Draft North East Cambridge Area Action Plan

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Please see letter attached Social and Community Infrastructure – Policy 14 Question 5 - Are we are planning for the right community facilities? 16. We welcome the reference to new social infrastructure (including schools) to be required to meet the needs of existing and new communities. 17. However, as drafted, it is not considered that this policy is wholly compliant with the NPPF, as it provides policy support only where there is recognised ‘local needs’. The NPPF, as set out above, gives weight to widening choice in education, which would include through the provision of specialist educational facilities. 18. We would therefore propose that the policy be extended as follows (additional wording in italics underlined): 1https://www.gov.uk/government/publications/national-planning-policy-framework--2 2 https://www.gov.uk/government/collections/opening-a-free-school 3 https://www.gov.uk/government/publications/establishing-a-new-school-free-school-presumption and https://www.gov.uk/government/publications/delivering-schools-to-support-housing-growth 4 Development proposals for new community, cultural and leisure facilities will be supported where it meets identified local needs. State funded education infrastructure which is capable of meeting wider regional needs will also be supported where this is deliverable and sustainable. 19. This will ensure that the policy is compliant with the NPPF and is positively prepared.

Re: North East Cambridge Area Action Plan Consultation under Regulation 18 of Town and Country Planning (Local Planning) (England) Regulations 2012 Submission of the Department for Education 1. The Department for Education (DfE) welcomes the opportunity to contribute to the development of planning policy at the local level. 2. Under the provisions of the Education Act 2011 and the Academies Act 2010, all new state schools are now academies/free schools and DfE is the delivery body for many of these, rather than local education authorities. However, local education authorities still retain the statutory responsibility to ensure sufficient school places, including those at sixth form, and have a key role in securing contributions from development to new education infrastructure. In this context, we aim to work closely with local authority education departments and planning authorities to meet the demand for new school places and new schools. We have published guidance on education provision in garden communities and securing developer contributions for education, at https://www.gov.uk/government/publications/delivering-schools-to-supporthousing- growth. You will also be aware of the corresponding additions to Planning Practice Guidance on planning obligations, viability and safe and healthy communities. 3. We would like to offer the following comments in response to the above consultation document. These comments follow from our previously submitted representations (March 2019) to the AAP which are appended, and also our representations to the Greater Cambridge Plan (February 2020). General Comments 4. DfE is looking to secure a site for the delivery of Cambridge Maths School through The Learning Alliance (a multi academy trust formed from merging Cambridgeshire Educational Trust into the Morris Education Trust) and has identified North East Cambridge as an ideal location for this, due to regional accessibility and wider economy and skills concentration. We look forward to working with Greater Cambridge Partnership (GCP) officers to achieve this and establish a high-performing educational establishment in the City. The government has committed to having a 16-19 maths school in every region, 11 in total. 5. By virtue of their high entry requirements, maths schools are small schools (with up to 250 places but usually 200 or less), this helps foster a close-knit and nurturing learning community. This is part of a range of initiatives to improve maths provision, including the Level 3 Mathematics Support Programme, and additional funding via the Advanced Maths Premium to support providers to increase A level maths participation; maths schools will also complement the work of Maths Hubs. Maths schools are characterised by high-quality long-term involvement from a university with a strong mathematics department – in this case Cambridge University. We expect the associated university to be committed to and accountable for the success of the school through a formal link with school governance and provision of, for example, curriculum and outreach support. 6. Two maths schools are currently established: King's Maths School and Exeter Maths School (opened in partnership with King’s College London and Exeter University respectively). Further maths schools in Cambridge, Durham, Imperial College London, Lancaster and Surrey are planned to open in two to three years, and Liverpool opened in September 2020. Ofsted found that the open maths schools (at King's and Exeter) both achieve high academic results, and provide an outstanding education, in 2017 inspections. In 2019 King’s Maths School was top in the country for A level attainment, ahead of every other school including independent schools. 100% of King’s students, and 93% of Exeter’s students, achieved an A or A* in A level mathematics. In 2019 King’s had an A level maths progress score of 1.28 and Exeter 1.45, meaning that pupils in these schools achieved on average a grade higher than similar students nationally; this places both schools in the top 1% of schools for A level maths progress. 7. All maths schools must offer A levels in Maths and Further Maths. There is some flexibility beyond this – there will be at least a third subject option which must include physics and be limited to STEM subjects. 8. The staffing model will be a matter for the school, in line with its pupil numbers and funding. Typically, a school (when full) will have a headteacher and assistant head, plus administrator, directors of faculty/subject leaders/subject teachers, teaching assistants, people with specialisms such as SEND & EAL, and typically graduate assistants/learning mentors. Schools will typically employ 15-20 FTE staff. 9. Maths schools are expected to draw pupils from a wide area, with pupils travelling for up to an hour/30 miles or even further. Therefore accessibility to transport links is important not just for the young people attending the school but also because maths schools are required to provide specialist outreach support to schools within their region, complementing the work of maths hubs. Teachers at the school will be travelling out to surrounding schools to do this. Also, pupils and their teachers at those schools will wish to be able to reach the maths school to access CPD and other opportunities. 10. As demonstrated by the open schools the highly specialist nature of the provision at maths schools, where every student has to undertake A Levels in maths and further maths, means we expect that it will only attract typically one or two pupils each from other schools and pupils will travel further than usual to access maths schools. 11. DfE welcomes reference within the plan to support the development of appropriate social and community infrastructure at section 6.3. DfE notes that the AAP includes site allocations pertaining to school delivery. 12. It is noted that paragraph 2.2 (3) ‘Strategic Objectives North East Cambridge’ will help meet the strategic needs of Cambridge and the sub-region. This wording is supported. 13. The National Planning Policy Framework (NPPF) advises that local planning authorities (LPAs) should take a proactive, positive and collaborative approach to ensuring that a sufficient choice of school places is available to meet the needs of communities and that LPAs should give great weight to the need to create, expand or alter schools to widen choice in education (para 94). 14. GCP should also have regard to the Joint Policy Statement from the Secretary of State for Communities and Local Government and the Secretary of State for Education on Planning for Schools Development1 (2011) which sets out the government’s commitment to support the development of state-funded schools and their delivery through the planning system. 15. Please note that there are two routes available for establishing a new school. Firstly, a local authority may seek proposals from new school proposers (academy trusts) to establish a free school, after which the Regional Schools Commissioner will select the successful trust. Under this ‘local authority presumption route’ the local authority is responsible for finding the site, providing the capital and managing the build process. Secondly, school proposers can apply directly to DfE during an application round or ‘wave’ to set up a free school, or (for maths schools) through submitting a business case. The local authority is less involved in this route but may support groups in pre-opening and/or provide a site. Either of these routes can be used to deliver schools on land that has been provided as a developer contribution. DfE has published further general information on opening free schools2 as well as specifically in relation to opening free schools in garden communities.3 (Question 5 and Policy comments added to specific questions) Site Suitability 27. The site is the most sustainably located of all of the sites appraised as part of the site search. This is due to its proximity to Cambridge North Station and busway interchange. Maths Schools are expected to have regional accessibility and therefore this is an optimum location for accessibility and sustainability. A full transport assessment will be undertaken and travel plan will be drawn up (having regard to the necessary policy requirements) to support the forthcoming planning application. 28. The proposed Maths School in land use terms is considered to be suitable for inclusion within a mixed-use residential/employment area. Indeed, the students who attend maths schools are high performing and studying a range of STEM subjects which are classroom based. The number of students is low and therefore it is unlikely that there will be any impact on amenity arising from the proposals. 29. The site has no heritage or ecological designations and is within Flood Zone 1. The layout and design will consider associated environmental constraints and propose mitigation measures where required. 30. The site may have former contamination issues which will be dealt with through detailed assessment provided at planning application stage. 31. The school is proposed to be built by Brookgate as part of the Cambridge North masterplan (location plan is appended) which would represent efficient land use and sustainable development, as well as enhancing mixed and balanced communities. 32. Therefore the allocation should include supportive wording which is sufficiently flexible for this use, as there are no alternative preferable sites. The development of a maths school at this site would assist in widening educational choice and attainment, and act as a high quality educational anchor for a mixeduse development within the AAP land in North East Cambridge. Policy wording should enable the delivery of specialist educational facilities in addition to schools meeting the needs of the wider demographic/population growth. This is required to ensure that the plan is compliant with the NPPF in widening choice. 33. The Learning Alliance trust has established links with Cambridge University and has also been in contact with the education authority at Cambridgeshire County Council, which has expressed support for the school (and a letter from CCC is appended setting this out in fuller detail). Conclusion 34. Finally, I hope the above comments are helpful in shaping the North East Cambridge AAP, with specific regard to the provision of land and a positive policy context for the proposed Cambridge Maths School. Please advise DfE of any proposed changes to the emerging policies, supporting text, site allocations and/or evidence base arising from these comments. 35. Please do not hesitate to contact me if you have any queries regarding this response. DfE looks forward to continuing to work with GCP to aid in the preparation of a sound AAP. Yours faithfully, Phoebe Juggins MRTPI Forward Planning Manager – South East

CCC Letter: My ref: HAB/Free Schools Your ref: Date: 17 July 2020 Contact: Hazel Belchamber Direct dial: E Mail: Mr Ryan Kelsall Principal Impington Village College New Road Impington Cambridge CB24 9LX Dear Ryan Cambridge Maths School It was good to have the opportunity to speak to you and Clare Hargreaves earlier this week on the progress with the Cambridge Maths School. As agreed, I am writing on behalf of the Education Directorate to confirm that: • The site on which the Maths School will be established seems an ideal location in that it: - is very close the new railway station and also the guided busway, offering easy access for both students and staff via public transport. Use of public transport will support students to further develop their independence. - offers connectivity not just into Cambridge but, importantly, a much wider area, helping to reinforce one of its key aims which is to extend opportunities to students from other parts of the county (as well as potentially from other Local Authorities) thus broadening participation and outreach. • Due to its specialism, the Maths School our assessment is that it is very unlikely to have a material adverse impact on any of the existing schools and colleges. It will not only complement, but enhance the range of educational provision available to students. You confirmed that the admissions criteria and process are still being refined, but the expectation is that you would start to promote the Maths School in early 2022, about 18 months before the school is due to open. My ref: HAB/Free Schools Your ref: Date: 17 July 2020 Contact: Hazel Belchamber Direct dial: E Mail: Mr Ryan Kelsall Principal Impington Village College New Road Impington Cambridge CB24 9LX People and Communities Executive Director: Wendi Ogle-Welbourn Box No: SH1210 Shire Hall Cambridge CB3 0AP I will be making contact with Councillor Simon Bywater, Chair of the Children and Young People’s Committee to provide him with a briefing on the project and seek his views on next steps with regard to sharing this information with other Council members. Kind regards Hazel Belchamber Assistant Director: Education Capital & Place Planning

Our Ref: DfE/Local Plan/NE Cambridge 7th March 2019 Dear Sir/Madam, Re: North East Cambridge Area Action Plan Consultation under Regulation 18 of Town and Country Planning (Local Planning) (England) Regulations 2012 Submission of the Department for Education 1. The Department for Education (DfE) welcomes the opportunity to contribute to the development of planning policy at the local level. 2. Under the provisions of the Education Act 2011 and the Academies Act 2010, all new state schools are now academies/free schools and the DfE is the delivery body for many of these, rather than local education authorities. However, local education authorities still retain the statutory responsibility to ensure sufficient schools, including sixth form places, and have a key role in securing contributions from development to new education infrastructure. In this context, we aim to work closely with local authority education departments and planning authorities to meet the demand for new school places and new schools. We do this through a variety of means, including by supporting the adoption of sound local plan policies, site allocations and guidance (all based on robust evidence) that facilitate the delivery of education infrastructure where and when it is needed and maximise developer contributions for schools. In this capacity, we would like to offer the following comments in response to the proposals outlined in the above consultation document. General Comments on the Area Action Plan Approach to New Schools 3. The DfE notes that significant growth and regeneration is being planned for North East Cambridge through joint development of this area action plan by Cambridge City Council and South Cambridgeshire District Council (referred to as the Councils below). While the number of homes has not yet been defined, a significant growth in housing stock is expected in the area which will place additional pressure on social infrastructure such as education facilities. The area action plan will therefore need to be ‘positively prepared’ to meet objectively assessed development needs and infrastructure requirements. 4. The DfE welcomes reference within the plan to support the development of appropriate community facilities (section 10) and we note that the councils are in ongoing discussions with service providers on what these needs are. 5. In light of the requirement for all Local Plans to be consistent with national policy, you will have no doubt taken account of key national policies relating to the provision of new school places, but it would be helpful if they were explicitly referenced or signposted within the document. In particular: - The National Planning Policy Framework (NPPF) advises that local planning authorities (LPAs) should take a proactive, positive and collaborative approach to ensuring that a sufficient choice of school places is available to meet the needs of communities and that LPAs should give great weight to the need to create, expand or alter schools to widen choice in education (para 94). - The DfE supports the principle of safeguarding land for the provision of new schools to meet government planning policy objectives as set out in paragraph 94 of the NPPF. When new schools are developed, local authorities should also seek to safeguard land for any future expansion of new schools where demand indicates this might be necessary. - The Councils should also have regard to the Joint Policy Statement from the Secretary of State for Communities and Local Government and the Secretary of State for Education on ‘Planning for Schools Development’1 (2011) which sets out the Government’s commitment to support the development of state-funded schools and their delivery through the planning system. 6. Given the above context and the Duty to Cooperate on strategic priorities such as community infrastructure (NPPF para 24-27)2, the DfE encourages close working with local authorities during all stages of planning policy development to help guide the development of new school infrastructure and to meet the predicted demand for primary and secondary school places. 7. In planning for schools, the DfE commends, for example, the approach taken by the London Borough of Ealing in producing a Planning for Schools Development Plan Document (DPD, 2016)3. We are not suggesting that the Councils produces a separate DPD as Ealing have done, but we do believe that the systematic approach they have taken is informative for local plans. The DPD provides policy direction, establishes the Council’s approach to providing primary and secondary school places and helps to identify sites which may be suitable for providing them (including, where necessary and justified, on Green Belt/MOL), whether by extension to existing schools or on new sites. It includes site allocations as well as policies to safeguard the sites and assist implementation and was adopted in May 2016 as part of the Local Plan. The DPD may provide useful guidance with respect to an evidence based approach to planning for new schools in the emerging AAP, securing site allocations for schools as well as providing example policies to aid delivery through Development Management policies. Site Allocations 8. Ensuring there is an adequate supply of sites for schools is essential and will ensure that the Cambridge City and South Cambridgeshire District Councils can swiftly and flexibly respond to the existing and future need for school places to meet the needs of the borough over the plan period. 9. At this early stage of the emerging Local Plan site allocations have not yet been drafted. The next version of the Local Plan should seek to identify specific sites (existing or new) which can deliver the school places needed to support growth, based on the latest evidence of identified need and demand in the updated Infrastructure Delivery Plan. The site allocations and/or associated safeguarding policies should also (1 https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment data/file/740441/ National Planning Policy Framework web accessible version.pdf 2 NPPF paragraph 24-27 specifies that this collaborative working should include infrastructure providers. 3 https://www.ealing.gov.uk/info/201164/local plans/1961/planning for schools dpd) seek to clarify requirements for the delivery of new schools, including when they should be delivered to support housing growth, the minimum site area required, any preferred site characteristics, and any requirements for safeguarding additional land for future expansion of schools where need and demand indicates this might be necessary. For an example of the latter, see draft policy CC7 in Milton Keynes’s Plan:MK Preferred Option draft from March 20174. 10. These site specific policy requirements need to be set out clearly, informed by robust evidence of infrastructure need, so that they can be accurately accounted for in the viability assessment of the local plan (to ensure that the total cumulative cost of all relevant policies will not undermine deliverability of the plan)5, and in the price paid for land by developers and other parties. 11. While it is important to provide clarity and certainty to developers, retaining a degree of flexibility about site specific requirements for schools is also necessary given that the need for school places can vary over time due to the many variables affecting it. The DfE therefore recommend the Council consider highlighting in the next version of the Local Plan that: - specific requirements for developer contributions to enlargements to existing schools and the provision of new schools for any particular site will be confirmed at application stage to ensure the latest data on identified need informs delivery; and that - requirements to deliver schools on some sites could change in future if it were demonstrated and agreed that the site had become surplus to requirements, and is therefore no longer required for school use. 12. The DfE currently has one live central wave pipeline free school project for which a site has been identified in the AAP area: Cambridge Mathematics School, a mainstream sixth form with a specialism in Maths (200 pupils at full capacity). We have identified a site in the south east corner of the AAP area, located immediately west of the new Cambridge North station on vacant land that was formerly railway sidings. The site is central within an area proposed for residential, commercial and business uses. 13. The DfE believe that a D1 use, of the type and specialism proposed here, would be complementary to the high tech science park to the west, as well as the university and would fit in well as a community use within the proposed residential-led mixed use development of the wider site. A school with a Maths specialism will attract pupils from an area wider than the immediate city and district, therefore this location close to the new railway station is considered a highly suitable and sustainable site for this particular school. It will contribute to widening choice in the local education offer, as supported by the NPPF (see paragraph 5 above). To provide certainty around delivery of the school, we request that a site which can be brought forward early, be considered for formal allocation for D1 use to accommodate the proposed school in the next iteration of the AAP. We would be happy to provide further information about the school if required. Forward Funding 14. In light of proposals for significant mixed use development proposed for NE Cambridge, emerging DfE proposals for forward funding schools as part of large residential developments may be relevant, for example if viability becomes an issue. The DfE aims to be able to clarify forward funding options for schools shortly, following recent (4 https://www.milton-keynes.gov.uk/planning-and-building/planning-policy/plan-mk 5 PPG on Viability: https://www.gov.uk/guidance/viability#viability-and-plan-making) approval from Treasury. We would be happy to meet to discuss this opportunity further once details of the plans for the area, including requirements for new schools, have been progressed. Any offer of forward funding would seek to maximise developer contributions to education infrastructure provision while supporting delivery of schools where and when they are needed. Developer Contributions and CIL 15. One of the tests of soundness is that a Local Plan is 'effective· i.e. the plan should be deliverable over its period. In this context and with specific regard to planning for schools, there is a need to ensure that education contributions made by developers are sufficient to deliver the additional school places required to meet the increase in demand generated by new developments. The DfE notes that neither Cambridge City Council or South Cambridgeshire District Council currently have adopted a Community Infrastructure Levy; rather the Councils intend, through the AAP, to put in place a Section 106 reg ime specific to the area "to ensure all proposed developments across NEC contribute equitably to the provision and/or funding of all appropriate infrastructure requirements" (para 12.4 ). The DfE broadly support this approach to ensuring developer contributions address the impacts arising from growth. 16. The council should set out education infrastructure requirements for the plan period within an Infrastructure Funding Statement6 . Where additional need for school places will be generated by housing growth, the statement should identify the anticipated section 106 funding towards this infrastructure. The statement should be reviewed annually to update the schedule and phasing of infrastructure requirements and report on the amount of funding received via developer contributions and how it has been used, providing transparency to all stakeholders. 17. The DfE would be particularly interested in responding to any update to the Infrastructure Delivery Plan or review of infrastructure requirements, which will inform any emerging CIL and/or amendments to the Regulation 123 list. As such, please add the DfE to the database for future CIL consultations. Conclusion 18. Finally, I hope the above comments are helpful in shaping the NE Cambridge Area Action Plan, with specific regard to the provision of land for schools. 19. Please do not hesitate to contact me if you have any queries regarding this response. The DfE looks forward to continuing to work with Cambridge City Council and South Cambridgeshire District Council to aid in the preparation of a sound Area Action Plan. Yours faithfully, Douglas McNab MRTPI Forward Planning Manager Tel: Email: Web: www.gov.uk/dfe (6PPG on Plan-Making: https://www.gov.uk/guidance/plan-making#maintaining-effective-cooperation)