and interest that will help create a successful community where people will choose to live and work and play?

It is considered that the inclusion of schools, community facilities, retail and leisure uses, open space, and transport services, in conjunction with walking and cycling connections to neighbouring areas will provide the attributes of a successful community.

The NEC AAP must recognise the wider role it plays in creating opportunities for surrounding communities, of which two neighbouring wards - East Chesterton and Kings Hedges - currently suffer from high levels of deprivation (included in the top three of most deprived wards in Cambridgeshire). The benefits of the AAP area should extend to these areas, to create new employment, education, social, leisure and recreation, health and community opportunities. Where new facilities are introduced to areas experiencing deprivation, a key challenge for optimising use of such facilities is affordability. Free or subsidised charging mechanisms should therefore be considered when providing new facilities for instance e.g. hire of sports pitches, meeting rooms etc.

It should, however, be recognised (and indeed it is in Question 79) that the ambitious development aspirations for the Site and wider AAP area will take a number of years to comprehensively plan and deliver. Certain elements will be possible to deliver early. Notwithstanding this, there is the opportunity to introduce 'meanwhile/worthwhile' uses the area as the transition progresses. Meanwhile/worthwhile uses offer creative and innovative ways of optimising sites on a stop-gap basis, creating a temporary opportunity to capture economic and/or social benefits for the wider area in the period between the closure/or reduction of an existing site operation and the commencement of the intended new development.

Question 13: Should the AAP require developments in the North East Cambridge AAP area to apply Healthy Towns principles?

NEC will provide a considerable opportunity for creating a healthy new community, and supporting neighbouring communities, through access to high quality housing, a design approach founded on sustainable modes of travel (walkable neighbourhoods), and improved employment, shopping, health, education, leisure and recreational opportunities. We also support the intended preparation of the Health Impact and Needs Assessment for NEC, which will take account of the wider deprivation challenges faced in the neighbouring wards of East Chesterton and Kings Hedges.

Question 14: How should the AAP recognise and make best use of the existing and potential new links between the AAP area and the CRC (Cambridge Regional College)?

Please see our response to Question 2.

Question 15: Should clusters of taller buildings around areas of high accessibility including district and local centres and transport stops form part of the design-led approach to this new city district?

We strongly support the principle that the greatest development densities should be located in the areas of greatest accessibility and public amenity. This maximises the potential for sustainable travel patterns and establishes a critical weight of local demand for leisure, cultural and retail uses.

It is important to note that 'high-density' does not automatically mean 'tall' and that compact mid-rise development can often be denser than taller development, particular where the latter is compensated for by a smaller overall development footprint. Compact mid-rise also typically enables a wider range of dwelling types and external amenity space, meeting a wider range housing needs.

We favour a 'transect' based approach to masterplanning which will ensure the density, scale, typology, and uses of development are allocated across the site as a whole and within each neighbourhood in a coordinated way, following the accessibility principle described above and responding to the opportunities and constraints of the Site. This may not mean 'clusters' - it could for example mean that the highest densities are located in 'corridors' along the primary streets, and/or at edges where having denser development acts to shelter lower-scale development from adjacent visual or noise intrusion. The masterplan will be backed up by a design code that will identify/mandate appropriate typologies for achieving the requisite densities in ways that are acceptable in other respects.

In addition to accessibility and other local factors, it is important to note that the extent and location of denser development will be affected by a range of detailed studies and appraisals (including Landscape Character and Visual Impact Assessment), that will recognise - and then balance - the challenges of creating areas of higher density and taller buildings in a highly sustainable location that is, nonetheless, on the edge of Cambridge with areas of open countryside beyond. This may also militate against achieving density through height.

Question 16: Should the AAP include any or a combination of the options below to improve pedestrian and cycling connectivity through the site and to the surrounding area?

A - Create a strong east-west axis to unite Cambridge North Station with Cambridge Science Park across Milton Road. This pedestrian and cycle corridor would be integrated into the wider green infrastructure network to create a pleasant and enjoyable route for people to travel through and around the site. The route could also allow other sustainable forms of transport to connect across Milton Road.

Yes. A strong east-west axis should be included to connect the different parts and proposed uses within NEC, and to encourage movement within the site by sustainable modes of transport.

B - Improve north-south movement between the Cowley Road part of the site and Nuffield Road. Through the redevelopment of the Nuffield Road area of NEC, it will be important that new and existing residents have convenient and safe pedestrian and cycle access to the services and facilities that will be provided as part of the wider North East Cambridge area proposals.

Yes.
C - Upgrade connections to Milton Country Park by both foot and cycle. This would include improving access to the Jane Coston Bridge over the A14, the Waterbeach Greenway project including a new access under the A14 (see Transport Chapter), as well as the existing underpass along the river towpath.

Yes. It is considered that improvements to connections with Milton Country Park and with existing and proposed pedestrian and cycle routes will be important for the success of development within the AAP. It is anticipated that NEC will provide a high density residential development, to take advantage of the close proximity of employment areas and public transport services, but which might limit opportunities for large scale open space/recreation areas. Therefore, it will be important to ensure that any proposal for an underpass will maximise connectivity through the Site, capitalising on permeability and wider Green Infrastructure initiatives (e.g. Waterbeach Greenway, Chisholm Trail, improving the public realm function of the 1st Drain etc).

D - Provide another Cambridge Guided Bus stop to serve a new District Centre located to the east side of Milton Road.

We support the suggestion to improve public transport accessibility around NEC but further work should be undertaken to determine whether an additional 'guided' busway stop is required or whether a 'normal' bus service, which could feasibly use the same buses as those on the Busway, could deliver the same benefits.

E - Increase ease of movement across the sites by opening up opportunities to walk and cycle through areas where this is currently difficult, for example Cambridge Business Park and the Cambridge Science Park improving access to the Kings Hedges and East Chesterton areas as well as the City beyond.

We very much support opportunities to increase the ease and convenience of walking and cycling movements across sites in NEC, as this will strengthen the concept of promoting internalised trips and reduce the reliance on travel by car.

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

It is noted that the River Cam towpath is identified as a route within the Waterbeach Greenway project, and it would be appropriate to take the opportunity to provide a pedestrian and cycling connection from this route into NEC, subject to the availability of funding.

The high density redevelopment of NEC is unlikely to achieve the level of Public Open Space that might otherwise be required under local plan policy. The focus is instead likely to be on securing high quality, flexible-use open space on-site, and improving/providing new connections to informal open space networks to the north and east of the AAP area (including the Waterbeach Greenway). Accordingly, an appropriate means of accessing off-site Green Infrastructure for NEC will be required, and the suggestion of a pedestrian/cycle bridge would facilitate this.

Please see our responses to Questions 2 and 7.

Question 18: Which of the following options would best improve connectivity across Milton Road between Cambridge North Station and Cambridge Science Park?
A - One or more new 'green bridges' for pedestrians and cycles could be provided over Milton Road. The bridges could form part of the proposed green infrastructure strategy for NEC, creating a substantial green/ecological link(s) over the road.
B - Subject to viability and feasibility testing, Milton Road could be 'cut-in' or tunnelled below ground in order to create a pedestrian and cycle friendly environment at street level. This option would allow for significant improvements to the street which would be more pleasurable for people to walk and cycle through.
C - Milton Road could be significantly altered to rebalance the road in a way that reduces the dominance of the road, including rationalising (reducing) the number of junctions between the Guided Busway and the A14 as well as prioritising walking, cycling and public transport users.
D - Connectivity across Milton Road could be improved through other measures. We would welcome any other suggestions that would improve the east-west connectivity through the site.
E - Other ways of improving connections (please specify)

In response to all five options listed above, we generally support the principle for securing high quality east-west connectivity. However, the means of crossing Milton Road will involve a range of complex issues, which cannot be determined at this stage. The crossing solution(s) should not ultimately be compromised by concerns about short-term disruption and inconvenience. The east-west axis will be fundamental in the overall success of NEC, and the justification for internalising trips will be partly made on the basis that pedestrian and cycle connectivity across NEC will be safe and convenient (and therefore likely to be commonly used as a means of travel).

Option A is considered to be the preferred option as it provides the opportunity to create a substantial green link over the road without adversely affect the flow of traffic on Milton Road, which has existing network capacity issues. It will also limit the impact on the operation of the Milton Road during construction when compared with either Option B and C.

Option B would likely result in significant disruption to the road network during construction and would likely require the lowering or redirecting or Statutory Undertakers Utilities. Both Option B and C would result in alterations to the access junctions into the Science Park and the Site, both of which have limited access opportunities for their respective sizes.

Question 19: Should development within the North East Cambridge area be more visible from Milton Road, and provide a high quality frontage to help create a new urban character for this area?

We generally support the suggestion of making new development within NEC more visible from Milton Road and providing a high quality frontage to create a new urban character for the area. Milton Road is currently a highly car dominated environment, with a number of confusing junctions serving Cambridge Science Park and Cowley Road. However, it is noted that Milton Road acts as a key north / southbound route into and out of Cambridge, and the Milton Interchange forms part of the Strategic Road Network and connects Cambridge to the A14 (a major east to west route, which has recently been upgraded to improve capacity). Given the level of traffic using this stretch of the Milton Road to access the Strategic Road Network at this location, the potential to reduce traffic to provide a high quality new urban character for the area may be limited in the short term. Notwithstanding this, where Milton Road runs southwards the nature of the road starts to change and becomes more urban in nature, potentially becoming more conducive to active frontage and activity on the footway.

Question 20: Do you agree with proposals to include low levels of parking as part of creating a sustainable new city district focusing on non-car transport?

Yes, we generally support this principle NEC provides an opportunity to reduce levels of parking, as part of a package of transport measures including new and additional walking and cycling routes, public transport services, and car share schemes. However, we would also suggest that interim car parking strategies might need to be considered, to support 'pioneer' uses/development during transitional phases of NEC i.e. until the full package of transport infrastructure and initiatives can be fully realised. As new infrastructure/initiatives are introduced, interim car parking can be gradually phased out.

Question 21a: In order to minimise the number of private motor vehicles using Milton Road, should Cambridge Science Park as well as other existing employment areas in this area have a reduction in car parking provision from current levels?

We very much support opportunities to reduce the reliance on travel by car in and around NEC, and instead increase the ease and convenience of walking and cycling movements across sites in NEC, as this will strengthen the concept of promoting internalised trips.

Question 21b: Should this be extended to introduce the idea of a reduction with a more equitable distribution of car parking across both parts of the AAP area?

Yes, as part of a package of transport measures to encourage travel by sustainable modes of transport.

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

Yes, subject to further understanding of the requirements of businesses and the needs of residents. The North East Cambridge area could include a number of delivery/collection hubs.

Question 23: Should development within the North East Cambridge area use car barns for the storage of vehicles?

We support the idea of using car barns, as part of a wider package of parking solutions across NEC. Whilst it is recognised that private on-plot parking is unlikely to be widely encouraged, there will inevitably be demand from some residents to have access to the use of a car/secure car parking but this should be priced accordingly to the end user. Car barns provide communal access to parking, and are typically located in less convenient locations in order to discourage frequent use. As an example, if a car was needed to do a weekly shop, the resident would park outside their property to unload their car and then move the car to a car barn. Car barns can also be used by 'car clubs', so that a resident can book a car for a certain period of time but not have the long-term cost and use commitment to owning a private car. The versatility of car barns should also be recognised, as parking can be let on a temporary basis and, as trends change, can be converted into alternative uses to reduce car usage further.

Question 24: Within the North East Cambridge area green space can be provided in a number of forms including the following options. Which of the following would you support?
A - Green space within the site could be predominately provided through the introduction of a large multi-functional district scale green space. Taking inspiration from Parker's Piece in Cambridge, a new large space will provide flexible space that can be used throughout the year for a wide range of sport, recreation and leisure activities and include a sustainable drainage function. The sustainable drainage element would link into a system developed around the existing First Public Drain and the drainage system in the Science Park. The green space could be further supported by a number of smaller neighbourhood block scale open spaces dispersed across the site.
B - Green spaces within the site could be provided through a series of green spaces of a neighbourhood scale that will be distributed across the residential areas. These green spaces will also be connected to the green infrastructure network to further encourage walking and cycling. Again, these spaces will include a sustainable drainage function and link into the existing First Public Drain and the Science Park drainage system.
C - Enhanced connections and corridors within and beyond the site to improve the biodiversity and ecological value as well as capturing the essential Cambridge character of green fingers extending into urban areas. These corridors could also be focussed around the green space network and sustainable drainage and would reflect the NPPF net environmental gain requirement.
D - Green fingers to unite both sides of Milton Road and capitalise on the existing green networks.
E - Consideration of the site edges - enhancement of the existing structural edge landscape and creating new structural landscape at strategic points within and on the edge of NEC. This would also enhance the setting to the City on this important approach into the City.
F - Creation of enhanced pedestrian and cycle connectivity to Milton Country Park and the River Cam corridor.

In response to all six options listed above, we support the principle for securing high quality green infrastructure across NEC. Subject to further capacity testing and Masterplanning, on-site provision might feasibly take the form of a larger green space for the whole NEC and complemented by smaller 'neighbourhood scale' spaces and enhanced connections and corridors to off-site green infrastructure. We aren't persuaded that Parkers Piece is an appropriate comparable for the size and function of this space but do consider that the green space should draw lessons from existing green spaces in Cambridge. However, in supporting the theme of innovation at all stages of the development it will be important to consider smart solutions for the open space strategy, maximising flexibility across all areas of on-site open space. For instance, playing fields associated with on-site school provision should be available to the wider community, at times when it is not required by the school. Management and security issues will need to be carefully considered in this regard. Landscape vegetation should encourage biodiversity, whilst also performing softening/screening functions. Formal playspace should be able to accommodate multi-use activities during the day and evening and throughout the year. Green infrastructure might incorporate elements of food growing e.g. fruit trees, herbs, and vegetables, enabling free access to foods that help promote healthier lifestyles.

In terms of the suggestion of how open space will be provided (and in what format and amount), this cannot be determined at this stage of the process. A series of studies and assessments have been or are being commissioned by Cambridge City Council, which will help inform development principles and Masterplanning. Consultation will also need to be carried out with a number of interested parties, including landowners, developers, local communities and local authority bodies. Therefore, we are neither supporting nor objecting to any of the suggested options at this stage.

Question 25: As set out in this chapter there are a range of public transport, cycling and walking schemes planned which will improve access to the North East Cambridge area. What other measures should be explored to improve access to this area?

We generally support the suggested options for improving public transport, cycling and walking accessibility around NEC. The proposed Waterbeach Greenway should be directed through the Site, to create a coherent route from Waterbeach to the station. This will allow future residents of the Site to cycle to the station helping to providing a means of travel for the 'first mile / last mile' of the journey to / from the station.

A new route for a busway from the proposed Waterbeach development should be routed through the Site down to Cambridge North Station. Stops on the route could form transport interchanges linking to other bus routes and cycle routes. High quality cycle links should be implemented to connect into existing infrastructure such as the Chisholm Trail.

The route of these two transport spines through the Site will help develop a single coherent sustainable transport corridor down to the station allowing seamless interchanges between transport modes where the routes intersect with one another. The interchanges will be located within a high-quality urban environment close to high density district centres and attractive locations encouraging linked trips and improving access to the district centres by public transport.
It will important to ensure that consideration is always given to promoting access beyond the AAP boundary (as currently shown), such as recognising the education/social role that CRC plays in the west, the retail and leisure/recreational/biodiversity roles of Tesco and Milton Country Park in the north, the leisure/recreational/biodiversity role of the river and green corridors in the east, and the existing Cambridge communities in the south.

Question 26: Do you agree that the AAP should be seeking a very low share of journeys to be made by car compared to other more sustainable means like walking, cycling and public transport to and from, and within the area?

We support the concept of encouraging a greater share of non-car modes of travel for NEC, but note that it is a concept that will need to be accepted by all landowners/occupiers in the AAP boundary in order for it to be successfully implemented. This is broadly in accordance with the advice from the Ely to Cambridge Transport Study, and will be further tested in the NEC AAP Transport Assessment work (due to be commissioned).

Question 27: Do you have any comments on the highway 'trip budget' approach, and how we can reduce the need for people to travel to and within the area by car?

We support the principle of a 'trip budget' as there is limited scope for large scale engineering interventions to create more capacity on the road network. However, the trip budget must be carefully considered and tested to ensure that it is both suitable and realistic. Appropriate measures will need to be employed if the trip budget is exceeded. The monitoring process will need to be carefully considered, as various land uses across the AAP site will be allocated a share of the trip budget.

Question 28: Do you agree that car parking associated with new developments should be low, and we should take the opportunity to reduce car parking in existing developments (alongside the other measures to improve access by means other than the car)?

We generally support the concept of encouraging a greater share of non-car modes of travel for NEC. This is broadly in accordance with the advice from the Ely to Cambridge Transport Study, and will be further tested in the NEC AAP Transport Assessment work (due to be commissioned). It is recognised that many existing employment uses, such as those in Cambridge Science Park, St John's Innovation Park and Cambridge Business Park, will have authorised car parking at significantly higher levels than what is now intended for NEC. We would support the Councils working with various landowners in exploring innovative/incentivised ways of reducing car usage from those sites.

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

We support the suggestion of requiring high levels of cycle parking from new developments. This approach will be supported by the new cycling infrastructure that is planned for Cambridge, including the Chisholm Trail and Waterbeach Greenways. Cycling helps support healthy lifestyles, and is a viable means of travelling around a compact city, assuming that safe and convenient routes and secure/covered parking can be provided. New and existing workplaces can be encouraged to provide showers, changing facilities and lockers to encourage staff to cycle into work.

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

Cycling is key to achieving a mode split and demand must be met, and therefore we support the suggestion of innovative solutions to cycle parking. As part of further capacity testing, Masterplanning and detailed design, consideration will be given to innovative storage solutions (using domestic and international examples) that enables cycle parking to be integrated appropriately into the public realm. The concept of micromobility should also be embraced, with provision made for parking dockless bikes to ensure that they are not left in inconsiderate locations such as the footway.

Question 31: What additional factors should we also be considering to encourage cycling use (e.g. requiring new office buildings to include secure cycle parking, shower facilities and lockers)?

New office buildings should include covered, secure cycle storage, showers and lockers. The cycle parking should also be conveniently located at basement/ground floor level or within easy access of lifts capable of transferring bikes between levels. Where possible segregated access for cyclists should be provided to minimise the conflict with pedestrians and vehicles accessing buildings.

Question 32: How do we design and plan for a place that makes the best use of current technologies and is also future proofed to respond to changing technologies over time?

Energy strategies
We will expect development on the Site to have a very low 'in use' energy demand, through robust design of built fabric and services. This will make it easier to meet more of the scheme's energy demand from renewable and low carbon energy sources - and in some case may allow a 'net positive' energy balance to be achieved. Implications for wider energy networks should also be considered, with consideration of energy storage and demand control options at building and community level.

Form and fabric

Development within the Site will be designed, at both masterplan and building scale, to result in minimal energy use through sensitive consideration of site conditions and a robust approach to fabric performance, using passive design strategies to achieve good comfort, day-lighting and air-quality.

Building services

Developments should ensure they build on high quality design of form and fabric by specifying robust and efficient building services. If care has been taken in the design of the built fabric, it should be simpler for efficient building services to meet the needs of those who live and work in a building.

Energy generation and supply

Once the gross energy demand for the proposed development has been reduced through efficient built form and services, it will become possible to evaluate how a greater proportion of its needs can be met through renewable and low carbon energy sources.

Provision for electric charging points for vehicles should be implemented to ensure that both residents and workers have access to electric car charging points. Way-finding points and real time journey time information should be implemented across the Site to ensure people have accurate up to date travel information.

Delivery hubs should be provided on the periphery of the site to intercept large delivery vehicles from accessing the site. This will also help to consolidate deliveries and reduce the need for large vehicles to enter the Site, with smaller electric vehicles providing the final leg of the journey to the front door of the residence or workplace.

Subterranean bins should be provided on the Site to minimise space requirements for waste storage and provide a secure location for the bins.

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

It is considered unlikely that an at grade crossing can be located to link the Science Park with the station due to capacity constraints on Milton Road. A well-designed overpass for pedestrians and cyclists may provide the best option to effectively reduce severance caused by Milton Road and link the station with the Science Park. The journey from the station to the Science Park, will be the last / first mile of commuter journey and micromobility solutions such as dockless e-bikes should be provided to support the movement on this link.

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

The knowledge-based cluster around Cambridge Science Park, St John's Innovation Park, and Cambridge Business Park is internationally recognised, and the significant economic role that it offers to NEC must be fully harnessed to encourage complementary industries (Artificial Intelligence, R+D and laboratories for smaller emerging businesses that need the cluster benefits, maker-space etc) and optimise further employment opportunities. We would therefore expect a range (in terms of use and size) of employment spaces across NEC, including Science, Research & Development and Technology-related employment. However, in advocating innovation throughout NEC, policy limitations should not be imposed that unduly restrict any particular use at this stage.

Question 35: In particular, should the plan require delivery of:
A - a flexible range of unit types and sizes, including for start-ups and Small and Medium Sized Enterprises (SMEs);
B - Specialist uses like commercial laboratory space;
C - hybrid buildings capable of a mix of uses, incorporating offices and manufacturing uses.
D - shared social spaces, for example central hubs, cafes.
E - Others (please specify).

We generally support all of the suggested options at this stage, and would seek inclusion of corporate headquarters within category A. These options should equally be applied to proposals for meanwhile/worthwhile uses, in order to optimise economic development benefits and promote innovation at the earlier stages of the development process for NEC.

Question 36: Which of the following approaches should the AAP take to existing industrial uses in the North East Cambridge area?
A - seek to relocate industrial uses away from the North East Cambridge area?
NEC represents a significant and unique opportunity to create a new and innovative high-density, high quality, mixed use Quarter for Cambridge and its surrounding area. The opportunity is dependent on Housing Infrastructure Funding that will facilitate the relocation of the Water Treatment Works, and optimise the quantum of new housing across the Site. Whilst it is recognised that other, non-residential uses, will also be needed in NEC in order to promote multi-functioning mixed communities and internalised trips, capacity testing and Masterplanning will need to carefully identify what uses (and how much) will be appropriate. Whilst the prospect of utilising some of the Site for industrial use has not, at this stage, been discounted, justification for the need and location of such a use will need to be very carefully considered. A greater understanding of industrial need is therefore required, and in particular how essential it is for certain businesses to be in Cambridge. Consideration should also be given to whether existing businesses are compatible with residential neighbourhoods, as if so, there may be scope to incorporate industrial (i.e. b1c) accommodation within a mixed use development. This might, for instance, include ground floor workshops/maker spaces where noise, odour, other forms of pollution, and type of deliveries will not give rise to unacceptable living conditions for neighbouring properties. For existing businesses where there is not a demonstrable need to be in Cambridge, relocation options outside the NEC should be considered.

B - seek innovative approaches to supporting uses on site as part of a mixed use City District?
See response to A, above.

Question 37: Are there particular uses that should be retained in the area or moved elsewhere?

See response to A, above. The AAP should set out the strategy for determining the needs of individual businesses (and whether there is an operational imperative to be closely related to Cambridge, and how the relocation of existing industrial uses can be appropriately implemented..

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

The residential ambitions and opportunities in NEC (and particularly the Site) will need to be fully understood and embraced in order for the Vision and Objectives of the AAP to be realised. For the high density levels of new housing envisaged, innovation will be essential at all stages and in all forms. Traditional approaches to housing in Cambridge are unlikely to be appropriate. Housing will be made available for a much wider market than might otherwise be expected for a new settlement/strategic urban extension elsewhere in the county (e.g. Northstowe, Waterbeach, Cambourne), including that which is more aligned to smaller household sizes e.g. students, post-graduates, young professionals, and older persons looking to downsize. Where family housing is to be provided, it will require 'smarter-space' solutions to reflect the Site-wide high density approach.
A greater understanding of need and demand, market trends and viability will be needed to define housing requirements for NEC in later stages of the AAP process.

Question 39: Should the AAP seek provision for housing for essential local workers and/or specific housing provided by employers (i.e. tethered accommodation outside of any affordable housing contribution)?

Yes, see response to Question 38.

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

We generally support the suggestion of having a challenging target for the provision of affordable housing. There is a chronic shortfall of affordable housing in South Cambridgeshire and Cambridge City, and the residential growth aspirations of NEC could make a significant contribution in reducing housing shortfall. It is also important to ensure that there are a range of homes of different sizes and tenures to achieve mixed and balanced communities. However, it is also important to ensure that the policy is sufficiently flexible to address viability challenges, and takes a pragmatic approach when recognising how different types of housing are provided and thereafter managed and maintained e.g. less reliance on traditional approaches of 'pepper-potting' etc. There is a significant cost in delivering the level and type of development envisaged and it will be essential to ensure that delivery of the development can be secured on a viable basis. Consideration must also be given to exploring other means of making housing more widely accessible, such as through PRS for instance.

Question 41: Should an element of the affordable housing provision be targeted at essential local workers?

We generally support this suggestion, but a more detailed understanding of housing need and demand in the area, and indeed an understanding of what key employers in the area require, should be undertaking before developing an AAP-specific affordable housing policy.

Question 42: Should the AAP require a proportion of development to provide custom build opportunities?

We generally support this suggestion, but again a greater understanding of demand, need and viability is required. Consideration should be given to examples where successful custom-build housing has been delivered, such as Marmalade Lane, Cambridge's first co-housing community made up of 42 custom build homes.

Question 43: Should the AAP allow a proportion of purpose built HMOs and include policy controls on the clustering of HMOs?

We support the suggestion of creating more shared living and co-living housing opportunities, as these can help improve variety and access to more affordable, good quality accommodation. This type of housing typically incorporates shared services and facilities and can benefit both younger and older aged groups. However, again a greater understanding of demand, need and viability is required.

Question 44: Should the AAP include Private Rented Sector (PRS) as a potential housing option as part of a wider housing mix across the North East Cambridge area?

We generally support this suggestion, as it typically lends itself to earlier delivery, it can be part of an affordable housing mix, and may suit the needs of the adjoining employment base. Similar to HMO's, PRS development needs to be well-managed to integrate successfully. Again a greater understanding of demand, need and viability is required.

Question 45: if PRS is to be supported, what specific policy requirements should we consider putting in place to manage its provision and to ensure it contributes towards creating a mixed and sustainable community?

We would suggest that this needs to be considered in greater detail, including need and demand, management of facilities, services, and amenities should be well defined and required.

Question 46: Should PRS provide an affordable housing contribution?

Subject to viability, policy requirements will need to reflect the distinct economics of this tenure. In most cases (as in London) this is acknowledging that a form of Discounted Market Rent (capped at 80% of Open Market Rents) is most applicable, as this can be managed by a non-Registered Provider and therefore enables tenure blind blocks to be delivered by PRS operators.

Question 47: What 'clawback' mechanisms should be included to secure the value of the affordable housing to meet local needs if the homes are converted to another tenure?

Typically a profit sharing mechanism up to an agreed cap (cap to be reflective of the affordable housing contribution possible for open market sale units - i.e. the value difference between a private for sale scheme at 40% and a PRS scheme at 30%)

Question 48: What would be a suitable period to require the retention of private rented homes in that tenure and what compensation mechanisms are needed if such homes are sold into a different tenure before the end of the period?

We would suggest a period of 15 years with clawback as outlined in Questions 46 and 47. This period is proposed in the London Plan and is generally accepted by institutional investors

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

We consider that this should be agreed with each operator, and should be brief and relevant to planning matters. This could ensure all prospective tenants are offered the option of a three year tenancy.

Question 50: Should the area provide for other forms of specialist housing (including older people, students & travellers), either onsite or through seeking contributions for off-site provision?

We generally support this suggestion, but again a greater understanding of demand, need and viability is required. A comprehensive analysis of the demographic portrait of Cambridge and its surrounding environs over the next 25 years should be undertaken to assess how new policy interventions - such as NEC (intensified housing and employment uses; new housing 'products' to promote affordability and variety), new transport initiatives to improve access to employment, shopping, leisure and recreation etc, may affect demand and supply of different forms of housing for the local population catchment. In terms of 'housing mix', this might then manifest into redefining 'mainstream' housing, to expand into other groups such as students/graduates, first-time buyers, those requiring good quality rental properties, downsizers, elderly care.

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

We generally support this suggestion. This is a standard that ensures appropriate homes are delivered that meet the needs of the occupants. However, there may be some formats where exceptions may be appropriate - for example co-living formats including student and young professional accommodation, housing for 'downsizers' etc. These groups may prefer smaller homes with greater shared space and it may be appropriate to provide for this need in the context of a balanced housing offer. However, in these cases we would expect there to be clear requirements around the nature and quality of shared space. We would also encourage pilot testing (on a smaller scale) of more innovative solutions to housing, which might include other micro-living models that have not yet been used in Cambridge but have proved successful in other UK/international cities.

Question 52: Should the AAP develop space standards for new purpose built HMOs?

All new housing should meet the Technical Housing Standards and offer adequate shared spaces to not only provide adequate space in a HMOs scenario but above all provide homes that are future proofed as people's lifestyle changes and needs such as working from home also emerge. Future-proofed housing is to offer adequate space for a wide range of scenarios, not only HMOs. A specifically-developed space standards for new purpose built HMOs may prove unnecessary or irrelevant if HMOs within the AAP is then not delivered through a purpose-built type. Please see our response to Question 51.

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

We support the principle of ensuring that all homes have adequate and appropriate access to outdoor space and support the aspiration for most homes to have some private outdoor space. We would, at this stage, question whether it is realistic to expect that 100% of dwellings will have direct access to an area of private amenity space, given the quantum of development envisaged and the range of different housing typologies that will be necessary to deliver this quantum. In situations where it isn't appropriate to deliver private outdoor space, convenient access to high quality communal and public spaces would be provided. Ultimately, a flexible approach to residential amenity space must be taken, incorporating elements such as roof gardens and balconies as well as elements such as private gardens.

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

We generally support this suggestion in principle. This standard is meeting Part M of the Building Regulations, however due to the requirements of meeting a higher than normal housing number target on the Site, we require flexibility on how the standard is applied. It is important that the Cambridge Local Plan accessibility standards offers flexibility on how the standards are achieved across the many elements of the new masterplanned scheme. While designing for and incorporating accessibility standards is also accepted as a progressive way to future-proof new housing, it is important the standards do not affect the ability of the scheme to meet the density and the target housing required. Currently the Cambridge Local Plan has adopted the optional standard Part M4(2) and has also adopted M4(3) based on a percentage, which is still higher than the national standards, this may have an adverse impact on our scheme.

Question 55: Do you agree with the range of considerations that the AAP will need to have regard to in planning for new retail and town centre provision in the North East Cambridge area? Are there other important factors we should be considering?

The ambitious intentions for NEC are likely to see the creation of thousands of new homes and intensified employment opportunities forming part of new mixed, balanced and prosperous new communities. This new 'Quarter' will therefore require district and local centres to help support and sustain it. Non-residential uses will help create vitality and vibrancy to NEC.

Question 56: Should the Councils be proposing a more multi-dimensional interpretation of the role of a town centre or high street for the North East Cambridge area, where retail is a key but not solely dominant element?

We generally support this suggestion. We would highlight the importance of seeking innovative, creative and flexible solutions across the Site and this will be applied when considering how a District or Local Centre is planned and delivered. Longer term trends (national, regional and local) relating to retail and leisure uses will need to be carefully considered in arriving at a strategy that will support the long term vitality and vibrancy of NEC.

Question 57: What community facilities are particularly needed in the North East Cambridge area?

Opportunities will exist to provide access to new services and facilities for residents of NEC and existing surrounding local communities. In terms of the latter, where there are higher levels of deprivation, the cost of using new facilities will need to take account of affordability issues to ensure the cost of use is not prohibitive to those on no/low incomes.
Provision will need to be informed by the NEC Community Facilities Audit, whilst also taking account of the growth assumptions of NEC (including sizes and tenures of housing, as this will have potentially very different outcomes on need). Provision of facilities should offer flexibility and multi-functional spaces.

Question 58: It is recognised that maximising the development potential of the North East Cambridge area may require a different approach to meeting the sport and open space needs of the new community. How might this be achieved?

See our response to Question 24. Owing to the ambitious development aspirations of the Site (and NEC) it will be necessary to consider a comprehensive package of solutions (on and off-site) for open space and recreational strategy. This strategy will be complemented by the various improvements to green infrastructure provision in and beyond the AAP boundary, facilitating greater access opportunities by walking and cycling.

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

See our response to Question 24.

Question 60: Should open space provision within the North East Cambridge area seek to provide for the widest variety of everyday structured and unstructured recreational opportunities, including walking, jogging, picnics, formal and informal play, casual sports, games, dog walking and youth recreation?

We generally support this suggestion. It will be important to ensure that all spaces within the Site are fully optimised, and creative/innovative solutions should be considered to allow for flexible/multi-functional uses.

Question 61: Where specific uses are required to provide of open space as part of the development, should the AAP allow for these to be met through multiple shared use (for example school playing fields & playing pitches for the general public)?

See our response to Question 24.

Question 62: Within this overall approach, in particular, which option do you prefer in relation to carbon reduction standards for residential development?
A - a 19% improvement on 2013 Building Regulations (the current Cambridge Local Plan standard); or
B - a requirement for carbon emissions to be reduced by a further 10% through the use of on-site renewable energy (the current South Cambridgeshire Local Plan standard); or
C - a 19% improvement on 2013 Building Regulations plus an additional 10% reduction through the use of on-site renewable energy (combining the current standards in the Local Plans); or
D - consider a higher standard and develop further evidence alongside the new joint Local Plan.

At this stage we support Option D. This is a complex area of policy setting due to the current grid decarbonisation and emerging guidance from different bodies such as the UKGBC task force, and the GLA London Plan. The context of the electricity grid decarbonisation should be considered to ensure that any targets set do not create perverse outcomes in the future over the timescales of the development and should consider the appropriateness of energy efficiency targets as well as carbon targets.

The AAP should aim to be exemplar while also drawing on the most up to date emerging evidence.

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

Yes, we generally support the AAP sustainable design and construction approaches set out. However with regard to water recycling we think that while water recycling can be an important part of reducing water consumption if used inappropriately can be unsustainable. Therefore we would expect a rounded view to be taken as to when it is most appropriate to apply the highest levels of water recycling (as required by the maximum BREEAM credits for water efficiency), including an understanding of maintenance and carbon efficiency.
Question 64: Do you support the proposal for the AAP to be clear that review mechanisms should be built into any planning permissions in order to reflect changes in policy regarding sustainable design and construction standards in local and national policy? What other mechanisms could be used?

Yes we think it is important to recognise that not all future scenarios are foreseeable and that in order to avoid perverse outcomes in future it may be necessary to reappraise the policy requirements so that the most up to date and relevant standards are applied where necessary, reasonable and practicable.

It may also be advisable to follow guidance from notable charities and NGOs (e.g. UKGBC)

Question 65: Do you support the plan requiring delivery of site wide approaches to issues such as energy and water, as well as the use of BREEAM Communities International Technical Standard at the masterplanning stage?

Subject to further Masterplanning, technical assessment and feasibility testing, we generally support the approach to site wide water proposed and support the approach to innovate energy infrastructure such as smart energy grids. We support the view that infrastructure necessary for decentralised energy should be explored early on in consultation with relevant parties and that consideration should be given to a range of technologies and approaches to ensure the approach with the lowest carbon overall can be identified and supported.

We fully support the principles in BREEAM Communities and believe that while certification often brings a certainty of outcomes it does not always. The effective outcomes of applying BREEAM communities at this stage should be subject to further consideration.

Question 66: Are there additional issues we should consider in developing the approach to deliver an exemplar development?

Consideration should be given to the embodied impacts of buildings and infrastructure installed as well as opportunities to support the circular economy. Consideration should also be given to embracing and supporting innovative smart-tech and infra-tech initiatives where feasible and viable to do so.

Question 67: What approach should the AAP take to ensure delivery of a net gain in biodiversity?

In terms of the Site, owing to the on-going uses of land e.g. Water Recycling Centre, driving range, former Park and Ride site, it is considered likely that it will have limited biodiversity value. It will be necessary, at the relevant stage in the process, to carry out site specific investigations on the potential suitability of habitat for protected species, and to consider mitigation where appropriate. If the assumption is correct, it seems reasonable to believe that the Site can deliver net gains in biodiversity. Notwithstanding this, sites within NEC may be asked to consider biodiversity collectively, to show how habitat mosaics and corridors can be delivered on a more strategic basis. In this event, the AAP will need to provide greater clarity on what process is likely to be followed, and how this will be applied to individual development schemes.

Consideration will also need to be given to increasing the amount of tree canopy cover in NEC.

Consideration should be given to where biodiversity enhancements opportunities exist in nearby areas as well so that the best opportunities for linkages beyond the site boundary are identified as well as ensuring the best opportunities locally can be realised if necessary to meet the net gain requirements.

Question 68: Should the AAP require developments in the area to integrate SMART technologies from the outset?

We generally support the suggestion that NEC should seek to integrate SMART technologies from the outset. As we have previously noted, we will seek to encourage innovative, creative and adaptable solutions throughout all elements of development on the Site. It will be important to consider preparation of a digital strategy for NEC, to seek optimum speeds for broadband/fibre, opportunities to integrate SMART technology in homes, businesses and other development around NEC.

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

We support innovation throughout all elements of development on the Site (and indeed NEC). Rather than committing to any specific type of solution at this stage, it will be necessary to understand whether innovative systems used on other sites, such as North West Cambridge, can be applied on the Site.

Question 70: Do you agree that the AAP should prioritise land that can feasibly be developed early? Are there any risks associated with this proposed approach?

The obvious challenge with sites seeking early release/delivery is how they demonstrate that development will not prejudice the wider delivery aspirations of NEC. Where landowners/developers can explain how development can be carried out in a coordinated/comprehensive manner, it seems reasonable to expect that early delivery can be achieved. A coordinated/comprehensive approach must fully ensure that all development complies with s106 tariff/highways trips budgets, in an equitable manner.

As discussed later in Questions 79 and 80, we would encourage a positive policy approach be taken in supporting temporary/meanwhile uses in order to activate the Site in its earlier development phases, and to optimise economic and social benefits in the local area.

Question 71: Should the AAP include a relocation strategy in preference to leaving this to the market to resolve?

The representations of landowners and occupiers will inform the approach. It is considered that the AAP will need to identify and define a strategy for key sites/uses to be relocated, but maintain flexibility for others. Notwithstanding this the NEC has significant potential to deliver economic, social and environmental benefits, and whilst there are a relatively small number of landowners, the strategic opportunities must not be compromised by one or more parties that are unwilling to support the delivery of the NEC. Accordingly, the Councils cannot discount the possibility of using their CPO powers if required.

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

An infrastructure delivery plan should be prepared for the North East Cambridge Area to identify the infrastructure required and the costs associated with those projects, in order to inform discussions on planning obligations. It would be reasonable to expect all development within the area to contribute towards the required infrastructure, where it benefits the AAP area as a whole rather than individual sites/landownerships

Question 73: What approach do you consider the most appropriate basis on which to apportion the cost of the infrastructure requirements arising from different land uses to ensure an equitable outcome?

We consider that this should form part of a specific study that includes, inter alia, the following considerations:
*Identify the infrastructure required across the AAP area that is necessary to delivering the comprehensive vision. This might include key routes, connections, bridges / underpasses, transport, education, energy/utilities, social etc.
*Identify where these are most appropriately located to meet the AAP vision.
*Establish a cost base for these, including appropriate cost of land recognising that in some cases it would be otherwise used for residential or other development
*Establish an appropriate equalisation formula across the AAP, levied on all new development. This could be one or a combination of a tariff per m2, per net acre etc and may be varied by use class.
*Set this out in a policy / legal framework with an appropriate indexing mechanism

Question 74: How should the AAP take into account potential changes over time, both positive and negative, that might affect development viability?

We consider that this should form part of a specific study that includes, inter alia, the following considerations
*ensuring that development continues steadily over potentially a number of economic cycles - this possibility should be acknowledged and planned for at the outset
*Any viability test whereby s106 or AH requirements would be reduced would need to be carefully calibrated to ensure that infrastructure is protected.
*A review mechanism within the S106 Agreement would allow viability to be reassessed if circumstances change.

Question 75: Do you agree with the proposal to require land assembly where it can be demonstrated that this is necessary for delivering the agreed masterplan for the North East Cambridge area and/or the proper planning of development?

Yes. This does not directly affect U+I. Land assembly will help to ensure the delivery of comprehensive redevelopment of NEC.

Question 76: Should the AAP state that the Councils will consider use of their Compulsory Purchase powers? If so, should the AAP also set out the circumstances under which this would appropriate?

The NEC has significant potential to deliver economic, social and environmental benefits, and whilst there are a relatively small number of landowners, the strategic opportunities must not be compromised by one or more parties that are unwilling to support the delivery of the NEC. It therefore seems appropriate for the AAP to specify how the Councils will use their CPO powers if required, and the circumstances for doing so. This will need to include the viability and timescales of pursuing a CPO process.

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

Yes. There are a range of stakeholders and landowners involved in the development at the North East Cambridge area, and the successful delivery of NEC will require a coordinated approach. This will need to consider a range of issues including connectivity, infrastructure locations, parking/trip budget, smart-city coordination, delivery programmes, design principles, energy/utilities and waste etc.

Question 78: Do you agree with the Councils' proposed approach to dealing with planning applications made ahead of the AAP reaching a more formal stage of preparation?

Yes. It is agreed that a coordinated approach is required and decisions on applications should be made against the AAP with appropriate, equitable contributions made.

Question 79: What types of 'meanwhile uses' should the AAP support for the North East Cambridge area?

We would suggest a range of 'meanwhile uses' could be appropriate for NEC, and would not expect policy to impose any particular restriction on types of use. The emphasis should be on promoting innovation and creativity, with meanwhile uses serving to provide early foundations for the new Quarter that will emerge and subsequently replace the meanwhile uses in the coming years. Meanwhile uses could therefore provide start-up/incubator accommodation for emerging/expanding sectors, pop-up/small-scale A class uses, community space to begin community cohesion with surrounding neighbourhoods etc. A positive policy approach to obligations and planning requirements will be needed to encourage temporary/meanwhile activation, helping to avoid onerous situations that might otherwise render creative initiatives unviable.

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

It seems unnecessary to impose a limitation on the scale of a proposed 'meanwhile use', as the purpose of a meanwhile use is, fundamentally, to make optimum use of a site that will otherwise be under-utilised for many years. This can have many short-term economic and social benefits. A policy limitation may stifle innovation and creativity. It is considered likely that many of the meanwhile use proposals will require formal planning consent, which will provide the Local Planning Authority with the ability to control and enforce development that is deemed inappropriate.

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

No. A minimum period should be based on the need and timetable for the permanent development. For the most successful meanwhile initiatives a reasonable period of operation is required in order to recoup the initial capital investment.

Question 82: Should the AAP also include a requirement for 'meanwhile uses' to demonstrate how they will add vibrancy and interest and/or deliver on the wider development outcomes and vision for the North East Cambridge area?

No. 'Meanwhile' uses are temporary in nature and an approach that seeks to make efficient use of land, in a compatible manner with surrounding uses, should be encouraged.

Question 83: What negative or positive impacts might the proposed plans have on residents or visitors to Cambridge with low incomes or who have particular characteristics protected under the Equality Act 2010? (The protected characteristics are age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex, and sexual orientation.)

We strongly support the intention of the Vision for NEC and Objective 5, to ensure social and economic inclusion, and as stated in our response to Question 5, would seek the addition of the word 'culturally' within the Vision i.e. 'North East Cambridge - a socially, culturally, and economically inclusive...'

It is recognised that NEC lies within close proximity of two highly deprived wards in Cambridgeshire, and that regeneration on the scale envisaged will create significant socio-economic opportunities for a wider catchment beyond the AAP boundary. Development on the Site, for instance, will create long term employment across a multitude of sectors and skill ranges, improved connectivity around the NEC and access to new services and facilities. We support the intention of the Councils to undertake a Health Needs and Impact Assessment, across an appropriate study area for the NEC, in order to better understand the challenges and issues faced in neighbouring wards, so as to link into opportunities that will arise in NEC.

As stated within our response to Question 5 we generally support the application of local plan accessibility in the NEC. This standard is meeting Part M of the Building Regulations, however due to the requirements of meeting a higher than normal housing number target on the Site, we require flexibility on how the standard is applied. It is important that the Cambridge Local Plan accessibility standards offers flexibility on how the standards are achieved across the many elements of the new masterplanned scheme. While designing for and incorporating accessibility standards is also accepted as a progressive way to future-proof new housing, it is important the standards do not affect the ability of the scheme to meet the density and the target housing required. Currently the Cambridge Local Plan has adopted the optional standard Part M4(2) and has also adopted M4(3) based on a percentage, which is still higher than the national standards, this may have an adverse impact on our scheme.

Question 84: Do you have any other comments about the North East Cambridge area and/or AAP? Are there other issues and alternatives that the councils should consider? If you wish to make suggestions, please provide your comments.

We would encourage a specific section on education and health provision within the NEC, noting the likelihood that if on-site provision is required, it may require different formats/approaches on how such provision is made i.e. traditional forms of provision in Cambridgeshire are unlikely to be suitable in a high density urban regeneration scheme of this nature.

If off-site provision is considered to be more appropriate, comment should be given on how and where need is expected to be accommodated (for instance it may be more appropriate to extend existing or proposed schools in Cambridge, to create additional Forms of Entry, rather than have a lower number of Forms of Entry on-site that falls below the recommended minimum sizes).

Introduction

Cambridge City Council and South Cambridgeshire District Council is consulting on Issues & Options for the North East Cambridge AAP. The consultation deadline is 25th March 2019. The draft response on behalf of U+I Group PLC ('U+I') is set out below. U+I have been selected by the landowners Anglian Water and Cambridge City Council as Master Developer for land outlined in red in the accompanying Site Plan ('the Site'). It is noted that Cambridge City Council also own other land beyond the Site, which may be the subject of other representations.

The representations contained herein relate primarily to the development intentions for the Site, but also in the context of the wider AAP area (as sites within the AAP boundary are largely intrinsically linked).

Representations

Question 1: Do you agree with changing the name of the plan to the 'North East Cambridge Area Action Plan'?

It is recognised that there is a need for a collective reference for the AAP area. This will provide consistency and clearer definition as the process evolves. Whilst it is inevitable that sub-areas of the AAP will emerge with different branding names and strategies, this will have more relevance to the individual sub-area concerned, in creating identity when publicising forthcoming planning applications through to marketing/sales disposals.

Question 2: Is the proposed boundary the most appropriate one for the AAP?

Generally, we support the proposed boundary for the AAP area. We would, however, make two observations/comments.

Firstly, it seems logical to include the site of Cambridge Regional College ('CRC') within the boundary. It is noted that in paragraph 3.5 comment is made that it is not expected to undergo major change in the way other sites across NEC are. However, CRC considers itself to be 'one of the best Further Education Colleges in the country for 16-18 year old level 3 achievement and a leading apprenticeship provider, with thousands of full time students and apprentices currently in training'. The significant range of vocational courses it offers could be positively utilised to support the long-term construction process around NEC (e.g. architectural technology, mechanical engineering, electrical, carpentry, bricklaying courses and apprenticeships), and then the on-going operational phases of the different sub-areas of NEC (e.g. from courses relating to biological science for industry, laboratory technicians and computing technologies, to business and catering and hospitality). It therefore has the potential to play an important learning and development role in the future NEC area. The built form of the current campus appears to be relatively low density, with large areas of used for surface level car parking. Buildings are predominantly 2-3 storeys in height. With the transformation of NEC, recognising the different approaches to internalised trips/reduced car parking, and taller buildings, it would seem likely that the estate management of CRC might change in the future, and if so, it should be included in the AAP.

Secondly, we would comment that, owing to the nature of NEC, development is likely to be high density, optimising the use of all land to work efficiently and effectively. The strategy for on-site Public Open Space is likely to focus on qualitative provision, than quantitative, with a stronger emphasis on formal recreational and leisure space than informal open space. Access to the latter however, is likely to be facilitated through new and improved connections to the east (potentially including land to the east of the railway line north of Cambridge North Train Station, to the river) and north (potentially including land to the north of the A14, such as Land to the south of Cambridge Road, and land including/extending Milton Country Park) of NEC. We would therefore simply pose the question about whether there is a need to include within the AAP boundary additional land that could provide informal open space, biodiversity and drainage functions, which might otherwise not be achievable within the single control of the NEC boundary. It is considered that land to the north and east of the current AAP boundary would primarily be used to facilitate access to green infrastructure for NEC.

Question 3: In this chapter have we correctly identified the physical characteristics of the North East Cambridge area and its surroundings?

Generally, yes. However, we consider it might be beneficial to include more information about the composition of site areas. For instance, on the employment parks, providing details about site area, total floorspace of buildings on the park (including extant planning consents) and the range of authorised planning uses e.g. % B1a uses, %B1b uses, estimated no. of employees, audit of authorised car parking spaces, audit of public open space (estimated total hectares). This would help to inform a baseline of land use within NEC, and then contribute in developing future strategy e.g. highway trip budget, employment strategy, connectivity and green infrastructure etc.
We would also note that it would be beneficial to have mapping information available relating to the environmental constraints identified e.g. noise, air quality, odour, important habitats.
Finally, it would be beneficial to show the broader extents of key infrastructure for NEC, including the full Chisholm Trail link (connecting NEC to Cambridge City, and the south of Cambridge (Addenbrookes), committed routes for other new cycle, pedestrian and public transport in and around the City, and the proposed Greenways link to Waterbeach).

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

In general, yes. However, we note that there is no reference to Archaeology and Heritage, and would suggest that comment is given about this, even if it is considered that NEC has limited archaeological significance. In terms of heritage, whilst we believe that there are no listed buildings, conservation areas, or other notable heritage constraints within NEC, the intention for taller buildings in NEC will need to be more widely considered in respect of longer-distant views and townscape issues (historic core of Cambridge). Taller buildings may also have potential implications for Air Safeguarding Zones (consultation required with Marshall Airport and the Ministry of Defence on structures over 15m in height), and the Mullard Radio Astronomy Observatory (consultation with the University of Cambridge). We acknowledge that the issue of building heights and taller buildings is likely to be assessed as part of the on-going Landscape Character and Visual Impact Assessment that is being undertaken by Cambridge City Council (it is understood that a 'Stage 1' exercise has already been commissioned), and that the findings are then likely to inform future stages of this AAP process.

We would also suggest consideration be given to the inclusion of Green Belt boundaries around NEC. This will help provide clarity to interested parties that all land envisaged for development and associated physical infrastructure will be accommodated on non-Green Belt land. It will also help to provide reassurance that the development aspirations for NEC will not automatically lead to further development beyond the identified boundaries, unless it is deemed to be 'appropriate development' (i.e. not 'inappropriate' as defined in the National Planning Policy Framework'), or that exceptional circumstances are demonstrated in future Local Plans, or a Very Special Circumstances argument is made to support development via a planning application process. In all cases, strict mechanisms for controlling additional future development beyond NEC will apply.

Reference should also be made to the presence of UKPN's overhead power cables (132KV) that span across the AAP boundary. In terms of ensuring optimum reuse of the Site (and indeed other sites, including Cambridge Science Park), we would support a policy seeking their diversion underground.

Question 5: Do you agree with the proposed Vision for the future of the North East Cambridge area? If not, what might you change?

Yes, we support the proposed Vision for NEC. The addition of the word 'culturally' might benefit this Vision further (in the context of 'North East Cambridge - a socially, culturally, and economically inclusive....)

Question 6: Do you agree with the overarching Objectives? If not, what might you change?

Generally, we support the overarching Objectives. The addition of the words 'Natural Capital' might benefit Objective 7 further (in the context of '...connecting and improving biodiversity to achieve a Natural Capital net gain....)

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

It is noted that the Concept Plan can only be treated as indicative at this stage in the AAP process, until the outcomes of the various Supporting Studies are known (notably Landscape Character and Visual Impact Assessment, Development Capacity Study, NEC AAP Transport Assessment, NEC Development Viability Assessment, NEC Infrastructure Delivery Plan), and wider consultation with relevant interested parties (e.g. landowners, developers, local communities, local authority bodies etc) has been carried out.

We support the residential-led mixed use allocation for the Site. We support the aspiration to create high quality pedestrian, cycle and public transport connectivity across the AAP area. We support the indication that a Mixed Use District Centre will be provided on the Site though we would suggest that its optimal location can only be determined after further study and masterplanning work. There may also be a need to include an additional Mixed Use Local Centre in the northern half of the Site (subject to further Masterplanning and an assessment on accessibility). We support the intention to provide and integrate Green Infrastructure throughout the AAP boundary, but what provision is made (and how/where it will be provided) will need to be determined following further studies/assessment and Masterplanning. Further consideration will need to be given to the suggested Industrial Development Sites in the north east corner of the Site, to understand what the rationale is for proposing to relocate existing industrial land at Nuffield Road and Cowley Road, to another part of the AAP site. It is assumed that the suggestion is made on the basis that it will provide noise abatement from the A14 to the new residential elements of the Site. However, we consider that there may be other more preferable solutions for controlling noise and, in Masterplanning terms it is less desirable bringing industrial-related traffic through a predominantly residential site. In the absence of clear justification for seeking relocation of industrial uses, we cannot support the industrial element of the proposal.

We aren't yet persuaded that the proposed location and quantum of industrial use is optimal. In particular we have concerns that this is currently shown at the furthest point from strategic highway connections. We also believe that different models and formats of industrial development should be further explored, specifically whether this should be concentrated in a single location, or whether it might be incorporated within a mixed-use approach throughout the Site.

We do not necessarily agree that the Site represents the best opportunity with the overall AAP area to accommodate a significant concentration of industrial uses in a single location.

We would suggest that the Cambridge Business Park is shaded as an Opportunity for Employment Intensification.

In addition to our response for Question 2, we would suggest that the CRC land we would suggest that this land is included within the AAP boundary, and that a new shading is applied that refers to an Opportunity for Education Intensification.

Question 8: Do you agree that outside of the existing business areas, the eastern part of the North East Cambridge AAP area (i.e. the area east of Milton Road) should provide a higher density mixed use residential led area with intensified employment, relocation of existing industrial uses and other supporting uses?

Generally, we support the initial development intentions for the area east of Milton Road. It is considered that this area could accommodate a high density mixed use residential-led development following the relocation of the existing Cambridge Water Recycling Centre and other industrial uses (subject to viability and finding suitable relocation site(s)) from the Site. A comprehensive, design-led, approach across the AAP will help maximise the redevelopment potential of a significant brownfield site in a highly sustainable location.

Question 9: Should Nuffield Road Industrial Estate be redeveloped for residential mixed use development?

Yes, we agree that consideration should be given to relocating existing industrial uses on the Nuffield Road Industrial Estate, in preference for higher density residential-led mixed use redevelopment. Consideration should be given to the viability of doing so (industrial land values are currently relatively high), and where existing businesses will be relocated. An Industrial Relocation Strategy might be appropriate, in order to understand what factors are important to businesses e.g. last mile strategies and what alternative sites might be available to accommodate relocation requirements. ]

As outlined in Question 7, the suggestion to relocate industrial uses from Nuffield Road Industrial Estate to the north east corner of the Site needs to be explained and justified. At this stage we do not support the suggestion to relocate industrial uses to the north-east corner of the Site.

Question 10: Do you agree that opportunities should be explored to intensify and diversify existing business areas? If so, with what sort of uses?

Yes, we broadly support this suggestion, subject to the establishment of a robust and equitable approach to Highways Trip Budget apportionment and s106 tariff system across the wider AAP area. The Cambridge Science Park was first established on the principle of accommodating 1-2 storey, low density commercial buildings within an attractive strategic landscape/parkland setting. Whilst much of the strategic landscaping remains, latter phases of the Science Park have sought to intensify development density, with taller buildings, lower car parking provision, and limited on-plot landscaping (other than to lessen/soften the impact of new development). This approach has been complemented by the introduction of Cambridge North Station Interchange, which has significantly improved accessibility via non-car modes. The growth aspirations now anticipated for the AAP area signals a radical change in approach to new development. New residential communities will be supported by existing and intensified employment and educational opportunities, potentially providing live and work/learning opportunities within walking/cycling distance of each other. Furthermore, access to inter alia Cambridge North, the Guided Busway, and the Chisholm Trail will support accessibility to existing business areas from a much wider catchment, therefore helping to improve the means of accessing work without the need to do so by car.

Opportunities to provide a greater quantum and diversity of employment should be encouraged. This will consolidate and strengthen the concept of the Cambridge Phenomenon, by creating a greater range and quantum of high quality accommodation for new businesses, in close proximity to a critical mass of similar businesses, thereby helping to support knowledge sharing and collaboration through co-location.

In order to promote diversity of employment types, planning policy consideration might be given to encouraging a certain percentage of 'affordable employment', to support the growth of new start-up businesses that require the same close links with similar businesses but cannot afford (and do not currently need) accommodation that becomes available.

Question 11: Are there any particular land uses that should be accommodated in the North East Cambridge area?

The North East Cambridge area should support any use that demonstrably contributes to the Vision and Objectives of the AAP area.
The AAP provides a significant opportunity to create thousands of new homes in a highly sustainable location. The growth of housing in this area will be supported by the economic benefits derived from the long-established science, innovation and business parks (many of which will be intensified), that have collectively grown from the success of clustering knowledge-based industries in close proximity of one another. The housing element of the Site will improve supply and affordability of high quality new homes to the many thousands of employees on these parks, helping to reduce the number of car movements on Milton Road. New homes and jobs on the scale envisage will need to be served by a number of social, retail, community, health, education, leisure and recreation facilities,

Question 12: What uses or activities should be included within the North East Cambridge AAP area which will create a district of culture, creativity and interest that will help create a successful community where people will choose to live and work and play?

It is considered that the inclusion of schools, community facilities, retail and leisure uses, open space, and transport services, in conjunction with walking and cycling connections to neighbouring areas will provide the attributes of a successful community.

The NEC AAP must recognise the wider role it plays in creating opportunities for surrounding communities, of which two neighbouring wards - East Chesterton and Kings Hedges - currently suffer from high levels of deprivation (included in the top three of most deprived wards in Cambridgeshire). The benefits of the AAP area should extend to these areas, to create new employment, education, social, leisure and recreation, health and community opportunities. Where new facilities are introduced to areas experiencing deprivation, a key challenge for optimising use of such facilities is affordability. Free or subsidised charging mechanisms should therefore be considered when providing new facilities for instance e.g. hire of sports pitches, meeting rooms etc.

It should, however, be recognised (and indeed it is in Question 79) that the ambitious development aspirations for the Site and wider AAP area will take a number of years to comprehensively plan and deliver. Certain elements will be possible to deliver early. Notwithstanding this, there is the opportunity to introduce 'meanwhile/worthwhile' uses the area as the transition progresses. Meanwhile/worthwhile uses offer creative and innovative ways of optimising sites on a stop-gap basis, creating a temporary opportunity to capture economic and/or social benefits for the wider area in the period between the closure/or reduction of an existing site operation and the commencement of the intended new development.

Question 13: Should the AAP require developments in the North East Cambridge AAP area to apply Healthy Towns principles?

NEC will provide a considerable opportunity for creating a healthy new community, and supporting neighbouring communities, through access to high quality housing, a design approach founded on sustainable modes of travel (walkable neighbourhoods), and improved employment, shopping, health, education, leisure and recreational opportunities. We also support the intended preparation of the Health Impact and Needs Assessment for NEC, which will take account of the wider deprivation challenges faced in the neighbouring wards of East Chesterton and Kings Hedges.

Question 14: How should the AAP recognise and make best use of the existing and potential new links between the AAP area and the CRC (Cambridge Regional College)?

Please see our response to Question 2.

Question 15: Should clusters of taller buildings around areas of high accessibility including district and local centres and transport stops form part of the design-led approach to this new city district?

We strongly support the principle that the greatest development densities should be located in the areas of greatest accessibility and public amenity. This maximises the potential for sustainable travel patterns and establishes a critical weight of local demand for leisure, cultural and retail uses.

It is important to note that 'high-density' does not automatically mean 'tall' and that compact mid-rise development can often be denser than taller development, particular where the latter is compensated for by a smaller overall development footprint. Compact mid-rise also typically enables a wider range of dwelling types and external amenity space, meeting a wider range housing needs.

We favour a 'transect' based approach to masterplanning which will ensure the density, scale, typology, and uses of development are allocated across the site as a whole and within each neighbourhood in a coordinated way, following the accessibility principle described above and responding to the opportunities and constraints of the Site. This may not mean 'clusters' - it could for example mean that the highest densities are located in 'corridors' along the primary streets, and/or at edges where having denser development acts to shelter lower-scale development from adjacent visual or noise intrusion. The masterplan will be backed up by a design code that will identify/mandate appropriate typologies for achieving the requisite densities in ways that are acceptable in other respects.

In addition to accessibility and other local factors, it is important to note that the extent and location of denser development will be affected by a range of detailed studies and appraisals (including Landscape Character and Visual Impact Assessment), that will recognise - and then balance - the challenges of creating areas of higher density and taller buildings in a highly sustainable location that is, nonetheless, on the edge of Cambridge with areas of open countryside beyond. This may also militate against achieving density through height.

Question 16: Should the AAP include any or a combination of the options below to improve pedestrian and cycling connectivity through the site and to the surrounding area?

A - Create a strong east-west axis to unite Cambridge North Station with Cambridge Science Park across Milton Road. This pedestrian and cycle corridor would be integrated into the wider green infrastructure network to create a pleasant and enjoyable route for people to travel through and around the site. The route could also allow other sustainable forms of transport to connect across Milton Road.

Yes. A strong east-west axis should be included to connect the different parts and proposed uses within NEC, and to encourage movement within the site by sustainable modes of transport.

B - Improve north-south movement between the Cowley Road part of the site and Nuffield Road. Through the redevelopment of the Nuffield Road area of NEC, it will be important that new and existing residents have convenient and safe pedestrian and cycle access to the services and facilities that will be provided as part of the wider North East Cambridge area proposals.

Yes.
C - Upgrade connections to Milton Country Park by both foot and cycle. This would include improving access to the Jane Coston Bridge over the A14, the Waterbeach Greenway project including a new access under the A14 (see Transport Chapter), as well as the existing underpass along the river towpath.

Yes. It is considered that improvements to connections with Milton Country Park and with existing and proposed pedestrian and cycle routes will be important for the success of development within the AAP. It is anticipated that NEC will provide a high density residential development, to take advantage of the close proximity of employment areas and public transport services, but which might limit opportunities for large scale open space/recreation areas. Therefore, it will be important to ensure that any proposal for an underpass will maximise connectivity through the Site, capitalising on permeability and wider Green Infrastructure initiatives (e.g. Waterbeach Greenway, Chisholm Trail, improving the public realm function of the 1st Drain etc).

D - Provide another Cambridge Guided Bus stop to serve a new District Centre located to the east side of Milton Road.

We support the suggestion to improve public transport accessibility around NEC but further work should be undertaken to determine whether an additional 'guided' busway stop is required or whether a 'normal' bus service, which could feasibly use the same buses as those on the Busway, could deliver the same benefits.

E - Increase ease of movement across the sites by opening up opportunities to walk and cycle through areas where this is currently difficult, for example Cambridge Business Park and the Cambridge Science Park improving access to the Kings Hedges and East Chesterton areas as well as the City beyond.

We very much support opportunities to increase the ease and convenience of walking and cycling movements across sites in NEC, as this will strengthen the concept of promoting internalised trips and reduce the reliance on travel by car.

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

It is noted that the River Cam towpath is identified as a route within the Waterbeach Greenway project, and it would be appropriate to take the opportunity to provide a pedestrian and cycling connection from this route into NEC, subject to the availability of funding.

The high density redevelopment of NEC is unlikely to achieve the level of Public Open Space that might otherwise be required under local plan policy. The focus is instead likely to be on securing high quality, flexible-use open space on-site, and improving/providing new connections to informal open space networks to the north and east of the AAP area (including the Waterbeach Greenway). Accordingly, an appropriate means of accessing off-site Green Infrastructure for NEC will be required, and the suggestion of a pedestrian/cycle bridge would facilitate this.

Please see our responses to Questions 2 and 7.

Question 18: Which of the following options would best improve connectivity across Milton Road between Cambridge North Station and Cambridge Science Park?
A - One or more new 'green bridges' for pedestrians and cycles could be provided over Milton Road. The bridges could form part of the proposed green infrastructure strategy for NEC, creating a substantial green/ecological link(s) over the road.
B - Subject to viability and feasibility testing, Milton Road could be 'cut-in' or tunnelled below ground in order to create a pedestrian and cycle friendly environment at street level. This option would allow for significant improvements to the street which would be more pleasurable for people to walk and cycle through.
C - Milton Road could be significantly altered to rebalance the road in a way that reduces the dominance of the road, including rationalising (reducing) the number of junctions between the Guided Busway and the A14 as well as prioritising walking, cycling and public transport users.
D - Connectivity across Milton Road could be improved through other measures. We would welcome any other suggestions that would improve the east-west connectivity through the site.
E - Other ways of improving connections (please specify)

In response to all five options listed above, we generally support the principle for securing high quality east-west connectivity. However, the means of crossing Milton Road will involve a range of complex issues, which cannot be determined at this stage. The crossing solution(s) should not ultimately be compromised by concerns about short-term disruption and inconvenience. The east-west axis will be fundamental in the overall success of NEC, and the justification for internalising trips will be partly made on the basis that pedestrian and cycle connectivity across NEC will be safe and convenient (and therefore likely to be commonly used as a means of travel).

Option A is considered to be the preferred option as it provides the opportunity to create a substantial green link over the road without adversely affect the flow of traffic on Milton Road, which has existing network capacity issues. It will also limit the impact on the operation of the Milton Road during construction when compared with either Option B and C.

Option B would likely result in significant disruption to the road network during construction and would likely require the lowering or redirecting or Statutory Undertakers Utilities. Both Option B and C would result in alterations to the access junctions into the Science Park and the Site, both of which have limited access opportunities for their respective sizes.

Question 19: Should development within the North East Cambridge area be more visible from Milton Road, and provide a high quality frontage to help create a new urban character for this area?

We generally support the suggestion of making new development within NEC more visible from Milton Road and providing a high quality frontage to create a new urban character for the area. Milton Road is currently a highly car dominated environment, with a number of confusing junctions serving Cambridge Science Park and Cowley Road. However, it is noted that Milton Road acts as a key north / southbound route into and out of Cambridge, and the Milton Interchange forms part of the Strategic Road Network and connects Cambridge to the A14 (a major east to west route, which has recently been upgraded to improve capacity). Given the level of traffic using this stretch of the Milton Road to access the Strategic Road Network at this location, the potential to reduce traffic to provide a high quality new urban character for the area may be limited in the short term. Notwithstanding this, where Milton Road runs southwards the nature of the road starts to change and becomes more urban in nature, potentially becoming more conducive to active frontage and activity on the footway.

Question 20: Do you agree with proposals to include low levels of parking as part of creating a sustainable new city district focusing on non-car transport?

Yes, we generally support this principle NEC provides an opportunity to reduce levels of parking, as part of a package of transport measures including new and additional walking and cycling routes, public transport services, and car share schemes. However, we would also suggest that interim car parking strategies might need to be considered, to support 'pioneer' uses/development during transitional phases of NEC i.e. until the full package of transport infrastructure and initiatives can be fully realised. As new infrastructure/initiatives are introduced, interim car parking can be gradually phased out.

Question 21a: In order to minimise the number of private motor vehicles using Milton Road, should Cambridge Science Park as well as other existing employment areas in this area have a reduction in car parking provision from current levels?

We very much support opportunities to reduce the reliance on travel by car in and around NEC, and instead increase the ease and convenience of walking and cycling movements across sites in NEC, as this will strengthen the concept of promoting internalised trips.

Question 21b: Should this be extended to introduce the idea of a reduction with a more equitable distribution of car parking across both parts of the AAP area?

Yes, as part of a package of transport measures to encourage travel by sustainable modes of transport.

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

Yes, subject to further understanding of the requirements of businesses and the needs of residents. The North East Cambridge area could include a number of delivery/collection hubs.

Question 23: Should development within the North East Cambridge area use car barns for the storage of vehicles?

We support the idea of using car barns, as part of a wider package of parking solutions across NEC. Whilst it is recognised that private on-plot parking is unlikely to be widely encouraged, there will inevitably be demand from some residents to have access to the use of a car/secure car parking but this should be priced accordingly to the end user. Car barns provide communal access to parking, and are typically located in less convenient locations in order to discourage frequent use. As an example, if a car was needed to do a weekly shop, the resident would park outside their property to unload their car and then move the car to a car barn. Car barns can also be used by 'car clubs', so that a resident can book a car for a certain period of time but not have the long-term cost and use commitment to owning a private car. The versatility of car barns should also be recognised, as parking can be let on a temporary basis and, as trends change, can be converted into alternative uses to reduce car usage further.

Question 24: Within the North East Cambridge area green space can be provided in a number of forms including the following options. Which of the following would you support?
A - Green space within the site could be predominately provided through the introduction of a large multi-functional district scale green space. Taking inspiration from Parker's Piece in Cambridge, a new large space will provide flexible space that can be used throughout the year for a wide range of sport, recreation and leisure activities and include a sustainable drainage function. The sustainable drainage element would link into a system developed around the existing First Public Drain and the drainage system in the Science Park. The green space could be further supported by a number of smaller neighbourhood block scale open spaces dispersed across the site.
B - Green spaces within the site could be provided through a series of green spaces of a neighbourhood scale that will be distributed across the residential areas. These green spaces will also be connected to the green infrastructure network to further encourage walking and cycling. Again, these spaces will include a sustainable drainage function and link into the existing First Public Drain and the Science Park drainage system.
C - Enhanced connections and corridors within and beyond the site to improve the biodiversity and ecological value as well as capturing the essential Cambridge character of green fingers extending into urban areas. These corridors could also be focussed around the green space network and sustainable drainage and would reflect the NPPF net environmental gain requirement.
D - Green fingers to unite both sides of Milton Road and capitalise on the existing green networks.
E - Consideration of the site edges - enhancement of the existing structural edge landscape and creating new structural landscape at strategic points within and on the edge of NEC. This would also enhance the setting to the City on this important approach into the City.
F - Creation of enhanced pedestrian and cycle connectivity to Milton Country Park and the River Cam corridor.

In response to all six options listed above, we support the principle for securing high quality green infrastructure across NEC. Subject to further capacity testing and Masterplanning, on-site provision might feasibly take the form of a larger green space for the whole NEC and complemented by smaller 'neighbourhood scale' spaces and enhanced connections and corridors to off-site green infrastructure. We aren't persuaded that Parkers Piece is an appropriate comparable for the size and function of this space but do consider that the green space should draw lessons from existing green spaces in Cambridge. However, in supporting the theme of innovation at all stages of the development it will be important to consider smart solutions for the open space strategy, maximising flexibility across all areas of on-site open space. For instance, playing fields associated with on-site school provision should be available to the wider community, at times when it is not required by the school. Management and security issues will need to be carefully considered in this regard. Landscape vegetation should encourage biodiversity, whilst also performing softening/screening functions. Formal playspace should be able to accommodate multi-use activities during the day and evening and throughout the year. Green infrastructure might incorporate elements of food growing e.g. fruit trees, herbs, and vegetables, enabling free access to foods that help promote healthier lifestyles.

In terms of the suggestion of how open space will be provided (and in what format and amount), this cannot be determined at this stage of the process. A series of studies and assessments have been or are being commissioned by Cambridge City Council, which will help inform development principles and Masterplanning. Consultation will also need to be carried out with a number of interested parties, including landowners, developers, local communities and local authority bodies. Therefore, we are neither supporting nor objecting to any of the suggested options at this stage.

Question 25: As set out in this chapter there are a range of public transport, cycling and walking schemes planned which will improve access to the North East Cambridge area. What other measures should be explored to improve access to this area?

We generally support the suggested options for improving public transport, cycling and walking accessibility around NEC. The proposed Waterbeach Greenway should be directed through the Site, to create a coherent route from Waterbeach to the station. This will allow future residents of the Site to cycle to the station helping to providing a means of travel for the 'first mile / last mile' of the journey to / from the station.

A new route for a busway from the proposed Waterbeach development should be routed through the Site down to Cambridge North Station. Stops on the route could form transport interchanges linking to other bus routes and cycle routes. High quality cycle links should be implemented to connect into existing infrastructure such as the Chisholm Trail.

The route of these two transport spines through the Site will help develop a single coherent sustainable transport corridor down to the station allowing seamless interchanges between transport modes where the routes intersect with one another. The interchanges will be located within a high-quality urban environment close to high density district centres and attractive locations encouraging linked trips and improving access to the district centres by public transport.
It will important to ensure that consideration is always given to promoting access beyond the AAP boundary (as currently shown), such as recognising the education/social role that CRC plays in the west, the retail and leisure/recreational/biodiversity roles of Tesco and Milton Country Park in the north, the leisure/recreational/biodiversity role of the river and green corridors in the east, and the existing Cambridge communities in the south.

Question 26: Do you agree that the AAP should be seeking a very low share of journeys to be made by car compared to other more sustainable means like walking, cycling and public transport to and from, and within the area?

We support the concept of encouraging a greater share of non-car modes of travel for NEC, but note that it is a concept that will need to be accepted by all landowners/occupiers in the AAP boundary in order for it to be successfully implemented. This is broadly in accordance with the advice from the Ely to Cambridge Transport Study, and will be further tested in the NEC AAP Transport Assessment work (due to be commissioned).

Question 27: Do you have any comments on the highway 'trip budget' approach, and how we can reduce the need for people to travel to and within the area by car?

We support the principle of a 'trip budget' as there is limited scope for large scale engineering interventions to create more capacity on the road network. However, the trip budget must be carefully considered and tested to ensure that it is both suitable and realistic. Appropriate measures will need to be employed if the trip budget is exceeded. The monitoring process will need to be carefully considered, as various land uses across the AAP site will be allocated a share of the trip budget.

Question 28: Do you agree that car parking associated with new developments should be low, and we should take the opportunity to reduce car parking in existing developments (alongside the other measures to improve access by means other than the car)?

We generally support the concept of encouraging a greater share of non-car modes of travel for NEC. This is broadly in accordance with the advice from the Ely to Cambridge Transport Study, and will be further tested in the NEC AAP Transport Assessment work (due to be commissioned). It is recognised that many existing employment uses, such as those in Cambridge Science Park, St John's Innovation Park and Cambridge Business Park, will have authorised car parking at significantly higher levels than what is now intended for NEC. We would support the Councils working with various landowners in exploring innovative/incentivised ways of reducing car usage from those sites.

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

We support the suggestion of requiring high levels of cycle parking from new developments. This approach will be supported by the new cycling infrastructure that is planned for Cambridge, including the Chisholm Trail and Waterbeach Greenways. Cycling helps support healthy lifestyles, and is a viable means of travelling around a compact city, assuming that safe and convenient routes and secure/covered parking can be provided. New and existing workplaces can be encouraged to provide showers, changing facilities and lockers to encourage staff to cycle into work.

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

Cycling is key to achieving a mode split and demand must be met, and therefore we support the suggestion of innovative solutions to cycle parking. As part of further capacity testing, Masterplanning and detailed design, consideration will be given to innovative storage solutions (using domestic and international examples) that enables cycle parking to be integrated appropriately into the public realm. The concept of micromobility should also be embraced, with provision made for parking dockless bikes to ensure that they are not left in inconsiderate locations such as the footway.

Question 31: What additional factors should we also be considering to encourage cycling use (e.g. requiring new office buildings to include secure cycle parking, shower facilities and lockers)?

New office buildings should include covered, secure cycle storage, showers and lockers. The cycle parking should also be conveniently located at basement/ground floor level or within easy access of lifts capable of transferring bikes between levels. Where possible segregated access for cyclists should be provided to minimise the conflict with pedestrians and vehicles accessing buildings.

Question 32: How do we design and plan for a place that makes the best use of current technologies and is also future proofed to respond to changing technologies over time?

Energy strategies
We will expect development on the Site to have a very low 'in use' energy demand, through robust design of built fabric and services. This will make it easier to meet more of the scheme's energy demand from renewable and low carbon energy sources - and in some case may allow a 'net positive' energy balance to be achieved. Implications for wider energy networks should also be considered, with consideration of energy storage and demand control options at building and community level.

Form and fabric

Development within the Site will be designed, at both masterplan and building scale, to result in minimal energy use through sensitive consideration of site conditions and a robust approach to fabric performance, using passive design strategies to achieve good comfort, day-lighting and air-quality.

Building services

Developments should ensure they build on high quality design of form and fabric by specifying robust and efficient building services. If care has been taken in the design of the built fabric, it should be simpler for efficient building services to meet the needs of those who live and work in a building.

Energy generation and supply

Once the gross energy demand for the proposed development has been reduced through efficient built form and services, it will become possible to evaluate how a greater proportion of its needs can be met through renewable and low carbon energy sources.

Provision for electric charging points for vehicles should be implemented to ensure that both residents and workers have access to electric car charging points. Way-finding points and real time journey time information should be implemented across the Site to ensure people have accurate up to date travel information.

Delivery hubs should be provided on the periphery of the site to intercept large delivery vehicles from accessing the site. This will also help to consolidate deliveries and reduce the need for large vehicles to enter the Site, with smaller electric vehicles providing the final leg of the journey to the front door of the residence or workplace.

Subterranean bins should be provided on the Site to minimise space requirements for waste storage and provide a secure location for the bins.

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

It is considered unlikely that an at grade crossing can be located to link the Science Park with the station due to capacity constraints on Milton Road. A well-designed overpass for pedestrians and cyclists may provide the best option to effectively reduce severance caused by Milton Road and link the station with the Science Park. The journey from the station to the Science Park, will be the last / first mile of commuter journey and micromobility solutions such as dockless e-bikes should be provided to support the movement on this link.

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

The knowledge-based cluster around Cambridge Science Park, St John's Innovation Park, and Cambridge Business Park is internationally recognised, and the significant economic role that it offers to NEC must be fully harnessed to encourage complementary industries (Artificial Intelligence, R+D and laboratories for smaller emerging businesses that need the cluster benefits, maker-space etc) and optimise further employment opportunities. We would therefore expect a range (in terms of use and size) of employment spaces across NEC, including Science, Research & Development and Technology-related employment. However, in advocating innovation throughout NEC, policy limitations should not be imposed that unduly restrict any particular use at this stage.

Question 35: In particular, should the plan require delivery of:
A - a flexible range of unit types and sizes, including for start-ups and Small and Medium Sized Enterprises (SMEs);
B - Specialist uses like commercial laboratory space;
C - hybrid buildings capable of a mix of uses, incorporating offices and manufacturing uses.
D - shared social spaces, for example central hubs, cafes.
E - Others (please specify).

We generally support all of the suggested options at this stage, and would seek inclusion of corporate headquarters within category A. These options should equally be applied to proposals for meanwhile/worthwhile uses, in order to optimise economic development benefits and promote innovation at the earlier stages of the development process for NEC.

Question 36: Which of the following approaches should the AAP take to existing industrial uses in the North East Cambridge area?
A - seek to relocate industrial uses away from the North East Cambridge area?
NEC represents a significant and unique opportunity to create a new and innovative high-density, high quality, mixed use Quarter for Cambridge and its surrounding area. The opportunity is dependent on Housing Infrastructure Funding that will facilitate the relocation of the Water Treatment Works, and optimise the quantum of new housing across the Site. Whilst it is recognised that other, non-residential uses, will also be needed in NEC in order to promote multi-functioning mixed communities and internalised trips, capacity testing and Masterplanning will need to carefully identify what uses (and how much) will be appropriate. Whilst the prospect of utilising some of the Site for industrial use has not, at this stage, been discounted, justification for the need and location of such a use will need to be very carefully considered. A greater understanding of industrial need is therefore required, and in particular how essential it is for certain businesses to be in Cambridge. Consideration should also be given to whether existing businesses are compatible with residential neighbourhoods, as if so, there may be scope to incorporate industrial (i.e. b1c) accommodation within a mixed use development. This might, for instance, include ground floor workshops/maker spaces where noise, odour, other forms of pollution, and type of deliveries will not give rise to unacceptable living conditions for neighbouring properties. For existing businesses where there is not a demonstrable need to be in Cambridge, relocation options outside the NEC should be considered.

B - seek innovative approaches to supporting uses on site as part of a mixed use City District?
See response to A, above.

Question 37: Are there particular uses that should be retained in the area or moved elsewhere?

See response to A, above. The AAP should set out the strategy for determining the needs of individual businesses (and whether there is an operational imperative to be closely related to Cambridge, and how the relocation of existing industrial uses can be appropriately implemented..

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

The residential ambitions and opportunities in NEC (and particularly the Site) will need to be fully understood and embraced in order for the Vision and Objectives of the AAP to be realised. For the high density levels of new housing envisaged, innovation will be essential at all stages and in all forms. Traditional approaches to housing in Cambridge are unlikely to be appropriate. Housing will be made available for a much wider market than might otherwise be expected for a new settlement/strategic urban extension elsewhere in the county (e.g. Northstowe, Waterbeach, Cambourne), including that which is more aligned to smaller household sizes e.g. students, post-graduates, young professionals, and older persons looking to downsize. Where family housing is to be provided, it will require 'smarter-space' solutions to reflect the Site-wide high density approach.
A greater understanding of need and demand, market trends and viability will be needed to define housing requirements for NEC in later stages of the AAP process.

Question 39: Should the AAP seek provision for housing for essential local workers and/or specific housing provided by employers (i.e. tethered accommodation outside of any affordable housing contribution)?

Yes, see response to Question 38.

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

We generally support the suggestion of having a challenging target for the provision of affordable housing. There is a chronic shortfall of affordable housing in South Cambridgeshire and Cambridge City, and the residential growth aspirations of NEC could make a significant contribution in reducing housing shortfall. It is also important to ensure that there are a range of homes of different sizes and tenures to achieve mixed and balanced communities. However, it is also important to ensure that the policy is sufficiently flexible to address viability challenges, and takes a pragmatic approach when recognising how different types of housing are provided and thereafter managed and maintained e.g. less reliance on traditional approaches of 'pepper-potting' etc. There is a significant cost in delivering the level and type of development envisaged and it will be essential to ensure that delivery of the development can be secured on a viable basis. Consideration must also be given to exploring other means of making housing more widely accessible, such as through PRS for instance.

Question 41: Should an element of the affordable housing provision be targeted at essential local workers?

We generally support this suggestion, but a more detailed understanding of housing need and demand in the area, and indeed an understanding of what key employers in the area require, should be undertaking before developing an AAP-specific affordable housing policy.

Question 42: Should the AAP require a proportion of development to provide custom build opportunities?

We generally support this suggestion, but again a greater understanding of demand, need and viability is required. Consideration should be given to examples where successful custom-build housing has been delivered, such as Marmalade Lane, Cambridge's first co-housing community made up of 42 custom build homes.

Question 43: Should the AAP allow a proportion of purpose built HMOs and include policy controls on the clustering of HMOs?

We support the suggestion of creating more shared living and co-living housing opportunities, as these can help improve variety and access to more affordable, good quality accommodation. This type of housing typically incorporates shared services and facilities and can benefit both younger and older aged groups. However, again a greater understanding of demand, need and viability is required.

Question 44: Should the AAP include Private Rented Sector (PRS) as a potential housing option as part of a wider housing mix across the North East Cambridge area?

We generally support this suggestion, as it typically lends itself to earlier delivery, it can be part of an affordable housing mix, and may suit the needs of the adjoining employment base. Similar to HMO's, PRS development needs to be well-managed to integrate successfully. Again a greater understanding of demand, need and viability is required.

Question 45: if PRS is to be supported, what specific policy requirements should we consider putting in place to manage its provision and to ensure it contributes towards creating a mixed and sustainable community?

We would suggest that this needs to be considered in greater detail, including need and demand, management of facilities, services, and amenities should be well defined and required.

Question 46: Should PRS provide an affordable housing contribution?

Subject to viability, policy requirements will need to reflect the distinct economics of this tenure. In most cases (as in London) this is acknowledging that a form of Discounted Market Rent (capped at 80% of Open Market Rents) is most applicable, as this can be managed by a non-Registered Provider and therefore enables tenure blind blocks to be delivered by PRS operators.

Question 47: What 'clawback' mechanisms should be included to secure the value of the affordable housing to meet local needs if the homes are converted to another tenure?

Typically a profit sharing mechanism up to an agreed cap (cap to be reflective of the affordable housing contribution possible for open market sale units - i.e. the value difference between a private for sale scheme at 40% and a PRS scheme at 30%)

Question 48: What would be a suitable period to require the retention of private rented homes in that tenure and what compensation mechanisms are needed if such homes are sold into a different tenure before the end of the period?

We would suggest a period of 15 years with clawback as outlined in Questions 46 and 47. This period is proposed in the London Plan and is generally accepted by institutional investors

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

We consider that this should be agreed with each operator, and should be brief and relevant to planning matters. This could ensure all prospective tenants are offered the option of a three year tenancy.

Question 50: Should the area provide for other forms of specialist housing (including older people, students & travellers), either onsite or through seeking contributions for off-site provision?

We generally support this suggestion, but again a greater understanding of demand, need and viability is required. A comprehensive analysis of the demographic portrait of Cambridge and its surrounding environs over the next 25 years should be undertaken to assess how new policy interventions - such as NEC (intensified housing and employment uses; new housing 'products' to promote affordability and variety), new transport initiatives to improve access to employment, shopping, leisure and recreation etc, may affect demand and supply of different forms of housing for the local population catchment. In terms of 'housing mix', this might then manifest into redefining 'mainstream' housing, to expand into other groups such as students/graduates, first-time buyers, those requiring good quality rental properties, downsizers, elderly care.

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

We generally support this suggestion. This is a standard that ensures appropriate homes are delivered that meet the needs of the occupants. However, there may be some formats where exceptions may be appropriate - for example co-living formats including student and young professional accommodation, housing for 'downsizers' etc. These groups may prefer smaller homes with greater shared space and it may be appropriate to provide for this need in the context of a balanced housing offer. However, in these cases we would expect there to be clear requirements around the nature and quality of shared space. We would also encourage pilot testing (on a smaller scale) of more innovative solutions to housing, which might include other micro-living models that have not yet been used in Cambridge but have proved successful in other UK/international cities.

Question 52: Should the AAP develop space standards for new purpose built HMOs?

All new housing should meet the Technical Housing Standards and offer adequate shared spaces to not only provide adequate space in a HMOs scenario but above all provide homes that are future proofed as people's lifestyle changes and needs such as working from home also emerge. Future-proofed housing is to offer adequate space for a wide range of scenarios, not only HMOs. A specifically-developed space standards for new purpose built HMOs may prove unnecessary or irrelevant if HMOs within the AAP is then not delivered through a purpose-built type. Please see our response to Question 51.

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

We support the principle of ensuring that all homes have adequate and appropriate access to outdoor space and support the aspiration for most homes to have some private outdoor space. We would, at this stage, question whether it is realistic to expect that 100% of dwellings will have direct access to an area of private amenity space, given the quantum of development envisaged and the range of different housing typologies that will be necessary to deliver this quantum. In situations where it isn't appropriate to deliver private outdoor space, convenient access to high quality communal and public spaces would be provided. Ultimately, a flexible approach to residential amenity space must be taken, incorporating elements such as roof gardens and balconies as well as elements such as private gardens.

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

We generally support this suggestion in principle. This standard is meeting Part M of the Building Regulations, however due to the requirements of meeting a higher than normal housing number target on the Site, we require flexibility on how the standard is applied. It is important that the Cambridge Local Plan accessibility standards offers flexibility on how the standards are achieved across the many elements of the new masterplanned scheme. While designing for and incorporating accessibility standards is also accepted as a progressive way to future-proof new housing, it is important the standards do not affect the ability of the scheme to meet the density and the target housing required. Currently the Cambridge Local Plan has adopted the optional standard Part M4(2) and has also adopted M4(3) based on a percentage, which is still higher than the national standards, this may have an adverse impact on our scheme.

Question 55: Do you agree with the range of considerations that the AAP will need to have regard to in planning for new retail and town centre provision in the North East Cambridge area? Are there other important factors we should be considering?

The ambitious intentions for NEC are likely to see the creation of thousands of new homes and intensified employment opportunities forming part of new mixed, balanced and prosperous new communities. This new 'Quarter' will therefore require district and local centres to help support and sustain it. Non-residential uses will help create vitality and vibrancy to NEC.

Question 56: Should the Councils be proposing a more multi-dimensional interpretation of the role of a town centre or high street for the North East Cambridge area, where retail is a key but not solely dominant element?

We generally support this suggestion. We would highlight the importance of seeking innovative, creative and flexible solutions across the Site and this will be applied when considering how a District or Local Centre is planned and delivered. Longer term trends (national, regional and local) relating to retail and leisure uses will need to be carefully considered in arriving at a strategy that will support the long term vitality and vibrancy of NEC.

Question 57: What community facilities are particularly needed in the North East Cambridge area?

Opportunities will exist to provide access to new services and facilities for residents of NEC and existing surrounding local communities. In terms of the latter, where there are higher levels of deprivation, the cost of using new facilities will need to take account of affordability issues to ensure the cost of use is not prohibitive to those on no/low incomes.
Provision will need to be informed by the NEC Community Facilities Audit, whilst also taking account of the growth assumptions of NEC (including sizes and tenures of housing, as this will have potentially very different outcomes on need). Provision of facilities should offer flexibility and multi-functional spaces.

Question 58: It is recognised that maximising the development potential of the North East Cambridge area may require a different approach to meeting the sport and open space needs of the new community. How might this be achieved?

See our response to Question 24. Owing to the ambitious development aspirations of the Site (and NEC) it will be necessary to consider a comprehensive package of solutions (on and off-site) for open space and recreational strategy. This strategy will be complemented by the various improvements to green infrastructure provision in and beyond the AAP boundary, facilitating greater access opportunities by walking and cycling.

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

See our response to Question 24.

Question 60: Should open space provision within the North East Cambridge area seek to provide for the widest variety of everyday structured and unstructured recreational opportunities, including walking, jogging, picnics, formal and informal play, casual sports, games, dog walking and youth recreation?

We generally support this suggestion. It will be important to ensure that all spaces within the Site are fully optimised, and creative/innovative solutions should be considered to allow for flexible/multi-functional uses.

Question 61: Where specific uses are required to provide of open space as part of the development, should the AAP allow for these to be met through multiple shared use (for example school playing fields & playing pitches for the general public)?

See our response to Question 24.

Question 62: Within this overall approach, in particular, which option do you prefer in relation to carbon reduction standards for residential development?
A - a 19% improvement on 2013 Building Regulations (the current Cambridge Local Plan standard); or
B - a requirement for carbon emissions to be reduced by a further 10% through the use of on-site renewable energy (the current South Cambridgeshire Local Plan standard); or
C - a 19% improvement on 2013 Building Regulations plus an additional 10% reduction through the use of on-site renewable energy (combining the current standards in the Local Plans); or
D - consider a higher standard and develop further evidence alongside the new joint Local Plan.

At this stage we support Option D. This is a complex area of policy setting due to the current grid decarbonisation and emerging guidance from different bodies such as the UKGBC task force, and the GLA London Plan. The context of the electricity grid decarbonisation should be considered to ensure that any targets set do not create perverse outcomes in the future over the timescales of the development and should consider the appropriateness of energy efficiency targets as well as carbon targets.

The AAP should aim to be exemplar while also drawing on the most up to date emerging evidence.

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

Yes, we generally support the AAP sustainable design and construction approaches set out. However with regard to water recycling we think that while water recycling can be an important part of reducing water consumption if used inappropriately can be unsustainable. Therefore we would expect a rounded view to be taken as to when it is most appropriate to apply the highest levels of water recycling (as required by the maximum BREEAM credits for water efficiency), including an understanding of maintenance and carbon efficiency.
Question 64: Do you support the proposal for the AAP to be clear that review mechanisms should be built into any planning permissions in order to reflect changes in policy regarding sustainable design and construction standards in local and national policy? What other mechanisms could be used?

Yes we think it is important to recognise that not all future scenarios are foreseeable and that in order to avoid perverse outcomes in future it may be necessary to reappraise the policy requirements so that the most up to date and relevant standards are applied where necessary, reasonable and practicable.

It may also be advisable to follow guidance from notable charities and NGOs (e.g. UKGBC)

Question 65: Do you support the plan requiring delivery of site wide approaches to issues such as energy and water, as well as the use of BREEAM Communities International Technical Standard at the masterplanning stage?

Subject to further Masterplanning, technical assessment and feasibility testing, we generally support the approach to site wide water proposed and support the approach to innovate energy infrastructure such as smart energy grids. We support the view that infrastructure necessary for decentralised energy should be explored early on in consultation with relevant parties and that consideration should be given to a range of technologies and approaches to ensure the approach with the lowest carbon overall can be identified and supported.

We fully support the principles in BREEAM Communities and believe that while certification often brings a certainty of outcomes it does not always. The effective outcomes of applying BREEAM communities at this stage should be subject to further consideration.

Question 66: Are there additional issues we should consider in developing the approach to deliver an exemplar development?

Consideration should be given to the embodied impacts of buildings and infrastructure installed as well as opportunities to support the circular economy. Consideration should also be given to embracing and supporting innovative smart-tech and infra-tech initiatives where feasible and viable to do so.

Question 67: What approach should the AAP take to ensure delivery of a net gain in biodiversity?

In terms of the Site, owing to the on-going uses of land e.g. Water Recycling Centre, driving range, former Park and Ride site, it is considered likely that it will have limited biodiversity value. It will be necessary, at the relevant stage in the process, to carry out site specific investigations on the potential suitability of habitat for protected species, and to consider mitigation where appropriate. If the assumption is correct, it seems reasonable to believe that the Site can deliver net gains in biodiversity. Notwithstanding this, sites within NEC may be asked to consider biodiversity collectively, to show how habitat mosaics and corridors can be delivered on a more strategic basis. In this event, the AAP will need to provide greater clarity on what process is likely to be followed, and how this will be applied to individual development schemes.

Consideration will also need to be given to increasing the amount of tree canopy cover in NEC.

Consideration should be given to where biodiversity enhancements opportunities exist in nearby areas as well so that the best opportunities for linkages beyond the site boundary are identified as well as ensuring the best opportunities locally can be realised if necessary to meet the net gain requirements.

Question 68: Should the AAP require developments in the area to integrate SMART technologies from the outset?

We generally support the suggestion that NEC should seek to integrate SMART technologies from the outset. As we have previously noted, we will seek to encourage innovative, creative and adaptable solutions throughout all elements of development on the Site. It will be important to consider preparation of a digital strategy for NEC, to seek optimum speeds for broadband/fibre, opportunities to integrate SMART technology in homes, businesses and other development around NEC.

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

We support innovation throughout all elements of development on the Site (and indeed NEC). Rather than committing to any specific type of solution at this stage, it will be necessary to understand whether innovative systems used on other sites, such as North West Cambridge, can be applied on the Site.

Question 70: Do you agree that the AAP should prioritise land that can feasibly be developed early? Are there any risks associated with this proposed approach?

The obvious challenge with sites seeking early release/delivery is how they demonstrate that development will not prejudice the wider delivery aspirations of NEC. Where landowners/developers can explain how development can be carried out in a coordinated/comprehensive manner, it seems reasonable to expect that early delivery can be achieved. A coordinated/comprehensive approach must fully ensure that all development complies with s106 tariff/highways trips budgets, in an equitable manner.

As discussed later in Questions 79 and 80, we would encourage a positive policy approach be taken in supporting temporary/meanwhile uses in order to activate the Site in its earlier development phases, and to optimise economic and social benefits in the local area.

Question 71: Should the AAP include a relocation strategy in preference to leaving this to the market to resolve?

The representations of landowners and occupiers will inform the approach. It is considered that the AAP will need to identify and define a strategy for key sites/uses to be relocated, but maintain flexibility for others. Notwithstanding this the NEC has significant potential to deliver economic, social and environmental benefits, and whilst there are a relatively small number of landowners, the strategic opportunities must not be compromised by one or more parties that are unwilling to support the delivery of the NEC. Accordingly, the Councils cannot discount the possibility of using their CPO powers if required.

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

An infrastructure delivery plan should be prepared for the North East Cambridge Area to identify the infrastructure required and the costs associated with those projects, in order to inform discussions on planning obligations. It would be reasonable to expect all development within the area to contribute towards the required infrastructure, where it benefits the AAP area as a whole rather than individual sites/landownerships

Question 73: What approach do you consider the most appropriate basis on which to apportion the cost of the infrastructure requirements arising from different land uses to ensure an equitable outcome?

We consider that this should form part of a specific study that includes, inter alia, the following considerations:
*Identify the infrastructure required across the AAP area that is necessary to delivering the comprehensive vision. This might include key routes, connections, bridges / underpasses, transport, education, energy/utilities, social etc.
*Identify where these are most appropriately located to meet the AAP vision.
*Establish a cost base for these, including appropriate cost of land recognising that in some cases it would be otherwise used for residential or other development
*Establish an appropriate equalisation formula across the AAP, levied on all new development. This could be one or a combination of a tariff per m2, per net acre etc and may be varied by use class.
*Set this out in a policy / legal framework with an appropriate indexing mechanism

Question 74: How should the AAP take into account potential changes over time, both positive and negative, that might affect development viability?

We consider that this should form part of a specific study that includes, inter alia, the following considerations
*ensuring that development continues steadily over potentially a number of economic cycles - this possibility should be acknowledged and planned for at the outset
*Any viability test whereby s106 or AH requirements would be reduced would need to be carefully calibrated to ensure that infrastructure is protected.
*A review mechanism within the S106 Agreement would allow viability to be reassessed if circumstances change.

Question 75: Do you agree with the proposal to require land assembly where it can be demonstrated that this is necessary for delivering the agreed masterplan for the North East Cambridge area and/or the proper planning of development?

Yes. This does not directly affect U+I. Land assembly will help to ensure the delivery of comprehensive redevelopment of NEC.

Question 76: Should the AAP state that the Councils will consider use of their Compulsory Purchase powers? If so, should the AAP also set out the circumstances under which this would appropriate?

The NEC has significant potential to deliver economic, social and environmental benefits, and whilst there are a relatively small number of landowners, the strategic opportunities must not be compromised by one or more parties that are unwilling to support the delivery of the NEC. It therefore seems appropriate for the AAP to specify how the Councils will use their CPO powers if required, and the circumstances for doing so. This will need to include the viability and timescales of pursuing a CPO process.

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

Yes. There are a range of stakeholders and landowners involved in the development at the North East Cambridge area, and the successful delivery of NEC will require a coordinated approach. This will need to consider a range of issues including connectivity, infrastructure locations, parking/trip budget, smart-city coordination, delivery programmes, design principles, energy/utilities and waste etc.

Question 78: Do you agree with the Councils' proposed approach to dealing with planning applications made ahead of the AAP reaching a more formal stage of preparation?

Yes. It is agreed that a coordinated approach is required and decisions on applications should be made against the AAP with appropriate, equitable contributions made.

Question 79: What types of 'meanwhile uses' should the AAP support for the North East Cambridge area?

We would suggest a range of 'meanwhile uses' could be appropriate for NEC, and would not expect policy to impose any particular restriction on types of use. The emphasis should be on promoting innovation and creativity, with meanwhile uses serving to provide early foundations for the new Quarter that will emerge and subsequently replace the meanwhile uses in the coming years. Meanwhile uses could therefore provide start-up/incubator accommodation for emerging/expanding sectors, pop-up/small-scale A class uses, community space to begin community cohesion with surrounding neighbourhoods etc. A positive policy approach to obligations and planning requirements will be needed to encourage temporary/meanwhile activation, helping to avoid onerous situations that might otherwise render creative initiatives unviable.

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

It seems unnecessary to impose a limitation on the scale of a proposed 'meanwhile use', as the purpose of a meanwhile use is, fundamentally, to make optimum use of a site that will otherwise be under-utilised for many years. This can have many short-term economic and social benefits. A policy limitation may stifle innovation and creativity. It is considered likely that many of the meanwhile use proposals will require formal planning consent, which will provide the Local Planning Authority with the ability to control and enforce development that is deemed inappropriate.

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

No. A minimum period should be based on the need and timetable for the permanent development. For the most successful meanwhile initiatives a reasonable period of operation is required in order to recoup the initial capital investment.

Question 82: Should the AAP also include a requirement for 'meanwhile uses' to demonstrate how they will add vibrancy and interest and/or deliver on the wider development outcomes and vision for the North East Cambridge area?

No. 'Meanwhile' uses are temporary in nature and an approach that seeks to make efficient use of land, in a compatible manner with surrounding uses, should be encouraged.

Question 83: What negative or positive impacts might the proposed plans have on residents or visitors to Cambridge with low incomes or who have particular characteristics protected under the Equality Act 2010? (The protected characteristics are age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex, and sexual orientation.)

We strongly support the intention of the Vision for NEC and Objective 5, to ensure social and economic inclusion, and as stated in our response to Question 5, would seek the addition of the word 'culturally' within the Vision i.e. 'North East Cambridge - a socially, culturally, and economically inclusive...'

It is recognised that NEC lies within close proximity of two highly deprived wards in Cambridgeshire, and that regeneration on the scale envisaged will create significant socio-economic opportunities for a wider catchment beyond the AAP boundary. Development on the Site, for instance, will create long term employment across a multitude of sectors and skill ranges, improved connectivity around the NEC and access to new services and facilities. We support the intention of the Councils to undertake a Health Needs and Impact Assessment, across an appropriate study area for the NEC, in order to better understand the challenges and issues faced in neighbouring wards, so as to link into opportunities that will arise in NEC.

As stated within our response to Question 5 we generally support the application of local plan accessibility in the NEC. This standard is meeting Part M of the Building Regulations, however due to the requirements of meeting a higher than normal housing number target on the Site, we require flexibility on how the standard is applied. It is important that the Cambridge Local Plan accessibility standards offers flexibility on how the standards are achieved across the many elements of the new masterplanned scheme. While designing for and incorporating accessibility standards is also accepted as a progressive way to future-proof new housing, it is important the standards do not affect the ability of the scheme to meet the density and the target housing required. Currently the Cambridge Local Plan has adopted the optional standard Part M4(2) and has also adopted M4(3) based on a percentage, which is still higher than the national standards, this may have an adverse impact on our scheme.

Question 84: Do you have any other comments about the North East Cambridge area and/or AAP? Are there other issues and alternatives that the councils should consider? If you wish to make suggestions, please provide your comments.

We would encourage a specific section on education and health provision within the NEC, noting the likelihood that if on-site provision is required, it may require different formats/approaches on how such provision is made i.e. traditional forms of provision in Cambridgeshire are unlikely to be suitable in a high density urban regeneration scheme of this nature.

If off-site provision is considered to be more appropriate, comment should be given on how and where need is expected to be accommodated (for instance it may be more appropriate to extend existing or proposed schools in Cambridge, to create additional Forms of Entry, rather than have a lower number of Forms of Entry on-site that falls below the recommended minimum sizes).

Introduction

Cambridge City Council and South Cambridgeshire District Council is consulting on Issues & Options for the North East Cambridge AAP. The consultation deadline is 25th March 2019. The draft response on behalf of U+I Group PLC ('U+I') is set out below. U+I have been selected by the landowners Anglian Water and Cambridge City Council as Master Developer for land outlined in red in the accompanying Site Plan ('the Site'). It is noted that Cambridge City Council also own other land beyond the Site, which may be the subject of other representations.

The representations contained herein relate primarily to the development intentions for the Site, but also in the context of the wider AAP area (as sites within the AAP boundary are largely intrinsically linked).

Representations

Question 1: Do you agree with changing the name of the plan to the 'North East Cambridge Area Action Plan'?

It is recognised that there is a need for a collective reference for the AAP area. This will provide consistency and clearer definition as the process evolves. Whilst it is inevitable that sub-areas of the AAP will emerge with different branding names and strategies, this will have more relevance to the individual sub-area concerned, in creating identity when publicising forthcoming planning applications through to marketing/sales disposals.

Question 2: Is the proposed boundary the most appropriate one for the AAP?

Generally, we support the proposed boundary for the AAP area. We would, however, make two observations/comments.

Firstly, it seems logical to include the site of Cambridge Regional College ('CRC') within the boundary. It is noted that in paragraph 3.5 comment is made that it is not expected to undergo major change in the way other sites across NEC are. However, CRC considers itself to be 'one of the best Further Education Colleges in the country for 16-18 year old level 3 achievement and a leading apprenticeship provider, with thousands of full time students and apprentices currently in training'. The significant range of vocational courses it offers could be positively utilised to support the long-term construction process around NEC (e.g. architectural technology, mechanical engineering, electrical, carpentry, bricklaying courses and apprenticeships), and then the on-going operational phases of the different sub-areas of NEC (e.g. from courses relating to biological science for industry, laboratory technicians and computing technologies, to business and catering and hospitality). It therefore has the potential to play an important learning and development role in the future NEC area. The built form of the current campus appears to be relatively low density, with large areas of used for surface level car parking. Buildings are predominantly 2-3 storeys in height. With the transformation of NEC, recognising the different approaches to internalised trips/reduced car parking, and taller buildings, it would seem likely that the estate management of CRC might change in the future, and if so, it should be included in the AAP.

Secondly, we would comment that, owing to the nature of NEC, development is likely to be high density, optimising the use of all land to work efficiently and effectively. The strategy for on-site Public Open Space is likely to focus on qualitative provision, than quantitative, with a stronger emphasis on formal recreational and leisure space than informal open space. Access to the latter however, is likely to be facilitated through new and improved connections to the east (potentially including land to the east of the railway line north of Cambridge North Train Station, to the river) and north (potentially including land to the north of the A14, such as Land to the south of Cambridge Road, and land including/extending Milton Country Park) of NEC. We would therefore simply pose the question about whether there is a need to include within the AAP boundary additional land that could provide informal open space, biodiversity and drainage functions, which might otherwise not be achievable within the single control of the NEC boundary. It is considered that land to the north and east of the current AAP boundary would primarily be used to facilitate access to green infrastructure for NEC.

Question 3: In this chapter have we correctly identified the physical characteristics of the North East Cambridge area and its surroundings?

Generally, yes. However, we consider it might be beneficial to include more information about the composition of site areas. For instance, on the employment parks, providing details about site area, total floorspace of buildings on the park (including extant planning consents) and the range of authorised planning uses e.g. % B1a uses, %B1b uses, estimated no. of employees, audit of authorised car parking spaces, audit of public open space (estimated total hectares). This would help to inform a baseline of land use within NEC, and then contribute in developing future strategy e.g. highway trip budget, employment strategy, connectivity and green infrastructure etc.
We would also note that it would be beneficial to have mapping information available relating to the environmental constraints identified e.g. noise, air quality, odour, important habitats.
Finally, it would be beneficial to show the broader extents of key infrastructure for NEC, including the full Chisholm Trail link (connecting NEC to Cambridge City, and the south of Cambridge (Addenbrookes), committed routes for other new cycle, pedestrian and public transport in and around the City, and the proposed Greenways link to Waterbeach).

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

In general, yes. However, we note that there is no reference to Archaeology and Heritage, and would suggest that comment is given about this, even if it is considered that NEC has limited archaeological significance. In terms of heritage, whilst we believe that there are no listed buildings, conservation areas, or other notable heritage constraints within NEC, the intention for taller buildings in NEC will need to be more widely considered in respect of longer-distant views and townscape issues (historic core of Cambridge). Taller buildings may also have potential implications for Air Safeguarding Zones (consultation required with Marshall Airport and the Ministry of Defence on structures over 15m in height), and the Mullard Radio Astronomy Observatory (consultation with the University of Cambridge). We acknowledge that the issue of building heights and taller buildings is likely to be assessed as part of the on-going Landscape Character and Visual Impact Assessment that is being undertaken by Cambridge City Council (it is understood that a 'Stage 1' exercise has already been commissioned), and that the findings are then likely to inform future stages of this AAP process.

We would also suggest consideration be given to the inclusion of Green Belt boundaries around NEC. This will help provide clarity to interested parties that all land envisaged for development and associated physical infrastructure will be accommodated on non-Green Belt land. It will also help to provide reassurance that the development aspirations for NEC will not automatically lead to further development beyond the identified boundaries, unless it is deemed to be 'appropriate development' (i.e. not 'inappropriate' as defined in the National Planning Policy Framework'), or that exceptional circumstances are demonstrated in future Local Plans, or a Very Special Circumstances argument is made to support development via a planning application process. In all cases, strict mechanisms for controlling additional future development beyond NEC will apply.

Reference should also be made to the presence of UKPN's overhead power cables (132KV) that span across the AAP boundary. In terms of ensuring optimum reuse of the Site (and indeed other sites, including Cambridge Science Park), we would support a policy seeking their diversion underground.

Question 5: Do you agree with the proposed Vision for the future of the North East Cambridge area? If not, what might you change?

Yes, we support the proposed Vision for NEC. The addition of the word 'culturally' might benefit this Vision further (in the context of 'North East Cambridge - a socially, culturally, and economically inclusive....)

Question 6: Do you agree with the overarching Objectives? If not, what might you change?

Generally, we support the overarching Objectives. The addition of the words 'Natural Capital' might benefit Objective 7 further (in the context of '...connecting and improving biodiversity to achieve a Natural Capital net gain....)

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

It is noted that the Concept Plan can only be treated as indicative at this stage in the AAP process, until the outcomes of the various Supporting Studies are known (notably Landscape Character and Visual Impact Assessment, Development Capacity Study, NEC AAP Transport Assessment, NEC Development Viability Assessment, NEC Infrastructure Delivery Plan), and wider consultation with relevant interested parties (e.g. landowners, developers, local communities, local authority bodies etc) has been carried out.

We support the residential-led mixed use allocation for the Site. We support the aspiration to create high quality pedestrian, cycle and public transport connectivity across the AAP area. We support the indication that a Mixed Use District Centre will be provided on the Site though we would suggest that its optimal location can only be determined after further study and masterplanning work. There may also be a need to include an additional Mixed Use Local Centre in the northern half of the Site (subject to further Masterplanning and an assessment on accessibility). We support the intention to provide and integrate Green Infrastructure throughout the AAP boundary, but what provision is made (and how/where it will be provided) will need to be determined following further studies/assessment and Masterplanning. Further consideration will need to be given to the suggested Industrial Development Sites in the north east corner of the Site, to understand what the rationale is for proposing to relocate existing industrial land at Nuffield Road and Cowley Road, to another part of the AAP site. It is assumed that the suggestion is made on the basis that it will provide noise abatement from the A14 to the new residential elements of the Site. However, we consider that there may be other more preferable solutions for controlling noise and, in Masterplanning terms it is less desirable bringing industrial-related traffic through a predominantly residential site. In the absence of clear justification for seeking relocation of industrial uses, we cannot support the industrial element of the proposal.

We aren't yet persuaded that the proposed location and quantum of industrial use is optimal. In particular we have concerns that this is currently shown at the furthest point from strategic highway connections. We also believe that different models and formats of industrial development should be further explored, specifically whether this should be concentrated in a single location, or whether it might be incorporated within a mixed-use approach throughout the Site.

We do not necessarily agree that the Site represents the best opportunity with the overall AAP area to accommodate a significant concentration of industrial uses in a single location.

We would suggest that the Cambridge Business Park is shaded as an Opportunity for Employment Intensification.

In addition to our response for Question 2, we would suggest that the CRC land we would suggest that this land is included within the AAP boundary, and that a new shading is applied that refers to an Opportunity for Education Intensification.

Question 8: Do you agree that outside of the existing business areas, the eastern part of the North East Cambridge AAP area (i.e. the area east of Milton Road) should provide a higher density mixed use residential led area with intensified employment, relocation of existing industrial uses and other supporting uses?

Generally, we support the initial development intentions for the area east of Milton Road. It is considered that this area could accommodate a high density mixed use residential-led development following the relocation of the existing Cambridge Water Recycling Centre and other industrial uses (subject to viability and finding suitable relocation site(s)) from the Site. A comprehensive, design-led, approach across the AAP will help maximise the redevelopment potential of a significant brownfield site in a highly sustainable location.

Question 9: Should Nuffield Road Industrial Estate be redeveloped for residential mixed use development?

Yes, we agree that consideration should be given to relocating existing industrial uses on the Nuffield Road Industrial Estate, in preference for higher density residential-led mixed use redevelopment. Consideration should be given to the viability of doing so (industrial land values are currently relatively high), and where existing businesses will be relocated. An Industrial Relocation Strategy might be appropriate, in order to understand what factors are important to businesses e.g. last mile strategies and what alternative sites might be available to accommodate relocation requirements. ]

As outlined in Question 7, the suggestion to relocate industrial uses from Nuffield Road Industrial Estate to the north east corner of the Site needs to be explained and justified. At this stage we do not support the suggestion to relocate industrial uses to the north-east corner of the Site.

Question 10: Do you agree that opportunities should be explored to intensify and diversify existing business areas? If so, with what sort of uses?

Yes, we broadly support this suggestion, subject to the establishment of a robust and equitable approach to Highways Trip Budget apportionment and s106 tariff system across the wider AAP area. The Cambridge Science Park was first established on the principle of accommodating 1-2 storey, low density commercial buildings within an attractive strategic landscape/parkland setting. Whilst much of the strategic landscaping remains, latter phases of the Science Park have sought to intensify development density, with taller buildings, lower car parking provision, and limited on-plot landscaping (other than to lessen/soften the impact of new development). This approach has been complemented by the introduction of Cambridge North Station Interchange, which has significantly improved accessibility via non-car modes. The growth aspirations now anticipated for the AAP area signals a radical change in approach to new development. New residential communities will be supported by existing and intensified employment and educational opportunities, potentially providing live and work/learning opportunities within walking/cycling distance of each other. Furthermore, access to inter alia Cambridge North, the Guided Busway, and the Chisholm Trail will support accessibility to existing business areas from a much wider catchment, therefore helping to improve the means of accessing work without the need to do so by car.

Opportunities to provide a greater quantum and diversity of employment should be encouraged. This will consolidate and strengthen the concept of the Cambridge Phenomenon, by creating a greater range and quantum of high quality accommodation for new businesses, in close proximity to a critical mass of similar businesses, thereby helping to support knowledge sharing and collaboration through co-location.

In order to promote diversity of employment types, planning policy consideration might be given to encouraging a certain percentage of 'affordable employment', to support the growth of new start-up businesses that require the same close links with similar businesses but cannot afford (and do not currently need) accommodation that becomes available.

Question 11: Are there any particular land uses that should be accommodated in the North East Cambridge area?

The North East Cambridge area should support any use that demonstrably contributes to the Vision and Objectives of the AAP area.
The AAP provides a significant opportunity to create thousands of new homes in a highly sustainable location. The growth of housing in this area will be supported by the economic benefits derived from the long-established science, innovation and business parks (many of which will be intensified), that have collectively grown from the success of clustering knowledge-based industries in close proximity of one another. The housing element of the Site will improve supply and affordability of high quality new homes to the many thousands of employees on these parks, helping to reduce the number of car movements on Milton Road. New homes and jobs on the scale envisage will need to be served by a number of social, retail, community, health, education, leisure and recreation facilities,

Question 12: What uses or activities should be included within the North East Cambridge AAP area which will create a district of culture, creativity and interest that will help create a successful community where people will choose to live and work and play?

It is considered that the inclusion of schools, community facilities, retail and leisure uses, open space, and transport services, in conjunction with walking and cycling connections to neighbouring areas will provide the attributes of a successful community.

The NEC AAP must recognise the wider role it plays in creating opportunities for surrounding communities, of which two neighbouring wards - East Chesterton and Kings Hedges - currently suffer from high levels of deprivation (included in the top three of most deprived wards in Cambridgeshire). The benefits of the AAP area should extend to these areas, to create new employment, education, social, leisure and recreation, health and community opportunities. Where new facilities are introduced to areas experiencing deprivation, a key challenge for optimising use of such facilities is affordability. Free or subsidised charging mechanisms should therefore be considered when providing new facilities for instance e.g. hire of sports pitches, meeting rooms etc.

It should, however, be recognised (and indeed it is in Question 79) that the ambitious development aspirations for the Site and wider AAP area will take a number of years to comprehensively plan and deliver. Certain elements will be possible to deliver early. Notwithstanding this, there is the opportunity to introduce 'meanwhile/worthwhile' uses the area as the transition progresses. Meanwhile/worthwhile uses offer creative and innovative ways of optimising sites on a stop-gap basis, creating a temporary opportunity to capture economic and/or social benefits for the wider area in the period between the closure/or reduction of an existing site operation and the commencement of the intended new development.

Question 13: Should the AAP require developments in the North East Cambridge AAP area to apply Healthy Towns principles?

NEC will provide a considerable opportunity for creating a healthy new community, and supporting neighbouring communities, through access to high quality housing, a design approach founded on sustainable modes of travel (walkable neighbourhoods), and improved employment, shopping, health, education, leisure and recreational opportunities. We also support the intended preparation of the Health Impact and Needs Assessment for NEC, which will take account of the wider deprivation challenges faced in the neighbouring wards of East Chesterton and Kings Hedges.

Question 14: How should the AAP recognise and make best use of the existing and potential new links between the AAP area and the CRC (Cambridge Regional College)?

Please see our response to Question 2.

Question 15: Should clusters of taller buildings around areas of high accessibility including district and local centres and transport stops form part of the design-led approach to this new city district?

We strongly support the principle that the greatest development densities should be located in the areas of greatest accessibility and public amenity. This maximises the potential for sustainable travel patterns and establishes a critical weight of local demand for leisure, cultural and retail uses.

It is important to note that 'high-density' does not automatically mean 'tall' and that compact mid-rise development can often be denser than taller development, particular where the latter is compensated for by a smaller overall development footprint. Compact mid-rise also typically enables a wider range of dwelling types and external amenity space, meeting a wider range housing needs.

We favour a 'transect' based approach to masterplanning which will ensure the density, scale, typology, and uses of development are allocated across the site as a whole and within each neighbourhood in a coordinated way, following the accessibility principle described above and responding to the opportunities and constraints of the Site. This may not mean 'clusters' - it could for example mean that the highest densities are located in 'corridors' along the primary streets, and/or at edges where having denser development acts to shelter lower-scale development from adjacent visual or noise intrusion. The masterplan will be backed up by a design code that will identify/mandate appropriate typologies for achieving the requisite densities in ways that are acceptable in other respects.

In addition to accessibility and other local factors, it is important to note that the extent and location of denser development will be affected by a range of detailed studies and appraisals (including Landscape Character and Visual Impact Assessment), that will recognise - and then balance - the challenges of creating areas of higher density and taller buildings in a highly sustainable location that is, nonetheless, on the edge of Cambridge with areas of open countryside beyond. This may also militate against achieving density through height.

Question 16: Should the AAP include any or a combination of the options below to improve pedestrian and cycling connectivity through the site and to the surrounding area?

A - Create a strong east-west axis to unite Cambridge North Station with Cambridge Science Park across Milton Road. This pedestrian and cycle corridor would be integrated into the wider green infrastructure network to create a pleasant and enjoyable route for people to travel through and around the site. The route could also allow other sustainable forms of transport to connect across Milton Road.

Yes. A strong east-west axis should be included to connect the different parts and proposed uses within NEC, and to encourage movement within the site by sustainable modes of transport.

B - Improve north-south movement between the Cowley Road part of the site and Nuffield Road. Through the redevelopment of the Nuffield Road area of NEC, it will be important that new and existing residents have convenient and safe pedestrian and cycle access to the services and facilities that will be provided as part of the wider North East Cambridge area proposals.

Yes.
C - Upgrade connections to Milton Country Park by both foot and cycle. This would include improving access to the Jane Coston Bridge over the A14, the Waterbeach Greenway project including a new access under the A14 (see Transport Chapter), as well as the existing underpass along the river towpath.

Yes. It is considered that improvements to connections with Milton Country Park and with existing and proposed pedestrian and cycle routes will be important for the success of development within the AAP. It is anticipated that NEC will provide a high density residential development, to take advantage of the close proximity of employment areas and public transport services, but which might limit opportunities for large scale open space/recreation areas. Therefore, it will be important to ensure that any proposal for an underpass will maximise connectivity through the Site, capitalising on permeability and wider Green Infrastructure initiatives (e.g. Waterbeach Greenway, Chisholm Trail, improving the public realm function of the 1st Drain etc).

D - Provide another Cambridge Guided Bus stop to serve a new District Centre located to the east side of Milton Road.

We support the suggestion to improve public transport accessibility around NEC but further work should be undertaken to determine whether an additional 'guided' busway stop is required or whether a 'normal' bus service, which could feasibly use the same buses as those on the Busway, could deliver the same benefits.

E - Increase ease of movement across the sites by opening up opportunities to walk and cycle through areas where this is currently difficult, for example Cambridge Business Park and the Cambridge Science Park improving access to the Kings Hedges and East Chesterton areas as well as the City beyond.

We very much support opportunities to increase the ease and convenience of walking and cycling movements across sites in NEC, as this will strengthen the concept of promoting internalised trips and reduce the reliance on travel by car.

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

It is noted that the River Cam towpath is identified as a route within the Waterbeach Greenway project, and it would be appropriate to take the opportunity to provide a pedestrian and cycling connection from this route into NEC, subject to the availability of funding.

The high density redevelopment of NEC is unlikely to achieve the level of Public Open Space that might otherwise be required under local plan policy. The focus is instead likely to be on securing high quality, flexible-use open space on-site, and improving/providing new connections to informal open space networks to the north and east of the AAP area (including the Waterbeach Greenway). Accordingly, an appropriate means of accessing off-site Green Infrastructure for NEC will be required, and the suggestion of a pedestrian/cycle bridge would facilitate this.

Please see our responses to Questions 2 and 7.

Question 18: Which of the following options would best improve connectivity across Milton Road between Cambridge North Station and Cambridge Science Park?
A - One or more new 'green bridges' for pedestrians and cycles could be provided over Milton Road. The bridges could form part of the proposed green infrastructure strategy for NEC, creating a substantial green/ecological link(s) over the road.
B - Subject to viability and feasibility testing, Milton Road could be 'cut-in' or tunnelled below ground in order to create a pedestrian and cycle friendly environment at street level. This option would allow for significant improvements to the street which would be more pleasurable for people to walk and cycle through.
C - Milton Road could be significantly altered to rebalance the road in a way that reduces the dominance of the road, including rationalising (reducing) the number of junctions between the Guided Busway and the A14 as well as prioritising walking, cycling and public transport users.
D - Connectivity across Milton Road could be improved through other measures. We would welcome any other suggestions that would improve the east-west connectivity through the site.
E - Other ways of improving connections (please specify)

In response to all five options listed above, we generally support the principle for securing high quality east-west connectivity. However, the means of crossing Milton Road will involve a range of complex issues, which cannot be determined at this stage. The crossing solution(s) should not ultimately be compromised by concerns about short-term disruption and inconvenience. The east-west axis will be fundamental in the overall success of NEC, and the justification for internalising trips will be partly made on the basis that pedestrian and cycle connectivity across NEC will be safe and convenient (and therefore likely to be commonly used as a means of travel).

Option A is considered to be the preferred option as it provides the opportunity to create a substantial green link over the road without adversely affect the flow of traffic on Milton Road, which has existing network capacity issues. It will also limit the impact on the operation of the Milton Road during construction when compared with either Option B and C.

Option B would likely result in significant disruption to the road network during construction and would likely require the lowering or redirecting or Statutory Undertakers Utilities. Both Option B and C would result in alterations to the access junctions into the Science Park and the Site, both of which have limited access opportunities for their respective sizes.

Question 19: Should development within the North East Cambridge area be more visible from Milton Road, and provide a high quality frontage to help create a new urban character for this area?

We generally support the suggestion of making new development within NEC more visible from Milton Road and providing a high quality frontage to create a new urban character for the area. Milton Road is currently a highly car dominated environment, with a number of confusing junctions serving Cambridge Science Park and Cowley Road. However, it is noted that Milton Road acts as a key north / southbound route into and out of Cambridge, and the Milton Interchange forms part of the Strategic Road Network and connects Cambridge to the A14 (a major east to west route, which has recently been upgraded to improve capacity). Given the level of traffic using this stretch of the Milton Road to access the Strategic Road Network at this location, the potential to reduce traffic to provide a high quality new urban character for the area may be limited in the short term. Notwithstanding this, where Milton Road runs southwards the nature of the road starts to change and becomes more urban in nature, potentially becoming more conducive to active frontage and activity on the footway.

Question 20: Do you agree with proposals to include low levels of parking as part of creating a sustainable new city district focusing on non-car transport?

Yes, we generally support this principle NEC provides an opportunity to reduce levels of parking, as part of a package of transport measures including new and additional walking and cycling routes, public transport services, and car share schemes. However, we would also suggest that interim car parking strategies might need to be considered, to support 'pioneer' uses/development during transitional phases of NEC i.e. until the full package of transport infrastructure and initiatives can be fully realised. As new infrastructure/initiatives are introduced, interim car parking can be gradually phased out.

Question 21a: In order to minimise the number of private motor vehicles using Milton Road, should Cambridge Science Park as well as other existing employment areas in this area have a reduction in car parking provision from current levels?

We very much support opportunities to reduce the reliance on travel by car in and around NEC, and instead increase the ease and convenience of walking and cycling movements across sites in NEC, as this will strengthen the concept of promoting internalised trips.

Question 21b: Should this be extended to introduce the idea of a reduction with a more equitable distribution of car parking across both parts of the AAP area?

Yes, as part of a package of transport measures to encourage travel by sustainable modes of transport.

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

Yes, subject to further understanding of the requirements of businesses and the needs of residents. The North East Cambridge area could include a number of delivery/collection hubs.

Question 23: Should development within the North East Cambridge area use car barns for the storage of vehicles?

We support the idea of using car barns, as part of a wider package of parking solutions across NEC. Whilst it is recognised that private on-plot parking is unlikely to be widely encouraged, there will inevitably be demand from some residents to have access to the use of a car/secure car parking but this should be priced accordingly to the end user. Car barns provide communal access to parking, and are typically located in less convenient locations in order to discourage frequent use. As an example, if a car was needed to do a weekly shop, the resident would park outside their property to unload their car and then move the car to a car barn. Car barns can also be used by 'car clubs', so that a resident can book a car for a certain period of time but not have the long-term cost and use commitment to owning a private car. The versatility of car barns should also be recognised, as parking can be let on a temporary basis and, as trends change, can be converted into alternative uses to reduce car usage further.

Question 24: Within the North East Cambridge area green space can be provided in a number of forms including the following options. Which of the following would you support?
A - Green space within the site could be predominately provided through the introduction of a large multi-functional district scale green space. Taking inspiration from Parker's Piece in Cambridge, a new large space will provide flexible space that can be used throughout the year for a wide range of sport, recreation and leisure activities and include a sustainable drainage function. The sustainable drainage element would link into a system developed around the existing First Public Drain and the drainage system in the Science Park. The green space could be further supported by a number of smaller neighbourhood block scale open spaces dispersed across the site.
B - Green spaces within the site could be provided through a series of green spaces of a neighbourhood scale that will be distributed across the residential areas. These green spaces will also be connected to the green infrastructure network to further encourage walking and cycling. Again, these spaces will include a sustainable drainage function and link into the existing First Public Drain and the Science Park drainage system.
C - Enhanced connections and corridors within and beyond the site to improve the biodiversity and ecological value as well as capturing the essential Cambridge character of green fingers extending into urban areas. These corridors could also be focussed around the green space network and sustainable drainage and would reflect the NPPF net environmental gain requirement.
D - Green fingers to unite both sides of Milton Road and capitalise on the existing green networks.
E - Consideration of the site edges - enhancement of the existing structural edge landscape and creating new structural landscape at strategic points within and on the edge of NEC. This would also enhance the setting to the City on this important approach into the City.
F - Creation of enhanced pedestrian and cycle connectivity to Milton Country Park and the River Cam corridor.

In response to all six options listed above, we support the principle for securing high quality green infrastructure across NEC. Subject to further capacity testing and Masterplanning, on-site provision might feasibly take the form of a larger green space for the whole NEC and complemented by smaller 'neighbourhood scale' spaces and enhanced connections and corridors to off-site green infrastructure. We aren't persuaded that Parkers Piece is an appropriate comparable for the size and function of this space but do consider that the green space should draw lessons from existing green spaces in Cambridge. However, in supporting the theme of innovation at all stages of the development it will be important to consider smart solutions for the open space strategy, maximising flexibility across all areas of on-site open space. For instance, playing fields associated with on-site school provision should be available to the wider community, at times when it is not required by the school. Management and security issues will need to be carefully considered in this regard. Landscape vegetation should encourage biodiversity, whilst also performing softening/screening functions. Formal playspace should be able to accommodate multi-use activities during the day and evening and throughout the year. Green infrastructure might incorporate elements of food growing e.g. fruit trees, herbs, and vegetables, enabling free access to foods that help promote healthier lifestyles.

In terms of the suggestion of how open space will be provided (and in what format and amount), this cannot be determined at this stage of the process. A series of studies and assessments have been or are being commissioned by Cambridge City Council, which will help inform development principles and Masterplanning. Consultation will also need to be carried out with a number of interested parties, including landowners, developers, local communities and local authority bodies. Therefore, we are neither supporting nor objecting to any of the suggested options at this stage.

Question 25: As set out in this chapter there are a range of public transport, cycling and walking schemes planned which will improve access to the North East Cambridge area. What other measures should be explored to improve access to this area?

We generally support the suggested options for improving public transport, cycling and walking accessibility around NEC. The proposed Waterbeach Greenway should be directed through the Site, to create a coherent route from Waterbeach to the station. This will allow future residents of the Site to cycle to the station helping to providing a means of travel for the 'first mile / last mile' of the journey to / from the station.

A new route for a busway from the proposed Waterbeach development should be routed through the Site down to Cambridge North Station. Stops on the route could form transport interchanges linking to other bus routes and cycle routes. High quality cycle links should be implemented to connect into existing infrastructure such as the Chisholm Trail.

The route of these two transport spines through the Site will help develop a single coherent sustainable transport corridor down to the station allowing seamless interchanges between transport modes where the routes intersect with one another. The interchanges will be located within a high-quality urban environment close to high density district centres and attractive locations encouraging linked trips and improving access to the district centres by public transport.
It will important to ensure that consideration is always given to promoting access beyond the AAP boundary (as currently shown), such as recognising the education/social role that CRC plays in the west, the retail and leisure/recreational/biodiversity roles of Tesco and Milton Country Park in the north, the leisure/recreational/biodiversity role of the river and green corridors in the east, and the existing Cambridge communities in the south.

Question 26: Do you agree that the AAP should be seeking a very low share of journeys to be made by car compared to other more sustainable means like walking, cycling and public transport to and from, and within the area?

We support the concept of encouraging a greater share of non-car modes of travel for NEC, but note that it is a concept that will need to be accepted by all landowners/occupiers in the AAP boundary in order for it to be successfully implemented. This is broadly in accordance with the advice from the Ely to Cambridge Transport Study, and will be further tested in the NEC AAP Transport Assessment work (due to be commissioned).

Question 27: Do you have any comments on the highway 'trip budget' approach, and how we can reduce the need for people to travel to and within the area by car?

We support the principle of a 'trip budget' as there is limited scope for large scale engineering interventions to create more capacity on the road network. However, the trip budget must be carefully considered and tested to ensure that it is both suitable and realistic. Appropriate measures will need to be employed if the trip budget is exceeded. The monitoring process will need to be carefully considered, as various land uses across the AAP site will be allocated a share of the trip budget.

Question 28: Do you agree that car parking associated with new developments should be low, and we should take the opportunity to reduce car parking in existing developments (alongside the other measures to improve access by means other than the car)?

We generally support the concept of encouraging a greater share of non-car modes of travel for NEC. This is broadly in accordance with the advice from the Ely to Cambridge Transport Study, and will be further tested in the NEC AAP Transport Assessment work (due to be commissioned). It is recognised that many existing employment uses, such as those in Cambridge Science Park, St John's Innovation Park and Cambridge Business Park, will have authorised car parking at significantly higher levels than what is now intended for NEC. We would support the Councils working with various landowners in exploring innovative/incentivised ways of reducing car usage from those sites.

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

We support the suggestion of requiring high levels of cycle parking from new developments. This approach will be supported by the new cycling infrastructure that is planned for Cambridge, including the Chisholm Trail and Waterbeach Greenways. Cycling helps support healthy lifestyles, and is a viable means of travelling around a compact city, assuming that safe and convenient routes and secure/covered parking can be provided. New and existing workplaces can be encouraged to provide showers, changing facilities and lockers to encourage staff to cycle into work.

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

Cycling is key to achieving a mode split and demand must be met, and therefore we support the suggestion of innovative solutions to cycle parking. As part of further capacity testing, Masterplanning and detailed design, consideration will be given to innovative storage solutions (using domestic and international examples) that enables cycle parking to be integrated appropriately into the public realm. The concept of micromobility should also be embraced, with provision made for parking dockless bikes to ensure that they are not left in inconsiderate locations such as the footway.

Question 31: What additional factors should we also be considering to encourage cycling use (e.g. requiring new office buildings to include secure cycle parking, shower facilities and lockers)?

New office buildings should include covered, secure cycle storage, showers and lockers. The cycle parking should also be conveniently located at basement/ground floor level or within easy access of lifts capable of transferring bikes between levels. Where possible segregated access for cyclists should be provided to minimise the conflict with pedestrians and vehicles accessing buildings.

Question 32: How do we design and plan for a place that makes the best use of current technologies and is also future proofed to respond to changing technologies over time?

Energy strategies
We will expect development on the Site to have a very low 'in use' energy demand, through robust design of built fabric and services. This will make it easier to meet more of the scheme's energy demand from renewable and low carbon energy sources - and in some case may allow a 'net positive' energy balance to be achieved. Implications for wider energy networks should also be considered, with consideration of energy storage and demand control options at building and community level.

Form and fabric

Development within the Site will be designed, at both masterplan and building scale, to result in minimal energy use through sensitive consideration of site conditions and a robust approach to fabric performance, using passive design strategies to achieve good comfort, day-lighting and air-quality.

Building services

Developments should ensure they build on high quality design of form and fabric by specifying robust and efficient building services. If care has been taken in the design of the built fabric, it should be simpler for efficient building services to meet the needs of those who live and work in a building.

Energy generation and supply

Once the gross energy demand for the proposed development has been reduced through efficient built form and services, it will become possible to evaluate how a greater proportion of its needs can be met through renewable and low carbon energy sources.

Provision for electric charging points for vehicles should be implemented to ensure that both residents and workers have access to electric car charging points. Way-finding points and real time journey time information should be implemented across the Site to ensure people have accurate up to date travel information.

Delivery hubs should be provided on the periphery of the site to intercept large delivery vehicles from accessing the site. This will also help to consolidate deliveries and reduce the need for large vehicles to enter the Site, with smaller electric vehicles providing the final leg of the journey to the front door of the residence or workplace.

Subterranean bins should be provided on the Site to minimise space requirements for waste storage and provide a secure location for the bins.

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

It is considered unlikely that an at grade crossing can be located to link the Science Park with the station due to capacity constraints on Milton Road. A well-designed overpass for pedestrians and cyclists may provide the best option to effectively reduce severance caused by Milton Road and link the station with the Science Park. The journey from the station to the Science Park, will be the last / first mile of commuter journey and micromobility solutions such as dockless e-bikes should be provided to support the movement on this link.

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

The knowledge-based cluster around Cambridge Science Park, St John's Innovation Park, and Cambridge Business Park is internationally recognised, and the significant economic role that it offers to NEC must be fully harnessed to encourage complementary industries (Artificial Intelligence, R+D and laboratories for smaller emerging businesses that need the cluster benefits, maker-space etc) and optimise further employment opportunities. We would therefore expect a range (in terms of use and size) of employment spaces across NEC, including Science, Research & Development and Technology-related employment. However, in advocating innovation throughout NEC, policy limitations should not be imposed that unduly restrict any particular use at this stage.

Question 35: In particular, should the plan require delivery of:
A - a flexible range of unit types and sizes, including for start-ups and Small and Medium Sized Enterprises (SMEs);
B - Specialist uses like commercial laboratory space;
C - hybrid buildings capable of a mix of uses, incorporating offices and manufacturing uses.
D - shared social spaces, for example central hubs, cafes.
E - Others (please specify).

We generally support all of the suggested options at this stage, and would seek inclusion of corporate headquarters within category A. These options should equally be applied to proposals for meanwhile/worthwhile uses, in order to optimise economic development benefits and promote innovation at the earlier stages of the development process for NEC.

Question 36: Which of the following approaches should the AAP take to existing industrial uses in the North East Cambridge area?
A - seek to relocate industrial uses away from the North East Cambridge area?
NEC represents a significant and unique opportunity to create a new and innovative high-density, high quality, mixed use Quarter for Cambridge and its surrounding area. The opportunity is dependent on Housing Infrastructure Funding that will facilitate the relocation of the Water Treatment Works, and optimise the quantum of new housing across the Site. Whilst it is recognised that other, non-residential uses, will also be needed in NEC in order to promote multi-functioning mixed communities and internalised trips, capacity testing and Masterplanning will need to carefully identify what uses (and how much) will be appropriate. Whilst the prospect of utilising some of the Site for industrial use has not, at this stage, been discounted, justification for the need and location of such a use will need to be very carefully considered. A greater understanding of industrial need is therefore required, and in particular how essential it is for certain businesses to be in Cambridge. Consideration should also be given to whether existing businesses are compatible with residential neighbourhoods, as if so, there may be scope to incorporate industrial (i.e. b1c) accommodation within a mixed use development. This might, for instance, include ground floor workshops/maker spaces where noise, odour, other forms of pollution, and type of deliveries will not give rise to unacceptable living conditions for neighbouring properties. For existing businesses where there is not a demonstrable need to be in Cambridge, relocation options outside the NEC should be considered.

B - seek innovative approaches to supporting uses on site as part of a mixed use City District?
See response to A, above.

Question 37: Are there particular uses that should be retained in the area or moved elsewhere?

See response to A, above. The AAP should set out the strategy for determining the needs of individual businesses (and whether there is an operational imperative to be closely related to Cambridge, and how the relocation of existing industrial uses can be appropriately implemented..

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

The residential ambitions and opportunities in NEC (and particularly the Site) will need to be fully understood and embraced in order for the Vision and Objectives of the AAP to be realised. For the high density levels of new housing envisaged, innovation will be essential at all stages and in all forms. Traditional approaches to housing in Cambridge are unlikely to be appropriate. Housing will be made available for a much wider market than might otherwise be expected for a new settlement/strategic urban extension elsewhere in the county (e.g. Northstowe, Waterbeach, Cambourne), including that which is more aligned to smaller household sizes e.g. students, post-graduates, young professionals, and older persons looking to downsize. Where family housing is to be provided, it will require 'smarter-space' solutions to reflect the Site-wide high density approach.
A greater understanding of need and demand, market trends and viability will be needed to define housing requirements for NEC in later stages of the AAP process.

Question 39: Should the AAP seek provision for housing for essential local workers and/or specific housing provided by employers (i.e. tethered accommodation outside of any affordable housing contribution)?

Yes, see response to Question 38.

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

We generally support the suggestion of having a challenging target for the provision of affordable housing. There is a chronic shortfall of affordable housing in South Cambridgeshire and Cambridge City, and the residential growth aspirations of NEC could make a significant contribution in reducing housing shortfall. It is also important to ensure that there are a range of homes of different sizes and tenures to achieve mixed and balanced communities. However, it is also important to ensure that the policy is sufficiently flexible to address viability challenges, and takes a pragmatic approach when recognising how different types of housing are provided and thereafter managed and maintained e.g. less reliance on traditional approaches of 'pepper-potting' etc. There is a significant cost in delivering the level and type of development envisaged and it will be essential to ensure that delivery of the development can be secured on a viable basis. Consideration must also be given to exploring other means of making housing more widely accessible, such as through PRS for instance.

Question 41: Should an element of the affordable housing provision be targeted at essential local workers?

We generally support this suggestion, but a more detailed understanding of housing need and demand in the area, and indeed an understanding of what key employers in the area require, should be undertaking before developing an AAP-specific affordable housing policy.

Question 42: Should the AAP require a proportion of development to provide custom build opportunities?

We generally support this suggestion, but again a greater understanding of demand, need and viability is required. Consideration should be given to examples where successful custom-build housing has been delivered, such as Marmalade Lane, Cambridge's first co-housing community made up of 42 custom build homes.

Question 43: Should the AAP allow a proportion of purpose built HMOs and include policy controls on the clustering of HMOs?

We support the suggestion of creating more shared living and co-living housing opportunities, as these can help improve variety and access to more affordable, good quality accommodation. This type of housing typically incorporates shared services and facilities and can benefit both younger and older aged groups. However, again a greater understanding of demand, need and viability is required.

Question 44: Should the AAP include Private Rented Sector (PRS) as a potential housing option as part of a wider housing mix across the North East Cambridge area?

We generally support this suggestion, as it typically lends itself to earlier delivery, it can be part of an affordable housing mix, and may suit the needs of the adjoining employment base. Similar to HMO's, PRS development needs to be well-managed to integrate successfully. Again a greater understanding of demand, need and viability is required.

Question 45: if PRS is to be supported, what specific policy requirements should we consider putting in place to manage its provision and to ensure it contributes towards creating a mixed and sustainable community?

We would suggest that this needs to be considered in greater detail, including need and demand, management of facilities, services, and amenities should be well defined and required.

Question 46: Should PRS provide an affordable housing contribution?

Subject to viability, policy requirements will need to reflect the distinct economics of this tenure. In most cases (as in London) this is acknowledging that a form of Discounted Market Rent (capped at 80% of Open Market Rents) is most applicable, as this can be managed by a non-Registered Provider and therefore enables tenure blind blocks to be delivered by PRS operators.

Question 47: What 'clawback' mechanisms should be included to secure the value of the affordable housing to meet local needs if the homes are converted to another tenure?

Typically a profit sharing mechanism up to an agreed cap (cap to be reflective of the affordable housing contribution possible for open market sale units - i.e. the value difference between a private for sale scheme at 40% and a PRS scheme at 30%)

Question 48: What would be a suitable period to require the retention of private rented homes in that tenure and what compensation mechanisms are needed if such homes are sold into a different tenure before the end of the period?

We would suggest a period of 15 years with clawback as outlined in Questions 46 and 47. This period is proposed in the London Plan and is generally accepted by institutional investors

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

We consider that this should be agreed with each operator, and should be brief and relevant to planning matters. This could ensure all prospective tenants are offered the option of a three year tenancy.

Question 50: Should the area provide for other forms of specialist housing (including older people, students & travellers), either onsite or through seeking contributions for off-site provision?

We generally support this suggestion, but again a greater understanding of demand, need and viability is required. A comprehensive analysis of the demographic portrait of Cambridge and its surrounding environs over the next 25 years should be undertaken to assess how new policy interventions - such as NEC (intensified housing and employment uses; new housing 'products' to promote affordability and variety), new transport initiatives to improve access to employment, shopping, leisure and recreation etc, may affect demand and supply of different forms of housing for the local population catchment. In terms of 'housing mix', this might then manifest into redefining 'mainstream' housing, to expand into other groups such as students/graduates, first-time buyers, those requiring good quality rental properties, downsizers, elderly care.

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

We generally support this suggestion. This is a standard that ensures appropriate homes are delivered that meet the needs of the occupants. However, there may be some formats where exceptions may be appropriate - for example co-living formats including student and young professional accommodation, housing for 'downsizers' etc. These groups may prefer smaller homes with greater shared space and it may be appropriate to provide for this need in the context of a balanced housing offer. However, in these cases we would expect there to be clear requirements around the nature and quality of shared space. We would also encourage pilot testing (on a smaller scale) of more innovative solutions to housing, which might include other micro-living models that have not yet been used in Cambridge but have proved successful in other UK/international cities.

Question 52: Should the AAP develop space standards for new purpose built HMOs?

All new housing should meet the Technical Housing Standards and offer adequate shared spaces to not only provide adequate space in a HMOs scenario but above all provide homes that are future proofed as people's lifestyle changes and needs such as working from home also emerge. Future-proofed housing is to offer adequate space for a wide range of scenarios, not only HMOs. A specifically-developed space standards for new purpose built HMOs may prove unnecessary or irrelevant if HMOs within the AAP is then not delivered through a purpose-built type. Please see our response to Question 51.

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

We support the principle of ensuring that all homes have adequate and appropriate access to outdoor space and support the aspiration for most homes to have some private outdoor space. We would, at this stage, question whether it is realistic to expect that 100% of dwellings will have direct access to an area of private amenity space, given the quantum of development envisaged and the range of different housing typologies that will be necessary to deliver this quantum. In situations where it isn't appropriate to deliver private outdoor space, convenient access to high quality communal and public spaces would be provided. Ultimately, a flexible approach to residential amenity space must be taken, incorporating elements such as roof gardens and balconies as well as elements such as private gardens.

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

We generally support this suggestion in principle. This standard is meeting Part M of the Building Regulations, however due to the requirements of meeting a higher than normal housing number target on the Site, we require flexibility on how the standard is applied. It is important that the Cambridge Local Plan accessibility standards offers flexibility on how the standards are achieved across the many elements of the new masterplanned scheme. While designing for and incorporating accessibility standards is also accepted as a progressive way to future-proof new housing, it is important the standards do not affect the ability of the scheme to meet the density and the target housing required. Currently the Cambridge Local Plan has adopted the optional standard Part M4(2) and has also adopted M4(3) based on a percentage, which is still higher than the national standards, this may have an adverse impact on our scheme.

Question 55: Do you agree with the range of considerations that the AAP will need to have regard to in planning for new retail and town centre provision in the North East Cambridge area? Are there other important factors we should be considering?

The ambitious intentions for NEC are likely to see the creation of thousands of new homes and intensified employment opportunities forming part of new mixed, balanced and prosperous new communities. This new 'Quarter' will therefore require district and local centres to help support and sustain it. Non-residential uses will help create vitality and vibrancy to NEC.

Question 56: Should the Councils be proposing a more multi-dimensional interpretation of the role of a town centre or high street for the North East Cambridge area, where retail is a key but not solely dominant element?

We generally support this suggestion. We would highlight the importance of seeking innovative, creative and flexible solutions across the Site and this will be applied when considering how a District or Local Centre is planned and delivered. Longer term trends (national, regional and local) relating to retail and leisure uses will need to be carefully considered in arriving at a strategy that will support the long term vitality and vibrancy of NEC.

Question 57: What community facilities are particularly needed in the North East Cambridge area?

Opportunities will exist to provide access to new services and facilities for residents of NEC and existing surrounding local communities. In terms of the latter, where there are higher levels of deprivation, the cost of using new facilities will need to take account of affordability issues to ensure the cost of use is not prohibitive to those on no/low incomes.
Provision will need to be informed by the NEC Community Facilities Audit, whilst also taking account of the growth assumptions of NEC (including sizes and tenures of housing, as this will have potentially very different outcomes on need). Provision of facilities should offer flexibility and multi-functional spaces.

Question 58: It is recognised that maximising the development potential of the North East Cambridge area may require a different approach to meeting the sport and open space needs of the new community. How might this be achieved?

See our response to Question 24. Owing to the ambitious development aspirations of the Site (and NEC) it will be necessary to consider a comprehensive package of solutions (on and off-site) for open space and recreational strategy. This strategy will be complemented by the various improvements to green infrastructure provision in and beyond the AAP boundary, facilitating greater access opportunities by walking and cycling.

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

See our response to Question 24.

Question 60: Should open space provision within the North East Cambridge area seek to provide for the widest variety of everyday structured and unstructured recreational opportunities, including walking, jogging, picnics, formal and informal play, casual sports, games, dog walking and youth recreation?

We generally support this suggestion. It will be important to ensure that all spaces within the Site are fully optimised, and creative/innovative solutions should be considered to allow for flexible/multi-functional uses.

Question 61: Where specific uses are required to provide of open space as part of the development, should the AAP allow for these to be met through multiple shared use (for example school playing fields & playing pitches for the general public)?

See our response to Question 24.

Question 62: Within this overall approach, in particular, which option do you prefer in relation to carbon reduction standards for residential development?
A - a 19% improvement on 2013 Building Regulations (the current Cambridge Local Plan standard); or
B - a requirement for carbon emissions to be reduced by a further 10% through the use of on-site renewable energy (the current South Cambridgeshire Local Plan standard); or
C - a 19% improvement on 2013 Building Regulations plus an additional 10% reduction through the use of on-site renewable energy (combining the current standards in the Local Plans); or
D - consider a higher standard and develop further evidence alongside the new joint Local Plan.

At this stage we support Option D. This is a complex area of policy setting due to the current grid decarbonisation and emerging guidance from different bodies such as the UKGBC task force, and the GLA London Plan. The context of the electricity grid decarbonisation should be considered to ensure that any targets set do not create perverse outcomes in the future over the timescales of the development and should consider the appropriateness of energy efficiency targets as well as carbon targets.

The AAP should aim to be exemplar while also drawing on the most up to date emerging evidence.

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

Yes, we generally support the AAP sustainable design and construction approaches set out. However with regard to water recycling we think that while water recycling can be an important part of reducing water consumption if used inappropriately can be unsustainable. Therefore we would expect a rounded view to be taken as to when it is most appropriate to apply the highest levels of water recycling (as required by the maximum BREEAM credits for water efficiency), including an understanding of maintenance and carbon efficiency.
Question 64: Do you support the proposal for the AAP to be clear that review mechanisms should be built into any planning permissions in order to reflect changes in policy regarding sustainable design and construction standards in local and national policy? What other mechanisms could be used?

Yes we think it is important to recognise that not all future scenarios are foreseeable and that in order to avoid perverse outcomes in future it may be necessary to reappraise the policy requirements so that the most up to date and relevant standards are applied where necessary, reasonable and practicable.

It may also be advisable to follow guidance from notable charities and NGOs (e.g. UKGBC)

Question 65: Do you support the plan requiring delivery of site wide approaches to issues such as energy and water, as well as the use of BREEAM Communities International Technical Standard at the masterplanning stage?

Subject to further Masterplanning, technical assessment and feasibility testing, we generally support the approach to site wide water proposed and support the approach to innovate energy infrastructure such as smart energy grids. We support the view that infrastructure necessary for decentralised energy should be explored early on in consultation with relevant parties and that consideration should be given to a range of technologies and approaches to ensure the approach with the lowest carbon overall can be identified and supported.

We fully support the principles in BREEAM Communities and believe that while certification often brings a certainty of outcomes it does not always. The effective outcomes of applying BREEAM communities at this stage should be subject to further consideration.

Question 66: Are there additional issues we should consider in developing the approach to deliver an exemplar development?

Consideration should be given to the embodied impacts of buildings and infrastructure installed as well as opportunities to support the circular economy. Consideration should also be given to embracing and supporting innovative smart-tech and infra-tech initiatives where feasible and viable to do so.

Question 67: What approach should the AAP take to ensure delivery of a net gain in biodiversity?

In terms of the Site, owing to the on-going uses of land e.g. Water Recycling Centre, driving range, former Park and Ride site, it is considered likely that it will have limited biodiversity value. It will be necessary, at the relevant stage in the process, to carry out site specific investigations on the potential suitability of habitat for protected species, and to consider mitigation where appropriate. If the assumption is correct, it seems reasonable to believe that the Site can deliver net gains in biodiversity. Notwithstanding this, sites within NEC may be asked to consider biodiversity collectively, to show how habitat mosaics and corridors can be delivered on a more strategic basis. In this event, the AAP will need to provide greater clarity on what process is likely to be followed, and how this will be applied to individual development schemes.

Consideration will also need to be given to increasing the amount of tree canopy cover in NEC.

Consideration should be given to where biodiversity enhancements opportunities exist in nearby areas as well so that the best opportunities for linkages beyond the site boundary are identified as well as ensuring the best opportunities locally can be realised if necessary to meet the net gain requirements.

Question 68: Should the AAP require developments in the area to integrate SMART technologies from the outset?

We generally support the suggestion that NEC should seek to integrate SMART technologies from the outset. As we have previously noted, we will seek to encourage innovative, creative and adaptable solutions throughout all elements of development on the Site. It will be important to consider preparation of a digital strategy for NEC, to seek optimum speeds for broadband/fibre, opportunities to integrate SMART technology in homes, businesses and other development around NEC.

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

We support innovation throughout all elements of development on the Site (and indeed NEC). Rather than committing to any specific type of solution at this stage, it will be necessary to understand whether innovative systems used on other sites, such as North West Cambridge, can be applied on the Site.

Question 70: Do you agree that the AAP should prioritise land that can feasibly be developed early? Are there any risks associated with this proposed approach?

The obvious challenge with sites seeking early release/delivery is how they demonstrate that development will not prejudice the wider delivery aspirations of NEC. Where landowners/developers can explain how development can be carried out in a coordinated/comprehensive manner, it seems reasonable to expect that early delivery can be achieved. A coordinated/comprehensive approach must fully ensure that all development complies with s106 tariff/highways trips budgets, in an equitable manner.

As discussed later in Questions 79 and 80, we would encourage a positive policy approach be taken in supporting temporary/meanwhile uses in order to activate the Site in its earlier development phases, and to optimise economic and social benefits in the local area.

Question 71: Should the AAP include a relocation strategy in preference to leaving this to the market to resolve?

The representations of landowners and occupiers will inform the approach. It is considered that the AAP will need to identify and define a strategy for key sites/uses to be relocated, but maintain flexibility for others. Notwithstanding this the NEC has significant potential to deliver economic, social and environmental benefits, and whilst there are a relatively small number of landowners, the strategic opportunities must not be compromised by one or more parties that are unwilling to support the delivery of the NEC. Accordingly, the Councils cannot discount the possibility of using their CPO powers if required.

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

An infrastructure delivery plan should be prepared for the North East Cambridge Area to identify the infrastructure required and the costs associated with those projects, in order to inform discussions on planning obligations. It would be reasonable to expect all development within the area to contribute towards the required infrastructure, where it benefits the AAP area as a whole rather than individual sites/landownerships

Question 73: What approach do you consider the most appropriate basis on which to apportion the cost of the infrastructure requirements arising from different land uses to ensure an equitable outcome?

We consider that this should form part of a specific study that includes, inter alia, the following considerations:
*Identify the infrastructure required across the AAP area that is necessary to delivering the comprehensive vision. This might include key routes, connections, bridges / underpasses, transport, education, energy/utilities, social etc.
*Identify where these are most appropriately located to meet the AAP vision.
*Establish a cost base for these, including appropriate cost of land recognising that in some cases it would be otherwise used for residential or other development
*Establish an appropriate equalisation formula across the AAP, levied on all new development. This could be one or a combination of a tariff per m2, per net acre etc and may be varied by use class.
*Set this out in a policy / legal framework with an appropriate indexing mechanism

Question 74: How should the AAP take into account potential changes over time, both positive and negative, that might affect development viability?

We consider that this should form part of a specific study that includes, inter alia, the following considerations
*ensuring that development continues steadily over potentially a number of economic cycles - this possibility should be acknowledged and planned for at the outset
*Any viability test whereby s106 or AH requirements would be reduced would need to be carefully calibrated to ensure that infrastructure is protected.
*A review mechanism within the S106 Agreement would allow viability to be reassessed if circumstances change.

Question 75: Do you agree with the proposal to require land assembly where it can be demonstrated that this is necessary for delivering the agreed masterplan for the North East Cambridge area and/or the proper planning of development?

Yes. This does not directly affect U+I. Land assembly will help to ensure the delivery of comprehensive redevelopment of NEC.

Question 76: Should the AAP state that the Councils will consider use of their Compulsory Purchase powers? If so, should the AAP also set out the circumstances under which this would appropriate?

The NEC has significant potential to deliver economic, social and environmental benefits, and whilst there are a relatively small number of landowners, the strategic opportunities must not be compromised by one or more parties that are unwilling to support the delivery of the NEC. It therefore seems appropriate for the AAP to specify how the Councils will use their CPO powers if required, and the circumstances for doing so. This will need to include the viability and timescales of pursuing a CPO process.

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

Yes. There are a range of stakeholders and landowners involved in the development at the North East Cambridge area, and the successful delivery of NEC will require a coordinated approach. This will need to consider a range of issues including connectivity, infrastructure locations, parking/trip budget, smart-city coordination, delivery programmes, design principles, energy/utilities and waste etc.

Question 78: Do you agree with the Councils' proposed approach to dealing with planning applications made ahead of the AAP reaching a more formal stage of preparation?

Yes. It is agreed that a coordinated approach is required and decisions on applications should be made against the AAP with appropriate, equitable contributions made.

Question 79: What types of 'meanwhile uses' should the AAP support for the North East Cambridge area?

We would suggest a range of 'meanwhile uses' could be appropriate for NEC, and would not expect policy to impose any particular restriction on types of use. The emphasis should be on promoting innovation and creativity, with meanwhile uses serving to provide early foundations for the new Quarter that will emerge and subsequently replace the meanwhile uses in the coming years. Meanwhile uses could therefore provide start-up/incubator accommodation for emerging/expanding sectors, pop-up/small-scale A class uses, community space to begin community cohesion with surrounding neighbourhoods etc. A positive policy approach to obligations and planning requirements will be needed to encourage temporary/meanwhile activation, helping to avoid onerous situations that might otherwise render creative initiatives unviable.

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

It seems unnecessary to impose a limitation on the scale of a proposed 'meanwhile use', as the purpose of a meanwhile use is, fundamentally, to make optimum use of a site that will otherwise be under-utilised for many years. This can have many short-term economic and social benefits. A policy limitation may stifle innovation and creativity. It is considered likely that many of the meanwhile use proposals will require formal planning consent, which will provide the Local Planning Authority with the ability to control and enforce development that is deemed inappropriate.

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

No. A minimum period should be based on the need and timetable for the permanent development. For the most successful meanwhile initiatives a reasonable period of operation is required in order to recoup the initial capital investment.

Question 82: Should the AAP also include a requirement for 'meanwhile uses' to demonstrate how they will add vibrancy and interest and/or deliver on the wider development outcomes and vision for the North East Cambridge area?

No. 'Meanwhile' uses are temporary in nature and an approach that seeks to make efficient use of land, in a compatible manner with surrounding uses, should be encouraged.

Question 83: What negative or positive impacts might the proposed plans have on residents or visitors to Cambridge with low incomes or who have particular characteristics protected under the Equality Act 2010? (The protected characteristics are age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex, and sexual orientation.)

We strongly support the intention of the Vision for NEC and Objective 5, to ensure social and economic inclusion, and as stated in our response to Question 5, would seek the addition of the word 'culturally' within the Vision i.e. 'North East Cambridge - a socially, culturally, and economically inclusive...'

It is recognised that NEC lies within close proximity of two highly deprived wards in Cambridgeshire, and that regeneration on the scale envisaged will create significant socio-economic opportunities for a wider catchment beyond the AAP boundary. Development on the Site, for instance, will create long term employment across a multitude of sectors and skill ranges, improved connectivity around the NEC and access to new services and facilities. We support the intention of the Councils to undertake a Health Needs and Impact Assessment, across an appropriate study area for the NEC, in order to better understand the challenges and issues faced in neighbouring wards, so as to link into opportunities that will arise in NEC.

As stated within our response to Question 5 we generally support the application of local plan accessibility in the NEC. This standard is meeting Part M of the Building Regulations, however due to the requirements of meeting a higher than normal housing number target on the Site, we require flexibility on how the standard is applied. It is important that the Cambridge Local Plan accessibility standards offers flexibility on how the standards are achieved across the many elements of the new masterplanned scheme. While designing for and incorporating accessibility standards is also accepted as a progressive way to future-proof new housing, it is important the standards do not affect the ability of the scheme to meet the density and the target housing required. Currently the Cambridge Local Plan has adopted the optional standard Part M4(2) and has also adopted M4(3) based on a percentage, which is still higher than the national standards, this may have an adverse impact on our scheme.

Question 84: Do you have any other comments about the North East Cambridge area and/or AAP? Are there other issues and alternatives that the councils should consider? If you wish to make suggestions, please provide your comments.

We would encourage a specific section on education and health provision within the NEC, noting the likelihood that if on-site provision is required, it may require different formats/approaches on how such provision is made i.e. traditional forms of provision in Cambridgeshire are unlikely to be suitable in a high density urban regeneration scheme of this nature.

If off-site provision is considered to be more appropriate, comment should be given on how and where need is expected to be accommodated (for instance it may be more appropriate to extend existing or proposed schools in Cambridge, to create additional Forms of Entry, rather than have a lower number of Forms of Entry on-site that falls below the recommended minimum sizes).

Introduction

Cambridge City Council and South Cambridgeshire District Council is consulting on Issues & Options for the North East Cambridge AAP. The consultation deadline is 25th March 2019. The draft response on behalf of U+I Group PLC ('U+I') is set out below. U+I have been selected by the landowners Anglian Water and Cambridge City Council as Master Developer for land outlined in red in the accompanying Site Plan ('the Site'). It is noted that Cambridge City Council also own other land beyond the Site, which may be the subject of other representations.

The representations contained herein relate primarily to the development intentions for the Site, but also in the context of the wider AAP area (as sites within the AAP boundary are largely intrinsically linked).

Representations

Question 1: Do you agree with changing the name of the plan to the 'North East Cambridge Area Action Plan'?

It is recognised that there is a need for a collective reference for the AAP area. This will provide consistency and clearer definition as the process evolves. Whilst it is inevitable that sub-areas of the AAP will emerge with different branding names and strategies, this will have more relevance to the individual sub-area concerned, in creating identity when publicising forthcoming planning applications through to marketing/sales disposals.

Question 2: Is the proposed boundary the most appropriate one for the AAP?

Generally, we support the proposed boundary for the AAP area. We would, however, make two observations/comments.

Firstly, it seems logical to include the site of Cambridge Regional College ('CRC') within the boundary. It is noted that in paragraph 3.5 comment is made that it is not expected to undergo major change in the way other sites across NEC are. However, CRC considers itself to be 'one of the best Further Education Colleges in the country for 16-18 year old level 3 achievement and a leading apprenticeship provider, with thousands of full time students and apprentices currently in training'. The significant range of vocational courses it offers could be positively utilised to support the long-term construction process around NEC (e.g. architectural technology, mechanical engineering, electrical, carpentry, bricklaying courses and apprenticeships), and then the on-going operational phases of the different sub-areas of NEC (e.g. from courses relating to biological science for industry, laboratory technicians and computing technologies, to business and catering and hospitality). It therefore has the potential to play an important learning and development role in the future NEC area. The built form of the current campus appears to be relatively low density, with large areas of used for surface level car parking. Buildings are predominantly 2-3 storeys in height. With the transformation of NEC, recognising the different approaches to internalised trips/reduced car parking, and taller buildings, it would seem likely that the estate management of CRC might change in the future, and if so, it should be included in the AAP.

Secondly, we would comment that, owing to the nature of NEC, development is likely to be high density, optimising the use of all land to work efficiently and effectively. The strategy for on-site Public Open Space is likely to focus on qualitative provision, than quantitative, with a stronger emphasis on formal recreational and leisure space than informal open space. Access to the latter however, is likely to be facilitated through new and improved connections to the east (potentially including land to the east of the railway line north of Cambridge North Train Station, to the river) and north (potentially including land to the north of the A14, such as Land to the south of Cambridge Road, and land including/extending Milton Country Park) of NEC. We would therefore simply pose the question about whether there is a need to include within the AAP boundary additional land that could provide informal open space, biodiversity and drainage functions, which might otherwise not be achievable within the single control of the NEC boundary. It is considered that land to the north and east of the current AAP boundary would primarily be used to facilitate access to green infrastructure for NEC.

Question 3: In this chapter have we correctly identified the physical characteristics of the North East Cambridge area and its surroundings?

Generally, yes. However, we consider it might be beneficial to include more information about the composition of site areas. For instance, on the employment parks, providing details about site area, total floorspace of buildings on the park (including extant planning consents) and the range of authorised planning uses e.g. % B1a uses, %B1b uses, estimated no. of employees, audit of authorised car parking spaces, audit of public open space (estimated total hectares). This would help to inform a baseline of land use within NEC, and then contribute in developing future strategy e.g. highway trip budget, employment strategy, connectivity and green infrastructure etc.
We would also note that it would be beneficial to have mapping information available relating to the environmental constraints identified e.g. noise, air quality, odour, important habitats.
Finally, it would be beneficial to show the broader extents of key infrastructure for NEC, including the full Chisholm Trail link (connecting NEC to Cambridge City, and the south of Cambridge (Addenbrookes), committed routes for other new cycle, pedestrian and public transport in and around the City, and the proposed Greenways link to Waterbeach).

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

In general, yes. However, we note that there is no reference to Archaeology and Heritage, and would suggest that comment is given about this, even if it is considered that NEC has limited archaeological significance. In terms of heritage, whilst we believe that there are no listed buildings, conservation areas, or other notable heritage constraints within NEC, the intention for taller buildings in NEC will need to be more widely considered in respect of longer-distant views and townscape issues (historic core of Cambridge). Taller buildings may also have potential implications for Air Safeguarding Zones (consultation required with Marshall Airport and the Ministry of Defence on structures over 15m in height), and the Mullard Radio Astronomy Observatory (consultation with the University of Cambridge). We acknowledge that the issue of building heights and taller buildings is likely to be assessed as part of the on-going Landscape Character and Visual Impact Assessment that is being undertaken by Cambridge City Council (it is understood that a 'Stage 1' exercise has already been commissioned), and that the findings are then likely to inform future stages of this AAP process.

We would also suggest consideration be given to the inclusion of Green Belt boundaries around NEC. This will help provide clarity to interested parties that all land envisaged for development and associated physical infrastructure will be accommodated on non-Green Belt land. It will also help to provide reassurance that the development aspirations for NEC will not automatically lead to further development beyond the identified boundaries, unless it is deemed to be 'appropriate development' (i.e. not 'inappropriate' as defined in the National Planning Policy Framework'), or that exceptional circumstances are demonstrated in future Local Plans, or a Very Special Circumstances argument is made to support development via a planning application process. In all cases, strict mechanisms for controlling additional future development beyond NEC will apply.

Reference should also be made to the presence of UKPN's overhead power cables (132KV) that span across the AAP boundary. In terms of ensuring optimum reuse of the Site (and indeed other sites, including Cambridge Science Park), we would support a policy seeking their diversion underground.

Question 5: Do you agree with the proposed Vision for the future of the North East Cambridge area? If not, what might you change?

Yes, we support the proposed Vision for NEC. The addition of the word 'culturally' might benefit this Vision further (in the context of 'North East Cambridge - a socially, culturally, and economically inclusive....)

Question 6: Do you agree with the overarching Objectives? If not, what might you change?

Generally, we support the overarching Objectives. The addition of the words 'Natural Capital' might benefit Objective 7 further (in the context of '...connecting and improving biodiversity to achieve a Natural Capital net gain....)

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

It is noted that the Concept Plan can only be treated as indicative at this stage in the AAP process, until the outcomes of the various Supporting Studies are known (notably Landscape Character and Visual Impact Assessment, Development Capacity Study, NEC AAP Transport Assessment, NEC Development Viability Assessment, NEC Infrastructure Delivery Plan), and wider consultation with relevant interested parties (e.g. landowners, developers, local communities, local authority bodies etc) has been carried out.

We support the residential-led mixed use allocation for the Site. We support the aspiration to create high quality pedestrian, cycle and public transport connectivity across the AAP area. We support the indication that a Mixed Use District Centre will be provided on the Site though we would suggest that its optimal location can only be determined after further study and masterplanning work. There may also be a need to include an additional Mixed Use Local Centre in the northern half of the Site (subject to further Masterplanning and an assessment on accessibility). We support the intention to provide and integrate Green Infrastructure throughout the AAP boundary, but what provision is made (and how/where it will be provided) will need to be determined following further studies/assessment and Masterplanning. Further consideration will need to be given to the suggested Industrial Development Sites in the north east corner of the Site, to understand what the rationale is for proposing to relocate existing industrial land at Nuffield Road and Cowley Road, to another part of the AAP site. It is assumed that the suggestion is made on the basis that it will provide noise abatement from the A14 to the new residential elements of the Site. However, we consider that there may be other more preferable solutions for controlling noise and, in Masterplanning terms it is less desirable bringing industrial-related traffic through a predominantly residential site. In the absence of clear justification for seeking relocation of industrial uses, we cannot support the industrial element of the proposal.

We aren't yet persuaded that the proposed location and quantum of industrial use is optimal. In particular we have concerns that this is currently shown at the furthest point from strategic highway connections. We also believe that different models and formats of industrial development should be further explored, specifically whether this should be concentrated in a single location, or whether it might be incorporated within a mixed-use approach throughout the Site.

We do not necessarily agree that the Site represents the best opportunity with the overall AAP area to accommodate a significant concentration of industrial uses in a single location.

We would suggest that the Cambridge Business Park is shaded as an Opportunity for Employment Intensification.

In addition to our response for Question 2, we would suggest that the CRC land we would suggest that this land is included within the AAP boundary, and that a new shading is applied that refers to an Opportunity for Education Intensification.

Question 8: Do you agree that outside of the existing business areas, the eastern part of the North East Cambridge AAP area (i.e. the area east of Milton Road) should provide a higher density mixed use residential led area with intensified employment, relocation of existing industrial uses and other supporting uses?

Generally, we support the initial development intentions for the area east of Milton Road. It is considered that this area could accommodate a high density mixed use residential-led development following the relocation of the existing Cambridge Water Recycling Centre and other industrial uses (subject to viability and finding suitable relocation site(s)) from the Site. A comprehensive, design-led, approach across the AAP will help maximise the redevelopment potential of a significant brownfield site in a highly sustainable location.

Question 9: Should Nuffield Road Industrial Estate be redeveloped for residential mixed use development?

Yes, we agree that consideration should be given to relocating existing industrial uses on the Nuffield Road Industrial Estate, in preference for higher density residential-led mixed use redevelopment. Consideration should be given to the viability of doing so (industrial land values are currently relatively high), and where existing businesses will be relocated. An Industrial Relocation Strategy might be appropriate, in order to understand what factors are important to businesses e.g. last mile strategies and what alternative sites might be available to accommodate relocation requirements. ]

As outlined in Question 7, the suggestion to relocate industrial uses from Nuffield Road Industrial Estate to the north east corner of the Site needs to be explained and justified. At this stage we do not support the suggestion to relocate industrial uses to the north-east corner of the Site.

Question 10: Do you agree that opportunities should be explored to intensify and diversify existing business areas? If so, with what sort of uses?

Yes, we broadly support this suggestion, subject to the establishment of a robust and equitable approach to Highways Trip Budget apportionment and s106 tariff system across the wider AAP area. The Cambridge Science Park was first established on the principle of accommodating 1-2 storey, low density commercial buildings within an attractive strategic landscape/parkland setting. Whilst much of the strategic landscaping remains, latter phases of the Science Park have sought to intensify development density, with taller buildings, lower car parking provision, and limited on-plot landscaping (other than to lessen/soften the impact of new development). This approach has been complemented by the introduction of Cambridge North Station Interchange, which has significantly improved accessibility via non-car modes. The growth aspirations now anticipated for the AAP area signals a radical change in approach to new development. New residential communities will be supported by existing and intensified employment and educational opportunities, potentially providing live and work/learning opportunities within walking/cycling distance of each other. Furthermore, access to inter alia Cambridge North, the Guided Busway, and the Chisholm Trail will support accessibility to existing business areas from a much wider catchment, therefore helping to improve the means of accessing work without the need to do so by car.

Opportunities to provide a greater quantum and diversity of employment should be encouraged. This will consolidate and strengthen the concept of the Cambridge Phenomenon, by creating a greater range and quantum of high quality accommodation for new businesses, in close proximity to a critical mass of similar businesses, thereby helping to support knowledge sharing and collaboration through co-location.

In order to promote diversity of employment types, planning policy consideration might be given to encouraging a certain percentage of 'affordable employment', to support the growth of new start-up businesses that require the same close links with similar businesses but cannot afford (and do not currently need) accommodation that becomes available.

Question 11: Are there any particular land uses that should be accommodated in the North East Cambridge area?

The North East Cambridge area should support any use that demonstrably contributes to the Vision and Objectives of the AAP area.
The AAP provides a significant opportunity to create thousands of new homes in a highly sustainable location. The growth of housing in this area will be supported by the economic benefits derived from the long-established science, innovation and business parks (many of which will be intensified), that have collectively grown from the success of clustering knowledge-based industries in close proximity of one another. The housing element of the Site will improve supply and affordability of high quality new homes to the many thousands of employees on these parks, helping to reduce the number of car movements on Milton Road. New homes and jobs on the scale envisage will need to be served by a number of social, retail, community, health, education, leisure and recreation facilities,

Question 12: What uses or activities should be included within the North East Cambridge AAP area which will create a district of culture, creativity and interest that will help create a successful community where people will choose to live and work and play?

It is considered that the inclusion of schools, community facilities, retail and leisure uses, open space, and transport services, in conjunction with walking and cycling connections to neighbouring areas will provide the attributes of a successful community.

The NEC AAP must recognise the wider role it plays in creating opportunities for surrounding communities, of which two neighbouring wards - East Chesterton and Kings Hedges - currently suffer from high levels of deprivation (included in the top three of most deprived wards in Cambridgeshire). The benefits of the AAP area should extend to these areas, to create new employment, education, social, leisure and recreation, health and community opportunities. Where new facilities are introduced to areas experiencing deprivation, a key challenge for optimising use of such facilities is affordability. Free or subsidised charging mechanisms should therefore be considered when providing new facilities for instance e.g. hire of sports pitches, meeting rooms etc.

It should, however, be recognised (and indeed it is in Question 79) that the ambitious development aspirations for the Site and wider AAP area will take a number of years to comprehensively plan and deliver. Certain elements will be possible to deliver early. Notwithstanding this, there is the opportunity to introduce 'meanwhile/worthwhile' uses the area as the transition progresses. Meanwhile/worthwhile uses offer creative and innovative ways of optimising sites on a stop-gap basis, creating a temporary opportunity to capture economic and/or social benefits for the wider area in the period between the closure/or reduction of an existing site operation and the commencement of the intended new development.

Question 13: Should the AAP require developments in the North East Cambridge AAP area to apply Healthy Towns principles?

NEC will provide a considerable opportunity for creating a healthy new community, and supporting neighbouring communities, through access to high quality housing, a design approach founded on sustainable modes of travel (walkable neighbourhoods), and improved employment, shopping, health, education, leisure and recreational opportunities. We also support the intended preparation of the Health Impact and Needs Assessment for NEC, which will take account of the wider deprivation challenges faced in the neighbouring wards of East Chesterton and Kings Hedges.

Question 14: How should the AAP recognise and make best use of the existing and potential new links between the AAP area and the CRC (Cambridge Regional College)?

Please see our response to Question 2.

Question 15: Should clusters of taller buildings around areas of high accessibility including district and local centres and transport stops form part of the design-led approach to this new city district?

We strongly support the principle that the greatest development densities should be located in the areas of greatest accessibility and public amenity. This maximises the potential for sustainable travel patterns and establishes a critical weight of local demand for leisure, cultural and retail uses.

It is important to note that 'high-density' does not automatically mean 'tall' and that compact mid-rise development can often be denser than taller development, particular where the latter is compensated for by a smaller overall development footprint. Compact mid-rise also typically enables a wider range of dwelling types and external amenity space, meeting a wider range housing needs.

We favour a 'transect' based approach to masterplanning which will ensure the density, scale, typology, and uses of development are allocated across the site as a whole and within each neighbourhood in a coordinated way, following the accessibility principle described above and responding to the opportunities and constraints of the Site. This may not mean 'clusters' - it could for example mean that the highest densities are located in 'corridors' along the primary streets, and/or at edges where having denser development acts to shelter lower-scale development from adjacent visual or noise intrusion. The masterplan will be backed up by a design code that will identify/mandate appropriate typologies for achieving the requisite densities in ways that are acceptable in other respects.

In addition to accessibility and other local factors, it is important to note that the extent and location of denser development will be affected by a range of detailed studies and appraisals (including Landscape Character and Visual Impact Assessment), that will recognise - and then balance - the challenges of creating areas of higher density and taller buildings in a highly sustainable location that is, nonetheless, on the edge of Cambridge with areas of open countryside beyond. This may also militate against achieving density through height.

Question 16: Should the AAP include any or a combination of the options below to improve pedestrian and cycling connectivity through the site and to the surrounding area?

A - Create a strong east-west axis to unite Cambridge North Station with Cambridge Science Park across Milton Road. This pedestrian and cycle corridor would be integrated into the wider green infrastructure network to create a pleasant and enjoyable route for people to travel through and around the site. The route could also allow other sustainable forms of transport to connect across Milton Road.

Yes. A strong east-west axis should be included to connect the different parts and proposed uses within NEC, and to encourage movement within the site by sustainable modes of transport.

B - Improve north-south movement between the Cowley Road part of the site and Nuffield Road. Through the redevelopment of the Nuffield Road area of NEC, it will be important that new and existing residents have convenient and safe pedestrian and cycle access to the services and facilities that will be provided as part of the wider North East Cambridge area proposals.

Yes.
C - Upgrade connections to Milton Country Park by both foot and cycle. This would include improving access to the Jane Coston Bridge over the A14, the Waterbeach Greenway project including a new access under the A14 (see Transport Chapter), as well as the existing underpass along the river towpath.

Yes. It is considered that improvements to connections with Milton Country Park and with existing and proposed pedestrian and cycle routes will be important for the success of development within the AAP. It is anticipated that NEC will provide a high density residential development, to take advantage of the close proximity of employment areas and public transport services, but which might limit opportunities for large scale open space/recreation areas. Therefore, it will be important to ensure that any proposal for an underpass will maximise connectivity through the Site, capitalising on permeability and wider Green Infrastructure initiatives (e.g. Waterbeach Greenway, Chisholm Trail, improving the public realm function of the 1st Drain etc).

D - Provide another Cambridge Guided Bus stop to serve a new District Centre located to the east side of Milton Road.

We support the suggestion to improve public transport accessibility around NEC but further work should be undertaken to determine whether an additional 'guided' busway stop is required or whether a 'normal' bus service, which could feasibly use the same buses as those on the Busway, could deliver the same benefits.

E - Increase ease of movement across the sites by opening up opportunities to walk and cycle through areas where this is currently difficult, for example Cambridge Business Park and the Cambridge Science Park improving access to the Kings Hedges and East Chesterton areas as well as the City beyond.

We very much support opportunities to increase the ease and convenience of walking and cycling movements across sites in NEC, as this will strengthen the concept of promoting internalised trips and reduce the reliance on travel by car.

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

It is noted that the River Cam towpath is identified as a route within the Waterbeach Greenway project, and it would be appropriate to take the opportunity to provide a pedestrian and cycling connection from this route into NEC, subject to the availability of funding.

The high density redevelopment of NEC is unlikely to achieve the level of Public Open Space that might otherwise be required under local plan policy. The focus is instead likely to be on securing high quality, flexible-use open space on-site, and improving/providing new connections to informal open space networks to the north and east of the AAP area (including the Waterbeach Greenway). Accordingly, an appropriate means of accessing off-site Green Infrastructure for NEC will be required, and the suggestion of a pedestrian/cycle bridge would facilitate this.

Please see our responses to Questions 2 and 7.

Question 18: Which of the following options would best improve connectivity across Milton Road between Cambridge North Station and Cambridge Science Park?
A - One or more new 'green bridges' for pedestrians and cycles could be provided over Milton Road. The bridges could form part of the proposed green infrastructure strategy for NEC, creating a substantial green/ecological link(s) over the road.
B - Subject to viability and feasibility testing, Milton Road could be 'cut-in' or tunnelled below ground in order to create a pedestrian and cycle friendly environment at street level. This option would allow for significant improvements to the street which would be more pleasurable for people to walk and cycle through.
C - Milton Road could be significantly altered to rebalance the road in a way that reduces the dominance of the road, including rationalising (reducing) the number of junctions between the Guided Busway and the A14 as well as prioritising walking, cycling and public transport users.
D - Connectivity across Milton Road could be improved through other measures. We would welcome any other suggestions that would improve the east-west connectivity through the site.
E - Other ways of improving connections (please specify)

In response to all five options listed above, we generally support the principle for securing high quality east-west connectivity. However, the means of crossing Milton Road will involve a range of complex issues, which cannot be determined at this stage. The crossing solution(s) should not ultimately be compromised by concerns about short-term disruption and inconvenience. The east-west axis will be fundamental in the overall success of NEC, and the justification for internalising trips will be partly made on the basis that pedestrian and cycle connectivity across NEC will be safe and convenient (and therefore likely to be commonly used as a means of travel).

Option A is considered to be the preferred option as it provides the opportunity to create a substantial green link over the road without adversely affect the flow of traffic on Milton Road, which has existing network capacity issues. It will also limit the impact on the operation of the Milton Road during construction when compared with either Option B and C.

Option B would likely result in significant disruption to the road network during construction and would likely require the lowering or redirecting or Statutory Undertakers Utilities. Both Option B and C would result in alterations to the access junctions into the Science Park and the Site, both of which have limited access opportunities for their respective sizes.

Question 19: Should development within the North East Cambridge area be more visible from Milton Road, and provide a high quality frontage to help create a new urban character for this area?

We generally support the suggestion of making new development within NEC more visible from Milton Road and providing a high quality frontage to create a new urban character for the area. Milton Road is currently a highly car dominated environment, with a number of confusing junctions serving Cambridge Science Park and Cowley Road. However, it is noted that Milton Road acts as a key north / southbound route into and out of Cambridge, and the Milton Interchange forms part of the Strategic Road Network and connects Cambridge to the A14 (a major east to west route, which has recently been upgraded to improve capacity). Given the level of traffic using this stretch of the Milton Road to access the Strategic Road Network at this location, the potential to reduce traffic to provide a high quality new urban character for the area may be limited in the short term. Notwithstanding this, where Milton Road runs southwards the nature of the road starts to change and becomes more urban in nature, potentially becoming more conducive to active frontage and activity on the footway.

Question 20: Do you agree with proposals to include low levels of parking as part of creating a sustainable new city district focusing on non-car transport?

Yes, we generally support this principle NEC provides an opportunity to reduce levels of parking, as part of a package of transport measures including new and additional walking and cycling routes, public transport services, and car share schemes. However, we would also suggest that interim car parking strategies might need to be considered, to support 'pioneer' uses/development during transitional phases of NEC i.e. until the full package of transport infrastructure and initiatives can be fully realised. As new infrastructure/initiatives are introduced, interim car parking can be gradually phased out.

Question 21a: In order to minimise the number of private motor vehicles using Milton Road, should Cambridge Science Park as well as other existing employment areas in this area have a reduction in car parking provision from current levels?

We very much support opportunities to reduce the reliance on travel by car in and around NEC, and instead increase the ease and convenience of walking and cycling movements across sites in NEC, as this will strengthen the concept of promoting internalised trips.

Question 21b: Should this be extended to introduce the idea of a reduction with a more equitable distribution of car parking across both parts of the AAP area?

Yes, as part of a package of transport measures to encourage travel by sustainable modes of transport.

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

Yes, subject to further understanding of the requirements of businesses and the needs of residents. The North East Cambridge area could include a number of delivery/collection hubs.

Question 23: Should development within the North East Cambridge area use car barns for the storage of vehicles?

We support the idea of using car barns, as part of a wider package of parking solutions across NEC. Whilst it is recognised that private on-plot parking is unlikely to be widely encouraged, there will inevitably be demand from some residents to have access to the use of a car/secure car parking but this should be priced accordingly to the end user. Car barns provide communal access to parking, and are typically located in less convenient locations in order to discourage frequent use. As an example, if a car was needed to do a weekly shop, the resident would park outside their property to unload their car and then move the car to a car barn. Car barns can also be used by 'car clubs', so that a resident can book a car for a certain period of time but not have the long-term cost and use commitment to owning a private car. The versatility of car barns should also be recognised, as parking can be let on a temporary basis and, as trends change, can be converted into alternative uses to reduce car usage further.

Question 24: Within the North East Cambridge area green space can be provided in a number of forms including the following options. Which of the following would you support?
A - Green space within the site could be predominately provided through the introduction of a large multi-functional district scale green space. Taking inspiration from Parker's Piece in Cambridge, a new large space will provide flexible space that can be used throughout the year for a wide range of sport, recreation and leisure activities and include a sustainable drainage function. The sustainable drainage element would link into a system developed around the existing First Public Drain and the drainage system in the Science Park. The green space could be further supported by a number of smaller neighbourhood block scale open spaces dispersed across the site.
B - Green spaces within the site could be provided through a series of green spaces of a neighbourhood scale that will be distributed across the residential areas. These green spaces will also be connected to the green infrastructure network to further encourage walking and cycling. Again, these spaces will include a sustainable drainage function and link into the existing First Public Drain and the Science Park drainage system.
C - Enhanced connections and corridors within and beyond the site to improve the biodiversity and ecological value as well as capturing the essential Cambridge character of green fingers extending into urban areas. These corridors could also be focussed around the green space network and sustainable drainage and would reflect the NPPF net environmental gain requirement.
D - Green fingers to unite both sides of Milton Road and capitalise on the existing green networks.
E - Consideration of the site edges - enhancement of the existing structural edge landscape and creating new structural landscape at strategic points within and on the edge of NEC. This would also enhance the setting to the City on this important approach into the City.
F - Creation of enhanced pedestrian and cycle connectivity to Milton Country Park and the River Cam corridor.

In response to all six options listed above, we support the principle for securing high quality green infrastructure across NEC. Subject to further capacity testing and Masterplanning, on-site provision might feasibly take the form of a larger green space for the whole NEC and complemented by smaller 'neighbourhood scale' spaces and enhanced connections and corridors to off-site green infrastructure. We aren't persuaded that Parkers Piece is an appropriate comparable for the size and function of this space but do consider that the green space should draw lessons from existing green spaces in Cambridge. However, in supporting the theme of innovation at all stages of the development it will be important to consider smart solutions for the open space strategy, maximising flexibility across all areas of on-site open space. For instance, playing fields associated with on-site school provision should be available to the wider community, at times when it is not required by the school. Management and security issues will need to be carefully considered in this regard. Landscape vegetation should encourage biodiversity, whilst also performing softening/screening functions. Formal playspace should be able to accommodate multi-use activities during the day and evening and throughout the year. Green infrastructure might incorporate elements of food growing e.g. fruit trees, herbs, and vegetables, enabling free access to foods that help promote healthier lifestyles.

In terms of the suggestion of how open space will be provided (and in what format and amount), this cannot be determined at this stage of the process. A series of studies and assessments have been or are being commissioned by Cambridge City Council, which will help inform development principles and Masterplanning. Consultation will also need to be carried out with a number of interested parties, including landowners, developers, local communities and local authority bodies. Therefore, we are neither supporting nor objecting to any of the suggested options at this stage.

Question 25: As set out in this chapter there are a range of public transport, cycling and walking schemes planned which will improve access to the North East Cambridge area. What other measures should be explored to improve access to this area?

We generally support the suggested options for improving public transport, cycling and walking accessibility around NEC. The proposed Waterbeach Greenway should be directed through the Site, to create a coherent route from Waterbeach to the station. This will allow future residents of the Site to cycle to the station helping to providing a means of travel for the 'first mile / last mile' of the journey to / from the station.

A new route for a busway from the proposed Waterbeach development should be routed through the Site down to Cambridge North Station. Stops on the route could form transport interchanges linking to other bus routes and cycle routes. High quality cycle links should be implemented to connect into existing infrastructure such as the Chisholm Trail.

The route of these two transport spines through the Site will help develop a single coherent sustainable transport corridor down to the station allowing seamless interchanges between transport modes where the routes intersect with one another. The interchanges will be located within a high-quality urban environment close to high density district centres and attractive locations encouraging linked trips and improving access to the district centres by public transport.
It will important to ensure that consideration is always given to promoting access beyond the AAP boundary (as currently shown), such as recognising the education/social role that CRC plays in the west, the retail and leisure/recreational/biodiversity roles of Tesco and Milton Country Park in the north, the leisure/recreational/biodiversity role of the river and green corridors in the east, and the existing Cambridge communities in the south.

Question 26: Do you agree that the AAP should be seeking a very low share of journeys to be made by car compared to other more sustainable means like walking, cycling and public transport to and from, and within the area?

We support the concept of encouraging a greater share of non-car modes of travel for NEC, but note that it is a concept that will need to be accepted by all landowners/occupiers in the AAP boundary in order for it to be successfully implemented. This is broadly in accordance with the advice from the Ely to Cambridge Transport Study, and will be further tested in the NEC AAP Transport Assessment work (due to be commissioned).

Question 27: Do you have any comments on the highway 'trip budget' approach, and how we can reduce the need for people to travel to and within the area by car?

We support the principle of a 'trip budget' as there is limited scope for large scale engineering interventions to create more capacity on the road network. However, the trip budget must be carefully considered and tested to ensure that it is both suitable and realistic. Appropriate measures will need to be employed if the trip budget is exceeded. The monitoring process will need to be carefully considered, as various land uses across the AAP site will be allocated a share of the trip budget.

Question 28: Do you agree that car parking associated with new developments should be low, and we should take the opportunity to reduce car parking in existing developments (alongside the other measures to improve access by means other than the car)?

We generally support the concept of encouraging a greater share of non-car modes of travel for NEC. This is broadly in accordance with the advice from the Ely to Cambridge Transport Study, and will be further tested in the NEC AAP Transport Assessment work (due to be commissioned). It is recognised that many existing employment uses, such as those in Cambridge Science Park, St John's Innovation Park and Cambridge Business Park, will have authorised car parking at significantly higher levels than what is now intended for NEC. We would support the Councils working with various landowners in exploring innovative/incentivised ways of reducing car usage from those sites.

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

We support the suggestion of requiring high levels of cycle parking from new developments. This approach will be supported by the new cycling infrastructure that is planned for Cambridge, including the Chisholm Trail and Waterbeach Greenways. Cycling helps support healthy lifestyles, and is a viable means of travelling around a compact city, assuming that safe and convenient routes and secure/covered parking can be provided. New and existing workplaces can be encouraged to provide showers, changing facilities and lockers to encourage staff to cycle into work.

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

Cycling is key to achieving a mode split and demand must be met, and therefore we support the suggestion of innovative solutions to cycle parking. As part of further capacity testing, Masterplanning and detailed design, consideration will be given to innovative storage solutions (using domestic and international examples) that enables cycle parking to be integrated appropriately into the public realm. The concept of micromobility should also be embraced, with provision made for parking dockless bikes to ensure that they are not left in inconsiderate locations such as the footway.

Question 31: What additional factors should we also be considering to encourage cycling use (e.g. requiring new office buildings to include secure cycle parking, shower facilities and lockers)?

New office buildings should include covered, secure cycle storage, showers and lockers. The cycle parking should also be conveniently located at basement/ground floor level or within easy access of lifts capable of transferring bikes between levels. Where possible segregated access for cyclists should be provided to minimise the conflict with pedestrians and vehicles accessing buildings.

Question 32: How do we design and plan for a place that makes the best use of current technologies and is also future proofed to respond to changing technologies over time?

Energy strategies
We will expect development on the Site to have a very low 'in use' energy demand, through robust design of built fabric and services. This will make it easier to meet more of the scheme's energy demand from renewable and low carbon energy sources - and in some case may allow a 'net positive' energy balance to be achieved. Implications for wider energy networks should also be considered, with consideration of energy storage and demand control options at building and community level.

Form and fabric

Development within the Site will be designed, at both masterplan and building scale, to result in minimal energy use through sensitive consideration of site conditions and a robust approach to fabric performance, using passive design strategies to achieve good comfort, day-lighting and air-quality.

Building services

Developments should ensure they build on high quality design of form and fabric by specifying robust and efficient building services. If care has been taken in the design of the built fabric, it should be simpler for efficient building services to meet the needs of those who live and work in a building.

Energy generation and supply

Once the gross energy demand for the proposed development has been reduced through efficient built form and services, it will become possible to evaluate how a greater proportion of its needs can be met through renewable and low carbon energy sources.

Provision for electric charging points for vehicles should be implemented to ensure that both residents and workers have access to electric car charging points. Way-finding points and real time journey time information should be implemented across the Site to ensure people have accurate up to date travel information.

Delivery hubs should be provided on the periphery of the site to intercept large delivery vehicles from accessing the site. This will also help to consolidate deliveries and reduce the need for large vehicles to enter the Site, with smaller electric vehicles providing the final leg of the journey to the front door of the residence or workplace.

Subterranean bins should be provided on the Site to minimise space requirements for waste storage and provide a secure location for the bins.

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

It is considered unlikely that an at grade crossing can be located to link the Science Park with the station due to capacity constraints on Milton Road. A well-designed overpass for pedestrians and cyclists may provide the best option to effectively reduce severance caused by Milton Road and link the station with the Science Park. The journey from the station to the Science Park, will be the last / first mile of commuter journey and micromobility solutions such as dockless e-bikes should be provided to support the movement on this link.

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

The knowledge-based cluster around Cambridge Science Park, St John's Innovation Park, and Cambridge Business Park is internationally recognised, and the significant economic role that it offers to NEC must be fully harnessed to encourage complementary industries (Artificial Intelligence, R+D and laboratories for smaller emerging businesses that need the cluster benefits, maker-space etc) and optimise further employment opportunities. We would therefore expect a range (in terms of use and size) of employment spaces across NEC, including Science, Research & Development and Technology-related employment. However, in advocating innovation throughout NEC, policy limitations should not be imposed that unduly restrict any particular use at this stage.

Question 35: In particular, should the plan require delivery of:
A - a flexible range of unit types and sizes, including for start-ups and Small and Medium Sized Enterprises (SMEs);
B - Specialist uses like commercial laboratory space;
C - hybrid buildings capable of a mix of uses, incorporating offices and manufacturing uses.
D - shared social spaces, for example central hubs, cafes.
E - Others (please specify).

We generally support all of the suggested options at this stage, and would seek inclusion of corporate headquarters within category A. These options should equally be applied to proposals for meanwhile/worthwhile uses, in order to optimise economic development benefits and promote innovation at the earlier stages of the development process for NEC.

Question 36: Which of the following approaches should the AAP take to existing industrial uses in the North East Cambridge area?
A - seek to relocate industrial uses away from the North East Cambridge area?
NEC represents a significant and unique opportunity to create a new and innovative high-density, high quality, mixed use Quarter for Cambridge and its surrounding area. The opportunity is dependent on Housing Infrastructure Funding that will facilitate the relocation of the Water Treatment Works, and optimise the quantum of new housing across the Site. Whilst it is recognised that other, non-residential uses, will also be needed in NEC in order to promote multi-functioning mixed communities and internalised trips, capacity testing and Masterplanning will need to carefully identify what uses (and how much) will be appropriate. Whilst the prospect of utilising some of the Site for industrial use has not, at this stage, been discounted, justification for the need and location of such a use will need to be very carefully considered. A greater understanding of industrial need is therefore required, and in particular how essential it is for certain businesses to be in Cambridge. Consideration should also be given to whether existing businesses are compatible with residential neighbourhoods, as if so, there may be scope to incorporate industrial (i.e. b1c) accommodation within a mixed use development. This might, for instance, include ground floor workshops/maker spaces where noise, odour, other forms of pollution, and type of deliveries will not give rise to unacceptable living conditions for neighbouring properties. For existing businesses where there is not a demonstrable need to be in Cambridge, relocation options outside the NEC should be considered.

B - seek innovative approaches to supporting uses on site as part of a mixed use City District?
See response to A, above.

Question 37: Are there particular uses that should be retained in the area or moved elsewhere?

See response to A, above. The AAP should set out the strategy for determining the needs of individual businesses (and whether there is an operational imperative to be closely related to Cambridge, and how the relocation of existing industrial uses can be appropriately implemented..

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

The residential ambitions and opportunities in NEC (and particularly the Site) will need to be fully understood and embraced in order for the Vision and Objectives of the AAP to be realised. For the high density levels of new housing envisaged, innovation will be essential at all stages and in all forms. Traditional approaches to housing in Cambridge are unlikely to be appropriate. Housing will be made available for a much wider market than might otherwise be expected for a new settlement/strategic urban extension elsewhere in the county (e.g. Northstowe, Waterbeach, Cambourne), including that which is more aligned to smaller household sizes e.g. students, post-graduates, young professionals, and older persons looking to downsize. Where family housing is to be provided, it will require 'smarter-space' solutions to reflect the Site-wide high density approach.
A greater understanding of need and demand, market trends and viability will be needed to define housing requirements for NEC in later stages of the AAP process.

Question 39: Should the AAP seek provision for housing for essential local workers and/or specific housing provided by employers (i.e. tethered accommodation outside of any affordable housing contribution)?

Yes, see response to Question 38.

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

We generally support the suggestion of having a challenging target for the provision of affordable housing. There is a chronic shortfall of affordable housing in South Cambridgeshire and Cambridge City, and the residential growth aspirations of NEC could make a significant contribution in reducing housing shortfall. It is also important to ensure that there are a range of homes of different sizes and tenures to achieve mixed and balanced communities. However, it is also important to ensure that the policy is sufficiently flexible to address viability challenges, and takes a pragmatic approach when recognising how different types of housing are provided and thereafter managed and maintained e.g. less reliance on traditional approaches of 'pepper-potting' etc. There is a significant cost in delivering the level and type of development envisaged and it will be essential to ensure that delivery of the development can be secured on a viable basis. Consideration must also be given to exploring other means of making housing more widely accessible, such as through PRS for instance.

Question 41: Should an element of the affordable housing provision be targeted at essential local workers?

We generally support this suggestion, but a more detailed understanding of housing need and demand in the area, and indeed an understanding of what key employers in the area require, should be undertaking before developing an AAP-specific affordable housing policy.

Question 42: Should the AAP require a proportion of development to provide custom build opportunities?

We generally support this suggestion, but again a greater understanding of demand, need and viability is required. Consideration should be given to examples where successful custom-build housing has been delivered, such as Marmalade Lane, Cambridge's first co-housing community made up of 42 custom build homes.

Question 43: Should the AAP allow a proportion of purpose built HMOs and include policy controls on the clustering of HMOs?

We support the suggestion of creating more shared living and co-living housing opportunities, as these can help improve variety and access to more affordable, good quality accommodation. This type of housing typically incorporates shared services and facilities and can benefit both younger and older aged groups. However, again a greater understanding of demand, need and viability is required.

Question 44: Should the AAP include Private Rented Sector (PRS) as a potential housing option as part of a wider housing mix across the North East Cambridge area?

We generally support this suggestion, as it typically lends itself to earlier delivery, it can be part of an affordable housing mix, and may suit the needs of the adjoining employment base. Similar to HMO's, PRS development needs to be well-managed to integrate successfully. Again a greater understanding of demand, need and viability is required.

Question 45: if PRS is to be supported, what specific policy requirements should we consider putting in place to manage its provision and to ensure it contributes towards creating a mixed and sustainable community?

We would suggest that this needs to be considered in greater detail, including need and demand, management of facilities, services, and amenities should be well defined and required.

Question 46: Should PRS provide an affordable housing contribution?

Subject to viability, policy requirements will need to reflect the distinct economics of this tenure. In most cases (as in London) this is acknowledging that a form of Discounted Market Rent (capped at 80% of Open Market Rents) is most applicable, as this can be managed by a non-Registered Provider and therefore enables tenure blind blocks to be delivered by PRS operators.

Question 47: What 'clawback' mechanisms should be included to secure the value of the affordable housing to meet local needs if the homes are converted to another tenure?

Typically a profit sharing mechanism up to an agreed cap (cap to be reflective of the affordable housing contribution possible for open market sale units - i.e. the value difference between a private for sale scheme at 40% and a PRS scheme at 30%)

Question 48: What would be a suitable period to require the retention of private rented homes in that tenure and what compensation mechanisms are needed if such homes are sold into a different tenure before the end of the period?

We would suggest a period of 15 years with clawback as outlined in Questions 46 and 47. This period is proposed in the London Plan and is generally accepted by institutional investors

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

We consider that this should be agreed with each operator, and should be brief and relevant to planning matters. This could ensure all prospective tenants are offered the option of a three year tenancy.

Question 50: Should the area provide for other forms of specialist housing (including older people, students & travellers), either onsite or through seeking contributions for off-site provision?

We generally support this suggestion, but again a greater understanding of demand, need and viability is required. A comprehensive analysis of the demographic portrait of Cambridge and its surrounding environs over the next 25 years should be undertaken to assess how new policy interventions - such as NEC (intensified housing and employment uses; new housing 'products' to promote affordability and variety), new transport initiatives to improve access to employment, shopping, leisure and recreation etc, may affect demand and supply of different forms of housing for the local population catchment. In terms of 'housing mix', this might then manifest into redefining 'mainstream' housing, to expand into other groups such as students/graduates, first-time buyers, those requiring good quality rental properties, downsizers, elderly care.

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

We generally support this suggestion. This is a standard that ensures appropriate homes are delivered that meet the needs of the occupants. However, there may be some formats where exceptions may be appropriate - for example co-living formats including student and young professional accommodation, housing for 'downsizers' etc. These groups may prefer smaller homes with greater shared space and it may be appropriate to provide for this need in the context of a balanced housing offer. However, in these cases we would expect there to be clear requirements around the nature and quality of shared space. We would also encourage pilot testing (on a smaller scale) of more innovative solutions to housing, which might include other micro-living models that have not yet been used in Cambridge but have proved successful in other UK/international cities.

Question 52: Should the AAP develop space standards for new purpose built HMOs?

All new housing should meet the Technical Housing Standards and offer adequate shared spaces to not only provide adequate space in a HMOs scenario but above all provide homes that are future proofed as people's lifestyle changes and needs such as working from home also emerge. Future-proofed housing is to offer adequate space for a wide range of scenarios, not only HMOs. A specifically-developed space standards for new purpose built HMOs may prove unnecessary or irrelevant if HMOs within the AAP is then not delivered through a purpose-built type. Please see our response to Question 51.

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

We support the principle of ensuring that all homes have adequate and appropriate access to outdoor space and support the aspiration for most homes to have some private outdoor space. We would, at this stage, question whether it is realistic to expect that 100% of dwellings will have direct access to an area of private amenity space, given the quantum of development envisaged and the range of different housing typologies that will be necessary to deliver this quantum. In situations where it isn't appropriate to deliver private outdoor space, convenient access to high quality communal and public spaces would be provided. Ultimately, a flexible approach to residential amenity space must be taken, incorporating elements such as roof gardens and balconies as well as elements such as private gardens.

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

We generally support this suggestion in principle. This standard is meeting Part M of the Building Regulations, however due to the requirements of meeting a higher than normal housing number target on the Site, we require flexibility on how the standard is applied. It is important that the Cambridge Local Plan accessibility standards offers flexibility on how the standards are achieved across the many elements of the new masterplanned scheme. While designing for and incorporating accessibility standards is also accepted as a progressive way to future-proof new housing, it is important the standards do not affect the ability of the scheme to meet the density and the target housing required. Currently the Cambridge Local Plan has adopted the optional standard Part M4(2) and has also adopted M4(3) based on a percentage, which is still higher than the national standards, this may have an adverse impact on our scheme.

Question 55: Do you agree with the range of considerations that the AAP will need to have regard to in planning for new retail and town centre provision in the North East Cambridge area? Are there other important factors we should be considering?

The ambitious intentions for NEC are likely to see the creation of thousands of new homes and intensified employment opportunities forming part of new mixed, balanced and prosperous new communities. This new 'Quarter' will therefore require district and local centres to help support and sustain it. Non-residential uses will help create vitality and vibrancy to NEC.

Question 56: Should the Councils be proposing a more multi-dimensional interpretation of the role of a town centre or high street for the North East Cambridge area, where retail is a key but not solely dominant element?

We generally support this suggestion. We would highlight the importance of seeking innovative, creative and flexible solutions across the Site and this will be applied when considering how a District or Local Centre is planned and delivered. Longer term trends (national, regional and local) relating to retail and leisure uses will need to be carefully considered in arriving at a strategy that will support the long term vitality and vibrancy of NEC.

Question 57: What community facilities are particularly needed in the North East Cambridge area?

Opportunities will exist to provide access to new services and facilities for residents of NEC and existing surrounding local communities. In terms of the latter, where there are higher levels of deprivation, the cost of using new facilities will need to take account of affordability issues to ensure the cost of use is not prohibitive to those on no/low incomes.
Provision will need to be informed by the NEC Community Facilities Audit, whilst also taking account of the growth assumptions of NEC (including sizes and tenures of housing, as this will have potentially very different outcomes on need). Provision of facilities should offer flexibility and multi-functional spaces.

Question 58: It is recognised that maximising the development potential of the North East Cambridge area may require a different approach to meeting the sport and open space needs of the new community. How might this be achieved?

See our response to Question 24. Owing to the ambitious development aspirations of the Site (and NEC) it will be necessary to consider a comprehensive package of solutions (on and off-site) for open space and recreational strategy. This strategy will be complemented by the various improvements to green infrastructure provision in and beyond the AAP boundary, facilitating greater access opportunities by walking and cycling.

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

See our response to Question 24.

Question 60: Should open space provision within the North East Cambridge area seek to provide for the widest variety of everyday structured and unstructured recreational opportunities, including walking, jogging, picnics, formal and informal play, casual sports, games, dog walking and youth recreation?

We generally support this suggestion. It will be important to ensure that all spaces within the Site are fully optimised, and creative/innovative solutions should be considered to allow for flexible/multi-functional uses.

Question 61: Where specific uses are required to provide of open space as part of the development, should the AAP allow for these to be met through multiple shared use (for example school playing fields & playing pitches for the general public)?

See our response to Question 24.

Question 62: Within this overall approach, in particular, which option do you prefer in relation to carbon reduction standards for residential development?
A - a 19% improvement on 2013 Building Regulations (the current Cambridge Local Plan standard); or
B - a requirement for carbon emissions to be reduced by a further 10% through the use of on-site renewable energy (the current South Cambridgeshire Local Plan standard); or
C - a 19% improvement on 2013 Building Regulations plus an additional 10% reduction through the use of on-site renewable energy (combining the current standards in the Local Plans); or
D - consider a higher standard and develop further evidence alongside the new joint Local Plan.

At this stage we support Option D. This is a complex area of policy setting due to the current grid decarbonisation and emerging guidance from different bodies such as the UKGBC task force, and the GLA London Plan. The context of the electricity grid decarbonisation should be considered to ensure that any targets set do not create perverse outcomes in the future over the timescales of the development and should consider the appropriateness of energy efficiency targets as well as carbon targets.

The AAP should aim to be exemplar while also drawing on the most up to date emerging evidence.

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

Yes, we generally support the AAP sustainable design and construction approaches set out. However with regard to water recycling we think that while water recycling can be an important part of reducing water consumption if used inappropriately can be unsustainable. Therefore we would expect a rounded view to be taken as to when it is most appropriate to apply the highest levels of water recycling (as required by the maximum BREEAM credits for water efficiency), including an understanding of maintenance and carbon efficiency.
Question 64: Do you support the proposal for the AAP to be clear that review mechanisms should be built into any planning permissions in order to reflect changes in policy regarding sustainable design and construction standards in local and national policy? What other mechanisms could be used?

Yes we think it is important to recognise that not all future scenarios are foreseeable and that in order to avoid perverse outcomes in future it may be necessary to reappraise the policy requirements so that the most up to date and relevant standards are applied where necessary, reasonable and practicable.

It may also be advisable to follow guidance from notable charities and NGOs (e.g. UKGBC)

Question 65: Do you support the plan requiring delivery of site wide approaches to issues such as energy and water, as well as the use of BREEAM Communities International Technical Standard at the masterplanning stage?

Subject to further Masterplanning, technical assessment and feasibility testing, we generally support the approach to site wide water proposed and support the approach to innovate energy infrastructure such as smart energy grids. We support the view that infrastructure necessary for decentralised energy should be explored early on in consultation with relevant parties and that consideration should be given to a range of technologies and approaches to ensure the approach with the lowest carbon overall can be identified and supported.

We fully support the principles in BREEAM Communities and believe that while certification often brings a certainty of outcomes it does not always. The effective outcomes of applying BREEAM communities at this stage should be subject to further consideration.

Question 66: Are there additional issues we should consider in developing the approach to deliver an exemplar development?

Consideration should be given to the embodied impacts of buildings and infrastructure installed as well as opportunities to support the circular economy. Consideration should also be given to embracing and supporting innovative smart-tech and infra-tech initiatives where feasible and viable to do so.

Question 67: What approach should the AAP take to ensure delivery of a net gain in biodiversity?

In terms of the Site, owing to the on-going uses of land e.g. Water Recycling Centre, driving range, former Park and Ride site, it is considered likely that it will have limited biodiversity value. It will be necessary, at the relevant stage in the process, to carry out site specific investigations on the potential suitability of habitat for protected species, and to consider mitigation where appropriate. If the assumption is correct, it seems reasonable to believe that the Site can deliver net gains in biodiversity. Notwithstanding this, sites within NEC may be asked to consider biodiversity collectively, to show how habitat mosaics and corridors can be delivered on a more strategic basis. In this event, the AAP will need to provide greater clarity on what process is likely to be followed, and how this will be applied to individual development schemes.

Consideration will also need to be given to increasing the amount of tree canopy cover in NEC.

Consideration should be given to where biodiversity enhancements opportunities exist in nearby areas as well so that the best opportunities for linkages beyond the site boundary are identified as well as ensuring the best opportunities locally can be realised if necessary to meet the net gain requirements.

Question 68: Should the AAP require developments in the area to integrate SMART technologies from the outset?

We generally support the suggestion that NEC should seek to integrate SMART technologies from the outset. As we have previously noted, we will seek to encourage innovative, creative and adaptable solutions throughout all elements of development on the Site. It will be important to consider preparation of a digital strategy for NEC, to seek optimum speeds for broadband/fibre, opportunities to integrate SMART technology in homes, businesses and other development around NEC.

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

We support innovation throughout all elements of development on the Site (and indeed NEC). Rather than committing to any specific type of solution at this stage, it will be necessary to understand whether innovative systems used on other sites, such as North West Cambridge, can be applied on the Site.

Question 70: Do you agree that the AAP should prioritise land that can feasibly be developed early? Are there any risks associated with this proposed approach?

The obvious challenge with sites seeking early release/delivery is how they demonstrate that development will not prejudice the wider delivery aspirations of NEC. Where landowners/developers can explain how development can be carried out in a coordinated/comprehensive manner, it seems reasonable to expect that early delivery can be achieved. A coordinated/comprehensive approach must fully ensure that all development complies with s106 tariff/highways trips budgets, in an equitable manner.

As discussed later in Questions 79 and 80, we would encourage a positive policy approach be taken in supporting temporary/meanwhile uses in order to activate the Site in its earlier development phases, and to optimise economic and social benefits in the local area.

Question 71: Should the AAP include a relocation strategy in preference to leaving this to the market to resolve?

The representations of landowners and occupiers will inform the approach. It is considered that the AAP will need to identify and define a strategy for key sites/uses to be relocated, but maintain flexibility for others. Notwithstanding this the NEC has significant potential to deliver economic, social and environmental benefits, and whilst there are a relatively small number of landowners, the strategic opportunities must not be compromised by one or more parties that are unwilling to support the delivery of the NEC. Accordingly, the Councils cannot discount the possibility of using their CPO powers if required.

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

An infrastructure delivery plan should be prepared for the North East Cambridge Area to identify the infrastructure required and the costs associated with those projects, in order to inform discussions on planning obligations. It would be reasonable to expect all development within the area to contribute towards the required infrastructure, where it benefits the AAP area as a whole rather than individual sites/landownerships

Question 73: What approach do you consider the most appropriate basis on which to apportion the cost of the infrastructure requirements arising from different land uses to ensure an equitable outcome?

We consider that this should form part of a specific study that includes, inter alia, the following considerations:
*Identify the infrastructure required across the AAP area that is necessary to delivering the comprehensive vision. This might include key routes, connections, bridges / underpasses, transport, education, energy/utilities, social etc.
*Identify where these are most appropriately located to meet the AAP vision.
*Establish a cost base for these, including appropriate cost of land recognising that in some cases it would be otherwise used for residential or other development
*Establish an appropriate equalisation formula across the AAP, levied on all new development. This could be one or a combination of a tariff per m2, per net acre etc and may be varied by use class.
*Set this out in a policy / legal framework with an appropriate indexing mechanism

Question 74: How should the AAP take into account potential changes over time, both positive and negative, that might affect development viability?

We consider that this should form part of a specific study that includes, inter alia, the following considerations
*ensuring that development continues steadily over potentially a number of economic cycles - this possibility should be acknowledged and planned for at the outset
*Any viability test whereby s106 or AH requirements would be reduced would need to be carefully calibrated to ensure that infrastructure is protected.
*A review mechanism within the S106 Agreement would allow viability to be reassessed if circumstances change.

Question 75: Do you agree with the proposal to require land assembly where it can be demonstrated that this is necessary for delivering the agreed masterplan for the North East Cambridge area and/or the proper planning of development?

Yes. This does not directly affect U+I. Land assembly will help to ensure the delivery of comprehensive redevelopment of NEC.

Question 76: Should the AAP state that the Councils will consider use of their Compulsory Purchase powers? If so, should the AAP also set out the circumstances under which this would appropriate?

The NEC has significant potential to deliver economic, social and environmental benefits, and whilst there are a relatively small number of landowners, the strategic opportunities must not be compromised by one or more parties that are unwilling to support the delivery of the NEC. It therefore seems appropriate for the AAP to specify how the Councils will use their CPO powers if required, and the circumstances for doing so. This will need to include the viability and timescales of pursuing a CPO process.

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

Yes. There are a range of stakeholders and landowners involved in the development at the North East Cambridge area, and the successful delivery of NEC will require a coordinated approach. This will need to consider a range of issues including connectivity, infrastructure locations, parking/trip budget, smart-city coordination, delivery programmes, design principles, energy/utilities and waste etc.

Question 78: Do you agree with the Councils' proposed approach to dealing with planning applications made ahead of the AAP reaching a more formal stage of preparation?

Yes. It is agreed that a coordinated approach is required and decisions on applications should be made against the AAP with appropriate, equitable contributions made.

Question 79: What types of 'meanwhile uses' should the AAP support for the North East Cambridge area?

We would suggest a range of 'meanwhile uses' could be appropriate for NEC, and would not expect policy to impose any particular restriction on types of use. The emphasis should be on promoting innovation and creativity, with meanwhile uses serving to provide early foundations for the new Quarter that will emerge and subsequently replace the meanwhile uses in the coming years. Meanwhile uses could therefore provide start-up/incubator accommodation for emerging/expanding sectors, pop-up/small-scale A class uses, community space to begin community cohesion with surrounding neighbourhoods etc. A positive policy approach to obligations and planning requirements will be needed to encourage temporary/meanwhile activation, helping to avoid onerous situations that might otherwise render creative initiatives unviable.

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

It seems unnecessary to impose a limitation on the scale of a proposed 'meanwhile use', as the purpose of a meanwhile use is, fundamentally, to make optimum use of a site that will otherwise be under-utilised for many years. This can have many short-term economic and social benefits. A policy limitation may stifle innovation and creativity. It is considered likely that many of the meanwhile use proposals will require formal planning consent, which will provide the Local Planning Authority with the ability to control and enforce development that is deemed inappropriate.

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

No. A minimum period should be based on the need and timetable for the permanent development. For the most successful meanwhile initiatives a reasonable period of operation is required in order to recoup the initial capital investment.

Question 82: Should the AAP also include a requirement for 'meanwhile uses' to demonstrate how they will add vibrancy and interest and/or deliver on the wider development outcomes and vision for the North East Cambridge area?

No. 'Meanwhile' uses are temporary in nature and an approach that seeks to make efficient use of land, in a compatible manner with surrounding uses, should be encouraged.

Question 83: What negative or positive impacts might the proposed plans have on residents or visitors to Cambridge with low incomes or who have particular characteristics protected under the Equality Act 2010? (The protected characteristics are age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex, and sexual orientation.)

We strongly support the intention of the Vision for NEC and Objective 5, to ensure social and economic inclusion, and as stated in our response to Question 5, would seek the addition of the word 'culturally' within the Vision i.e. 'North East Cambridge - a socially, culturally, and economically inclusive...'

It is recognised that NEC lies within close proximity of two highly deprived wards in Cambridgeshire, and that regeneration on the scale envisaged will create significant socio-economic opportunities for a wider catchment beyond the AAP boundary. Development on the Site, for instance, will create long term employment across a multitude of sectors and skill ranges, improved connectivity around the NEC and access to new services and facilities. We support the intention of the Councils to undertake a Health Needs and Impact Assessment, across an appropriate study area for the NEC, in order to better understand the challenges and issues faced in neighbouring wards, so as to link into opportunities that will arise in NEC.

As stated within our response to Question 5 we generally support the application of local plan accessibility in the NEC. This standard is meeting Part M of the Building Regulations, however due to the requirements of meeting a higher than normal housing number target on the Site, we require flexibility on how the standard is applied. It is important that the Cambridge Local Plan accessibility standards offers flexibility on how the standards are achieved across the many elements of the new masterplanned scheme. While designing for and incorporating accessibility standards is also accepted as a progressive way to future-proof new housing, it is important the standards do not affect the ability of the scheme to meet the density and the target housing required. Currently the Cambridge Local Plan has adopted the optional standard Part M4(2) and has also adopted M4(3) based on a percentage, which is still higher than the national standards, this may have an adverse impact on our scheme.

Question 84: Do you have any other comments about the North East Cambridge area and/or AAP? Are there other issues and alternatives that the councils should consider? If you wish to make suggestions, please provide your comments.

We would encourage a specific section on education and health provision within the NEC, noting the likelihood that if on-site provision is required, it may require different formats/approaches on how such provision is made i.e. traditional forms of provision in Cambridgeshire are unlikely to be suitable in a high density urban regeneration scheme of this nature.

If off-site provision is considered to be more appropriate, comment should be given on how and where need is expected to be accommodated (for instance it may be more appropriate to extend existing or proposed schools in Cambridge, to create additional Forms of Entry, rather than have a lower number of Forms of Entry on-site that falls below the recommended minimum sizes).

Introduction

Cambridge City Council and South Cambridgeshire District Council is consulting on Issues & Options for the North East Cambridge AAP. The consultation deadline is 25th March 2019. The draft response on behalf of U+I Group PLC ('U+I') is set out below. U+I have been selected by the landowners Anglian Water and Cambridge City Council as Master Developer for land outlined in red in the accompanying Site Plan ('the Site'). It is noted that Cambridge City Council also own other land beyond the Site, which may be the subject of other representations.

The representations contained herein relate primarily to the development intentions for the Site, but also in the context of the wider AAP area (as sites within the AAP boundary are largely intrinsically linked).

Representations

Question 1: Do you agree with changing the name of the plan to the 'North East Cambridge Area Action Plan'?

It is recognised that there is a need for a collective reference for the AAP area. This will provide consistency and clearer definition as the process evolves. Whilst it is inevitable that sub-areas of the AAP will emerge with different branding names and strategies, this will have more relevance to the individual sub-area concerned, in creating identity when publicising forthcoming planning applications through to marketing/sales disposals.

Question 2: Is the proposed boundary the most appropriate one for the AAP?

Generally, we support the proposed boundary for the AAP area. We would, however, make two observations/comments.

Firstly, it seems logical to include the site of Cambridge Regional College ('CRC') within the boundary. It is noted that in paragraph 3.5 comment is made that it is not expected to undergo major change in the way other sites across NEC are. However, CRC considers itself to be 'one of the best Further Education Colleges in the country for 16-18 year old level 3 achievement and a leading apprenticeship provider, with thousands of full time students and apprentices currently in training'. The significant range of vocational courses it offers could be positively utilised to support the long-term construction process around NEC (e.g. architectural technology, mechanical engineering, electrical, carpentry, bricklaying courses and apprenticeships), and then the on-going operational phases of the different sub-areas of NEC (e.g. from courses relating to biological science for industry, laboratory technicians and computing technologies, to business and catering and hospitality). It therefore has the potential to play an important learning and development role in the future NEC area. The built form of the current campus appears to be relatively low density, with large areas of used for surface level car parking. Buildings are predominantly 2-3 storeys in height. With the transformation of NEC, recognising the different approaches to internalised trips/reduced car parking, and taller buildings, it would seem likely that the estate management of CRC might change in the future, and if so, it should be included in the AAP.

Secondly, we would comment that, owing to the nature of NEC, development is likely to be high density, optimising the use of all land to work efficiently and effectively. The strategy for on-site Public Open Space is likely to focus on qualitative provision, than quantitative, with a stronger emphasis on formal recreational and leisure space than informal open space. Access to the latter however, is likely to be facilitated through new and improved connections to the east (potentially including land to the east of the railway line north of Cambridge North Train Station, to the river) and north (potentially including land to the north of the A14, such as Land to the south of Cambridge Road, and land including/extending Milton Country Park) of NEC. We would therefore simply pose the question about whether there is a need to include within the AAP boundary additional land that could provide informal open space, biodiversity and drainage functions, which might otherwise not be achievable within the single control of the NEC boundary. It is considered that land to the north and east of the current AAP boundary would primarily be used to facilitate access to green infrastructure for NEC.

Question 3: In this chapter have we correctly identified the physical characteristics of the North East Cambridge area and its surroundings?

Generally, yes. However, we consider it might be beneficial to include more information about the composition of site areas. For instance, on the employment parks, providing details about site area, total floorspace of buildings on the park (including extant planning consents) and the range of authorised planning uses e.g. % B1a uses, %B1b uses, estimated no. of employees, audit of authorised car parking spaces, audit of public open space (estimated total hectares). This would help to inform a baseline of land use within NEC, and then contribute in developing future strategy e.g. highway trip budget, employment strategy, connectivity and green infrastructure etc.
We would also note that it would be beneficial to have mapping information available relating to the environmental constraints identified e.g. noise, air quality, odour, important habitats.
Finally, it would be beneficial to show the broader extents of key infrastructure for NEC, including the full Chisholm Trail link (connecting NEC to Cambridge City, and the south of Cambridge (Addenbrookes), committed routes for other new cycle, pedestrian and public transport in and around the City, and the proposed Greenways link to Waterbeach).

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

In general, yes. However, we note that there is no reference to Archaeology and Heritage, and would suggest that comment is given about this, even if it is considered that NEC has limited archaeological significance. In terms of heritage, whilst we believe that there are no listed buildings, conservation areas, or other notable heritage constraints within NEC, the intention for taller buildings in NEC will need to be more widely considered in respect of longer-distant views and townscape issues (historic core of Cambridge). Taller buildings may also have potential implications for Air Safeguarding Zones (consultation required with Marshall Airport and the Ministry of Defence on structures over 15m in height), and the Mullard Radio Astronomy Observatory (consultation with the University of Cambridge). We acknowledge that the issue of building heights and taller buildings is likely to be assessed as part of the on-going Landscape Character and Visual Impact Assessment that is being undertaken by Cambridge City Council (it is understood that a 'Stage 1' exercise has already been commissioned), and that the findings are then likely to inform future stages of this AAP process.

We would also suggest consideration be given to the inclusion of Green Belt boundaries around NEC. This will help provide clarity to interested parties that all land envisaged for development and associated physical infrastructure will be accommodated on non-Green Belt land. It will also help to provide reassurance that the development aspirations for NEC will not automatically lead to further development beyond the identified boundaries, unless it is deemed to be 'appropriate development' (i.e. not 'inappropriate' as defined in the National Planning Policy Framework'), or that exceptional circumstances are demonstrated in future Local Plans, or a Very Special Circumstances argument is made to support development via a planning application process. In all cases, strict mechanisms for controlling additional future development beyond NEC will apply.

Reference should also be made to the presence of UKPN's overhead power cables (132KV) that span across the AAP boundary. In terms of ensuring optimum reuse of the Site (and indeed other sites, including Cambridge Science Park), we would support a policy seeking their diversion underground.

Question 5: Do you agree with the proposed Vision for the future of the North East Cambridge area? If not, what might you change?

Yes, we support the proposed Vision for NEC. The addition of the word 'culturally' might benefit this Vision further (in the context of 'North East Cambridge - a socially, culturally, and economically inclusive....)

Question 6: Do you agree with the overarching Objectives? If not, what might you change?

Generally, we support the overarching Objectives. The addition of the words 'Natural Capital' might benefit Objective 7 further (in the context of '...connecting and improving biodiversity to achieve a Natural Capital net gain....)

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

It is noted that the Concept Plan can only be treated as indicative at this stage in the AAP process, until the outcomes of the various Supporting Studies are known (notably Landscape Character and Visual Impact Assessment, Development Capacity Study, NEC AAP Transport Assessment, NEC Development Viability Assessment, NEC Infrastructure Delivery Plan), and wider consultation with relevant interested parties (e.g. landowners, developers, local communities, local authority bodies etc) has been carried out.

We support the residential-led mixed use allocation for the Site. We support the aspiration to create high quality pedestrian, cycle and public transport connectivity across the AAP area. We support the indication that a Mixed Use District Centre will be provided on the Site though we would suggest that its optimal location can only be determined after further study and masterplanning work. There may also be a need to include an additional Mixed Use Local Centre in the northern half of the Site (subject to further Masterplanning and an assessment on accessibility). We support the intention to provide and integrate Green Infrastructure throughout the AAP boundary, but what provision is made (and how/where it will be provided) will need to be determined following further studies/assessment and Masterplanning. Further consideration will need to be given to the suggested Industrial Development Sites in the north east corner of the Site, to understand what the rationale is for proposing to relocate existing industrial land at Nuffield Road and Cowley Road, to another part of the AAP site. It is assumed that the suggestion is made on the basis that it will provide noise abatement from the A14 to the new residential elements of the Site. However, we consider that there may be other more preferable solutions for controlling noise and, in Masterplanning terms it is less desirable bringing industrial-related traffic through a predominantly residential site. In the absence of clear justification for seeking relocation of industrial uses, we cannot support the industrial element of the proposal.

We aren't yet persuaded that the proposed location and quantum of industrial use is optimal. In particular we have concerns that this is currently shown at the furthest point from strategic highway connections. We also believe that different models and formats of industrial development should be further explored, specifically whether this should be concentrated in a single location, or whether it might be incorporated within a mixed-use approach throughout the Site.

We do not necessarily agree that the Site represents the best opportunity with the overall AAP area to accommodate a significant concentration of industrial uses in a single location.

We would suggest that the Cambridge Business Park is shaded as an Opportunity for Employment Intensification.

In addition to our response for Question 2, we would suggest that the CRC land we would suggest that this land is included within the AAP boundary, and that a new shading is applied that refers to an Opportunity for Education Intensification.

Question 8: Do you agree that outside of the existing business areas, the eastern part of the North East Cambridge AAP area (i.e. the area east of Milton Road) should provide a higher density mixed use residential led area with intensified employment, relocation of existing industrial uses and other supporting uses?

Generally, we support the initial development intentions for the area east of Milton Road. It is considered that this area could accommodate a high density mixed use residential-led development following the relocation of the existing Cambridge Water Recycling Centre and other industrial uses (subject to viability and finding suitable relocation site(s)) from the Site. A comprehensive, design-led, approach across the AAP will help maximise the redevelopment potential of a significant brownfield site in a highly sustainable location.

Question 9: Should Nuffield Road Industrial Estate be redeveloped for residential mixed use development?

Yes, we agree that consideration should be given to relocating existing industrial uses on the Nuffield Road Industrial Estate, in preference for higher density residential-led mixed use redevelopment. Consideration should be given to the viability of doing so (industrial land values are currently relatively high), and where existing businesses will be relocated. An Industrial Relocation Strategy might be appropriate, in order to understand what factors are important to businesses e.g. last mile strategies and what alternative sites might be available to accommodate relocation requirements. ]

As outlined in Question 7, the suggestion to relocate industrial uses from Nuffield Road Industrial Estate to the north east corner of the Site needs to be explained and justified. At this stage we do not support the suggestion to relocate industrial uses to the north-east corner of the Site.

Question 10: Do you agree that opportunities should be explored to intensify and diversify existing business areas? If so, with what sort of uses?

Yes, we broadly support this suggestion, subject to the establishment of a robust and equitable approach to Highways Trip Budget apportionment and s106 tariff system across the wider AAP area. The Cambridge Science Park was first established on the principle of accommodating 1-2 storey, low density commercial buildings within an attractive strategic landscape/parkland setting. Whilst much of the strategic landscaping remains, latter phases of the Science Park have sought to intensify development density, with taller buildings, lower car parking provision, and limited on-plot landscaping (other than to lessen/soften the impact of new development). This approach has been complemented by the introduction of Cambridge North Station Interchange, which has significantly improved accessibility via non-car modes. The growth aspirations now anticipated for the AAP area signals a radical change in approach to new development. New residential communities will be supported by existing and intensified employment and educational opportunities, potentially providing live and work/learning opportunities within walking/cycling distance of each other. Furthermore, access to inter alia Cambridge North, the Guided Busway, and the Chisholm Trail will support accessibility to existing business areas from a much wider catchment, therefore helping to improve the means of accessing work without the need to do so by car.

Opportunities to provide a greater quantum and diversity of employment should be encouraged. This will consolidate and strengthen the concept of the Cambridge Phenomenon, by creating a greater range and quantum of high quality accommodation for new businesses, in close proximity to a critical mass of similar businesses, thereby helping to support knowledge sharing and collaboration through co-location.

In order to promote diversity of employment types, planning policy consideration might be given to encouraging a certain percentage of 'affordable employment', to support the growth of new start-up businesses that require the same close links with similar businesses but cannot afford (and do not currently need) accommodation that becomes available.

Question 11: Are there any particular land uses that should be accommodated in the North East Cambridge area?

The North East Cambridge area should support any use that demonstrably contributes to the Vision and Objectives of the AAP area.
The AAP provides a significant opportunity to create thousands of new homes in a highly sustainable location. The growth of housing in this area will be supported by the economic benefits derived from the long-established science, innovation and business parks (many of which will be intensified), that have collectively grown from the success of clustering knowledge-based industries in close proximity of one another. The housing element of the Site will improve supply and affordability of high quality new homes to the many thousands of employees on these parks, helping to reduce the number of car movements on Milton Road. New homes and jobs on the scale envisage will need to be served by a number of social, retail, community, health, education, leisure and recreation facilities,

Question 12: What uses or activities should be included within the North East Cambridge AAP area which will create a district of culture, creativity and interest that will help create a successful community where people will choose to live and work and play?

It is considered that the inclusion of schools, community facilities, retail and leisure uses, open space, and transport services, in conjunction with walking and cycling connections to neighbouring areas will provide the attributes of a successful community.

The NEC AAP must recognise the wider role it plays in creating opportunities for surrounding communities, of which two neighbouring wards - East Chesterton and Kings Hedges - currently suffer from high levels of deprivation (included in the top three of most deprived wards in Cambridgeshire). The benefits of the AAP area should extend to these areas, to create new employment, education, social, leisure and recreation, health and community opportunities. Where new facilities are introduced to areas experiencing deprivation, a key challenge for optimising use of such facilities is affordability. Free or subsidised charging mechanisms should therefore be considered when providing new facilities for instance e.g. hire of sports pitches, meeting rooms etc.

It should, however, be recognised (and indeed it is in Question 79) that the ambitious development aspirations for the Site and wider AAP area will take a number of years to comprehensively plan and deliver. Certain elements will be possible to deliver early. Notwithstanding this, there is the opportunity to introduce 'meanwhile/worthwhile' uses the area as the transition progresses. Meanwhile/worthwhile uses offer creative and innovative ways of optimising sites on a stop-gap basis, creating a temporary opportunity to capture economic and/or social benefits for the wider area in the period between the closure/or reduction of an existing site operation and the commencement of the intended new development.

Question 13: Should the AAP require developments in the North East Cambridge AAP area to apply Healthy Towns principles?

NEC will provide a considerable opportunity for creating a healthy new community, and supporting neighbouring communities, through access to high quality housing, a design approach founded on sustainable modes of travel (walkable neighbourhoods), and improved employment, shopping, health, education, leisure and recreational opportunities. We also support the intended preparation of the Health Impact and Needs Assessment for NEC, which will take account of the wider deprivation challenges faced in the neighbouring wards of East Chesterton and Kings Hedges.

Question 14: How should the AAP recognise and make best use of the existing and potential new links between the AAP area and the CRC (Cambridge Regional College)?

Please see our response to Question 2.

Question 15: Should clusters of taller buildings around areas of high accessibility including district and local centres and transport stops form part of the design-led approach to this new city district?

We strongly support the principle that the greatest development densities should be located in the areas of greatest accessibility and public amenity. This maximises the potential for sustainable travel patterns and establishes a critical weight of local demand for leisure, cultural and retail uses.

It is important to note that 'high-density' does not automatically mean 'tall' and that compact mid-rise development can often be denser than taller development, particular where the latter is compensated for by a smaller overall development footprint. Compact mid-rise also typically enables a wider range of dwelling types and external amenity space, meeting a wider range housing needs.

We favour a 'transect' based approach to masterplanning which will ensure the density, scale, typology, and uses of development are allocated across the site as a whole and within each neighbourhood in a coordinated way, following the accessibility principle described above and responding to the opportunities and constraints of the Site. This may not mean 'clusters' - it could for example mean that the highest densities are located in 'corridors' along the primary streets, and/or at edges where having denser development acts to shelter lower-scale development from adjacent visual or noise intrusion. The masterplan will be backed up by a design code that will identify/mandate appropriate typologies for achieving the requisite densities in ways that are acceptable in other respects.

In addition to accessibility and other local factors, it is important to note that the extent and location of denser development will be affected by a range of detailed studies and appraisals (including Landscape Character and Visual Impact Assessment), that will recognise - and then balance - the challenges of creating areas of higher density and taller buildings in a highly sustainable location that is, nonetheless, on the edge of Cambridge with areas of open countryside beyond. This may also militate against achieving density through height.

Question 16: Should the AAP include any or a combination of the options below to improve pedestrian and cycling connectivity through the site and to the surrounding area?

A - Create a strong east-west axis to unite Cambridge North Station with Cambridge Science Park across Milton Road. This pedestrian and cycle corridor would be integrated into the wider green infrastructure network to create a pleasant and enjoyable route for people to travel through and around the site. The route could also allow other sustainable forms of transport to connect across Milton Road.

Yes. A strong east-west axis should be included to connect the different parts and proposed uses within NEC, and to encourage movement within the site by sustainable modes of transport.

B - Improve north-south movement between the Cowley Road part of the site and Nuffield Road. Through the redevelopment of the Nuffield Road area of NEC, it will be important that new and existing residents have convenient and safe pedestrian and cycle access to the services and facilities that will be provided as part of the wider North East Cambridge area proposals.

Yes.
C - Upgrade connections to Milton Country Park by both foot and cycle. This would include improving access to the Jane Coston Bridge over the A14, the Waterbeach Greenway project including a new access under the A14 (see Transport Chapter), as well as the existing underpass along the river towpath.

Yes. It is considered that improvements to connections with Milton Country Park and with existing and proposed pedestrian and cycle routes will be important for the success of development within the AAP. It is anticipated that NEC will provide a high density residential development, to take advantage of the close proximity of employment areas and public transport services, but which might limit opportunities for large scale open space/recreation areas. Therefore, it will be important to ensure that any proposal for an underpass will maximise connectivity through the Site, capitalising on permeability and wider Green Infrastructure initiatives (e.g. Waterbeach Greenway, Chisholm Trail, improving the public realm function of the 1st Drain etc).

D - Provide another Cambridge Guided Bus stop to serve a new District Centre located to the east side of Milton Road.

We support the suggestion to improve public transport accessibility around NEC but further work should be undertaken to determine whether an additional 'guided' busway stop is required or whether a 'normal' bus service, which could feasibly use the same buses as those on the Busway, could deliver the same benefits.

E - Increase ease of movement across the sites by opening up opportunities to walk and cycle through areas where this is currently difficult, for example Cambridge Business Park and the Cambridge Science Park improving access to the Kings Hedges and East Chesterton areas as well as the City beyond.

We very much support opportunities to increase the ease and convenience of walking and cycling movements across sites in NEC, as this will strengthen the concept of promoting internalised trips and reduce the reliance on travel by car.

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

It is noted that the River Cam towpath is identified as a route within the Waterbeach Greenway project, and it would be appropriate to take the opportunity to provide a pedestrian and cycling connection from this route into NEC, subject to the availability of funding.

The high density redevelopment of NEC is unlikely to achieve the level of Public Open Space that might otherwise be required under local plan policy. The focus is instead likely to be on securing high quality, flexible-use open space on-site, and improving/providing new connections to informal open space networks to the north and east of the AAP area (including the Waterbeach Greenway). Accordingly, an appropriate means of accessing off-site Green Infrastructure for NEC will be required, and the suggestion of a pedestrian/cycle bridge would facilitate this.

Please see our responses to Questions 2 and 7.

Question 18: Which of the following options would best improve connectivity across Milton Road between Cambridge North Station and Cambridge Science Park?
A - One or more new 'green bridges' for pedestrians and cycles could be provided over Milton Road. The bridges could form part of the proposed green infrastructure strategy for NEC, creating a substantial green/ecological link(s) over the road.
B - Subject to viability and feasibility testing, Milton Road could be 'cut-in' or tunnelled below ground in order to create a pedestrian and cycle friendly environment at street level. This option would allow for significant improvements to the street which would be more pleasurable for people to walk and cycle through.
C - Milton Road could be significantly altered to rebalance the road in a way that reduces the dominance of the road, including rationalising (reducing) the number of junctions between the Guided Busway and the A14 as well as prioritising walking, cycling and public transport users.
D - Connectivity across Milton Road could be improved through other measures. We would welcome any other suggestions that would improve the east-west connectivity through the site.
E - Other ways of improving connections (please specify)

In response to all five options listed above, we generally support the principle for securing high quality east-west connectivity. However, the means of crossing Milton Road will involve a range of complex issues, which cannot be determined at this stage. The crossing solution(s) should not ultimately be compromised by concerns about short-term disruption and inconvenience. The east-west axis will be fundamental in the overall success of NEC, and the justification for internalising trips will be partly made on the basis that pedestrian and cycle connectivity across NEC will be safe and convenient (and therefore likely to be commonly used as a means of travel).

Option A is considered to be the preferred option as it provides the opportunity to create a substantial green link over the road without adversely affect the flow of traffic on Milton Road, which has existing network capacity issues. It will also limit the impact on the operation of the Milton Road during construction when compared with either Option B and C.

Option B would likely result in significant disruption to the road network during construction and would likely require the lowering or redirecting or Statutory Undertakers Utilities. Both Option B and C would result in alterations to the access junctions into the Science Park and the Site, both of which have limited access opportunities for their respective sizes.

Question 19: Should development within the North East Cambridge area be more visible from Milton Road, and provide a high quality frontage to help create a new urban character for this area?

We generally support the suggestion of making new development within NEC more visible from Milton Road and providing a high quality frontage to create a new urban character for the area. Milton Road is currently a highly car dominated environment, with a number of confusing junctions serving Cambridge Science Park and Cowley Road. However, it is noted that Milton Road acts as a key north / southbound route into and out of Cambridge, and the Milton Interchange forms part of the Strategic Road Network and connects Cambridge to the A14 (a major east to west route, which has recently been upgraded to improve capacity). Given the level of traffic using this stretch of the Milton Road to access the Strategic Road Network at this location, the potential to reduce traffic to provide a high quality new urban character for the area may be limited in the short term. Notwithstanding this, where Milton Road runs southwards the nature of the road starts to change and becomes more urban in nature, potentially becoming more conducive to active frontage and activity on the footway.

Question 20: Do you agree with proposals to include low levels of parking as part of creating a sustainable new city district focusing on non-car transport?

Yes, we generally support this principle NEC provides an opportunity to reduce levels of parking, as part of a package of transport measures including new and additional walking and cycling routes, public transport services, and car share schemes. However, we would also suggest that interim car parking strategies might need to be considered, to support 'pioneer' uses/development during transitional phases of NEC i.e. until the full package of transport infrastructure and initiatives can be fully realised. As new infrastructure/initiatives are introduced, interim car parking can be gradually phased out.

Question 21a: In order to minimise the number of private motor vehicles using Milton Road, should Cambridge Science Park as well as other existing employment areas in this area have a reduction in car parking provision from current levels?

We very much support opportunities to reduce the reliance on travel by car in and around NEC, and instead increase the ease and convenience of walking and cycling movements across sites in NEC, as this will strengthen the concept of promoting internalised trips.

Question 21b: Should this be extended to introduce the idea of a reduction with a more equitable distribution of car parking across both parts of the AAP area?

Yes, as part of a package of transport measures to encourage travel by sustainable modes of transport.

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

Yes, subject to further understanding of the requirements of businesses and the needs of residents. The North East Cambridge area could include a number of delivery/collection hubs.

Question 23: Should development within the North East Cambridge area use car barns for the storage of vehicles?

We support the idea of using car barns, as part of a wider package of parking solutions across NEC. Whilst it is recognised that private on-plot parking is unlikely to be widely encouraged, there will inevitably be demand from some residents to have access to the use of a car/secure car parking but this should be priced accordingly to the end user. Car barns provide communal access to parking, and are typically located in less convenient locations in order to discourage frequent use. As an example, if a car was needed to do a weekly shop, the resident would park outside their property to unload their car and then move the car to a car barn. Car barns can also be used by 'car clubs', so that a resident can book a car for a certain period of time but not have the long-term cost and use commitment to owning a private car. The versatility of car barns should also be recognised, as parking can be let on a temporary basis and, as trends change, can be converted into alternative uses to reduce car usage further.

Question 24: Within the North East Cambridge area green space can be provided in a number of forms including the following options. Which of the following would you support?
A - Green space within the site could be predominately provided through the introduction of a large multi-functional district scale green space. Taking inspiration from Parker's Piece in Cambridge, a new large space will provide flexible space that can be used throughout the year for a wide range of sport, recreation and leisure activities and include a sustainable drainage function. The sustainable drainage element would link into a system developed around the existing First Public Drain and the drainage system in the Science Park. The green space could be further supported by a number of smaller neighbourhood block scale open spaces dispersed across the site.
B - Green spaces within the site could be provided through a series of green spaces of a neighbourhood scale that will be distributed across the residential areas. These green spaces will also be connected to the green infrastructure network to further encourage walking and cycling. Again, these spaces will include a sustainable drainage function and link into the existing First Public Drain and the Science Park drainage system.
C - Enhanced connections and corridors within and beyond the site to improve the biodiversity and ecological value as well as capturing the essential Cambridge character of green fingers extending into urban areas. These corridors could also be focussed around the green space network and sustainable drainage and would reflect the NPPF net environmental gain requirement.
D - Green fingers to unite both sides of Milton Road and capitalise on the existing green networks.
E - Consideration of the site edges - enhancement of the existing structural edge landscape and creating new structural landscape at strategic points within and on the edge of NEC. This would also enhance the setting to the City on this important approach into the City.
F - Creation of enhanced pedestrian and cycle connectivity to Milton Country Park and the River Cam corridor.

In response to all six options listed above, we support the principle for securing high quality green infrastructure across NEC. Subject to further capacity testing and Masterplanning, on-site provision might feasibly take the form of a larger green space for the whole NEC and complemented by smaller 'neighbourhood scale' spaces and enhanced connections and corridors to off-site green infrastructure. We aren't persuaded that Parkers Piece is an appropriate comparable for the size and function of this space but do consider that the green space should draw lessons from existing green spaces in Cambridge. However, in supporting the theme of innovation at all stages of the development it will be important to consider smart solutions for the open space strategy, maximising flexibility across all areas of on-site open space. For instance, playing fields associated with on-site school provision should be available to the wider community, at times when it is not required by the school. Management and security issues will need to be carefully considered in this regard. Landscape vegetation should encourage biodiversity, whilst also performing softening/screening functions. Formal playspace should be able to accommodate multi-use activities during the day and evening and throughout the year. Green infrastructure might incorporate elements of food growing e.g. fruit trees, herbs, and vegetables, enabling free access to foods that help promote healthier lifestyles.

In terms of the suggestion of how open space will be provided (and in what format and amount), this cannot be determined at this stage of the process. A series of studies and assessments have been or are being commissioned by Cambridge City Council, which will help inform development principles and Masterplanning. Consultation will also need to be carried out with a number of interested parties, including landowners, developers, local communities and local authority bodies. Therefore, we are neither supporting nor objecting to any of the suggested options at this stage.

Question 25: As set out in this chapter there are a range of public transport, cycling and walking schemes planned which will improve access to the North East Cambridge area. What other measures should be explored to improve access to this area?

We generally support the suggested options for improving public transport, cycling and walking accessibility around NEC. The proposed Waterbeach Greenway should be directed through the Site, to create a coherent route from Waterbeach to the station. This will allow future residents of the Site to cycle to the station helping to providing a means of travel for the 'first mile / last mile' of the journey to / from the station.

A new route for a busway from the proposed Waterbeach development should be routed through the Site down to Cambridge North Station. Stops on the route could form transport interchanges linking to other bus routes and cycle routes. High quality cycle links should be implemented to connect into existing infrastructure such as the Chisholm Trail.

The route of these two transport spines through the Site will help develop a single coherent sustainable transport corridor down to the station allowing seamless interchanges between transport modes where the routes intersect with one another. The interchanges will be located within a high-quality urban environment close to high density district centres and attractive locations encouraging linked trips and improving access to the district centres by public transport.
It will important to ensure that consideration is always given to promoting access beyond the AAP boundary (as currently shown), such as recognising the education/social role that CRC plays in the west, the retail and leisure/recreational/biodiversity roles of Tesco and Milton Country Park in the north, the leisure/recreational/biodiversity role of the river and green corridors in the east, and the existing Cambridge communities in the south.

Question 26: Do you agree that the AAP should be seeking a very low share of journeys to be made by car compared to other more sustainable means like walking, cycling and public transport to and from, and within the area?

We support the concept of encouraging a greater share of non-car modes of travel for NEC, but note that it is a concept that will need to be accepted by all landowners/occupiers in the AAP boundary in order for it to be successfully implemented. This is broadly in accordance with the advice from the Ely to Cambridge Transport Study, and will be further tested in the NEC AAP Transport Assessment work (due to be commissioned).

Question 27: Do you have any comments on the highway 'trip budget' approach, and how we can reduce the need for people to travel to and within the area by car?

We support the principle of a 'trip budget' as there is limited scope for large scale engineering interventions to create more capacity on the road network. However, the trip budget must be carefully considered and tested to ensure that it is both suitable and realistic. Appropriate measures will need to be employed if the trip budget is exceeded. The monitoring process will need to be carefully considered, as various land uses across the AAP site will be allocated a share of the trip budget.

Question 28: Do you agree that car parking associated with new developments should be low, and we should take the opportunity to reduce car parking in existing developments (alongside the other measures to improve access by means other than the car)?

We generally support the concept of encouraging a greater share of non-car modes of travel for NEC. This is broadly in accordance with the advice from the Ely to Cambridge Transport Study, and will be further tested in the NEC AAP Transport Assessment work (due to be commissioned). It is recognised that many existing employment uses, such as those in Cambridge Science Park, St John's Innovation Park and Cambridge Business Park, will have authorised car parking at significantly higher levels than what is now intended for NEC. We would support the Councils working with various landowners in exploring innovative/incentivised ways of reducing car usage from those sites.

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

We support the suggestion of requiring high levels of cycle parking from new developments. This approach will be supported by the new cycling infrastructure that is planned for Cambridge, including the Chisholm Trail and Waterbeach Greenways. Cycling helps support healthy lifestyles, and is a viable means of travelling around a compact city, assuming that safe and convenient routes and secure/covered parking can be provided. New and existing workplaces can be encouraged to provide showers, changing facilities and lockers to encourage staff to cycle into work.

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

Cycling is key to achieving a mode split and demand must be met, and therefore we support the suggestion of innovative solutions to cycle parking. As part of further capacity testing, Masterplanning and detailed design, consideration will be given to innovative storage solutions (using domestic and international examples) that enables cycle parking to be integrated appropriately into the public realm. The concept of micromobility should also be embraced, with provision made for parking dockless bikes to ensure that they are not left in inconsiderate locations such as the footway.

Question 31: What additional factors should we also be considering to encourage cycling use (e.g. requiring new office buildings to include secure cycle parking, shower facilities and lockers)?

New office buildings should include covered, secure cycle storage, showers and lockers. The cycle parking should also be conveniently located at basement/ground floor level or within easy access of lifts capable of transferring bikes between levels. Where possible segregated access for cyclists should be provided to minimise the conflict with pedestrians and vehicles accessing buildings.

Question 32: How do we design and plan for a place that makes the best use of current technologies and is also future proofed to respond to changing technologies over time?

Energy strategies
We will expect development on the Site to have a very low 'in use' energy demand, through robust design of built fabric and services. This will make it easier to meet more of the scheme's energy demand from renewable and low carbon energy sources - and in some case may allow a 'net positive' energy balance to be achieved. Implications for wider energy networks should also be considered, with consideration of energy storage and demand control options at building and community level.

Form and fabric

Development within the Site will be designed, at both masterplan and building scale, to result in minimal energy use through sensitive consideration of site conditions and a robust approach to fabric performance, using passive design strategies to achieve good comfort, day-lighting and air-quality.

Building services

Developments should ensure they build on high quality design of form and fabric by specifying robust and efficient building services. If care has been taken in the design of the built fabric, it should be simpler for efficient building services to meet the needs of those who live and work in a building.

Energy generation and supply

Once the gross energy demand for the proposed development has been reduced through efficient built form and services, it will become possible to evaluate how a greater proportion of its needs can be met through renewable and low carbon energy sources.

Provision for electric charging points for vehicles should be implemented to ensure that both residents and workers have access to electric car charging points. Way-finding points and real time journey time information should be implemented across the Site to ensure people have accurate up to date travel information.

Delivery hubs should be provided on the periphery of the site to intercept large delivery vehicles from accessing the site. This will also help to consolidate deliveries and reduce the need for large vehicles to enter the Site, with smaller electric vehicles providing the final leg of the journey to the front door of the residence or workplace.

Subterranean bins should be provided on the Site to minimise space requirements for waste storage and provide a secure location for the bins.

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

It is considered unlikely that an at grade crossing can be located to link the Science Park with the station due to capacity constraints on Milton Road. A well-designed overpass for pedestrians and cyclists may provide the best option to effectively reduce severance caused by Milton Road and link the station with the Science Park. The journey from the station to the Science Park, will be the last / first mile of commuter journey and micromobility solutions such as dockless e-bikes should be provided to support the movement on this link.

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

The knowledge-based cluster around Cambridge Science Park, St John's Innovation Park, and Cambridge Business Park is internationally recognised, and the significant economic role that it offers to NEC must be fully harnessed to encourage complementary industries (Artificial Intelligence, R+D and laboratories for smaller emerging businesses that need the cluster benefits, maker-space etc) and optimise further employment opportunities. We would therefore expect a range (in terms of use and size) of employment spaces across NEC, including Science, Research & Development and Technology-related employment. However, in advocating innovation throughout NEC, policy limitations should not be imposed that unduly restrict any particular use at this stage.

Question 35: In particular, should the plan require delivery of:
A - a flexible range of unit types and sizes, including for start-ups and Small and Medium Sized Enterprises (SMEs);
B - Specialist uses like commercial laboratory space;
C - hybrid buildings capable of a mix of uses, incorporating offices and manufacturing uses.
D - shared social spaces, for example central hubs, cafes.
E - Others (please specify).

We generally support all of the suggested options at this stage, and would seek inclusion of corporate headquarters within category A. These options should equally be applied to proposals for meanwhile/worthwhile uses, in order to optimise economic development benefits and promote innovation at the earlier stages of the development process for NEC.

Question 36: Which of the following approaches should the AAP take to existing industrial uses in the North East Cambridge area?
A - seek to relocate industrial uses away from the North East Cambridge area?
NEC represents a significant and unique opportunity to create a new and innovative high-density, high quality, mixed use Quarter for Cambridge and its surrounding area. The opportunity is dependent on Housing Infrastructure Funding that will facilitate the relocation of the Water Treatment Works, and optimise the quantum of new housing across the Site. Whilst it is recognised that other, non-residential uses, will also be needed in NEC in order to promote multi-functioning mixed communities and internalised trips, capacity testing and Masterplanning will need to carefully identify what uses (and how much) will be appropriate. Whilst the prospect of utilising some of the Site for industrial use has not, at this stage, been discounted, justification for the need and location of such a use will need to be very carefully considered. A greater understanding of industrial need is therefore required, and in particular how essential it is for certain businesses to be in Cambridge. Consideration should also be given to whether existing businesses are compatible with residential neighbourhoods, as if so, there may be scope to incorporate industrial (i.e. b1c) accommodation within a mixed use development. This might, for instance, include ground floor workshops/maker spaces where noise, odour, other forms of pollution, and type of deliveries will not give rise to unacceptable living conditions for neighbouring properties. For existing businesses where there is not a demonstrable need to be in Cambridge, relocation options outside the NEC should be considered.

B - seek innovative approaches to supporting uses on site as part of a mixed use City District?
See response to A, above.

Question 37: Are there particular uses that should be retained in the area or moved elsewhere?

See response to A, above. The AAP should set out the strategy for determining the needs of individual businesses (and whether there is an operational imperative to be closely related to Cambridge, and how the relocation of existing industrial uses can be appropriately implemented..

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

The residential ambitions and opportunities in NEC (and particularly the Site) will need to be fully understood and embraced in order for the Vision and Objectives of the AAP to be realised. For the high density levels of new housing envisaged, innovation will be essential at all stages and in all forms. Traditional approaches to housing in Cambridge are unlikely to be appropriate. Housing will be made available for a much wider market than might otherwise be expected for a new settlement/strategic urban extension elsewhere in the county (e.g. Northstowe, Waterbeach, Cambourne), including that which is more aligned to smaller household sizes e.g. students, post-graduates, young professionals, and older persons looking to downsize. Where family housing is to be provided, it will require 'smarter-space' solutions to reflect the Site-wide high density approach.
A greater understanding of need and demand, market trends and viability will be needed to define housing requirements for NEC in later stages of the AAP process.

Question 39: Should the AAP seek provision for housing for essential local workers and/or specific housing provided by employers (i.e. tethered accommodation outside of any affordable housing contribution)?

Yes, see response to Question 38.

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

We generally support the suggestion of having a challenging target for the provision of affordable housing. There is a chronic shortfall of affordable housing in South Cambridgeshire and Cambridge City, and the residential growth aspirations of NEC could make a significant contribution in reducing housing shortfall. It is also important to ensure that there are a range of homes of different sizes and tenures to achieve mixed and balanced communities. However, it is also important to ensure that the policy is sufficiently flexible to address viability challenges, and takes a pragmatic approach when recognising how different types of housing are provided and thereafter managed and maintained e.g. less reliance on traditional approaches of 'pepper-potting' etc. There is a significant cost in delivering the level and type of development envisaged and it will be essential to ensure that delivery of the development can be secured on a viable basis. Consideration must also be given to exploring other means of making housing more widely accessible, such as through PRS for instance.

Question 41: Should an element of the affordable housing provision be targeted at essential local workers?

We generally support this suggestion, but a more detailed understanding of housing need and demand in the area, and indeed an understanding of what key employers in the area require, should be undertaking before developing an AAP-specific affordable housing policy.

Question 42: Should the AAP require a proportion of development to provide custom build opportunities?

We generally support this suggestion, but again a greater understanding of demand, need and viability is required. Consideration should be given to examples where successful custom-build housing has been delivered, such as Marmalade Lane, Cambridge's first co-housing community made up of 42 custom build homes.

Question 43: Should the AAP allow a proportion of purpose built HMOs and include policy controls on the clustering of HMOs?

We support the suggestion of creating more shared living and co-living housing opportunities, as these can help improve variety and access to more affordable, good quality accommodation. This type of housing typically incorporates shared services and facilities and can benefit both younger and older aged groups. However, again a greater understanding of demand, need and viability is required.

Question 44: Should the AAP include Private Rented Sector (PRS) as a potential housing option as part of a wider housing mix across the North East Cambridge area?

We generally support this suggestion, as it typically lends itself to earlier delivery, it can be part of an affordable housing mix, and may suit the needs of the adjoining employment base. Similar to HMO's, PRS development needs to be well-managed to integrate successfully. Again a greater understanding of demand, need and viability is required.

Question 45: if PRS is to be supported, what specific policy requirements should we consider putting in place to manage its provision and to ensure it contributes towards creating a mixed and sustainable community?

We would suggest that this needs to be considered in greater detail, including need and demand, management of facilities, services, and amenities should be well defined and required.

Question 46: Should PRS provide an affordable housing contribution?

Subject to viability, policy requirements will need to reflect the distinct economics of this tenure. In most cases (as in London) this is acknowledging that a form of Discounted Market Rent (capped at 80% of Open Market Rents) is most applicable, as this can be managed by a non-Registered Provider and therefore enables tenure blind blocks to be delivered by PRS operators.

Question 47: What 'clawback' mechanisms should be included to secure the value of the affordable housing to meet local needs if the homes are converted to another tenure?

Typically a profit sharing mechanism up to an agreed cap (cap to be reflective of the affordable housing contribution possible for open market sale units - i.e. the value difference between a private for sale scheme at 40% and a PRS scheme at 30%)

Question 48: What would be a suitable period to require the retention of private rented homes in that tenure and what compensation mechanisms are needed if such homes are sold into a different tenure before the end of the period?

We would suggest a period of 15 years with clawback as outlined in Questions 46 and 47. This period is proposed in the London Plan and is generally accepted by institutional investors

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

We consider that this should be agreed with each operator, and should be brief and relevant to planning matters. This could ensure all prospective tenants are offered the option of a three year tenancy.

Question 50: Should the area provide for other forms of specialist housing (including older people, students & travellers), either onsite or through seeking contributions for off-site provision?

We generally support this suggestion, but again a greater understanding of demand, need and viability is required. A comprehensive analysis of the demographic portrait of Cambridge and its surrounding environs over the next 25 years should be undertaken to assess how new policy interventions - such as NEC (intensified housing and employment uses; new housing 'products' to promote affordability and variety), new transport initiatives to improve access to employment, shopping, leisure and recreation etc, may affect demand and supply of different forms of housing for the local population catchment. In terms of 'housing mix', this might then manifest into redefining 'mainstream' housing, to expand into other groups such as students/graduates, first-time buyers, those requiring good quality rental properties, downsizers, elderly care.

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

We generally support this suggestion. This is a standard that ensures appropriate homes are delivered that meet the needs of the occupants. However, there may be some formats where exceptions may be appropriate - for example co-living formats including student and young professional accommodation, housing for 'downsizers' etc. These groups may prefer smaller homes with greater shared space and it may be appropriate to provide for this need in the context of a balanced housing offer. However, in these cases we would expect there to be clear requirements around the nature and quality of shared space. We would also encourage pilot testing (on a smaller scale) of more innovative solutions to housing, which might include other micro-living models that have not yet been used in Cambridge but have proved successful in other UK/international cities.

Question 52: Should the AAP develop space standards for new purpose built HMOs?

All new housing should meet the Technical Housing Standards and offer adequate shared spaces to not only provide adequate space in a HMOs scenario but above all provide homes that are future proofed as people's lifestyle changes and needs such as working from home also emerge. Future-proofed housing is to offer adequate space for a wide range of scenarios, not only HMOs. A specifically-developed space standards for new purpose built HMOs may prove unnecessary or irrelevant if HMOs within the AAP is then not delivered through a purpose-built type. Please see our response to Question 51.

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

We support the principle of ensuring that all homes have adequate and appropriate access to outdoor space and support the aspiration for most homes to have some private outdoor space. We would, at this stage, question whether it is realistic to expect that 100% of dwellings will have direct access to an area of private amenity space, given the quantum of development envisaged and the range of different housing typologies that will be necessary to deliver this quantum. In situations where it isn't appropriate to deliver private outdoor space, convenient access to high quality communal and public spaces would be provided. Ultimately, a flexible approach to residential amenity space must be taken, incorporating elements such as roof gardens and balconies as well as elements such as private gardens.

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

We generally support this suggestion in principle. This standard is meeting Part M of the Building Regulations, however due to the requirements of meeting a higher than normal housing number target on the Site, we require flexibility on how the standard is applied. It is important that the Cambridge Local Plan accessibility standards offers flexibility on how the standards are achieved across the many elements of the new masterplanned scheme. While designing for and incorporating accessibility standards is also accepted as a progressive way to future-proof new housing, it is important the standards do not affect the ability of the scheme to meet the density and the target housing required. Currently the Cambridge Local Plan has adopted the optional standard Part M4(2) and has also adopted M4(3) based on a percentage, which is still higher than the national standards, this may have an adverse impact on our scheme.

Question 55: Do you agree with the range of considerations that the AAP will need to have regard to in planning for new retail and town centre provision in the North East Cambridge area? Are there other important factors we should be considering?

The ambitious intentions for NEC are likely to see the creation of thousands of new homes and intensified employment opportunities forming part of new mixed, balanced and prosperous new communities. This new 'Quarter' will therefore require district and local centres to help support and sustain it. Non-residential uses will help create vitality and vibrancy to NEC.

Question 56: Should the Councils be proposing a more multi-dimensional interpretation of the role of a town centre or high street for the North East Cambridge area, where retail is a key but not solely dominant element?

We generally support this suggestion. We would highlight the importance of seeking innovative, creative and flexible solutions across the Site and this will be applied when considering how a District or Local Centre is planned and delivered. Longer term trends (national, regional and local) relating to retail and leisure uses will need to be carefully considered in arriving at a strategy that will support the long term vitality and vibrancy of NEC.

Question 57: What community facilities are particularly needed in the North East Cambridge area?

Opportunities will exist to provide access to new services and facilities for residents of NEC and existing surrounding local communities. In terms of the latter, where there are higher levels of deprivation, the cost of using new facilities will need to take account of affordability issues to ensure the cost of use is not prohibitive to those on no/low incomes.
Provision will need to be informed by the NEC Community Facilities Audit, whilst also taking account of the growth assumptions of NEC (including sizes and tenures of housing, as this will have potentially very different outcomes on need). Provision of facilities should offer flexibility and multi-functional spaces.

Question 58: It is recognised that maximising the development potential of the North East Cambridge area may require a different approach to meeting the sport and open space needs of the new community. How might this be achieved?

See our response to Question 24. Owing to the ambitious development aspirations of the Site (and NEC) it will be necessary to consider a comprehensive package of solutions (on and off-site) for open space and recreational strategy. This strategy will be complemented by the various improvements to green infrastructure provision in and beyond the AAP boundary, facilitating greater access opportunities by walking and cycling.

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

See our response to Question 24.

Question 60: Should open space provision within the North East Cambridge area seek to provide for the widest variety of everyday structured and unstructured recreational opportunities, including walking, jogging, picnics, formal and informal play, casual sports, games, dog walking and youth recreation?

We generally support this suggestion. It will be important to ensure that all spaces within the Site are fully optimised, and creative/innovative solutions should be considered to allow for flexible/multi-functional uses.

Question 61: Where specific uses are required to provide of open space as part of the development, should the AAP allow for these to be met through multiple shared use (for example school playing fields & playing pitches for the general public)?

See our response to Question 24.

Question 62: Within this overall approach, in particular, which option do you prefer in relation to carbon reduction standards for residential development?
A - a 19% improvement on 2013 Building Regulations (the current Cambridge Local Plan standard); or
B - a requirement for carbon emissions to be reduced by a further 10% through the use of on-site renewable energy (the current South Cambridgeshire Local Plan standard); or
C - a 19% improvement on 2013 Building Regulations plus an additional 10% reduction through the use of on-site renewable energy (combining the current standards in the Local Plans); or
D - consider a higher standard and develop further evidence alongside the new joint Local Plan.

At this stage we support Option D. This is a complex area of policy setting due to the current grid decarbonisation and emerging guidance from different bodies such as the UKGBC task force, and the GLA London Plan. The context of the electricity grid decarbonisation should be considered to ensure that any targets set do not create perverse outcomes in the future over the timescales of the development and should consider the appropriateness of energy efficiency targets as well as carbon targets.

The AAP should aim to be exemplar while also drawing on the most up to date emerging evidence.

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

Yes, we generally support the AAP sustainable design and construction approaches set out. However with regard to water recycling we think that while water recycling can be an important part of reducing water consumption if used inappropriately can be unsustainable. Therefore we would expect a rounded view to be taken as to when it is most appropriate to apply the highest levels of water recycling (as required by the maximum BREEAM credits for water efficiency), including an understanding of maintenance and carbon efficiency.
Question 64: Do you support the proposal for the AAP to be clear that review mechanisms should be built into any planning permissions in order to reflect changes in policy regarding sustainable design and construction standards in local and national policy? What other mechanisms could be used?

Yes we think it is important to recognise that not all future scenarios are foreseeable and that in order to avoid perverse outcomes in future it may be necessary to reappraise the policy requirements so that the most up to date and relevant standards are applied where necessary, reasonable and practicable.

It may also be advisable to follow guidance from notable charities and NGOs (e.g. UKGBC)

Question 65: Do you support the plan requiring delivery of site wide approaches to issues such as energy and water, as well as the use of BREEAM Communities International Technical Standard at the masterplanning stage?

Subject to further Masterplanning, technical assessment and feasibility testing, we generally support the approach to site wide water proposed and support the approach to innovate energy infrastructure such as smart energy grids. We support the view that infrastructure necessary for decentralised energy should be explored early on in consultation with relevant parties and that consideration should be given to a range of technologies and approaches to ensure the approach with the lowest carbon overall can be identified and supported.

We fully support the principles in BREEAM Communities and believe that while certification often brings a certainty of outcomes it does not always. The effective outcomes of applying BREEAM communities at this stage should be subject to further consideration.

Question 66: Are there additional issues we should consider in developing the approach to deliver an exemplar development?

Consideration should be given to the embodied impacts of buildings and infrastructure installed as well as opportunities to support the circular economy. Consideration should also be given to embracing and supporting innovative smart-tech and infra-tech initiatives where feasible and viable to do so.

Question 67: What approach should the AAP take to ensure delivery of a net gain in biodiversity?

In terms of the Site, owing to the on-going uses of land e.g. Water Recycling Centre, driving range, former Park and Ride site, it is considered likely that it will have limited biodiversity value. It will be necessary, at the relevant stage in the process, to carry out site specific investigations on the potential suitability of habitat for protected species, and to consider mitigation where appropriate. If the assumption is correct, it seems reasonable to believe that the Site can deliver net gains in biodiversity. Notwithstanding this, sites within NEC may be asked to consider biodiversity collectively, to show how habitat mosaics and corridors can be delivered on a more strategic basis. In this event, the AAP will need to provide greater clarity on what process is likely to be followed, and how this will be applied to individual development schemes.

Consideration will also need to be given to increasing the amount of tree canopy cover in NEC.

Consideration should be given to where biodiversity enhancements opportunities exist in nearby areas as well so that the best opportunities for linkages beyond the site boundary are identified as well as ensuring the best opportunities locally can be realised if necessary to meet the net gain requirements.

Question 68: Should the AAP require developments in the area to integrate SMART technologies from the outset?

We generally support the suggestion that NEC should seek to integrate SMART technologies from the outset. As we have previously noted, we will seek to encourage innovative, creative and adaptable solutions throughout all elements of development on the Site. It will be important to consider preparation of a digital strategy for NEC, to seek optimum speeds for broadband/fibre, opportunities to integrate SMART technology in homes, businesses and other development around NEC.

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

We support innovation throughout all elements of development on the Site (and indeed NEC). Rather than committing to any specific type of solution at this stage, it will be necessary to understand whether innovative systems used on other sites, such as North West Cambridge, can be applied on the Site.

Question 70: Do you agree that the AAP should prioritise land that can feasibly be developed early? Are there any risks associated with this proposed approach?

The obvious challenge with sites seeking early release/delivery is how they demonstrate that development will not prejudice the wider delivery aspirations of NEC. Where landowners/developers can explain how development can be carried out in a coordinated/comprehensive manner, it seems reasonable to expect that early delivery can be achieved. A coordinated/comprehensive approach must fully ensure that all development complies with s106 tariff/highways trips budgets, in an equitable manner.

As discussed later in Questions 79 and 80, we would encourage a positive policy approach be taken in supporting temporary/meanwhile uses in order to activate the Site in its earlier development phases, and to optimise economic and social benefits in the local area.

Question 71: Should the AAP include a relocation strategy in preference to leaving this to the market to resolve?

The representations of landowners and occupiers will inform the approach. It is considered that the AAP will need to identify and define a strategy for key sites/uses to be relocated, but maintain flexibility for others. Notwithstanding this the NEC has significant potential to deliver economic, social and environmental benefits, and whilst there are a relatively small number of landowners, the strategic opportunities must not be compromised by one or more parties that are unwilling to support the delivery of the NEC. Accordingly, the Councils cannot discount the possibility of using their CPO powers if required.

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

An infrastructure delivery plan should be prepared for the North East Cambridge Area to identify the infrastructure required and the costs associated with those projects, in order to inform discussions on planning obligations. It would be reasonable to expect all development within the area to contribute towards the required infrastructure, where it benefits the AAP area as a whole rather than individual sites/landownerships

Question 73: What approach do you consider the most appropriate basis on which to apportion the cost of the infrastructure requirements arising from different land uses to ensure an equitable outcome?

We consider that this should form part of a specific study that includes, inter alia, the following considerations:
*Identify the infrastructure required across the AAP area that is necessary to delivering the comprehensive vision. This might include key routes, connections, bridges / underpasses, transport, education, energy/utilities, social etc.
*Identify where these are most appropriately located to meet the AAP vision.
*Establish a cost base for these, including appropriate cost of land recognising that in some cases it would be otherwise used for residential or other development
*Establish an appropriate equalisation formula across the AAP, levied on all new development. This could be one or a combination of a tariff per m2, per net acre etc and may be varied by use class.
*Set this out in a policy / legal framework with an appropriate indexing mechanism

Question 74: How should the AAP take into account potential changes over time, both positive and negative, that might affect development viability?

We consider that this should form part of a specific study that includes, inter alia, the following considerations
*ensuring that development continues steadily over potentially a number of economic cycles - this possibility should be acknowledged and planned for at the outset
*Any viability test whereby s106 or AH requirements would be reduced would need to be carefully calibrated to ensure that infrastructure is protected.
*A review mechanism within the S106 Agreement would allow viability to be reassessed if circumstances change.

Question 75: Do you agree with the proposal to require land assembly where it can be demonstrated that this is necessary for delivering the agreed masterplan for the North East Cambridge area and/or the proper planning of development?

Yes. This does not directly affect U+I. Land assembly will help to ensure the delivery of comprehensive redevelopment of NEC.

Question 76: Should the AAP state that the Councils will consider use of their Compulsory Purchase powers? If so, should the AAP also set out the circumstances under which this would appropriate?

The NEC has significant potential to deliver economic, social and environmental benefits, and whilst there are a relatively small number of landowners, the strategic opportunities must not be compromised by one or more parties that are unwilling to support the delivery of the NEC. It therefore seems appropriate for the AAP to specify how the Councils will use their CPO powers if required, and the circumstances for doing so. This will need to include the viability and timescales of pursuing a CPO process.

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

Yes. There are a range of stakeholders and landowners involved in the development at the North East Cambridge area, and the successful delivery of NEC will require a coordinated approach. This will need to consider a range of issues including connectivity, infrastructure locations, parking/trip budget, smart-city coordination, delivery programmes, design principles, energy/utilities and waste etc.

Question 78: Do you agree with the Councils' proposed approach to dealing with planning applications made ahead of the AAP reaching a more formal stage of preparation?

Yes. It is agreed that a coordinated approach is required and decisions on applications should be made against the AAP with appropriate, equitable contributions made.

Question 79: What types of 'meanwhile uses' should the AAP support for the North East Cambridge area?

We would suggest a range of 'meanwhile uses' could be appropriate for NEC, and would not expect policy to impose any particular restriction on types of use. The emphasis should be on promoting innovation and creativity, with meanwhile uses serving to provide early foundations for the new Quarter that will emerge and subsequently replace the meanwhile uses in the coming years. Meanwhile uses could therefore provide start-up/incubator accommodation for emerging/expanding sectors, pop-up/small-scale A class uses, community space to begin community cohesion with surrounding neighbourhoods etc. A positive policy approach to obligations and planning requirements will be needed to encourage temporary/meanwhile activation, helping to avoid onerous situations that might otherwise render creative initiatives unviable.

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

It seems unnecessary to impose a limitation on the scale of a proposed 'meanwhile use', as the purpose of a meanwhile use is, fundamentally, to make optimum use of a site that will otherwise be under-utilised for many years. This can have many short-term economic and social benefits. A policy limitation may stifle innovation and creativity. It is considered likely that many of the meanwhile use proposals will require formal planning consent, which will provide the Local Planning Authority with the ability to control and enforce development that is deemed inappropriate.

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

No. A minimum period should be based on the need and timetable for the permanent development. For the most successful meanwhile initiatives a reasonable period of operation is required in order to recoup the initial capital investment.

Question 82: Should the AAP also include a requirement for 'meanwhile uses' to demonstrate how they will add vibrancy and interest and/or deliver on the wider development outcomes and vision for the North East Cambridge area?

No. 'Meanwhile' uses are temporary in nature and an approach that seeks to make efficient use of land, in a compatible manner with surrounding uses, should be encouraged.

Question 83: What negative or positive impacts might the proposed plans have on residents or visitors to Cambridge with low incomes or who have particular characteristics protected under the Equality Act 2010? (The protected characteristics are age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex, and sexual orientation.)

We strongly support the intention of the Vision for NEC and Objective 5, to ensure social and economic inclusion, and as stated in our response to Question 5, would seek the addition of the word 'culturally' within the Vision i.e. 'North East Cambridge - a socially, culturally, and economically inclusive...'

It is recognised that NEC lies within close proximity of two highly deprived wards in Cambridgeshire, and that regeneration on the scale envisaged will create significant socio-economic opportunities for a wider catchment beyond the AAP boundary. Development on the Site, for instance, will create long term employment across a multitude of sectors and skill ranges, improved connectivity around the NEC and access to new services and facilities. We support the intention of the Councils to undertake a Health Needs and Impact Assessment, across an appropriate study area for the NEC, in order to better understand the challenges and issues faced in neighbouring wards, so as to link into opportunities that will arise in NEC.

As stated within our response to Question 5 we generally support the application of local plan accessibility in the NEC. This standard is meeting Part M of the Building Regulations, however due to the requirements of meeting a higher than normal housing number target on the Site, we require flexibility on how the standard is applied. It is important that the Cambridge Local Plan accessibility standards offers flexibility on how the standards are achieved across the many elements of the new masterplanned scheme. While designing for and incorporating accessibility standards is also accepted as a progressive way to future-proof new housing, it is important the standards do not affect the ability of the scheme to meet the density and the target housing required. Currently the Cambridge Local Plan has adopted the optional standard Part M4(2) and has also adopted M4(3) based on a percentage, which is still higher than the national standards, this may have an adverse impact on our scheme.

Question 84: Do you have any other comments about the North East Cambridge area and/or AAP? Are there other issues and alternatives that the councils should consider? If you wish to make suggestions, please provide your comments.

We would encourage a specific section on education and health provision within the NEC, noting the likelihood that if on-site provision is required, it may require different formats/approaches on how such provision is made i.e. traditional forms of provision in Cambridgeshire are unlikely to be suitable in a high density urban regeneration scheme of this nature.

If off-site provision is considered to be more appropriate, comment should be given on how and where need is expected to be accommodated (for instance it may be more appropriate to extend existing or proposed schools in Cambridge, to create additional Forms of Entry, rather than have a lower number of Forms of Entry on-site that falls below the recommended minimum sizes).

Introduction

Cambridge City Council and South Cambridgeshire District Council is consulting on Issues & Options for the North East Cambridge AAP. The consultation deadline is 25th March 2019. The draft response on behalf of U+I Group PLC ('U+I') is set out below. U+I have been selected by the landowners Anglian Water and Cambridge City Council as Master Developer for land outlined in red in the accompanying Site Plan ('the Site'). It is noted that Cambridge City Council also own other land beyond the Site, which may be the subject of other representations.

The representations contained herein relate primarily to the development intentions for the Site, but also in the context of the wider AAP area (as sites within the AAP boundary are largely intrinsically linked).

Representations

Question 1: Do you agree with changing the name of the plan to the 'North East Cambridge Area Action Plan'?

It is recognised that there is a need for a collective reference for the AAP area. This will provide consistency and clearer definition as the process evolves. Whilst it is inevitable that sub-areas of the AAP will emerge with different branding names and strategies, this will have more relevance to the individual sub-area concerned, in creating identity when publicising forthcoming planning applications through to marketing/sales disposals.

Question 2: Is the proposed boundary the most appropriate one for the AAP?

Generally, we support the proposed boundary for the AAP area. We would, however, make two observations/comments.

Firstly, it seems logical to include the site of Cambridge Regional College ('CRC') within the boundary. It is noted that in paragraph 3.5 comment is made that it is not expected to undergo major change in the way other sites across NEC are. However, CRC considers itself to be 'one of the best Further Education Colleges in the country for 16-18 year old level 3 achievement and a leading apprenticeship provider, with thousands of full time students and apprentices currently in training'. The significant range of vocational courses it offers could be positively utilised to support the long-term construction process around NEC (e.g. architectural technology, mechanical engineering, electrical, carpentry, bricklaying courses and apprenticeships), and then the on-going operational phases of the different sub-areas of NEC (e.g. from courses relating to biological science for industry, laboratory technicians and computing technologies, to business and catering and hospitality). It therefore has the potential to play an important learning and development role in the future NEC area. The built form of the current campus appears to be relatively low density, with large areas of used for surface level car parking. Buildings are predominantly 2-3 storeys in height. With the transformation of NEC, recognising the different approaches to internalised trips/reduced car parking, and taller buildings, it would seem likely that the estate management of CRC might change in the future, and if so, it should be included in the AAP.

Secondly, we would comment that, owing to the nature of NEC, development is likely to be high density, optimising the use of all land to work efficiently and effectively. The strategy for on-site Public Open Space is likely to focus on qualitative provision, than quantitative, with a stronger emphasis on formal recreational and leisure space than informal open space. Access to the latter however, is likely to be facilitated through new and improved connections to the east (potentially including land to the east of the railway line north of Cambridge North Train Station, to the river) and north (potentially including land to the north of the A14, such as Land to the south of Cambridge Road, and land including/extending Milton Country Park) of NEC. We would therefore simply pose the question about whether there is a need to include within the AAP boundary additional land that could provide informal open space, biodiversity and drainage functions, which might otherwise not be achievable within the single control of the NEC boundary. It is considered that land to the north and east of the current AAP boundary would primarily be used to facilitate access to green infrastructure for NEC.

Question 3: In this chapter have we correctly identified the physical characteristics of the North East Cambridge area and its surroundings?

Generally, yes. However, we consider it might be beneficial to include more information about the composition of site areas. For instance, on the employment parks, providing details about site area, total floorspace of buildings on the park (including extant planning consents) and the range of authorised planning uses e.g. % B1a uses, %B1b uses, estimated no. of employees, audit of authorised car parking spaces, audit of public open space (estimated total hectares). This would help to inform a baseline of land use within NEC, and then contribute in developing future strategy e.g. highway trip budget, employment strategy, connectivity and green infrastructure etc.
We would also note that it would be beneficial to have mapping information available relating to the environmental constraints identified e.g. noise, air quality, odour, important habitats.
Finally, it would be beneficial to show the broader extents of key infrastructure for NEC, including the full Chisholm Trail link (connecting NEC to Cambridge City, and the south of Cambridge (Addenbrookes), committed routes for other new cycle, pedestrian and public transport in and around the City, and the proposed Greenways link to Waterbeach).

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

In general, yes. However, we note that there is no reference to Archaeology and Heritage, and would suggest that comment is given about this, even if it is considered that NEC has limited archaeological significance. In terms of heritage, whilst we believe that there are no listed buildings, conservation areas, or other notable heritage constraints within NEC, the intention for taller buildings in NEC will need to be more widely considered in respect of longer-distant views and townscape issues (historic core of Cambridge). Taller buildings may also have potential implications for Air Safeguarding Zones (consultation required with Marshall Airport and the Ministry of Defence on structures over 15m in height), and the Mullard Radio Astronomy Observatory (consultation with the University of Cambridge). We acknowledge that the issue of building heights and taller buildings is likely to be assessed as part of the on-going Landscape Character and Visual Impact Assessment that is being undertaken by Cambridge City Council (it is understood that a 'Stage 1' exercise has already been commissioned), and that the findings are then likely to inform future stages of this AAP process.

We would also suggest consideration be given to the inclusion of Green Belt boundaries around NEC. This will help provide clarity to interested parties that all land envisaged for development and associated physical infrastructure will be accommodated on non-Green Belt land. It will also help to provide reassurance that the development aspirations for NEC will not automatically lead to further development beyond the identified boundaries, unless it is deemed to be 'appropriate development' (i.e. not 'inappropriate' as defined in the National Planning Policy Framework'), or that exceptional circumstances are demonstrated in future Local Plans, or a Very Special Circumstances argument is made to support development via a planning application process. In all cases, strict mechanisms for controlling additional future development beyond NEC will apply.

Reference should also be made to the presence of UKPN's overhead power cables (132KV) that span across the AAP boundary. In terms of ensuring optimum reuse of the Site (and indeed other sites, including Cambridge Science Park), we would support a policy seeking their diversion underground.

Question 5: Do you agree with the proposed Vision for the future of the North East Cambridge area? If not, what might you change?

Yes, we support the proposed Vision for NEC. The addition of the word 'culturally' might benefit this Vision further (in the context of 'North East Cambridge - a socially, culturally, and economically inclusive....)

Question 6: Do you agree with the overarching Objectives? If not, what might you change?

Generally, we support the overarching Objectives. The addition of the words 'Natural Capital' might benefit Objective 7 further (in the context of '...connecting and improving biodiversity to achieve a Natural Capital net gain....)

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

It is noted that the Concept Plan can only be treated as indicative at this stage in the AAP process, until the outcomes of the various Supporting Studies are known (notably Landscape Character and Visual Impact Assessment, Development Capacity Study, NEC AAP Transport Assessment, NEC Development Viability Assessment, NEC Infrastructure Delivery Plan), and wider consultation with relevant interested parties (e.g. landowners, developers, local communities, local authority bodies etc) has been carried out.

We support the residential-led mixed use allocation for the Site. We support the aspiration to create high quality pedestrian, cycle and public transport connectivity across the AAP area. We support the indication that a Mixed Use District Centre will be provided on the Site though we would suggest that its optimal location can only be determined after further study and masterplanning work. There may also be a need to include an additional Mixed Use Local Centre in the northern half of the Site (subject to further Masterplanning and an assessment on accessibility). We support the intention to provide and integrate Green Infrastructure throughout the AAP boundary, but what provision is made (and how/where it will be provided) will need to be determined following further studies/assessment and Masterplanning. Further consideration will need to be given to the suggested Industrial Development Sites in the north east corner of the Site, to understand what the rationale is for proposing to relocate existing industrial land at Nuffield Road and Cowley Road, to another part of the AAP site. It is assumed that the suggestion is made on the basis that it will provide noise abatement from the A14 to the new residential elements of the Site. However, we consider that there may be other more preferable solutions for controlling noise and, in Masterplanning terms it is less desirable bringing industrial-related traffic through a predominantly residential site. In the absence of clear justification for seeking relocation of industrial uses, we cannot support the industrial element of the proposal.

We aren't yet persuaded that the proposed location and quantum of industrial use is optimal. In particular we have concerns that this is currently shown at the furthest point from strategic highway connections. We also believe that different models and formats of industrial development should be further explored, specifically whether this should be concentrated in a single location, or whether it might be incorporated within a mixed-use approach throughout the Site.

We do not necessarily agree that the Site represents the best opportunity with the overall AAP area to accommodate a significant concentration of industrial uses in a single location.

We would suggest that the Cambridge Business Park is shaded as an Opportunity for Employment Intensification.

In addition to our response for Question 2, we would suggest that the CRC land we would suggest that this land is included within the AAP boundary, and that a new shading is applied that refers to an Opportunity for Education Intensification.

Question 8: Do you agree that outside of the existing business areas, the eastern part of the North East Cambridge AAP area (i.e. the area east of Milton Road) should provide a higher density mixed use residential led area with intensified employment, relocation of existing industrial uses and other supporting uses?

Generally, we support the initial development intentions for the area east of Milton Road. It is considered that this area could accommodate a high density mixed use residential-led development following the relocation of the existing Cambridge Water Recycling Centre and other industrial uses (subject to viability and finding suitable relocation site(s)) from the Site. A comprehensive, design-led, approach across the AAP will help maximise the redevelopment potential of a significant brownfield site in a highly sustainable location.

Question 9: Should Nuffield Road Industrial Estate be redeveloped for residential mixed use development?

Yes, we agree that consideration should be given to relocating existing industrial uses on the Nuffield Road Industrial Estate, in preference for higher density residential-led mixed use redevelopment. Consideration should be given to the viability of doing so (industrial land values are currently relatively high), and where existing businesses will be relocated. An Industrial Relocation Strategy might be appropriate, in order to understand what factors are important to businesses e.g. last mile strategies and what alternative sites might be available to accommodate relocation requirements. ]

As outlined in Question 7, the suggestion to relocate industrial uses from Nuffield Road Industrial Estate to the north east corner of the Site needs to be explained and justified. At this stage we do not support the suggestion to relocate industrial uses to the north-east corner of the Site.

Question 10: Do you agree that opportunities should be explored to intensify and diversify existing business areas? If so, with what sort of uses?

Yes, we broadly support this suggestion, subject to the establishment of a robust and equitable approach to Highways Trip Budget apportionment and s106 tariff system across the wider AAP area. The Cambridge Science Park was first established on the principle of accommodating 1-2 storey, low density commercial buildings within an attractive strategic landscape/parkland setting. Whilst much of the strategic landscaping remains, latter phases of the Science Park have sought to intensify development density, with taller buildings, lower car parking provision, and limited on-plot landscaping (other than to lessen/soften the impact of new development). This approach has been complemented by the introduction of Cambridge North Station Interchange, which has significantly improved accessibility via non-car modes. The growth aspirations now anticipated for the AAP area signals a radical change in approach to new development. New residential communities will be supported by existing and intensified employment and educational opportunities, potentially providing live and work/learning opportunities within walking/cycling distance of each other. Furthermore, access to inter alia Cambridge North, the Guided Busway, and the Chisholm Trail will support accessibility to existing business areas from a much wider catchment, therefore helping to improve the means of accessing work without the need to do so by car.

Opportunities to provide a greater quantum and diversity of employment should be encouraged. This will consolidate and strengthen the concept of the Cambridge Phenomenon, by creating a greater range and quantum of high quality accommodation for new businesses, in close proximity to a critical mass of similar businesses, thereby helping to support knowledge sharing and collaboration through co-location.

In order to promote diversity of employment types, planning policy consideration might be given to encouraging a certain percentage of 'affordable employment', to support the growth of new start-up businesses that require the same close links with similar businesses but cannot afford (and do not currently need) accommodation that becomes available.

Question 11: Are there any particular land uses that should be accommodated in the North East Cambridge area?

The North East Cambridge area should support any use that demonstrably contributes to the Vision and Objectives of the AAP area.
The AAP provides a significant opportunity to create thousands of new homes in a highly sustainable location. The growth of housing in this area will be supported by the economic benefits derived from the long-established science, innovation and business parks (many of which will be intensified), that have collectively grown from the success of clustering knowledge-based industries in close proximity of one another. The housing element of the Site will improve supply and affordability of high quality new homes to the many thousands of employees on these parks, helping to reduce the number of car movements on Milton Road. New homes and jobs on the scale envisage will need to be served by a number of social, retail, community, health, education, leisure and recreation facilities,

Question 12: What uses or activities should be included within the North East Cambridge AAP area which will create a district of culture, creativity and interest that will help create a successful community where people will choose to live and work and play?

It is considered that the inclusion of schools, community facilities, retail and leisure uses, open space, and transport services, in conjunction with walking and cycling connections to neighbouring areas will provide the attributes of a successful community.

The NEC AAP must recognise the wider role it plays in creating opportunities for surrounding communities, of which two neighbouring wards - East Chesterton and Kings Hedges - currently suffer from high levels of deprivation (included in the top three of most deprived wards in Cambridgeshire). The benefits of the AAP area should extend to these areas, to create new employment, education, social, leisure and recreation, health and community opportunities. Where new facilities are introduced to areas experiencing deprivation, a key challenge for optimising use of such facilities is affordability. Free or subsidised charging mechanisms should therefore be considered when providing new facilities for instance e.g. hire of sports pitches, meeting rooms etc.

It should, however, be recognised (and indeed it is in Question 79) that the ambitious development aspirations for the Site and wider AAP area will take a number of years to comprehensively plan and deliver. Certain elements will be possible to deliver early. Notwithstanding this, there is the opportunity to introduce 'meanwhile/worthwhile' uses the area as the transition progresses. Meanwhile/worthwhile uses offer creative and innovative ways of optimising sites on a stop-gap basis, creating a temporary opportunity to capture economic and/or social benefits for the wider area in the period between the closure/or reduction of an existing site operation and the commencement of the intended new development.

Question 13: Should the AAP require developments in the North East Cambridge AAP area to apply Healthy Towns principles?

NEC will provide a considerable opportunity for creating a healthy new community, and supporting neighbouring communities, through access to high quality housing, a design approach founded on sustainable modes of travel (walkable neighbourhoods), and improved employment, shopping, health, education, leisure and recreational opportunities. We also support the intended preparation of the Health Impact and Needs Assessment for NEC, which will take account of the wider deprivation challenges faced in the neighbouring wards of East Chesterton and Kings Hedges.

Question 14: How should the AAP recognise and make best use of the existing and potential new links between the AAP area and the CRC (Cambridge Regional College)?

Please see our response to Question 2.

Question 15: Should clusters of taller buildings around areas of high accessibility including district and local centres and transport stops form part of the design-led approach to this new city district?

We strongly support the principle that the greatest development densities should be located in the areas of greatest accessibility and public amenity. This maximises the potential for sustainable travel patterns and establishes a critical weight of local demand for leisure, cultural and retail uses.

It is important to note that 'high-density' does not automatically mean 'tall' and that compact mid-rise development can often be denser than taller development, particular where the latter is compensated for by a smaller overall development footprint. Compact mid-rise also typically enables a wider range of dwelling types and external amenity space, meeting a wider range housing needs.

We favour a 'transect' based approach to masterplanning which will ensure the density, scale, typology, and uses of development are allocated across the site as a whole and within each neighbourhood in a coordinated way, following the accessibility principle described above and responding to the opportunities and constraints of the Site. This may not mean 'clusters' - it could for example mean that the highest densities are located in 'corridors' along the primary streets, and/or at edges where having denser development acts to shelter lower-scale development from adjacent visual or noise intrusion. The masterplan will be backed up by a design code that will identify/mandate appropriate typologies for achieving the requisite densities in ways that are acceptable in other respects.

In addition to accessibility and other local factors, it is important to note that the extent and location of denser development will be affected by a range of detailed studies and appraisals (including Landscape Character and Visual Impact Assessment), that will recognise - and then balance - the challenges of creating areas of higher density and taller buildings in a highly sustainable location that is, nonetheless, on the edge of Cambridge with areas of open countryside beyond. This may also militate against achieving density through height.

Question 16: Should the AAP include any or a combination of the options below to improve pedestrian and cycling connectivity through the site and to the surrounding area?

A - Create a strong east-west axis to unite Cambridge North Station with Cambridge Science Park across Milton Road. This pedestrian and cycle corridor would be integrated into the wider green infrastructure network to create a pleasant and enjoyable route for people to travel through and around the site. The route could also allow other sustainable forms of transport to connect across Milton Road.

Yes. A strong east-west axis should be included to connect the different parts and proposed uses within NEC, and to encourage movement within the site by sustainable modes of transport.

B - Improve north-south movement between the Cowley Road part of the site and Nuffield Road. Through the redevelopment of the Nuffield Road area of NEC, it will be important that new and existing residents have convenient and safe pedestrian and cycle access to the services and facilities that will be provided as part of the wider North East Cambridge area proposals.

Yes.
C - Upgrade connections to Milton Country Park by both foot and cycle. This would include improving access to the Jane Coston Bridge over the A14, the Waterbeach Greenway project including a new access under the A14 (see Transport Chapter), as well as the existing underpass along the river towpath.

Yes. It is considered that improvements to connections with Milton Country Park and with existing and proposed pedestrian and cycle routes will be important for the success of development within the AAP. It is anticipated that NEC will provide a high density residential development, to take advantage of the close proximity of employment areas and public transport services, but which might limit opportunities for large scale open space/recreation areas. Therefore, it will be important to ensure that any proposal for an underpass will maximise connectivity through the Site, capitalising on permeability and wider Green Infrastructure initiatives (e.g. Waterbeach Greenway, Chisholm Trail, improving the public realm function of the 1st Drain etc).

D - Provide another Cambridge Guided Bus stop to serve a new District Centre located to the east side of Milton Road.

We support the suggestion to improve public transport accessibility around NEC but further work should be undertaken to determine whether an additional 'guided' busway stop is required or whether a 'normal' bus service, which could feasibly use the same buses as those on the Busway, could deliver the same benefits.

E - Increase ease of movement across the sites by opening up opportunities to walk and cycle through areas where this is currently difficult, for example Cambridge Business Park and the Cambridge Science Park improving access to the Kings Hedges and East Chesterton areas as well as the City beyond.

We very much support opportunities to increase the ease and convenience of walking and cycling movements across sites in NEC, as this will strengthen the concept of promoting internalised trips and reduce the reliance on travel by car.

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

It is noted that the River Cam towpath is identified as a route within the Waterbeach Greenway project, and it would be appropriate to take the opportunity to provide a pedestrian and cycling connection from this route into NEC, subject to the availability of funding.

The high density redevelopment of NEC is unlikely to achieve the level of Public Open Space that might otherwise be required under local plan policy. The focus is instead likely to be on securing high quality, flexible-use open space on-site, and improving/providing new connections to informal open space networks to the north and east of the AAP area (including the Waterbeach Greenway). Accordingly, an appropriate means of accessing off-site Green Infrastructure for NEC will be required, and the suggestion of a pedestrian/cycle bridge would facilitate this.

Please see our responses to Questions 2 and 7.

Question 18: Which of the following options would best improve connectivity across Milton Road between Cambridge North Station and Cambridge Science Park?
A - One or more new 'green bridges' for pedestrians and cycles could be provided over Milton Road. The bridges could form part of the proposed green infrastructure strategy for NEC, creating a substantial green/ecological link(s) over the road.
B - Subject to viability and feasibility testing, Milton Road could be 'cut-in' or tunnelled below ground in order to create a pedestrian and cycle friendly environment at street level. This option would allow for significant improvements to the street which would be more pleasurable for people to walk and cycle through.
C - Milton Road could be significantly altered to rebalance the road in a way that reduces the dominance of the road, including rationalising (reducing) the number of junctions between the Guided Busway and the A14 as well as prioritising walking, cycling and public transport users.
D - Connectivity across Milton Road could be improved through other measures. We would welcome any other suggestions that would improve the east-west connectivity through the site.
E - Other ways of improving connections (please specify)

In response to all five options listed above, we generally support the principle for securing high quality east-west connectivity. However, the means of crossing Milton Road will involve a range of complex issues, which cannot be determined at this stage. The crossing solution(s) should not ultimately be compromised by concerns about short-term disruption and inconvenience. The east-west axis will be fundamental in the overall success of NEC, and the justification for internalising trips will be partly made on the basis that pedestrian and cycle connectivity across NEC will be safe and convenient (and therefore likely to be commonly used as a means of travel).

Option A is considered to be the preferred option as it provides the opportunity to create a substantial green link over the road without adversely affect the flow of traffic on Milton Road, which has existing network capacity issues. It will also limit the impact on the operation of the Milton Road during construction when compared with either Option B and C.

Option B would likely result in significant disruption to the road network during construction and would likely require the lowering or redirecting or Statutory Undertakers Utilities. Both Option B and C would result in alterations to the access junctions into the Science Park and the Site, both of which have limited access opportunities for their respective sizes.

Question 19: Should development within the North East Cambridge area be more visible from Milton Road, and provide a high quality frontage to help create a new urban character for this area?

We generally support the suggestion of making new development within NEC more visible from Milton Road and providing a high quality frontage to create a new urban character for the area. Milton Road is currently a highly car dominated environment, with a number of confusing junctions serving Cambridge Science Park and Cowley Road. However, it is noted that Milton Road acts as a key north / southbound route into and out of Cambridge, and the Milton Interchange forms part of the Strategic Road Network and connects Cambridge to the A14 (a major east to west route, which has recently been upgraded to improve capacity). Given the level of traffic using this stretch of the Milton Road to access the Strategic Road Network at this location, the potential to reduce traffic to provide a high quality new urban character for the area may be limited in the short term. Notwithstanding this, where Milton Road runs southwards the nature of the road starts to change and becomes more urban in nature, potentially becoming more conducive to active frontage and activity on the footway.

Question 20: Do you agree with proposals to include low levels of parking as part of creating a sustainable new city district focusing on non-car transport?

Yes, we generally support this principle NEC provides an opportunity to reduce levels of parking, as part of a package of transport measures including new and additional walking and cycling routes, public transport services, and car share schemes. However, we would also suggest that interim car parking strategies might need to be considered, to support 'pioneer' uses/development during transitional phases of NEC i.e. until the full package of transport infrastructure and initiatives can be fully realised. As new infrastructure/initiatives are introduced, interim car parking can be gradually phased out.

Question 21a: In order to minimise the number of private motor vehicles using Milton Road, should Cambridge Science Park as well as other existing employment areas in this area have a reduction in car parking provision from current levels?

We very much support opportunities to reduce the reliance on travel by car in and around NEC, and instead increase the ease and convenience of walking and cycling movements across sites in NEC, as this will strengthen the concept of promoting internalised trips.

Question 21b: Should this be extended to introduce the idea of a reduction with a more equitable distribution of car parking across both parts of the AAP area?

Yes, as part of a package of transport measures to encourage travel by sustainable modes of transport.

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

Yes, subject to further understanding of the requirements of businesses and the needs of residents. The North East Cambridge area could include a number of delivery/collection hubs.

Question 23: Should development within the North East Cambridge area use car barns for the storage of vehicles?

We support the idea of using car barns, as part of a wider package of parking solutions across NEC. Whilst it is recognised that private on-plot parking is unlikely to be widely encouraged, there will inevitably be demand from some residents to have access to the use of a car/secure car parking but this should be priced accordingly to the end user. Car barns provide communal access to parking, and are typically located in less convenient locations in order to discourage frequent use. As an example, if a car was needed to do a weekly shop, the resident would park outside their property to unload their car and then move the car to a car barn. Car barns can also be used by 'car clubs', so that a resident can book a car for a certain period of time but not have the long-term cost and use commitment to owning a private car. The versatility of car barns should also be recognised, as parking can be let on a temporary basis and, as trends change, can be converted into alternative uses to reduce car usage further.

Question 24: Within the North East Cambridge area green space can be provided in a number of forms including the following options. Which of the following would you support?
A - Green space within the site could be predominately provided through the introduction of a large multi-functional district scale green space. Taking inspiration from Parker's Piece in Cambridge, a new large space will provide flexible space that can be used throughout the year for a wide range of sport, recreation and leisure activities and include a sustainable drainage function. The sustainable drainage element would link into a system developed around the existing First Public Drain and the drainage system in the Science Park. The green space could be further supported by a number of smaller neighbourhood block scale open spaces dispersed across the site.
B - Green spaces within the site could be provided through a series of green spaces of a neighbourhood scale that will be distributed across the residential areas. These green spaces will also be connected to the green infrastructure network to further encourage walking and cycling. Again, these spaces will include a sustainable drainage function and link into the existing First Public Drain and the Science Park drainage system.
C - Enhanced connections and corridors within and beyond the site to improve the biodiversity and ecological value as well as capturing the essential Cambridge character of green fingers extending into urban areas. These corridors could also be focussed around the green space network and sustainable drainage and would reflect the NPPF net environmental gain requirement.
D - Green fingers to unite both sides of Milton Road and capitalise on the existing green networks.
E - Consideration of the site edges - enhancement of the existing structural edge landscape and creating new structural landscape at strategic points within and on the edge of NEC. This would also enhance the setting to the City on this important approach into the City.
F - Creation of enhanced pedestrian and cycle connectivity to Milton Country Park and the River Cam corridor.

In response to all six options listed above, we support the principle for securing high quality green infrastructure across NEC. Subject to further capacity testing and Masterplanning, on-site provision might feasibly take the form of a larger green space for the whole NEC and complemented by smaller 'neighbourhood scale' spaces and enhanced connections and corridors to off-site green infrastructure. We aren't persuaded that Parkers Piece is an appropriate comparable for the size and function of this space but do consider that the green space should draw lessons from existing green spaces in Cambridge. However, in supporting the theme of innovation at all stages of the development it will be important to consider smart solutions for the open space strategy, maximising flexibility across all areas of on-site open space. For instance, playing fields associated with on-site school provision should be available to the wider community, at times when it is not required by the school. Management and security issues will need to be carefully considered in this regard. Landscape vegetation should encourage biodiversity, whilst also performing softening/screening functions. Formal playspace should be able to accommodate multi-use activities during the day and evening and throughout the year. Green infrastructure might incorporate elements of food growing e.g. fruit trees, herbs, and vegetables, enabling free access to foods that help promote healthier lifestyles.

In terms of the suggestion of how open space will be provided (and in what format and amount), this cannot be determined at this stage of the process. A series of studies and assessments have been or are being commissioned by Cambridge City Council, which will help inform development principles and Masterplanning. Consultation will also need to be carried out with a number of interested parties, including landowners, developers, local communities and local authority bodies. Therefore, we are neither supporting nor objecting to any of the suggested options at this stage.

Question 25: As set out in this chapter there are a range of public transport, cycling and walking schemes planned which will improve access to the North East Cambridge area. What other measures should be explored to improve access to this area?

We generally support the suggested options for improving public transport, cycling and walking accessibility around NEC. The proposed Waterbeach Greenway should be directed through the Site, to create a coherent route from Waterbeach to the station. This will allow future residents of the Site to cycle to the station helping to providing a means of travel for the 'first mile / last mile' of the journey to / from the station.

A new route for a busway from the proposed Waterbeach development should be routed through the Site down to Cambridge North Station. Stops on the route could form transport interchanges linking to other bus routes and cycle routes. High quality cycle links should be implemented to connect into existing infrastructure such as the Chisholm Trail.

The route of these two transport spines through the Site will help develop a single coherent sustainable transport corridor down to the station allowing seamless interchanges between transport modes where the routes intersect with one another. The interchanges will be located within a high-quality urban environment close to high density district centres and attractive locations encouraging linked trips and improving access to the district centres by public transport.
It will important to ensure that consideration is always given to promoting access beyond the AAP boundary (as currently shown), such as recognising the education/social role that CRC plays in the west, the retail and leisure/recreational/biodiversity roles of Tesco and Milton Country Park in the north, the leisure/recreational/biodiversity role of the river and green corridors in the east, and the existing Cambridge communities in the south.

Question 26: Do you agree that the AAP should be seeking a very low share of journeys to be made by car compared to other more sustainable means like walking, cycling and public transport to and from, and within the area?

We support the concept of encouraging a greater share of non-car modes of travel for NEC, but note that it is a concept that will need to be accepted by all landowners/occupiers in the AAP boundary in order for it to be successfully implemented. This is broadly in accordance with the advice from the Ely to Cambridge Transport Study, and will be further tested in the NEC AAP Transport Assessment work (due to be commissioned).

Question 27: Do you have any comments on the highway 'trip budget' approach, and how we can reduce the need for people to travel to and within the area by car?

We support the principle of a 'trip budget' as there is limited scope for large scale engineering interventions to create more capacity on the road network. However, the trip budget must be carefully considered and tested to ensure that it is both suitable and realistic. Appropriate measures will need to be employed if the trip budget is exceeded. The monitoring process will need to be carefully considered, as various land uses across the AAP site will be allocated a share of the trip budget.

Question 28: Do you agree that car parking associated with new developments should be low, and we should take the opportunity to reduce car parking in existing developments (alongside the other measures to improve access by means other than the car)?

We generally support the concept of encouraging a greater share of non-car modes of travel for NEC. This is broadly in accordance with the advice from the Ely to Cambridge Transport Study, and will be further tested in the NEC AAP Transport Assessment work (due to be commissioned). It is recognised that many existing employment uses, such as those in Cambridge Science Park, St John's Innovation Park and Cambridge Business Park, will have authorised car parking at significantly higher levels than what is now intended for NEC. We would support the Councils working with various landowners in exploring innovative/incentivised ways of reducing car usage from those sites.

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

We support the suggestion of requiring high levels of cycle parking from new developments. This approach will be supported by the new cycling infrastructure that is planned for Cambridge, including the Chisholm Trail and Waterbeach Greenways. Cycling helps support healthy lifestyles, and is a viable means of travelling around a compact city, assuming that safe and convenient routes and secure/covered parking can be provided. New and existing workplaces can be encouraged to provide showers, changing facilities and lockers to encourage staff to cycle into work.

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

Cycling is key to achieving a mode split and demand must be met, and therefore we support the suggestion of innovative solutions to cycle parking. As part of further capacity testing, Masterplanning and detailed design, consideration will be given to innovative storage solutions (using domestic and international examples) that enables cycle parking to be integrated appropriately into the public realm. The concept of micromobility should also be embraced, with provision made for parking dockless bikes to ensure that they are not left in inconsiderate locations such as the footway.

Question 31: What additional factors should we also be considering to encourage cycling use (e.g. requiring new office buildings to include secure cycle parking, shower facilities and lockers)?

New office buildings should include covered, secure cycle storage, showers and lockers. The cycle parking should also be conveniently located at basement/ground floor level or within easy access of lifts capable of transferring bikes between levels. Where possible segregated access for cyclists should be provided to minimise the conflict with pedestrians and vehicles accessing buildings.

Question 32: How do we design and plan for a place that makes the best use of current technologies and is also future proofed to respond to changing technologies over time?

Energy strategies
We will expect development on the Site to have a very low 'in use' energy demand, through robust design of built fabric and services. This will make it easier to meet more of the scheme's energy demand from renewable and low carbon energy sources - and in some case may allow a 'net positive' energy balance to be achieved. Implications for wider energy networks should also be considered, with consideration of energy storage and demand control options at building and community level.

Form and fabric

Development within the Site will be designed, at both masterplan and building scale, to result in minimal energy use through sensitive consideration of site conditions and a robust approach to fabric performance, using passive design strategies to achieve good comfort, day-lighting and air-quality.

Building services

Developments should ensure they build on high quality design of form and fabric by specifying robust and efficient building services. If care has been taken in the design of the built fabric, it should be simpler for efficient building services to meet the needs of those who live and work in a building.

Energy generation and supply

Once the gross energy demand for the proposed development has been reduced through efficient built form and services, it will become possible to evaluate how a greater proportion of its needs can be met through renewable and low carbon energy sources.

Provision for electric charging points for vehicles should be implemented to ensure that both residents and workers have access to electric car charging points. Way-finding points and real time journey time information should be implemented across the Site to ensure people have accurate up to date travel information.

Delivery hubs should be provided on the periphery of the site to intercept large delivery vehicles from accessing the site. This will also help to consolidate deliveries and reduce the need for large vehicles to enter the Site, with smaller electric vehicles providing the final leg of the journey to the front door of the residence or workplace.

Subterranean bins should be provided on the Site to minimise space requirements for waste storage and provide a secure location for the bins.

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

It is considered unlikely that an at grade crossing can be located to link the Science Park with the station due to capacity constraints on Milton Road. A well-designed overpass for pedestrians and cyclists may provide the best option to effectively reduce severance caused by Milton Road and link the station with the Science Park. The journey from the station to the Science Park, will be the last / first mile of commuter journey and micromobility solutions such as dockless e-bikes should be provided to support the movement on this link.

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

The knowledge-based cluster around Cambridge Science Park, St John's Innovation Park, and Cambridge Business Park is internationally recognised, and the significant economic role that it offers to NEC must be fully harnessed to encourage complementary industries (Artificial Intelligence, R+D and laboratories for smaller emerging businesses that need the cluster benefits, maker-space etc) and optimise further employment opportunities. We would therefore expect a range (in terms of use and size) of employment spaces across NEC, including Science, Research & Development and Technology-related employment. However, in advocating innovation throughout NEC, policy limitations should not be imposed that unduly restrict any particular use at this stage.

Question 35: In particular, should the plan require delivery of:
A - a flexible range of unit types and sizes, including for start-ups and Small and Medium Sized Enterprises (SMEs);
B - Specialist uses like commercial laboratory space;
C - hybrid buildings capable of a mix of uses, incorporating offices and manufacturing uses.
D - shared social spaces, for example central hubs, cafes.
E - Others (please specify).

We generally support all of the suggested options at this stage, and would seek inclusion of corporate headquarters within category A. These options should equally be applied to proposals for meanwhile/worthwhile uses, in order to optimise economic development benefits and promote innovation at the earlier stages of the development process for NEC.

Question 36: Which of the following approaches should the AAP take to existing industrial uses in the North East Cambridge area?
A - seek to relocate industrial uses away from the North East Cambridge area?
NEC represents a significant and unique opportunity to create a new and innovative high-density, high quality, mixed use Quarter for Cambridge and its surrounding area. The opportunity is dependent on Housing Infrastructure Funding that will facilitate the relocation of the Water Treatment Works, and optimise the quantum of new housing across the Site. Whilst it is recognised that other, non-residential uses, will also be needed in NEC in order to promote multi-functioning mixed communities and internalised trips, capacity testing and Masterplanning will need to carefully identify what uses (and how much) will be appropriate. Whilst the prospect of utilising some of the Site for industrial use has not, at this stage, been discounted, justification for the need and location of such a use will need to be very carefully considered. A greater understanding of industrial need is therefore required, and in particular how essential it is for certain businesses to be in Cambridge. Consideration should also be given to whether existing businesses are compatible with residential neighbourhoods, as if so, there may be scope to incorporate industrial (i.e. b1c) accommodation within a mixed use development. This might, for instance, include ground floor workshops/maker spaces where noise, odour, other forms of pollution, and type of deliveries will not give rise to unacceptable living conditions for neighbouring properties. For existing businesses where there is not a demonstrable need to be in Cambridge, relocation options outside the NEC should be considered.

B - seek innovative approaches to supporting uses on site as part of a mixed use City District?
See response to A, above.

Question 37: Are there particular uses that should be retained in the area or moved elsewhere?

See response to A, above. The AAP should set out the strategy for determining the needs of individual businesses (and whether there is an operational imperative to be closely related to Cambridge, and how the relocation of existing industrial uses can be appropriately implemented..

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

The residential ambitions and opportunities in NEC (and particularly the Site) will need to be fully understood and embraced in order for the Vision and Objectives of the AAP to be realised. For the high density levels of new housing envisaged, innovation will be essential at all stages and in all forms. Traditional approaches to housing in Cambridge are unlikely to be appropriate. Housing will be made available for a much wider market than might otherwise be expected for a new settlement/strategic urban extension elsewhere in the county (e.g. Northstowe, Waterbeach, Cambourne), including that which is more aligned to smaller household sizes e.g. students, post-graduates, young professionals, and older persons looking to downsize. Where family housing is to be provided, it will require 'smarter-space' solutions to reflect the Site-wide high density approach.
A greater understanding of need and demand, market trends and viability will be needed to define housing requirements for NEC in later stages of the AAP process.

Question 39: Should the AAP seek provision for housing for essential local workers and/or specific housing provided by employers (i.e. tethered accommodation outside of any affordable housing contribution)?

Yes, see response to Question 38.

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

We generally support the suggestion of having a challenging target for the provision of affordable housing. There is a chronic shortfall of affordable housing in South Cambridgeshire and Cambridge City, and the residential growth aspirations of NEC could make a significant contribution in reducing housing shortfall. It is also important to ensure that there are a range of homes of different sizes and tenures to achieve mixed and balanced communities. However, it is also important to ensure that the policy is sufficiently flexible to address viability challenges, and takes a pragmatic approach when recognising how different types of housing are provided and thereafter managed and maintained e.g. less reliance on traditional approaches of 'pepper-potting' etc. There is a significant cost in delivering the level and type of development envisaged and it will be essential to ensure that delivery of the development can be secured on a viable basis. Consideration must also be given to exploring other means of making housing more widely accessible, such as through PRS for instance.

Question 41: Should an element of the affordable housing provision be targeted at essential local workers?

We generally support this suggestion, but a more detailed understanding of housing need and demand in the area, and indeed an understanding of what key employers in the area require, should be undertaking before developing an AAP-specific affordable housing policy.

Question 42: Should the AAP require a proportion of development to provide custom build opportunities?

We generally support this suggestion, but again a greater understanding of demand, need and viability is required. Consideration should be given to examples where successful custom-build housing has been delivered, such as Marmalade Lane, Cambridge's first co-housing community made up of 42 custom build homes.

Question 43: Should the AAP allow a proportion of purpose built HMOs and include policy controls on the clustering of HMOs?

We support the suggestion of creating more shared living and co-living housing opportunities, as these can help improve variety and access to more affordable, good quality accommodation. This type of housing typically incorporates shared services and facilities and can benefit both younger and older aged groups. However, again a greater understanding of demand, need and viability is required.

Question 44: Should the AAP include Private Rented Sector (PRS) as a potential housing option as part of a wider housing mix across the North East Cambridge area?

We generally support this suggestion, as it typically lends itself to earlier delivery, it can be part of an affordable housing mix, and may suit the needs of the adjoining employment base. Similar to HMO's, PRS development needs to be well-managed to integrate successfully. Again a greater understanding of demand, need and viability is required.

Question 45: if PRS is to be supported, what specific policy requirements should we consider putting in place to manage its provision and to ensure it contributes towards creating a mixed and sustainable community?

We would suggest that this needs to be considered in greater detail, including need and demand, management of facilities, services, and amenities should be well defined and required.

Question 46: Should PRS provide an affordable housing contribution?

Subject to viability, policy requirements will need to reflect the distinct economics of this tenure. In most cases (as in London) this is acknowledging that a form of Discounted Market Rent (capped at 80% of Open Market Rents) is most applicable, as this can be managed by a non-Registered Provider and therefore enables tenure blind blocks to be delivered by PRS operators.

Question 47: What 'clawback' mechanisms should be included to secure the value of the affordable housing to meet local needs if the homes are converted to another tenure?

Typically a profit sharing mechanism up to an agreed cap (cap to be reflective of the affordable housing contribution possible for open market sale units - i.e. the value difference between a private for sale scheme at 40% and a PRS scheme at 30%)

Question 48: What would be a suitable period to require the retention of private rented homes in that tenure and what compensation mechanisms are needed if such homes are sold into a different tenure before the end of the period?

We would suggest a period of 15 years with clawback as outlined in Questions 46 and 47. This period is proposed in the London Plan and is generally accepted by institutional investors

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

We consider that this should be agreed with each operator, and should be brief and relevant to planning matters. This could ensure all prospective tenants are offered the option of a three year tenancy.

Question 50: Should the area provide for other forms of specialist housing (including older people, students & travellers), either onsite or through seeking contributions for off-site provision?

We generally support this suggestion, but again a greater understanding of demand, need and viability is required. A comprehensive analysis of the demographic portrait of Cambridge and its surrounding environs over the next 25 years should be undertaken to assess how new policy interventions - such as NEC (intensified housing and employment uses; new housing 'products' to promote affordability and variety), new transport initiatives to improve access to employment, shopping, leisure and recreation etc, may affect demand and supply of different forms of housing for the local population catchment. In terms of 'housing mix', this might then manifest into redefining 'mainstream' housing, to expand into other groups such as students/graduates, first-time buyers, those requiring good quality rental properties, downsizers, elderly care.

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

We generally support this suggestion. This is a standard that ensures appropriate homes are delivered that meet the needs of the occupants. However, there may be some formats where exceptions may be appropriate - for example co-living formats including student and young professional accommodation, housing for 'downsizers' etc. These groups may prefer smaller homes with greater shared space and it may be appropriate to provide for this need in the context of a balanced housing offer. However, in these cases we would expect there to be clear requirements around the nature and quality of shared space. We would also encourage pilot testing (on a smaller scale) of more innovative solutions to housing, which might include other micro-living models that have not yet been used in Cambridge but have proved successful in other UK/international cities.

Question 52: Should the AAP develop space standards for new purpose built HMOs?

All new housing should meet the Technical Housing Standards and offer adequate shared spaces to not only provide adequate space in a HMOs scenario but above all provide homes that are future proofed as people's lifestyle changes and needs such as working from home also emerge. Future-proofed housing is to offer adequate space for a wide range of scenarios, not only HMOs. A specifically-developed space standards for new purpose built HMOs may prove unnecessary or irrelevant if HMOs within the AAP is then not delivered through a purpose-built type. Please see our response to Question 51.

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

We support the principle of ensuring that all homes have adequate and appropriate access to outdoor space and support the aspiration for most homes to have some private outdoor space. We would, at this stage, question whether it is realistic to expect that 100% of dwellings will have direct access to an area of private amenity space, given the quantum of development envisaged and the range of different housing typologies that will be necessary to deliver this quantum. In situations where it isn't appropriate to deliver private outdoor space, convenient access to high quality communal and public spaces would be provided. Ultimately, a flexible approach to residential amenity space must be taken, incorporating elements such as roof gardens and balconies as well as elements such as private gardens.

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

We generally support this suggestion in principle. This standard is meeting Part M of the Building Regulations, however due to the requirements of meeting a higher than normal housing number target on the Site, we require flexibility on how the standard is applied. It is important that the Cambridge Local Plan accessibility standards offers flexibility on how the standards are achieved across the many elements of the new masterplanned scheme. While designing for and incorporating accessibility standards is also accepted as a progressive way to future-proof new housing, it is important the standards do not affect the ability of the scheme to meet the density and the target housing required. Currently the Cambridge Local Plan has adopted the optional standard Part M4(2) and has also adopted M4(3) based on a percentage, which is still higher than the national standards, this may have an adverse impact on our scheme.

Question 55: Do you agree with the range of considerations that the AAP will need to have regard to in planning for new retail and town centre provision in the North East Cambridge area? Are there other important factors we should be considering?

The ambitious intentions for NEC are likely to see the creation of thousands of new homes and intensified employment opportunities forming part of new mixed, balanced and prosperous new communities. This new 'Quarter' will therefore require district and local centres to help support and sustain it. Non-residential uses will help create vitality and vibrancy to NEC.

Question 56: Should the Councils be proposing a more multi-dimensional interpretation of the role of a town centre or high street for the North East Cambridge area, where retail is a key but not solely dominant element?

We generally support this suggestion. We would highlight the importance of seeking innovative, creative and flexible solutions across the Site and this will be applied when considering how a District or Local Centre is planned and delivered. Longer term trends (national, regional and local) relating to retail and leisure uses will need to be carefully considered in arriving at a strategy that will support the long term vitality and vibrancy of NEC.

Question 57: What community facilities are particularly needed in the North East Cambridge area?

Opportunities will exist to provide access to new services and facilities for residents of NEC and existing surrounding local communities. In terms of the latter, where there are higher levels of deprivation, the cost of using new facilities will need to take account of affordability issues to ensure the cost of use is not prohibitive to those on no/low incomes.
Provision will need to be informed by the NEC Community Facilities Audit, whilst also taking account of the growth assumptions of NEC (including sizes and tenures of housing, as this will have potentially very different outcomes on need). Provision of facilities should offer flexibility and multi-functional spaces.

Question 58: It is recognised that maximising the development potential of the North East Cambridge area may require a different approach to meeting the sport and open space needs of the new community. How might this be achieved?

See our response to Question 24. Owing to the ambitious development aspirations of the Site (and NEC) it will be necessary to consider a comprehensive package of solutions (on and off-site) for open space and recreational strategy. This strategy will be complemented by the various improvements to green infrastructure provision in and beyond the AAP boundary, facilitating greater access opportunities by walking and cycling.

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

See our response to Question 24.

Question 60: Should open space provision within the North East Cambridge area seek to provide for the widest variety of everyday structured and unstructured recreational opportunities, including walking, jogging, picnics, formal and informal play, casual sports, games, dog walking and youth recreation?

We generally support this suggestion. It will be important to ensure that all spaces within the Site are fully optimised, and creative/innovative solutions should be considered to allow for flexible/multi-functional uses.

Question 61: Where specific uses are required to provide of open space as part of the development, should the AAP allow for these to be met through multiple shared use (for example school playing fields & playing pitches for the general public)?

See our response to Question 24.

Question 62: Within this overall approach, in particular, which option do you prefer in relation to carbon reduction standards for residential development?
A - a 19% improvement on 2013 Building Regulations (the current Cambridge Local Plan standard); or
B - a requirement for carbon emissions to be reduced by a further 10% through the use of on-site renewable energy (the current South Cambridgeshire Local Plan standard); or
C - a 19% improvement on 2013 Building Regulations plus an additional 10% reduction through the use of on-site renewable energy (combining the current standards in the Local Plans); or
D - consider a higher standard and develop further evidence alongside the new joint Local Plan.

At this stage we support Option D. This is a complex area of policy setting due to the current grid decarbonisation and emerging guidance from different bodies such as the UKGBC task force, and the GLA London Plan. The context of the electricity grid decarbonisation should be considered to ensure that any targets set do not create perverse outcomes in the future over the timescales of the development and should consider the appropriateness of energy efficiency targets as well as carbon targets.

The AAP should aim to be exemplar while also drawing on the most up to date emerging evidence.

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

Yes, we generally support the AAP sustainable design and construction approaches set out. However with regard to water recycling we think that while water recycling can be an important part of reducing water consumption if used inappropriately can be unsustainable. Therefore we would expect a rounded view to be taken as to when it is most appropriate to apply the highest levels of water recycling (as required by the maximum BREEAM credits for water efficiency), including an understanding of maintenance and carbon efficiency.
Question 64: Do you support the proposal for the AAP to be clear that review mechanisms should be built into any planning permissions in order to reflect changes in policy regarding sustainable design and construction standards in local and national policy? What other mechanisms could be used?

Yes we think it is important to recognise that not all future scenarios are foreseeable and that in order to avoid perverse outcomes in future it may be necessary to reappraise the policy requirements so that the most up to date and relevant standards are applied where necessary, reasonable and practicable.

It may also be advisable to follow guidance from notable charities and NGOs (e.g. UKGBC)

Question 65: Do you support the plan requiring delivery of site wide approaches to issues such as energy and water, as well as the use of BREEAM Communities International Technical Standard at the masterplanning stage?

Subject to further Masterplanning, technical assessment and feasibility testing, we generally support the approach to site wide water proposed and support the approach to innovate energy infrastructure such as smart energy grids. We support the view that infrastructure necessary for decentralised energy should be explored early on in consultation with relevant parties and that consideration should be given to a range of technologies and approaches to ensure the approach with the lowest carbon overall can be identified and supported.

We fully support the principles in BREEAM Communities and believe that while certification often brings a certainty of outcomes it does not always. The effective outcomes of applying BREEAM communities at this stage should be subject to further consideration.

Question 66: Are there additional issues we should consider in developing the approach to deliver an exemplar development?

Consideration should be given to the embodied impacts of buildings and infrastructure installed as well as opportunities to support the circular economy. Consideration should also be given to embracing and supporting innovative smart-tech and infra-tech initiatives where feasible and viable to do so.

Question 67: What approach should the AAP take to ensure delivery of a net gain in biodiversity?

In terms of the Site, owing to the on-going uses of land e.g. Water Recycling Centre, driving range, former Park and Ride site, it is considered likely that it will have limited biodiversity value. It will be necessary, at the relevant stage in the process, to carry out site specific investigations on the potential suitability of habitat for protected species, and to consider mitigation where appropriate. If the assumption is correct, it seems reasonable to believe that the Site can deliver net gains in biodiversity. Notwithstanding this, sites within NEC may be asked to consider biodiversity collectively, to show how habitat mosaics and corridors can be delivered on a more strategic basis. In this event, the AAP will need to provide greater clarity on what process is likely to be followed, and how this will be applied to individual development schemes.

Consideration will also need to be given to increasing the amount of tree canopy cover in NEC.

Consideration should be given to where biodiversity enhancements opportunities exist in nearby areas as well so that the best opportunities for linkages beyond the site boundary are identified as well as ensuring the best opportunities locally can be realised if necessary to meet the net gain requirements.

Question 68: Should the AAP require developments in the area to integrate SMART technologies from the outset?

We generally support the suggestion that NEC should seek to integrate SMART technologies from the outset. As we have previously noted, we will seek to encourage innovative, creative and adaptable solutions throughout all elements of development on the Site. It will be important to consider preparation of a digital strategy for NEC, to seek optimum speeds for broadband/fibre, opportunities to integrate SMART technology in homes, businesses and other development around NEC.

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

We support innovation throughout all elements of development on the Site (and indeed NEC). Rather than committing to any specific type of solution at this stage, it will be necessary to understand whether innovative systems used on other sites, such as North West Cambridge, can be applied on the Site.

Question 70: Do you agree that the AAP should prioritise land that can feasibly be developed early? Are there any risks associated with this proposed approach?

The obvious challenge with sites seeking early release/delivery is how they demonstrate that development will not prejudice the wider delivery aspirations of NEC. Where landowners/developers can explain how development can be carried out in a coordinated/comprehensive manner, it seems reasonable to expect that early delivery can be achieved. A coordinated/comprehensive approach must fully ensure that all development complies with s106 tariff/highways trips budgets, in an equitable manner.

As discussed later in Questions 79 and 80, we would encourage a positive policy approach be taken in supporting temporary/meanwhile uses in order to activate the Site in its earlier development phases, and to optimise economic and social benefits in the local area.

Question 71: Should the AAP include a relocation strategy in preference to leaving this to the market to resolve?

The representations of landowners and occupiers will inform the approach. It is considered that the AAP will need to identify and define a strategy for key sites/uses to be relocated, but maintain flexibility for others. Notwithstanding this the NEC has significant potential to deliver economic, social and environmental benefits, and whilst there are a relatively small number of landowners, the strategic opportunities must not be compromised by one or more parties that are unwilling to support the delivery of the NEC. Accordingly, the Councils cannot discount the possibility of using their CPO powers if required.

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

An infrastructure delivery plan should be prepared for the North East Cambridge Area to identify the infrastructure required and the costs associated with those projects, in order to inform discussions on planning obligations. It would be reasonable to expect all development within the area to contribute towards the required infrastructure, where it benefits the AAP area as a whole rather than individual sites/landownerships

Question 73: What approach do you consider the most appropriate basis on which to apportion the cost of the infrastructure requirements arising from different land uses to ensure an equitable outcome?

We consider that this should form part of a specific study that includes, inter alia, the following considerations:
*Identify the infrastructure required across the AAP area that is necessary to delivering the comprehensive vision. This might include key routes, connections, bridges / underpasses, transport, education, energy/utilities, social etc.
*Identify where these are most appropriately located to meet the AAP vision.
*Establish a cost base for these, including appropriate cost of land recognising that in some cases it would be otherwise used for residential or other development
*Establish an appropriate equalisation formula across the AAP, levied on all new development. This could be one or a combination of a tariff per m2, per net acre etc and may be varied by use class.
*Set this out in a policy / legal framework with an appropriate indexing mechanism

Question 74: How should the AAP take into account potential changes over time, both positive and negative, that might affect development viability?

We consider that this should form part of a specific study that includes, inter alia, the following considerations
*ensuring that development continues steadily over potentially a number of economic cycles - this possibility should be acknowledged and planned for at the outset
*Any viability test whereby s106 or AH requirements would be reduced would need to be carefully calibrated to ensure that infrastructure is protected.
*A review mechanism within the S106 Agreement would allow viability to be reassessed if circumstances change.

Question 75: Do you agree with the proposal to require land assembly where it can be demonstrated that this is necessary for delivering the agreed masterplan for the North East Cambridge area and/or the proper planning of development?

Yes. This does not directly affect U+I. Land assembly will help to ensure the delivery of comprehensive redevelopment of NEC.

Question 76: Should the AAP state that the Councils will consider use of their Compulsory Purchase powers? If so, should the AAP also set out the circumstances under which this would appropriate?

The NEC has significant potential to deliver economic, social and environmental benefits, and whilst there are a relatively small number of landowners, the strategic opportunities must not be compromised by one or more parties that are unwilling to support the delivery of the NEC. It therefore seems appropriate for the AAP to specify how the Councils will use their CPO powers if required, and the circumstances for doing so. This will need to include the viability and timescales of pursuing a CPO process.

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

Yes. There are a range of stakeholders and landowners involved in the development at the North East Cambridge area, and the successful delivery of NEC will require a coordinated approach. This will need to consider a range of issues including connectivity, infrastructure locations, parking/trip budget, smart-city coordination, delivery programmes, design principles, energy/utilities and waste etc.

Question 78: Do you agree with the Councils' proposed approach to dealing with planning applications made ahead of the AAP reaching a more formal stage of preparation?

Yes. It is agreed that a coordinated approach is required and decisions on applications should be made against the AAP with appropriate, equitable contributions made.

Question 79: What types of 'meanwhile uses' should the AAP support for the North East Cambridge area?

We would suggest a range of 'meanwhile uses' could be appropriate for NEC, and would not expect policy to impose any particular restriction on types of use. The emphasis should be on promoting innovation and creativity, with meanwhile uses serving to provide early foundations for the new Quarter that will emerge and subsequently replace the meanwhile uses in the coming years. Meanwhile uses could therefore provide start-up/incubator accommodation for emerging/expanding sectors, pop-up/small-scale A class uses, community space to begin community cohesion with surrounding neighbourhoods etc. A positive policy approach to obligations and planning requirements will be needed to encourage temporary/meanwhile activation, helping to avoid onerous situations that might otherwise render creative initiatives unviable.

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

It seems unnecessary to impose a limitation on the scale of a proposed 'meanwhile use', as the purpose of a meanwhile use is, fundamentally, to make optimum use of a site that will otherwise be under-utilised for many years. This can have many short-term economic and social benefits. A policy limitation may stifle innovation and creativity. It is considered likely that many of the meanwhile use proposals will require formal planning consent, which will provide the Local Planning Authority with the ability to control and enforce development that is deemed inappropriate.

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

No. A minimum period should be based on the need and timetable for the permanent development. For the most successful meanwhile initiatives a reasonable period of operation is required in order to recoup the initial capital investment.

Question 82: Should the AAP also include a requirement for 'meanwhile uses' to demonstrate how they will add vibrancy and interest and/or deliver on the wider development outcomes and vision for the North East Cambridge area?

No. 'Meanwhile' uses are temporary in nature and an approach that seeks to make efficient use of land, in a compatible manner with surrounding uses, should be encouraged.

Question 83: What negative or positive impacts might the proposed plans have on residents or visitors to Cambridge with low incomes or who have particular characteristics protected under the Equality Act 2010? (The protected characteristics are age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex, and sexual orientation.)

We strongly support the intention of the Vision for NEC and Objective 5, to ensure social and economic inclusion, and as stated in our response to Question 5, would seek the addition of the word 'culturally' within the Vision i.e. 'North East Cambridge - a socially, culturally, and economically inclusive...'

It is recognised that NEC lies within close proximity of two highly deprived wards in Cambridgeshire, and that regeneration on the scale envisaged will create significant socio-economic opportunities for a wider catchment beyond the AAP boundary. Development on the Site, for instance, will create long term employment across a multitude of sectors and skill ranges, improved connectivity around the NEC and access to new services and facilities. We support the intention of the Councils to undertake a Health Needs and Impact Assessment, across an appropriate study area for the NEC, in order to better understand the challenges and issues faced in neighbouring wards, so as to link into opportunities that will arise in NEC.

As stated within our response to Question 5 we generally support the application of local plan accessibility in the NEC. This standard is meeting Part M of the Building Regulations, however due to the requirements of meeting a higher than normal housing number target on the Site, we require flexibility on how the standard is applied. It is important that the Cambridge Local Plan accessibility standards offers flexibility on how the standards are achieved across the many elements of the new masterplanned scheme. While designing for and incorporating accessibility standards is also accepted as a progressive way to future-proof new housing, it is important the standards do not affect the ability of the scheme to meet the density and the target housing required. Currently the Cambridge Local Plan has adopted the optional standard Part M4(2) and has also adopted M4(3) based on a percentage, which is still higher than the national standards, this may have an adverse impact on our scheme.

Question 84: Do you have any other comments about the North East Cambridge area and/or AAP? Are there other issues and alternatives that the councils should consider? If you wish to make suggestions, please provide your comments.

We would encourage a specific section on education and health provision within the NEC, noting the likelihood that if on-site provision is required, it may require different formats/approaches on how such provision is made i.e. traditional forms of provision in Cambridgeshire are unlikely to be suitable in a high density urban regeneration scheme of this nature.

If off-site provision is considered to be more appropriate, comment should be given on how and where need is expected to be accommodated (for instance it may be more appropriate to extend existing or proposed schools in Cambridge, to create additional Forms of Entry, rather than have a lower number of Forms of Entry on-site that falls below the recommended minimum sizes).

Introduction

Cambridge City Council and South Cambridgeshire District Council is consulting on Issues & Options for the North East Cambridge AAP. The consultation deadline is 25th March 2019. The draft response on behalf of U+I Group PLC ('U+I') is set out below. U+I have been selected by the landowners Anglian Water and Cambridge City Council as Master Developer for land outlined in red in the accompanying Site Plan ('the Site'). It is noted that Cambridge City Council also own other land beyond the Site, which may be the subject of other representations.

The representations contained herein relate primarily to the development intentions for the Site, but also in the context of the wider AAP area (as sites within the AAP boundary are largely intrinsically linked).

Representations

Question 1: Do you agree with changing the name of the plan to the 'North East Cambridge Area Action Plan'?

It is recognised that there is a need for a collective reference for the AAP area. This will provide consistency and clearer definition as the process evolves. Whilst it is inevitable that sub-areas of the AAP will emerge with different branding names and strategies, this will have more relevance to the individual sub-area concerned, in creating identity when publicising forthcoming planning applications through to marketing/sales disposals.

Question 2: Is the proposed boundary the most appropriate one for the AAP?

Generally, we support the proposed boundary for the AAP area. We would, however, make two observations/comments.

Firstly, it seems logical to include the site of Cambridge Regional College ('CRC') within the boundary. It is noted that in paragraph 3.5 comment is made that it is not expected to undergo major change in the way other sites across NEC are. However, CRC considers itself to be 'one of the best Further Education Colleges in the country for 16-18 year old level 3 achievement and a leading apprenticeship provider, with thousands of full time students and apprentices currently in training'. The significant range of vocational courses it offers could be positively utilised to support the long-term construction process around NEC (e.g. architectural technology, mechanical engineering, electrical, carpentry, bricklaying courses and apprenticeships), and then the on-going operational phases of the different sub-areas of NEC (e.g. from courses relating to biological science for industry, laboratory technicians and computing technologies, to business and catering and hospitality). It therefore has the potential to play an important learning and development role in the future NEC area. The built form of the current campus appears to be relatively low density, with large areas of used for surface level car parking. Buildings are predominantly 2-3 storeys in height. With the transformation of NEC, recognising the different approaches to internalised trips/reduced car parking, and taller buildings, it would seem likely that the estate management of CRC might change in the future, and if so, it should be included in the AAP.

Secondly, we would comment that, owing to the nature of NEC, development is likely to be high density, optimising the use of all land to work efficiently and effectively. The strategy for on-site Public Open Space is likely to focus on qualitative provision, than quantitative, with a stronger emphasis on formal recreational and leisure space than informal open space. Access to the latter however, is likely to be facilitated through new and improved connections to the east (potentially including land to the east of the railway line north of Cambridge North Train Station, to the river) and north (potentially including land to the north of the A14, such as Land to the south of Cambridge Road, and land including/extending Milton Country Park) of NEC. We would therefore simply pose the question about whether there is a need to include within the AAP boundary additional land that could provide informal open space, biodiversity and drainage functions, which might otherwise not be achievable within the single control of the NEC boundary. It is considered that land to the north and east of the current AAP boundary would primarily be used to facilitate access to green infrastructure for NEC.

Question 3: In this chapter have we correctly identified the physical characteristics of the North East Cambridge area and its surroundings?

Generally, yes. However, we consider it might be beneficial to include more information about the composition of site areas. For instance, on the employment parks, providing details about site area, total floorspace of buildings on the park (including extant planning consents) and the range of authorised planning uses e.g. % B1a uses, %B1b uses, estimated no. of employees, audit of authorised car parking spaces, audit of public open space (estimated total hectares). This would help to inform a baseline of land use within NEC, and then contribute in developing future strategy e.g. highway trip budget, employment strategy, connectivity and green infrastructure etc.
We would also note that it would be beneficial to have mapping information available relating to the environmental constraints identified e.g. noise, air quality, odour, important habitats.
Finally, it would be beneficial to show the broader extents of key infrastructure for NEC, including the full Chisholm Trail link (connecting NEC to Cambridge City, and the south of Cambridge (Addenbrookes), committed routes for other new cycle, pedestrian and public transport in and around the City, and the proposed Greenways link to Waterbeach).

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

In general, yes. However, we note that there is no reference to Archaeology and Heritage, and would suggest that comment is given about this, even if it is considered that NEC has limited archaeological significance. In terms of heritage, whilst we believe that there are no listed buildings, conservation areas, or other notable heritage constraints within NEC, the intention for taller buildings in NEC will need to be more widely considered in respect of longer-distant views and townscape issues (historic core of Cambridge). Taller buildings may also have potential implications for Air Safeguarding Zones (consultation required with Marshall Airport and the Ministry of Defence on structures over 15m in height), and the Mullard Radio Astronomy Observatory (consultation with the University of Cambridge). We acknowledge that the issue of building heights and taller buildings is likely to be assessed as part of the on-going Landscape Character and Visual Impact Assessment that is being undertaken by Cambridge City Council (it is understood that a 'Stage 1' exercise has already been commissioned), and that the findings are then likely to inform future stages of this AAP process.

We would also suggest consideration be given to the inclusion of Green Belt boundaries around NEC. This will help provide clarity to interested parties that all land envisaged for development and associated physical infrastructure will be accommodated on non-Green Belt land. It will also help to provide reassurance that the development aspirations for NEC will not automatically lead to further development beyond the identified boundaries, unless it is deemed to be 'appropriate development' (i.e. not 'inappropriate' as defined in the National Planning Policy Framework'), or that exceptional circumstances are demonstrated in future Local Plans, or a Very Special Circumstances argument is made to support development via a planning application process. In all cases, strict mechanisms for controlling additional future development beyond NEC will apply.

Reference should also be made to the presence of UKPN's overhead power cables (132KV) that span across the AAP boundary. In terms of ensuring optimum reuse of the Site (and indeed other sites, including Cambridge Science Park), we would support a policy seeking their diversion underground.

Question 5: Do you agree with the proposed Vision for the future of the North East Cambridge area? If not, what might you change?

Yes, we support the proposed Vision for NEC. The addition of the word 'culturally' might benefit this Vision further (in the context of 'North East Cambridge - a socially, culturally, and economically inclusive....)

Question 6: Do you agree with the overarching Objectives? If not, what might you change?

Generally, we support the overarching Objectives. The addition of the words 'Natural Capital' might benefit Objective 7 further (in the context of '...connecting and improving biodiversity to achieve a Natural Capital net gain....)

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

It is noted that the Concept Plan can only be treated as indicative at this stage in the AAP process, until the outcomes of the various Supporting Studies are known (notably Landscape Character and Visual Impact Assessment, Development Capacity Study, NEC AAP Transport Assessment, NEC Development Viability Assessment, NEC Infrastructure Delivery Plan), and wider consultation with relevant interested parties (e.g. landowners, developers, local communities, local authority bodies etc) has been carried out.

We support the residential-led mixed use allocation for the Site. We support the aspiration to create high quality pedestrian, cycle and public transport connectivity across the AAP area. We support the indication that a Mixed Use District Centre will be provided on the Site though we would suggest that its optimal location can only be determined after further study and masterplanning work. There may also be a need to include an additional Mixed Use Local Centre in the northern half of the Site (subject to further Masterplanning and an assessment on accessibility). We support the intention to provide and integrate Green Infrastructure throughout the AAP boundary, but what provision is made (and how/where it will be provided) will need to be determined following further studies/assessment and Masterplanning. Further consideration will need to be given to the suggested Industrial Development Sites in the north east corner of the Site, to understand what the rationale is for proposing to relocate existing industrial land at Nuffield Road and Cowley Road, to another part of the AAP site. It is assumed that the suggestion is made on the basis that it will provide noise abatement from the A14 to the new residential elements of the Site. However, we consider that there may be other more preferable solutions for controlling noise and, in Masterplanning terms it is less desirable bringing industrial-related traffic through a predominantly residential site. In the absence of clear justification for seeking relocation of industrial uses, we cannot support the industrial element of the proposal.

We aren't yet persuaded that the proposed location and quantum of industrial use is optimal. In particular we have concerns that this is currently shown at the furthest point from strategic highway connections. We also believe that different models and formats of industrial development should be further explored, specifically whether this should be concentrated in a single location, or whether it might be incorporated within a mixed-use approach throughout the Site.

We do not necessarily agree that the Site represents the best opportunity with the overall AAP area to accommodate a significant concentration of industrial uses in a single location.

We would suggest that the Cambridge Business Park is shaded as an Opportunity for Employment Intensification.

In addition to our response for Question 2, we would suggest that the CRC land we would suggest that this land is included within the AAP boundary, and that a new shading is applied that refers to an Opportunity for Education Intensification.

Question 8: Do you agree that outside of the existing business areas, the eastern part of the North East Cambridge AAP area (i.e. the area east of Milton Road) should provide a higher density mixed use residential led area with intensified employment, relocation of existing industrial uses and other supporting uses?

Generally, we support the initial development intentions for the area east of Milton Road. It is considered that this area could accommodate a high density mixed use residential-led development following the relocation of the existing Cambridge Water Recycling Centre and other industrial uses (subject to viability and finding suitable relocation site(s)) from the Site. A comprehensive, design-led, approach across the AAP will help maximise the redevelopment potential of a significant brownfield site in a highly sustainable location.

Question 9: Should Nuffield Road Industrial Estate be redeveloped for residential mixed use development?

Yes, we agree that consideration should be given to relocating existing industrial uses on the Nuffield Road Industrial Estate, in preference for higher density residential-led mixed use redevelopment. Consideration should be given to the viability of doing so (industrial land values are currently relatively high), and where existing businesses will be relocated. An Industrial Relocation Strategy might be appropriate, in order to understand what factors are important to businesses e.g. last mile strategies and what alternative sites might be available to accommodate relocation requirements. ]

As outlined in Question 7, the suggestion to relocate industrial uses from Nuffield Road Industrial Estate to the north east corner of the Site needs to be explained and justified. At this stage we do not support the suggestion to relocate industrial uses to the north-east corner of the Site.

Question 10: Do you agree that opportunities should be explored to intensify and diversify existing business areas? If so, with what sort of uses?

Yes, we broadly support this suggestion, subject to the establishment of a robust and equitable approach to Highways Trip Budget apportionment and s106 tariff system across the wider AAP area. The Cambridge Science Park was first established on the principle of accommodating 1-2 storey, low density commercial buildings within an attractive strategic landscape/parkland setting. Whilst much of the strategic landscaping remains, latter phases of the Science Park have sought to intensify development density, with taller buildings, lower car parking provision, and limited on-plot landscaping (other than to lessen/soften the impact of new development). This approach has been complemented by the introduction of Cambridge North Station Interchange, which has significantly improved accessibility via non-car modes. The growth aspirations now anticipated for the AAP area signals a radical change in approach to new development. New residential communities will be supported by existing and intensified employment and educational opportunities, potentially providing live and work/learning opportunities within walking/cycling distance of each other. Furthermore, access to inter alia Cambridge North, the Guided Busway, and the Chisholm Trail will support accessibility to existing business areas from a much wider catchment, therefore helping to improve the means of accessing work without the need to do so by car.

Opportunities to provide a greater quantum and diversity of employment should be encouraged. This will consolidate and strengthen the concept of the Cambridge Phenomenon, by creating a greater range and quantum of high quality accommodation for new businesses, in close proximity to a critical mass of similar businesses, thereby helping to support knowledge sharing and collaboration through co-location.

In order to promote diversity of employment types, planning policy consideration might be given to encouraging a certain percentage of 'affordable employment', to support the growth of new start-up businesses that require the same close links with similar businesses but cannot afford (and do not currently need) accommodation that becomes available.

Question 11: Are there any particular land uses that should be accommodated in the North East Cambridge area?

The North East Cambridge area should support any use that demonstrably contributes to the Vision and Objectives of the AAP area.
The AAP provides a significant opportunity to create thousands of new homes in a highly sustainable location. The growth of housing in this area will be supported by the economic benefits derived from the long-established science, innovation and business parks (many of which will be intensified), that have collectively grown from the success of clustering knowledge-based industries in close proximity of one another. The housing element of the Site will improve supply and affordability of high quality new homes to the many thousands of employees on these parks, helping to reduce the number of car movements on Milton Road. New homes and jobs on the scale envisage will need to be served by a number of social, retail, community, health, education, leisure and recreation facilities,

Question 12: What uses or activities should be included within the North East Cambridge AAP area which will create a district of culture, creativity and interest that will help create a successful community where people will choose to live and work and play?

It is considered that the inclusion of schools, community facilities, retail and leisure uses, open space, and transport services, in conjunction with walking and cycling connections to neighbouring areas will provide the attributes of a successful community.

The NEC AAP must recognise the wider role it plays in creating opportunities for surrounding communities, of which two neighbouring wards - East Chesterton and Kings Hedges - currently suffer from high levels of deprivation (included in the top three of most deprived wards in Cambridgeshire). The benefits of the AAP area should extend to these areas, to create new employment, education, social, leisure and recreation, health and community opportunities. Where new facilities are introduced to areas experiencing deprivation, a key challenge for optimising use of such facilities is affordability. Free or subsidised charging mechanisms should therefore be considered when providing new facilities for instance e.g. hire of sports pitches, meeting rooms etc.

It should, however, be recognised (and indeed it is in Question 79) that the ambitious development aspirations for the Site and wider AAP area will take a number of years to comprehensively plan and deliver. Certain elements will be possible to deliver early. Notwithstanding this, there is the opportunity to introduce 'meanwhile/worthwhile' uses the area as the transition progresses. Meanwhile/worthwhile uses offer creative and innovative ways of optimising sites on a stop-gap basis, creating a temporary opportunity to capture economic and/or social benefits for the wider area in the period between the closure/or reduction of an existing site operation and the commencement of the intended new development.

Question 13: Should the AAP require developments in the North East Cambridge AAP area to apply Healthy Towns principles?

NEC will provide a considerable opportunity for creating a healthy new community, and supporting neighbouring communities, through access to high quality housing, a design approach founded on sustainable modes of travel (walkable neighbourhoods), and improved employment, shopping, health, education, leisure and recreational opportunities. We also support the intended preparation of the Health Impact and Needs Assessment for NEC, which will take account of the wider deprivation challenges faced in the neighbouring wards of East Chesterton and Kings Hedges.

Question 14: How should the AAP recognise and make best use of the existing and potential new links between the AAP area and the CRC (Cambridge Regional College)?

Please see our response to Question 2.

Question 15: Should clusters of taller buildings around areas of high accessibility including district and local centres and transport stops form part of the design-led approach to this new city district?

We strongly support the principle that the greatest development densities should be located in the areas of greatest accessibility and public amenity. This maximises the potential for sustainable travel patterns and establishes a critical weight of local demand for leisure, cultural and retail uses.

It is important to note that 'high-density' does not automatically mean 'tall' and that compact mid-rise development can often be denser than taller development, particular where the latter is compensated for by a smaller overall development footprint. Compact mid-rise also typically enables a wider range of dwelling types and external amenity space, meeting a wider range housing needs.

We favour a 'transect' based approach to masterplanning which will ensure the density, scale, typology, and uses of development are allocated across the site as a whole and within each neighbourhood in a coordinated way, following the accessibility principle described above and responding to the opportunities and constraints of the Site. This may not mean 'clusters' - it could for example mean that the highest densities are located in 'corridors' along the primary streets, and/or at edges where having denser development acts to shelter lower-scale development from adjacent visual or noise intrusion. The masterplan will be backed up by a design code that will identify/mandate appropriate typologies for achieving the requisite densities in ways that are acceptable in other respects.

In addition to accessibility and other local factors, it is important to note that the extent and location of denser development will be affected by a range of detailed studies and appraisals (including Landscape Character and Visual Impact Assessment), that will recognise - and then balance - the challenges of creating areas of higher density and taller buildings in a highly sustainable location that is, nonetheless, on the edge of Cambridge with areas of open countryside beyond. This may also militate against achieving density through height.

Question 16: Should the AAP include any or a combination of the options below to improve pedestrian and cycling connectivity through the site and to the surrounding area?

A - Create a strong east-west axis to unite Cambridge North Station with Cambridge Science Park across Milton Road. This pedestrian and cycle corridor would be integrated into the wider green infrastructure network to create a pleasant and enjoyable route for people to travel through and around the site. The route could also allow other sustainable forms of transport to connect across Milton Road.

Yes. A strong east-west axis should be included to connect the different parts and proposed uses within NEC, and to encourage movement within the site by sustainable modes of transport.

B - Improve north-south movement between the Cowley Road part of the site and Nuffield Road. Through the redevelopment of the Nuffield Road area of NEC, it will be important that new and existing residents have convenient and safe pedestrian and cycle access to the services and facilities that will be provided as part of the wider North East Cambridge area proposals.

Yes.
C - Upgrade connections to Milton Country Park by both foot and cycle. This would include improving access to the Jane Coston Bridge over the A14, the Waterbeach Greenway project including a new access under the A14 (see Transport Chapter), as well as the existing underpass along the river towpath.

Yes. It is considered that improvements to connections with Milton Country Park and with existing and proposed pedestrian and cycle routes will be important for the success of development within the AAP. It is anticipated that NEC will provide a high density residential development, to take advantage of the close proximity of employment areas and public transport services, but which might limit opportunities for large scale open space/recreation areas. Therefore, it will be important to ensure that any proposal for an underpass will maximise connectivity through the Site, capitalising on permeability and wider Green Infrastructure initiatives (e.g. Waterbeach Greenway, Chisholm Trail, improving the public realm function of the 1st Drain etc).

D - Provide another Cambridge Guided Bus stop to serve a new District Centre located to the east side of Milton Road.

We support the suggestion to improve public transport accessibility around NEC but further work should be undertaken to determine whether an additional 'guided' busway stop is required or whether a 'normal' bus service, which could feasibly use the same buses as those on the Busway, could deliver the same benefits.

E - Increase ease of movement across the sites by opening up opportunities to walk and cycle through areas where this is currently difficult, for example Cambridge Business Park and the Cambridge Science Park improving access to the Kings Hedges and East Chesterton areas as well as the City beyond.

We very much support opportunities to increase the ease and convenience of walking and cycling movements across sites in NEC, as this will strengthen the concept of promoting internalised trips and reduce the reliance on travel by car.

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

It is noted that the River Cam towpath is identified as a route within the Waterbeach Greenway project, and it would be appropriate to take the opportunity to provide a pedestrian and cycling connection from this route into NEC, subject to the availability of funding.

The high density redevelopment of NEC is unlikely to achieve the level of Public Open Space that might otherwise be required under local plan policy. The focus is instead likely to be on securing high quality, flexible-use open space on-site, and improving/providing new connections to informal open space networks to the north and east of the AAP area (including the Waterbeach Greenway). Accordingly, an appropriate means of accessing off-site Green Infrastructure for NEC will be required, and the suggestion of a pedestrian/cycle bridge would facilitate this.

Please see our responses to Questions 2 and 7.

Question 18: Which of the following options would best improve connectivity across Milton Road between Cambridge North Station and Cambridge Science Park?
A - One or more new 'green bridges' for pedestrians and cycles could be provided over Milton Road. The bridges could form part of the proposed green infrastructure strategy for NEC, creating a substantial green/ecological link(s) over the road.
B - Subject to viability and feasibility testing, Milton Road could be 'cut-in' or tunnelled below ground in order to create a pedestrian and cycle friendly environment at street level. This option would allow for significant improvements to the street which would be more pleasurable for people to walk and cycle through.
C - Milton Road could be significantly altered to rebalance the road in a way that reduces the dominance of the road, including rationalising (reducing) the number of junctions between the Guided Busway and the A14 as well as prioritising walking, cycling and public transport users.
D - Connectivity across Milton Road could be improved through other measures. We would welcome any other suggestions that would improve the east-west connectivity through the site.
E - Other ways of improving connections (please specify)

In response to all five options listed above, we generally support the principle for securing high quality east-west connectivity. However, the means of crossing Milton Road will involve a range of complex issues, which cannot be determined at this stage. The crossing solution(s) should not ultimately be compromised by concerns about short-term disruption and inconvenience. The east-west axis will be fundamental in the overall success of NEC, and the justification for internalising trips will be partly made on the basis that pedestrian and cycle connectivity across NEC will be safe and convenient (and therefore likely to be commonly used as a means of travel).

Option A is considered to be the preferred option as it provides the opportunity to create a substantial green link over the road without adversely affect the flow of traffic on Milton Road, which has existing network capacity issues. It will also limit the impact on the operation of the Milton Road during construction when compared with either Option B and C.

Option B would likely result in significant disruption to the road network during construction and would likely require the lowering or redirecting or Statutory Undertakers Utilities. Both Option B and C would result in alterations to the access junctions into the Science Park and the Site, both of which have limited access opportunities for their respective sizes.

Question 19: Should development within the North East Cambridge area be more visible from Milton Road, and provide a high quality frontage to help create a new urban character for this area?

We generally support the suggestion of making new development within NEC more visible from Milton Road and providing a high quality frontage to create a new urban character for the area. Milton Road is currently a highly car dominated environment, with a number of confusing junctions serving Cambridge Science Park and Cowley Road. However, it is noted that Milton Road acts as a key north / southbound route into and out of Cambridge, and the Milton Interchange forms part of the Strategic Road Network and connects Cambridge to the A14 (a major east to west route, which has recently been upgraded to improve capacity). Given the level of traffic using this stretch of the Milton Road to access the Strategic Road Network at this location, the potential to reduce traffic to provide a high quality new urban character for the area may be limited in the short term. Notwithstanding this, where Milton Road runs southwards the nature of the road starts to change and becomes more urban in nature, potentially becoming more conducive to active frontage and activity on the footway.

Question 20: Do you agree with proposals to include low levels of parking as part of creating a sustainable new city district focusing on non-car transport?

Yes, we generally support this principle NEC provides an opportunity to reduce levels of parking, as part of a package of transport measures including new and additional walking and cycling routes, public transport services, and car share schemes. However, we would also suggest that interim car parking strategies might need to be considered, to support 'pioneer' uses/development during transitional phases of NEC i.e. until the full package of transport infrastructure and initiatives can be fully realised. As new infrastructure/initiatives are introduced, interim car parking can be gradually phased out.

Question 21a: In order to minimise the number of private motor vehicles using Milton Road, should Cambridge Science Park as well as other existing employment areas in this area have a reduction in car parking provision from current levels?

We very much support opportunities to reduce the reliance on travel by car in and around NEC, and instead increase the ease and convenience of walking and cycling movements across sites in NEC, as this will strengthen the concept of promoting internalised trips.

Question 21b: Should this be extended to introduce the idea of a reduction with a more equitable distribution of car parking across both parts of the AAP area?

Yes, as part of a package of transport measures to encourage travel by sustainable modes of transport.

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

Yes, subject to further understanding of the requirements of businesses and the needs of residents. The North East Cambridge area could include a number of delivery/collection hubs.

Question 23: Should development within the North East Cambridge area use car barns for the storage of vehicles?

We support the idea of using car barns, as part of a wider package of parking solutions across NEC. Whilst it is recognised that private on-plot parking is unlikely to be widely encouraged, there will inevitably be demand from some residents to have access to the use of a car/secure car parking but this should be priced accordingly to the end user. Car barns provide communal access to parking, and are typically located in less convenient locations in order to discourage frequent use. As an example, if a car was needed to do a weekly shop, the resident would park outside their property to unload their car and then move the car to a car barn. Car barns can also be used by 'car clubs', so that a resident can book a car for a certain period of time but not have the long-term cost and use commitment to owning a private car. The versatility of car barns should also be recognised, as parking can be let on a temporary basis and, as trends change, can be converted into alternative uses to reduce car usage further.

Question 24: Within the North East Cambridge area green space can be provided in a number of forms including the following options. Which of the following would you support?
A - Green space within the site could be predominately provided through the introduction of a large multi-functional district scale green space. Taking inspiration from Parker's Piece in Cambridge, a new large space will provide flexible space that can be used throughout the year for a wide range of sport, recreation and leisure activities and include a sustainable drainage function. The sustainable drainage element would link into a system developed around the existing First Public Drain and the drainage system in the Science Park. The green space could be further supported by a number of smaller neighbourhood block scale open spaces dispersed across the site.
B - Green spaces within the site could be provided through a series of green spaces of a neighbourhood scale that will be distributed across the residential areas. These green spaces will also be connected to the green infrastructure network to further encourage walking and cycling. Again, these spaces will include a sustainable drainage function and link into the existing First Public Drain and the Science Park drainage system.
C - Enhanced connections and corridors within and beyond the site to improve the biodiversity and ecological value as well as capturing the essential Cambridge character of green fingers extending into urban areas. These corridors could also be focussed around the green space network and sustainable drainage and would reflect the NPPF net environmental gain requirement.
D - Green fingers to unite both sides of Milton Road and capitalise on the existing green networks.
E - Consideration of the site edges - enhancement of the existing structural edge landscape and creating new structural landscape at strategic points within and on the edge of NEC. This would also enhance the setting to the City on this important approach into the City.
F - Creation of enhanced pedestrian and cycle connectivity to Milton Country Park and the River Cam corridor.

In response to all six options listed above, we support the principle for securing high quality green infrastructure across NEC. Subject to further capacity testing and Masterplanning, on-site provision might feasibly take the form of a larger green space for the whole NEC and complemented by smaller 'neighbourhood scale' spaces and enhanced connections and corridors to off-site green infrastructure. We aren't persuaded that Parkers Piece is an appropriate comparable for the size and function of this space but do consider that the green space should draw lessons from existing green spaces in Cambridge. However, in supporting the theme of innovation at all stages of the development it will be important to consider smart solutions for the open space strategy, maximising flexibility across all areas of on-site open space. For instance, playing fields associated with on-site school provision should be available to the wider community, at times when it is not required by the school. Management and security issues will need to be carefully considered in this regard. Landscape vegetation should encourage biodiversity, whilst also performing softening/screening functions. Formal playspace should be able to accommodate multi-use activities during the day and evening and throughout the year. Green infrastructure might incorporate elements of food growing e.g. fruit trees, herbs, and vegetables, enabling free access to foods that help promote healthier lifestyles.

In terms of the suggestion of how open space will be provided (and in what format and amount), this cannot be determined at this stage of the process. A series of studies and assessments have been or are being commissioned by Cambridge City Council, which will help inform development principles and Masterplanning. Consultation will also need to be carried out with a number of interested parties, including landowners, developers, local communities and local authority bodies. Therefore, we are neither supporting nor objecting to any of the suggested options at this stage.

Question 25: As set out in this chapter there are a range of public transport, cycling and walking schemes planned which will improve access to the North East Cambridge area. What other measures should be explored to improve access to this area?

We generally support the suggested options for improving public transport, cycling and walking accessibility around NEC. The proposed Waterbeach Greenway should be directed through the Site, to create a coherent route from Waterbeach to the station. This will allow future residents of the Site to cycle to the station helping to providing a means of travel for the 'first mile / last mile' of the journey to / from the station.

A new route for a busway from the proposed Waterbeach development should be routed through the Site down to Cambridge North Station. Stops on the route could form transport interchanges linking to other bus routes and cycle routes. High quality cycle links should be implemented to connect into existing infrastructure such as the Chisholm Trail.

The route of these two transport spines through the Site will help develop a single coherent sustainable transport corridor down to the station allowing seamless interchanges between transport modes where the routes intersect with one another. The interchanges will be located within a high-quality urban environment close to high density district centres and attractive locations encouraging linked trips and improving access to the district centres by public transport.
It will important to ensure that consideration is always given to promoting access beyond the AAP boundary (as currently shown), such as recognising the education/social role that CRC plays in the west, the retail and leisure/recreational/biodiversity roles of Tesco and Milton Country Park in the north, the leisure/recreational/biodiversity role of the river and green corridors in the east, and the existing Cambridge communities in the south.

Question 26: Do you agree that the AAP should be seeking a very low share of journeys to be made by car compared to other more sustainable means like walking, cycling and public transport to and from, and within the area?

We support the concept of encouraging a greater share of non-car modes of travel for NEC, but note that it is a concept that will need to be accepted by all landowners/occupiers in the AAP boundary in order for it to be successfully implemented. This is broadly in accordance with the advice from the Ely to Cambridge Transport Study, and will be further tested in the NEC AAP Transport Assessment work (due to be commissioned).

Question 27: Do you have any comments on the highway 'trip budget' approach, and how we can reduce the need for people to travel to and within the area by car?

We support the principle of a 'trip budget' as there is limited scope for large scale engineering interventions to create more capacity on the road network. However, the trip budget must be carefully considered and tested to ensure that it is both suitable and realistic. Appropriate measures will need to be employed if the trip budget is exceeded. The monitoring process will need to be carefully considered, as various land uses across the AAP site will be allocated a share of the trip budget.

Question 28: Do you agree that car parking associated with new developments should be low, and we should take the opportunity to reduce car parking in existing developments (alongside the other measures to improve access by means other than the car)?

We generally support the concept of encouraging a greater share of non-car modes of travel for NEC. This is broadly in accordance with the advice from the Ely to Cambridge Transport Study, and will be further tested in the NEC AAP Transport Assessment work (due to be commissioned). It is recognised that many existing employment uses, such as those in Cambridge Science Park, St John's Innovation Park and Cambridge Business Park, will have authorised car parking at significantly higher levels than what is now intended for NEC. We would support the Councils working with various landowners in exploring innovative/incentivised ways of reducing car usage from those sites.

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

We support the suggestion of requiring high levels of cycle parking from new developments. This approach will be supported by the new cycling infrastructure that is planned for Cambridge, including the Chisholm Trail and Waterbeach Greenways. Cycling helps support healthy lifestyles, and is a viable means of travelling around a compact city, assuming that safe and convenient routes and secure/covered parking can be provided. New and existing workplaces can be encouraged to provide showers, changing facilities and lockers to encourage staff to cycle into work.

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

Cycling is key to achieving a mode split and demand must be met, and therefore we support the suggestion of innovative solutions to cycle parking. As part of further capacity testing, Masterplanning and detailed design, consideration will be given to innovative storage solutions (using domestic and international examples) that enables cycle parking to be integrated appropriately into the public realm. The concept of micromobility should also be embraced, with provision made for parking dockless bikes to ensure that they are not left in inconsiderate locations such as the footway.

Question 31: What additional factors should we also be considering to encourage cycling use (e.g. requiring new office buildings to include secure cycle parking, shower facilities and lockers)?

New office buildings should include covered, secure cycle storage, showers and lockers. The cycle parking should also be conveniently located at basement/ground floor level or within easy access of lifts capable of transferring bikes between levels. Where possible segregated access for cyclists should be provided to minimise the conflict with pedestrians and vehicles accessing buildings.

Question 32: How do we design and plan for a place that makes the best use of current technologies and is also future proofed to respond to changing technologies over time?

Energy strategies
We will expect development on the Site to have a very low 'in use' energy demand, through robust design of built fabric and services. This will make it easier to meet more of the scheme's energy demand from renewable and low carbon energy sources - and in some case may allow a 'net positive' energy balance to be achieved. Implications for wider energy networks should also be considered, with consideration of energy storage and demand control options at building and community level.

Form and fabric

Development within the Site will be designed, at both masterplan and building scale, to result in minimal energy use through sensitive consideration of site conditions and a robust approach to fabric performance, using passive design strategies to achieve good comfort, day-lighting and air-quality.

Building services

Developments should ensure they build on high quality design of form and fabric by specifying robust and efficient building services. If care has been taken in the design of the built fabric, it should be simpler for efficient building services to meet the needs of those who live and work in a building.

Energy generation and supply

Once the gross energy demand for the proposed development has been reduced through efficient built form and services, it will become possible to evaluate how a greater proportion of its needs can be met through renewable and low carbon energy sources.

Provision for electric charging points for vehicles should be implemented to ensure that both residents and workers have access to electric car charging points. Way-finding points and real time journey time information should be implemented across the Site to ensure people have accurate up to date travel information.

Delivery hubs should be provided on the periphery of the site to intercept large delivery vehicles from accessing the site. This will also help to consolidate deliveries and reduce the need for large vehicles to enter the Site, with smaller electric vehicles providing the final leg of the journey to the front door of the residence or workplace.

Subterranean bins should be provided on the Site to minimise space requirements for waste storage and provide a secure location for the bins.

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

It is considered unlikely that an at grade crossing can be located to link the Science Park with the station due to capacity constraints on Milton Road. A well-designed overpass for pedestrians and cyclists may provide the best option to effectively reduce severance caused by Milton Road and link the station with the Science Park. The journey from the station to the Science Park, will be the last / first mile of commuter journey and micromobility solutions such as dockless e-bikes should be provided to support the movement on this link.

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

The knowledge-based cluster around Cambridge Science Park, St John's Innovation Park, and Cambridge Business Park is internationally recognised, and the significant economic role that it offers to NEC must be fully harnessed to encourage complementary industries (Artificial Intelligence, R+D and laboratories for smaller emerging businesses that need the cluster benefits, maker-space etc) and optimise further employment opportunities. We would therefore expect a range (in terms of use and size) of employment spaces across NEC, including Science, Research & Development and Technology-related employment. However, in advocating innovation throughout NEC, policy limitations should not be imposed that unduly restrict any particular use at this stage.

Question 35: In particular, should the plan require delivery of:
A - a flexible range of unit types and sizes, including for start-ups and Small and Medium Sized Enterprises (SMEs);
B - Specialist uses like commercial laboratory space;
C - hybrid buildings capable of a mix of uses, incorporating offices and manufacturing uses.
D - shared social spaces, for example central hubs, cafes.
E - Others (please specify).

We generally support all of the suggested options at this stage, and would seek inclusion of corporate headquarters within category A. These options should equally be applied to proposals for meanwhile/worthwhile uses, in order to optimise economic development benefits and promote innovation at the earlier stages of the development process for NEC.

Question 36: Which of the following approaches should the AAP take to existing industrial uses in the North East Cambridge area?
A - seek to relocate industrial uses away from the North East Cambridge area?
NEC represents a significant and unique opportunity to create a new and innovative high-density, high quality, mixed use Quarter for Cambridge and its surrounding area. The opportunity is dependent on Housing Infrastructure Funding that will facilitate the relocation of the Water Treatment Works, and optimise the quantum of new housing across the Site. Whilst it is recognised that other, non-residential uses, will also be needed in NEC in order to promote multi-functioning mixed communities and internalised trips, capacity testing and Masterplanning will need to carefully identify what uses (and how much) will be appropriate. Whilst the prospect of utilising some of the Site for industrial use has not, at this stage, been discounted, justification for the need and location of such a use will need to be very carefully considered. A greater understanding of industrial need is therefore required, and in particular how essential it is for certain businesses to be in Cambridge. Consideration should also be given to whether existing businesses are compatible with residential neighbourhoods, as if so, there may be scope to incorporate industrial (i.e. b1c) accommodation within a mixed use development. This might, for instance, include ground floor workshops/maker spaces where noise, odour, other forms of pollution, and type of deliveries will not give rise to unacceptable living conditions for neighbouring properties. For existing businesses where there is not a demonstrable need to be in Cambridge, relocation options outside the NEC should be considered.

B - seek innovative approaches to supporting uses on site as part of a mixed use City District?
See response to A, above.

Question 37: Are there particular uses that should be retained in the area or moved elsewhere?

See response to A, above. The AAP should set out the strategy for determining the needs of individual businesses (and whether there is an operational imperative to be closely related to Cambridge, and how the relocation of existing industrial uses can be appropriately implemented..

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

The residential ambitions and opportunities in NEC (and particularly the Site) will need to be fully understood and embraced in order for the Vision and Objectives of the AAP to be realised. For the high density levels of new housing envisaged, innovation will be essential at all stages and in all forms. Traditional approaches to housing in Cambridge are unlikely to be appropriate. Housing will be made available for a much wider market than might otherwise be expected for a new settlement/strategic urban extension elsewhere in the county (e.g. Northstowe, Waterbeach, Cambourne), including that which is more aligned to smaller household sizes e.g. students, post-graduates, young professionals, and older persons looking to downsize. Where family housing is to be provided, it will require 'smarter-space' solutions to reflect the Site-wide high density approach.
A greater understanding of need and demand, market trends and viability will be needed to define housing requirements for NEC in later stages of the AAP process.

Question 39: Should the AAP seek provision for housing for essential local workers and/or specific housing provided by employers (i.e. tethered accommodation outside of any affordable housing contribution)?

Yes, see response to Question 38.

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

We generally support the suggestion of having a challenging target for the provision of affordable housing. There is a chronic shortfall of affordable housing in South Cambridgeshire and Cambridge City, and the residential growth aspirations of NEC could make a significant contribution in reducing housing shortfall. It is also important to ensure that there are a range of homes of different sizes and tenures to achieve mixed and balanced communities. However, it is also important to ensure that the policy is sufficiently flexible to address viability challenges, and takes a pragmatic approach when recognising how different types of housing are provided and thereafter managed and maintained e.g. less reliance on traditional approaches of 'pepper-potting' etc. There is a significant cost in delivering the level and type of development envisaged and it will be essential to ensure that delivery of the development can be secured on a viable basis. Consideration must also be given to exploring other means of making housing more widely accessible, such as through PRS for instance.

Question 41: Should an element of the affordable housing provision be targeted at essential local workers?

We generally support this suggestion, but a more detailed understanding of housing need and demand in the area, and indeed an understanding of what key employers in the area require, should be undertaking before developing an AAP-specific affordable housing policy.

Question 42: Should the AAP require a proportion of development to provide custom build opportunities?

We generally support this suggestion, but again a greater understanding of demand, need and viability is required. Consideration should be given to examples where successful custom-build housing has been delivered, such as Marmalade Lane, Cambridge's first co-housing community made up of 42 custom build homes.

Question 43: Should the AAP allow a proportion of purpose built HMOs and include policy controls on the clustering of HMOs?

We support the suggestion of creating more shared living and co-living housing opportunities, as these can help improve variety and access to more affordable, good quality accommodation. This type of housing typically incorporates shared services and facilities and can benefit both younger and older aged groups. However, again a greater understanding of demand, need and viability is required.

Question 44: Should the AAP include Private Rented Sector (PRS) as a potential housing option as part of a wider housing mix across the North East Cambridge area?

We generally support this suggestion, as it typically lends itself to earlier delivery, it can be part of an affordable housing mix, and may suit the needs of the adjoining employment base. Similar to HMO's, PRS development needs to be well-managed to integrate successfully. Again a greater understanding of demand, need and viability is required.

Question 45: if PRS is to be supported, what specific policy requirements should we consider putting in place to manage its provision and to ensure it contributes towards creating a mixed and sustainable community?

We would suggest that this needs to be considered in greater detail, including need and demand, management of facilities, services, and amenities should be well defined and required.

Question 46: Should PRS provide an affordable housing contribution?

Subject to viability, policy requirements will need to reflect the distinct economics of this tenure. In most cases (as in London) this is acknowledging that a form of Discounted Market Rent (capped at 80% of Open Market Rents) is most applicable, as this can be managed by a non-Registered Provider and therefore enables tenure blind blocks to be delivered by PRS operators.

Question 47: What 'clawback' mechanisms should be included to secure the value of the affordable housing to meet local needs if the homes are converted to another tenure?

Typically a profit sharing mechanism up to an agreed cap (cap to be reflective of the affordable housing contribution possible for open market sale units - i.e. the value difference between a private for sale scheme at 40% and a PRS scheme at 30%)

Question 48: What would be a suitable period to require the retention of private rented homes in that tenure and what compensation mechanisms are needed if such homes are sold into a different tenure before the end of the period?

We would suggest a period of 15 years with clawback as outlined in Questions 46 and 47. This period is proposed in the London Plan and is generally accepted by institutional investors

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

We consider that this should be agreed with each operator, and should be brief and relevant to planning matters. This could ensure all prospective tenants are offered the option of a three year tenancy.

Question 50: Should the area provide for other forms of specialist housing (including older people, students & travellers), either onsite or through seeking contributions for off-site provision?

We generally support this suggestion, but again a greater understanding of demand, need and viability is required. A comprehensive analysis of the demographic portrait of Cambridge and its surrounding environs over the next 25 years should be undertaken to assess how new policy interventions - such as NEC (intensified housing and employment uses; new housing 'products' to promote affordability and variety), new transport initiatives to improve access to employment, shopping, leisure and recreation etc, may affect demand and supply of different forms of housing for the local population catchment. In terms of 'housing mix', this might then manifest into redefining 'mainstream' housing, to expand into other groups such as students/graduates, first-time buyers, those requiring good quality rental properties, downsizers, elderly care.

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

We generally support this suggestion. This is a standard that ensures appropriate homes are delivered that meet the needs of the occupants. However, there may be some formats where exceptions may be appropriate - for example co-living formats including student and young professional accommodation, housing for 'downsizers' etc. These groups may prefer smaller homes with greater shared space and it may be appropriate to provide for this need in the context of a balanced housing offer. However, in these cases we would expect there to be clear requirements around the nature and quality of shared space. We would also encourage pilot testing (on a smaller scale) of more innovative solutions to housing, which might include other micro-living models that have not yet been used in Cambridge but have proved successful in other UK/international cities.

Question 52: Should the AAP develop space standards for new purpose built HMOs?

All new housing should meet the Technical Housing Standards and offer adequate shared spaces to not only provide adequate space in a HMOs scenario but above all provide homes that are future proofed as people's lifestyle changes and needs such as working from home also emerge. Future-proofed housing is to offer adequate space for a wide range of scenarios, not only HMOs. A specifically-developed space standards for new purpose built HMOs may prove unnecessary or irrelevant if HMOs within the AAP is then not delivered through a purpose-built type. Please see our response to Question 51.

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

We support the principle of ensuring that all homes have adequate and appropriate access to outdoor space and support the aspiration for most homes to have some private outdoor space. We would, at this stage, question whether it is realistic to expect that 100% of dwellings will have direct access to an area of private amenity space, given the quantum of development envisaged and the range of different housing typologies that will be necessary to deliver this quantum. In situations where it isn't appropriate to deliver private outdoor space, convenient access to high quality communal and public spaces would be provided. Ultimately, a flexible approach to residential amenity space must be taken, incorporating elements such as roof gardens and balconies as well as elements such as private gardens.

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

We generally support this suggestion in principle. This standard is meeting Part M of the Building Regulations, however due to the requirements of meeting a higher than normal housing number target on the Site, we require flexibility on how the standard is applied. It is important that the Cambridge Local Plan accessibility standards offers flexibility on how the standards are achieved across the many elements of the new masterplanned scheme. While designing for and incorporating accessibility standards is also accepted as a progressive way to future-proof new housing, it is important the standards do not affect the ability of the scheme to meet the density and the target housing required. Currently the Cambridge Local Plan has adopted the optional standard Part M4(2) and has also adopted M4(3) based on a percentage, which is still higher than the national standards, this may have an adverse impact on our scheme.

Question 55: Do you agree with the range of considerations that the AAP will need to have regard to in planning for new retail and town centre provision in the North East Cambridge area? Are there other important factors we should be considering?

The ambitious intentions for NEC are likely to see the creation of thousands of new homes and intensified employment opportunities forming part of new mixed, balanced and prosperous new communities. This new 'Quarter' will therefore require district and local centres to help support and sustain it. Non-residential uses will help create vitality and vibrancy to NEC.

Question 56: Should the Councils be proposing a more multi-dimensional interpretation of the role of a town centre or high street for the North East Cambridge area, where retail is a key but not solely dominant element?

We generally support this suggestion. We would highlight the importance of seeking innovative, creative and flexible solutions across the Site and this will be applied when considering how a District or Local Centre is planned and delivered. Longer term trends (national, regional and local) relating to retail and leisure uses will need to be carefully considered in arriving at a strategy that will support the long term vitality and vibrancy of NEC.

Question 57: What community facilities are particularly needed in the North East Cambridge area?

Opportunities will exist to provide access to new services and facilities for residents of NEC and existing surrounding local communities. In terms of the latter, where there are higher levels of deprivation, the cost of using new facilities will need to take account of affordability issues to ensure the cost of use is not prohibitive to those on no/low incomes.
Provision will need to be informed by the NEC Community Facilities Audit, whilst also taking account of the growth assumptions of NEC (including sizes and tenures of housing, as this will have potentially very different outcomes on need). Provision of facilities should offer flexibility and multi-functional spaces.

Question 58: It is recognised that maximising the development potential of the North East Cambridge area may require a different approach to meeting the sport and open space needs of the new community. How might this be achieved?

See our response to Question 24. Owing to the ambitious development aspirations of the Site (and NEC) it will be necessary to consider a comprehensive package of solutions (on and off-site) for open space and recreational strategy. This strategy will be complemented by the various improvements to green infrastructure provision in and beyond the AAP boundary, facilitating greater access opportunities by walking and cycling.

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

See our response to Question 24.

Question 60: Should open space provision within the North East Cambridge area seek to provide for the widest variety of everyday structured and unstructured recreational opportunities, including walking, jogging, picnics, formal and informal play, casual sports, games, dog walking and youth recreation?

We generally support this suggestion. It will be important to ensure that all spaces within the Site are fully optimised, and creative/innovative solutions should be considered to allow for flexible/multi-functional uses.

Question 61: Where specific uses are required to provide of open space as part of the development, should the AAP allow for these to be met through multiple shared use (for example school playing fields & playing pitches for the general public)?

See our response to Question 24.

Question 62: Within this overall approach, in particular, which option do you prefer in relation to carbon reduction standards for residential development?
A - a 19% improvement on 2013 Building Regulations (the current Cambridge Local Plan standard); or
B - a requirement for carbon emissions to be reduced by a further 10% through the use of on-site renewable energy (the current South Cambridgeshire Local Plan standard); or
C - a 19% improvement on 2013 Building Regulations plus an additional 10% reduction through the use of on-site renewable energy (combining the current standards in the Local Plans); or
D - consider a higher standard and develop further evidence alongside the new joint Local Plan.

At this stage we support Option D. This is a complex area of policy setting due to the current grid decarbonisation and emerging guidance from different bodies such as the UKGBC task force, and the GLA London Plan. The context of the electricity grid decarbonisation should be considered to ensure that any targets set do not create perverse outcomes in the future over the timescales of the development and should consider the appropriateness of energy efficiency targets as well as carbon targets.

The AAP should aim to be exemplar while also drawing on the most up to date emerging evidence.

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

Yes, we generally support the AAP sustainable design and construction approaches set out. However with regard to water recycling we think that while water recycling can be an important part of reducing water consumption if used inappropriately can be unsustainable. Therefore we would expect a rounded view to be taken as to when it is most appropriate to apply the highest levels of water recycling (as required by the maximum BREEAM credits for water efficiency), including an understanding of maintenance and carbon efficiency.
Question 64: Do you support the proposal for the AAP to be clear that review mechanisms should be built into any planning permissions in order to reflect changes in policy regarding sustainable design and construction standards in local and national policy? What other mechanisms could be used?

Yes we think it is important to recognise that not all future scenarios are foreseeable and that in order to avoid perverse outcomes in future it may be necessary to reappraise the policy requirements so that the most up to date and relevant standards are applied where necessary, reasonable and practicable.

It may also be advisable to follow guidance from notable charities and NGOs (e.g. UKGBC)

Question 65: Do you support the plan requiring delivery of site wide approaches to issues such as energy and water, as well as the use of BREEAM Communities International Technical Standard at the masterplanning stage?

Subject to further Masterplanning, technical assessment and feasibility testing, we generally support the approach to site wide water proposed and support the approach to innovate energy infrastructure such as smart energy grids. We support the view that infrastructure necessary for decentralised energy should be explored early on in consultation with relevant parties and that consideration should be given to a range of technologies and approaches to ensure the approach with the lowest carbon overall can be identified and supported.

We fully support the principles in BREEAM Communities and believe that while certification often brings a certainty of outcomes it does not always. The effective outcomes of applying BREEAM communities at this stage should be subject to further consideration.

Question 66: Are there additional issues we should consider in developing the approach to deliver an exemplar development?

Consideration should be given to the embodied impacts of buildings and infrastructure installed as well as opportunities to support the circular economy. Consideration should also be given to embracing and supporting innovative smart-tech and infra-tech initiatives where feasible and viable to do so.

Question 67: What approach should the AAP take to ensure delivery of a net gain in biodiversity?

In terms of the Site, owing to the on-going uses of land e.g. Water Recycling Centre, driving range, former Park and Ride site, it is considered likely that it will have limited biodiversity value. It will be necessary, at the relevant stage in the process, to carry out site specific investigations on the potential suitability of habitat for protected species, and to consider mitigation where appropriate. If the assumption is correct, it seems reasonable to believe that the Site can deliver net gains in biodiversity. Notwithstanding this, sites within NEC may be asked to consider biodiversity collectively, to show how habitat mosaics and corridors can be delivered on a more strategic basis. In this event, the AAP will need to provide greater clarity on what process is likely to be followed, and how this will be applied to individual development schemes.

Consideration will also need to be given to increasing the amount of tree canopy cover in NEC.

Consideration should be given to where biodiversity enhancements opportunities exist in nearby areas as well so that the best opportunities for linkages beyond the site boundary are identified as well as ensuring the best opportunities locally can be realised if necessary to meet the net gain requirements.

Question 68: Should the AAP require developments in the area to integrate SMART technologies from the outset?

We generally support the suggestion that NEC should seek to integrate SMART technologies from the outset. As we have previously noted, we will seek to encourage innovative, creative and adaptable solutions throughout all elements of development on the Site. It will be important to consider preparation of a digital strategy for NEC, to seek optimum speeds for broadband/fibre, opportunities to integrate SMART technology in homes, businesses and other development around NEC.

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

We support innovation throughout all elements of development on the Site (and indeed NEC). Rather than committing to any specific type of solution at this stage, it will be necessary to understand whether innovative systems used on other sites, such as North West Cambridge, can be applied on the Site.

Question 70: Do you agree that the AAP should prioritise land that can feasibly be developed early? Are there any risks associated with this proposed approach?

The obvious challenge with sites seeking early release/delivery is how they demonstrate that development will not prejudice the wider delivery aspirations of NEC. Where landowners/developers can explain how development can be carried out in a coordinated/comprehensive manner, it seems reasonable to expect that early delivery can be achieved. A coordinated/comprehensive approach must fully ensure that all development complies with s106 tariff/highways trips budgets, in an equitable manner.

As discussed later in Questions 79 and 80, we would encourage a positive policy approach be taken in supporting temporary/meanwhile uses in order to activate the Site in its earlier development phases, and to optimise economic and social benefits in the local area.

Question 71: Should the AAP include a relocation strategy in preference to leaving this to the market to resolve?

The representations of landowners and occupiers will inform the approach. It is considered that the AAP will need to identify and define a strategy for key sites/uses to be relocated, but maintain flexibility for others. Notwithstanding this the NEC has significant potential to deliver economic, social and environmental benefits, and whilst there are a relatively small number of landowners, the strategic opportunities must not be compromised by one or more parties that are unwilling to support the delivery of the NEC. Accordingly, the Councils cannot discount the possibility of using their CPO powers if required.

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

An infrastructure delivery plan should be prepared for the North East Cambridge Area to identify the infrastructure required and the costs associated with those projects, in order to inform discussions on planning obligations. It would be reasonable to expect all development within the area to contribute towards the required infrastructure, where it benefits the AAP area as a whole rather than individual sites/landownerships

Question 73: What approach do you consider the most appropriate basis on which to apportion the cost of the infrastructure requirements arising from different land uses to ensure an equitable outcome?

We consider that this should form part of a specific study that includes, inter alia, the following considerations:
*Identify the infrastructure required across the AAP area that is necessary to delivering the comprehensive vision. This might include key routes, connections, bridges / underpasses, transport, education, energy/utilities, social etc.
*Identify where these are most appropriately located to meet the AAP vision.
*Establish a cost base for these, including appropriate cost of land recognising that in some cases it would be otherwise used for residential or other development
*Establish an appropriate equalisation formula across the AAP, levied on all new development. This could be one or a combination of a tariff per m2, per net acre etc and may be varied by use class.
*Set this out in a policy / legal framework with an appropriate indexing mechanism

Question 74: How should the AAP take into account potential changes over time, both positive and negative, that might affect development viability?

We consider that this should form part of a specific study that includes, inter alia, the following considerations
*ensuring that development continues steadily over potentially a number of economic cycles - this possibility should be acknowledged and planned for at the outset
*Any viability test whereby s106 or AH requirements would be reduced would need to be carefully calibrated to ensure that infrastructure is protected.
*A review mechanism within the S106 Agreement would allow viability to be reassessed if circumstances change.

Question 75: Do you agree with the proposal to require land assembly where it can be demonstrated that this is necessary for delivering the agreed masterplan for the North East Cambridge area and/or the proper planning of development?

Yes. This does not directly affect U+I. Land assembly will help to ensure the delivery of comprehensive redevelopment of NEC.

Question 76: Should the AAP state that the Councils will consider use of their Compulsory Purchase powers? If so, should the AAP also set out the circumstances under which this would appropriate?

The NEC has significant potential to deliver economic, social and environmental benefits, and whilst there are a relatively small number of landowners, the strategic opportunities must not be compromised by one or more parties that are unwilling to support the delivery of the NEC. It therefore seems appropriate for the AAP to specify how the Councils will use their CPO powers if required, and the circumstances for doing so. This will need to include the viability and timescales of pursuing a CPO process.

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

Yes. There are a range of stakeholders and landowners involved in the development at the North East Cambridge area, and the successful delivery of NEC will require a coordinated approach. This will need to consider a range of issues including connectivity, infrastructure locations, parking/trip budget, smart-city coordination, delivery programmes, design principles, energy/utilities and waste etc.

Question 78: Do you agree with the Councils' proposed approach to dealing with planning applications made ahead of the AAP reaching a more formal stage of preparation?

Yes. It is agreed that a coordinated approach is required and decisions on applications should be made against the AAP with appropriate, equitable contributions made.

Question 79: What types of 'meanwhile uses' should the AAP support for the North East Cambridge area?

We would suggest a range of 'meanwhile uses' could be appropriate for NEC, and would not expect policy to impose any particular restriction on types of use. The emphasis should be on promoting innovation and creativity, with meanwhile uses serving to provide early foundations for the new Quarter that will emerge and subsequently replace the meanwhile uses in the coming years. Meanwhile uses could therefore provide start-up/incubator accommodation for emerging/expanding sectors, pop-up/small-scale A class uses, community space to begin community cohesion with surrounding neighbourhoods etc. A positive policy approach to obligations and planning requirements will be needed to encourage temporary/meanwhile activation, helping to avoid onerous situations that might otherwise render creative initiatives unviable.

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

It seems unnecessary to impose a limitation on the scale of a proposed 'meanwhile use', as the purpose of a meanwhile use is, fundamentally, to make optimum use of a site that will otherwise be under-utilised for many years. This can have many short-term economic and social benefits. A policy limitation may stifle innovation and creativity. It is considered likely that many of the meanwhile use proposals will require formal planning consent, which will provide the Local Planning Authority with the ability to control and enforce development that is deemed inappropriate.

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

No. A minimum period should be based on the need and timetable for the permanent development. For the most successful meanwhile initiatives a reasonable period of operation is required in order to recoup the initial capital investment.

Question 82: Should the AAP also include a requirement for 'meanwhile uses' to demonstrate how they will add vibrancy and interest and/or deliver on the wider development outcomes and vision for the North East Cambridge area?

No. 'Meanwhile' uses are temporary in nature and an approach that seeks to make efficient use of land, in a compatible manner with surrounding uses, should be encouraged.

Question 83: What negative or positive impacts might the proposed plans have on residents or visitors to Cambridge with low incomes or who have particular characteristics protected under the Equality Act 2010? (The protected characteristics are age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex, and sexual orientation.)

We strongly support the intention of the Vision for NEC and Objective 5, to ensure social and economic inclusion, and as stated in our response to Question 5, would seek the addition of the word 'culturally' within the Vision i.e. 'North East Cambridge - a socially, culturally, and economically inclusive...'

It is recognised that NEC lies within close proximity of two highly deprived wards in Cambridgeshire, and that regeneration on the scale envisaged will create significant socio-economic opportunities for a wider catchment beyond the AAP boundary. Development on the Site, for instance, will create long term employment across a multitude of sectors and skill ranges, improved connectivity around the NEC and access to new services and facilities. We support the intention of the Councils to undertake a Health Needs and Impact Assessment, across an appropriate study area for the NEC, in order to better understand the challenges and issues faced in neighbouring wards, so as to link into opportunities that will arise in NEC.

As stated within our response to Question 5 we generally support the application of local plan accessibility in the NEC. This standard is meeting Part M of the Building Regulations, however due to the requirements of meeting a higher than normal housing number target on the Site, we require flexibility on how the standard is applied. It is important that the Cambridge Local Plan accessibility standards offers flexibility on how the standards are achieved across the many elements of the new masterplanned scheme. While designing for and incorporating accessibility standards is also accepted as a progressive way to future-proof new housing, it is important the standards do not affect the ability of the scheme to meet the density and the target housing required. Currently the Cambridge Local Plan has adopted the optional standard Part M4(2) and has also adopted M4(3) based on a percentage, which is still higher than the national standards, this may have an adverse impact on our scheme.

Question 84: Do you have any other comments about the North East Cambridge area and/or AAP? Are there other issues and alternatives that the councils should consider? If you wish to make suggestions, please provide your comments.

We would encourage a specific section on education and health provision within the NEC, noting the likelihood that if on-site provision is required, it may require different formats/approaches on how such provision is made i.e. traditional forms of provision in Cambridgeshire are unlikely to be suitable in a high density urban regeneration scheme of this nature.

If off-site provision is considered to be more appropriate, comment should be given on how and where need is expected to be accommodated (for instance it may be more appropriate to extend existing or proposed schools in Cambridge, to create additional Forms of Entry, rather than have a lower number of Forms of Entry on-site that falls below the recommended minimum sizes).