Draft North East Cambridge Area Action Plan

Disagree

The degree of innovation in the vision is welcome. • The dense, legalistic and complex documentation is not inviting or readily understandable for the vast majority of people. The vision is also poorly illustrated, requiring the reader to mentally superimpose multiple 2D thematic maps to build a complete picture. When can the public see an interactive 3D rendering of the complete site to give people a clearer understanding of what is proposed? • There is no translation of business/industrial floor space to land area take, making it difficult to assess the true density of the housing proposed. • The use of dwellings per hectare without stating the average occupancy rate also makes it difficult to determine the true living density. Government advice is: “Dwellings per hectare, used in isolation, can encourage particular building forms over others, in ways that may not fully address the range of local housing needs. … It is therefore important to consider how housing needs, local character and appropriate building forms relate to the density measures being used.” https://www.gov.uk/guidance/effective-use-of-land • The boundary of the AAP is somewhat arbitrary. There is no clear justification for excluding Chesterton Fen, which is mooted as a compensatory site for a nature reserve. This development offers a unique, possibly the only, opportunity to invest in Chesterton Fen to address longstanding problems of access and land use. • Given the aspiration for high-density living, it makes little sense to exclude housing from the relatively low-density Science Park. Without housing, the open space in the Science Park will continue to be underused and open spaces to the east of Milton Rd overused. • The proposed local centre at the western end of the Science Park could include a gradual introduction of housing along its southern edge, integrating it into Kings Hedges. • It would also draw people to use the Science Park land more if it included social and cultural amenities, and land was reserved here for a secondary school. This could also help justify investment in a barrier-free pedestrian/cycle link between the two sides of Milton Rd. • Who will be the developer(s)? How will the planning authority ensure that commercial developers do not use viability assessments to reduce commitments agreed in the final action plan for social housing, public amenities and open space? • The draft AAP merely creates a flexible regulatory framework which the market could easily manipulate, with a consequent dilution of the ambitions. We very strongly believe that serious consideration should be given to establishing a special purpose vehicle, perhaps a locally controlled Development Corporation, to ensure that the vision for the area is carried through and properly co-ordinated and funded.

Mostly yes

Improving permeability to the south, through Cambridge Business Park and Nuffield Rd business park, is a welcome and important element of the plan. • A pedestrian/cycle-friendly crossing of Milton Rd is needed, but it is unclear whether a bridge is the answer: the land take will be large to create a comfortable incline at both sides, and sufficient vehicle clearance. More detail of options needs to be examined and discussed. • The proposed cycle/footbridge over the railway to Chesterton Fen should be a road bridge to replace the problematic level crossing on Fen Rd. The latter can then be converted into a cycle/footway underpass, resolving a weak link in the Chisholm Trail (which relies on a small cut-through between Fen Rd and the towpath).

Mostly not

• Industrial units and the aggregates railhead should not be at the heart of the development. It will create a hazardous and unwelcome mix of traffic on the main residential access road. Far better would be to relocate these to the north-east corner of the site and/or create a separate industrial access road alongside the A14 from the north end of Cowley Rd. • If the industrial uses are moved to the north-east corner, then housing currently assigned there can move away from the A14 and enjoy lower noise and air pollution. • Is there a risk that the noise barrier will reflect more sound back towards Milton Country Park?

Mostly not

• Clarity is needed on how the 8,000+ new homes and 20,000 new jobs fit within the envelope of the Local Plans (33,500 new homes and 44,100 new jobs between 2011 and 2031). • The “Preferred approach” in the Skills, Training & Local Employment Topic Paper states, “The North East Cambridge development is likely to bring 10,000 to 15,000 new jobs through a mix of employment opportunities supporting local residents and the Greater Cambridge economy.” So, where does the 20,000 new jobs come from? • Already 15,400 new jobs have been created in Greater Cambridge (ONS data). At least another 34,000 are planned excluding NEC. This estimate includes (see Appendix C for sources): — Biomedical Campus (5,000 estimated of 8,750 expected to be delivered between 2017 and 2031) — North West Cambridge (3,000 in 100,000m2) — West Cambridge (5,000 in 170,000m2) — Wellcome Genome Campus (4,330 in 146,832m2) — Babraham Institute (400 in 10,000m2) — Granta Park (1,700 @ 32.5 m2/person in 55,463m2) — Peterhouse Technology Park (1,900 @ 15m2/person in 28,000m2) — 104–112 Hills Rd, Cambridge (2,500 in 26,674m2) — Northstowe (6,000 – 2020 Economic Development Strategy) — Waterbeach New Town (4,000 @ 10m2 / person in 24,800m2 + 15,000m2) — Huawei, Sawston (350+ in 9,500 m2) • With 20,000 new jobs at NEC, the total projection exceeds 69,000 jobs, compared with 44,100 in the Local Plans. The housing requirement for those jobs is around 55,000, i.e. over 20,000 more than currently planned for. • The 8,350 homes planned for NEC are expected to accommodate about 18,000 people, of whom about 10,500 will be in employment (69.5% of Cambridge residents are aged 16–64, and 83% of them are economically active), some self-employed. The addition of 20,000 new jobs at NEC will therefore create at least 9,500 new jobs for which housing will be required elsewhere. In other words, this development will increase, not decrease overall demand for housing, exacerbating an already acute and worsening housing shortage in Greater Cambridge. • If NEC is to have only a neutral impact on housing demand, the number of new jobs should not exceed 10,500. How many workplaces that equates to must take into account realistic predictions for self-employment, home-working, remote-working, and hot- desking. • Connected to this point, since most housing cannot be delivered until the water treatment plant is decommissioned and there is no such impediment to building most of the new employment places, we recommend phasing the build-out of both employment and housing land parcels to maintain balance in the housing demand.

Mostly not

Retail provision is well defined. • Detail is needed about the outdoor sports and play facilities that will be provided on the sites of the three or four schools. • There needs to be clarity on whether and where a GP surgery and pharmacy will be provided on-site. • The high proportion of flats within the new development is likely to create a higher demand for allotments than the Local Plan standard of 0.4ha/1,000 population. • It is proposed that much of the demand for open space, sporting and other public amenities will be provided off-site. Relatively little provision is being made on-site that will also address deficiencies elsewhere in the city (e.g. swimming pools). This policy has significant implications for the quality of life of current and future residents of the city. There will be transport implications too, as more people will be inclined to drive to amenities that are beyond a comfortable walking distance. Both implications need to be examined fully. • There is a concern that the plans will become overly prescriptive, resulting in a sterile, soulless living environment. The developments around Cambridge station and now emerging at Cambridge North station are examples that must not be repeated here: a meanness of public space, social segregation (in particular the Warren Close triangle), poor functional design, architectural incoherence, and a general lack of human-scale craftsmanship. • Living and working patterns are evolving rapidly. Post-COVID, home-working is likely to remain popular, but there will need to be greatly increased provision for remote-working in serviced offices and multifunctional spaces. It is essential that the Action Plan is contemporary with contemporary social trends and flexible enough to accommodate unforeseen changes over the 20 years of the build-out. • Given the high degree of uncertainty about climate adaptation and social trends over the next few decades, the Action Plan must promote highly adaptable designs of buildings and spaces.

Mostly not

• The 8,000 additional homes proposed is a “minimum”, implying more may be added. • We understand that the Housing Infrastructure Fund grant to enable the relocation of the water treatment plant is conditional on building this quantity of housing. That creates an unwanted pressure that could lead to overdevelopment of this land. • The population of Milton is estimated at a little under 5,000 in approximately 100 hectares, a density of 50 people per hectare. • The land proposed for redevelopment is approximately 84 hectares (excluding Cambridge North station and Milton Rd garage). It is proposed it will accommodate 8,250 dwellings (including beyond the plan period). At the dwelling occupancy rate of East Chesterton, Arbury and King’s Hedges (2.3 people/dwelling – 2011 Census), that would accommodate 19,000 people at a density of 226 per hectare. Once inaccessible and industrial (B2 and B8) land is excluded, the density will be higher still. Camden has a density of 109 people/ha (see Figure 13). How is it plausible to propose double that for NEC? • The justification for building up to 13 storeys “to create a visual focus” is weak. Precedent studies show that 5-6 storey buildings work well as a perimeter ‘mansion block’ with a shared internal garden. 8 storeys should be the absolute maximum. Building higher implies a tower block typology, for which there is no successful precedent in Cambridge. • These building heights will set a precedent for other developments, which are already pushing for heights that are out of keeping with Cambridge’s distinctly urban-rural character. • It is unclear whether any assessment has been made of the impact of proposed building heights on significant views. We have concerns about views from the River Cam floodplain and Fen Ditton, where the topography is flat and buildings of low heights, apart from church spires. The landscape and views are primarily fields and trees but this is being harmed by the Cambridge North Station development currently under construction (7 storeys) – see photographs in Appendix B. For this reason, building heights should be restricted and analysis is required as to where on the site the impact on important views might be greatest – which should influence the location of building heights. • The proposed housing densities were decided pre-COVID-19. The implications of this and future pandemics on longer-term living and working patterns needs to be analysed carefully. If the conclusion is that, for instance, homes need to include space for a home- office and residents need access to more public open space, this must be factored into the design density.

Not at all

• Is it appropriate to use urban design standards of Cambridge city (2.2 ha per 1,000 pop) rather than South Cambridgeshire (3.2 ha/1,000), given this site borders the Green Belt? • The Cambridge City Local Plan open space standards require 2.2 ha/1,000, or around 40 hectares for NEC. If South Cambridgeshire’s open space standard (3.2 ha/1,000 population) were applied, the requirement would be for 59 hectares. • Neither standard includes allowance for the needs of the working population (e.g. during lunch breaks and for post-work socialising). • The Open Space Topic Paper bases most calculations on a population of 16,236, but, in the same document a population of 17,891 in 8,400 homes is given. It seems therefore that all the open spaces calculations need to be uplifted (see Figure 7). • It appears to be largely undecided how the open space requirements will be satisfied. • The AAP proposes just 9.6 hectares as a linear and triangular park (see Figure 6), which will provide less amenity, e.g. to play informal sports, than recreation grounds elsewhere in Cambridge, e.g. Nun’s Way (4.5ha), Coleridge (5ha), Romsey (2.5ha). • In such a dense development there will be a need for a significant large open space, which will not be served by linear and triangular parks. • The needs of teenagers and young adults in particular appear to be poorly served. • Residents in the south-west quadrant of NEC will have poor access to open space. • Where is the evidence that “enhancing” off-site provision of green space, e.g. at Milton Country Park, will increase their capacity sufficiently to accommodate demand from NEC residents without overburdening the local ecology? • It is wholly unjustifiable to count Milton Country Park (approx. 32ha) towards NEC’s open space requirement as it is already frequently at full capacity during busy periods. • The AAP also acknowledges that MCP and other Milton amenities are too remote for use by child residents of NEC: “North of NEC, Milton Country Park and Milton Village have several existing sport and leisure facilities. Whilst access to these facilities will be improved through a new underpass under the A14, these are not considered sufficiently accessible for children to access from NEC.” • Chesterton Fen is ruled out as potential recreational land: “Due to the potential for flooding, the Chesterton Fen area will not be considered as part of any calculation for formal recreational provision.” However, Logan’s Meadow also floods but provides a valuable space for walking and recreation for local residents. Further consideration should be given to whether Chesterton Fen can provide additional recreation space as well as a wetland nature reserve. • If off-site provision is required then, as well as providing new public open space in the surrounding area, consideration could also be given to drawing some existing visitors away from Milton Country Park to other locations, e.g. new Sports Lake Country Park or adding similar amenities, attractions and activities at other country parks in northern Cambridge, in particular at Darwin Green. That could allow MCP to accommodate more people from NEC. • What actions arise from this statement in Policy 8: “For non-strategic open space

Mostly yes

• We believe the policies set out in the AAP are sound and comply with the latest thinking on biodiversity and development. • Ecological disturbance of surrounding areas caused by increased population pressure is mentioned but insufficiently examined in the AAP. • When applying a biodiversity matrix, levels of disturbance increase the amount of compensatory habitat required because existing habitat quality will be reduced by human disturbance. Natural England has developed an alternative measure for situations where there are recognised recreational pressures on designated nature conservation sites: the Suitable Alternative Natural Green Spaces (SANGS) measure suggests that natural greenspaces should be provided at a level of 8ha per 1,000 population. Here, that would entail a new natural green space of at least 10ha. The proposed new nature reserve at Chesterton Fen would be just 26ha. • SANGS includes a range of other recommendations as to the minimum size and characteristics of natural greenspaces for them to effectively act as alternatives to vulnerable nature conservation sites. While this approach was originally developed for internationally important heathland sites, it is starting to be more widely used. • The AAP recommends a S106 agreement to fund the creation of a wetland nature reserve on Chesterton Fen. Is this realistic? How much will the land acquisition and landscaping cost? How much of that could a S106 agreement be expected cover? What additional funding sources will be used? We would prefer to see this area included in the AAP and subject to a local Development Corporation which would have the ability to implement it. • The AAP acknowledges that at least some of the 10% net gain in biodiversity will have to ‘outsourced’, but no further detail is provided.

Mostly not

• The proposed street hierarchy is good, provided it extends to the outer junctions of the development where, in the past, designs have tended to default to maximising capacity and priority for motor vehicles (e.g. Eddington and Darwin Green junctions with Huntingdon Rd and Madingley Rd). • The use of contemporary data on car parking requirements is largely irrelevant to planning a net-zero development, which will require very different styles of living. • 0.5 parking spaces per dwelling implies that private car ownership will continue to be the norm for 50% of resident families, couples and sole occupiers. It equates to approximately 4,000 additional cars in the city, sitting unused for, on average, 96.5% of the time. That is not efficient or sustainable. • Car clubs and pools make more efficient use of far fewer cars. The development should be designed around active, public and shared transport, not private car ownership. • How will a ‘car-barn’ (multi-storey car park) be kept safe and secure? • As both technology, social attitudes and employment practices are all changing rapidly, it is imperative that NEC travel needs and options are reviewed regularly through the development of the action, outline and detailed plans. • There need to be loading bays for deliveries, removals and private un/loading every 40– 50m to ensure adequate availability and to eliminate obstructive parking in the carriageway, or on pavements or cycleways). • Provision of a consolidation hub within the development for business and home deliveries is essential. • Secure lockers, including refrigerated units, are needed within 100m of every front door to facilitate efficient and flexible home deliveries. • Though we applaud and support the ambition of the ‘trip budget’ approach to maintaining current traffic levels, we do not believe its viability has been demonstrated theoretically or practically. • None of the scenarios modelled in the Transport Evidence Base matches what is being proposed in the AAP (see Figure 10). Therefore, evidence is lacking that the ‘trip budget’ approach for redistributing road trip demand is viable in theory. • Setting a ceiling of 4,185 parking spaces for around 32,000 workers (1 space per 7.6 workers) requires an action plan with teeth. Yet there appear to be no practical measures proposed for how to force existing sites to reduce parking provision and car trips, yet alone at a faster rate than new homes and offices create additional demand. • The “if possible” qualification in the strategy (see Figure 11) is potentially fatal. What happens if existing occupiers of the science and business parks find that removing parking spaces hurts their ability to recruit? If that gives rise to resistance to continuing the phase-out or, worse, a demand to reinstate parking, where does that leave the viability of the unbuilt parts of NEC? • It would be wholly unacceptable for parking to be relocated, say, to an expanded Milton P&R, or some other location in the green belt.

Neutral

• Is BREEAM Excellent sufficiently ambitious and compliant with realistic carbon budgeting? • With considerable research going into materials and construction techniques to reduce the carbon footprints of construction and operation of buildings, this needs to be reviewed regularly as the action plan evolves into detailed plans. • Is the resilience level adequate given the accelerating frequency of exceptional storms, floods, heatwaves and droughts? • Is the target consumption of 80 litres/person/day of treated water sufficiently ambitious? Can more be done to enable use of rainwater and greywater for non-drinking use? • Who will be responsible for drawing up and delivering the site-wide energy masterplan? • Even without the effects of climate change, the cumulative additional demand for water at this and developments already underway will far exceed the supply available from existing aquifers. The viability of this development depends, amongst other things, on ng committed to develop sufficient new water sources.