Greater Cambridge Local Plan Issues & Options 2020

Opening Comments: Thank you for consulting Historic England on the Greater Cambridge Local Plan Issues and Options stage and Sustainability Appraisal Scoping. As the Government’s adviser on the historic environment, Historic England is keen to ensure that the protection of the historic environment is fully taken into account at all stages and levels of the local planning process. Therefore we welcome the opportunity to comment on the Issues and Options consultation and Call for Sites. Further Guidance on Local Plans and the Historic Environment We have produced a number of detailed Good Practice Advice and Advice Note documents. We recommend that you review the following as part of your plan preparation process: The Historic Environment in Local Plan - Good Practice Advice in Planning 1 https://historicengland.org.uk/images-books/publications/gpa1-historic-environmentlocal-plans/ The Setting of Heritage Assets 2nd ed. - Good Practice Advice in Planning 3 https://historicengland.org.uk/images-books/publications/gpa3-setting-of-heritageassets/ The Historic Environment and Site Allocations and Local Plans - Advice Note 3 https://historicengland.org.uk/images-books/publications/historic-environment-andsite-allocations-in-local-plans/

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Question 2: Please submit any sites for employment and housing you wish to suggest for allocation in the Local Plan. Provide as much information and supporting evidence as possible. Q2 response: Whilst Historic England does not advocate particular sites, we can provide advice on how to take account of the historic environment as you evaluate submissions and sites brought forward from elsewhere. Site Allocations Historic England advocates a wide definition of the historic environment which includes not only those areas and buildings with statutory designated protection but also those which are locally valued and important, as well as the landscape and townscape components of the historic environment. The importance and extent of below ground archaeology is often unknown, although information in the Historic Environment Record (HER) will indicate areas of known interest, or high potential where further assessment is required before decisions or allocations are made. Conservation and archaeology staff within the relevant councils should be consulted on matters relating to archaeology, landscape/townscape and the historic environment generally. Assessing sites Our advice note 3 on site allocations in local plans sets out a suggested approach to assessing sites and their impact on heritage assets. It advocates a number of steps, including understanding what contribution a site, in its current form, makes to the significance of the heritage asset/s, and identifying what impact the allocation might have on significance. This could be applied to the assessment and selecting of sites within a plan. In essence, it is important that you: a) Identify any heritage assets that may be affected by the potential site allocation. b) Understand what contribution the site makes to the significance of the asset c) Identify what impact the allocation might have on that significance d) Consider maximising enhancements and avoiding harm e) Determine whether the proposed allocation is appropriate in light of the NPPFs tests of soundness In assessing sites it is important to identify those sites which are inappropriate for development and also to assess the potential capacity of the site in the light of any historic environment (and other) factors. This should be more than a distance based criteria but rather a more holistic process which seeks to understand their significance and value including setting. Whilst a useful starting point, a focus on distance or visibility alone as a gauge is not appropriate. If a site is allocated, we would expect to see reference in the policy and supporting text to the need to conserve and seek opportunities to enhance the on-site or nearby heritage assets and their setting, the need for high quality design and any other factors relevant to the historic environment and the site in question. Site allocations which include a heritage asset (for example a site within a Conservation Area) may offer opportunities for enhancement and tackling heritage at risk. Paragraph16 of the National Planning Framework requires Local Plans to ‘contain policies that are clearly written and unambiguous, so it is evident how a decision maker should react to development proposals’. Planning Practice Guidance states, ‘Where sites are proposed for allocation, sufficient detail should be given to provide clarity to developers, local communities and other interested parties about the nature and scale of development’ (PPG Paragraph: 027 Reference ID: 61-02720180913Revision date: 13 09 2018). Protection and enhancement of the historic environment is part of the environment objective of the planning system (Paragraph 8 of the NPPF) and Local Plans should set out a positive strategy in this respect (Paragraph 185). General comments on policy wording for site allocations It is important that policies include sufficient information regarding criteria for development. Paragraph 16d of the NPPF states that policies should provide a clear indication of how a decision maker should react to a development proposal. To that end we make the following suggestions for consideration when drafting site allocation policies. a) The policy and supporting text should refer to the designated assets and their settings both on site and nearby. By using the word ‘including’ this avoids the risk of missing any assets off the list. b) The policy should use the appropriate wording from the list below depending on the type of asset e.g. conservation area or listed building or combination of heritage assets c) The policy and supporting text should refer to specific appropriate mitigation measures e.g. landscaping or careful design or maintaining key views or buffer/set back/breathing space etc. d) The NPPF is very clear on the importance of setting of all assets – further advice about settings is given in our advice note and also in the PPG. However, settings are not protected in and of themselves. It is the harm to significance that may be caused by development within the setting of an asset which is key. Try to work this into the policy or at least supporting text. e) The NPPF uses the words ‘conserve and enhance’ and ‘sustain and enhance’. f) PPG explains in more detail what is meant by conservation and enhancement of the historic environment. Here the wording is ‘conserved and where appropriate enhanced. g) The NPPF is newer than the legislation. h) Local Plans need to be consistent with the policies in the Framework Where a site has the potential to affect a heritage asset, we would expect to see the following typical wording within the policy: combination of heritage assets - ‘Development should conserve/sustain or where appropriate enhance the significance of heritage assets (noting that significance may be harmed by development within the setting of an asset).’ This is based on the wording in the NPPF and Planning Practice Guidance Paragraph: 002 Reference ID: 18a-002-20190723 Revision date: 23 07 2019 listed building ‘Development should preserve the significance of the listed building (noting that significance may be harmed by development within the setting of an asset).’. This is based on the wording in Part 1, Chapter 1, paragraph 1 (3) (b) of the Planning (Listed Buildings and Conservation Areas) Act 1990. conservation area ‘Development should preserve, or where opportunities arise, enhance the character or appearance of the Conservation Area and its setting’. This is based on the wording in Part 2, paragraph 69 (a) of the Planning (Listed Buildings and Conservation Areas) Act 1990 and paragraph 200 of the NPPF. Note that if you refer to character …appearance, use the word ‘or’ not ‘and’ registered park and garden - ‘Development should conserve or enhance the significance of the registered park and garden assets (noting that significance may be harmed by development within the setting of an asset).’ scheduled monument ‘Development should conserve or enhance the significance of the scheduled monument (noting that significance may be harmed by development within the setting of an asset).’ Or instead of the words in brackets you could add the following sentence ‘This includes any contribution made to its significance by its setting.’

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3.4 How we are developing the Plan? 3.4.1 Gathering the Evidence We note the wide range of evidence based documents that you are proposing as part of the plan preparation process Green Belt Evidence We note the commitment to prepare evidence in relation the green belt. One of the five purposes of the Green Belt is to preserve the setting and special character of historic towns. Historic towns and former towns are situated across the region and should form a consideration in any review of Green Belt. Without an appreciation of the history of the region’s historic settlements and their close relationship to their surrounding landscapes, it is not possible to properly ascribe a value to the openness of the Green Belt land around them. Consideration of the value of the Green Belt requires understanding the historic significance of this open landscape and how this contributes to the significance of the historic environment. Whilst Green Belt reviews often divide the area into parcels of land to make the assessment exercise manageable, parcels should not be solely reviewed individually within their immediate context. It also is important to understand how collectively they achieve the strategic aims of the Green Belt. We consider the question of the Green Belt in more detail under question 39, including whether a further review and/or additional evidence in needed. Historic Environment Evidence Any evidence base should be proportionate. However, with a local plan we would expect to see a comprehensive and robust evidence base for the historic environment. Sources include: National Heritage List for England. www.historicengland.org.uk/the-list/ Heritage Gateway. www.heritagegateway.org.uk Historic Environment Record. National and local heritage at risk registers. www.historicengland.org.uk/advice/heritage-at-risk Non-designated or locally listed heritage assets (buildings, monuments, parks and gardens, areas) Conservation area appraisals and management plans Historic characterisation assessments e.g. the Extensive Urban Surveys and Historic Landscape Characterisation Programme or more local documents. www.archaeologydataservice.ac.uk/archives/view/EUS/ Whilst there is some landscape character assessment of the area we understand that there is a lack of Historic Landscape Characterisation for the county of Cambridgeshire. Ideally this work would be completed to inform the decisions regarding development in the area. We recommend early discussion with the County Council and MHCLG in this regard. Environmental capacity studies for historic towns and cities or for historic areas e.g. the Craven Conservation Areas Assessment Project. www.cravendc.gov.uk/CHttpHandler.ashx?id=11207&p=0 Detailed historic characterisation work assessing impact of specific proposals. Heritage Impact Assessments looking into significance and setting – more on this below. Visual impact assessments. Archaeological assessment Topic papers - We advocate the preparation of a Historic Environment topic paper in which you can catalogue the evidence you have gathered and to show how that has translated into the policy choices you have made. Do this from the start, as a working document, that you add to throughout the plan preparation process, not just before EiP. This should form part of the evidence base for your Plan. Heritage Impact Assessment In order to help refine which growth allocations to take forward, we would suggest that a Heritage Impact Assessment is undertaken of each of these sites. We would refer you to our Advice Note 3 ‘The Historic Environment and Site Allocations in Local Plans. All potential sites will need to be appraised against potential historic environment impacts. It is imperative to have this robust evidence base in place to ensure the soundness of the Plan. We recommend that the appraisal approach should avoid merely limiting assessment of impact on a heritage asset to its distance from, or intervisibility with, a potential site. Site allocations which include a heritage asset (for example a site within a Conservation Area) may offer opportunities for enhancement and tackling heritage at risk, while conversely, an allocation at a considerable distance away from a heritage asset may cause harm to its significance, rendering the site unsuitable. Cumulative effects of site options on the historic environment should be considered too. The following broad steps might be of assistance in terms of assessing sites: • Identify the heritage assets on or within the vicinity of the potential site allocation at an appropriate scale • Assess the contribution of the site to the significance of heritage assets on or within its vicinity • Identify the potential impacts of development upon the significance of heritage asset • Consider how any harm might be removed or reduced, including reasonable alternatives sites • Consider how any enhancements could be achieved and maximised • Consider and set out the public benefits where harm cannot be removed or reduced The HIAs should assess the suitability of each area for development and the impact on the historic environment. Should the HIA conclude that development in the area could be acceptable and the site be allocated, the findings of the HIA should inform the Local Plan policy including development criteria and a strategy diagram which expresses the development criteria in diagrammatic form. Tall Buildings evidence We also consider that it would be helpful to undertake a tall buildings study to update the evidence base and contribute towards the development of an appropriate tall buildings policy for the Plan. We broadly welcome policy 60 and Appendix F of the 2018 Cambridge City Local Plan. However, we consider that this could be further supplemented to indicate which areas may or may not be suited to taller buildings. Our advice note in relation to tall buildings provides further guidance in this respect We have been having discussions with the team preparing The North East Area Action Plan in relation to tall buildings studies and have provided a detailed advice letter in that regard. We suggest that the work for the North East Area Action Plan in relation to taller buildings is consistent with and co-ordinated with that for the Plan area as a whole. Please refer to our advice letters in relation to NEA Action Plan and tall buildings for further information on our position.

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About Greater Cambridge We welcome the references to the vision for Cambridge being a ‘compact, dynamic city, located within the high-quality landscape setting provided by the Cambridge Green Belt. The city has an iconic historic core, heritage assets, river and structural green corridors, with generous, accessible and biodiverse open spaces and well-designed architecture. South Cambridgeshire’s villagesvary greatly in size, with each having a unique character.’ It is crucial that plans for the future development of Cambridge ensure that the city remains compact, and the setting of the city within a high quality landscape is retained by the Cambridge Green Belt. The iconic historic core, heritage assets and the river and structural green corridors (wedges and fingers) are intrinsic to the distinct quality of the City. The unique character, based on the individual settlement morphology, place within the landscape and individual heritage must also be maintained. Cambridge City Council Vision We broadly welcome the Cambridge City Council vision for the area and references for the historic iconic core although we recognise the heritage is not just confined to the core of the city. The wider setting of the city within the landscape is an important consideration in planning for future development. We suggest that this is included in a revised vision. South Cambridgeshire District Council Vision Although many of the aims and objectives within the vision are laudable, there is no mention of the historic environment. This is a disappointing omission. The historic environment of the district is one of the aspects of the district that makes it such a great place to live and work, and yet without suitable protection and enhancement and a recognition of the role of the unique heritage of the district in shaping existing settlement pattern and form as well as future growth this represents a striking omission. We suggest that this is included in a revised vision. Local Plan Vision We strongly suggest that any vision for the Plan itself recognises not only the importance of the historic environment in the Core of Cambridge but also throughout the two districts. The Plan should describe the historic environment of all of the Plan area and capture what is special and distinctive about each part of the area as well as highlighting the importance of the wider setting of the City.

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Agree

When considering proposed development close to the boundaries of the Local Plan area, it is important to consider impacts on the areas beyond the planning boundaries. For example, in relation to heritage assets, the impact of development upon heritage assets and their settings across the Local Plan boundary should be considered. Regarding the North Uttlesford Garden Community you will now be aware of the Inspector’s letter to the Uttlesford District Council dated 10th January which places the future of the NUGC into question.

Agree

We broadly welcome the Big Themes for the Local Plan being Climate Change, Biodiversity and Green Spaces, well-being and social inclusion and Great Places. We assume that the consideration of the historic environment falls within the Great Places broad theme although we would like to see specific reference to the historic environment udder this heading. Are there other themes or issues we should be considering that could inform our new vision for Greater Cambridge? See above comment regarding the historic environment.

Great Places, Biodiversity and Green Spaces, Climate Change, Wellbeing and Social Inclusion

It is difficult to prioritise or rank these themes as all are important, but given the primary role of the Local Plan as a land use planning tool, we have placed Great Places first. However, we acknowledge that many of these themes are inter-related and depend on one another.

Yes, strongly agree. In designing new development there is an opportunity to secure high standards for climate adaptation and resilience features. Historic England is broadly supportive of the goal to achieve net zero carbon by 2020. A sustainable approach should secure a balance between the benefits that such development delivers and the environmental costs it incurs. The policy should seek to limit and mitigate any such cost to the historic environment. We invite a specific policy relating to the inclusion of renewable technologies within Conservation Areas and with regard to historic buildings and the wider historic landscape. Listed buildings, buildings in conservation areas and scheduled monuments are exempted from the need to comply with energy efficiency requirements of the Building Regulations where compliance would unacceptably alter their character and appearance. Special considerations under Part L are also given to locally listed buildings, buildings of architectural and historic interest within registered parks and gardens and the curtilages of scheduled monuments, and buildings of traditional construction with permeable fabric that both absorbs and readily allows the evaporation of moisture. In developing policy covering this area you may find the Historic England guidance Energy Efficiency and Historic Buildings – Application of Part L of the Building Regulations to historically and traditionally constructed buildings https://content.historicengland.org.uk/images-books/publications/energy-efficiencyhistoric-buildings-ptl/heag014-energy-efficiency-partlL.pdf/ to be helpful in understanding these special considerations. We invite a specific policy relating to the inclusion of renewable technologies within Conservation Areas and with regard to historic buildings and the wider historic landscape. A sustainable approach should secure a balance between the benefits that such development delivers and the environmental costs it incurs. The policy should seek to limit and mitigate any such cost to the historic environment. Listed buildings, buildings in conservation areas and scheduled monuments are exempted from the need to comply with energy efficiency requirements of the Building Regulations where compliance would unacceptably alter their character and appearance. Special considerations under Part L are also given to locally listed buildings, buildings of architectural and historic interest within registered parks and gardens and the curtilages of scheduled monuments, and buildings of traditional construction with permeable fabric that both absorbs and readily allows the evaporation of moisture. In developing policy covering this area you may find the Historic England guidance Energy Efficiency and Historic Buildings – Application of Part L of the Building Regulations to historically and traditionally constructed buildings https://content.historicengland.org.uk/images-books/publications/energy-efficiencyhistoric-buildings-ptl/heag014-energy-efficiency-partlL.pdf/ to be helpful in understanding these special considerations.

Yes, strongly agree. In designing new development there is an opportunity to secure high standards for climate adaptation and resilience features. Historic England is broadly supportive of the goal to achieve net zero carbon by 2020. A sustainable approach should secure a balance between the benefits that such development delivers and the environmental costs it incurs. The policy should seek to limit and mitigate any such cost to the historic environment. We invite a specific policy relating to the inclusion of renewable technologies within Conservation Areas and with regard to historic buildings and the wider historic landscape. Listed buildings, buildings in conservation areas and scheduled monuments are exempted from the need to comply with energy efficiency requirements of the Building Regulations where compliance would unacceptably alter their character and appearance. Special considerations under Part L are also given to locally listed buildings, buildings of architectural and historic interest within registered parks and gardens and the curtilages of scheduled monuments, and buildings of traditional construction with permeable fabric that both absorbs and readily allows the evaporation of moisture. In developing policy covering this area you may find the Historic England guidance Energy Efficiency and Historic Buildings – Application of Part L of the Building Regulations to historically and traditionally constructed buildings https://content.historicengland.org.uk/images-books/publications/energy-efficiencyhistoric-buildings-ptl/heag014-energy-efficiency-partlL.pdf/ to be helpful in understanding these special considerations. We invite a specific policy relating to the inclusion of renewable technologies within Conservation Areas and with regard to historic buildings and the wider historic landscape. A sustainable approach should secure a balance between the benefits that such development delivers and the environmental costs it incurs. The policy should seek to limit and mitigate any such cost to the historic environment. Listed buildings, buildings in conservation areas and scheduled monuments are exempted from the need to comply with energy efficiency requirements of the Building Regulations where compliance would unacceptably alter their character and appearance. Special considerations under Part L are also given to locally listed buildings, buildings of architectural and historic interest within registered parks and gardens and the curtilages of scheduled monuments, and buildings of traditional construction with permeable fabric that both absorbs and readily allows the evaporation of moisture. In developing policy covering this area you may find the Historic England guidance Energy Efficiency and Historic Buildings – Application of Part L of the Building Regulations to historically and traditionally constructed buildings https://content.historicengland.org.uk/images-books/publications/energy-efficiencyhistoric-buildings-ptl/heag014-energy-efficiency-partlL.pdf/ to be helpful in understanding these special considerations.

Yes, strongly agree

Yes, strongly agree. In designing new development there is an opportunity to secure high standards for climate adaptation and resilience features. Historic England is broadly supportive of the goal to achieve net zero carbon by 2020. A sustainable approach should secure a balance between the benefits that such development delivers and the environmental costs it incurs. The policy should seek to limit and mitigate any such cost to the historic environment. We invite a specific policy relating to the inclusion of renewable technologies within Conservation Areas and with regard to historic buildings and the wider historic landscape. Listed buildings, buildings in conservation areas and scheduled monuments are exempted from the need to comply with energy efficiency requirements of the Building Regulations where compliance would unacceptably alter their character and appearance. Special considerations under Part L are also given to locally listed buildings, buildings of architectural and historic interest within registered parks and gardens and the curtilages of scheduled monuments, and buildings of traditional construction with permeable fabric that both absorbs and readily allows the evaporation of moisture. In developing policy covering this area you may find the Historic England guidance Energy Efficiency and Historic Buildings – Application of Part L of the Building Regulations to historically and traditionally constructed buildings https://content.historicengland.org.uk/images-books/publications/energy-efficiencyhistoric-buildings-ptl/heag014-energy-efficiency-partlL.pdf/ to be helpful in understanding these special considerations. We invite a specific policy relating to the inclusion of renewable technologies within Conservation Areas and with regard to historic buildings and the wider historic landscape. A sustainable approach should secure a balance between the benefits that such development delivers and the environmental costs it incurs. The policy should seek to limit and mitigate any such cost to the historic environment. Listed buildings, buildings in conservation areas and scheduled monuments are exempted from the need to comply with energy efficiency requirements of the Building Regulations where compliance would unacceptably alter their character and appearance. Special considerations under Part L are also given to locally listed buildings, buildings of architectural and historic interest within registered parks and gardens and the curtilages of scheduled monuments, and buildings of traditional construction with permeable fabric that both absorbs and readily allows the evaporation of moisture. In developing policy covering this area you may find the Historic England guidance Energy Efficiency and Historic Buildings – Application of Part L of the Building Regulations to historically and traditionally constructed buildings https://content.historicengland.org.uk/images-books/publications/energy-efficiencyhistoric-buildings-ptl/heag014-energy-efficiency-partlL.pdf/ to be helpful in understanding these special considerations.