Draft North East Cambridge Area Action Plan

1.7 ‘Open Spaces’ • 3 ‘A Spatial Framework for North East Cambridge’ • 6 ‘Jobs, Homes and Services’, particularly: o Policy 12a ‘Business’; and o Policy 12b ‘Industry, Storage and Distribution’ • 8.3 ‘Environmental Protection’, particularly: o Policy 25 ‘Environmental Protection’; • 8.4 ‘Aggregates and waste sites’, particularly: o Policy 26 ‘Aggregates and waste sites’. Comments: General Comments on the AAP, specifically Section 1.7 ‘Open Spaces’, Section 3 ‘A Spatial Framework for North East Cambridge’, and Section 6 ‘Jobs, Homes and Services’: These comments are submitted on behalf of our client, Tarmac, who operate a rail fed asphalt plant, an aggregate handling depot, and readymix concrete plant within the Area Action Plan (AAP) for North East Cambridge (NEC). The sidings, plant, and depot are located as shown on the Proposed land uses within the AAP boundary (Figure 11) labelled ‘aggregate railheads’. Our client’s operations take place on land within Network Rail freehold ownership but are well- established and benefit from planning consent as well as policy support for their safeguarding within the Cambridgeshire and Peterborough Minerals and Waste Site Specific Proposals DPD (Policy SS P T2). Our client has previously submitted comments to the Issues and Options stage of the AAP’s development in March 2019, whereby it was emphasised that “the site is vital to enabling the sustainable transport of minerals which will be required to deliver the development of infrastructure in Cambridge and the surrounding areas. It is important that the rail fed asphalt plant and aggregates depot is safeguarded and appropriate development is proposed in the area surrounding it.” At this stage, we would like to re-emphasise the above and support the inclusion of Policy 25 ‘Environmental Protection’ and Policy 26 ‘Aggregates and waste sites’, particularly in light of the new ‘Proposed land uses’ shown on Figure 11 of the latest version of the AAP. Figure 11 shows the retention of the aggregates railhead with what appear to be a potentially more appropriate mix of land uses surrounding the site (labelled as Industrial (B2), storage and distribution (B8), and a Linear Park as shown at Section 1.7), at least when compared with the Issues and Options version of the AAP. The objectives contained within Policy 26 to safeguard the existing mineral operations in accordance with the area’s Development Plan and paragraphs 182 (detailed below) and 204(e) of the NPPF to ensure the safeguarding of the mineral transportation and handling operations are supported. Whilst we welcome the introduction of Policies 25 and 26 as well as a buffer/screen between the existing mineral operations and potential sensitive receptors such as residential properties, the AAP should ensure that proposed buffer/screens are sufficiently robust and provide adequate protection for potential future residential occupiers given the potential for unintended adverse impacts, or nuisance impacts, that could emanate from the mineral operations. In accordance with the ‘agent of change’ principle contained within NPPF at paragraph 182, existing businesses and facilities should not have unreasonable restrictions placed upon them as a result of development permitted after they were established. The onus to protect or ‘provide suitable mitigation’ for future residential amenity is on newly-introduced land uses rather than established / consented land uses and operations. We support the specific direction within Policy 26 that accords with the need to safeguard mineral activities in accordance with NPPF paragraph 204(e) that states that “any residential proposal … will need to demonstrate how it achieves acceptable environmental standards (i.e. buffering) from the negative impacts of the aggregate railheads.” Having regard to the above, consideration should be given to the appropriateness of the ‘Linear Park’ shown at Section 1.7 to provide effective amenity screening of the existing mineral operations (specifically to mitigate visual and noise impact). Figure 11 of the latest iteration of the AAP still shows ‘housing-led’ land uses north of the aggregate railhead, depot, and readymix plant in close proximity with only a narrow Linear Park shown (at section 1.7) between mineral operations and housing-led development. If the AAP proposes to introduce buffer / screening land use between sensitive uses and established mineral operations, the content of the AAP should consider that practically, the successful implementation and effectiveness of buffer / screening land use is reliant on assessment of the effectiveness of any screen, and subject to the findings of that assessment, the buffer / screen being delivered prior to the introduction of sensitive land uses. As well as questioning how effective the narrow Linear Park would be in protecting the amenity of nearby sensitive receptors, we would also like to emphasise that phasing of development will be critical to ensuring that existing mineral operations can continue without adverse impact on new residential or similarly sensitive land uses. It is important to protect amenity by ensuring that sufficient and robust buffers / screening uses are in place prior to the introduction of new sensitive receptors close to the existing mineral operations. The AAP should be prescriptive in requiring technical assessment(s) (such as noise and air quality assessments) alongside proposals for sensitive land uses to ensure no unacceptable disamenity impacts on new development will occur from the existing mineral operations. We support a requirement for new development proposals to be accompanied by “effective mitigation and remediation plans … to consider individual and cumulative impacts, timing and phasing, and current and future uses” as outlined in Policy 25. Regarding the wider spatial distribution of housing within NEC, the AAP should recognise that whilst the ‘Chesterton Sidings’ parcel of NEC may be the most sustainable location for new housing given its proximity to Cambridge North Station, the sidings are the only possible location for the existing rail-fed mineral operations and they should be safeguarded in accordance with NPPF paragraph 204(e). By contrast, there remains flexibility over where to locate residential and similar sensitive uses within NEC. At present, Policy 26 states that redevelopment of the railheads “will only be acceptable if the current operation is relocated off-site”. We submit that the railheads and associated mineral operations remain a strategic site for mineral transport and an important site for mineral processing. It is the intention of Tarmac to continue to operate the site throughout the AAP plan-period to 2040 unless, in line with the intentions of Policy 26, a suitable alternative site was identified and adequate commercial terms were presented. In such a circumstance, Tarmac would consider the relocation of these strategic operations. Until any possible future relocation of the mineral operations is agreed, the railhead, depot and readymix plant should be safeguarded and great weight given to the protection of their strategically important operations within the AAP. Finally, Policy 12a ‘Business’ and Policy 12b ‘Industry, Storage and Distribution’ propose the delivery of up to 36,500m2 of additional B1 floorspace and a minimum of 8,500m2 of B2/B8 floorspace within the Chesterton Sidings area of NEC. We submit that the existing mineral operations should not be directly or indirectly detrimentally impacted upon by the introduction of a significant volume of new development. Whilst Policy 26 aims to protect residential development from disamenity associated with the existing mineral operations, the potential for commercial operations to similarly impacted are not considered. Potentially sensitive non-residential land uses should likewise be proposed for locations whereby disamenity associated with mineral operations at Chesterton Sidings are not considered a nuisance due to sufficient separation distance, or can be demonstrated through technical assessment.