Draft North East Cambridge Area Action Plan

South Cambridgeshire District Council Cambourne Business Park Our ref: PL00545646 Cambourne Cambridge Cambridgeshire CB23 6EA Our ref: 29 September 2020 Dear Greater Cambridge Shared Planning Team North East Cambridge Area Action Plan – Reg 18 Draft Consultation 2020 Thank you for your consultation in respect of the above document. 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. Our detailed comments are listed in the attached document, Appendix A. Our two key areas of concern relate to firstly the density and heights of development within the site and the potential impact of that upon the historic environment, and secondly the lack of a policy for the historic environment in the Plan. a) Building heights, densities and setting in relation to the historic environment We welcome the on-going work you are undertaking in relation to building heights, densities and setting in relation to the historic environment. As you know, we are very concerned about the current building heights and densities being proposed within this area as part of the Area Action Plan and the potential impact upon heritage assets and the wider historic setting of the City. We are also concerned that decisions regarding height and density are evidence-based and informed by the evidence, not simply justified by retrospective evidence. We look forward to continuing to work with you on this aspect of the Plan. b) Lack of policy for the historic environment Whilst we appreciate that the historic environment is addressed to some degree in the design and heights policies, it is our view that the Plan would benefit from a specific policy for the historic environment. Fuller discussion of this is provided in Appendix A but in essence, we consider that there is also a case for a specific historic environment policy to address this particular strategic site. The policy should cover nearby heritage assets and the need to conserve and where appropriate enhance these, discuss the wider setting of the historic city and should make clear 3004 p Historic England NIA Historic England, Brooklands, 24 Brooklands Avenue, Cambridge CB2 8BU Telephone 01223 58 2749 HistoricEngland.org.uk Please note that Historic England operates an access to information policy. Correspondence or information which you send us may therefore become publicly available. the approach to archaeology within the site (we suggest further discussion with the County Council in this regard). Finally, we should like to stress that this opinion is based on the information provided by the Council in its consultation. To avoid any doubt, this does not affect our obligation to provide further advice and, potentially, object to specific proposals, which may subsequently arise where we consider that these would have an adverse effect upon the historic environment. If you have any questions with regards to the comments made then please do get back to me. In the meantime we look forward to continuing to work with you and your colleagues. Debbie Mack Historic Environment Planning Adviser

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Support/Object/Comment: Object Comments: We welcome the regeneration of this area of Cambridge and recognise the exciting opportunity that this brings to develop a modern and distinctive new community for the city. We welcome the aspirations to create a real sense of place and also to firmly integrate the area within the surrounding communities. There is however no mention of the historic environment and the importance of drawing on, reflecting, protecting and enhancing that through new development. Please amend to include reference to that in your vision. Suggested Change: We suggest that you amend the vision to include reference to the historic environment and the importance of drawing on, reflecting, protecting and enhancing that through new development.

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Comment: Is it worth including provision for places of worship?

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Object: We continue to be concerned about the sheer scale of residential and employment growth on the site and the capacity of the site to absorb such growth as an appropriate density for the City and its setting (more on this in question 6) Suggested Change: We look forward to continuing to work with you regarding densities, heights, scale and massing on this site. We look forward to seeing the report that you are commissioning in this regard.

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Comment: Is it worth including provision for places of worship?

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Object: We welcome the on-going work you are undertaking in relation to building heights, densities and setting in relation to the historic environment. As you know, we are very concerned about the current building heights and densities being proposed within this area as part of the Area Action Plan. We are also concerned that decisions regarding height and density are evidence-based and informed by the evidence, not simply justified by retrospective evidence. We look forward to continuing to work with you on this aspect of the Plan. Suggested Change: We look forward to continuing to work with you regarding densities, heights, scale and massing on this site. We look forward to seeing the report that you are commissioning in this regard.

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Object: We suggest that it might be appropriate to include planting/landscaping along the western edge of Chesterton Fen to soften the edge of the railway and built for of the development in views across the river and from the Fen Ditton Conservation Area, as well as softening the edge of the city and its overall setting. Suggested Change: Include planting along the western edge of Chesterton Fen to soften the edge of the railway and built development.

36 Strategic Objectives: Object There is still nothing within the strategic objectives about the importance of the historic environment and in particular that development of this area protects and enhances the wider setting of the city of Cambridge as well as responding to individual heritage assets such as the conservation areas etc. Please include reference to this in your objectives Suggested Change: Include reference to the historic environment in the objectives, in particular, the need to protect and enhance the wider setting of the city of Cambridge as well as responding to individual heritage assets such as the nearby conservation areas etc.

39 Figure 10: Support We welcome the landscape buffer shown on figure 10 along the edge of Chesterton Fen. We consider this important in softening the edge of the built development and protecting the setting of the City more generally.

48 Figure 13: Object A small point but increased floor to ceiling heights will inevitably increase overall building height. We need to be careful about how building heights are expressed in terms of storeys or metres as clearly floor to ceiling heights will have a bearing on this. This will need to be factored into any work on taller buildings and heritage currently being undertaken. Suggested Change: Factor in ceiling heights in work on taller buildings and heritage impact