J/NE: New employment and development proposals

The emerging Policy J/NE New employment development proposals sets out whether proposals for employment uses within Classes E(g), B2 and B8 will be supported. According to the emerging policy, such developments will only be allowed at sites set out in the Proposed Policy S/DS: Development strategy, within towns and villages where it is of an appropriate scale, in a list of ‘established employment areas in the countryside’ or where expansion of existing businesses fulfil a number of criteria (described in the justification). The emerging policy, then, states at the end that “Large scale national and regional warehousing and distribution centres will not be supported in Greater Cambridge”.

From our review, it appears that this approach has been justified by the following paragraph:
“A need for additional space for warehousing and distribution (Use Class B8) was identified in the Greater Cambridge Employment Land and Economic Development Evidence Study (November 2020) and potential sites are proposed to be allocated (see the Strategy section of this consultation). However, whilst we need to meet the needs for local distribution, as a central location the area may be desirable to national distributors. Given the very high land take of this type of use, the local pressures on land supply for a range of uses, and the greenbelt location, it is proposed that the plan continues to not support large scale regional and national distribution proposals.”

The 2020 ELEDES that underpins the emerging Policy J/NE identifies a combined office, R&D, industrial and storage and distribution need of about 664,300 sq.m, of which just over 46,930 sq.m relates to storage and distribution uses (within B8 Class). When these figures are compared with the identified supply position, it results in a shortfall of 24,470 sq.m for storage and distribution space, and a combined shortfall of c.76,940 sq.m for the industrial and distribution space across Greater Cambridge to 2041 according to the Council’s evidence.
A detailed review by Lichfields of the 2020 ELEDES (as set out in Appendix 1) indicates a number of deficiencies in the evidence which has been produced, which we consider point to a significantly greater level of need for B8 storage and distribution floorspace in Greater Cambridge than is recommended in the study. This is set out in Chapter 2 of Appendix 1. A briefing note summarising these findings was shared with Greater Cambridge planning policy team on 26 November 2021.

In short, the review indicates that the requirements identified in the 2020 ELEDES for storage and distribution floorspace are at least 50% to 115% lower than the level of need within Greater Cambridge when considering the latest data, and applying a more consistent approach in estimating employment needs. It should be noted that these reflect net requirements, without considering any allowances for flexibility or losses replacement. Most importantly, these requirements relate to local, indigenous requirements for small businesses operating in storage and distribution-based sectors across the area and does not reflect the strategic requirements that are identified across the appropriate market area as set out in the PPG Paragraphs 26 and 31 and NPPF Paragraph 83.

In our view, the need for storage and distribution has been effectively overlooked by the emerging Local Plan, counter to the NPPF’s requirement for planning policies to accommodate the bespoke locational requirements for storage and distribution operations of all scales, and the PPG’s guidance in ‘How can local authorities assess need and allocate space for logistics?’ (Paragraph 31). On this basis, we have identified the lack of the evidential basis to robustly justify the emerging Policy J/NE stating that large scale national and regional warehousing and distribution centres will not be supported in Greater Cambridge, which clearly undermines the soundness of the Plan as currently proposed.

We recommend that Greater Cambridge must therefore now seek to properly assess and have regard to the requirements for storage and distribution operations of all scales and in suitably accessible locations in line with NPPF, taking account of the relevant FEMA and PMA, and to provide for such facilities. This requires a full assessment of strategic distribution needs, and an appraisal of all the available supply options to accommodate those needs, once identified. This is critical in order for the emerging Local Plan to be compliant with NPPF (Paragraphs 32 and 83) and PPG on Economic Need (Paragraph 31).

In the current absence of available evidence being prepared for the Councils, Lichfields has reviewed the existing evidence base and undertaken analysis of strategic distribution needs. This analysis was supported by detail market evidence from two of the most active commercial agents across the market, namely Savills and Bidwells (these market reports comprise part of Appendix 1). Both the market reports support that there is high demand for more additional employment space to serve Greater Cambridge and the wider market.

Our analysis as presented in Appendix 1 indicates that the appropriate scale of storage and distribution requirements arising in Greater Cambridge as part of the requirement identified across the relevant strategic logistics Property Market Area (PMA), which extends beyond the identified Functional Economic Market Area (FEMA) to parts of Northamptonshire, Bedfordshire, Hertfordshire, Essex and Suffolk, is estimated to be between 69.0 ha and 85.5 ha. This range reflects patterns of Greater Cambridge’s economic activity and employment representation across the market. This need is at least 500% to 630% above the proposed B8 requirements estimated by the 2020 ELEDES.

Lichfields scrutinised the identified supply across Greater Cambridge, and concluded that there is evidently only one site of 14ha developable area that can be genuinely regarded as suitable and available to accommodate strategic distribution uses. This represents just 2.8% of the requirement identified across the PMA, 8.7% of the FEMA’s equivalent and 16%-20% of the need identified in Greater Cambridge itself. Synthesising the analysis, there is a shortfall of storage and distribution employment land in Greater Cambridge between 55.0 ha and 71.5 ha across the Plan period to 2041.

Some of this shortfall must be accommodated within Greater Cambridge rather than those areas that have historically been relied upon to accommodate logistics need across the PMA (such as Peterborough and Northamptonshire) to avoid compromising the functioning of Greater Cambridge’s economy and to avoid a sub-optimal distribution network resulting in longer journeys by road and higher vehicle emissions.

Synthesising the above, the emerging Local Plan needs to consider updated evidence and to subsequently increase the employment supply across Greater Cambridge by allocating additional land of between 55.0 ha and 71.5 ha which is suitable, available and deliverable across the Plan period to 2041. This will align with NPPF and enable the soundness of the Local Plan.

As set out in Grosvenor's representations, see comments on the spatial strategy, the plan does not support the employment growth to the south of the City with housing allocations within the RSC. This is a major failing of the Plan.

Cambourne Town council would request the following statement be revised.
"Recognising that a number of business parks are located in the rural areas of South Cambridgeshire these key employment sites outside the Green Belt were identified in the Local Plan 2018 as ‘Established Employment Areas in the Countryside’. It is proposed to continue this designation for the sites previously identified to support their continued evolution:
• Cambourne Business Park, Cambourne;"
Is this still appropriate as South Cambs District Council aim to develop a large proportion of the site as residential or should it be clarified?

Amend

Draft Policy J/NE: New employment and development

The provisions in the development plan need to give greater weight to the significance of Granta Park in supported its continued evolution.

the National Planning Policy Framework (NPPF) 2021 is a significant material consideration. This outlines that planning decisions should make provision for clusters or networks of knowledge and data-driven, creative, or high technology industries (paragraph 81); and that planning policy and decisions should help create the conditions in which businesses can invest, expand and adapt (paragraph 83).

Within the UK the Cambridge sub-region is the major centre for the biotechnology sector and information and technology sector (ICT), and success in these sectors is recognised as being crucial to the success of the UK as a whole. The origins of biotechnology in the sub-region stem from the internationally renowned research base in the area.

The concentration (in the form of a mini cluster) of high-tech businesses at Granta has brought significant benefits to those businesses. This drive to support economic development, and in particular with a focus on the high technology and research sectors is reflected in the adopted Local Plan (2018).

The Government is committed to ensuring that the planning system does everything it can to support sustainable economic growth and the NPPF is clear in its mantra that planning should operate to encourage and not act as impediment to sustainable growth. At paragraph 81 of the NPPF is explicit that ‘significant weight should be placed on the need to support economic growth and productivity taking into account both local business needs and wider opportunities for development (our emphasis)’.

The research and development Sector has seen consistent fast growth particularly in South Cambridgeshire since around 1999. This is a key employment sector relating to life sciences (including biotech, natural science, and engineering) and linked to recent and planned growth across the various campuses including Granta Park and we expect a high level of tenant demand to continue. Clustering and agglomeration benefits are most obviously applicable to the life sciences. Greater Cambridge Employment Land and Economic Needs Study Nov 2020 identifies that the R&D Sector will continue to see growth.

Clustering and agglomeration benefits are most obviously applicable to the life sciences. Although, there are other examples of clustering such as the Cambridge Biomedical Campus which is located alongside Addenbrooke’s Hospital; the development of other campus / business parks across such as Granta Park - demonstrates the ability of life sciences companies to grow around Greater Cambridge – recognising the footprint of the specialist labour market and the fact that not every life sciences business requires adjacency to a research centre or hospital.

Granta Park is one of the leading U.K. Science Campuses offering state of the art laboratory and office facilities across 14 buildings. The Park spans 120 acres and is in one of the most recognised areas for scientific success globally and is home to leading companies, including Heptares AstraZeneca, Illumina, Pfizer, and PPD.

BioMed Reality’s approach to development has had a material impact on the biotechnology sector, enabling businesses to access first class facilities and so allowing them rapidly to progress their research and generate tangible results. BioMed Reality has a long-term relationship with tenant businesses and has thus facilitated the development and expansion of several established companies on the site. At the heart of the scheme’s ethos is creating a building that is flexible and adaptable and capable of accommodating a number of tenants. The new laboratory building will contain a maximum of 8 tenants and will contain a mixture of laboratory and office space.

Policies with the Local Plan need to recognise the growth opportunities on established Parks as they continue to evolve and be supportive of these, recognising the need to be able to respond to changing market below and re-invest in the existing built form. Policies within the emerging local plan should explicitly support employment development, and Granta Park should be being given similar weight to other campus developments.

Granta Park provides a high-quality working environment for over 2,000 people. The buildings are set within 120 acres of fresh air and inspiring views, and to help attain a good work-life balance the estate team organises a sports and social programme and a range of amenities on the estate. At the heart of the scheme’s ethos is creating a building that is flexible and adaptable and capable of accommodating a number of tenants, generate employment and have a material impact on the biotechnology sector, enabling businesses to access first class facilities and so allowing them rapidly to progress their research and generate tangible results. The development will make an important contribution to high tech activity within South Cambridgeshire. The park benefits from existing infrastructure that means that it is very well positioned to support further change.

Social Cohesion
The Granta Park Sports and Social programme includes an annual Rounders Tournament, a Football Tournament, cricket matches, an annual ‘Track and Field’ event, a weekly Granta Park Choir, a growing Christian Fellowship and ad hoc coach trips and social events. The Social Committee meetings are used as a forum to share ideas between the companies concerning charity events and local community events. A wide range of networking events are held throughout the year offering those on the Park ample opportunity to share information. This helps to create a culture of collaboration within Granta Park and the wider business community.

Nursery Provision
The 75 place day nursery opened on the science park in January 2001. This was replaced with a new nursery in 2017. Operated by Sunhill Daycare the Granta Park the new Montessori Nursery offers a maximum of 90 places between the opening hours of 07:30-18:30, Monday to Friday. The premises have been carefully designed to offer children a stimulating and exciting environment to play and learn in. Each room has its own secure outdoor area, offering all children interesting and challenging experiences both indoors and outdoors in all weathers. The outdoor areas have been created to develop children’s early science skills, and to help promote children’s creative and critical thinking. Children are introduced to the Montessori ethos before reaching pre-school age. The nursery accepts children aged from 3 months to 5 years for day care and pre-school, and up to 8 years for out of school club.

The Montessori ethos is used, alongside the Early Years Foundation Stage. Montessori focuses on the immense capacity of children to absorb information by giving them the freedom and independence to learn at their own pace. This is based on the deep understanding of the way children learn, through choosing, trying and doing things for themselves. Activities are designed to teach children independence from an early age, including self-serving their own meals, and washing up and tidying up afterwards.

Facilities (Gym and Food provision)
A full application for the “Apiary Building” to the west of Phase 2 Land has and implemented (ref: S/1315/15/FL). This is an ancillary facility serving the Park. That proposal was designed to offer fitness and networking facilities as well as some flexible space that could be used for a range of activities (including fitness activities, meetings or other social events). A day nursery has also been relatively recently implemented serving the research and development businesses on the Granta Park campus. The building has been completed to a high standard with air-conditioning throughout and is equipped with cardiovascular fitness machines, weights, benches, mats and weight resistant equipment. Gym members are entitled to attend free classes including fitball at lunch time and circuit training before and after work. Events at lunchtime such as a healthy eating promotion take place from time to time organised by the fitness trainer.

The coffee & sandwich bar is currently open between 10.30 and 14:30, Monday to Friday and operating a takeaway service only. Provided the facility is well used, it will remain open for those working at the Park. The facility provides snacks and coffees throughout the day, and hot and cold food at lunchtime freshly prepared on site and providing lots of healthy options. The restaurant offers a choice of hot and cold food freshly prepared on site providing healthy options and the opportunity for people to eat their main meal of the day at lunch time. The TWI approved scheme provides further café/eating facilities, which will be available to all users of the park.

Public Transport Links and commuter bus
Granta Park provides two commuter bus services, one from Cambridge Train Station with stops at Hills Road and Addenbrookes’ Hospital, and one from Whittlesford Parkway Station. The Commuter Bus starts at Cambridge city centre train station and picks up at four stops along the way into and out of Granta Park three times in the morning and three times in the afternoon. By train; the train station at Whittlesford which is on the Cambridge to London route is only four miles from the Estate. The Commuter Bus operates between this station and the park every day.

By public bus; Stagecoach number 13 bus runs from Cambridge to Haverhill stopping at Great Abington by a Granta Park footpath which takes about 10 minutes to walk. The Commuter Bus picks up from this bus stop on its way in and out each day for those who prefer not to walk. By bike, there are a number of cycle paths in and around the park and shower facilities on site for those wet weather cyclists.

Granta Park bicycles are available for staff based on the Park to borrow during their working day. They provide a great opportunity to grab some fresh air and take a break from your desk. The scheme provides for covered bicycle parking, and WC’s/Shower and associated storage facilities

Wider cycle links
Nearby, the N11 cycle route connects Cambridge to Sawston and there is a dedicated off-road cycle path linking Sawston and Babraham. There is a permissive cycle path through Babraham Farm which provides a link between Babraham and the Granta Park main entrance. This route includes a footbridge with cycle wheel ramps across the A11. Additionally, a link to the cycle route along the A1307 was opened in February 2017. This link provides a traffic free cycle route through The Babraham Institute which connects to the existing cycle network.

Car Share
Granta Park car share scheme is a great way to set up a lift share with other staff members commuting to Granta Park. Granta Park has its own dedicated car share website which offers members a quick, easy and secure way to make contact with each other.

Security
The Granta Park Estate is a safe environment to work in due to the 24 hour security which includes CCTV, a person present at the security gatehouse, and evening and night patrols. This supports flexible working hours where people can access the Estate at any time and will feel safe if they are working late at night.

Health and sport
In terms of benefits to the local community the permissive paths around the Estate are well used by local residents. Also, Granta Park sponsors the Linton Village College Youth Development Cricket Team which plays on the county standard cricket pitch each Saturday during the cricket season.

Woodland Walks and Biodiversity
Granta Park is also subject to a biodiversity action plan, which covers the estate and Granta Park. The site includes nature trails, woodland works and informal footways, which all provide an opportunity for exercise and recreational activity. The action plan also promotes and encourages diversity, which benefits the environment.

Granta Park sits next to the River Granta with its own lake and three woodland walks. It is home to a variety There is also a strong drive to improve biodiversity and support ecology, with the planting of native species and those known to benefit to local wildlife. This will help to increase native plant species diversity, and provide more ecologically valuable habitats of wildlife, many of which have taken permanent residence while others are regular visitors. The list of wildlife includes: the native crayfish, otter, kingfisher, little owl, barn owl and stock doves to name but a few. In addition, the wildflower meadow attracts an abundance of insects and butterflies as well as rare flowers such as bee orchids. Granta Park is also currently home to seven beehives. The honeybees are owned and managed by a local apiarist with many years’ experience in beekeeping.

It also needs to be recognised that the site context will be changing. The Cambridge South East Transport (CSET) proposals for a new Travel Hub adjacent to Granta Park would provide an off-road public transport route between Granta Park and Cambridge with an adjacent footway /cycleway, thereby providing an off-road route between the city centre and Granta Park. It is proposed to improve the cycle bridge across the A11 between Granta Park and the Babraham Research Institute thereby improving cycle access a significant barrier. As part of Phase 2 of the CSET route will create a new bus and cycle route direct to Granta Park. These routes will connect to the Chisholm Trail for journeys to north Cambridge, or the rest of the Cambridge City cycle network, and will allow a mode shift to cycling. The site benefits through from a highly successful Travel Plan sets a stringent target of 53% for single occupancy vehicle use. Granta Park fully recognises the importance of active travel management and this Travel Plan has been developed to provide a holistic approach for both the Park as a whole and for the individual tenant organisations

Comment

BioMed Realty requests that full consideration is given to ensure the development plan policies support the continued development and evolution of the part and recognises that recognises opportunities afforded through the redevelopment of the site, through both the repurposing and adaption of the existing building stock, but also the opportunities afforded to attract new occupiers through new development on the park. The sustainability credentials of the site are changing through the significant infrastructure improvements that are being delivered improving connectivity to Cambridge, but also nearby settlements. This will open new opportunities for the Park to continue to evolve and make better use of the site.

Policies in the Local Plan need to be flexible enough to supporting the needs of clusters and proactively recognise opportunities for some densification to make best use of established R&D Parks, including Granta Park.

The proposed Policy J/NE restriction on the provision of large-scale regional and national warehousing and distribution within the area is contrary to economic trends, market evidence and the scale of economic ambition for the Region. There is no evidential basis for the proposed restriction on large-scale regional and national warehousing and distribution within the area in draft Policy J/NE. Policy restriction on large scale regional and national warehousing and distribution within the area in Policy J/NE should be removed to align with national planning policy guidance should be removed for the reasons set out in the detailed representations submitted separately.

APPROPRIATE JOBS/WORKSPACE
Intense growth in the South and East of the country creates jobs in areas where there is already effectively full employment. The only shortage of homes in the area applies to homes that are truly affordable. To recruit more jobs, and then to argue that more homes are needed to support these new jobs is ludicrous. The jobs that are desperately needed are green jobs: those that will enable existing homes to be retrofitted, and the training that accompanies them; and care jobs. The councils acknowledge that they do not have the power in the local plan to determine which jobs will be filling the employment spaces. There is evidence that high-tech employment growth is actually damaging to low-skilled workers. It is also disingenuous to expect that the people moving into these new homes will be the same people as those taking the new jobs. Currently there are many residents who commute to jobs outside Cambridge (indeed, Cambridge is sold as a cheaper housing alternative to London, while being commutable), and many others who work in Cambridge but choose to live outside and commute in. The projected workspace also does not take into account the changing world of work which the pandemic has prompted. Office demand is becoming less with flexible working and hot-desking; shops are closing because of greater on-line purchasing.

NORTH-EAST CAMBRIDGE ‘CORE SITE’, COWLEY ROAD,
CAMBRIDGE


GREATER CAMBRIDGE LOCAL PLAN 'FIRST PROPOSALS' (REG 18)

Written Response on behalf of U&I PLC / TOWN

Monday, 13 December 2021


Classification L2 - Business Data



CONTENTS




0.0 INTRODUCTION 1
1.0 POLICY RESPONSE 2


0.0 INTRODUCTION

0.1 This document sets out written representations on behalf of U+I / TOWN, to a formal consultation by Greater Cambridge Shared Planning Services (‘GCSP’) on the Greater Cambridge Local Plan ‘First Proposals’ (Preferred Options, Regulation 18, 2021) (‘First Proposals’).
0.2 U+I and TOWN have been selected by Anglian Water and Cambridge City Council (as landowners) to act as Master Developer for the comprehensive redevelopment of the existing Waste Water Treatment Works (‘WWTW’), council depot and golf driving range (to be referred collectively as ‘the Core Site’), for the delivery of approximately 5,500 homes, 23,500m2 of new business space, 13,600m2 of new shops, community, leisure and recreation space (as currently set out in the North East Cambridge Area Action Plan (‘NEC AAP’) Proposed Submission Regulation 19 document). For the avoidance of doubt, these representations are submitted on behalf of U+I and TOWN as master developers rather than the landowners themselves.

0.3 Regeneration of the Core Site will be facilitated by the relocation of the WWTW, which will be funded from the Homes England’s Housing Infrastructure Fund, and which is currently going through a Development Consent Order approval process. Anglian Water will be submitting separate representations to the First Proposals, on this specific element.

0.4 U+I/TOWN have been actively involved in the policy formation process of the NEC AAP and are therefore looking to ensure there is policy consistency between the NEC AAP Proposed Submission and First Proposals documents.

0.5 Consideration will need to be given to the prospect of policy inconsistencies between the Greater Cambridge Local Plan (‘GCLP’) and NEC AAP.

0.6 As a point of broad principle, we would request that relevant GCLP policy (particularly where performance standards are stated) provides appropriate wording that defers to more area/site-specific policy, where it is being formed in other Development Plan Documents, such as NEC AAP. In the event of any inconsistency, this will ensure that there is a clear understanding over which policy takes preference. For instance, if a 20% biodiversity net gain (‘BNG’) target is ultimately adopted in GCLP policy, and a minimum 10% BNG is sought in NEC AAP, then there would be a clear signal in the GCLP policy that the NEC AAP policy is the correct standard to apply.



1.0 POLICY RESPONSE

Policy S/JH: Level of Jobs and Housing
OBJECT
1.1 The Cambridgeshire and Peterborough Devolution Deal committed to delivering substantial economic growth and to double economic output during the next 25 years. The Cambridge and Peterborough Combined Authority and the Greater Cambridge Greater Peterborough Enterprise Partnership acknowledge and support the economic growth potential of the Greater Cambridge area and consider that there is a need to substantially increase housing delivery in order to support economic growth (that is needed to meet the objective of doubling GVA by 2040) and address the significant housing affordability issues that exist (Cambridgeshire and Peterborough Independent Economic Review). At present there is an imbalance between rates of economic growth and housing delivery in Greater Cambridge.
1.2 These factors support a significantly higher number of homes than are proposed in the preferred ‘medium plus’ growth option of Policy S/JH. It is considered that the ‘medium plus’ growth option makes insufficient upward adjustments to the housing requirement (from Section Id.2a of the Planning Practice Guidance) to take into account growth strategies, strategic infrastructure improvements and housing affordability in Greater Cambridge.
1.3 It is suggested that the emerging GCLP should have selected the higher growth level option to support economic growth, address housing affordability, and reduce in-commuting. A higher growth level option would be consistent with the Government’s aspirations for the Oxford to Cambridge Arc.
1.4 It is requested that housing and jobs requirements in Policy S/JH are based on delivering the higher growth level option.


Policy S/DS: Development Strategy

SUPPORT

1.5 We broadly support this approach, given that it identifies North-East Cambridge for the creation of new compact city district on brownfield land, noting that it has already been identified for homes and jobs growth.
1.6 However, we are extremely concerned by the ‘Homes’ target for NEC that is stated in the table on page 32, which refers to 3,900 homes between 2020 and 2041. Fundamentally, this is at odds to the trajectory that has been agreed with Homes England as a pre-requisite for the substantial public funding that has been agreed in principle to relocate the WWTW.
1.7 We would therefore instead support a policy that recognises 5,600 homes will be provided on the Core Site by 2041. Consideration will also then need to be given to other housing that is expected to come forward within the NEC AAP.



Policy S/NEC: North-East Cambridge

SUPPORT

1.8 We support this approach but would request that GCLP policy for S/NEC is entirely consistent with NEC AAP. A simple policy that specifies reference to NEC AAP will enable GCLP policy to remain up to date, as and when changes are made through the examination and adoption process.
1.9 We would note that Policy 1 of the NEC AAP Proposed Submission states ‘approximately 8,350 new homes, 15,000 new jobs’, as opposed to ‘up to’ as set out in S/NEC.
1.10 S/NEC policy should therefore be amended to refer to ‘approximately’ and provide a clearer link to NEC AAP.


Policy BG/BG: Biodiversity and Geodiversity

OBJECT

1.11 The policy wording suggests that there will be a requirement for development to achieve a minimum 20% biodiversity net gain, which has been based on the South Cambridgeshire District Council Doubling Nature Strategy (2021), the draft Cambridge City Council Biodiversity Strategy 2021 – 2030, and the Oxford-Cambridge Arc Environment Principles (2021).
The Environment Act 2021, however, states that a minimum of 10% Biodiversity Net Gain should be achieved, and specifies the three forms for doing so:

- Post-development biodiversity value of the onsite habitat;

- the biodiversity value, in relation to the development, of any registered offsite biodiversity gain allocated to the development;

- the biodiversity value of any biodiversity credits purchased for the development;

1.12 Whilst U+I/TOWN recognise the importance in providing significant biodiversity improvements through development, it is considered that the mandatory minimum limit should reflect the legislative target. However, policy could still actively encourage schemes to exceed the minimum, recognising that those that do will be considered as a planning ‘benefit’ of development in sustainability terms (the greater the increase, the greater the weight attached to the assessment of benefit in any planning balance).
1.13 In terms of implications for the Core Site in North-East Cambridge, the NEC Ecology Study (2020) recommended that a target for a net gain of 10% is applied for all developments within NEC. Where this is not achievable within the site boundary then offsite measures should be provisioned.
1.14 By way illustration, a 20% gain to the 36.76 biodiversity units that have been identified in the Ecology Study would result in the need to achieve 44.112 biodiversity credits, in order to satisfy policy requirements. This seems highly ambitious, given the level of density that will need to be achieved across the Core Site to meet NEC strategy objectives. We will continue to make representations on this point as the NEC AAP progresses. GCSP must also consider alternatives to on-site provision where the necessary biodiversity net gain cannot be achieved on site. This could include a range of options including biodiversity net gain ‘credits’ being able to be purchased from other sites.



1.15 Ultimately, the aim of BNG is to leave the natural environment in a measurably better condition than beforehand. Therefore, if it can be robustly demonstrated that on-site provision is not achievable, the opportunity to measurably improve the natural environment of other appropriate receptor sites through off-site provision should still have a significant value attached to it.

Policy WS/HD: Creating Healthy New Developments

SUPPORT

1.16 We broadly support the 10 principles for creating healthy places. The vision for North-East Cambridge is of a healthy, inclusive, walkable, low-carbon new city district with a vibrant mix of high quality homes, workplaces, services and social spaces, fully integrated with surrounding neighbourhoods.
1.17 One of the five strategic objectives of the NEC AAP is for a healthy and safe neighbourhood and notes the principles of the Health New Towns programme.

Policy WS/MU: Meanwhile Uses During Long Term redevelopments

SUPPORT

1.18 We support the inclusion of a Meanwhile Use policy and agree that it can play an important role on strategic development sites. Phases of development can occur over a significant period of time, and therefore utilisation of vacant/redundant land/buildings for social and/or economic purposes can help activate an area and provide short/medium term benefits that might not otherwise be realised.

Policy GP/LC: Protection and Enhancement of Landscape Character

COMMENT

1.19 The policy notes that ‘the edges of Cambridge and the villages are an important area of transition which require sensitive landscaping to protect the setting of the settlements and to provide a well- defined edge which respects townscape and the countryside beyond’.
1.20 The Core Site at North-East Cambridge will need to be planned to a high density in order to fully achieve the the strategic objectives of the NEC AAP, as well as to hit the quantum of development required under Homes England’s Housing & Infrastructure Fund. This will require a number of buildings that are taller than may otherwise be commonly found in the north of Cambridge (including surrounding villages, such as Milton). The masterplan for the Core Site will take great care in how its development edges interface with the landscape and setting of nearby settlements, as well as adjoining ‘bad neighbour’ uses currently in existence. The policy will need to recognise the strategic objectives of NEC AAP and avoid imposing conditions that could unreasonably restrict development.

Policy GP/QD: Achieving High Quality Development

SUPPORT



Policy GP/QP: Establishing High Quality Landscape and Public Realm

SUPPORT


Policy J/NE: New Employment Development Proposals

SUPPORT

1.21 We broadly support the intent of the policy but consider it essential that GCSP takes a more ambitious approach in seeking to capture and accommodate the substantial demand in office, R&D, lab and associated manufacturing space in the Greater Cambridge area. There is a need to provide sufficient supply in order to meet the balanced homes/jobs requirements and to reflect the high employment density and employment skills these uses engender.
1.22 The Greater Cambridge Local Plan Strategic Spatial Options Assessment (Housing and Employment Relationships Nov 2021), upon which the homes and jobs growth of the First Proposals has been based (‘Central Growth’), considered a Higher Growth option of 78,742 jobs in the Plan Period. It
noted that ‘this is a plausible but more aspirational growth outcome’. We believe that the Higher Growth option should be pursued to reflect the Combined Authority’s commitment to doubling GVA by 2040 and capitalise on the significant appetite for research/knowledge-based, commercial development in the City.

Policy J/AW: Affordable Workspace and Creative Industries

SUPPORT

Policy H/HD: Housing Density

SUPPORT

Policy H/CB: Self and Custom-build Homes

OBJECT

1.23 The concern we have with this policy is the ability for the Core Site scheme to comply with the amount of Self-build/custom build being sought, given the high-density development that is envisaged. We would seek reference in the policy to wording that reflects the relevant policy in the NEC AAP i.e. to support ‘custom-finish’ as well.


Policy I/ST: Sustainable Transport and Connectivity
SUPPORT

On behalf of our client, Cambridge Innovation Parks Ltd (CIPL), we write in response to the Greater Cambridge Local Plan Regulation 18 public consultation.
We have reviewed the draft Plan and supporting documentation and set out our comments below.

Cambridge Innovation Parks Ltd

CIPL is a locally based developer and investor who provides premium serviced office space alongside additional amenities to create an ideal environment for nurturing high-tech companies from their very inception through to the point at which they need to start scaling up and beyond.

CIPL seeks to achieve the highest standards of sustainable development and strives to positively influence and accelerate sustainable change in the wider environments and communities in which it lives and works.

CIPL owns sites to the north, south and west of Cambridge. The intention is to create some of the first fully and truly sustainable campuses, focusing not just on construction and operation but also including leading environmentally friendly approaches such as carbon off-setting. In December 2020, CIPL submitted a hybrid application (ref: 20/05253/FUL) for the first of these schemes, which involves the expansion of an existing business park close to Waterbeach Barracks, into a sustainable innovation park, known as Cambridge Innovation Park North (CIPN). In July 2021, South Cambridgeshire District Council (SCDC) Planning Committee resolved to grant planning permission, subject to a S106 Agreement, which is in its final stages of negotiation.

Cambridge Innovation Park West

CIPL has interests in land to the east and west of Cambourne, in between the A428 and St Neots Road. An indicative location plan is included at Appendix A of the proposed allocation and a further smaller plot detailed in Appendix B which lies adjacent to the proposed allocation. CIPL is currently preparing proposals to create its second highly environmentally sustainable business park which will bring numerous high-skilled jobs to the local area, supporting the local economy. It will be known as Cambridge Innovation Park West (CIPW). Both plots of land are available for the use.
CIPL is therefore wholly supportive of proposed employment allocation ref: S/RRA/SNR (Land to the north of St Neots Road, Dry Drayton), which proposes to allocate the 4.6ha site for the following employment uses:

• E(g)(i) Offices to carry out any operational or administrative functions;

• E(g)(ii) Research and development of products or processes; and

• E(g)(iii) Industrial processes

CIPL would however request that the allocation boundary be expanded to also include for the additional land (Appendix B) which can provide for development and other associated use and mitigation.
CIPL operates within and is fully aligned with the principles of the Oxford-Cambridge Arc – a Government initiative that aims to promote and accelerate the development of a unique set of educational, research and business assets and activities, to create an arc of innovation and entrepreneurial activity that will, in time, be ‘best in class'.

Whilst CIPL are supportive of the proposed allocation, they are also keen to seek the nearby smaller plot as detailed in Appendix B also be included as part of the proposed allocation as it is also available, suitable, achievable in the short term and would help provide more employment land and fully capitalise on the sustainable location.

The CIPW site will be the flagship campus adopting an all-encompassing approach to sustainability targeting established forward-thinking companies who share CIPL’s sustainability and wellness values. The intention is to deliver an exemplar site built to zero carbon standards bringing together tenants who share their values and creating a community nurtured by their surroundings.

Deliverability

CIPL is in early discussions with South Cambridgeshire District Council regarding its plans to develop the site into a sustainable innovation park, with the intention to submit a planning application in late 2022. Construction will begin on site soon after permission is granted, meaning that the site will be in use ahead of the intended start date of 2025 for the construction of the Bedford to Cambridge section of the EWR.

In accordance with the definition contained at Annex 2 of the NPPF, the site is deliverable as it is: a) available; b) suitable; and c) achievable:

Availability

As stated, CIPL has interests in the proposed allocation site and additional land which is available now for development, subject to planning. CIPL intends to submit a planning application in late 2022 with the view to construction commencing immediately after the grant of consent. As such, the site is considered deliverable in the short-term (i.e. the next 5 years).

Suitability

The sites are in a highly sustainable location, situated adjacent to a junction of the A428 - the main easterly route into and out of Cambridge, with links to the A14 and the M11.

CIPL has engaged with the consultation for the construction of the Bedford to Cambridge section of the EWR and supports the emerging preferred options for the new rail link (Route Alignment 1 and Route Alignment 9) which will connect communities between Oxford and Cambridge – a project which can bring significant economic benefits to the wider area and increase public transport connectivity to rural areas of Cambridge.

Furthermore, the sites lie adjacent to the aspirational route of the proposed automated busway which will further connect the site with the Cambridge area and introduce another sustainable mode of transport on offer.

This increased connectivity, coupled with the sites being located immediately adjacent to a junction of the A428 will ensure that the sites area highly accessible and well-connected employment campus which can harness a substantial workforce in the Cambridge area.

Achievability

Technical work is underway to inform the scheme design and forthcoming planning application. There are no known constraints that cannot be mitigated or would prevent a scheme coming forward in the short-term.

The sites are therefore clearly and demonstrably deliverable in the short-term and its proposed allocation (and expanded allocation) is therefore justified and should be carried forward through to adoption.

CIPL also supports emerging strategic policies S/JH (new jobs and homes), J/NE (new employment) and J/EP (supporting a range of facilities in employment parks), which the CIPW proposals would directly respond to. Indeed, substantial planned housing growth will generate additional employment land requirements. Furthermore, CIPW would contribute to the spatial distribution of employment land – providing significant and high-quality floorspace and shared campus-style facilities in a predominantly rural, yet sustainable location.

Next steps

CIPL is wholly supportive of proposed allocation ref: S/RRA/SNR and request that it be expanded to include the additional land. They are also supportive of the emerging direction of the Greater Cambridge Local Plan. CIPL is keen to work closely with the joint councils during the plan preparation phase and in the pre-application discussions for the CIPW proposals.

Please can you therefore ensure we are kept up to date on plan progress and please do not hesitate to contact me, should you require any further information about the site.

Context
The NPPF places great importance on building a strong, competitive economy, and states that: “Significant weight should be placed on the need to support economic growth and productivity, taking into account both local business needs and wider opportunities for development. The approach taken should allow each area to build on its strengths, counter any weaknesses and address the challenges of the future. This is particularly important where Britain can be a global leader in driving innovation, and in areas with high levels of productivity, which should be able to capitalise on their performance and potential.” (Paragraph 81).
Planning policies and decisions should also “recognise and address the specific locational requirements of different sectors. This includes making provision for clusters or networks of knowledge and data-driven, creative or high technology industries.” (NPPF Paragraph 83).
The national and international significance of the Cambridge economy and its high technology clusters is recognised as a key component throughout the Reg 18 consultation. Cambridge has a leading presence in specialist sectors – including knowledge intensive businesses such as hightech manufacturing, life sciences and healthcare – and the retention and ongoing growth of these dominating sectors needs to be fully supported by the GCLP. The strength of Cambridge’s economy is typically attributed to the spatial concentration of local business networks within and on the edge of the city itself, which encourages sharing of knowledge and labour through economies of agglomeration, as well as the presence of a local, highly-skilled workforce which is driven by the esteemed Cambridge University and other research organisations. This was exemplified by the recent re-location of AstraZeneca’s global headquarters to the city in order to build on its relationship with leading research, academic and healthcare organisations based in and around Cambridge, which make it ‘one of the most exciting bioscience hotspots in the world’.
Future scale of employment growth in Cambridge
In this context, the Reg 18 consultation sets out the level of needs in Greater Cambridge that development will meet over the plan period of 2020 – 2041. For jobs, Policy S/JH proposes that the GCLP will meet the objectively assessed need for 58,500 new jobs, around 20,000 of which would be office and industrial jobs and the rest for jobs in services and support uses such as shops, schools and healthcare. This identified need is based on, albeit 100 jobs greater, the ‘Central Scenario’ (referred to as KS3) in the Greater Cambridge Employment Land and Economic Development Evidence Study (‘the employment evidence’). The Higher Scenario (KS2) forecast a need for 78,700 jobs over the plan period, compared to the central growth scenario of 58,400 jobs. Importantly, this is concluded to be the preferred – and recommended – range, and as such the two figures represent an upper and lower employment forecast to 2041. As it stands, the emerging GCLP only provides for the lowest identified need in this range (being just 100 jobs over the lower figure).
The authors of this study, GL Hearn, considered that the Central Scenario was appropriate over the Higher Scenario as per the below: “The reduction in growth rates is important to consider as it allows for the rate of growth in percentage terms to slow as the sectors expand, avoiding unrealistic absolute year-on-year changes in the sectors as they get larger.”
The highest growth projection scenario (KS1) was rejected because it “exceeds historic rates due to high long-term annual growth rates for growing individual sectors leading to disproportionate absolute change. This rate or level of growth should not be considered realistic given the population, development and environmental implications.”
Whilst it is noted that there is a possibility of individual sectors slowing in growth as they expand, those particular sectors which have primarily driven growth in Greater Cambridge such as tech and biomedical have not seen such a slowdown in growth. The assessment of the scenarios in the Greater Cambridge Employment Land and Economic Development Evidence Study looks at trends between 2001-2017 and 1991-2017, i.e. not taking into account growth in the past four years. Indeed, sectors such as tech and biomedical have accelerated over the Covid19 period and certainly since 2017. It is therefore considered that the evidence to support the adoption of the Central Scenario is lacking, and that the prevalence of these high growth sectors and their unfettered growth in challenging economic conditions would point to continued long term growth with associated higher long term job growth for Greater Cambridge. On this basis, planning for the ‘Central Scenario’ is not a sound, or realistic approach to planning for job growth in Greater Cambridge.
Further, the Reg 18 consultation acknowledges that the employment evidence suggested providing flexibility in employment land in case the market delivers more jobs than anticipated. This reflects the Cambridgeshire and Peterborough Independent Economic Review (CPIER), which considered employment projections that were even greater than the ‘Higher Scenario’ set out by the Councils. In their final report published in September 2018, the Independent Review judged that the most reasonable level of employment growth is that which assumes a continuation of recent higher employment growth rates, which have come in the context of nationally high employment growth, before gradually returning to longer-term levels. This would be in line with the much higher rates of growth that have been occurring in the Greater Cambridge area.
Importantly, the Independent Review also notes that there has been an under-projection of employment growth in the area; in other words, high employment growth has been unanticipated and therefore not built into targets. The East of England Forecasting Model (EEFM) is the primary model used to inform local plans in this region, and the report states that EEFM’s projections for employment growth in recent years fell below the actual output by a significant margin. In the aforementioned employment and economic evidence study, the Councils confirm that their preferred approach to employment forecasting involved using the EEFM; if employment growth continues to be significantly above that forecast by this model, then the GCLP will not provide for enough development (jobs and homes, which must be planned for in parallel to ensure unsustainable commuting patterns and worsening of affordability to not go unchecked). This is particularly significant given that the Reg 18 consultation is currently planning for the lower end of the recommended employment forecast.
The under-estimation of employment growth in Cambridge has been evident in recent years; since 2011 (the start of the current plan periods) Greater Cambridge has seen between 56% and 91% (depending on which source is used) of all jobs planned for in the 2011-31 period (41,400), despite only being around one-third of the way into the plan period. Given there is clear historic evidence of employment growth running higher than anticipated, it is vital that the GCLP recognises the likelihood of this continuing and allows for flexibility, particularly by expressing any employment figure in the plan as a clear ‘minimum’. The Council should also consider an early review mechanism if employment growth continues to run substantially above anticipated levels, in order that sufficient sites can be brought forward more quickly to accommodate this growth.
Taking the above points together, there is clearly justification for including higher employment related figures in the GCLP. The national importance of the Greater Cambridge economy, combined with world-renowned clusters and the strong performance of knowledge intensive sectors, has the potential to drive growth beyond the relatively modest figure in the emerging GCLP. The persistently higher growth rates in the Cambridge city region are also emphasised by other relevant stakeholders, including Cambridge Ahead. The need for flexibility to respond to economic opportunities is central to the NPPF (as cited above) but also the PPG (ID: 2a-027) with its requirement for plans to “consider and plan for the implications of alternative economic scenarios.”
Spatial options for employment
When considering the Spatial Strategy that the Greater Cambridge Local Plan is pursuing, it is notable from a review of the First Proposals map that there is a lack of new housing or employment allocations located on the south eastern edge of Cambridge. As can be identified through the existing allocations from the Cambridge City Local Plan within Policy S/EOC: (Other site allocations on the edge of Cambridge), there are a number of strong employment and housing sites which are being retained, but no further allocations to help strengthen and build those new communities which were started under the existing Local Plan, and provide no further options for growth for those important business locations. Notably within South East Cambridge, these include Peterhouse Technology Park and the allocations GB1 -4 which provide for both housing and employment uses.
This is particularly surprising given the locational advantages that this particular area on the edge of Cambridge benefits from, notably the upcoming delivery of the Cambridge South train station that is proposed at the Biomedical Campus. As is confirmed by the Transport and Works Act Order (TWAO) application made by Network Rail on the 18th June 2021 the proposed station will be supported by significant infrastructure upgrades, including the provision for 1,000 cycle parking spaces and improved roads/crossings to provide access to the station. As such, the station will be highly accessible by cycle, and sites with existing allocations such as the land south of Peterhouse will be easily accessible by cycle. It would therefore seem unnecessarily restrictive of Greater Cambridge to limit the allocations for employment growth in this area solely to the Biomedical Campus, and not to other strong employment locations such as those existing allocation sites GB3-4 which are within short public access of the new train station.
In addition to the overall need for new jobs, Table 3 in the Councils’ employment evidence also confirms that there is a demonstrable need for B1a/b uses, with projections showing that there will be a significant undersupply across the GCLP period even after the potential contribution of B1 mixed sites is taken into account. The evidence suggests that this reflects that most of the projected demand in B1b is assumed to be for research and development (R&D) employment, and that if the ‘higher growth scenario’ was achieved over the plan period then the current pipeline of supply is likely to be insufficient.
Businesses evidently want to tap into the location of Cambridge, and our site’s location to the south eastern edge of the city has existing connections to the rest of the Cambridge economy. Further Green Belt release would be justified in this area to facilitate further economic growth extensions at the PTP site in the context of Cambridge’s local need. This leads us on to the consideration of the identified locations for employment growth in the Reg 18 consultation.
The GCLP consultation sets out the proposed strategy for development in Greater Cambridge and Policy S/DS provides detail on where the homes and jobs identified in Policy S/JH should be provided in order to meet the vision and aims of the local plan. The growth strategy appears to be separated into five distinct locations – namely the Cambridge urban area, the edge of Cambridge, new settlements, the rural southern cluster, and the rest of the rural area – with the amount of proposed development differing in these areas according to their scale, characteristics and sustainability.
While the development strategy is not overtly clear on which sites will specifically include employment uses to accommodate the need for new jobs, Policy S/DS suggests that the overall focus for employment growth – some of which relates to mixed-use sites – will be at North East Cambridge, Cambridge East, Cambridge Biomedical Campus, Babraham Research Campus and other new or continued sites, primarily within the Cambridge urban area and existing business parks at the Rural Southern Cluster. The policy clearly lists the specific sites that will contribute to meeting the housing need requirement, setting out the quantum of homes to be delivered at those sites over the plan period, however it does not provide the same transparent approach with regards to the supply of jobs (i.e. sites for employment).
The GCLP provides further detail on new employment development proposals in Policy J/NE. This policy supports employment development in Cambridge at the sites set out in the development strategy and within appropriate mixed use areas of major change and opportunity areas, and states that other employment proposals in Cambridge will be considered on their merits where they are of an appropriate scale, character and accessible location. The policy goes on to specify a range of sites which are particularly suited to supporting the need of clusters, which include significant opportunities at:
• North East Cambridge
• West Cambridge
• North West Cambridge
• Cambridge Biomedical Campus
• Welcome Trust Genome Campus
• Granta Park
• Babraham Research Campus
• New Towns at Northstowe and Waterbeach.
While the policy recognises that cluster related employment is not restricted to these areas, the GCLP is not currently proposing to direct growth towards South East Cambridge – and neither is it identified as a proposed location for further employment development. It is considered that, given the need to plan for higher employment growth, the spatial approach and proposed allocations are somewhat limited and do not fully explore the potential of South East Cambridge to support other existing clusters. The site provides an opportunity to deliver additional employment land in a sustainable location; fundamentally, it can facilitate growth despite its current location within the Green Belt.
As such, the Councils should not arbitrarily limit themselves at this key stage in the local plan process by not countenancing Green Belt release, particularly in those locations such as South East Cambridge where there is already an established employment cluster that could suitably accommodate further development. The expansion of the PTP cluster should be specifically supported by the GCLP, and the Green Belt release of such sites could in fact lead to more sustainable outcomes, for example by facilitating a nature network as discussed in the previous section, and by delivering jobs in close proximity to homes.
The needs of specific sectors
Moreover, the specific need for further employment provision in specialist sectors – as identified throughout the GCLP and supporting employment evidence – means that there will be demand for further expansion of clusters that currently support these types of businesses and/or technologies. Arm Holdings (‘ARM’) is the anchor tenant at PTP and is a driving force in the global semiconductor (computer chip) industry. Its primary business is in the design of ARM processors (CPUs), for which it is considered to be market dominant, and it is one of the best-known ‘Silicon Fen’ companies (also known as the Cambridge Cluster).
There is currently a worldwide shortage in semiconductor production, which is not expected to end in the short-term, and ARM is therefore one of the companies that is well positioned to help address increasing industry demand. Millions of everyday products, such as cars, smartphones and fridges, rely on semiconductors and demand for new products that use semiconductors will only continue to grow. Further investment in semiconductor manufacturing capacity to boost supply is anticipated, and ARM is a leading global company set within the context of Cambridge’s economy which has an international reach. The demand for further expansion of ARM at PTP, which has emerged as a significant high-tech employment cluster, beyond 2041 can therefore be expected.
Considering the strength of and continued need for specialist sectors in Cambridge, it is also of importance that jobs in these sectors are unlikely to have been – or will continue to be – negatively impacted by COVID-19. The Reg 18 consultation document states that the employment evidence is based upon pre-COVID-19 data. However, the strength of Cambridge’s knowledge-intensive sectors, particularly its globally renowned life sciences cluster, has only been underscored by the recent COVID-19 pandemic and as a result, job growth has and will continue to trend upwards. A report by New London Architecture (NLA) highlights the contribution of the life sciences sector to the national economy and states that it is one of the most resilient sectors. While one of the most significant impacts of COVID-19 is the rise of homeworking, the nature of most jobs in life sciences requires employees to be physically present. As the economy adjusts to the ‘new normal’ it therefore seems apparent that both the global reach of Cambridge’s life sciences cluster and demand for space in this sector will only continue to grow.
How do other options compare?
New settlements
As previously noted, areas beyond Cambridge City are unproven employment markets; demand for employment space remains primarily in and on the edge of Cambridge City.
The emerging GCLP identifies Cambourne as a broad location for longer term strategic scale growth, with part of the settlement’s role to be a growing employment centre to provide local opportunities for its residents and nearby communities. However, Policy S/CB states that future development at Cambourne will need to consider: The economic role of the place, and which employment sectors would benefit from the location to support the needs of the Greater Cambridge economy. This suggests that there is no latent demand from existing occupiers or a particular need arising in this location for specific forms of employment space. As is confirmed below through a planning history review, existing provision on site includes predominantly general office space rather than research and technology companies which tend to gravitate to specialist clusters on the edge of Cambridge such as that at PTP. Policy S/NS sets out the direction for the three new settlements of Northstowe, the new town north of Waterbeach, and Bourn Airfield new village, which are proposed to continue to grow during the period of the new Local Plan and beyond, including elements of employment development.
Neither policy is clear on the amount or type of employment development that is to be allocated or supported in these new settlements. Historically, Cambourne and Northstowe have been delivering housing at relatively strong rates and are better associated with residential orientated development. A review of the relevant evidence and recent planning applications relating to potential employment development at the new towns indicates the following:
1 Waterbeach – Arguably the strongest potential new settlement for employment development due to the proximity of the existing Cambridge Innovation Park and Cambridge Research Park, which lie adjacent to the new town. Waterbeach is likely to build on the ICT/professional services and biotech sectors located at the existing parks and the site is coming forward through two large applications under two land ownerships.
Planning applications comprise: an outline application for 6,500 homes and 15,000m² of business (B1) floorspace, including small to medium sized offices, light industrial workshops, studios and maker spaces (reference S/0559/17/OL, approved 2019); an outline application for 5,500 homes and up to 22,400m² B1a office and 2,400m² B1c/B8 light industrial, storage and distribution space (reference S/2075/18/OL, awaiting decision); and a further application for the expansion of the Innovation Park, including new office buildings and floorspace (reference 20/05253/FUL, awaiting decision).
2 Cambourne – The extension of Cambourne (Cambourne West) is located immediately adjacent to the existing Cambourne Business Park, which contains larger scale office accommodation occupied by a mix of businesses in professional services, IT, telecommunications and research and development. The employment evidence confirms that the Business Park itself ‘has taken some time to work towards being an established employment location’, raising questions on the potential for the extension to deliver further employment space.
Outline planning permission was granted in 2017 for the Cambourne West extension (reference S/2903/14/OL), which included land for the provision of up to c.6ha of B1 employment space, anticipated to be small offices, R&D and clean technology businesses – however to date there does not appear to be further activity on this provision. Significantly, the land directly south of the Business Park is being promoted for residential development only; a screening opinion was recently submitted for 300 new homes (21/03771/SCRE).
3 Bourn Airfield – Located to the east of Cambourne, planning applications at Bourn Airfield suggest that the site is expected to deliver a mixed-use village comprising of 3,500 dwellings and supporting uses including 1,500m² of employment floorspace comprising offices, R&D and light industry (Class B1a, b and c uses) (reference S/3440/18/OL, awaiting decision). A further application, granted in January 2021, includes provision for an additional 24,620m² of employment space consisting of a mix of B1b (research and development), B1c (light industrial) and B8 (storage and distribution) (reference 20/02568/FUL).
4 Northstowe – The employment evidence makes clear that ‘Northstowe has a challenge in bringing forward employment under the current strategy’. The new town will eventually include up to 10,000 new homes and a range of other uses. Planning applications to date suggest that there will be a series of employment area parcels across the phases of development in association with the town centre and local centres, primarily for mixed B1 uses, however no employment floorspace has yet been completed within the new settlement which is in early phases of development. There are a number of other identified employment locations that are either established or seeking market position – including Cambourne and Waterbeach.
While this review provides an insight into potential employment development in the new town designated areas, it is not clear how much, and what type, of employment space is already permitted against that still being proposed in the emerging GCLP. As noted previously, the Reg 18 consultation does not set this out in a transparent way, and it is difficult to ascertain whether or not the importance (and delivery) of employment growth that is being proposed at these new towns is likely to materialise or be successful. If Cambridge wants to fully capitalise on its economic success then it must maximise the development potential of employment sites located close to established employment clusters which attract the best businesses and workers; this is an opportunity available to Greater Cambridge at Land South of Cambridge.

As established above, demand for both commercial development space has grown due to industrial expansions across Cambridgeshire in manufacturing, supply chain logistics and distribution, as well as the various technology sectors. However, the record low levels of available industrial and warehouse space are indicative of a widening gap between the supply of and demand for industrial space - a gap stimulated by a paucity in supply. As such, we support the Greater Cambridge Partnership's policy direction, which encourages employment development at appropriate scales on village boundaries.
In relation to Land to the east of Whittlesford Highway Depot in Whittlesford Bridge, commercial development of the site would provide a substantial boost to local job opportunities and would constitute a comprehensive expansion of the existing employment space along the site's western boundary. Furthermore, aligning with the aims of Policy J/NE and various other sustainability initiatives forwarded by the Greater Cambridge Partnership, development of the site would provide new commercial space with direct links to rail networks, therein reducing the need for incoming commuters to rely on their private cars.

Employment policy is considering supporting classes E(g), B2 and B8 in locations (In Cambridge Within towns and villages, Close to but outside settlement boundaries of villages, In defined ‘established employment areas in the countryside’ and In the countryside for the expansion of existing businesses). Which are not appropriate for either general industrial uses or for logistics development. The plan is looking to impose a blanket prohibition on large scale national and regional warehousing and distribution centres in Greater Cambridge.

A Distribution Centre is a warehouse that distributes goods outside of a company’s internal supply chain or to its retail estate. However, the ‘National’ prefix implies that it also transfers goods to Regional Distribution Centres (RDC). The ‘Regional’ prefix usually implies that the RDC is part of a warehouse network and it is supplied from a National Distribution Centre (see NDC) in order to better service a local region. Local companies with national or international customers would require a NDC or RDC. Similarly, companies supply the Greater Cambridge region would require a local RDC.

A Distribution Centre is a warehouse that distributes goods outside of a company’s internal supply chain or to its retail estate. However, the ‘National’ prefix implies that it also transfers goods to Regional Distribution Centres (RDC). The ‘Regional’ prefix usually implies that the RDC is part of a warehouse network and it is supplied from a National Distribution Centre (see NDC) in order to better service a local region. Local companies with national or international customers would require a NDC or RDC. Similarly, companies supply the Greater Cambridge region would require a local RDC.

While the plan is seeking to provide a range of new employment space this will not, together with the existing allocations, provide a good range in the type, size and location of sites that respond to the needs of businesses. A range of employment sites must be able to cater for the needs of the logistics sector and provide sites of at least 10ha close to the SRN. A single warehouse of 25,000 sqm (which is below the current market average) requires a site of around 10ha. Greater Cambridge will need to consider whether regional distribution centres are being provided in sustainable locations in adjoining authority areas to meet any regional need before unilaterally abdicating responsibility to meet regional needs.

The Plan needs to reflect the current and future needs of the logistic industry as that need is now manifesting itself, post Covid and post Brexit. Large sustainable sites close to the SRN need to be identified in a planned way.

See attached document.

Bruntwood SciTech are the recent new freehold owners of Melbourn Science Park and as landowners, seek to engage proactively with the plan making process. Established in 2018, Bruntwood SciTech is a 50:50 joint venture between Bruntwood and Legal & General and is the UK’s largest property provider dedicated to driving the growth of the science and technology sector.

With 10 campuses in six locations across Birmingham, Cheshire, Leeds, Liverpool, Manchester, Oxford and Cambridge, Bruntwood SciTech provides significant opportunities for science and tech businesses to connect, collaborate and grow.

With the new Joint Local Plan that is intended to run up to 2041, it is imperative that landowners such as Bruntwood Sci Tech are involved in the process of shaping policies and plans over this period of time.
Savills (UK) Ltd are instructed by Bruntwood SciTech to make the necessary submissions. (Savills have acted for Melbourn Science Park Ltd as previous owners of the site).
We confirm that a strategy of preparing the first Joint Local Plan for the Cambridge area is supported. There is a very strong symbiotic relationship between the built up area of Cambridge and the surrounding 101 villages as well as the market towns lying further afield. Given that many living within the surrounding villages turn to the City for work, retail, leisure and entertainment it is clear that a planning framework that acknowledges this relationship needs to be developed.

Paragraph 2.1
Figure 4 is an illustrative map showing the locations of proposed new housing development 2020 – 2041 and identifies a site at Melbourn for 140 homes. On the basis of the supporting paragraphs, it is logical to assume that the reasons behind the Council identifying new development in Melbourn is consistent with the strategy of directing development to where it has the least climate impact, where active and public transport is the natural choice, or green infrastructure can be delivered alongside new development and where jobs, services and facilities can be located near to where people live.
In the context of the proposed new housing development in Melbourn, it is the case that the village retains a very strong employment base and the history of major companies being attracted to the village continues to evolve - the current expansion of the new TTP group headquarters on the northern side of Melbourn Science Park and the aspirations of the new owners of that Park (Bruntwood SciTech) reflect the strong commitment of firms to invest in Melbourn. It is Bruntwood Sci Tech’s objective to become the leading network of thriving innovation districts acquiring buildings and sites for the long term and currently brings together a collaborative community of over 500 businesses across the UK. Its business strategy is to continue to grow the business through further acquisitions and the steady growth of existing sites and aims to provide 40,000 high value jobs over next 10 years whilst helping to level-up and rebalance the UK economy. As part of this growth, the company provides business support as standard, supporting science and tech companies to form, scale and grow. This includes facilitating access to finance, talent and new markets through connections and an extensive partner network to support the growth of the UK knowledge economy.
The recognition that the Plan gives to Melbourn as a location where growth can occur is important. The relationship between homes and jobs is, of course not a direct one but the provision of major employment opportunity in villages such as Melbourn is intended to reduce travel to work distances and provide the very opportunities that should exist in every settlement for people who wish to live in that village.


Policy S/JH “New Jobs and Homes”
The proposed new Local Plan is intended to follow the objectively assessed needs for development within the plan period 2020 – 2021 to meet the following:
• 58,500 jobs
• 44,400 homes which reflects an annual objectively assessed need of 2,111 homes per year.
The identification of 58,500 jobs reflects the choice of the Councils to provide for the medium growth level from the strategic options that were published in November 2020. The Council contend that this is the most likely figure of new jobs coming forward and whilst they are cognisant of the fact that the research identified the higher growth forecast, it is intended that the plan builds in some flexibility in case the market delivers more jobs than anticipated.

Policy S/DS “Development Strategy”
This policy sets out the proposed strategy for the pattern, scale and design quality of spaces created within Greater Cambridge and sets out where the homes identified in Policy S/GH should be located in order to meet the vision and aims of the Local Plan. In such a context, a development strategy is proposed which reflects the Councils’ intention to largely retain the Cambridge Green Belt whilst directing growth within Cambridge (20%, the edge of Cambridge (24%), new settlements (38%) and finally the rural areas (18%). The broad strategy is one where jobs and homes can be located close to each other and served by good quality public transport, cycling and walking lengths. Whilst the text does not specifically relate to Melbourn which is the home of Melbourn Science Park now owned by Bruntwood SciTech, it does refer to housing and employment in villages that have good public transport access and are close to jobs.

The development strategy needs to continue to tackle significant commuting patterns that have been established over many years between the outlying villages and Cambridge City. The presence of a tightly drawn Green Belt around the edge of the City and then tightly around the necklace villages and beyond means that the opportunities for expansion on the edge of Cambridge and on the surrounding villages is extremely limited. Consequently, this strategy places great reliance on those areas outside of the Cambridge Green Belt to develop and consolidate their employment sector to provide attractive locations for new investment and jobs. Melbourn Science Park provides such a significant opportunity and the new owners will continue to work with the local planning authorities in order to introduce new investment into the Park whilst ensuring that the very qualities and legacy that has been established over many years continues to thrive and prosper.

Policy S/SH “Settlement Hierarchy”
This policy within the Joint Local Plan is intended to group similar settlements into categories that reflect their scale, characteristics and sustainability. The village of Melbourn remains as a Rural Centre within this emerging Local Plan and is supported having regard to the acknowledgement that the Council’s recognise the role that the village can play in accommodating new development and in particular the allocation for a mixed use site on the eastern side of Melbourn Science Park. A Rural Centre places a settlement in a settlement hierarchy which acknowledges its sustainable location and the opportunity that this brings for new investment in terms of new housing as well as supply of new jobs.
In such a context, with Melbourn Science Park having been developed in its current form some 40 years ago, the demands of tenants, new sustainability targets and technology require a review and assessment of new building provision in order to attract new jobs and investment. Bruntwood SciTech as the new owners of Melbourn Science Park recognise the opportunity for the redevelopment of Melbourn Science Park as a previously developed site to bring forward new buildings and open spaces and land uses which are forward thinking and much better reflect the needs and demands of tenants, the businesses in general as well as visitors and the local community. The opportunity to make the best use of previously developed land in this location in a settlement identified as a Rural Centre is logical and reflects a sensible strategy with the opportunities of growth need not all be on greenfield land but rather need to critically analyse existing forms and sites to make best use of a limited resource.
It is the case that the acquisition of Melbourn Science Park is seen as a key strategic component of Bruntwood SciTech ’s science and technology business and will enable them to share knowledge and expertise across these sectors. The intention is to ensure that the site grows as a successful science and technology cluster that is sustainable in the long-term and contributes to the wider Cambridge economy. The company’s experience in these sectors, and with their relationship with funders, aligned to their commitment to expansion ensures that Bruntwood Sci Tech are ideally placed to deliver further growth at Melbourn Science Park.


Policy S/RRA/CR – Land to the West of Cambridge Road, Melbourn
A new mixed use allocation is identified on a 6.5 hectare site immediately to the west of Cambridge Road, Melbourn adjacent to Melbourn Science Park. This allocation has an indicative capacity for approximately 120 homes and some 2.5 hectares for employment uses. As a site that lies adjacent to Melbourn Science Park, there is a clear opportunity to enhance the village’s existing employment sector through more jobs and investment and providing a logical extension to the Park whilst planning for the adjacent residential development in an appropriate manner. Clearly, the layout and the integration with the adjacent Park will be critical and the ability to provide a sensible and logical arrangement for such uses can be achieved and consequently the identification of this allocation is supported by Bruntwood SciTech as the new owners of Melbourn Science Park.

Policy J/NE “New Employment Development Proposals”
This policy is intended to set out criteria which will determine whether proposals for employment development in urban areas, villages and the countryside are acceptable.
Having regard to our clients’ interests within the existing Melbourn Science Park which is already contained within the built up area of Melbourn, it is entirely appropriate that the proposed policy direction within the Greater Cambridge Local Plan is one that simply assesses the appropriate scale and character having regard to its location and the scale of settlement. It is entirely appropriate in this context to acknowledge that the present use of the site as a employment park is accepted and that the nature and scale of its existing character provides the opportunity for redevelopment to develop a much more modern approach to employment parks and to work alongside the authorities and the local community to develop a strong vision that continues the legacy of this part of the village to the village of Melbourn. As the Local Plan quite rightly acknowledges, for developments within town and village settlement boundaries, it is the scale and character that are key to ensuring that the overall character of the settlement is maintained. In such a case the Council expect that larger proposals are likely to be considered favourably in towns and Rural Centres and where Melbourn as identified as the latter within the settlement hierarchy it is entirely appropriate that our client looks positively at the opportunities that exist for redevelopment of the park. Whilst the Local Plan similarly does not list Melbourn Science Park as one of the key employment sites outside the Green Belt as stated in the Local Plan 2018, supporting text to Policy J/NE states that development in locations which provide a range of suitable units, including for start ups, SME’s and incubatory units will be supported.

Please find enclosed comments on Policy S/JH.

0.0 INTRODUCTION

0.1 This document sets out written representations on behalf of U+I to a formal consultation by Greater Cambridge Shared Planning Services (‘GCSP’) on the Greater Cambridge Local Plan ‘First Proposals’ (Preferred Options, Regulation 18, 2021) (‘First Proposals’).

0.2 This response concerns a site of 1.86 hectares, identified as Land South of Cambridge Road, Milton, whose red-line boundary is provided in Appendix A (“the Site”). The Site lies to the north of the A14 and adjoins the village of Milton. The Site has recently been used by Balfour Beatty as an offices and storage compound for the A14 Improvement Works since 2018, and photos of the Site (from Google Streetview), are provided in Appendix B. Balfour Beatty has now completed the relevant works on the A14 and has vacated the Site.

0.3 In terms of the broader context, U+I have been selected by Anglian Water and Cambridge City Council (as landowners) to act as Master Developer for the comprehensive redevelopment of the existing Waste Water Treatment Works (‘WWTW’), council depot and golf driving range (referred collectively as ‘the Core Site’), for the delivery of approximately 5,500 homes, 23,500m2 of new business space, 13,600m2 of new shops, community, leisure and recreation space (as currently set out in the North East Cambridge Area Action Plan (‘NEC AAP’) Proposed Submission Regulation 19 document).

0.4 In order to deliver the comprehensive redevelopment envisaged in the NEC AAP, a number of existing industrial /non-conforming uses (to residential) will need to either be re-accommodated within a mixed use, higher density, development superblock within NEC AAP or, more likely, be relocated from areas such as Cowley Road Industrial Estate to another location close to the north-eastern edge of Cambridge.

0.5 A Commercial Advice and Relocation Strategy has been commissioned by GCSP to consider this matter in greater detail, and its findings are expected imminently. It is unfortunate that this has not been made available to comment upon during this consultation process.

0.6 Notwithstanding this, it is considered that the Site has significant potential to accommodate the existing, important, businesses in the NEC AAP that will be displaced as a consequence of the major residential-led mixed use development that will be brought forward, following the decommissioning and relocation of the Waste Water Treatment Works.

0.7 Pre-Application Advice was sought from GCSP in respect of a series of development scenarios for the Site, as provided in Appendix C. The purpose of this was to explain the flexibility of the Site, and the attitude towards development of U+I to support those businesses that play a vital role in the wider economy and have a demonstrable need to be on the North-Eastern edge of Cambridge on a site that has excellent connectivity to the strategic highways network and pedestrian/cycle connectivity into Cambridge via the Jane Costen bridge.

0.8 A series of preliminary technical documents were also provided to support the pre-application request and can also be found in Appendix C.

0.9 The Site is currently located within the Green Belt, and this representation requests that it is released and allocated to accommodate commercial/employment uses for those business displaced from the NEC AAP

1.0 POLICY RESPONSE

Policy S/JH: Level of Jobs and Housing OBJECT

1.1 The Cambridgeshire and Peterborough Devolution Deal committed to delivering substantial economic growth and to double economic output during the next 25 years. The Cambridge and Peterborough Combined Authority and the Greater Cambridge Greater Peterborough Enterprise Partnership acknowledge and support the economic growth potential of the Greater Cambridge area and consider that there is a need to substantially increase housing delivery in order to support economic growth (that is needed to meet the objective of doubling GVA by 2040) and address the significant housing affordability issues that exist (Cambridgeshire and Peterborough Independent Economic Review). At present there is an imbalance between rates of economic growth and housing delivery in Greater Cambridge.

1.2 These factors support a significantly higher number of homes than are proposed in the preferred ‘medium plus’ growth option of Policy S/JH. It is considered that the ‘medium plus’ growth option makes insufficient upward adjustments to the housing requirement (from Section Id.2a of the Planning Practice Guidance) to take into account growth strategies, strategic infrastructure improvements and housing affordability in Greater Cambridge.

1.3 It is essential that any increase to housing is supported by a commensurate increase in the level of jobs (and vice versa), in order to maintain to maintain an appropriate balance of locating homes close to opportunities to work, within or on the edge of Cambridge, where it is accessible to public transport and/or good pedestrian / cycle / micro-mobility connections. 1.4 It is suggested that the emerging GCLP should have selected the higher growth level option to support economic growth, address housing affordability, and reduce in-commuting. A higher growth level option would be consistent with the Government’s aspirations for the Oxford to Cambridge Arc.

1.5 It is essential that housing and jobs requirements in Policy S/JH are based on delivering the higher growth level option.

Policy S/DS: Development Strategy OBJECT

1.6 Whilst we broadly, partially, support this approach, given that it identifies North-East Cambridge for the creation of new compact city district on brownfield land (noting that it has already been identified for homes and jobs growth) we object on the basis that it does not identify the Site as a suitable ‘receptor’ site for displaced commercial uses from NEC AAP.

1.7 Paragraph 140 of the NPPF allows Green Belt boundaries to be altered through the plan-making process provided exceptional circumstances exist, and those exceptional circumstances should be based on evidence and justified. It is considered that exceptional circumstances exist to release the Site, which is related to the specific need to provide land for existing businesses that will displaced by the NEC AAP.

1.8 Paragraph 141 requires plan-making authorities to examine all other reasonable options to meet identified development needs before considering whether exceptional circumstances exist to justify changes to Green Belt boundaries i.e. make as much use of previously developed land, increase the density of development, and consider whether development needs could be accommodated in neighbouring areas. In the case of Cambridge increasing densities and reusing previously developed land is not straightforward and may be inappropriate because of heritage assets and the difficulty of finding alternative sites for existing uses. The adopted Local Plans for Cambridge and South Cambridgeshire already identified previously developed land opportunities, and the emerging GCLP seeks to do them same. As such, previously developed land opportunities that are deliverable have already been identified within and on the edge of Cambridge.

1.9 Paragraph 142 requires any review of Green Belt boundaries to consider the need to promote sustainable patterns of development, and that where the release of land from the Green Belt is necessary that priority is given to previously developed land or sites that are well-served by public transport. It is acknowledged in emerging GCLP and the associated Sustainability Appraisal that the edge of Cambridge is a sustainable location because of its close proximity to employment and the opportunity to travel by non-car modes of transport.

1.10 The Site is ideally located to NEC AAP, being on the fringe of it, well connected to the strategic highway network and will be extremely well connected to NEC AAP via existing pedestrian and cycle routes across the Jane Costen bridge, that will lead directly into St John’s Innovation Park and the wider NEC area beyond it. Therefore, the release of the Site from the Green Belt would be consistent with the approach in national policy to give priority to those Green Belt sites that will support active travel.

Section 2.6: Rest of Rural Area / Policy S/RRA: Allocations in Rest of the Rural Area OBJECT

1.11 The successful delivery of the redevelopment of NEC is a key part of the development strategy for emerging GCLP. However, the redevelopment of NEC is reliant in part on the timely relocation of existing business from land to be redeveloped by other uses. It is considered that the relocation process would be made easier if additional land was identified in emerging GCLP for relocated businesses from NEC, whether temporary or permanent.

1.12 It is requested that the Site should be allocated in emerging GCLP as a suitable relocation site for some businesses that will be displaced from the NEC AAP. This outcome would represent the exceptional circumstances to justify the release of land from the Green Belt.

1.13 It is considered that, taking into account the current Green Belt status of the Site, land could be suitable for a range of potential industrial uses (or other uses that would be deemed ‘non-conforming’ to the residential uses within the NEC AAP). The Site is ideal for this type of end-use – there are no existing residential receptors within close proximity (the nearest residential property in Milton is 125m away, but this would separated by the intervening existing Industrial Park and Tesco), and the nearest new residential receptor in NEC AAP will be over 100m away and separated by the A14 (and therefore any residential edge of NEC AAP will be protected by new acoustic barriers on the southern edge of the A14).

Policy S/NEC: North-East Cambridge SUPPORT

1.14 We support this approach but would request that GCLP policy for S/NEC is entirely consistent with NEC AAP. A simple policy that specifies reference to NEC AAP will enable GCLP policy to remain up to date, as and when changes are made through the examination and adoption process. 1.15 We would note that Policy 1 of the NEC AAP Proposed Submission states ‘approximately 8,350 new homes, 15,000 new jobs’, as opposed to ‘up to’ as set out in S/NEC. 1.16 S/NEC policy should therefore be amended to refer to ‘approximately’ and provide a clearer link to NEC AAP. Policy BG/BG: Biodiversity and Geodiversity OBJECT 1.17 The policy wording suggests that there will be a requirement for development to achieve a minimum 20% biodiversity net gain, which has been based on the South Cambridgeshire District Council Doubling Nature Strategy (2021), the draft Cambridge City Council Biodiversity Strategy 2021 – 2030, and the Oxford-Cambridge Arc Environment Principles (2021).

1.18 The Environment Act 2021, however, states that a minimum of 10% Biodiversity Net Gain should be achieved, and specifies the three forms for doing so: • Post-development biodiversity value of the onsite habitat; • the biodiversity value, in relation to the development, of any registered offsite biodiversity gain allocated to the development; • the biodiversity value of any biodiversity credits purchased for the development;

1.19 Whilst U+I recognise the importance in providing significant biodiversity improvements through development, it is considered that the mandatory minimum limit should reflect the legislative target. However, policy could still actively encourage schemes to exceed the minimum, recognising that those that do will be considered as a planning ‘benefit’ of development in sustainability terms (the greater the increase, the greater the weight attached to the assessment of benefit in any planning balance).

1.20 GCSP must also consider alternatives to on-site provision where the necessary biodiversity net gain cannot be achieved on site. This could include a range of options including biodiversity net gain ‘credits’ being able to be purchased from other sites.

1.21 Ultimately, the aim of BNG is to leave the natural environment in a measurably better condition than beforehand. Therefore, if it can be robustly demonstrated that on-site provision is not achievable, the opportunity to measurably improve the natural environment of other appropriate receptor sites through off-site provision should still have a significant value attached to it.

Policy WS/MU: Meanwhile Uses During Long Term redevelopments
SUPPORT


1.22 We support the inclusion of a Meanwhile Use policy and agree that it can play an important role on strategic development sites. Phases of development can occur over a significant period of time, and therefore utilisation of vacant/redundant land/buildings for social and/or economic purposes can help activate an area and provide short/medium term benefits that might not otherwise be realised.

Policy J/NE: New Employment Development Proposals
SUPPORT

1.23 We broadly support the intent of the policy but consider that GCSP should be taking a more ambitious approach in seeking to capture and accommodate the substantial demand in office, R&D, lab and associated manufacturing space in the Greater Cambridge area.

1.24 The Greater Cambridge Local Plan Strategic Spatial Options Assessment (Housing and Employment Relationships Nov 2021), upon which the homes and jobs growth of the First Proposals has been based (‘Central Growth’), considered a Higher Growth option of 78,742 jobs in the Plan Period. It noted that ‘this is a plausible but more aspirational growth outcome’. We believe that the Higher Growth option should be pursued to reflect the Combined Authority’s commitment to doubling GVA by 2040 and capitalise on the significant appetite for research/knowledge-based, commercial development in the City.

Policy J/AW: Affordable Workspace and Creative Industries
SUPPORT

HELAA Site Assessment – Land South of Milton, North of the A14 (Site Ref. 47943)

1.25 U&I’s comments and suggested amendments to the site assessment are as follows: – Proposed Development – refers to Residential, Market and affordable housing, Specialist/other forms of housing, Office, Research and Development. We would request this be amended to B2/B8/sui generis uses applicable to other uses currently in NEC AAP i.e. those that might be considered non-conforming to residential; – Flood Risk – it is considered that this should be categorised as ‘green’.
The Site lies within Flood Zone 1, and any planning application would need to be accompanied by a site-specific Flood Risk Assessment, demonstrating how any localised flood risk arising from the proposed development could be adequately mitigated. Furthermore, the proposed use would be considered less vulnerable in flood risk terms.

– Landscape and Townscape: the Site lies between the existing urban edge of Milton (with Tesco to the north, the industrial park to the east, and separated from NEC AAP by the A14. The northern edge of NEC AAP (opposite the Site) has been considered acceptable (in Landscape / Townscape assessment) for new development of 3-6 storeys. It therefore seems perverse that the Site can be assessed as ‘Red’ in Landscape and Townscape terms and would request this be
changed to Green. The intended uses for the Site would be industrial / storage / sui generis uses, that are likely to be typically 1-2 storeys in height. The Site also benefits from landscaping on its boundaries, to help soften the impact of any new development.

– Site Access – we would request that this is changed to ‘Green’, given that the assessment notes that the proposed site is acceptable in principle subject to detailed design. There are potential access constraints, but these could be overcome through development.

- Noise, Vibration, Odour and Light Pollution – we would request that this is changed to ‘Green’, given that the assessment notes that ‘the proposed site will be affected by road traffic noise from nearby main roads but is acceptable in principle subject to appropriate detailed design considerations and mitigation. The proposed site will be affected by noise from nearby industrial/commercial activities but is acceptable in principle subject to appropriate detailed design considerations and mitigation. The site is capable of being developed to provide healthy internal and external environments in regard to noise / vibration/ odour/ Light Pollution after careful site layout, design and mitigation. Furthermore, the proposed use for industrial / storage / sui generis would be less sensitive (than for a residential use, for instance).

– Strategic Highways Impact: The good accessibility of the Site by sustainable modes of transport and future improvements to public transport, walking and cycling, would provide employees with an alternative to the car for journeys to work and reduce traffic impacts from the promoted development. If the Site is to be used as a ‘receptor’ site for existing industrial uses in NEC AAP, such uses will already be making a contribution to the strategic network (in terms of existing trips) and therefore the proposed use of this Site will have a negligible impact.

– Green Belt: The Site is currently located within the Green Belt. The Site has been assessed as having ‘moderate high’ Green Belt value. In comparative terms, this performs well in the context of other Green Belt sites in the north of Cambridge. Notwithstanding this, in terms of the five spatial ‘Purposes’ of Green Belt, namely: (a) to check the unrestricted sprawl of large built-up areas; (b) to prevent neighbouring towns merging into one another; (c) to assist in safeguarding the countryside from encroachment; (d) to preserve the setting and special character of historic towns; and (e) to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.

1.26 It is considered that only (b) and (e) would potentially be relevant here. In terms of (b) the Site lies in between the urban edge of Milton, and the northern edge of Cambridge. Theoretical coalescence between Milton and Cambridge has already, in effect, taken place by the presence of the industrial park, and its relationship to the north of Cambridge. However, this is physically separated by the permanent presence of the A14. The same would be true if the Site is developed. In terms of (e), it is considered applicable, albeit in the opposite manner of how (e) is intended. The release of land from the Green Belt here will assist in urban regeneration, by providing a receptor site that aids relocation of existing sites and facilitates NEC’s delivery.

1.27 It is considered that the Site provides lower value in Green Belt terms than has been assessed and its release would provide significant benefits insofar as providing a receptor site for important commercial/employment uses that would be displaced by the wider regeneration taking place at NEC.