S/NEC: North east Cambridge

North East Cambridge:
We have previously commented in detail on the plans for NE Cambridge [1]. We welcome some of the changes made to the Area Action Plan following the consultation, notably the increase in green space provision, reduction in building heights, and the rebalancing of jobs and homes which has been achieved through a reduction in the area of commercial office space. However, we remain essentially opposed to this development on the following grounds: a) although on a brownfield site, the development will directly cause the destruction of Green Belt land by displacing the Waste Water Treatment Works to Honey Hill. There is no operational need for the works to move; the proposal is purely to create development opportunity. b) As set out in our response to S/JH, we believe that the number of new houses already committed in the adopted Local Plans is sufficient to meet objectively assessed need: therefore we do not agree with bringing additional large developments forward at this point.
[1] https://southcambs.greenparty.org.uk/assets/images/local_parties/southcambridgeshire/NE%20Cambridge%20Development%20Sep2020.pdf

SUMMARY BELOW, REPRESENTATION DOCUMENT ATTACHED

ADDITIONAL DOCUMENTS SUBMITTED TO HELAA SITE 40096

7. Summary & Conclusions

7.1. The exclusion of a draft allocation for CSPN at this stage is regrettable and it is TCC’s view that following a review of both the supporting evidence bases for the JLP and North East Cambridge Action Plan (NECAAP), that neither documents current aims are deliverable without CSPN being allocated.

7.2. The JLP also does not identify how Cambridge can meet its future job targets or identified need, particularly in the mid-tech sector. To achieve the transport, employment and socio economic aims of the JLP, and separately the NECAAP, a radical reappraisal and interrogation of its supporting evidence base is required.

7.3. The evidence base is inconsistent and in places flawed. An allocation for CSPN provides the supporting policy and development management framework to recognise and harness CSP’s continued evolution and regional role as a significant contributor to employment, research and development for the Cambridge and UK economy. Additionally, an allocation for CSPN provides the capacity to deliver on the JLP’s stated employment aims. Its allocation is also an exciting opportunity to keep Cambridge at the forefront of innovation, securing a mid-tech future for Cambridge, the region, and the UK as a Scientific Superpower. Cambridge Science Park

7.4. Cambridge Science Park is the most sustainable location for further employment growth within Greater Cambridge, therefore the emerging JLP should reference the continued importance of Cambridge Science Park as an employment site.

7.5. Given the recognition of all other comparable science parks and employment destinations within the emerging JLP, and the recognition that North East Cambridge is the most sustainable location for development in Greater Cambridge.

7.6. The emerging JLP should therefore include the following policy: Policy S/CSP: New Employment Provision – Cambridge Science Park Appropriate proposals for employment development and redevelopment on Cambridge Science Park (as defined on the Policies Map) will be supported, where they enable the continued development of the Cambridge Cluster of high technology research and development companies. The need for Mid-Tech

7.7. As part of our Call for Sites submission we provided a 2019 report by Volterra (resubmitted for ease of reference), which clearly set out the floorspace requirements of mid-tech occupiers, to 2031 as ranging between c. 80,000 - 450,000 sqm of new floorspac.

7.8. A further Technical Note by Volterra is submitted with these representations setting out our feedback on the methodology and why we believe that the emerging mid-tech sector is not appropriately considered or acknowledged in these requirements, leading to a substantial under-provision of space which, if taken forward, will result in constraints on employment growth in the future. The importance of mid-tech and why it is not covered in the Employment Land Review are summarised as follows: • Mid-tech is not included in the ‘key sectors’ that are used to forecast employment need as these identify previously growing sectors, rather than future growth sectors; • The densities and use classes used to estimate future floorspace need may not be appropriate for the mid-tech sector.

7.9. We would urge Greater Cambridge to review the evidence with regard to mid-tech needs, and to engage with the Cambridge Science Park team to understand the needs of the sector.

7.10. We ask why has there been no consideration of mid-tech as a growth sector? Had this been done, it would be clear that (i) it has a large growth potential and (ii) it would benefit from clustering with CSP.

7.11. Our own analysis of the sectors which make up mid-tech highlights a very significant concentration of mid-tech in the local area. Why is this not acknowledged or given any weight?

7.12. The emerging JLP should recognise the importance of the research, development & innovation that occurs within the Cambridge economy and the need to accelerate the move to net-zero by supporting scientific innovation. The appraisal of CSPN

7.13. A review of the HELAA results for the other large employment sites identifies that there are other sites scoring similarly that are taken forward for Green Belt release.

7.14. Interrogating the two red scores for CSPN these relate to Landscape and the Strategic Highways Impact, the former has been considered on a strategic basis and takes no account of the local landscape (ie the impact of the A14) nor the landscape improvements included within the proposals. The Strategic Highways Impact is questioned for a scheme committed to no net increase.

7.15. However, despite CSP North being categorised as Red for its suitability, the site has been carried forward for the SA and an appraisal undertaken.

7.16. The site again scores similarly to other Green Belt sites taken forward for release. The SA then undertaken for the policies relating to those sites includes the policy mitigation, for example where landscape improvements are included within the policy, those sites are then afforded a more positive score than a site not taken through to policy wording. If this approach were undertaken for CSPN the site would score similarly well through the SA process.

7.17. The arguments made for other sites could also be said of CSP/CSPN but in the context of midtech rather than life sciences. CSP plays a recognised role in the clustering and growth of high-tech firms, supporting start-ups and scale-up businesses, but now needs space to enable mid-tech firms to continue to innovate and grow here. Whilst this growth could occur to a lesser scale on alternative sites outside the Green Belt, this would not benefit from the clustering with CSP and therefore the growth would be lower and less productive (the opportunities provided by a co-located Campus). CSP has, and CSPN will, be subject to significant private sector investment (just as valuable – arguably more so – than public investment) which in turn will deliver benefits to the public sector, such as playing a crucial role in delivering the sustainable travel objectives of the area.

7.18. It is therefore questioned as to why these arguments are recognised in the context of other Green Belt sites but not CSPN? Exceptional circumstances

7.19. The need for mid-tech is demonstrated, and the need for this type of employment space in close proximity to Cambridge Science Park and Cambridge Science Park has a distinct and unique set of characteristics, not available anywhere else at other research facilities in the sub-region and fully aligned with the Government’s Industrial Strategy.

7.20. CSPN would benefit from proximity to CSP and the long term custodianship of Trintiy College Cambridge, the later having made CSP one of the most successful Science Parks in Europe.

7.21. The socio-economic benefits in this location are illustrated, and links to Cambridge Regional College and wider educational institutions will benefit the next generation of innovators.

7.22. The sustainability credentials of delivering this site on a key transport route are clear, whilst the vision for a site with the highest environmental quality are demonstrated. Risks to NECAAP

7.23. Without significant interventions such as those which may be delivered by CSPN, a reduction in vehicle trips at CSP, sufficient to allow the delivery of the wider NECAAP will be difficult to deliver.

Conclusion

7.24. The exclusion of a draft allocation for CSPN at this stage is regrettable and it is TCC’s view that following a review of both the supporting evidence bases for the JLP and North East Cambridge Action Plan (NECAAP), that neither documents current aims are deliverable without CSPN being allocated.

7.25. The JLP also does not identify how Cambridge can meet its future job targets or identified need, particularly in the mid-tech sector. To achieve the transport, employment and socio economic aims of the JLP, and separately the NECAAP, a radical reappraisal and interrogation of its supporting evidence base is required. The evidence base is inconsistent and in places flawed.

7.26. An allocation for CSPN provides the supporting policy and development management framework to recognise and harness CSP’s continued evolution and regional role as a significant contributor to employment, research and development for the Cambridge and UK economy. Additionally, an allocation for CSPN provides the capacity to deliver on the JLP’s stated employment aims. Its allocation is also an exciting opportunity to keep Cambridge at the forefront of innovation, securing a mid-tech future for Cambridge, the region, and the UK as a Scientific Superpower.

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.