Draft North East Cambridge Area Action Plan

As an overarching position, Trinity College Cambridge and Cambridge Science Park are supportive of the proposed vision for North East Cambridge set out within the Regulation 18 Area Action Plan (NECAAP) and its aspirations for an inclusive, walkable, low-carbon new city district with a mix of homes, workplaces, services and social spaces which is fully integrated with the surrounding neighbourhood. TCC fully support the North East Cambridge Area Action Plan’s placemaking strategy which is to be guided by the following principles: • To create a sense of place; • To deliver a significant number of new homes, range of jobs and supporting facilities; • To respond to climate and biodiversity through a net zero carbon approach; • To create a place designed for a healthy and safe community, and • To be planned around sustainable transport modes first, discouraging car use in order to address climate change. As one of the principle landowners within the NECAAP, TCC have engaged with the Greater Cambridge Shared Planning Service Team during the preparation of the Regulation 18 document. The comments set out within this response are informed by those discussions and in direct response to the material now published for consultation. This document provides a composite version of all responses by TCC to the Greater Cambridge North East Cambridge Area Action Plan (Regulation 18:) consultation. Appended to this response are the following supporting documents: • Economic Analysis – Volterra (September 2020) • Transport Topic Paper Review – Vectos (September 2020) • Response to the North East Cambridge Area Action Plan Transport Evidence Base - Vectos (May 2020) The Context - Cambridge Science Park and Cambridge Science Park North Section 2 of the NECAAP Regulation 18 document sets out the context for the area but fails to recognise the importance of Cambridge Science Park. The context includes no reference to the historic economic importance of CSP, nor reference to the type of Research and Development which is undertaken within the AAP area and the importance of this existing employment land to the Cambridge and UK economy. The adopted South Cambridgeshire Local Plan, 2018 recognises this1 and it is therefore disappointing that the NECAAP which covers a much smaller area does not. Moreover figure 1 represents an unhelpful and simply false figure of ‘4,400 unused car parking spaces on Cambridge Science Park’. This is an incredibly disappointing inclusion within the draft document, and unfortunately sets the tone for a document which misses the local, regional and national significance of CSP and the asset this presents to the vision for the NEC AAP wider area. The following provides important context for the team preparing this document. Cambridge Science Park Trinity College established the Cambridge Science Park in 1970 in response to recommendations by Harold Wilson’s Labour government that UK universities should form better links with the emerging “white-hot” hi-tech industries. In 1969 at the University of Cambridge, Cavendish Professor Sir Neville Mott and his committee produced a report recommending an expansion of science-based industry close to the city that would enable companies to collaborate with the nearby concentration of world-leading academic scientific expertise. Trinity College and its Senior Bursar, Sir John Bradfield, were impressed with this idea and began masterminding a development scheme for a plot of land to the north of the city which the College had owned since the 1500s. Planning permission was granted one year later, and the first tenant, Laser-Scan, a spin-out from the Cavendish Laboratory, took occupation of its 10,000 sq. ft premises in 1973. Today the Park comprises 58 buildings set in 152 acres of landscaped parkland and is home to over 130 companies employing almost 7,500 people. Whilst the College has retained the freehold of the estate, approximately 56% of the land has been let on long leases (excluding areas of public realm). In terms of economic interests, the split is approximately 37% Trinity and 63% long leaseholders. With its links to the University of Cambridge, prestigious owner and 50-year track record of success, the Park enjoys an enviable reputation as one of the leading Science Parks in the world. One of the Park’s key differentiators when compared to other science and technology Parks is the diversity of its occupiers in terms of sector, size, nationality and age. Diversity is important because scientific disciplines that were once separate and distinct are now converging. Rather than build in-house capabilities beyond their core area of expertise, companies are sourcing innovation from businesses with complementary competencies. Proximity to relevant scientific expertise is therefore an important factor in a company’s choice of location. Increasingly, science-based companies want to be part of a dynamic, multi-sectoral “ecosystem”. The Cambridge Science Park offers this level of diversity and therefore provides unrivalled opportunities for companies to form cross-sector collaborations. Given the importance of CSP as one of the world’s most prestigious science parks which sits right at the heart of one of the UK’s fastest growing economies it is extremely disappointing that the NEC AAP fails to reference either the history of, or the ongoing economic importance of CSP. From its inception, Cambridge Science Park has played a pivotal role in championing innovation and supporting the ‘knowledge economy’ that the region has become so famous for. This established park is recognised as a leading technology hub, with a thriving tenant base. The NEC AAP fails to recognise the value of CSP to the AAP area or the Cambridge economy as an existing asset to the area. In summary, support is given to proposals for an inclusive, walkable, low-carbon new city district with a lively mix of homes, workplaces, services, and social spaces, fully integrated with surrounding neighbourhoods. However, the draft NECAAP fails to recognise the value of CSP to the AAP area or the Cambridge economy as an existing asset to the area. The overall approach to mobility outlined in the NECAAP, focusing and prioritising walking and cycling in additional to shared travel opportunities is supported. TCC does not support the strategic route illustrated within the NECAAP through the centre of the CSP. The inner ring road within CSP can be modified to provide enhanced facilities for pedestrians and cyclists including the provision of a fully segregated cycle route. TCC strongly objects to the wording within Policy 17: … Unless more detailed design can prove the feasibility of a street level crossing of Milton Road, this crossing is likely to be a bridge. This is unsupported by any evidence and as yet uncosted therefore at this stage this statement cannot hold any weight. TCC supports the NECAAP’s identification of local, neighbourhood and district ‘centres’ within the NECAAP area. However, CSP is not the location for a consolidation centre, TCC would suggest this can be better accommodated within land to the north of the A14 – enabling deliveries to be made from this consolidation centre to hubs located within the entire NECAAP area via cycles, electric vehicles, automated pods or vehicles and drones. There should perhaps be more of a focus on homes rather than jobs in the NEC area. Compared against the combined targets for housing and employment delivery over the period 2011 to 2031 across Cambridge and South Cambridgeshire the 20,000 new jobs would amount to 45% of the total employment growth targeted for both local authorities combined over the plan periods. In contrast, the 8,000 new homes targeted for the NEC would only deliver 24% of the combined housing target for the local authorities, highlighting the clear bias towards employment in the area when compared to residential need. This imbalance also results in a deficit on site of open space and biodiversity provision, off-site improvements to which are focussed to the north and east, turning their back on the identified areas that would benefit from additional resource to the south west. Finally with regard to the private car, first and foremost Trinity College Cambridge and Cambridge Science Park have committed to and begun implementing measures aimed at reducing the modal split away from the use of the private car as the primary means of accessing CSP. We have previously responded to the 2019 Transport Assessment and include within this response our response to the Transport Topic Paper. TCC and CSP take issue against the false premise contained with the draft NECAAP which refers to prolific and unconstrained car parking at CSP. This statement as a particularly unhelpful, and frankly false inclusion within a document that also refers to 4,400 ‘unused car parking spaces on Cambridge Science Park’ (another unevidenced and incorrect statement). Given the document contains both unsubstantiated comments it is unclear whether the document seeks to claim there is prolific, unconstrained car parking, or whether there are 4,400 unused spaces. Neither statement is true. On the 20th December 2019 a Section 106 agreement was signed by South Cambridgeshire District Council, Cambridge City Council, Cambridgeshire County Council and Trinity College Cambridge with regard to Cambridge Science Park agreeing to the implementation of a Parking Management Strategy for the entire CSP area. This agreement committed CSP to limit the total number of parking spaces within the site to 7,498 and to use reduce this to 6,977 by the December 2029. The S106 Agreement sets out the complex leaseholder arrangements within CSP, and the commitment to remove and reduce parking spaces from tenancies and lettings as leases either expire or are renewed. The commitment to achieve this is there. However, in order to achieve this step-change a commitment is needed via a package of measures required to facilitate non-car access to this key employment destination. Vectos have produced a note setting out how CSP can support the measures set out within the 2019 Transport Assessment, and we believe CSPN has to be viewed as an important part of the solution. To conclude therefore, whilst the principle of the draft NECAAP is supported, the balance between the provision of homes and office space is questioned. Finally, there remain key questions relating to the open space and biodiversity provision and the transport solutions required to enable any homes to be built in this location. Key areas which CSPN can help to achieve. Given the latest adoption of the LDS considers the opportunity to link delivery of the new Local Plan and the NECAAP, it would seem sensible at this stage to consider the potential for a wider area to deliver the crucial infrastructure required to enable the development of this new neighbourhood and deliver much needed HIF funded homes in this location

Agree

Trinity College Cambridge support the general strategic principles for the NECAAP. Support is given to proposals for an inclusive, walkable, low-carbon new city district with a lively mix of homes, workplaces, services, and social spaces, fully integrated with surrounding neighbourhoods. Indeed, the prospect of an exciting new urban quarter immediately adjacent to CSP is welcomed and wholeheartedly supported. The environmental and social sustainability focus of the proposed big themes is commended. The delivery of a significant number of homes is also of paramount importance in a time of national housing need. The policy commitment to delivering 40% of all net additional units as affordable housing is supported. This is especially important in Cambridge and South Cambridgeshire with private housing being significantly more expensive than that of the national average. In addition, the NECAAP should recognise, develop, and enhance the successful knowledge-based economy based within and surrounding Greater Cambridge. It is crucial that the plan tackles strategic scale thinking to enable plan led economic growth. Having one of the region’s most significant employment sites on the NECAAP’s doorstep is a substantial benefit for those who will live in the emerging NECAAP area. Ensuring strong connections between the NECAAP area, Cambridge Science Park and Cambridge Science Park North is therefore of paramount importance. Whilst the overarching principles set out within the NECAAP are supported, at this stage the policy provision within the NECAAP needs to be refined in order to achieve this vision.

Mostly yes

The overall approach to mobility outlined in the NECAAP, focusing and prioritising walking and cycling in additional to shared travel opportunities is supported. The shift from a predict and provide approach towards a vision and validate approach is something we advocate. This will help direct investment towards local living and active and shared travel opportunities. The approach will help a move away from investment in infrastructure that prioritises and encourages car use which historically has occurred due to the focus on forecast based evidence. Through the discussions on the NECAAP Action Plan Evidence Base (September 2019) and resultant implications for the NECAAP area it has become increasingly apparent that there is a requirement for a strategic approach to deliver the step change in modal shift required to facilitate development within the NECAAP area. In terms of walking and cycling the NECAAP proposes the measures shown in Figure 5. The commitment to prioritising walking and cycling over vehicular traffic should be taken through to the assessment stage. Any benefits in this regard should not be viewed negatively should they result in increased journey times for those travelling in vehicles. Such an approach will truly prioritise walking and cycling. Protecting the status quo for vehicles may act as a constraint to the delivery of walking and cycling measures. Strategic walking and cycling routes TCC does not support the strategic route illustrated within the NECAAP through the centre of the CSP. The masterplan for CSP preserves this route as a tranquil area for leisure and wandering. Indeed Figure 19 and Policy 8 within the Draft NECAAP refer to the value of the open space provided within Cambridge Science Park. Research by Strava in 2014 revealed that cycle commuters in Cambridgeshire are the fastest in the UK logging an average speed of 26kmh (16.1 mph); as an average speed the implication would be that much higher speeds need to be accounted for. Commuting cyclists therefore need their own route which is not at odds with the purpose of open space. The current route as illustrated by Figure 36 in the draft NECAAP would potentially frustrate and disincentivise commuting cyclists and put the enjoyment and safety of users of the open space at odds. The inner ring road within CSP can be modified to provide enhanced facilities for pedestrians and cyclists including the provision of a fully segregated cycle route. This should be reflected in the figure as the strategic cycling route (see figure 6). Cycling & Connections TCC agree that cycle parking provision in excess of Local Plan requirements are likely to be needed. Clarity is needed over the following statement where it is not clear how the level of cycle parking will directly demonstrate conformity with the trip budget. ‘Applicants will need to demonstrate that they have fully considered the appropriate levels to provide cycle parking within the Design and Access Statement and Travel Plan that accompany their planning applications to demonstrate that they will meet the trip budget’. The acknowledgement that electric cycles or ebikes can enable greater travel and commuting distances is welcomed. This should be recognised by the approving authorities when considering trip attraction and generation within Transport Assessments. The reach of cyclising as a mode of travel can be expanded beyond ‘standard’ distances. The reference to Cambridge City Council’s Cycle Parking Guide for New Residential Developments needs to be reviewed where this document does not provide guidance on the full range of matters provided in the policy. Notwithstanding this, to deliver a new district of the scale proposed an implementable package of measures are required. The role of Cambridge Science Park together with Cambridge Science Park North (detailed later in this document), as an extension to the existing Cambridge Science Park offers a solution which incorporates both existing and proposed public transport infrastructure to intercept car movements and further promote the use of sustainable transport modes, including walking and cycling. Moreover, our proposals seek to provide a step change in the use of private vehicles to access employment destinations within the NECAAP area. Our proposals provide a consolidated location for parking which is linked to a mobility hub providing pedestrian, cycle, PLEV, shuttle and sustainable mass transit facilities for onward travel. Milton Road Crossing: There is nothing presented within the evidence base at this stage to suggest that the crossing of Milton Road needs to be via a bridge. There does not appear to be any clearly identified reason why grade separation is preferred. Indeed, this approach is also at odds with the principles for at-grade crossings of Milton Road at the busway detailed elsewhere in the NECAAP. The busway link is the most critical route for movements between CRC / CSP and Cambridge North Station. It is not clear why at-grade crossings are acceptable at this location, but grade separation is identified further north. TCC has significant concerns that once appropriate clearance heights to a bridge and, gradients and ramp lengths for users are accounted for, the provision of a bridge is likely to be unfeasible. At-grade crossing facilities are generally preferable to grade separation. The requirement to funnel people towards the end of the ramp has the clear potential to take people away from their desire line. People will continue to cross Milton Road at-grade. There is also a wider consistency point for this crossing. Elsewhere in the NECAAP and other supporting documents, the relative roles of grade or at-grade seem to be presented in absolute terms. A more balanced consideration of the crossing type should be considered in this section of the policy. TCC strongly objects to the wording within Policy 17: … Unless more detailed design can prove the feasibility of a street level crossing of Milton Road, this crossing is likely to be a bridge. It needs to be acknowledged that the ability to cross at-grade already exists. This will be improved through the implementation of CSP committed development and can be improved even further, especially for cyclists. We maintain that the case for grade separation is unproven, has not been costed and is potentially detrimental to the movement of people, reinforcing the barrier effect of Milton Road and placing people below vehicles in the road user’s hierarchy. The Internalisation Topic Paper referred to as providing part of the evidence base sets out that the feature to address at Milton Road would be ‘At grade (at street level) or grade separated (e.g. bridge or under-pass) facilities for pedestrians and cyclists to cross the Milton Road.. Grade separation cannot be seen to be prioritising walking and cycling over vehicle movements in using 1950’s style methods to sperate vehicles, pedestrians and cyclists. Quite the opposite. TCC strongly agree with the statement ‘the policy approach focuses on reducing the need to travel and facilitating travel by non-car modes rather than catering for vehicular trips’. These measures begin to provide additional certainty to the narrative of supporting the existing employment sites through the provision of improved sustainable transport measures. However, what is also not clear at present is the timescales and deliverability of these measures

Mostly yes

TCC supports the NECAAP’s identification of local, neighbourhood and district ‘centres’ within the NECAAP area. It is crucial that appropriate supporting uses for CSP are supported in the NECAAP as the key employment location in the NECAAP area. In accordance with the NPPF3 the planning system should actively manage patterns of growth focusing significant development in locations which are sustainable, limiting the need to travel and offer a genuine choice of transport modes. TCC are committed to maintaining and enhancing the existing Cambridge Science Park whilst transforming a parcel of agricultural land adjacent to the Cambridge Science Park into a worldleading centre of excellence in skilled manufacturing and development. TCC commends the Council having identified the need for a consolidation hub for last mile deliveries. TCC would like it on record that such a hub should not be proposed in the Cambridge Science Park local centre, as such an allocation would be disruptive and detrimental to the significant number employees of the science park and the tranquil world class environment they work in. CSPN, however, provides opportunity for this, providing a link from the A14 that would reduce trips on Milton Road. The provision of direct cycle and busway links to the wider area will mean that deliveries by way of cycles, electric vehicles, automated pods or vehicles and drones is realistic and deliverable. Intercepting deliveries outside the NECAAP area, to no detriment to surrounding residential properties must be a more sustainable option, rather than funnelling these movements onto Kings Hedges Road. These points are further emphasised in the Policy which states: ‘A hub has been identified within Cambridge Science Park Local Centre, as set out in Policy 10c. An additional hub could be located close to Milton Road where it can be accessed directly from the primary street to reduce vehicle movements within the Area Action Plan area’. The references to congestion and no opportunity to increase capacity further provides additional examples of why the Trip Budget incorrectly focuses upon the peak hour. Deliveries are examples of movements that generally take place outside of peak periods where capacity pressures on networks such as the highway network for vehicular traffic is much less. ‘Unconstrained deliveries direct to business premises and properties is, with the growth in e-commerce, likely to generate many trips and exceed the trip budget’. Notwithstanding this, the role that a consolidation centre can play in the overall strategy is supported and can be delivered by CSPN. ‘Consideration should be given to co-locating the hub with other active uses, such as shops and other services and facilities’. We consider a primary mobility Hub to be an ideal partner to a consolidation centre. Close to remote consolidated parking, storage of parcels and the like for staff members would provide a location for collection in addition to the consolidation of delivery.

Nothing chosen

In order to fully answer this question, please read this section alongside the supplemental full response prepared by Volterra. The overarching vision set out for North East Cambridge includes the following principles (among others): ‘have a real sense of place’, ‘firmly integrated with surrounding communities’, ‘provide a significant number of new homes, a range of jobs for all’, ‘planned around walking, cycling and public transport, discouraging car use’. Implicit to the success of achieving these principles is the range and mix of uses proposed, and the balance between those proposed uses. The vision includes plans for an additional 8,000 new homes, with 40% being affordable, the baseline position includes just 3 homes currently on site. Alongside 8,000 new homes, there are plans for an additional 20,000 new jobs within the area on top of the 15,000 existing jobs currently provided within CSP, the existing business parks and on the industrial estates. This presents a high likelihood of creating an imbalance of jobs relative to working residents within the NECAAP area. In order to ascertain whether this would create an imbalance more widely, it is necessary to consider firstly the need for both homes and jobs, and secondly how this very localised area interacts with the wider area around it. How balanced is the wider Cambridge and South Cambridgeshire area? Cambridge and South Cambridgeshire have relatively high economic activity rates, coupled with generally low unemployment rates. The difference between the skill levels of residents is larger in Cambridge, where there are more highly skilled residents but also a higher proportion of residents with no qualifications. There is currently a slight overbalance towards jobs rather than residents in the two local authorities, particularly within Cambridge City. The workforces in both local authorities are relatively well-contained, with 82% and 74% of the workforce respectively commuting from within the county of Cambridgeshire. This is broadly in line with the ONS definition of a ‘Travel to Work Area’ (TTWA), which suggests that approximately 75% of the workforce should commute from within that given area. The NEC AAP area is an almost exclusively employment-focused area currently, with a higher density of jobs than residents. Employment centres are (expectedly) much more focused than areas where residents live, with the main employment centres existing around the key transport hubs within the local authorities. What quantum of jobs and housing growth are planned/needed? In quantitative terms, the Objectively Assessed Housing Need (OAHN) was judged to be 14,000 new dwellings for Cambridge and 19,000 for South Cambridgeshire over the total period, equivalent to 700 and 950 new dwellings per year respectively. In the South Cambridgeshire Local Plan, adopted September 2018, this target for housing rises to 19,500 new homes in the district over the same time period, equivalent to 975 homes per year. The SHMA deemed that over the plan period (2011 to 2031), the affordable housing need amounted to a total of 15,975 affordable homes across the two areas, of which 10,402 should be in Cambridge and 5,573 in South Cambridgeshire. This amounts to an annual need of 520 affordable homes in Cambridge and 279 in South Cambridgeshire. With regards to employment, Policy S/5 of the South Cambridgeshire Local Plan establishes a target of 22,000 new jobs to be provided in the district in the twenty years to 2031. According to research by Cambridge Econometrics, sectors anticipated to grow in the future include professional services, computing and business services, construction and health. Considering this 20-year target on an annual basis, South Cambridgeshire would need to deliver 1,100 new jobs per year on average to deliver the target amount. It should be noted that the number of jobs is a forecast and not a target to be met at all costs. The Employment Land Review identifies that employment growth on this scale would generate a net demand for around 143,000m2 of additional employment floorspace or 43ha of land in the ‘B’ use classes. Employment has been growing at a faster rate than housing is being delivered in both local authorities. This could represent a problem going into the future, whereby both local authorities already relying on in commuting the need for which will increase if this disparity is not addressed. What would this vision mean for the NEC area? The NECAAP specifies an additional 234,500m2 of B1-use office space to be delivered in the North East Cambridge area to 2040. The AAP justifies this quantum of space as follows: “The amount of employment floorspace identified for North East Cambridge has the potential to provide a significant increase in the quantity of B1 accommodation in the area to meet future business needs.” As of 2018, there are an estimated 10,400 people working in office-based employment in the Local Area, with an estimated 34,250 and 35,000 respectively in the districts of Cambridge and South Cambridgeshire. The main office hubs within the borough are in the Cambridge city centre, around Cambridge station, and around Cambridge North station in close proximity to the NEC AAP area. The densest area of the borough on this measure is around Cambridge station. Over the period 2009-2018, office-based employment in the Local Area, defined to act as a proxy for the NEC AAP area, has grown by 35%. This is equivalent to an average annual growth rate of 3.9%, below the average annual growth rates of office employment in South Cambridgeshire (6.4%) and Cambridge (4.1%) respectively. The 234,500m2 of B1 floorspace outlined within the NECAAP is estimated to deliver an additional 16,600 full-time equivalents (FTEs) in the North East Cambridge area by 2040, assuming a standard density of one FTE per 12m2 of commercial office space. After accounting for 2018 part-time working patterns in the NEC area, this amounts to an estimated 18,700 office-based jobs. This increase therefore represents a 180% uplift (almost tripling) in the amount of 2018 office-based employment supported in the Local Area, as well as a 27% uplift for Cambridge-based and South Cambridgeshire-based 2018 office employment combined. To put this into context, this 180% uplift in local area office employment would need an average of 8.2% office employment growth every year over the period 2018-2040, in order to achieve the scale of B1 office growth that the NECAAP is targeting. This is more than double the average annual growth rate in office employment recorded since 2009 in the local area (3.9%), highlighting the potentially over ambitious B1 targets set out in the draft AAP. In absolute terms, the local area has increased its office employment by an estimated 2,700 over the past decade. The equivalent figures for the whole of Cambridge and South Cambridgeshire are 9,250 and 12,800 new office jobs respectively. This means that over the period to 2040, the NECAAP area would need to deliver seven times more new office jobs than it has over the past decade, or 85% of the office jobs delivered across the whole of the two boroughs. This suggests a very considerable uplift in future growth rate, and an extreme concentration of this future growth in one specific location. The need for more residential growth We estimate the number of residents that could be supported in the proposed 8,000 homes. We do this in two ways, firstly using the current residents per dwelling ratio in the two districts (2.31 residents per dwelling), and secondly using the GLA Population Yield Calculator – set in Outer London achieving an average PTAL rating of 3-4 – and assuming an even split of units between 1 to 4-bed residential units, with a 60-40 split of private versus affordable. The resident per dwelling method results in an estimated 18,500 new residents, and the GLA calculator estimates that 20,800 residents could be supported by the 8,000 units. Over the period April 2019 – March 2020, the (weighted) average 16-64 economic activity rate across Cambridge and South Cambridgeshire was 82.3%. Of these residents, approximately 11,900-15,100 would be expected to be of working age (16-64). Applying the average economic activity rate in Cambridge and South Cambridgeshire to these working age residents, we’d expect 9,800-12,500 of these residents to be economically active. Clearly, it is not conceivable that all of these 9,800-12,500 economically active residents moving into the area would be seeking work, as many would already be employed. However, in the scenario where they were all seeking work, there would still be a shortfall of 7,500-10,200 between new jobs and residents in the NEC area. Including the existing 15,000 jobs already within the NEC area would further accentuate this imbalance. Therefore, in order to support the planned levels of new jobs and new homes, there would clearly need to be a substantial amount of in-commuting to the area, which can have a range of adverse impacts such as noise and congestion. This analysis suggests that the proposed balance might not be quite right. Instead, there should perhaps be more of a focus on homes rather than jobs in the NEC area. The combined targets for housing and employment delivery over the period 2011 to 2031 across Cambridge and South Cambridgeshire are as follows: • Employment: 44,100 new jobs, equivalent to 2,205 additional jobs a year; and • Housing: 33,500 new homes, equivalent to 1,675 additional homes a year. Comparing this to the target for the NEC area, the 20,000 new jobs would amount to 45% of the total employment growth targeted for both local authorities combined over the plan periods. In contrast, the 8,000 new homes targeted for the NEC would only deliver 24% of the combined housing target for the local authorities, highlighting the clear bias towards employment in the area when compared to residential need. What types of jobs & homes are needed? Creating a community requires a mix of uses: commercial, residential and community uses, but also different types of jobs within the commercial uses. The NECAAP at present clearly has a focus on the additional provision of office jobs. Whilst these jobs are often seen as highly skilled and high value, they may not necessarily be the sorts of jobs that local residents, and those residents who most need access to employment opportunities, are most suited to and hence may not be the most accessible for those who need them most. According to the Skills, Training & Local Employment Topic Paper jointly released by Cambridge City Council and South Cambridgeshire District Council , in Cambridge approximately 30% of the city’s jobs are in the knowledge intensive sector, and these jobs require specialist skills and are highlypaid. Unfortunately, however, there is a small but growing proportion of jobs in the city that are paid below the real living wage (13.1% in 2018). In addition to this, due to success of the tech sector and the world-renowned university: “there are large numbers of high-skilled jobs, some unskilled or low-skilled jobs, but very few jobs requiring mid-level skills compared to other parts of the country. This makes it very difficult for people with limited qualification or skills to secure jobs with salaries that are high enough to meet the high cost of living and housing in the city.” To counter this, the councils are aiming to reduce the skills gap in the local authorities through the following sorts of measures: • 400 new apprenticeships through partnership with Cambridge Regional College; • For school leavers looking to further their career, Anglia Ruskin University (ARU) has set up degree apprenticeships with a range of employers paying tuition fees alongside Government funding; Training and employment opportunities from developers secured through s106 agreements during the construction phase of development; and • Operational developers should provide an Employment and Skills Plan (ESP). Whilst these sorts of measures should all be viewed positively, to truly assess whether the appropriate types of jobs are being provided we need to assess the current conditions of the local NEC area. Analysis carried out on socio-economic indicators show that the NEC area is close to many groups of people who desperately require future economic opportunities to be provided to them, not all of which will be B1 office opportunities. We have analysed the index of multiple deprivation (by sub-domain) for the local area surrounding Cambridge Science Park (CSP) and the local authorities of Cambridge and South Cambridgeshire. The three figures below show that the area surrounding both CSP and the NECAAP area are among the most deprived in the local authorities, with respect to overall deprivation, as well as employment and skills deprivation levels. Clearly, if the residents living near the NEC area are among the most deprived in terms of education, skills and training, the provision of highly-skilled office jobs in the local area is likely going to do very little to improve their outcomes in life, as these types of jobs will not be accessible to them and will instead be filled by in-commuters. Instead, some lower skilled, entry level, but good quality career jobs are needed in the NEC (or wider local) area in order to offer opportunities for these groups. Previous work by Volterra and CSP identified the opportunity for 7,500 new jobs in skilled manufacturing at CSP North, just north of CSP and on the outskirts of the AAP area. As explained previously, with appropriate collaboration with partners, including the CRC, it is highly likely that these types of jobs would be better suited to addressing the future employment needs of some of the more deprived parts of the area, whilst also delivering growth in a highly exportable sector. When combining this potential employment growth along with that planned at the NEC area, it further underlines the potential imbalance between jobs and homes, and the importance of delivering the right kinds of jobs to maximise benefits for all, including importantly those who need improved opportunities most. Referring back then to some of the NECAAP’s principles: ‘firmly integrated with surrounding communities’, ‘provide a significant number of new homes, a range of jobs for all’, it becomes clear that the balance of types and quantum of jobs proposed in the NEC area will not deliver these objectives in isolation. Combined with the opportunity presented at CSP North, along with a reconsideration of the NEC quantum of growth in favour of homes, however, these principles could be met. Cambridge Science Park North: Trinity College is proposing to transform a parcel of agricultural land adjacent to the Cambridge Science Park into a world- leading centre of excellence in skilled manufacturing and development. Branded Cambridge Science Park North, it will be an extension of, and benefit from the successful innovation ecosystem of the Science Park. It will promote social inclusion by facilitating the creation of skilled, well paid jobs in local companies where people from all backgrounds work together. The Centre will be nestled in 250 acres of stunning parkland with recreational facilities open to local residents. Cambridge benefits from an incredibly successful Research and Development based economy. Indeed, Cambridge is home to companies that are famous for innovation. Trinity College through its development and nurturing of Cambridge Science Park has always been a pioneer in terms of supporting growth in Science and Technology in Cambridge. Innovation involves a high degree of risk; in particular, the risk that products may not perform in the real world in the same way they did in the laboratory or workshop. Often products need to be redesigned, re-tested and adapted to meet the needs of the market. Moreover, in order to stay ahead of their competitors, research intensive companies need to implement a programme of continuous innovation. Already, a number of Technology companies manufacture close to their research base where changes in design can easily be implemented and new product ideas rapidly prototyped and tested. This is an increasing trend particularly in the case of the low-volume, high value products such as robotics, medical devices, electronics and batteries - areas where Cambridge leads the world. Whilst there is a good supply of premises suitable for undertaking product research, when it comes to high quality, affordable manufacturing and testing space, there is a significant shortage in Cambridge. This type of employment typically needs to operate from larger buildings with more of a quality industrial nature and do not readily operate from the stock of offices and laboratories currently available within the local market. There is now a shortage of suitable manufacturing and testing space in the Cambridge area and the existing Cambridge Science Park. This is in part due to Cambridge’s success in providing the right conditions for Research and Development organisations to grow, however this has resulted in increasing office and laboratory values; while significant areas of potential new land have also been lost as a result of past and proposed housing development and allocations. This shortage of suitable available space means companies are being forced to undertake their manufacturing potentially in other regions of the UK, however given the global competition for attracting the economic benefits of this type of employment overseas locations will increasingly be considered if nearby premises are not available. The geographic distance between their research and manufacturing facilities can negatively impact business performance, leading to long term strategic business decisions focusing on the availability of whole lifecycle premises. CSP competes on a global scale with places such as Kista Science City, Stockholm, WISTA Science and Technology Park, Berlin Crucially though, without these manufacturing companies in Cambridge, there is a shortage of job opportunities for people who want to work in a technical or engineering environment but do not have the qualifications to undertake the roles that require a university degree. Opportunities that could benefit students at the Cambridge Regional College and North Cambridge Academy. As part of our work we have engaged with Cambridge Regional College who are very supportive of these proposals. Further conversations have also been held with Impington Village College and will be held with the North Cambridge Academy to understand the opportunities for their students. If Cambridge can supply the manufacturing space required by these companies, a new category of jobs could be created (illustrated in Figure 8). This would help to close the inequality gap in the city, and help lift families out of poverty, particularly those in the immediate vicinity of the proposed development such as Arbury and Kings Hedges. The benefit to the wider economy of skilled manufacturing and development in this location need to be considered by Greater Cambridge. This development within close proximity to Cambridge Science Park, the Guided Busway, Cambridge North Station and Cambridge Regional College presents this unique opportunity. This site is located On the Edge of Cambridge: Green Belt AND on Public Transport Corridors as identified as potential locations for growth within the Emerging Local Plan4 – both of these factors are of equal importance to this type of development.

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Creating a cohesive and sustainable community requires certain community uses to be provided that support local residents. The kind of community facilities that should be provided alongside residential homes include community centres, general practices, educational institutions, play space and open space. Broadly, the layout of the proposed masterplan within the NEC area appears to be appropriate, as the proposed uses appear to be close to the proposed residential units. It is crucial to the future success of this area as a community, however, that these community uses are indeed delivered, otherwise additional pressure will be placed on existing services and/or the place will lack the desired ‘sense of place’ for prospective new residents.

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Question 6 and the relevant sections within the NECAAP need to relate back to the response to Question 4. Are the densities and the building heights proposed in direct response to the context of the immediate area and good place making; or are they as a result of an imbalanced proposition including an excess of office employment provision? At present it is not clear should the office employment provision reduce, would densities and heights reduce, or would additional housing be provided. If so, open space and community infrastructure needs would increase and therefore density may still reduce. At the heart of the new urban quarter should be good placemaking, and therefore building heights and densities should reflect the needs of the area in terms of environmental, social and economic benefits.

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Having reviewed Section 5.3 whilst there is provision for public open space the document should acknowledge Public Health England’s March 2020 document ‘Improving access to greenspace: A new review for 2020’.5 This document advocates that good design integrates green infrastructure into the holistic masterplan in ways that promote active travel, recreation and leisure, and support community and social engagement. Greenspace must be recognised as critical infrastructure that will help meet a range of local priorities and is not just something ‘nice to have’. Whilst brownfield in nature, the relocation of the Waste Water Treatment Works (WWTW) does provide a somewhat blank canvas in terms of the potential masterplan for the area. However, the balance of green and blue infrastructure appears to heavily rely on that already provided within CSP, with the introduction of a linear park and triangular space which fit around the built form, rather than a landscape rich approach. Figure 20 within the draft NECAAP illustrates the proposed Cowley Triangle Park providing 1.1 hectares of new open space and the Proposed Linear Park providing 8.5 hectares. The Open Space Topic Paper sets out a total Open Space Provision of 66.3 hectares, 40.4 being dedicated to informal open space and equipped children’s play areas. This poses the question as to where this additional open space provision can and will be accommodated. Cambridge Science Park currently includes circa 8 hectares of amenity landscaping, which is included within the NECAAP is short of at least 22 hectares of informal open space and play areas according to the supporting Topic Paper. Reference is made to improvements to Milton Country Park, Chesterton Fen and Bramblefields Nature Reserves in lieu of appropriate on-site provision. However, whilst in theory this could provide part of the solution, it is questionable as to how this investment will support the initiatives set out within the Anti-Poverty and Inequality Topic Paper. This points to the wards of Arbury and Kings Hedges which neighbour the NECAAP area has falling within the most deprived areas within Cambridge. That same paper sets out the importance of providing access to open space as a means to address health inequalities. Guidance for Outdoor Sport and Play6 sets out recommendations for walking distances to varying open space typologies, which are all below the distance from Kings Hedges to the off-site improvements. One solution to the lack of new open space provision would be through Cambridge Science Park North which is being developed as a location that can provide compensatory improvements to a substantial (circa 90 hectares) area of remaining Green Belt land providing: • A network of new green infrastructure; with links to Milton Country Park, Histon & Impington, and Arbury and Kings Hedges. • Woodland planting of sufficient scale to provide meaningful woodland carbon capture; • Landscape and visual enhancements taking existing agricultural land and creating a valuable green asset for neighbouring communities and employees. • Improvements to biodiversity, habitat connectivity and the introduction of natural capital to an area of low ecological value agricultural land. • New and enhanced walking and cycle routes, linking into the planned improvements to Mere Way; and • Improved access to new recreational and playing field provision. These proposed uses are all entirely compatible with both the purposes of the Green Belt and uses which are deemed as appropriate within the Green Belt i.e. material changes in the use of land for outdoor sport and recreation.

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As per the previous response, whilst brownfield in nature the relocation of the WWTW does provide a somewhat blank canvas in terms of the potential masterplan for the area. However, the balance of green and blue infrastructure appears to heavily rely on that already provided within CSP, with the introduction of a linear park and triangular space which fit around the built form, rather than a landscape and biodiversity rich approach. The 2020 Biodiversity Assessment which supports the draft NECAAP sets out a number of recommendations, which TCC believes development of CSPN would help to achieve as follows: • Recommendation 4: All developments and projects should deliver a measurable biodiversity net gain with a target of 10% gain. • Recommendation 12: Develop green loops to encourage engagement and contact with nature to promote well-being and to deliver health benefits. • Recommendation 17: Encourage the provision of priority habitats within NEC including woodland, ponds, drains, grasslands, hedgerows and living roofs. Emphasis should be placed on delivering a mosaic of habitats to ensure diversity in opportunities for the species using them. One solution to the acknowledged difficulty in providing biodiverse development within the AAP area would be through Cambridge Science Park North which is being developed as a location that can provide compensatory improvements to a substantial (circa 90 hectares) area of remaining Green Belt land providing: • A network of new green infrastructure; with links to Milton Country Park, Histon & Impington, and Arbury and Kings Hedges. • Woodland planting of sufficient scale to provide meaningful woodland carbon capture; • Landscape and visual enhancements taking existing agricultural land and creating a valuable green asset for neighbouring communities and employees. • Improvements to biodiversity, habitat connectivity and the introduction of natural capital to an area of low ecological value agricultural land. • New and enhanced walking and cycle routes, linking into the planned improvements to Mere Way; and, • Improved access to new recreational and playing field provision. These proposed uses are all entirely compatible with both the purposes of the Green Belt and uses which are deemed as appropriate within the Green Belt i.e. material changes in the use of land for outdoor sport and recreation.

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With regard to the private car, first and foremost Trinity College Cambridge and Cambridge Science Park have committed to and begun implementing measures aimed at reducing the modal split away from the use of the private car as the primary means of accessing CSP. We have previously responded to the 2019 Transport Assessment and include within this response our response to the Transport Topic Paper. TCC and CSP take issue against the false premise contained with the draft NECAAP which refers to prolific and unconstrained car parking at CSP. This statement as a particularly unhelpful, and frankly false inclusion within a document that also refers to 4,400 ‘unused car parking spaces on Cambridge Science Park’ (another unevidenced and incorrect statement). Given the document contains both unsubstantiated comments it is unclear whether the document seeks to claim there is prolific, unconstrained car parking, or whether there are 4,400 unused spaces. Neither statement is true. On the 20th December 2019 a Section 106 agreement was signed by South Cambridgeshire District Council, Cambridge City Council, Cambridgeshire County Council and Trinity College Cambridge with regard to Cambridge Science Park agreeing to the implementation of a Parking Management Strategy for the entire CSP area. This agreement committed CSP to limit the total number of parking spaces within the site to 7,498 and to use reduce this to 6,977 by the December 2029. The S106 Agreement sets out the complex leaseholder arrangements within CSP, and the commitment to remove and reduce parking spaces from tenancies and lettings as leases either expire or are renewed. The commitment to achieve this is there. However, in order to achieve this step change a commitment is needed via a package of measures required to facilitate non-car access to this key employment destination. Vectos have produced a note setting out how CSP can support the measures set out within the 2019 Transport Assessment, and we believe CSPN has to be viewed as an important part of the solution. To conclude therefore, whilst the principle of the draft NECAAP is supported, the balance between the provision of homes and office space is questioned. Finally, there remain key questions relating to the open space and biodiversity provision and the transport solutions required to enable any homes to be built in this location. Key areas which CSPN can help to achieve. Given the latest adoption of the LDS considers the opportunity to link delivery of the new Local Plan and the NECAAP, it would seem sensible at this stage to consider the potential for a wider area to deliver the crucial infrastructure required to enable the development of this new neighbourhood. CSPN Supporting Sustainable Transport Part of the rationale behind locating this new hub of excellence in skilled manufacturing and development in this location relate to the fact the site is extremely well linked to existing public transport corridors, located on the existing guided busway to Northstowe and within close proximity to Cambridge North Railway Station (see Figure 9). The recently published consultation for CAM includes a Cambridge Science Park North stop, which Trinity College Cambridge supports and wholly endorses as a forward-thinking approach to infrastructure provision. A key challenge facing delivery of the NECAAP area will be bringing forward both residential and employment land uses whilst adhering to the proposed vehicle trip budget in accordance with the emerging AAP. Through the discussions on the NECAAP Transport Study and resultant implications for the NECAAP area it has become increasingly apparent that there is a requirement for a strategic approach to deliver the step change in modal shift required to facilitate development within the AAP area. The site provides an opportunity to provide growth together with an enhanced transport solution. The strategic transport solution required to unlock the AAP area for housing will need to be funded through the commercial development of CSPN and the wider AAP area. Ongoing work reviewing the Transport Study baseline figures, using a different model, and reviewing the assumptions may achieve limited headroom. However, to deliver a new district of the scale proposed an implementable package of measures are required. CSPN, as an extension to the existing Cambridge Science Park offers part of the solution which incorporates both existing and proposed public transport infrastructure to intercept car movements before they enter the AAP area whilst also promoting the use of sustainable transport modes. The A10 suffers peak hour congestion and there are few alternatives at present. Additional movements along the A10, many of which will be towards the employment areas in North East Cambridge, may add sufficient pollution levels to trigger Air Quality exceedances in the AAP area. CSP and CSPN have the opportunity to intercept those trips and provide a workplace destination for future residents. The emerging Cambridge Autonomous Metro would be the obvious way of travelling to and from work in this location, providing a direct and convenient route. A core contemporary planning approach is the promotion of transit-oriented developments (also referred to as TODs) with greater emphasis on encouraging sustainable growth around public transport corridors and interchanges. Locating employment on a key transport node makes strategic planning sense. TCC’s proposals provide a consolidated location for parking which is linked to a mobility hub providing pedestrian, cycle, PLEV, shuttle and sustainable mass transit facilities for onward travel. A shift towards accessing alternative modes for the last mile of travel to employment destinations in itself providing health, wellbeing, pollution and climate change benefits. The consolidated mobility hub can also provide a micro-consolidation centre, reducing the number of delivery vehicles and intercepting deliveries before they enter the AAP area. Waterbeach Route of Cambridge Autonomous Metro: At the local level we are examining the opportunity to potentially relocate the Park & Ride facility on Butts Lane to a mobility hub location within the expansion land (see Figure 10). We have been liaising with the Cambridge and Peterborough Combined Authority team that are investigating options for the ‘Waterbeach Route’ and made clear our willingness to work with them and accommodate the CAM route within our own planning. Placing the Waterbeach CAM route through CSPN has a number of advantages including: • Linking the existing guided busway with the proposed CAM route alongside the committed pedestrian / cycle improvements to Mere Way; • Integrating Waterbeach sustainable transport proposals with NEC AAP proposals; • Utilising existing infrastructure under the A14, reducing overall costs and timescales for delivery of the first phase of the Waterbeach connections; Re-routing the Park & Ride shuttle service off the A10 onto a congestion free, dedicated transit route; • Associated reliability and speed of Park & Ride services to employment within Cambridge Science Park, Cambridge Regional College, and other employment land within the wider AAP; • Linking Park & Ride arrivals with a multi-modal choice of sustainable transport options to reach employment locations within Cambridge Science Park and beyond; • Air Quality improvements by reducing traffic on the A10 and reducing congestion on Junction 33 of the A14; • Direct links into the existing transit corridor linking Cambridge North railway station to St Ives; • As submitted within the recent call for sites, the 163ha site to the north of the A14 will incorporate circa 90 hectares of land intended to remain within the Green Belt, but providing substantial areas of accessible natural green space, biodiversity improvements and sport and recreation facilities. Providing a sustainable transport hub in close proximity to this will increase accessibility to this resource; • The route would directly serve new employment at CSPN; • Cambridge Regional College the largest further education provider for 16 to 19 year olds in the region, which is set to accommodate increasing numbers of pupils, would be directly served by CAM routes from all directions; • Cambridge Regional College would additionally benefit from a new park & ride stop assisting in their own step change in parking. The potential benefits of this route option for the Waterbeach to Cambridge route need to be considered as part of the assessment of the NECAAP. Route options are at a relatively early stage, and this potentially substantial piece of infrastructure and the economic, social and environmental benefits should be considered as part of the emerging NECAAP.