Question 11 - General comments

Policy omission – The Historic Environment: Object Historic Environment Policy omission Whilst we appreciate that the historic environment is addressed to some degree in the design and heights policies, it is our view that the Plan would benefit from a specific policy for the historic environment. We fully acknowledge that there are no designated heritage assets within the site boundary. There are however heritage assets in the vicinity and, given the scale of the proposed development, there is the potential for development of this area to impact on the setting of those heritage assets. Those include assets located within the historic core of Cambridge, the character and appearance of the central conservation area (and in particular the eastern arm that extends along the river corridor immediately to the south of this site) and the conservation area of Fen Ditton to the east of the site, including the wider setting of the many listed buildings that lie within that conservation area. We have also been exploring with you the potential for wider impacts on assets such as Anglesey Abbey. In addition, there will be non-designated heritage assets including (unknown) archaeology which will need to be addressed. While we appreciate the site is largely brownfield, there may still be archaeology to be explored and addressed within the site, We appreciate that this Plan sits under the Cambridge City and South Cambs Local Plans and to that end can draw on the historic environment policies therein. However, we consider that there is also a case for a specific historic environment policy to address this particular strategic site. The policy should cover nearby heritage assets and the need to conserve and where appropriate enhance these, discuss the wider setting of the historic city and should make clear the approach to archaeology within the site (we suggest further discussion with the County Council in this regard). Suggested Change: Include a policy for the Historic Environment including heritage assets, the wider setting of the historic city and approach to archaeology within the site.

NEC APP, Planning Policy Team, South Cambridgeshire Hall, Cambourne Business Park, Cambourne, Cambridge. CB23 6EA Dear Councillors North East Cambridge Area Action Plan I am emailing you as I am concerned about your vision for North East Cambridge. These are my concerns: Need for the development Is this the right time to be planning such a large development of very high density housing? We are in an economic crisis when Covid-19 has meant a change to working practices. Is that amount of commercial space necessary with home working? Are the planned properties going to provide adequate homes or would prioritising gardens and outdoor space lead to better quality of life? Connected and integrated This relies on people being able to walk or cycle to work. It presupposes that everyone living there will be young and active and remain that way. Communities are a mixture of all ages and abilities but this development will not cater for them. Building heights and density Such high density (more than London or Paris) is not appropriate for this area. One and two bedroom dwellings in 13 storey blocks could lead to social isolation and lack of community feeling. It doesn’t cater for growing families. Are they expected to move out when children reach secondary school age? Open places Whatever open spaces are planned they cannot compensate for the loss of wide open green belt where the new WWTP is sited. Milton Park is not sufficiently big or open to accommodate so many people. Biodiversity The toll on flora and fauna caused by the construction process cannot be undone. The site chosen for relocation of WWTP for this development will suffer. Discouraging car use Not everyone will be able to walk or cycle to work. As people age or their families grow they will be reliant on cars. I understand that to register for this consultation my name will be published with my comment, but that, in line with your privacy statement, my contact details and other personal information will not. Yours sincerely, Rosanna

From: Owen Smith Sent: 05 September 2020 20:31 To: North East Cambridge AAP <nec@greatercambridgeplanning.org> Subject: Why do I have to create an account to comment on NEC Area Action Plan? The consultation on the location of the new waste water treatment plant does not require me to create an account in order to comment. So why does this? I hate all these systems that insist on creating accounts, they are just trying to harvest my data and sell it to businesses. By insisting on an account creation, you have denied me the ability to comment online on the NEC Area Action Plan. I work , it is a nice place to work. Your plans will destroy it. I have my car serviced at Barr-Tech off Cowley Road, your plans will force them to relocate. I live and value the fact that the area between Milton is not entirely built up. Your plans will join Milton to Cambridge in a high rise conurbation. I am opposed to all you plans, the area under discussion is fine as it is. Stop trying to make profit from everything. -- Owen Smith Cambridge, UK

Healthwatch Cambridgeshire and Peterborough North East Cambridge Area Action Plan: Consultation response Healthwatch Cambridgeshire and Peterborough welcomes the opportunity to comment on the Area Action Plan for North East Cambridge and is supportive of the aims to develop an integrated low carbon community. Our Healthwatch hears from many people regarding their difficulties accessing health and social care services. We are aware of the pressure on GP services, in particular. It is a major concern for local people that housing growth will bring increased pressure on services and that they will experience even more waits to obtain GP appointments. Healthwatch Cambridgeshire and Peterborough is also aware of the complexity of commissioning health provision and strongly recommends that all organisations work together to ensure that developer contributions are used in a timely manner to improve local services and that local people are effectively involved in designing and planning community and service provision. We would also like to highlight the importance of affordable and accessible leisure and outdoor exercise facilities and the benefits that this brings for community wellbeing. Sandie Smith CEO, Healthwatch Cambridgeshire and Peterborough 1st October 2020

Dear Sirs/Ladies,What are you doing?Putting a megacity in the Cambridgeshire countryside,thus ruining the latter?Vitally,WHERE WILL YOU GET ALL THE WATER?Everywhere I look ,I hear of acquifers ,streams.and rivers drying up.The Milton sewage plant was only recently upgraded,for £20million,why waste that?Just to move it where there is no infrastructure for it?Total waste of money,ruining at least four villages in the process. Not to mention the possible legal costs when said villages start suing for loss of amenity.Not to mention the Marleigh development fiasco,w.hen they presumably withdraw or sue on finding themselves in the middle of urban sprawl and a sewage complex.Does anyone really want all this?Yours,Fardijah Freedman PS I have seen urban sprawl in America -it's awful

I am concerned about your vision for the development of North East Cambridge. Firstly I would question the need for this development post COVID. And think that it would be wise to stop , reflect and review if this is a good use of public money. I think the particular development design is more suited to London than historic Cambridge. I am concerned that a development of this nature is not “connected” architecturally to the local area. It would appear to me to be a stand alone and possible “ghetto “ of the future . I strongly object to using Green belt land to relocate the sewage works to facilitate this development. There are so many arguments , which you will be aware of , to support the need for all the Green belt land we have. Not least the bio diversity that this land supports. That is recognised for a healthy population and planet. Do we not owe our children this ? As far as discouraging car use. Of course , but consider too if the money could be invested to provide better cycle ways to connect the existing outer villages with Cambridge city centre. Lastly the idea that Milton country park can support the recreation of the residents of the development is unrealistic.

I represent Barton & District Bridleways Group (140 members) and also the BHS as an Access & Bridleways Officer. This email is in response to the Draft North East Cambridge Area Action Plan consultation survey. This survey makes no mention whatsoever to equestrians and as such it fails to meet the requirements of the Cambridgeshire and Peterborough Local Transport Plan (LTP), as Active Travel is defined in the plan as pedestrians, cyclists and equestrians. This is unacceptable and the complete omission of equestrians from the non-motorised user transport and travel sections needs to be corrected. Everywhere in the document where cyclists and pedestrians are mentioned it should also mention equestrians. It is not good enough to say that horses do not live in urban areas and therefore do not need this access. There are many equestrians located in and around Cambridge city and its rural surrounds on all sides. Horses live within the city confines and are regularly ridden across, through and around it. Any crossing of any major transport barriers, road, rail or river, needs to provide access for equestrians as well as pedestrians and cyclists. Please find below a list of equestrian access that should be provided in this area: Safe off road access for Equestrians from Waterbeach to the Guided Busway bridleway. Greenway link between the Waterbeach Greenway and the Guided busway. Access for Equestrians to the Jane Costen bridge or an equivalent safe alternative. A peripheral bridleway, similar to the peripheral bridleway at Cambourne, with links to existing rights of way. Creation of new Rights of Ways for NMUs to help link up the fragmented ROW network, particularly Bridleways and Byways, providing essential. safe links between villages. The Chisholm Trail should also be usable by equestrians as well as cyclists and walkers. Equestrians are equally vulnerable and also need safe routes across the city. This project no longer complies with the requirements of the LTP and needs to be reviewed. The Genome Trail path from Shelford to Addenbrookes should be open to equestrians. Mere Way is a Public Byway and therefore open to walkers, cyclists, equestrians. This is shown incorrectly in this plan. Because of the fragmented nature of the bridleway network in this country, equestrians have no choice but to use the roads, which of course are becoming more and more busy as new houses are built, and with this brings more accidents and near misses on the roads affecting equestrians. Horse riders are one of the most vulnerable road users. Equestrian accident statistics In the UK the period November 2010 to March 2019 road incidents involving horses : 43 humans died 315 horses died 3757 incidents were reported to the British Horse Society (BHS) although it is believed that this represents only 10% of the actual incidents. The East of England is one of the regions with the highest accident rates. Recently in Girton a car had to do an emergency stop to avoid hitting a horse rider after coming round the bend. Luckily no one was hurt, but the vehicle behind did hit the car in front. This could have been avoided. Horse riders currently only have access to 22% of public rights of way. The provision of safe off road hacking for equestrians has many benefits. Horse riders are mostly female and a lot of older women also ride, two groups who are known not to take regular exercise. However horse riding and all the related horse care provides regular exercise, along with the benefits of mental well-being, as horse therapy is well known for relieving stress. We should therefore be encouraging this group, along with all other horse riders to get out into the countryside and enjoy this rural pursuit, however this becomes less attractive if the only place to ride is on the roads. In the North East Cambridge Area the GCP should be looking towards creating a cohesive joined-up Rights of Way network, suitable for all user groups, equestrians, cyclists and pedestrians. Care should be taken not to put any one user group, such as equestrians, at risk in the provision of access for others, endangering equestrians with potential fatal consequences. In the provision of access the surfacing of paths should be carefully considered to avoid urbanisation of the countryside. Roadside access should where possible be screened and separated from the road by provision of hedging/vegetation, such as the roadside path at Quy. Such roadside paths should be suitable for all NMU users including equestrians. This would also help with provision of biodiversity and encourage free movement of wildlife by providing safe connections. This email should please be counted as a response to your survey. As equestrians were not specifically mentioned in the survey it was difficult to respond the the questions directly.

Sewage Works leaves bad smell The whole idea really is quite bonkers. Moving a sewage works that Anglian Water had advised us does not have to be moved, from an operational perspective, and where the current site is large enough to build a new, less odorous and carbon-neutral treatment plant. The cost of decontaminating this site will be high, the time lengthy and unlikely to be without some issue. To maximise profit, this is to be counterbalanced by building high density offices and housing, including 13-storey high rises, we are told. What will they call this new development I wonder, Milton-on-Sewer? Cambridge certainly needs some new low cost housing but surely we should offer our residents better than this. Furthermore, how will this complement a city with some of the best and historic architecture in the country? We can do better, surely. Is this development what the people of Cambridge really want or need? The City and South Cambs District Councils will be hard pressed to prove it, as they will need to do to fulfil the requirements of the HIF grant. The Covid-19 pandemic has changed the world, in the way we work, perhaps forever. Furthermore, the uncertainty Brexit has created and the strained relationship with China creates a perfect storm of unpredictability for economic growth. The country is in the grip of a recession that could last for several years. Until the future is clearer, should this consultation even be taking place? Surely, at the very least, it should be put on hold until the path ahead is visible. All the data and modelling to predict the economic growth of Cambridge, office space and housing need, was undertaken before the pandemic and the current economic crisis. In the future it is possible, if not probable, that more people will be working from home. We will really need more office space when so much currently stands empty or underused? Fundamental housing design of the future may need to change, for example, to incorporate a realistic ergonomic workstation and separate space, moving away from the current trends of open space living design. The council needs to call a halt to this consultation now, wait a while and then reassess...and do much better for the people of Cambridge. The traffic modelling for this nightmare "vision" is very dubious. It is assumed most people will walk or cycle. When will these middle-aged men in lycra realise that life isn't always that simple. For approximately 70 per cent of us, cycling to work cannot be an option. Many residents will work away from the area; life moves on, jobs change, families grow. We are advised that the average national commute is 40 minutes. It is just not viable for time-restricted working parents with young children of different ages, needing to be delivered to different schools, the elderly and those with disabilities. The impact of even an extra 5,000 cars on Milton Road (approximately half a car per house) and cars of those working on site, will be considerable and air pollution will be increased substantially. With allowable parking space of half a car per home, many cars will be parked in the narrow streets. Have the developers allowed for this when they tell us that emergency vehicles, delivery lorries and dustcarts will be able to traverse them? It is almost beyond belief that in order to build on this brownfield site, that green belt land is to be sacrificed to build a new sewage works, if these plans go ahead. Even the empire-building Mayor of Cambridge agrees, we need our green spaces and building on green belt is against government policy. The inclusion of Honey Hill as one of the potential site options, threatening the whole Wicken Fen Vision, is frankly shameful and unforgiveable. It is also of note that there are no current plans to build a new secondary school and how will our roads and hospitals cope in the short term? It will be the tax payer who is left to pick up the deficit when ill thought out schemes go over budget. The 'Vision's' suggestion that the voluntary sector can fill in the gaps, is quite frankly, naïve. Many charities are struggling in the current economic crisis, many won't survive and is there really going to be the money to provide social services when cuts have already been made to the city's social care budget? The effect of ill-considered over expansion could be devastating for the city. Look to Ireland, where the Celtic Tiger over expanded and suddenly went into sharp recession, hundreds of ghost developments of empty new houses, ultimately requiring the UK to provide financial bailout. Building your way out of a recession is only viable if there is demand and this is the crux of the matter, there simply won't be this demand in the foreseeable future. I am also concerned about the efficacy of this "consultation", when U +I PLC Developers, were actually appointed as the contractors to build the new development on the current sewage works, back in July 2018. The whole consultation frankly leaves a bad smell and is flawed. Our councillors need to stop and rethink this whole, ma(illegible)money-driven scheme.

After studying the North East Cambridge Area Action Plan and attending/ engaging with the webinars, Histon and Impington Parish Council do not support the current NECAAP. Our key reasons for not supporting the action plan are listed below: • You state building on 182 hectares of brownfield land. Releasing some of this land will involve the loss of greenbelt land due to the relocation of the current sewage works. Histon and Impington Parish Council do not support the loss of greenbelt land. • The maximum storeys of the proposed buildings are incompatible with a historic city of the likes of Cambridge. • The majority of residents in tall buildings will rely on good mobility due to the introduction of single person lifts which will also impact deliveries of furniture and white goods. • The noise of high-density dwelling needs government to agree to change building regulations and design criteria. • Deliveries of furniture and white goods to the proposed homes have not been considered. Such deliveries will often require large goods vehicles which will have serious access problems. • The dwellings and jobs are likely to result in the majority of workers commuting in to the area negating the concept of sustainable, walking cycling area • Ideas of daily waste collections at surrounding development have been refused by SCDC in the past. This would make daily collections unlikely hence larger waste storage would be required. • The Milton Road roundabout will be a core transport link and is already at capacity before the A10 upgrade and new Cambridge Police station has been built. • There is a big concern regarding the 40% affordable housing not being enforced. • The whole area with its high density will be unlike other parts of Cambridge, making it difficult to integrate it with the rest of the city. • It is unclear what the green roofs will be used for: sports area, amenity space for flat dwellers, local growing areas to replace allotments. Which one? • Many residents will be afraid of using a dark enclosed tunnel to the nearby Milton Country Park due to heightened risk of perceived crime (for example) meaning a shortage of green space with a safe walking route. • Support from consultees on the principles are essential to ensure these principles are adhered to. • There is only one Nursery school. Young families will be attracted to this area hence this would appear inadequate. • The nearby Cambridge Science Park quote that employers are competing for top talent hence the majority of employees will be commuting in from outside the area hence likely to drive. It is expected new employers will search for the best talent wherever they reside making the walking to work principle unachievable. Added to our concerns above, we are deeply troubled by the overall concept. With the proposed balance of new jobs (20,000) and new dwellings (8,000) and the similar imbalance on the Cambridge North Railway Station development, we estimate, on even the most generous assumptions, on the numbers living in NECAAP and commuting to London, spouses working outside the area and number of economically active persons per dwelling much higher than the national average, that at least 15,000 people will need to travel into the area for work. The strictures on no investment in access road infrastructure and the over optimistic estimates of facility for modal shifts form what will be a considerable catchment area, leading us to the conclusion that this is impractical and unrealistic. We have heard the passionate support of the concepts from the planners involved. Our fear is that this will become the new "Harlow"; planners being praised and lauded for designs on paper but lambasted in future for the designs in concrete. We consider many of the details (e.g. on deliveries to dwellings, use of stairs, assumptions on travel to work modes) all together are a recipe for disaster. Yours faithfully Histon and Impington Parish Council.

Dear Sir/Madam Draft North East Cambridge Area Action Plan I refer to the recently published Draft North East Cambridge Action Plan (NECAAP) which is currently the subject of a consultation exercise. The National Trust has significant land holdings in the locality of the North East Cambridge Area and has therefore considered the potential impact on that land from the proposals within the draft NECAAP. The Trust owns Anglesey Abbey (a Grade I Listed Building set within a Grade II* Registered Park and Garden and an estate which extends to over 46ha) and approximately 800ha of land at Wicken Fen, a National Nature Reserve and designated SSSI and an internationally designated Special Area for Conservation and Ramsar site. Beyond its own landholdings, the Trust has an interest in the extensive area of land in the corridor between the River Cam and the B1102 stretching from the A14 in the south to Wicken village in the north. This land is recognised as the “Wicken Fen 100 Year Vision Area” and the Trust, working with partners and landowners, has a long-term ambition to see this 5,300ha area managed for nature conservation with improved public access for recreation, community engagement and learning. The plans for the site at North East Cambridge (NEC) are radical and ambitious, involving the proposed development of a whole new “city district” which will accommodate at least 8,000 new homes and deliver 20,000 new jobs within the 182 hectare site. This will be achieved mainly through redevelopment of the areas to the east of Milton Road (principally for housing) and the intensification of existing employment sites in the Science/Business Park area to the west of Milton Road. The site will also deliver 3 primary schools, retail floorspace, 10 hectares of public open space and safeguard a site for a secondary school. The NEC site has the benefit of proximity to Cambridge city centre and to public transport hubs (Cambridge North Rail Station; Guided Busway route) and strategic cycle routes and is well-located in terms of linkages to jobs, services and recreation. The indicative layout shows a hierarchy of streets that would limit vehicle movements (other than buses) within the residential areas and improve cycle/walking links with neighbouring areas, the city centre and the public right of way network beyond the site, particularly to the north and east. In the redeveloped areas there would be a vertical mix of land uses; a high proportion of affordable housing; energy/water efficiency designed into buildings and an expectation of 10% net gain in biodiversity throughout. Overall, the site scores very well against many indicators of sustainability: it’s a brownfield site; it’s well-located with good connectivity; it’s outside the Green Belt; it’s large enough to deliver a whole new community and provide both homes and jobs. In general terms, the National Trust would support the principles which guide this approach to the redevelopment of the site. Nevertheless, the Trust has serious concerns about the scale and intensity of development proposed for the NEC site and the consequences that this will have for the ongoing management of National Trust land, including the safeguarding of internationally designated sites within that land. The National Trust also has doubts about the deliverability of the modal shift that underpins the density of residential development that the Area Action Plan seeks to achieve. These concerns are set out in detail below. Residential density and deficiency in publicly accessible open space The intensity of residential development is radical and a distinct departure from existing residential neighbourhoods in the locality. Densities within the proposed development range from 75 dwellings/hectare to 385 dwellings/hectare with the vast bulk expected to exceed 225 dwellings/hectare. To achieve such high densities tall buildings (up to 13 storeys in the core of the District) are proposed across much of the land east of Milton Road. In addition to the high density of the residential development, there is very little of the NEC site that would not be developed land. There are only two significant areas of public open space proposed (totalling around 10 hectares) the largest of which is a “linear park” sited between high density blocks. The shape and context of a linear urban park clearly limits its range of use as it offers less potential for formal recreation (e.g. football pitches) or informal kickabout/dog walking. It is also not clear how much of this undeveloped space would need to be set aside to meet the need for Sustainable Urban Drainage (i.e. swales and lagoons to address flood risk). The 10 hectares would be expected to meet the needs of a population of around 18,000 people yet the pubic open space standards of the adopted Cambridge City Local Plan would expect a new population of this size to be provided with around 70 hectares in a mix of formal, informal, play and allotment space. Even the Open Space Topic Paper which forms part of the evidence base for the Draft NECAAP estimates that around 66ha of public open space will be required to serve the residential community within NEC. This means that the residential development would be provided with barely 15% of the open space provision that would be expected for a community of this size. A new community of the size proposed for NEC, served by so little useable open space will inevitably generate greater recreational pressure upon publicly accessible open space in the areas beyond the city fringe. The planned improvements to linkages to the existing public rights of way network could only add to that impact. The areas of open space that would be most affected are the Milton Country Park and the National Trust land at Wicken Fen. These are areas that will already be expected to experience increased recreational pressure arising from the recently approved developments at Waterbeach. This increased recreational pressure would have consequences in terms of the ongoing maintenance and management of National Trust land and could even pose a threat to the condition of the Wicken Fen Ramsar/Fenland SAC. In fact, prompted by the proposals for Waterbeach, the National Trust commissioned a visitor survey to establish the range/profile of its visitor “catchment” to Wicken Fen; how this might change as a consequence of the proposed expansion of Waterbeach; and the threat that additional visitor numbers would pose to the Trust’s endeavours to protect vulnerable habitats within the Wicken Fen Nature Reserve (designated SSSI, Special Area of Conservation and Ramsar Site) as well as safeguarding the quality of the recreational experience that Wicken Fen and the Vision Area offer to visiting members of the public. I have included a copy of the Footprint Ecology Report with this letter for information. The Footprint Ecology Report is a robust piece of research which shows the extensive size of the catchment for visits to Wicken Fen and the high proportion of repeat visits made by local residents, many of whom are accessing the site via the Public Rights of Way network. The proposed development at NEC would add a significant population to the local area and, without adequate provision for recreation within the site, the inevitable consequence is increased pressure on sites like Wicken Fen. It is of note that the draft Habitat Regulations Assessment (HRA) that accompanies the Draft NECAAP is very clear about the threat of increased recreational demand at Wicken Fen arising from the proposed development and it also makes reference to the Footprint Ecology Visitor Survey results. The relevant extract from the HRA states: 5.30 Wicken Fen Ramsar and a component part of Fenland SAC are located 10km to the north-east of North East Cambridge boundary and is subject to high levels of recreation every year. The National Trust records over 65,000 visitors to at their visitor centre with more people using the access network in the Wicken Fen Vision Area each year. Following a recent visitor study of the Wicken Fen Vision Area, visitors to the European sites comprised of first-time visitors travelling a greater distance in the wider area and visitors from the local area who visit the site two to three times a month. 5.31 Key activities undertaken by visitors to the European site included dog walking and walking. Other activities recorded at lower levels included cycling, bird/wildlife watching and photography. These activities have the potential to adversely affect qualifying habitats of the Ramsar site and SAC, which are fragile and susceptible to damage and disturbance to vegetation from trampling and illegal activities, such as bonfires and vandalism to contamination from litter and dog fouling and disturbance of livestock from dogs, which prevents the successful management of habitats being grazed. 5.32 Although, the Information Sheet on Ramsar Wetlands for Wicken Fen Ramsar and the Standard Data From and Natural England Site Improvement Plan for Fenland SAC do not highlight recreation as a key threat, due to the high levels of visitors to this site there is potential for impacts to the qualifying feature of the Ramsar site from recreational pressure to occur. Given the NECAAP will result in the provision of an additional 8,500 dwellings within the 20km ZOI for these sites, there is potential for AEoI (Adverse Effect on Integrity) to occur alone and in-combination with the Greater Cambridgeshire Local Plan and other surrounding local authorities without any mitigation measures. 5.33 The Ramsar site and overlapping SAC are well managed by the National Trust. Existing management measures are expected to provide some level of mitigation for increased recreational pressure to the sites. These measures include controlling access to the site by requiring permits before entry, zoning remote areas away from the central hub to protect habitats from damage and disturbance and engaging with visitors at their visitor centre. However, it is recommended that discussions are undertaken with the National Trust to determine exact measures that will be required to mitigate for impacts to Wicken Fen Ramsar and Fenland SAC. This will be undertaken alongside the development of the NECAAP and will be outlined at a later iteration of this report. Unfortunately, the draft HRA makes the assumption that the delivery of sufficient recreation space within the development will help to mitigate the impact of the increased recreational pressure arising from the new development. However, as outlined above, the proposed development falls far short of the public open space provision required by the adopted Cambridge City Council Local Plan and falls even further short of the green space provision recommended by Natural England in their response to consultation on the earlier Issues and Options report on the NECAAP. The Natural England recommendation, as advocated by the Suitable Alternative Green Space (SANGS) Guidance, is for 8ha/1000 population. This would equate to a provision of over 140 hectares of green space in the NEC site. The draft HRA recommends that the green space provision advocated by Natural England is implemented within the development “to ensure that increased demand for recreation is focussed away from Wicken Fen Ramsar and Fenland SAC”. This clear recommendation within the HRA has not been reflected in the draft policies of the NECAAP that concern provision for public open space. In fact, despite stating that there is an “expectation that all open space requirements will be met on site”, Policy 8 allows for under-provision of strategic open space where the development site is too small, or provision can be made off-site through way-finding or increasing capacity at neighbouring areas of public open space such as Milton Country Park. Surely, the Action Area Plan is the appropriate place to identify the required area of open space rather than to encourage a piecemeal approach that will fail to deliver the scale and range of space required. This failure to secure adequate recreation space within the NEC site raises serious concerns for the National Trust’s ability to prevent a consequent detriment to the integrity of designated European Sites for which it has responsibility. In addition, no approach has been made by the Greater Cambridge Partnership to the National Trust to “determine exact measures that will be required to mitigate for impacts to Wicken Fen Ramsar and Fenland SAC” as recommended by the HRA. This dialogue should ideally be developed with the organisational leads of the Cambridge Nature Network (Cambridge Past Present and Future and the Wildlife Trust) and should explore further research into the scale and impact of the increase in recreational pressure at sites beyond Cambridge (building on the Footprint Ecology work) and the scope for alternative off-site provision of green space to serve the new community. Assumptions about the level of car use The allocation of land use within the Draft NECAAP relies on a very optimistic assumption of the level of car use by residents of the new community. The car parking standard that would apply is a maximum of 0.5 spaces per dwelling, most of which would be accommodated in “car barns” (multi-storey car parks). Certainly, the prospects of achieving high levels of cycling and walking are better on a site at the edge of Cambridge than elsewhere in the country. However, there doesn’t appear to be any evidence to show that such a low level of car parking provision has been achieved in other similar scale developments within the UK or Europe and, if this low level of provision proves over-optimistic, the consequences for the quality of the residential environment could be dire. There have certainly been cases elsewhere in East Anglia where a lack of sufficient provision for car parking (due to ambitious maximum parking standards) resulted in unwelcome on street parking that obstructed public transport routes and access for emergency vehicles and compromised safe pedestrian movement. The high-density nature of the proposed development leaves little scope to address the problems that might emerge if the shift turns out to be from petrol car to electric vehicle, particularly for families. Potential impact on water quantity and quality at designated sites The draft HRA highlights the potential impact of the development upon water quantity and water quality at European designated sites in the locality. The HRA confirms that in the absence of a Water Cycle Study it cannot be concluded that there will not be adverse effects on the integrity of the Wicken Fen Ramsar/Fenland SAC. It is understood that a Water Cycle Study has been prepared in connection with the Greater Cambridge Local Plan and that this takes into account the development proposed in the Draft NECAAP. Beyond the requirement for a Water Cycle Study to determine whether measures can be secured that would ensure that adverse effect are avoided, the HRA recommends a commitment to a Water Recycling Centre that can cope with the additional demand (for sewage treatment and waste water capacity) that will arise from the development. The Trust is aware that the development of NEC is predicated on the relocation of the Milton WWTP, however, the new site for the WWTP has not yet been settled and the proposals will be subject to the Development Consent Order process. In advance of this decision, the Trust would hope for an assurance that whichever site is chosen for the new WWTP, it will be designed to meet the increased demand in a manner that avoids any adverse effects on the integrity of the Wicken Fen Ramsar/Fenland SAC in relation to water quantity and quality. In conclusion, the draft NECAAP envisages an extremely ambitious intensity of development for a site at the edge of Cambridge’s urban area. The strategic vision for the site is: an inclusive, walkable, low-carbon new city district with a lively mix of homes, workplaces, services and social spaces, fully integrated with surrounding neighbourhoods. Curiously the strategic vision makes no reference to the recreational needs of the new community and the serious deficiency in green space provision causes the National Trust to raise objection to the intensity of residential development that the Draft NECAAP aims to deliver. Judged against the standards of the adopted Cambridge City Local Plan, the proposed residential development within NEC would be provided with barely 15% of the quantum of public open space expected for a community of 18,000. The dramatic deficiency in the scale and range of open space provision will generate increased recreational pressure at neighbouring publicly accessible green spaces, including the Trust’s Nature Reserve at Wicken Fen. Without adequate mitigation this increased recreational pressure has the clear potential to cause harm to the integrity of the Wicken Fen Ramsar/Fenland SAC. These concerns have been highlighted in representations at the Issues and Options stage and through the HRA process but have not been properly addressed in the Area Action Plan. This failing, compounded by a very optimistic assumption about the level of car use, would deliver a less than satisfactory living environment for the new community and potential harm to sensitive environments beyond the site. The National Trust considers that these matters need further review and research (following dialogue with the organisational leads for Cambridge Nature Network) into the scale and impact of the increase in recreational pressure at sites beyond Cambridge and the scope for alternative off-site provision of green space to serve the new community. Yours faithfully Tessa Lambert Tessa Lambert BA (Hons), DipTP MRTPI Assistant Planning Adviser (East of England)

Cambridge Ahead welcomes this opportunity to respond to the draft North East Cambridge Area Action Plan consultation. Our comments here follow directly from our input to the development of the next Local Plan for Greater Cambridge in February of this year. Plans for North East Cambridge should reflect that it is a key employment site for the City, with significant scope for employment creation in high-value knowledge intensive industries, and therefore should contain ambitions for higher levels of employment than have currently been identified. The North East Cambridge site has the unique and enviable position of being the strategic growth site best served by public transport with the railway, busway, motorway linked to the park & ride site, and cycling and walking connectivity. Therefore, strategic planning for this site should be ambitious in making best use of this connectivity to maximise high-value job creation for the future of Greater Cambridge. Our input to the Local Plan for Greater Cambridge was based on the recommendations made by the Cambridgeshire and Peterborough Independent Economic Review (CPIER) and was supported by significant data and modelling. It put forward a spatial vision which we believe will unlock high-value jobs, spread Cambridge clusters outwards across a wider footprint, support major shifts towards sustainable travel and improve the environment and sustain quality of life for local people. Central to our proposal was the densification of five strategic employment sites, to be supported by strong public transport connectivity. These would support the high levels of employment growth in the city, which in recent years has been significantly higher than forecast and are set to continue. The Cambridge North East Site is identified as one of these key employment sites because of the current low-density nature of the site and because of its position along key transport corridors into the city. The proposals set out in the draft North East Cambridge Area Action Plan do not meet the level of ambition that we believe is required to support future employment growth in the area. A higher level of commercial allocation should be considered to expand the available floor space and create capacity for many more new jobs in the area. Analysis from the Centre for Business Research shows that employment on the existing three parks within the area; Cambridge Science Park, St John’s Innovation Centre and Cambridge Business Park, is already at 12,500. Proposals to create space for 20,000 jobs would therefore only leave an available capacity of 7,500 for future growth over the next 20 years. The modelling to support our spatial vision suggested that for the North East Cambridge area as a whole, there exists potential for between 29,200 and 38,700 jobs by 2041. Cambridge Ahead recognises the uncertainty created at the current time by the Covid-19 pandemic. The long-term implications on employment growth potential are of course yet to be known. But our view is that whilst the footprint of commercial space and use of the transport network may vary, the employment creation opportunity of Cambridge (and therefore this strategic site) is unlikely to vary dramatically over the period to 2041. We feel that bringing data and insight to the table that helps us collectively understand more about what the impact will be on our economy is now crucial, which is why we are working with partners locally to develop a number of short-term and long-term research inputs. However, even allowing for a slower level of growth than previously anticipated the Area Action Plan proposals do not go far enough. We must ensure that in the current environment of uncertainty, we to do not miss an opportunity to plan in the right way for the future. As we develop plans for North East Cambridge, to guide the long term development of the area over the next 20 years, it is essential that we take the opportunity to support jobs and continue to enhance the Greater Cambridge economy. We welcome the opportunity to work with the Greater Cambridge Shared Planning Service in any way we can to overcome barriers which might exist to higher levels of densification on the site, rather than risk missing this crucial opportunity.

Why we are commenting on the North East Cambridge Area Action Plan The Cam Valley Forum is a voluntary group, established in 2001. We are an association of local individuals with diverse environmental, recreational, academic and business interests, concerned directly or indirectly with the River Cam. Our interests embrace not only the main river within the city, its ‘beating heart’ and one of the most intensively-used stretches of water in Europe, but also the smaller watercourses that convey water through the fields and villages, local towns and Cambridge suburbs. Our mission is to be the voice for the River Cam, defending its health and wellbeing for its wildlife, environment and everyone that enjoys it, and safeguarding its historical and cultural importance. In this role, the Cam Valley Forum speaks for the very large number of local people who value its heritage, beauty and recreational value. Last year, our River Cam Manifesto revealed widespread support for our now diminished Chalk-stream fed river. This year our recent report ‘Let it Flow!’ - addresses the fact that the River Cam is no longer the river it once was. This is the driest part of Britain and potentially the fastest growing in human population! Those two facts are now on a collision course. The way in which we currently demand so much water for so many things - our own personal domestic supply, our recreation, our food production and our lowland and wetland wildlife - needs much more careful planning. Moreover, we cannot rely on past ways alone for solving our own selfish water needs. ..................................... What follows are our responses, with our insights and interests, to your listed concerns, 1, 2, 6, 7, and 10. 1. The Vision: Broadly, we do recognise the need to provide more low cost housing for the city, this is a crying need; but the density, scale, social, environmental and infrastructural deficiencies of this plan are grossly inappropriate and frankly demeaning of Cambridge City as we have known it and as it might be. Even the location of this plan is deeply worrying. The Anglian Water Milton Sewage works has spare capacity now and could be improved further without a move to any of the proposed smaller sites in the green belt. All we hear from our communities and observe from the local press is that this scale of development really has not been thought through sufficiently and appears to be driven by a myopic central government focus on the South East and an unwanted local growth agenda. It appears largely driven by business interests, and with scant regard to environmental factors and, centrally, to human wellbeing. If, however, after all sensitive and pragmatic considerations are taken on board and what is proposed still gets the go-ahead we would like you to consider a re-focus on the following concerns of the Cam Valley Forum. 2. Walking and Cycling Connections. With respect to walking and cycling, access should be provided to adequate open space. Milton Country Park will be possibly accessible, by bridge or tunnel under the motorway, but it is already heavily used, without an influx from 8000 extra new homes. Much of Cambridge has accessible green space for local residents. There is nothing here that is comparable in terms of easy urban access. At present there is a riverside path from Chesterton to Baits Bite Lock. It is used by walkers, dog-walkers, anglers, cyclists, rowing interests etc., and is already at times very congested and hazardous. Added pressure from the new residents on this route will therefore need to be carefully managed. A substantial buffer area between new buildings and the river needs to be protected for nature and informal recreational use. Where possible, opportunities to segregate walkers and cyclists within and around the development should be seized. 6. Heights and densities. Whether you are housed in them, or whether they are on the skyline it is not in any way desirable to have ten storey buildings around the periphery of Cambridge. The initial Landscape Study claimed that tall buildings would be invisible from the towpath hidden behind hedges and trees. But the views of the Cam in its own floodplain, from Stourbridge Common and Ditton Meadows matter greatly to us. They will not be graced at all by what is proposed here. Stourbridge Common is an historical site of significance. Stourbridge fair held annually on Stourbridge Common was, at its peak, the largest fair in the whole of Europe. 7.Public Open spaces. Widely viewed as the best current example of progressive, environmentally sound social housing, the Goldsmith Street development in Norwich, has a density of 83 households per hectare. For Brookgate and the Sewage Works 225 to 385 households per hectare are envisaged. It is already offensive to many current residents of the Cambridge area that access to open space is currently inversely correlated with personal wealth. The poor in Cambridge City have least access to nature and open spaces. This will be the more so here with this development. Large cities in the UK typically average an area of green space at one fifth (20%) the total area. It is typically greater in Cambridge City at present. What is proposed here is 10%. If this happens we ought be ashamed. If this development must happen then Chesterton Fen should be protected and managed as a ‘Nature Park’, a green lung accessible by a purpose built, railway bridge. There would then be an opportunity for wetland re-creation and a genuine benefit to present biodiversity losses. 10. Climate Crisis. A year ago we rang alarm bells for the health of the River Cam and, in our support, the Cambridge City Council declared an environmental crisis - with, in part, our depleted Chalk groundwater and our diminished river flows in mind. We are concerned not only about pressure on currently unsustainable water use and infrastructure but also about climate change. These effects are real and need to be reflected in wiser choices. (a) Water: water use targets. The North East Cambridge Area plan envisages water consumption of 110 litres per person per day. The city currently uses about 140 litres per person per day and is asking for economy. At present it seems likely that the Government will implement only a national standard of water economy on North East Cambridge Area building regulations. The Cambridgeshire regional water stress, that we have highlighted (which is to large extent acknowledged now by the Environment Agency), is still not regarded as sufficiently important by central Government. Cambridge University, to its credit, designed and built the Eddington development with an 80 litres per person per day target. This however had extensive grey water and rainfall capture/recycling built in. The same standard needs to be adopted in the North East Cambridge Plan. The local plan should require the new development to be ‘water neutral’. Hence, any additional demand for water should first be minimised - through innovations such as those used at Eddington - and then further offset by water efficiency programmes in existing local social housing, schools, hospitals and other public buildings We know that all water companies are obliged to supply to demand and that even by pursuing water neutrality, they will still have to find the water for this development. The task is likely to fall to the Cambridge Water Company whose supply area it is. They take their water almost exclusively from the Chalk. The Cam Valley Forum are asking that the company should be required instead to meet any new demand through water transfers from non Chalk-aquifer sources.. As there is an intercompany pipe supply network this is surely a possibility. (b) Global warming Greater Cambridge Partnership need to do some longer term planning for climate change. Two immediate hazards are on the time horizon now. Firstly, climate change includes longer and hotter summers which exacerbate soil moisture deficits and will undoubtedly make aquifer recharge harder - possibly even with the cessation of abstraction. The needed aquifer recharge is not occurring in a large fraction of current winters. Secondly, and no longer trivially, over recent decades the forecasts of when sea level rise will have its impact are accelerating. This is due very largely to thermal expansion as well as glacial melt. Massive earthworks may be needed to defend our lowlands and fenlands, which pale into insignificance beside the necessary infrastructural changes to water supply. In the most recent interglacial periods the sea has been up to just north of Cambridge more than once. The North East Cambridge Area site is at most 10 metres above sea level (OD) and some is lower, the Cam as it exits Cambridge is 5 metres above OD. Should such a building project be undertaken at all here? Zero carbon infrastructure is needed now in the UK and very soon globally and even then it will take many decades for our anthropogenic greenhouse gas reversal to impact on ocean warming. If the EA are already planning for a planned retreat and North Sea ingress, how will Cambridge be impacted? Stephen P. Tomkins (Chairman CVF) 5th October 2020

Message: I am very concerned at the number of planned residences. NE Cambridge has been continuously developed since 1950s. SW Cambridge has been untouched. Is this a bias to protect the Newnham area and the University precincts. The green space and biodiversity ambitions are completely inadequate. Why no open wildspace like Eddington/ Trumpington Meadows/Hobsobs Park? This reinforces the Councils prejudices against the working people of north Cambridge! In the same way that housing developments were proposed for St Albans recreation ground. I have politely written to Cllr Herbert about green matters but have not had the courtesy of any response - and I'm a member of the Labour Party! This is an opportunity to reinstate the wet water meadows of Chesterton Fen to link with riverside habitats and Ditton meadows and create genuine wildspace. Milton Country Park is already heavily used. The proposals to build 13 storey flats is completely out of character - you know this. It is just part a a strategy to maximise the number of units. Will there be a public meeting to discuss your proposals? Bob Jarman 3.10 20

Subject: Living near busy road can stunt children's lung growth, study says - BBC News Hi Reference North East Cambridge Area Action Plan I wish to object to the proposal to build 8000 home next to the increasingly busy A14 and Milton Road as there increasing evidence that the pollution from road fumes from vehicle exhausts , tyres and road noise can seriously damage the health of people who live nearby. I attach one of the many articles on this subject and I request a full environmental report is prepared prior to the Planning discussions. Kind regards Jonathan Barker https://www.bbc.com/news/health-50467700

From: Sent: 24 October 2020 10:22 To: North East Cambridge AAP <nec@greatercambridgeplanning.org> Subject: Small increases in air pollution linked to rise in depression, finds study Small increases in air pollution linked to rise in depression, finds study https://www.theguardian.com/environment/2020/oct/24/small-increases-in-air-pollution-linked-to-rise-in-depression-finds-study?CMP=Share_iOSApp_Other Sent from my iPhone

Dear councillors, I am concerned about your vision for the redevelopment of the North East of Cambridge and wish to comment on the following points in the proposed development: Rationale for redevelopment: the need for this major development has not been well articulated and indeed seems very doubtful to me. Rather than clearly being based on the needs of the community, the proposed development seems to be designed to capture maximum value from the government "City Deal". The proposal includes over 275,000 sq.m of new office space, and yet we see employers in the area closing offices, and large amounts of commercial property standing empty. This trend is likely to continue in the coming years as we feel the effects of Brexit and the ongoing impact of, and economic uncertainty from the coronavirus pandemic. The plan calls for a large loss of green belt land to move the water works; in my view, if such encroachment into the greenbelt is necessary, the wider community would be much better served by carving out smaller pieces of green belt land all around Cambridge, each served by the existing villages (this would also substantially reduce transportation and infrastructure pressures), and existing surplus office space could instead by re-zoned and converted into residential accommodation. Resilience: the proposal seems to presuppose that residents will find employment in the immediate vicinity, while not giving consideration to their families or to changing needs over time. Much of the employment in the immediate vicinity is high skill / high pay jobs in the science parks, but the housing being planned does not seem to cater to this demographic. In many cases, such households have growing families and want (and can afford) more space, space for working from home (many employers are emboldened by the successes of working from home this year and plan to continue offering their staff the ability to work from home on an ongoing basis), and want flexibility to cater for changing needs over time. Housing developments designed for resiliency provide for changing needs over time; for example, many households in more central parts of Cambridge have this year built or plan to build summerhouses in their garden or extensions/conversions to their home to better facilitate homeworking. Adapting to changing requirements is also incompatible with the plan to reduce car ownership in the NEC development – most obviously the plan to move car parking away from dwellings and into "car barns" makes car parking space unsuitable for future repurposing or adaptation. Conversely conventional garaging as part of the dwelling provides flexibility through re-purposing of the space for storage, art, craft and music space, home gyms, workshops or space for hobbies and "making" – the grassroots lifeblood that will ensure future generations will stay as innovative as Cambridge has been historically, providing fuel for starting future small businesses and enterprises. Having a space that can be used as such, or converted into more accomodation for a growing family, still achieves the stated goal of reducing dependence on cars. Private gardens could also work towards this goal, but they are also not provided for in the plan, despite 2020 giving us cause to appreciate private gardens even more than previously. Secondly, the goal itself (reducing car dependence) must be questioned in this planning context. Not everyone is fit and able to live without a car and the proposal discriminates against disabled or less abled people, older people and those not confident on a bike, families with young children, or families where only one of the adults has employment to the North/East of Cambridge. Finally, people change jobs, and should still be able to commute to jobs outside the pedestrian/cycle-commutable area. Building heights and density: I am very concerned by the proposed density and building heights. The density provided by blocks up to 13 stories high, with many of the dwellings one or two bedroom, is substantially higher than most of London, and runs a very serious significant risk of social problems and lack of community feeling. In my view, such density and height will, despite the best efforts of planners and developers, inevitably feel dystopian (like the infamous London tower developments, or the "projects" in New York City). There is no need for this in Cambridge. Such housing will also lack resilience and flexibility (as above) and outdoor space (very important for wellbeing, as we have all learnt this year). I am also concerned that insufficient consideration seems to have been given to views and sightlines around Cambridge. These dystopian towers will be some of the tallest buildings in Cambridge, and by virtue of our famously flat topography, will be highly visible from afar, including the few remaining wild open spaces in Cambridge (such as Stourbridge Common and the Fen Ditton Meadows– where existing developments such as the new hotel at Cambridge North station have already eroded the feeling of nature with its height and imposing unattractive stature). In my view, limiting building height to around 4-5 stories max would be appropriate for this area. Loss of natural spaces and impact on biodiversity: I am very concerned by the continual erosion of green spaces and trees in and around Cambridge. For example, in my area, the developments for the Chisholm Trail have resulted in substantial and careless loss of mature trees, hedgerow, and naturalistic areas. This NECCAP proposal will eliminate a large and valuable chunk of the green belt for the water works relocation, and will replace low density land in the development itself, much of which is open and well used by wildlife, with very high density urban development. The loss of biodiversity can not be compensated for, but at least an attempt should be made at atonement, through the purchase and establishment of much more open natural space around the developments. For example, Milton Country Park is very heavily used, and if the proposed development goes ahead will become very crowded. Substantial further land should be acquired and developed into similar naturalistic parks around the developments, for example if the proposed water works relocation were to take place, large woodlands/forest should be planted around it to screen it from view and provide some compensation for the loss of greenbelt space. Finally, I object to the "greenwashing" in the proposal around the role of cars and climate change; cars represent a small fraction of the carbon footprint in a development like the proposed, with concrete, construction equipment and energy use, and the ongoing energy use of the proposed dwellings dwarfing the contribution from private cars (especially given many of them will soon be electric, and all new cars from 2035). When viewed as part of a wider pattern in the Cambridge area, the focus on car carbon contribution seems like a thinly veiled excuse for the lack of a proper transportation strategy in the area, and the unmitigated disaster of the guided busway system. Lack of infrastructure: as mentioned above, the plans for transportation seem to rely on wishful thinking; that all residents will work in the immediate area and commute by walking or cycling, and move out before children reach secondary school age. Problems caused by lack of proper public transportation infrastructure (such as a Cambridge metro) will be made worse by the lack of a new secondary school in the plan. There is also no mention of a new police station or other emergency services. The plan also seems to imply removal of all or most of the car parking at Cambridge North station, which will cause further transport problems in Cambridge and ripple into the wider area with more congestion, more demand on train services, more demand for car parks at other train stations to the north of Cambridge (such as Waterbeach and Ely), and create more pollution by forcing more commuters to travel longer distances by car. I understand that to register for this consultation, my name will be published with my comments. However in line with your privacy statement, I wish to opt out of sharing my contact details, address, and any other personal information publicly. Kind regards, Hugo Vincent

Response to the Consultation on NE Cambridge proposed development The NE Cambridge development, works against the commitment to act on the climate and biodiversity emergencies declared by the City Council. A recent report ‘Absolute Zero’ from researchers at Cambridge University argues that the most difficult problem in meeting our climate change obligations is cement. Its manufacture releases emissions regardless of which process is used to produce it, and there is no viable alternative in sight at the scale needed for current, let alone projected, use. Consequently, any attempt to convey an impression that the new development in NE Cambridge will be ‘green’ is misleading. Claiming that the development will be carbon neutral is incorrect, not least because it won’t be taking into account all the carbon emissions produced overseas as a result of important buiding materials. Development on the scale proposed in the area will put untenable strain on an already stressed water system. Cambridge is experiencing rapid water depletion and increasingly poor water quality. Its iconic river, the Cam, has reduced flow and is experiencing higher polllution levels. It is predicted it will be stagnant within a very small number of years. The Cam and Granta now have a depth of 2 inches in places and at high summer the Granta has no flow. The chalk streams, described as the UK’s rain forest since we have 85% of the global number of such streams, which feed the Cam, are drying up. The flow of the Cam is maintained by ground water pumped into it by Anglian Water which has also leaked polluted water directly into the Cam. There is a continuing groundwater emergency which the Environment Agency has failed to declare and so the alarm evident to many can be ignored by those with a ‘growth at any cost’ mindset. The NE Cambridge development will exacerbate the water shortage in the region. Green spaces and biodiversity are already under development pressure. The assertion that the NE Cambridge development will benefit local low income neighbourhoods is hard to justify. These neigbourhoods are already losing open space to development (eg the go-ahead for council homes building recently given on land taken from St Albans Road recreation land). Creating bridge and tunnel access to a supposedly ‘high quality’ recreational landscape, while not directly improving open spaces in Arbury, Abbey and Kings Hedges will exacerbate differences. Moreover, claiming that introducing landscaped planting into what was previously a ‘brownfield’ site will increase biodiversity, may be disingenuous. According to Buglife in 2018, at least 12-15% of UK rare & scarce invertebrates are found on brownfield sites, including 194 invertebrate species of conservation importance such as 50 red data book and 131 nationally scarce species; 50% of rare solitary bees & wasps and 35% of rare ground beetles. Brownfields are some of the UK’s richest invertebrate sites on a par with ancient woodland. Growth does not distribute widespread benefit While the ‘growth theory’ approach to economics has promoted the idea that wealth ‘trickles down’ to those who are poorest, it manifestly doesn’t. If it did, Cambridge would not be reported as the most economically divided city in the country. Cambridge ranked highest on the GINI co-efficient - 0.46 (0 is equality, 1 is complete inequality), by a survey of 58 cities measured by the Centre for Cities. Additionally, according to the ONS in 2019, Cambridge had one of the highest gender pay gaps in the country. As ‘The Spirit Level’ has amply demonstrated, from inequality follows, amongst other things, poorer health, higher teenage pregnancies, bigger prison populations and an eroded sense of community. Cambridge Commons research shows that men in the most deprived areas in the city lived 9.3 years less than those in the least deprived; the differential for women is 7.4 years. The Joint Strategic Needs Assessment reports the gap in life expectancy between the least and most deprived areas in the city to be ‘noticeably high’ for both women and men. Differences between the poorest wards and the city as a whole reporting good and very good health relative to the national average is found to be statistically significant. Likewise, Cambridge is reported to have statistically significant higher than average levels of statutory homelessness, diabetes diagnosis, hospital stays for self harm and alcohol related harm, schizophrenia, bi-polar affective disorder and other psychoses. Rampant house building does not satisfy housing demand nor bring prices down. While Cambridge has seen the highest proportionate housing growth in England and Wales in the last 10 years (by 15%, almost twice the rate as London), unaffordability has risen, not fallen. According to research by the Centre for Cities which covered the 62 largest cities in the UK, Cambridge ranked 2nd on mean house prices in 2018 (but, in 2014, 62nd on mean welfare spend overall and per capita). ‘Affordable homes’ (priced at 80% of the market rate) in a city where house prices are inflated are not affordable to key workers such as nurses and teachers, and certainly not to others we depend on such as carers, bus drivers and shop assistants. Meanwhile, council homes do not provide the city with a permanent stock of homes for people on low incomes as long as there is the ‘right to buy’. Council tenants may buy their houses at 35% discount after 3 years tenancy (rising after 5 years, to a maximum of £84,000); their flats at 50% discount. Five years after their purchase, homeowners may sell their bought council house on the open market. Also, past experience suggests that developers approach council house owners with offers to help them buy the property and then sell it on. If national figures are anything to go by Cambridge can expect to lose 1 in 20 social homes (council and housing association homes) to the market between 2012 and 2022, as calculated by the Local Government Association. Four in 10 of those bought are now owned by private landlords. Growth means more pressure on already stressed infrastructure, while the city and region has an inadequate and environmentally polluting transport system The A14 has just been widened at a cost of £1.5 billion, and is unlikely to be able to cope with the commuter traffic generated by the 20,000 proposed new jobs based in NE Cambridge. Trains to and from London are full, and at peak times are standing room only. The idea that residents moving into areas will take jobs in those same areas is fanciful, and cannot be assumed and certainly not enforced. The opposite is the case in new developments planned on live-work principles, from Milton Keynes to Poundbury. Creating more jobs (c20,000) than homes (8,000) can only make the housing and commuting situations worse. Moreover, Post-Covid 19, there is increasing evidence that there will be a reduced demand for offices as businesses are commiting to reduce their office space, to benefit from more of the staff working at home. The growth agenda will undoubtedly benefit College landowners, big private developers, estate agents and other members of corporate lobby group Cambridge Ahead, but this doesn’t benefit residents, their associations and small independent businesses, whose voices need to heard more loudly than powerful lobbies. As an example of the failure of ‘trickle down economics’, and ‘rising tides lift all boats’ theories, Cambridge University is one of the unfairest employers in the city. Although the University adopted a living wage policy in 2018 for those it directly employs, only 8 of the 31 colleges paid all workers at or above a real living wage in late 2018 (£8.75), a time when Cambridge Colleges had a combined wealth of £6.9 billion . The college which paid worst (Robinson: with 128 staff on receiving below the real living wage, and with the lowest recorded wage of all the colleges of £7.38 an hour) has £89.5 million of assets, 25th out of the 31 colleges). Meanwhile, during the Covid-19 pandemic, some colleges (including Magdelene and Sydney Sussex), and the University Superannuation Fund have refused to negotiate lower rents for independent businesses. Two colleges stand to gain significantly, financially, by the NE Cambridge development, at the expense of local residents. Indeed, the involvement of Cambridge University in planning for growth, continues the undemocratic position it has held in the City for centuries. It has to be made transparent, in order that it may be challenged. We should expect all proposals to be honestly assessed for environmental impacts from the proposal stage onwards and rejected if they cannot contribute to the rapid improvements needed to address the climate and biodiversity emergencies. We should expect the City and its councillors to promote a vision for a just transition to a zero carbon city and area that reverses rapid biodiversity loss and then join with citizens to put it into effect. This includes the need to revive local democracy, with timely real consultation, rather than the promotion of schemes by developer-friendly planning departments.

Part C- Comment of Specific policies and supporting documents I am objecting to the entire North East Cambridge Area Action Plan. It is a misuse of public money, it has nothing to do with fulfilling a local requirement for housing and everything to do with making money for developers and investors I am objecting to the entire North East Cambridge Area Action Plan. It is a misuse of public money, it has nothing to do with fulfilling a local requirement for housing and everything to do with making money for land owners (Universitys), developers and investors. Relocating a hugely invested in, full operational sewage works onto green belt is wholly unacceptable even more so that it is to create even more housing. Show me the proof that there is a need for housing. How many at Trumpington are full? How many at Addenbrookes? How many off Madinlgley Rd. Of those how many are first time buyers? or local people?

NORTH EAST CAMBRIDGE AREA ACTION PLAN. Thank you for your recent consultation on the Draft NECAAP. We have the following comments, informatives and recommendations to offer under their individual water topic headings. In summary, we find that the plan presents some significant risks and opportunities. From a flood risk perspective it presents a potential betterment, and the LLFA will guide Greater Cambridge on this. The plan will be delivered at a time when we expect weighty pressures between supply and demand for water in and around Cambridge. The Integrated Water Management Study (IWMS) will need to consider the capacity and timing of the NECAAP and ensure that sufficient controls are in place to ensure that sustainable water supplies are in place for NECAAP and its respective phases. Monitoring may form a part of this depending on the progress of current work on wider growth and water supply. For water quality there are some significant risks that will require detailed investigation and analysis for land contamination. These are likely to need to occur before a detailed SUDS plan can be drawn up, which in turn may influence layout. The plan provides a unique opportunity to significantly improve water quality, amenity and thus further neighborhood integration in the vicinity of Fen Road, Chesterton. Environment Management: Water quality /wastewater. The policy states that a water quality risk assessment will be required and secured through a planning obligation and developers will need to demonstrate that proposed developments will have an adequate supply of water. The policy will need some clarity as we do not understand what it is achieving, requiring or saying. This is probably best discussed then we can advise on wording. “A Water Quality Risk Assessment will be required and secured through a planning obligation to identify foul sewage, surface water and groundwater on surface and groundwater systems and consider appropriate avoidance measures before incorporating appropriate mitigation measures including works to the First Public Drain where necessary.” Water Resources. The AAP lies within the area historically supplied by Cambridge Water. The location of developments should take into consideration the relative availability of existing developed water resources. The timing and cost of infrastructure improvements will be a consideration. The water companies have recently produced water resources management plans (WRMP), which set out how the companies will maintain customer supplies over the period 2020- 2045. WRMPS show how companies will provide sufficient supplies to meet existing growth plans. This includes how strategic schemes may contribute to this, along with reducing demands and leakage. We advise that councils consider the viability of supplying new developments in the relevant part of the plan period and how the phasing of growth links to the timings of the planned new strategic schemes. The Anglian River Basin Management Plan. https://www.gov.uk/government/publications/anglian-river-basin-district-river-basinmanagement- plan considered the status of all rivers and aquifers in the Region. This showed many waterbodies did not have the flow required to support the ecology and groundwater units not meeting ‘good status’. Given the pressure the chalk aquifer faces, we cannot rule out future further reductions in the supplies available to water companies to prevent deterioration of the water related ecology. The council should seek the water company’s assurance of how it can meet the needs of the AAP’s growth without causing deterioration. The Environment Agency determines that current levels of abstraction are causing environmental damage. Any increase in use within existing licensed volumes will increase the pressure on a system that is already failing environmental targets. We support the AAP considering water resources as a key issue and the councils further informing the plan with an IWMS. This work seeks to address, amongst other things, the potential for growth to lock in any long term increases in abstraction, and to offset this this with sustainable supplies. The IWMS will take into account commitments in the area, the wider effect of growth and the overall influences on the supply and demand for water including climate change. Where there is a shortfall in supply that would risk reliance on new abstraction, the plan needs to identify where the additional water would come from (i.e. other supply sources, leakage reduction or existing demand reduction). The LPA will need to be satisfied it could be supplied in line with the site’s phasing. We endorse the use of water efficiency measures in new developments provided these have a clear and realistic framework for delivery and upkeep. All new residential developments are required to achieve a water consumption limit of a maximum of 125 litres per person per day as set out within the Building Regulations &c. (Amendment) Regulations 2015. We are supportive of Cambridge Water aiming to set the highest possible standards for water efficiency with reference to 80 litres/person/day for residential development, but would need to see how this would be achieved before it could be relied upon. More specific comments on section 4. We also note that Paragraph 149 of the NPPF places a duty on local planning authorities to adopt ‘a proactive approach to mitigating and adapting to climate change, taking into account long term implications for flood risk, coastal change, water supply, biodiversity and landscape’ [our emphasis]. Further to this the Environment Agency supports ‘early consideration of integrated approaches to water management that considers not just flood risk but also water resource availability’ as stated on pg57. However the completion of a IWMS/Water cycle strategy alone may not be enough to satisfy Water Resource (and hence public water supply) issues. We anticipate that policy 4 will need further measures to secure sustainable supplies and reduce demand from the development. The statement pg. 57 that ‘policies reflect concerns in relation to demand and water stress including climate change’ is not yet evidenced to a sufficient degree - although it is clear that this is their aim. This is covered in more detail below. Water management policies: 4a water efficiency The EA appreciates the fact that water efficiency is a key priority for the new development. Whilst the NPPF/NPPG does not allow for councils setting a more ambitious mandatory target than 110l/p/d, developments will aim for an efficiency of 80l/p/d in residential settings and will aim to ‘minimise water use as far as possible’. It also encourages water reuse such as rainwater harvesting and grey water recycling. Whilst we consider these necessary aims, policy 4a on water efficiency needs to be taken in the context of supply options and new development of this size. The overwhelming fact remains that the AAP will require a significant increase in overall public water supply from existing levels. Policy 4b ’Water quality and ensuring water supply’ This includes: ‘councils will expect developers to demonstrate all proposed developments will be served by an adequate supply of water’. This ‘adequate supply of water’ needs to be qualified and redefined in sustainability terms. At planning application stage, effective control via 4b would not happen because Water Companies already have an obligation to supply water to approved developments, and have regard to existing allocations. It is therefore vital that it is determined at the plan level. The timeframes for the water demand on the AAP site are relatively long given that the relocated Wastewater works would need to be operational before the existing works can be decommissioned, demolished, remediated and redeveloped. This may put the AAP redevelopment in the middle and latter part of the local plan period. The question of whether there are reasonable prospects for an environmentally sustainable supply of water during this period needs to be considered holistically at plan assessment stage and through SA/SEA. That should inform a suitable policy to be put in place to secure sustainable supplies prior to outline planning permission/permission in principle. Whilst the IWMS process is welcome, it still needs to address the picture of infrastructure delivery and cumulative growth in the middle and latter parts of the local plan period. Large Strategic schemes to supply sustainable new water are being considered by projects such as Water Resources East. However these schemes to develop more sustainable public water supply options in the area are a relatively long way off being planned and delivered. WRE and water companies are still exploring options at this stage. Until more strategic schemes are brought online, Cambridge Water Company (CWC) currently appear likely to remain dependent on groundwater abstractions, mostly from the chalk aquifer. Water company Water Resource Management Plans (WRMPs) set out how the water companies plan to supply water for the period 2020-2045. These plans do not take into account further potential reductions in existing licensed quantities which cannot be ruled out, due to the over abstraction of the chalk aquifer and potential for further knock on impacts on chalk streams and related ecology. Natural England will lead advice on ecology initially looking at SSSIs and Natura 200 sites. This may lead on to further liaison with the Wildlife Trust and other local designation site managers. We note that CWC’s current WRMPs place substantial reliance on reduction in leakage and demand management to meet immediate growth demands without increasing overall abstraction. We consider that achievability of this will depend on the actual rate of wider growth and the effectiveness of those measures. We therefore advise that the balance of water company supply and growth demand needs to be addressed in the IWMP, then monitored and reviewed for the NECAAP. It would be particularly helpful for the NECAAP if water were planned strategically across boundaries with other growth planned in the area across Cambridgeshire, Peterborough and adjacent North Herts, West Suffolk and Uttlesford. This wider scale work (broadly covering the Cambridgeshire and Peterborough Combined Authority area) would significantly narrow the risk margin caused by understudied supply and demand pressures outside the plan area. When the risk margin is sufficiently narrowed, it should be possible to add a policy 4b along the lines of: ‘councils will expect developers to demonstrate all proposed developments will be served by an adequate supply of water that is demonstrated to have a positive or neutral impact on the water environment’. Groundwater & Contaminated Land (GWCL) It is also noted that the majority of the development will be on brownfield sites, so we offer some informative advice below that would apply to developments on brownfield sites. Land Contamination Potential land contamination should be given due consideration very early in the site design process. Policy 4b currently requires that this is looked at ‘prior to commencement’. We advise that stage is too late to inform the location and design of SUDS and any associated Green infrastructure. The policy as it stands risks SUDS becoming ‘grey SUDS’ i.e. using concrete and tanks in areas that may turn out to have contamination. For land that may have been affected by contamination as a result of its previous use or those of its surroundings, we would expect as a minimum to be provided with a Preliminary Risk Assessment (PRA) demonstrating that the risks to controlled waters are understood and can be addressed to a level compatible with SUDS and other future land uses. Any land contamination investigations should be carried out by suitably qualified and experienced professionals, and in accordance with relevant guidance and standards. Piling or other ground improvement methods could have an adverse impact on groundwater quality. Sustainable Drainage Systems (SuDS). We support the use of infiltration SuDS for surface water disposal where they do not present a risk to controlled waters. This will require some up-front PRAs and any investigations to confirm the suitability of infiltration SuDS to meet criteria in relevant Groundwater Protection Position Statements. SUDS must not be constructed in contaminated ground where they could re-mobilise pre-existing contamination and cause pollution of groundwater. Infiltration SuDS require a minimum of 1.2 m clearance between their base and peak seasonal groundwater levels. Infiltration SUDs greater than 2.0 m below ground level constitute a deep system and are generally unacceptable. Appropriate pollution prevention measures and run-off from these areas should pass through a suitable number of SuDS treatment train components. We suggest that policy 4b is amended to require: Prior to commencement of the layout of the development being determined, the potential for contaminated land (both human health and controlled waters) shall be comprehensively characterised, investigated where appropriate and risk assessed including the consideration of remediation as necessary having regard to the proposed end uses. Sustainability report final July 2020. Policy 4a water efficiency SA Objective 3: ‘protect and where possible enhance the quality of the water environment’ SA objective 8: reduce vulnerability to future climate change effects. It is noted that the preferred policy may help promote greater water efficiency for non-residential water use across the site and consideration of water recycling and grey water recycling is welcomed. However given constraints in the Building Regulations, the report acknowledges that it will not necessarily change the residential use as this is set by the local plan and can’t be set below 110l/p/d for mains water use. It is unclear as to why significant positive effects are expected against objective 3 for both the preferred policy and the existing policy as more water overall will be taken from the Environment as a result of this development. Measures to promote/require greater water efficiency and water quality improvements are welcomed, but are unlikely to be overall significant benefit on their own unless considered in parallel with a new Wastewater works which is still be planned and probably cannot be considered. For the preferred policy ‘Minor positive effects are expected against SA objective 8 as improving water efficiency will help adapt to lower water availability which is likely to occur as a result of climate change’ As above, although water efficiency measures are welcomed, any positive impact this may achieve will be very small in context of more water being needed overall as a result of the development locking in new water consumption. This will therefore be a negative score. Paragraph 47 policy 4b water quality and ensuring supply: (same objectives SA 3 and 8 as for policy 4a). ‘the preferred option is expected to have significant positive effects on SA objective 3……..The policy states that a water quality risk assessment will be required and secured through a planning obligation and developers will need to demonstrate that proposed developments will have an adequate supply of water…..’ Whilst water quality aspects could have a positive effect on water environment (see Fen Road opportunity below), we disagree that the current 4b’s requirement for developers to demonstrate that proposed developments will have an adequate supply of water, will ensure that this water comes from an environmentally sustainable source. See our suggestion under 4b to link this to environmental protection. Flood risk: Overall we regard this as a positive document for flood risk management and lays a framework for sound design. Small changes may improve this document’s ability to result in flood risk reductions. We are unlikely to be directly involved in the flood risk aspects of this development area as it is currently within flood zone 1 (low risk) on our national flood mapping. Sequential approach. In our response to the previous issues and options we raised the matter of the flood risk sequential test and the extent to which the plan would need to demonstrate its impact on reducing risk by potentially displacing the Wastewater Treatment Works (WwTW) from a site in flood zone 1 to a site at higher risk. Since then Anglian Water has released a public consultation with relocation site options. These are all as substantively in flood zone 1 as possible for a site of that size. Obviously if the options and chosen site remain as such in flood zone 1, there would be no need for the NEC AAP to further demonstrate a sequential test. A sequential approach process would need revisiting if this changed. Specific comments. Policy 2: Designing for the climate emergency. g. Futureproofing. There would be benefits in widening this section to include future proofing measures to combat the impacts of climate change rather than just the causes of it. Policy 4c: Flood Risk and Sustainable Drainage. Part a, we would recommend that this is worded stronger i.e. peak run off rates should be set as low as is technically feasible but not higher than greenfield run off rates. We would also recommend that the policy considers the volume of water discharged and how quickly it starts discharging from the time it rains. There also needs to be a balance between reducing the impacts of floods and ensuring that rainfall in summer months help relieve water stress within the local watercourses Part e refers to a Strategic Flood Risk Assessment, we assume this is meant to refer to a site specific flood risk assessment. Parts f and g aren’t written very clearly and, for the most, part replicate the NPPF requirements. Given that the area designated within the area action plan is wholly within flood zone 1 of the Flood Map for Planning (rivers and sea), the focus of the flood risk policy should be on other forms of flood risk and how the proposals contributes to offsite flood risk and it mitigation. The Policy refers to ‘surface water wet spots’ but doesn’t appear to define what constitutes a wet spot? Environment Management and enhancement opportunities (Policy 5): Fen Road Chesterton lies just outside the boundary of the NECAAP, directly to the east of Cambridge North Station. The length of Fen Road, to the north of the railway line is not served by mains foul sewer. The site consists of a number of industrial units, a few houses and several travelers’ plots comprising of permanent travelers’ homes and caravans. The travelers’ site has been growing in size and has been in existence for around 50 years, possibly longer. The Fen Road site is currently served by several small unpermitted package treatment plants and one permitted package treatment plant that is not large enough to be routinely sampled by the EA. The drainage in the area appears haphazard and we believe is unmapped. It is likely that some of these treatment plants are not working effectively and that poorly treated sewage is being discharged into the River Cam and into a boggy area by the side of the tow path. Pollution has also been found in local ditches. Over the years there have been a number of reports of foul sewage from Fen Road discharging into the river Cam, causing chronic ongoing pollution. There have also been reports of pollution from business on the Cave Industrial Estate. Historically a lot of effort was made to try and connect the site to the mains foul sewer. Anglian Water resisted connecting the site on the grounds that the site was “temporary”. We recall this issue went to legal review at the time and Anglian Water’s position was upheld. In 2013 Cambridgeshire County Council approved Fen Road as a permanent travelers’ site. There are several brick built business units on Cave Industrial Estate and several permanent travelers’ homes. Whilst it is difficult to see how Anglian Water’s previous stance could still be valid, Anglian Water may now welcome intervention to compliment the major improvements in water quality being delivered (in a large part by Anglian Water) throughout the whole River Cam catchment. In any event, the relocation of Milton sewage works and the redevelopment of North East Cambridge presents the best foreseeable opportunity to incorporate mains drainage connection into the Fen Road site. The site is the only sizable location within Cambridge that is not connected to mains drainage. Unaddressed it will continue to be a source of ongoing local water quality and environmental health problems in the River Cam vicinity for the foreseeable future. Protected species such as water vole will likely be affected given their presence and the vulnerability of their habitat and food chain to this type of pollution. In respect of amenity and the public realm, it has visual and more widespread odor impacts for existing and prospective occupants of homes and businesses. Whilst we do not seek to evaluate matters outside EA’s core expertise, we note that addressing these impacts may also be an opportunity to enhance local public relations with Anglian Water and further wider social cohesion with Fen Road residents. In support of this proposition, we note that the North East Cambridge Area Action Plan lists Biodiversity and Green Spaces as one of the key themes of the redevelopment. The MKA Biodiversity Assessment identifies water voles as being present, and under pressure. The plan recognises that the River Cam is a County Wildlife Site and that current pressures have led to reduced flow in the river, impacting wildlife. The Action Plan states that both councils recognise the pressures on the environment and want to explore how more can be done to enhance the green infrastructure network and achieve Biodiversity Net Gain. SA Objective 3: ‘protect and where possible enhance the quality of the water environment’ and SA objective 8: ‘reduce vulnerability to future climate change effects’ are both relevant. The Environment Agency therefore submits that here is a strong opportunity (in policy and outcomes on the ground) to work with the site owners on a matter that they have relevant expertise, resources and strategic benefit in addressing. This action may work best if it is set out and agreed prior to land transactions so that there is join up with any obligations on previous and future owners of relevant land, where relevant. We propose a change to policy 5 as follows: 4. Delivering coordinated habitat and water quality improvements to the First Public Drain, Milton Country Park, and Chesterton Fen and the River Cam related to foul drainage improvements serving land uses in the vicinity of Fen Road, Chesterton; We are happy to clarify the above. Yours faithfully M Chris Swain Planning Specialist Sustainable Places Team Direct e-mail planning.brampton@environment-agency.gov.uk

In general, we are supportive of a development on this brownfield site rather than seeing green belt countryside used instead. NEC is also a very accessible site, served by rail, guided busway and cross city cycle routes and so providing development in this location makes sense. The key points on which we object to the Draft AAP are: 1. We believe that relying on landowners and developers to deliver the AAP is far too risky. That risk would be minimised if all the land to be redeveloped were transferred to a single owner, a development corporation in which the local authority is a controlling shareholder. The lessons from CB1 must be learnt: agreements struck today with current landowners may be picked apart by future landowners and developers. The environment for residents in Great Northern Rd in particular is far inferior to that envisaged in the masterplan. Masterplans need to evolve to accommodate changing social, technical and environmental needs. But that risks opening up opportunities for developers to renegotiate planning parameters, constraints and obligations to the detriment of net social benefit. 2. The on-site provision of open space, sporting and recreational amenities is wholly inadequate for the number of homes proposed. The proposed ‘outsourcing’ lacks evidence that it is both viable and sufficiently accessible (e.g. the limited capacity of Milton Country Park and no location yet determined for a public swimming pool). 3. The “trip budget” plan for transferring car trips from the Science Park to the new development is hugely ambitious. However, it is not evidenced with an appropriate model, nor a plausible action plan for reducing car parking provision on existing sites. 4. The strategic case for relocating the Water Treatment Plant to free up land for housing must not automatically override the cost-benefit analysis and Environmental Impact Assessment. 5. The additional demand for treated water created by the new homes and offices in NEC must be matched by a funded and contemporaneously scheduled plan to supply that water sustainably.

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.

Sent via e-mail only Dear Sir/Madam, Boyer 15De Grey Square De Grey Road Colchester Essex C045YQ Re: Draft North East Cambridge Area Action Plan (AAP) - Consultation Response on behalf of RLW Estates Introduction These representations are submitted on behalf of RLW Estates. As you may be aware, RLW Estates are joint promoters of Waterbeach New Town, which is allocated as a strategic development site in the adopted South Cambridgeshire Local Plan, controlling the eastern part of the site. They currently have an outline planning application for up to 4,500 dwellings and a range of associated commercial, community and recreational uses that is under consideration by South Cambridgeshire District Council (SCDC), having already secured full planning permissionfor a new relocated railway station to serve the new and existing communities. An outline planning permission has already been granted for up to 6,500 dwellings on the western part of the allocation. Given the proximity between Waterbeach New Town and the area covered by the North East Cambridge AAP, at less than 5km, there is a clear relationship between these, and therefore opportunities to ensure that development of each is brought forward in a mutually beneficial manner, having regard to the objectives of maximising sustainability and creating attractive and functional new communities. The functional relationship between the two areas, and the opportunities presented, are significantly enhanced by the direct rail connection between Cambridge North station and the relocated Waterbeach station, in addition to other direct non-car linkages, such as the proposed Greenway. It is with this context in mind that the following comments are provided, largely by way of support for the emerging AAP and the vision for sustainable development that it presents.

Dear Sir As the County Access & Bridleways Officer, I represent the riders and owners of the 25,500 horses (excluding the racing industry) in Cambridgeshire on behalf of the British Horse Society. This response is therefore a Stakeholder Response from a specific user group. The survey fails to meet the requirements of the Cambridgeshire and Peterborough Local Transport Plan (LTP) in that there is no reference whatsoever to equestrians – Active Travel is defined in the LTP as pedestrians, cyclists and equestrians. This document therefore discriminates against one whole user group by excluding their opportunity to input. The majority of the maps / schematics included in the survey are inaccurate and contain misleading information. The survey maps should have included the public rights of way correctly labelled. Describing a Byway as a cycle route is not only misleading but can be the cause of conflict between cyclists, expecting a path to themselves to speed along, becoming angry to find pedestrians and horse riders rightfully using the route and impeding the cyclists’ way. This also raises the question of the status of the routes you are creating. Multi user routes should be created as Bridleways and included on the Definitive Map as such. The complete omission of equestrians from the non-motorised user transport and travel sections needs to be corrected. The Greater Cambridge Partnership Greenways initiative is to deliver high quality non-motorised user routes for walkers, cyclists and equestrians. There are many equestrians located in and around Cambridge city and its rural surrounds on all sides. Horses live within the city confines and are regularly ridden across, through and around it. The GCP Board have given equestrians some important undertakings : 1. None of their projects will reduce the public rights of way / access amenity of horses – in fact, they have undertake to improve the amenity. 2. They will seek to secure alternative routes where equestrians are excluded from any new path creation. 3. All Road Safety Audits will include the need to assess the impact of a route on the safety of equestrians. This is particularly important where the intention is to create on road cycle or shared cycle pedestrian paths which leave horses dangerously sandwiched between vehicular traffic on their outside and fast moving cycles on their inside. These undertakings must be applied to all Cambridgeshire projects, including this one. Any crossing of any major transport barriers, road, rail or river, needs to provide access for equestrians as well as pedestrians and cyclists. For example, equestrians from Waterbeach should have safe off road access to the Guided Busway bridleway. There should be a pleasant, gold standard, Greenway link between the Waterbeach Greenway and the Guided busway. A pleasant route would benefit all users, walkers, cyclists, horse riders, runners, dog walkers and with careful design, could benefit the environment / biodiversity. The benefit of a rural environment on mental health and wellbeing is well documented and again has been highlighted during Covid 19 and Lockdown. The design team should consider a peripheral bridleway, similar to excellent peripheral bridleway at Cambourne, with links to existing rights of way. Every opportunity should be taken to create multi user access, especially in links between communities and rights of way, as it is morally, socially and environmentally correct to spend public money to benefit the most users / user groups and enhance the environment. Covid 19 has demonstrated the need for public access which is something other than a tarmac path. We do not support the provision of tarmac only paths – there is a myriad of alternative pleasant surfaces which would enhance a rural feel of a path in an urban area and this is the standard to which Cambridgeshire should be aspiring. Your map 2.1.3 shows Mere Way as a "non-surfaced off road cycle route". This is incorrect. It is a Public Byway and therefore open to walkers, cyclists, equestrians (ridden and driven) and unless there is a wet season closure gate on it, it is also open to motorised traffic. The Chisholm Trail project underway should be usable by equestrians as well as cyclists and walkers. All three groups are vulnerable and need safe routes across the city. This project no longer complies with the requirements of the LTP and should be immediately reviewed. No reference is made to the potential A10 transport project which will also impact on this area. It has already been stated that these major transport projects will include provision for equestrians along with the other non motorised users. It is therefore essential that similar provision should be provided in this project. The following are comments against specific survey questions: Q1 Question fails to meet the requirements of the Cambridgeshire and Peterborough Local Transport Plan which refers to Active Travel not just walking and cycling – Active Travel is defined as pedestrians, cyclists and equestrians. Question also fails because it excludes any reference to leisure transport which includes equestrians. Q1.2 No. Creation of restrictive pedestrian and cycling only access discriminates against females because the majority of horse riders are female. Excludes any equestrian access despite the fact that some of the links are to places equestrians use e.g. Milton Country Park, Waterbeach, proposals for Cambridges Lakes, some are to bridleways e.g. the Guided Busway bridleway and some are multi user routes e.g. the Greenways. Policy 17: Connecting to the wider network To improve the wider connectivity between North East Cambridge and adjoining areas including nearby villages, Cambridge city centre, employment and residential areas, and open spaces within the wider countryside and Rights of Way network development will be required to contribute to new and improved connections for non-motorised users, as shown on Figure 37. The following new and improved provision must be incorporated early in the design stages and layout of the development: This refers to non motorised users but there is no reference whatsoever to equestrians. The British Horse Society has consulted and advised throughout the early stages of this project but its input and comments have been completely ignored. This is totally unacceptable. There is not one horse shown on Fig 37 despite a reference to provision for horse riders (with, of course, the usual caveat ‘where appropriate’) in connection with structures. These proposals fail to meet the requirements of the Equal Opportunities Act by excluding one group of NMU’s. Q7 No because you have not included any provision for equestrians. Q9 Care needs to be taken not to endanger equestrians in the race to provide cycling facilities. Equestrians must not be left sandwiched between fast moving vehicular traffic and speeding cyclists. This will not apply to all roads but it could to some. The needs and ambitions of equestrians and their riders is a specialised knowledge area. The BHS Cambridgeshire Access Team, together with the various local bridleway groups, are able to provide this specialised knowledge and are experienced in communicating with transport project groups. We would be very happy to provide you with any information you need. I have attached some quick visuals to give you an idea of where equestrian rights of way have been omitted and ignored from your survey, where horses are currently kept – I have no doubt there are far more horses in the area than I have actually shown – and areas where equestrian access is permitted / should be permitted. I would be happy to elaborate on this brief submission. Finally, I have tried to respond to your survey online but since we have not been included in any of the information, it is impossible to respond with any degree of clarity. I have therefore advised local riders to write to you direct. Please can you reassure me that lack of horse rider responses to the online survey (from which you have excluded the needs of horse riders), will not impact negatively on the evidence of the need for horse riders to be taken into consideration within the project? Yours faithfully Lynda Warth County Access & Bridleways Officer – Cambridgeshire British Horse Society

I am very concerned about your vision for North East Cambridge on the following grounds: Need for the development: Is this the right time to be planning such a large development of very high-density housing? We are in an economic crisis when Covid-19 has meant a change to working practices. It would be better to build in existing villages all around Cambridge, not just in the north east. Is there really a need for so many homes in this area? I question the need for over 275,000 square metres of new business space when office blocks up and down the country are standing empty and could be converted to residential accommodation. Connected and integrated: This relies on people being able to walk or cycle to work. It presupposes that everyone living there will be young and active and remain that way. Communities are a mixture of all ages and abilities, but this development does not appear to cater for all of them. Building heights and density: Such high density (more than London or Paris) is not appropriate for this area. One- and two-bedroom dwellings in 13 storey blocks could lead to social isolation and lack of community feeling. It doesn’t cater for growing families. Are they expected to move out when children reach secondary school age? Open places: Whatever open spaces are planned they cannot compensate for the loss of wide open Green Belt where the new WWTP is expected to be sited. Milton Country Park is not sufficiently big or open to accommodate so many people and it is already very well used. Biodiversity: The negative impact on flora and fauna caused by the construction process cannot be undone. The site chosen for the relocation of WWTP to enable this development will suffer immeasurably and catastrophically. Discouraging car use: Not everyone is able to walk or cycle to work. As people age or their families grow they will become reliant on cars. The development does not take this into consideration. Additional points to consider: Where are the secondary schools? Surely there won’t just be primary school age children living there. I understand that to register for this consultation my name will be published with my comment, but that, in line with your privacy statement, my contact details and other personal information will not.

This is a great opportunity for North East Cambridge to create a low carbon area to include green and sustainable construction to develop low carbon homes in line with the governments targets. As the area is to be designed to be inclusive and walkable it is important to provide a characterful area and it could enhance and add more green areas and green corridors connecting different areas. It will also allow the integration with the surrounding communities and add vitality to the area. A lively mix of homes could include buildings which could be given personality and with organic architecture to blend into the surroundings and add interest. As Cambridge has beautiful historic buildings it is important to create some beautiful buildings for future generations. By incorporating traditional crafts alongside new construction embracing it’s past but looking forward to it’s future. As part of the development there is an opportunity for some affordable housing and to consider health alongside some biodiverse areas so that not all biodiversity is located in one area as with more people they will require access not only to social areas such as Cafe’s (perhaps a Cafe with a Cosmology theme - i.e. in honour of Stephen Hawking) shops, perhaps a creative hub for local people which can also enhance creativity especially as there is likely to be an R & D sector nearby. Social areas could include an area for music and the arts. Benches or even buildings shaped like books to create a sense of wonder giving the area an identity alongside its science and innovation roots. Good planting and trees and with the addition of some organic architecture will ensure a successful future and address climate change. Access to spaces could promote a sense of wellbeing and to be good for mental health with beautiful trees providing clean air. Areas for people to work from home especially important at times of pandemics. Areas for outdoor yoga and active space. Green construction, permeable paving and diversity. Areas to include recycled and repurposed products in innovative ways could maybe include a recycled sector. Harvesting of rainwater and a perhaps a fountain in the square. This development can also encourage investment in the green sustainable housing sector and innovation which in turn will feed into many different areas of the green circular economy and provide local jobs and future opportunities in green technology throughout the UK. Perhaps solar street lights, paving areas that when walked on create energy allowing energy to be harvested for future use. With Cambridge North station nearby it provides good access to this part of Cambridge so excellent for work and growth in the science sectors but should include some creative/digital areas and work places. The plan for North East Cambridge does mention walkable, however for it to be inclusive some areas of Cambridge are not so accessible such as surrounding villages so an area with the potential for car sharing perhaps including electric cars with charging points available could be encouraged, especially for older residents, work purposes, mums with younger children, access to health and in and during the transitional phase towards Zero Carbon by 2050. Sustainable transport such as electric buses and areas to rent bikes, including electric bikes for those city journeys providing an active lifestyle for all. I feel that a lower density could possibly be considered alongside the height of buildings so as to not to create wind tunnels. Organic architecture and the inclusion of green walls in some areas could be considered to soften walls. Building house sand buildings to higher EPC levels is the way forward. The plan looks at creating a sustainable future. It should take into account sustainable homes and buildings and combat energy and fuel poverty. The plan takes into account diversity and all demographics and genders. It looks at creating a sustainable community and integration to other communities. Nature and biodiversity have been considered and could be enhanced. It will ensure future jobs and opportunities for future generations. It looks at a responsible way forward.

Re: North East Cambridge Area Action Plan Consultation CPRE Cambridge and Peterborough Branch Objects to and adds the following comments to the Greater Cambridge Partnership’s (GCP) proposals for the Cambridge North East Area contained in the current Action Plan. 1. Anglian Water concur that there is no operational need to move the Milton Waste Water Treatment (WWT) plant from the current site. The current installation has been upgraded to serve the City’s needs until 2050 and is currently operating at approximately half capacity. 2. It has been demonstrated that a modern WWT plant using new technology could be built on the current Anglian Water site. This would prevent the AAP boundary spilling into the Cambridge Green Belt and onto prime agricultural land. The timing of the AAP consultation appears to be premature until the outcome of the consultation and any planning application relating to the relocation of the Milton WWT plant into the Green Belt, upon which these proposals are dependent, is known. CPRE would be very concerned indeed if the outcome of the WWT plant study is either being assumed or pre-determined. 3. CPRE has concerns regarding the density per hectare of 235 dwellings in certain areas of the development which requires twelve storey high tower blocks. These would be out of keeping with the City and South Cambridgeshire landscape in which the proposed settlement will be sited. It is also important to keep the sense of place of Cambridge City as well as the identity of the necklace of villages characteristic of the South Cambridgeshire District Council Area. 4. CPRE would like to remind the GCP that Cambridge is nationally a very special place. The Cambridge Green Belt, unlike other nationally designated Green Belts, was specifically designated in order to preserve the historic character of the City as well to protect it from generating urban sprawl into the surrounding gentle countryside. This objective was expressed in the Green Belt Local Plan by the phrase “To preserve the special character of Cambridge and its setting”. This being an addition to the more usual objectives also contained in the Green Belt Local Plan of: • “To control the urban expansion of Cambridge; • To allow for the development of communities in accordance with Structure Plan policies; • To prevent the further coalescence of settlements; • To enhance the visual quality of the area; • To balance the provision of suitable recreational and leisure facilities against the needs of agriculture”. 5. CPRE is aware that, due to COVID19, working and living patterns have changed. We suggest to GCP that this new situation should be taken into account as a significant factor when developing this Plan. It is now a requirement of many people when seeking new homes that they provide space to work from home and gardens to enjoy which contradicts the current plans in the draft AAP. We recommend that GCP consider the following studies: Felstead, A and Reuschke, D (2020) ‘Homeworking in the UK: before and during the 2020 lockdown’, WISERD Report, Cardiff: Wales Institute of Social and Economic Research. Available for download from: https://wiserd.ac.uk/publications/homeworking-uk-and-during-2020-lockdown Business Times https://www.businesstimes.com.sg/real-estate/london-office-property-market-likely-to-see-structural-changes Royal Institute of Chartered Surveyors https://www.rics.org/globalassets/rics-website/media/knowledge/research/market-surveys/uk-commercial-property-market-survey---q1-2020.pdf Royal Institute of Chartered Surveyors https://www.rics.org/globalassets/rics-website/media/market-surveys/gcpm/rics-uk-commercial-property-market-survey---q2-2020.pdf These clearly indicate a trend towards home-working and the potential for existing commercial buildings in town and city centres to become available for conversion for residential use. 6. There is a distinct lack of green space within the settlement as planned. This applies particularly to dwellers in the proposed tower blocks. It has become widely known that connecting with green space and nature is important for mental health and physical wellbeing. CPRE are also concerned that Milton Country Park is the suggested green space. This is outside of the development and to the north of the A14. Milton Country Park already experiences heavy footfall from existing residents. South Cambridgeshire District Council have recently provided funding to ensure that the Country Park continues to provide this vital green lung. However, if footfall becomes too heavy, its primary purpose will be damaged as will the wildlife and bio-diversity it contains. 7. CPRE note that car parking spaces of 0.5 per dwelling have been allocated. This assumes that each household will in the main use sustainable transport and that the majority of residents will live and work within the proposed settlement. It is unclear how the GCP will “police” how many motor vehicles per household there will be. It is also unclear how the less mobile members of the community will have access to parking close to their homes. 8. The number of commercial buildings including office space proposed within the AAP should be questioned due to the current changes in working patterns following COVID 19. CPRE consider that it is unlikely the GCP can guarantee that all residents who wish to will be able to live and work within the proposed development. 9. CPRE has concerns regarding the potential impact that the density and scale of the AAP will have on existing communities particularly Milton, Chesterton, Milton Road and Kings Hedges. CPRE are also concerned by the impact on existing roads and other essential services. How will the development be created to design out crime and to create an integrated community particularly with the proposed housing mix and lack of affordability for local people? 10. CPRE are aware that the Greater Cambridge area is currently in water stress and enquire as to how supply will be made available to the settlement without creating further harm to the already depleted chalk streams and the river Cam. CPRE consider it irresponsible to rely on the legal obligation of local water companies to supply in a situation of known water stress and when one of those companies, Anglian Water, has recently been heavily criticised and fined for poor environmental performance and causing pollution. What mitigations will be put in place to protect and enhance the River Cam corridor due to the impact that an increased footfall may have. How will biodiversity be enhanced and increased. 11. CPRE seek clarity as to how the GCP will mitigate the impact of climate change, especially flooding due to global temperature rise and consequent sea level rise. Studies now predict that land from the Wash to Cambridge will likely experience regular from floods by 2050: https://www.climatecentral.org/ In Summary • CPRE reiterate that the existing Wate Water Treatment plant should remain on the existing site. • CPRE considers that this consultation is premature given that there has as yet been no public decision about the future of the WWT. • CPRE considers that the height and the density of the proposed development is out of context with the character of the City of Cambridge and South Cambridgeshire District. • Because of its apparent dependence upon the move of the Waste Water Treatment plan this plan will lead to a further reduction in the already limited Cambridge Green Belt, which was designed to protect the character of the City. CPRE is totally opposed to such incursions which have now reached a totally unacceptable level. • The Greater Cambridge Partnership through this development has the opportunity to take a holistic approach in creating a sustainable community that suits the needs of residents and businesses in the light of the changes in lifestyle and working practices due to COVID19. If the AAP proceeds, CPRE hopes that truly affordable, social-rented homes will be available for local people, not homes branded as ‘affordable’ by the current government definition. • More green space for leisure and mental wellbeing should be integrated into the development whilst increasing biodiversity. The reliance on Milton Country Park to mitigate the lack of green space on the site is not a practicable solution. • Sustainable travel and car parking space allocation needs to be evidence based whilst factoring in the requirements of the less mobile in the new community. Travel plans should be factored in for commuters to and from the settlement. • The impact on existing communities, infrastructure and essential services require further study and mitigations to ensure truly sustainable living and that the development does not irreparably damage the River Cam corridor and environment. • CPRE believe that water stress and the risk of flooding due to climate change and their mitigation, in association with carbon emission reduction, must be seriously considered before any application for planning permission is made. Yours sincerely, Jane Williams On behalf of CPRE Cambridgeshire and Peterborough Branch.

Introduction These representations relate to the site occupied by Veolia Waste Recycling Transfer facility off Cowley Road. Veolia has a long leasehold interest in the land. It is anticipated in the North East Cambridge AAP that the land currently occupied by the Veolia Waste Recycling Transfer Site would be redeveloped for business (B1) and housing uses within tall buildings of between 5 to 8 storeys in height, and adjacent to business and town centre uses and housing. However, the plan provided at Figure 11 is not particularly clear and it would appear that important operations such as Veolia have been forgotten about throughout the process to date. The site needs to generate a high use value to make the land viable and to fund the purchase, development and move to another relocation site. Therefore the proposed use of the Veolia site for business (B1) and housing uses are supported. It is proposed in Policy 26 that the existing Waste Recycling Transfer facility would be relocated off site. As noted in Policy 26, that relocation would be undertaken in collaboration with the Minerals and Waste Authority (Cambridgeshire County Council) and is a pre-requisite of the redevelopment of the site and surrounding area for the proposed uses. It is acknowledged in the supporting text to Policy 26 that the Council will work with the landowner to secure a suitable alternative site for the Waste Recycling Transfer facility. However, it should be noted that funding has been provided to enable the relocation of the Cambridge Waste Water Treatment Works, but no funding is available for the relocation of other services and facilities including the waste recycling transfer facility which is also essential to the delivery of the AAP. The relocation of Veolia’s operations to another site needs to be viable and acceptable to the company from an operational perspective. Support As set out in these representations, the adopted and emerging Minerals & Waste Local Plans seek to safeguard the existing waste recycling transfer facility operated by Veolia in its current location, and it appears that the policy requirements for a replacement facility might be difficult to achieve on a suitable alternative site. Veolia is an existing established business, and a replacement facility should be located within or close to Cambridge in order to avoid the unnecessary transportation of recycled waste and material. It is requested that Policy 26 is amended so that the redevelopment of the existing Veolia Waste Recycling Transfer facility site off Cowley Road cannot happen until a suitable alternative site for this facility has been identified and approved. Policy 1: A comprehensive approach at North East Cambridge The comprehensive approach towards development and regeneration at North East Cambridge is broadly supported. However, a comprehensive approach must include the following: appropriate phasing of redevelopment sites to ensure that proposed uses are compatible with existing business operations on adjacent sites and in close proximity, including the existing waste recycling transfer facility off Cowley Road; ‘meanwhile’ uses that are appropriate and compatible with existing business operations on adjacent sites; and, the successful relocation of the existing waste recycling transfer facility to a suitable alternative site within close proximity of Cambridge. Policy 9: Density, heights, scale and massing Figure 21 shows building heights for the proposed business space (B1) and housing at the Veolia site off Cowley Road of between 5 to 6 storeys and a maximum of 8 storeys. The proposed uses on the neighbouring areas also include tall buildings. The proposed uses and the building heights for the Veolia site are supported, and these higher value uses are necessary to enable the existing waste recycling transfer facility to be relocated off site, otherwise relocation would not be viable. In addition, the phasing of redevelopment will be important in order to ensure that tall buildings are compatible with existing uses e.g. waste recycling transfer facility such like Veolia that might remain in operation if an alternative site is not identified. It is unlikely that effective temporary noise mitigation measures could be provided within the proposed residential buildings to address the noise generated by activities associated with the existing waste recycling transfer facility. Policy 14: Social, community and cultural infrastructure The inclusion of additional social, community and cultural facilities within the North East Cambridge area is supported. Policy 15: Shops and local services The inclusion of additional shops and local services, including a new district centre, within the North East Cambridge area is supported. However, these uses need to be delivered in locations reflective of the land value generated where that it is necessary to facilitate release of land. Lower value uses should not be proposed on the Veolia site. Policy 23: Comprehensive and Coordinated Development Policy 23 seeks to ensure a comprehensive and coordinated approach to development and regeneration at North East Cambridge, which is broadly supported. Policy 23 requires applications for major development to successfully integrate with the surrounding area and to successfully mitigate environmental constraints – see criteria c(ii) and c(vii). It is anticipated that the land currently occupied by the Veolia waste recycling facility would be redeveloped for business (B1) and housing with the adjacent land redeveloped for business and town centre uses and housing. The proposed buildings on the site would be up to a maximum of 8 storeys, and on the neighbouring land the buildings would be up to a maximum of 13 storeys high. However, it is expected that the existing waste recycling transfer facility would continue to operate for a temporary period or indefinitely if a suitable alternative relocation site is not identified. Therefore, an appropriate phasing of redevelopment sites must be provided to ensure that proposed uses are compatible with existing business operations on adjacent sites and in close proximity, including for the existing waste recycling transfer facility off Cowley Road, in order to avoid potential noise and residential impacts. However, as outlined above the existing Veolia operation will only relocate if they can make the land viable. Policy 24a: Land Assembly It is proposed in Policy 26 that the existing waste recycling transfer facility off Cowley Road would be relocated off site, but at this stage no suitable and viable alternative relocation site is identified. Veolia would be affected by the redevelopment of its existing site, and would welcome discussions with the Council to find a suitable alternative viable site from which it can operate a waste recycling transfer facility and release of value from their existing site to facilitate any move. It would not be necessary or appropriate for compulsory purchase to be used because the Veolia site could be redeveloped in conjunction with Cambridge City Council for the proposed business and housing uses, and designed to meet the policy requirements specified in the AAP. Policy 24b: Relocation It is proposed in Policy 26 that the existing waste recycling transfer facility off Cowley Road would be relocated off site, but at this stage no suitable and viable alternative relocation site is identified. Veolia intends to remain operating the waste recycling transfer facility until a suitable and viable alterative relocation site has been identified and approved. It is anticipated in the North East Cambridge AAP that the land currently occupied by Veolia would be redeveloped for business (B1) and housing uses; the retention of the existing waste recycling transfer facility at the existing site is not an option. Criteria (b) of Policy 24b requires engagement with affected occupiers and tenants where relocation of existing businesses is proposed as part of development at North East Cambridge. Veolia would be affected by the redevelopment of its existing site, and would welcome discussions with the Council to find a suitable alternative site from which it can operate a waste recycling transfer facility. It is disappointing that, given Veolia is a key relocation site (albeit small scale), that they have not been invited to participate in the masterplanning workshops for the wider AAP area that have taken place to date. This engagement with existing land owners and users is an important part of the process and is identified within the Sustainability Appraisal. Given the failure to engage on this site, the legitimacy of the outcomes from these workshops could be challenged. Criteria (c) of Policy 24b sets out a sequential approach to the re-provision of existing uses. Veolia is an existing established business, and a replacement facility should be located within or close to Cambridge in order to avoid the unnecessary transportation of recycling waste and material. As set out in the response to Policy 26, it appears that the policy requirements for a replacement facility might be difficult to achieve on a suitable alternative site without assistance and support from the Council to enable Veolia to relocate its existing operations in a viable manner. Policy 25: Environmental Protection Policy 25 seeks to ensure that environmental impacts are considered for development at North East Cambridge, and identifies criteria for development. As set out above, the existing waste recycling transfer facility at the Veolia site off Cowley Road is expected to continue until a suitable and viable alternative relocation site is identified. The operations associated with the waste recycling transfer facility e.g. noise, odours and vehicle movements, could be incompatible with new residential, commercial, town centre and community uses on neighbouring sites without appropriate phasing and the effective relocation of Veolia’s operations. Therefore, the criteria in Policy 25 relating to noise and air quality to be assessed as part of design and layout (criteria c), new sensitive uses to be integrated with existing businesses (criteria d), and to avoid unreasonable restrictions on existing business operations (criteria e) are supported. Policy 26: Aggregates and waste sites It is stated in Policy 26 that “the safeguarded Veolia Waste Recycling Transfer Station should be relocated off-site. This would need to be undertaken in collaboration with the Local Minerals and Waste Authority and is a pre-requisite to future sensitive development coming forward on surrounding plots”. It is anticipated in the AAP that the land currently occupied by the Veolia waste recycling facility would be redeveloped for business and housing uses. However, as explained below, the adopted and emerging Minerals & Waste Local Plans seek to safeguard the existing waste recycling transfer facility in its current location, it appears that the policy requirements for a replacement facility might be difficult to achieve on a suitable alternative site, and at this stage no alternative site for the relocation of Veolia’s operations have been identified. The relevant policies of the adopted and emerging Minerals & Waste Local Plan are identified below, as are the relevant policies of the adopted Cambridge and South Cambridgeshire Local Plans. The Veolia site is safeguarded as a waste recycling transfer station in the adopted and emerging Minerals & Waste Local Plans, and as such it is anticipated that the existing facility would be retained on site, relocation is not anticipated and no alternative/replacement sites are identified. Policy CS18: Waste Management Proposals Outside Allocated Areas of the Minerals and Waste Core Strategy Development Plan Document (adopted July 2011) states: “Proposals for waste management development outside allocated areas will be considered favourably where :- • this is consistent with the spatial strategy for waste management, and • it can be demonstrated that they will contribute towards sustainable waste management, moving waste up the waste hierarchy Waste recovery and recycling facilities may be permitted where they are: a. for on-site management of waste b. on land identified for general industrial use c. co-located with complementary activities (including existing permanent waste management sites) d. on previously developed land e. on farm holdings to facilitate agricultural waste recycling f. within a medical or research institution which is generating waste (bio-medical, research and clinical waste only) g. in strategic development areas h. at inert landfill sites (inert waste recycling only) All strategic development will make provision for permanent waste management.” The existing waste recycling transfer facility operated by Veolia is for general use and is not related to on-site waste management, agricultural waste, medical/research waste, or inert waste. Therefore, criteria (a), (e), (f) or (h) are not relevant in terms of potential alternative sites. It is expected that previously developed land within and on the edge of Cambridge would be redeveloped for higher value uses or the relocation of other commercial activities, and other potentially available land would be subject to constraints including impacts on residential amenity. The employment areas within Cambridge are protected for existing commercial uses or are subject to redevelopment proposals which excluded general industrial type uses. The employment areas in South Cambridgeshire are protected for a limited range of employment uses or are in villages where impacts on residential amenity would restrict a waste recycling use. The strategic development areas on the edge of Cambridge and in South Cambridgeshire are for residential and high value commercial uses where a waste recycling transfer facility is not anticipated or appropriate. Therefore, there are very limited opportunities within or close to Cambridge for a replacement site for a waste recycling transfer facility. Policy 4: Providing for Waste Management of the emerging Minerals and Waste Local Plan (Proposed Submission Draft November 2019) expects existing waste sites to meet identified needs and so no specific new allocations are proposed. Policy 4 sets out a criteria based policy for new waste facilities, which in summary must be located on sites within the settlement boundary of main settlements and in employment areas identified as suitable for B2/B8 uses or within strategic employment areas. The adopted Cambridge Local Plan 2018 identifies Areas of Major Change but none are suitable for a relocated waste recycling transfer facility, and there are no policies that support this type of use within the settlement boundary. It is likely that any redevelopment opportunities that exist in Cambridge would be brought forward for high value uses e.g. residential and commercial, rather than a waste recycling transfer facility. The South Cambridgeshire Local Plan 2018 does include allocations for B1/B2/B8 uses – at Over and Papworth Everard (see Policy E/5), and Policies E/12 and E/13 support employment uses within and on edge of villages but subject to no adverse impacts, and Policy E/15 identifies established employment areas which mostly accommodate office, research and development, manufacturing and logistics uses. It is likely that the existing employment sites in South Cambridge would not be suitable for a relocated waste recycling transfer facility because they are too far from Cambridge and existing and surrounding uses would be incompatible with such a facility. The Veolia site is identified as a Waste Management Areas (WMA), and Policy 10 of the emerging Minerals and Waste Local Plan applies. Policy 10 expects such sites to be used for waste management or compatible facilities. Criteria (c) of Policy 10 states: “proposals which demonstrate clear wider regeneration benefits which outweigh the harm of discontinued operation of the site as a WMA, together with a demonstration to the Waste Planning Authority as to how the existing (or recent) waste stream managed at the site will be (or already is being) accommodated elsewhere”. Criteria (c) anticipates that if waste management facilities are to be relocated – as is proposed in the North East Cambridge AAP – that there would be a strategy in place to manage the existing waste e.g. recycled waste treated at Veolia’s existing operation. Policy 10 is consistent with the approach advocated in Policy 26 (of the North East Cambridge AAP) that the relocation of the existing waste recycling transfer facility is a pre-requisite of redevelopment of the site currently occupied by Veolia. Therefore, it is considered that there are very limited opportunities within or close to Cambridge for a replacement site for a waste recycling transfer facility, in that available sites within Cambridge would be redeveloped for high value uses and that existing employment sites within Cambridge and South Cambridgeshire would not be suitable for such a use. Veolia is an existing established business, and a replacement facility must be located within or close to Cambridge in order to avoid the unnecessary transportation of recycled waste and material. This emphasises the need to maximise the development value of the Veolia site through this process in order to facilitate a relocation to ensure that they can compete with land values and ensure that that any move is financially viable as well as operationally. As set out in the response to Policy 24b, Veolia would be affected by the redevelopment of its existing site, and would welcome discussions and assistance from the Council to find a suitable alternative site from which it can operate a waste recycling transfer facility. Policy 27: Planning Contributions Policy 27 sets out the purpose and approach to planning contributions for development within the North East Cambridge Area. It is acknowledged that the policy contains some flexibility, in that contributions will be assessed on a site by site basis and that viability will be assessed where relevant. It is requested that the level of planning contributions and viability matters should also take into account whether a development is related to the relocation of an existing business or use within the AAP area and enable the delivery of wider aspirations and a coordinated strategy for the area. For example, it is proposed in the AAP that the existing waste recycling transfer facility operated by Veolia will relocate off site. The Veolia site needs to be redeveloped for high value business and housing uses. However, there will be costs associated with the relocation of the waste recycling transfer facility to an alternative site including the purchase of land. The relocation of the waste recycling transfer facility is a prerequisite and essential for the successful redevelopment of this part of the AAP area. It should be noted that HIF funding has been provided to enable the relocation of Cambridge Waste Water Treatment Works, but no public funding is available to support the relocation of Veolia’s operations. Therefore, it is requested that any planning contributions and viability considerations for the redevelopment of the Veolia site reflect and take into account the costs associated with the relocation of the waste recycling transfer facility. As outlined within these Representations the value of the Veolia site needs to be maximised to enable a future relocation and therefore the introduction of business (B1) and housing uses are supported. S106 or other associated development costs should be minimised. If the redevelopment of the Veolia site and the associated relocation of the existing waste recycling transfer facility is not viable, then it will either not happen or adjustments will need to be made to the proposed quantum of development or mix and type of uses provided at the site and/or to the level of planning contributions provided. Policy 28: Meanwhile uses The grant of temporary consent for ‘meanwhile’ uses within North East Cambridge is broadly supported. The ‘meanwhile’ uses could temporarily add to the range of facilities within the area, and could reuse empty or underused land and buildings. It is noted that Policy 28 includes a requirement for ‘meanwhile’ uses to be subject to relevant amenity issues. As set out above, the existing waste recycling transfer facility at the Veolia site located off Cowley Road is expected to continue until a suitable and viable alternative relocation site is identified. If ‘meanwhile’ uses occur in the vicinity of the Veolia site in advance of redevelopment it is requested that any temporary uses are compatible with the activities associated with a waste recycling transfer facility on the adjacent site. It is requested that compatibility with neighbouring uses is added to the list of criteria in Policy 28 for the approval of ‘meanwhile’ uses. Policy 29: Employment and Training The employment, skills and training initiatives associated with development within North East Cambridge are supported.

I write as Chair of the Federation of Cambridge Residents’ Associations, on behalf of the FeCRA Committee You will, I know, have received responses to the consultation both from individual residents and from Residents’ Associations. We endorse all the views expressed by Residents’ Associations, including, for example, those expressed by Milton Road Residents’ Association, one of the groups of residents who will be most severely and directly impacted by what is proposed. We were also struck by the comments made by (NAME REDACTED). My purpose in writing is to ensure that you are aware that we have registered a strong groundswell of opinion from residents that the overwhelming answer to every one of the ten questions in the Consultation is ‘No’. This proposal has become less and less attractive and persuasive as it has evolved, and the time has arrived for fundamental re-thinking of all parameters. There is grave doubt that what is currently proposed will be of any benefit to Cambridge, its residents, present and future, or provide any positive contribution towards solving the many concerns to which we are all fully alert. The building heights and massing are entirely inappropriate, and the building standards for the residential buildings fall far below Passivhaus or Sustainable Building Level 6. Water conservation standards proposed are far too weak. In this regard, as in many others, the model should be the standards already set by Eddington. The amount of dedicated green space is far too low, facilities are inadequate, and the proposed contribution to increasing biodiversity is totally inadequate. Whatever the undoubted merits of seeking to increase the availability of affordable housing, the price to be paid with this poor proposal is simply too high. Not least, the development will greatly exacerbate the housing crisis by drawing in twice as many people to the 20,000 new jobs as are being housed. We also have something like a new town with no social housing at all. We are very concerned that the consultation has not been fully and appropriately publicised, that the leaflet distribution was partial and flawed, and we have grave doubts that even now there is an appropriately widespread and full engagement with the important questions that arise. There are fundamental failures of programme management already. There is no risk analysis in the plan so there is no recognition that some outcomes depend on things which are highly problematic and with no way of recovering from failure. For instance, gridlock on Milton Road can only be avoided if two thirds of the potential car trips are entirely “discouraged”. This depends on measures which are unproven, and partly dependent on the whims of developers and property owners. If reducing traffic in Cambridge is this easy why it has not happened already? There is not space to consider the critical dependence on a transport strategy which is in complete disarray. “We want North East Cambridge to be an inclusive, walkable, low-carbon new city district with a lively mix of homes, workplaces, services and social spaces, fully integrated with surrounding neighbourhoods." The problem with this is it does not say what its objectives are in terms of housing and jobs, for who, and how this benefits different stakeholders. The current residents may or may not be included in this. It seems building is an end in itself.

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