Draft North East Cambridge Area Action Plan

Comment

Representation ID: 55746

Received: 05/10/2020

Respondent: Brookgate

Agent: Bidwells

Neutral:
Policy 3 states that an Area Action Plan wide approach to energy and associated infrastructure
should be investigated and, where feasible and viable, implemented. The Shared Planning Service has
commissioned the development of an Energy and Infrastructure Study and Energy Masterplan for NEC.
This will consider the energy options and associated infrastructure requirements needed to support
the energy demands of the development and the transition to net zero carbon, giving consideration
to energy use in buildings, battery storage and that required for transportation. It will also give
consideration to the development of local energy communities and local collaboration and options
for community ownership of decentralised energy opportunities that may arise from the energy
masterplan.

At this stage of the Plan, the site wide energy and infrastructure study and energy masterplan has
not been prepared.

Whilst Brookgate do not oppose the approach set out in Policy 3 in principle, throughout the NEC
AAP workshops, Brookgate has made it clear that they have already sourced their power and other
such requirements both on and off site in
respect of the Chesterton Sidings site.

Comment

Representation ID: 55747

Received: 05/10/2020

Respondent: Brookgate

Agent: Bidwells

Neutral:
Policies 4a, b and c set standards and expectations for development across all
water related issues.
Brookgate broadly support these policies from a climate change resilience and in-combination
climate change impacts perspective. However, Policy 4c needs to be
aligned with Environment Agency guidance on climate change allowance:
(https://www.gov.uk/guidance/flood-risk-assessments-climate-change-allowances).

Comment

Representation ID: 55748

Received: 05/10/2020

Respondent: Brookgate

Agent: Bidwells

Neutral:
Policies 4a, b and c set standards and expectations for development across all
water related issues.
Brookgate broadly support these policies from a climate change resilience and in-combination
climate change impacts perspective. However, Policy 4c needs to be
aligned with Environment Agency guidance on climate change allowance:
(https://www.gov.uk/guidance/flood-risk-assessments-climate-change-allowances).

Comment

Representation ID: 55749

Received: 05/10/2020

Respondent: Brookgate

Agent: Bidwells

Neutral:
Policies 4a, b and c set standards and expectations for development across all
water related issues.
Brookgate broadly support these policies from a climate change resilience and in-combination
climate change impacts perspective. However, Policy 4c needs to be
aligned with Environment Agency guidance on climate change allowance:
(https://www.gov.uk/guidance/flood-risk-assessments-climate-change-allowances).

Comment

Representation ID: 55750

Received: 05/10/2020

Respondent: Brookgate

Agent: Bidwells

Neutral:
This Policy states that planning applications for major development within the North
East Area Action Plan area will be supported subject to a number of criteria. This
includes, inter alia, demonstrating the development will make an appropriate and
proportionate contribution to site wide infrastructure and be supported by a
comprehensive masterplan that accords with the overarching AAP Spatial
Framework and other AAP policies, including, where appropriate:
i. The ability to connect and contribute to Area Action Plan-wide utilities and
communications grids; and
ii. The setting aside of land for strategic and site-specific infrastructure provision.
Representations in respect of the setting aside of land for CAM are provided in
response to Question 2 and Policy 19.
It also needs to be recognised that the adopted plans of South Cambridgeshire
District Council and Cambridge City Council make it clear that planning applications
are capable of being submitted and granted planning permission in advance of the
AAP being adopted (South Cambridgeshire Local Plan Policy SS/4 and Cambridge
City Local Plan Policy 15).
The approach in the recently adopted local plan in respect of early submissions
should not be watered down through the AAP process, indeed, through the AAP
process the opportunity to bring forward Land at Cambridge North early should be
explicitly acknowledged as beneficial to the regeneration of the area, creating a
sense of place and arrival around the new Station and evidencing in commercial
terms how the low parking ratios might work.

Comment

Representation ID: 55751

Received: 05/10/2020

Respondent: Brookgate

Agent: Bidwells

Neutral:
The Arup Odour Report concluded that overall the range of evidence available from
all the various reported modelling studies, as well as the Arup study, indicate that
odour levels on the proposed development site would be below the levels generally
considered to have a low risk of adverse odour impacts. The report was based on a
further, more detailed odour analysis of the potential for odours at the development
site at Cambridge North in response to the Odournet report. Anglian Water
collaborated with Arup in terms of inputting into the report and agreed with the
methodology adopted within the report.
The conclusions of the Arup Odour Report are as follows:
“A qualitative Source Pathway Receptor assessment concludes that the proposed
development site would have a Low to Moderate risk of adverse odour impacts.
This is because the development site is more than 400-800m from the more
odorous parts of CWRC meaning odours which allows for dispersion and hence
dilution of the odours released.
Overall the range of evidence available from all the various reported modelling
studies and this study indicate that odour levels on the proposed development site
would be below the levels generally considered to have a low risk of adverse odour
impacts. The only exception is the Odournet study which appears to have made
some very pessimistic assumptions and the results can only be replicated by nearly
doubling the measured odour emission rates on site.
The evidence from modelling studies is further supported by the evidence form the
Source, Pathway, Receptor qualitative approach and the sensory assessments.
Odour complaints are received at a frequency of once a year (and some are
~
□
□
□
□ ~ □
received in areas where all studies would suggest that there is a risk of adverse
odour impacts) and the evidence from sniff testing is consistent with the modelling
studies undertaken by Arup, Anglian Water and CERC”
A number of reports have been commissioned on the potential for odour in
connection with the CWRC, all of which have reached consistent findings as the
Arup Odour Report detailed above, with the exception of the Odournet Report
which has far higher readings.
The evidence from these reports collectively is clear and this allows the LPA to
confidently take informed decisions.

Comment

Representation ID: 55752

Received: 05/10/2020

Respondent: Brookgate

Agent: Bidwells

Neutral:
It is proposed that the Cambridge North East Aggregates Railheads at North East Cambridge continues
to be safeguarded within the NEC AAP. These are located in the Chesterton Sidings Site and the
extent of the safeguarded area is shown in Figure 42 of the AAP (see below).

However, Policy 26 does support residential and commercial development of the aggregates railheads
site if the current operation is relocated off-site, subject to meeting the requirements of the
Minerals and Waste Local Plan (or future equivalent), or if the Minerals and Waste Local Plan (or
future equivalent) removes the safeguarding policy related to the site.

Brookgate, as part of their Chesterton Partnership meetings (comprising Brookgate, Network Rail and
DB Cargo UK), are in regular liaison with DB Cargo UK and their tenant Tarmac regarding the future
potential relocation of the railheads. These discussions have confirmed that there is in principle
support for their relocation.
In terms of Figure 42 and associated text, the following should be noted;
● The haul road leading to the aggregates and freight lines is not consistent with other diagrams/figures within the AAP i.e. other figures do not include the haul road and possibly assume the aggregates and freight site are relocated;
● The narrow white/non colour strip between the aggregates and freight tracks should also be
part of the Aggregates Railheads site, and shaded brown;
● The plan does not show the full extent of the aggregates railheads , including land on Cowley Road;

●The AAP shows mixed and confusing details in relation to the aggregates railheads. It should therefore clearly demonstrate a situation which includes the retention of the aggregates railheads