S/CBC: Cambridge Biomedical Campus (including Addenbrooke's Hospital)

64 Knightly Avenue
Cambridge
CB2 0AL
07764 683951
fionawaller@gmail.com

12/12/2021



Dear Sir/Madam

I am writing in a personal capacity to object to the Draft Local Plan on the following grounds:
• Inadequate water supply
• Effect on national food security
• Failure to minimise climate change
• Likely irreparable damage to ecosystems
• Carbon emissions resulting from construction
• Lack of an integrated public transport system
• Undermining of the Government's policy of ‘levelling up’
• A democratic deficit in the process and evidence base .

I support the letter of objection sent to you by Friends of the Cam, available here:

https://www.friendsofthecam.org/sites/default/files/ObjectiontoNext%20LocalPlan_0.pdf


More specifically, I would like to comment on the proposals relating to the expansion of the biomedical campus to the south of the city. These proposals would take the fields in S/CBC/A, just south of the Ninewells development, out of the green belt.

The first proposals for the Greater Cambridge Local Plan set out to ‘increase and improve our network of habitats for wildlife, and green spaces for people, ensuring that development leaves the natural environment better than it was before.’ It will aim to do this by requiring ‘development to achieve a minimum 20% biodiversity net gain’.

The councils recognise, in relation to the plans for S/CBC/A that: “release of the areas proposed would result in very high harm to the Green Belt” and that “there are concerns regarding biodiversity and landscape impacts”.

However, they argue that “the harm of release would be lower than other land in this area, although this is still acknowledged as a high level of harm”.
I strongly believe that this high level of ecological harm can neither be justified or mitigated and can in no way meet the ‘20% biodiversity net gain’ requirement.
At first sight this area may appear unlikely to support high levels of biodiversity. However, in practice, as recorded by John Meed in his 10-year survey (https://queen-ediths.info/wp-content/uploads/2021/12/Interim_report_JM_2021.pdf), it is home to remarkable populations of red-listed farmland bird species of high conservation concern (1), as well as the equally endangered water voles. There are also good numbers of brown hare and a range of other birds, mammals (fox, rabbits, stoats, badgers etc), arable plants, butterflies, dragonflies and other invertebrates.

I am a herbalist and amateur botanist and have been amazed by the wide array of wild flowers at the field edges, some rare. I have never seen such an array at field edges in this country. The ancient hedgerows and margins, and waterways, are also rich in both flora and fauna.

I completely agree with the assessment of John Meed in his response to the plan (https://queen-ediths.info/wp-content/uploads/2021/12/Response-to-Policy-S_CBC-JM.pdf), that the mitigations Policy S/CBC proposes ‘to enhance biodiversity and green infrastructure’ on the field sloping up to White Hill do not go anywhere near far enough to counter the species loss elsewhere.

As he concludes: ‘It should be clear from the evidence I have gathered over the last ten years that Policy S/CBC/A will have a negative impact on biodiversity, and that the mitigation measures proposed will be insufficient to prevent this, let alone achieve biodiversity net gain. Habitat creation is always harder work than maintaining existing habitat.’

I have additional concerns regarding the use of the fields to expand the biomedical campus. The area is prone to severe waterlogging during wet periods; the area is used extensively by local residents for leisure; it is unclear what kind of development would be allowed; development will place additional demands on infrastructure and local services.
The Ninewells housing development was promised as a ‘soft edge’ to the city. Now, with the last sales on the estate only recently completed, the next Local Plan proposes taking the field immediately to the south (which is twice the size of Ninewells) out of the Green Belt to allow the Biomedical Campus to expand further – a hard, commercial edge to the city with disastrous ecological impact.

Please confirm that you have received my objection, and that this individual submission is noted, recorded, counted and made available.

Biomedical Campus expansion into areas south of Ninewells development should be resisted. Ninewells was advertised as the boundary when houses went on sale. The land is liable to flood on that southern part. It has execellent biodiversity. It is green belt. Expanding the Campus by that amount will add jobs that will increase pressure on homes in the area. Will increase water supply needs in unpredictable ways.It will add to climate change in the buildings and the extra concreting over of land.

I am very against the proposal to release land from the Green Belt adjoining Babraham Road and north of Granham's Road. The current development of Ninewells, only recently finished, emphasised a soft, green edge to the city. What was the point of this if new development is then added on? If the idea all along was to allow this field to be developed then it should have been done at the same time as the Ninewells development, so that all the space could be developed in an integrated manner, rather than just piecemeal. Another development, GB1 and GB2, on the other side of Babraham Road, has already been approved, which means already 430 more homes are going to be built in the next couple of years. Combined with the 270 homes in Ninewells, that means already 700 extra homes along Babraham Road. The road is already solid with cars coming into Cambridge every weekday morning after 7:45am, and solid with cars leaving Cambridge after about 3:30pm. An extra 430 homes will make it worse. The proposed expansion of the biomedical campus to Babraham Road will make it MUCH worse.

The land is grade 2 agricultural land which should protected in line with the government's national planning policy framework. It supports a great deal of wildlife including grey partridges seen just today. A lot of people walk around it and cycle past it. It leads to the important Gog hills and White Hill and the Nine Wells nature reserve. The land acts as a buffer between Granham's Road and the southern edge of the city. If the land is built upon then the edge of the city will be Granham's Road - a hard edge which is against the vision of Cambridge as a “compact, dynamic city located within the high quality landscape setting of the Cambridge Green Belt” (Cambridge 2018 Local Plan). Rather than proposing building, this area should be proudly incorporated into safeguarded area to link the Nine Wells nature reserve with the hills south of the city, and protected as part of the landscape setting of the city.

Previous plans had considered this Green Belt land but had rejected its use because of the risk of flooding. In January this year, when we had particularly heavy rains, there was a lake covering a large part of the field, corresponding very clearly with the flood risks (level 3) identified in the 2018 Local Plan. I would be happy to supply photos. I’m at a loss to understand how the flooding risk has reduced since 2018. It is an extremely serious problem and the Ninewells development has had the playground underwater and unusable by my daughters for most of the past winters.

The proposals talk about the importance of the Cambridge Biomedical Campus, and it is indeed a great asset to the city and the country, but there is currently plenty of space around the current buildings. I don’t understand how the Abcam building was allowed to have more space for the car park than for the building, since the traffic around Addenbrookes is already very heavy. Surely the existing and proposed extensions to the Park and Ride facilities along Babraham Road and further south, plus the Trumpington site, should have been leveraged rather than encouraging more car journeys by employees on the Campus? Another puzzle to me is why the air ambulance doesn’t go straight to a dedicated helipad on the roof of the hospital which would surely be quicker for patients than having to ride the last few hundred metres in an ambulance. This would free up a large area east of the new Abcam building. It seems to me poor justification to erode the Green Belt in order to satisfy the expansion of a Campus half a mile away that is currently much lower density than its potential. A Campus that sprawls across a mile of land will be less successful than one which achieves a critical density. No approval for development of this site should be given until the Campus has a clear plan for using the space it has already. This area shouldn't be speculatively included for Campus expansion in this version of the Local Plan.

Finally, there is one section that really grates. " • No development will be permitted south of Granham’s Road. However there may be potential to realign the eastern end of Granham’s Road to a point no further south than the southern boundary of the Wort’s Causeway development to the east of Babraham Road, subject to achieving an acceptable junction arrangement, with the Green Belt boundary following the line of the road. The additional area that may be created by realigning Granham’s Road is shown as a separate area at this stage, and will be explored further, with the boundary to be defined in the draft Local Plan.” This would be the junction of Granham’s Road that has just been modified, at great expense and disruption. The hedgerow that was cut down nearly two years ago still hasn’t been restored, and yet plans are already afoot to make this entire change redundant.

I aw very concerned with:
1. The removal of runoff drainage land on a low lying area
2. Damage and threat to wildlife very close to a nature reserve
3. Developers cutting corners and delivering poor quality housing / non-sustainable housing.
4. Lack of consideration given to non-car based transport and local civic facilities (Playgrounds are not enough!)

I strongly object to S/CBC-A being released from the green belt and further extension of the CBC. I believe this will create a harsh commercial edge to the city that is highly visible on the A1307 approach down from Wandlebury. There will be a high level of harm to the area with significant loss of open space and leisure routes on the edge of the city.

Wrapping the CBC around residential housing of Ninewells and Babraham Road is unacceptable and will have an extremely negative impact on the amenity of these existing residences. I feel the CBC could make better use of existing campus space and meet future growth needs through redevelopment of their existing campus and higher density development toward the train line. They could also seek an alternate approach of meeting new demand by collocating common services at off-site research campuses. I also object to the idea of realigning Granhams Road to create further expansion of the campus and erosion of the green belt.

The land denoted by S/CBC-A supports a large amount of wildlife and I believe mitigation for the loss of habitat in the proposed area of major change is likely to be insufficient. The area is prone to flooding and it’s possible that development could exacerbate existing drainage problems on the Ninewells development.

The CBC already has a large number of private car trips and local roads are extremely congested with spill over parking in the local area. The transport infrastructure is already insufficient with no viable alternatives provided for current use, never mind future increased demand. Credible infrastructure improvements need to be delivered and improvements to wellbeing of surrounding communities provided before future development is permitted (within existing campus boundary only).

I strongly object any development on site S/CBC-A. Reasons are many but include: the site is currently wholly within the Cambridge green belt and outside of the development framework. Any development here would substantially weaken the divide between urban and rural landscapes, despite other less impactful and non green belt options being available, e.g. brownfield options and even nearby land adjacent to the rail line, but not included for consideration. It would also impact wildlife and the biodiversity of the southern fringe, including important bird species. The site is close to the Nine Wells nature reserve, any development would be detrimental to this SSSI. A more appropriate option would be to expand the nature reserve to these fields and provide recreational utility for Addenbrookes and biomedical campus staff as well as local residents. As the development proposed is largely laboratory/office this development would likely cause further congestion and environmental impact as most people working on the biomedical campus would not live in walking or cycling distance. Though the Cambridge South station will be available, the limited station options on the rail route mean that most people would commute by car. The site is also liable to flooding as was clear last winter - many people can provide photos. More generally the water supply for Cambridge and the Addenbrookes site is unlikely be to adequate to support significant development. Any consideration of this site should be shelved until the existing biomedical site has been fully utilised and an assessment of the demand in a post/peri COVID context has been made. Much greater consideration of the spill over effects of further development on the wider community is required

Strongly object. There will be a significant increase in airborne particulates as a result of this plan. Biodiversity will be yet further decreased, with more encroachment on an already decimated greenbelt. Ninewells conservation area will be further threatened, along with several rare species that have been regularly observed in these fields. The fields regularly flood, and more hard surfaces will further increase watershed and risk of local flooding. The flood mitigation at the Ninewells housing development has been a complete disaster. Cambridge infrastructure is already poor, and in the absence of substantial improvements throughout the city, further development is only going to make matters worse. The whole fabric of what made Cambridge special is being eroded, and the Council seems hell bent on turning this city into some clone of Milton Keynes.

Unlike the Great Knighton area, which has been similarly overdeveloped, there is no country park on this side of Cambridge. This would be a much more sensible use of the land, making a positive contribution to climate change, biodiversity and mental and physical wellbeing.

Several scientific campuses are flourishing in Cambridgeshire in more rural locations. As a medical practitioner I know there is absolutely no logistic reason why labs have to be in close proximity to each other, or even to a hospital.

I argue that there would not be expected to be an ever continuing need for healthcare facilities on the CBC beyond those significant investments already planned (Cambridge Childrens' Hospital and Cambridge Cancer Research Hospital) in the next 25 - 50 years and use of exisiting allocated land in this area. If expansion of the hospital facilities are anticipated to outgrow the existing campus one could again look to expand other peripheral facilities. Patients currently travel considerable distances for tertiary care at Addenbrooke's and efforts to provide outreach clinics and services at the surrounding local hospitals would reduce the considerable burden of travel for these large numbers of patients. Furthermore, with improvements in health and social care allowing more care to be delivered in the community, the increasing use of technology for virtual consultations, and advances in treatment that allow therapy to be delivered in patients' own homes or in tablet rather than injection forms, it is debatable whether exisiting hospital capacity on the campus needs to expand significantly or if this would be for the benefit of patients. The idea that staff need to be centred in one location containing multiple different functions is also outdated, given the ability to work virtually, and the specialised facilities required by individual departments in the hospital, as far as elective surgery and elective consultations are concerned also need not be centralised on this Campus. Rather one wonders why there could not be development of further healthcare facilities toward the east of the city around the Airport, which would make use of the existing and planned housing developements in this area and would in fact reduce commuting for those staff members who live in and around the Cherry Hinton area, while public transport links from the east of the city to the hospital and any future Cambridge South station should be strengthened. Equally if Campus expansion is deemed to be inevitable there would appear to less environmental impact from development of the land south of Addenbrooke's Road, between Hobson's brook and the railway line, or indeed land further to the West, between Addenbrooke's road and the M11. In the case of the latter, this site could easily be linked with the existing campus by shuttle bus and would reduce congestion around Trumpinton Road and M11 J11 if a dedicated access path were made, while it would bring considerable enhancement to the land south of Addenbrooke's Road.

Arguments relating to colocalisation of research and industry on the campus are of course attractive to investors and industry, but for decades such investment has supported the development and expansion of numerous science parks outside of Cambridge, where there is less of an impact on the environment form development than in the already congested Cambridge Southern Fringe. Research facilities on the Campus are currently under-occupied and building new facilities where existing building are unusued purely for commercial gain or profit from lands sales does not seem an appropriate use of Greenbelt Land. Pharmaceutical and Biotech companies in the area currently have no difficulty recruiting staff to Cambridge but indeed local transport infrastructure would be improved by the planned busway towards Babraham Road Park and Ride and consideration of extending this from the Biomedical Campus to Granta Park and improving the frequency of busses along Babraham Road to the Babraham Research Campus. Indeed the number of people communiting out of Cambridge rather than into Cambridge for work is an opportunity to develop new and expand existing sustainable transport links to these peripheral science parks as it is inevitable that some employees of any potential new developments on Campus will live at a distance requiring their own transport methods including motor vehicles. Whilst it is noted the the development will be dependent on a Trip Budget approach I would argue that this is in reality extremely difficult to model accurately and is unlikely to result in a net reduction in car travel, either for employees in this location or for travel to and from local facilities, and schools for example due to the considerable distance from central Cambridge and exisiting education facilities.

The numerous new housing developements in the Clay Farm Estate, Ninewells and Trumpington Meadows sites have already augmented the housing available to staff and in particular key-workers on the Biomedical Campus. There is clearly a profit to be made for the landowners from conversion of this Greenbelt land if permission is given to develop commercial property and housing, simply due to the existing transport and proximity to Cambridge as well as allowing road travel out of and around Cambridge on this Southern Fringe site, but this commercial gain does not seem a valid reason for removal of this site from Greenbelt land. While some of the housing will be available for keyworkers, the majority would also not be afforable for the majority of staff working on Campus and therefore the argument that this would be required to support the growth of the campus is hard to realise. Adjacent Greenbelt land has aleady been released either side of Wort's Causeway and if unbiased modelling shows further housing is genuinely required by the Biomedical campus, with a desire to reduce travel into Cambridge or the campus, sale of these houses should be prioritised for staff and keyworkers on the campus.

Besides the question as to the need for allocation of this further Greenbelt land to the campus, the impact of removal of the proposed area in S/CBC-A would be hugely detrimental to the biodiversity supported both within the fields and by the natural hedgerows that surround these, which form an exisiting green corridor, as flagged by the council's own assessment. It seems unlikely any amount of compensatory work to increase biodiversity close to existing Ninewell's nature reserve could exceed the loss of biodiversity that development of this site would result in, if only because of the areas of land involved, and the density of animal populations this could support, as the proposed protected land is already rich in biodiveristy, so there is likely to be only a token gain from the proposed Green Belt enchancement. Similarly, there is already a very easily accessible large green public space close to the Campus near to and surrounding the Hobson's Park bird reserve, which is currently under-utilised and could be made more accessible by providing easier access by foot and cycle to cross the railway line, where the footpath at the exisiting southern edge of the biomedical Campus joins the DNA path from the Shelfords and the south. Indeed the area could better be enhanced by increasing the green infrastructure either side of the railway line and towards the Shelfords.

In terms of topology, the S/CBC-A site is both at the bottom of the chalkland ridge and Gog Magog hills, and also downhill of the existing Biomedical campus, such that there is a high ground water level in this location, and the area can already become waterlogged for several months of the year with groundwater flooding apparent for several weeks or months most winters. If this land were developed it would lead to reduced drainage into the exisiting ground and result in increased rainwater falling from the Gog Magog hills and the developed land having to drain at the northern margin of the site. This has the potential to result in a significantly increased risk of flooding to surrounding exisiting developments and drains, which are already often at capacity due to the nature of the clay soil and numerous aquifers in this region. There are also a number of red-listed farmland birds that occupy this area as well as other wildlife, attracted especially by the rich natural hedgerows that surround this land. There is also a significant issue related to sewerage in this region with pumping and storage already required for sewerage from the Ninewells development.

The proposal to build commercial premesis would also result in unacceptable noise, traffic and importantly visual disturbance to existing residents who enjoy this quiet landscape and natural edge to the city along the designated Greenbelt land and these units would both significantly impact existing views of and from this edge of the city. A moreover new commercial premesis would result in further congestion to exisiting transport routes along Babraham road and the Southern Fringe. As the majority of Keyworkers tend to be younger individuals or those with families, development of new Keyworker housing would also need to be conducted hand-in-hand with appropriate transport links and education facilities provided for these families. The lack of school provision in the plans is surprising and I believe would lead to further heavy vehicle traffic toward the schools in Queen Edith's and nearby areas. Babraham road is already thorougly congested at peak times and adding another 990 homes in this area would surely exacerbate matters further besides the traffic to the commerical areas, as mentioned above, with the significiant difficulties likely to be encountered in attempting to model a Trip Budget accurately.

In summary I do not believe there is, or at least there has not been presented, adequate evidence for the need of further release of Greenbelt land adjacent to that already agreed in the area, nor the need for significant further expansion of the Biomedical Campus itself for reasons outlined above, and moreover that there are advantages to continuing to develop the links to exisiting out of town Science parks and the surrounding villages and communities.

The Biomedical Campus should not be allowed to sprawl half a mile to the east until it has filled in all the gaps - and utilised the helicopter landing area - in its current Campus. An efficient, high density development will be more effective than a sprawl. Use less space for car parks and keep cars off the Campus more effectively. Above all, don't allow a speculative sprawl now. Don't give permission that depends on conditions being met, but make it part of a future Local Plan with all of the consultation and consideration that entails.

For the last ten years I have been conducting ecological surveys of one square kilometre of green belt which includes the area of major change. The fields I study are bounded by the Biomedical Campus, the Nine Wells development, Babraham Road, Granhams Road and the railway line. I attach a copy of my interim report for 2021.
At first sight the area I study may appear unlikely to support high levels of biodiversity. However, in practice it is home to remarkable populations of red-listed farmland bird species of high conservation concern, as well as the equally endangered water voles. There are also good numbers of brown hare and a range of other birds, mammals, arable plants, butterflies, dragonflies and other invertebrates. The fields affected by S/CBC/A and S/CBC/E2 all form crucial parts of the wider ecosystem.
Key species affected include grey partridge, which declined by 93% between 1970 and 2018 and are now considered vulnerable to extinction in the UK; corn bunting and yellow wagtail which declined respectively by 89% and 68% and are now considered near threatened meaning that they are likely to become at high risk of extinction in the UK in the near future. The fields affected by S/CBC/A were home this year to five pairs of grey partridge, four corn bunting territories and three pairs of yellow wagtail.
For several reasons which I discuss in the attached detailed submission it is entirely unrealistic to expect Policy S/CBC, as it stands, to achieve the minimum required 20% biodiversity net gain of habitat. Even if offsite habitats were proposed that might benefit farmland birds elsewhere these would not justify losses of sedentary farmland bird species from their existing range.
If Policy S/CBC is genuinely essential to the future of the City and South Cambridgeshire, and sufficiently exceptional to justify the release of green belt, a separate mitigation or compensation package would be required for the farmland birds in order to take account of particular species in a locality that give habitats their local distinctiveness (Defra). This would mean improving the arable habitat across Granhams Road land to provide a refuge for the displaced wildlife as the species concerned are not readily mobile. In the attached detailed submission I propose ways in which this might be achieved; however, habitat creation is always harder work than maintaining existing habitat and retaining the existing fields would be a less risky option.
I attach both more a more detailed submission and my interim report for 2021 of the area I survey.

The strategic rationale given for release of this site from the Green Belt is the economic importance of the Cambridge Biomedical Campus (CBC). The prospectus submitted by the principal occupants of the CBC, ‘Vision 2050’, sets out the scale and benefits of colocation between the NHS, the University of Cambridge, the Medical Research Council and the private sector. It argues that this dynamic biomedical complex is of local, regional and national importance for the production of both health and wealth. These arguments are well-rehearsed and there is abundant evidence available to support them. The basic premise that the CBC is a national asset is not, in any way, challenged here.
That said, there are two aspects of this prospectus that are problematic, and that need be critically examined as part of the Local Plan process. First, although Vision 2050 articulates the importance of the interaction between the various sectors represented on the CBC, it disregards the need to maintain a balance between these sectors. Second, it is misleading about the prospects for NHS hospital renewal on the campus. These two issues are closely interlinked.
An appropriate balance between investment in hospital renewal and growth is needed for two reasons. First, and most obviously, the CBC is driving employment growth and consequential population growth. The most obvious example of this is Astra Zeneca, which will be creating or relocating an additional 2,000 jobs on the campus. These people, and their families, will add to existing demands on local health infrastructure, including hospital services. Second, the success of the CBC biomedical complex relies on clinical research as well as laboratory research. The co-location of these two types of research is critical for the knowledge and wealth production dynamics of the CBC, as has been recognised since the original ‘2020 Vision’ first published in 1999. Clinical research requires a well-founded hospital, with sufficient space, staff and supporting infrastructure to deliver this strand of the ‘tripartite mission’ (i.e. clinical care, clinical research and clinical education).
At present, what we see on the CBC is a growing imbalance between the facilities available to the research partners on the site and the public hospital. To put this in stark terms, gleaming new research facilities surround the decaying and increasingly overcrowded NHS facilities at the heart of the campus. Land zoned for Addenbrooke’s hospital development for over a decade still stands empty (apart from some Covid response modular buildings,) providing a constant reminder of how little progress has been made in addressing this deficit. Only the new Royal Papworth, which is under separate management, provides a welcome contrast. The growth and renewal of Addenbrooke’s was at the heart of 2020 Vision, yet this aspect of the original strategy has been least advanced least over the past decade.
Vision 2050 is optimistic in its statements about this situation, stating that ‘soon, building will commence on a new cancer hospital and a new children’s hospital on site’. These claims need to be critically examined in the context of the Government’s programme for ‘40 new hospitals’. Well-informed commentators are remarking on the severe inadequacy of the sum set aside, £3.8 billion, to fund this ‘Health Infrastructure Programme’ (HIP). NHS Providers estimates the true sum required to be at least £20 million. In addition, NHS hospitals face a total ‘backlog maintenance’ bill of £9 million, of which more than half is ‘high risk’ or ‘significant risk’. Cambridge University Health Partners, which runs Addenbrooke’s and The Rosie hospitals has backlog maintenance reported at £104 million in 2020. The new Cambridge cancer hospital is in ‘HIP 2’, which is a tranche of schemes due to open between 2025 and 2030. The only funding so far set aside for schemes in HIP 2 is an undisclosed amount of ‘seed funding’. The children’s hospital, which has been under discussion for around 30 years, is not even included in HIP, and its status remains unclear. The use of the word ‘soon’ in this context is certainly very optimistic, and potentially misleading.
In these circumstances, it is unfortunate that Addenbrooke’s hospital management has chosen to align itself in an uncritical way with proposals for further development of the CBC, even to the extent of supporting those for large areas of land south of the campus and between the M11, Addenbrookes Road and the A1301 (thankfully, these proposals have not made their way into the draft Local Plan). Instead of supporting developer-led proposals that will further stoke up demands on the hospital, to the disbenefit of all local people, the hospital should be vigorously pursuing the argument that some of the planning gain from further CBC development must be ringfenced for hospital renewal. This must be in addition to reliance on HIP, prospects for which appear increasingly uncertain. The GCP Local Plan process offers an exceptional opportunity for the sub-region to lead the way in developing such an alternative approach.

Allowing CBC to expand into S/CBC/A will cause irreparable damage to the environment, the biodiversity, and the setting of Cambridge. GCP’s Site Assessment Summary grades the suitability as “RED”, and with a rating of “Very High harm”. This site should not be included in the Local Plan.

There must be an updated masterplan for the existing CBC land allocations, to provide for all the facilities required on a campus of this size, before any further land allocation is considered. Redesign must additionally address inadequate cycle and pedestrian permeability through the campus and to the new station and busway.

My husband and I strongly object to any development on site S/CBC-A. The reasons are many but include the following:-

1. There will be a significant increase in airborne particulates as a result of this plan.

2. Biodiversity will be yet further decreased, with more encroachment on an already decimated greenbelt.

3. Ninewells conservation area will be further threatened, along with several rare species that have been regularly observed in these fields.

4. The fields regularly flood, and more hard surfaces will further increase watershed and risk of local flooding. The flood mitigation at the Ninewells housing development has already proven to be a complete disaster.

5. Cambridge infrastructure is already poor, and in the absence of substantial improvements throughout the city, further development is only going to make matters worse. As the development proposed is largely laboratory/office, this is likely to cause greater congestion and environmental impact.

6. The whole fabric of what made Cambridge special is being eroded, and the Council seems hell bent on turning this city into some clone of Milton Keynes.

Unlike the Great Knighton area, which has been similarly overdeveloped, there is no country park on this side of Cambridge. This would be a much more sensible use of the land, making a positive contribution to climate change, biodiversity and mental and physical wellbeing.

Several scientific campuses are flourishing in Cambridgeshire in more rural locations. As a medical practitioner (Philip Edwards), we know that there is absolutely no logistic reason why laboratories have to be in close proximity to each other, or even to a hospital.

Aware of need, but must be sensitive to the valued landscape and impact on natural environment

Whilst Cambridge Past, Present & Future appreciate the international significance of the Cambridge Biomedical Campus and the benefits of a centre of medical excellence on our doorstep, we nevertheless have reservations about the continued expansion of the CBC and OBJECT to this policy because it would cause a high level of harm to the green belt, loss of biodiversity (see attached report from John Meed) and increase flood risk.

Future growth of the Campus is constrained by the Gog Magog Hills. The hills are arguably the most important landscape area on the city fringes and it is generally agreed that any development of the slopes would be unacceptable. Not only that but building right up to the slopes will also have significant detrimental visual impacts. This raises a fundamental question about the longer term.

If the campus does continue to expand then where will it expand if there is no acceptable land adjacent to the Campus? The answer is a new campus in a different location. If that is the long-term future, then why not address it now rather than encroaching on an important part of the green belt? Has that option been considered as part of the plan making process?

Given that future land for the campus in this location is likely to be highly constrained we challenge whether any residential provision should be made and we would also argue that a more rigorous set of criteria should be agreed so that new enterprises and activities have to demonstrate why co-location within the Campus is absolutely essential for their operation. Co-location would be desirable for any biomedical company, but is it crucial to the effective operation of that company?

Notwithstanding our objection in principle to this policy, we comment specifically on the proposal:
• "Significant Green Belt enhancement in adjoining areas of White Hill and Nine Wells will be required, to provide green infrastructure and biodiversity improvements supporting the objectives of the Strategic Initiative 3: Gog Magog Hills and chalkland fringe. These areas would remain within the Green Belt and are included in the Area of Major Change to highlight that future proposals for built development on the allocated areas must also include green infrastructure and biodiversity improvements within its adjoining open area."

We welcome this approach. Some of the previous attempts to mitigate the impacts of development through green infrastructure and public access improvements through Area Action Plans and similar have failed because they have been considered aspirational rather than contingent. Policy drafting must ensure that:

i). Any development is contingent on green infrastructure and biodiversity improvements in the adjoining area.

ii). The scale and type of improvements are spelt out clearly so that both the developer and community understand what is expected.

We are attaching with our submission a report by John Meed who has been studying farmland birds on this land for the past ten years. He reports that “At first sight the area I study may appear unlikely to support high levels of biodiversity. However, in practice it is home to remarkable populations of threatened farmland birds, all red-listed species of high conservation concern, as well as the equally endangered water voles, brown hare, and a good range of other birds, mammals, arable plants, butterflies, dragonflies and other invertebrates.” John’s report highlights that many of these species would be impacted not just by the development but potentially by future landscape and biodiversity plans. He proposes that in addition to the land identified at White Hill and Nine Wells that additional work would be needed on adjacent farmland to mitigate the impact on farmland wildlife.

In relation to the statement:
• No development will be permitted south of Granham’s Road. However there may be potential to realign the eastern end of Granham’s Road to a point no further south than the southern boundary of the Wort’s Causeway development to the east of Babraham Road, subject to achieving an acceptable junction arrangement, with the Green Belt boundary following the line of the road. The additional area that may be created by realigning Granham’s Road is shown as a separate area at this stage, and will be explored further, with the boundary to be defined in the draft Local Plan.
We note that the realignment of the road would result in further loss of 5-6 acres of greenbelt to development because Granham’s Road (the green belt boundary) would effectively be moved south.

Please consider this as an additional comment to the one I have already sent yesterday, with ID:57830

The arguments in favour of releasing the Greenbelt have not been specified clearly. As a researcher currently working in the CBC, I do not see the need for extension and further building of the CBC, considering that

1) The old LMB has a lot of empty laboratory space
2) Same for the CIMR, or The Keith Peters Building
3) New buildings such as JCBC are also currently not working at full capacity (and this is *not* because of COVID!)

The bottleneck for filling the existing space is not the lack of housing, but rather research funding and possibly another kick-on effect of Brexit, a not insignificant hurdle to overcome for researchers considering a scientific career in the UK. These are all issues that need to be tackled at Government level rather than with a local plan!

Evidence for the need of new offices or research building needs to be *much better* assessed and presented. As it is, it feel just like an excuse to make profit only benefitting landowners and developers but not the general community.

Extension of Addenbrookes campus S/CBC-A
I object to this extension. The Campus has adequate space and further development into the green belt is unacceptable. It will ruin, despite promises of mitigation, the view from the hills to south east and will endanger the unique setting of the historic nine wells nature reserve.

The University supports the response from CBC Limited and landowners for the CBC expansion proposals.

We support:
- the proposed policy direction for development of the Cambridge Biomedical Campus to meet local, regional or national health care needs and for biomedical and biotechnology research and development activities, related higher education and sui generis medical research institutes, associated support activities to meet the needs of employees and visitors, and residential uses where it would provide affordable and key worker homes for campus employees.
- Recognition that CBC is of national and international importance.
- Recognition of the CBC Vision 2050.


We support the policy position that the first priority should be to reassess the existing campus land.

The Preferred Option for future expansion does not support CBC Ltd and the landowners’ projections on future demand for life sciences space in Greater Cambridge, however. We are concerned that the Council’s preferred jobs forecast is based on an assumption that jobs growth for life sciences (and other key sectors) in the plan period to 2041 will be lower than that actually achieved between 2001-2017. A common set of growth projections for the CBC needs to be agreed in order to inform the next stages of local plan preparation.

Please see attached representation

TMLC supports the need to provide affordable housing for the key workers close to key employment sites.

I strongly object to the release of S/CBC-A from the green belt for development. This will have a detrimental impact on the local area with a significant loss of wildlife and open space on the edge of the city. The development of this site will create a harsh commercial edge to the city, visible from the approach down from Wandlebury and from the Gog Magog hills. I also object to the realignment of Granhams Road to yet further erode this important part of the green belt.
The Bio-medical campus could be better expanded by redevelopment of less dense areas within the existing campus and also by increasing the density of building on the areas already approved for development. The campus could also meet new demand by collocating common services at other nearby research campuses.
The field proposed for development is an area prone to flooding and development of the field could worsen the existing drainage issues on the neighbouring Ninewells development.
Transport infrastructure to the CBC is already insufficient. Credible infrastructure improvements have to be delivered before any future development within the existing boundary of the CBC is permitted.

The landowners and CBC Limited support Policy S/CBC and in particular welcome the support it offers to Vision 2050 and the design principles established therein. As author and steward of Vision 2050, CBC Ltd is glad that the First Proposals document supports effective placemaking on the existing Campus and emphasises the need to consider the existing land and any future expansion as a single district that must operate in an integrated way, whilst also integrating with and providing enhanced facilities and benefits to the existing neighbouring communities.

We support the policy position that a priority should be to enhance the existing Campus land. CBC Limited and the landowners support the intention to renew the masterplan for the Campus, taking account of existing commitments and anticipating the implications of Vision 2050 future expansion, to ensure that it can deliver an effective and broader offering of facilities and services to support the needs of Campus employees and visitors, together with an integrated programme of services, utilities and transport. The masterplan will embed the placemaking principles of Vision 2050, including establishing a clear, legible urban grain with active and sustainable travel at its heart.

The First Proposals advise that “Development on the additional land will only be allowed to take place when evidence is provided that opportunities on the existing Campus have been fully explored and utilised before development takes place on the released land”. We recognise that land on the Campus must be used efficiently and that expansion onto greenfield land requires special justification. In this context, the landowners and CBC Limited acknowledge the need to plan the development of the expansion land taking full account of the development of the Campus.

It is our clear view that, even with a more intensive use of existing land, the market demand for Life Sciences space, coupled with the need to offer a much better, more wide ranging Campus experience to attract, retain and support talent on site will exhaust the existing allocated land early in the plan period. We are also aware that the existing proposed land release may be insufficient to address all the pertinent matters, not just in terms of demand, but also to provide the wider landscape, amenity and neighbourhood mitigations required to make a growing CBC fulfil its potential as an asset for the economy and for South Cambridge communities.

To that end, we wish to work with GCSP to determine the proposed boundaries to ensure that any solution works with the true grain of the landscape and optimises infrastructure, sustainability and placemaking priorities.

Looking therefore at the programme of work required to assess the ultimate need, scale, phasing, mix, accessibility, environmental impact, delivery and design of the Campus expansion we propose the following key tasks and assessment approach should be worked through jointly with the Councils during the course of next year:

CBC Ltd and the landowners intend to work closely together and with:
• all landowners affected by the development and expansion of the Campus,
• GCSP, the Highways Authority, Statutory Undertakers and all other regulatory stakeholders,
• The local communities of South Cambridge, those employed on Campus and those who regularly use and benefit from or are impacted by the services provided on site.

The work would be designed to produce:
• A set of clear parameters that support the social, environmental, and economic priorities of stakeholders, including:
• an environmentally facing solution for energy, water, waste and transport; which futureproofs the Campus against change;
• an agreed approach to accelerate delivery of supporting uses to remedy existing qualitative deficiencies;
• A clear movement strategy that leverages the opportunities created by investment in sustainable transport on site and to promote an active travel hierarchy;
• A placemaking strategy with a specific set of phased interventions that improve legibility, wayfinding and better integrate the campus with its hinterland; and
• Committing to achieve Net Zero and net biodiversity gain within a clear route map.

The work would also produce principles of a landscaping and green infrastructure strategy that enhances the wider environment and mitigates visual impacts from the Campus expansion, whilst enhancing the quality and access to the countryside south of the expansion land.

These documents would then enable GCSP to:
• determine whether the parties had addressed the various requirements of the First Proposals sufficiently to justify the removal of the land from the Green Belt and
• Design a suite of site allocation planning policies to effectively manage the growth of the Campus so that it can become more reflective of Vision 2050 and achieve the highest standards of inclusive, sustainable placemaking it represents.

In order to ensure that this evaluation and design process is followed and to provide GCSP with the resources it would need to fully engage in that process, CBC Ltd and the landowners would be pleased to formalise that approach. This would help direct resources as required, ensure governance is effective and enable an effective working relationship to be established without prejudicing the independence of the planning authority.

I am not convinced that a case has been made for a further allocation of Green Belt land to allow for Biomedical Campus expansion, given that, as GCSP itself acknowledges in this policy, this allocation will cause “a high level of harm”. It will also remove high quality agricultural land from use, which is arguably contrary to proposed policy J/AL “protecting the best quality agricultural land”. This is even more so for any re-routing of Granham’s Road as contemplated in this policy. Given that further land for expansion was allocated in South Cambridgeshire District Council’s 2018 Local Plan (“SCDC’s Local Plan”), another allocation only three years later feels very much like an unwelcome progression down a slippery slope from the perspective of neighbouring communities, especially with the possible re-routing of Granham’s Road, which would bring the city edge very close to Shelford Bottom. Proposed policy GP/GB: Protection and enhancement of the Cambridge Green Belt correctly places emphasis on the established local purposes of the Green Belt “which are to:

Preserve the unique character of Cambridge as a compact....city...
maintain and enhance the quality of its setting
prevent communities in the environs of Cambridge from merging into one another and with the city.”

I wonder whether “high level of harm”, as regards the further proposed expansion, an understatement, when examined against these purposes. The narrow, but critically important, area of Green Belt between the Biomedical Campus and Trumpington, the Shelfords and Stapleford is already at risk of death by infrastructure, due to possible combined impact of East West Rail, if a southern approach is taken (and most especially if grade separation is required near Shepreth Branch Junction), and CSET.

Stronger reasons than any as yet put forward seem to me to be needed for further incursion into the Green Belt. Vision 2050 is essentially a marketing document and does not establish a strategic case for further expansion (in contrast to its predecessor “the 2020 Vision at Addenbrookes - the future of the hospital campus”(“2020 Vision”)). Page 7 of the 2004 version of the 2020 Vision is instructive in this respect; it identifies what is the beating heart of the Biomedical Campus - joined now, I would suggest, by Royal Papworth. The success of the Biomedical Campus is dependent upon the continuing success of the hospitals and on the hospitals having sufficient physical and staff capacity and in the right areas to support clinical research. This is recognised in GCSP’s policy which highlights first that GCSP “will support development on the Cambridge Biomedical Campus to meet local, regional or national health care needs”, but needs to carried through into the conditions GCSP imposes in the policy. It is also implicitly acknowledged in the fact that the 2050 Vision says in its Foreword “Today we look again to the future as both a centre of excellence for healthcare provision in Cambridge and global innovation hub...”. However, the foundational importance of the hospitals to the success of the Biomedical Campus is not explained in the 2050 Vision.

A revised master plan for the site and all the other conditions GCSP is proposing in its policy are needed whether or not further expansion land is allocated in this update to the Local Plan. The ambition for the revised master plan expressed in the policy (“to improve the overall experience of the site for workers and visitors”) appears too narrow. I would also suggest that a revised version of the 2050 Vision is needed, which begins with the hospitals and sets out their renovation and expansion plans, and explaining expected timing and funding. This is likely to highlight that, among other things, s106 funding will be needed to make them achievable.

The hospitals should, in this suggested revised 2050 Vision, along with their partners on the biomedical campus, identify what the clinical areas which support further expansion are.

The 2020 Vision was led by Addenbrookes and developed with the University and the Medical Research Council. The 2050 Vision says very little about the hospitals and it is unclear who is leading it. I would suggest that it must be led by the hospitals (as first among equals) supported by the other institutions.

The revised 2050 Vision needs to review other employment sites identified in Appendix H of the Greater Cambridge Economic Development and Employment Land Evidence Study close to the Biomedical Campus and, if appropriate, explain why they cannot be used for its proposed expansion. It should also be scaled back to address the more limited allocations already in SCDC’s Local Plan and, if appropriate, the additional allocation in the First Proposals, including that at the Babraham Research Campus (policy S/BRC), given that the CEO is a signatory to the 2050 Vision. The 2050 Vision will be a different one without co-located housing.

GCSP should also ask for a review of the 2020 Vision, the existing master plan, outline planning permission for the Biomedical Campus and the major more detailed subsequent applications to pull together things proposed or conditions imposed which have not yet been fulfilled.
Nine Wells requires particular attention and, I would suggest, a comprehensive plan for restoration. Great Shelford is not well-endowed with footpaths and this is one of them.

From personal experience on a bike and on foot, I note that I had difficulty finding the cycle path around the back of the Biomedical Campus which links to the Genome Path from Babraham Road (an unfamiliar direction for me) and that when I walked from Cambridge Station recently along the guided busway to get to a routine appointment, the Breast Unit (the entrance to which is obscurely located) was poorly signposted.

Finally, and I am sure that GCSP has already identified this, one of the transport proposals made in the context of the more extensive Cambridge South proposals for Biomedical Campus expansion was to close Granham’s Road to through traffic. This would be very damaging to Great Shelford and Stapleford as it would likely drive traffic onto Hinton Way and lacks rationality, given that the Genome Path already provides a cycling and walking route to broadly the same destinations. This proposal should not be taken forward.

The First Proposals rightly recognise the importance of Cambridge Biomedical Campus as an asset of national importance. The First Proposals, however, set out an inappropriately restricted approach to growth requirements which have been demonstrated in the Vision 2050 and in our submissions to the GCSP. The Local Plan is required to take a long term approach to developments of strategic importance and this requires a more comprehensive response to the scale of housing and employment needed in Cambridge and to the specific, demonstrated needs of the Campus.

GSPC has serious concerns regarding the proposed expansion plans of the Cambridge Biomedical Campus (CBC).

Great Shelford Parish Council is extremely concerned that any further expansion of CBC and related developments threaten the individual, rural and distinct nature of our village. The combination of these plans and the traffic infrastructure plans for the area, including but not limited to CSET and East West Rail, could rapidly see Great Shelford absorbed into Cambridge city. We oppose any plans that increase this threat.

On this basis, we are pleased that the plan called ‘Cambridge South’ by the developers that was linked to CBC and would have overwhelmed the north area of Great Shelford have not been put forward in the First Proposals. (See: http://cambridgesouth.azurewebsites.net). We opposed those plans strongly.

CBC is situated on the edge of very sensitive ecological areas that would be irreparably harmed by further expansion. This includes Nine Wells, the chalk stream of Hobson’s Brook, the edge of the Gog Magog downs and a Scheduled Monument within Great Shelford.

GSPC opposes the proposal to allow CBC to expand further into the green belt up to the boundary with Great Shelford along the A1307 and up to Granhams Road. Indeed, we are opposed to any proposal that would result in green belt land in or around Great Shelford being released for development. Further, we believe that the plans do not meet the requirements for green belt land to be released for development.

South Cambridgeshire has a world-leading cluster of life sciences companies and one of the main characteristics of this cluster is that it is distributed around many of the villages in the region. Notable and successful examples include Babraham, Hinxton, Melbourn and Harston. This means that the benefits and the drawbacks of this development is spread around the region; in particular, it brings quality jobs to villages that may otherwise be struggling for high quality employment and ensures that the resulting transport requirements aren’t concentrated in one small area. There is very little evidence that the continued success of this industry within South Cambridgeshire requires additional expansion of the CBC site.

In addition, the increased expansion of the CBC site can only increase pressure on the local transport network which is already overloaded. The road network is often close to gridlock at times during the day and the bus network is insufficient to cope with demand. Further, we note that the proposed expansion of the CBC site is distant from the planned site of Cambridge South station and the CSET route. Should the expanded site for CBC be allowed, GSPC believes that an alternative busway along the route of the A1307 would better serve CBC whilst minimising the significant ecological damage that CSET would create. It would also be quicker and cheaper to deliver. Schemes such as the light rail concept proposed by Cambridge Connect also demonstrate some attractive aspects that could benefit the whole of the Greater Cambridge Shared Planning area, including villages such as Great Shelford, and should be examined in the context of the draft Local Plan.

Cambridge Biomedical Campus Ltd (CBC Ltd), on behalf of our campus members, welcomes the recognition that Policy Proposal S/CBC provides to the importance and growth requirements of the Campus. We continue to have an active dialogue with all landowners with an interests in CBC including our own members, other landowners within the existing campus and those with interests in future potential phases including the land provisionally identified for expansion.

As things stand, there are no signed legal agreements between these groups to ensure an integrated development of the campus in a way that would realise the CBC 2050 Vision. We remain hopeful that suitable agreements will be completed. But in any event, an effective series of Town Planning controls is essential to guide development across the Campus and its future phases to help realise Vision 2050 and deliver benefits for local communities. Consequently, CBC seeks to work with the Planning Authority to agree a comprehensive suite of planning framework controls to safeguard the delivery of the Campus 2050 Vision.

In addition, as well as a series of policy controls, we also believe the establishment of a formal review forum (e.g. a new CBC-led Campus Design Review panel, with local community representation) to review and influence any proposed campus planning applications in advance of submission, as well as act as a consultee to support the LPA in its assessment of applications once submitted. A similar forum could also engage in negotiations on Community Infrastructure Levy, Section 106 or other ‘Planning Gain’ mechanisms to optimise the benefits that high quality, inclusive, sustainable, and placemaking focussed development can achieve.

Allowing CBC to expand into S/CBC/A will cause irreparable damage to the environment, the biodiversity, and the setting of Cambridge. GCP's own Site Assessment Summary grades the suitability as "RED", and with a rating of "Very High harm". This site should not be included in the Local Plan.

There must be an updated masterplan for the existing CBC land allocations, to provide for all the facilities required on a campus of this size, before any further land allocation is considered. Redesign must additionally address inadequate cycle and pedestrian permeability through the campus and to the new station and busway.

I shall try to follow the order of the First Proposals document.
An updated masterplan will be required for the Campus, to improve the overall experience of the site for workers and visitors. This should maximise opportunities to improve the "legibility "of the Campus by providing a network of cycle and pedestrian routes, high quality new public realm and open space, but in particular explore opportunities to enhance connections with the proposed Cambridge South Railway Station.
This masterplan is key to the entire policy and with wider implications for the whole of the surrounding neighbourhood. A proper plan for hospital infrastructure needs to support expected housing and economic growth and the ageing population in the region. The right infrastructure and people capacity in the hospitals is important to enable successful expansion of the biomedical campus but the implications of the masterplan are far wider than just the hospitals. As you say on p 88, the Cambridge Biomedical Campus is of national and international importance. It has a local, regional and national role in providing medical facilities and medical research. It is a key location for the life-sciences and biotechnology cluster of Greater Cambridge. The masterplan must cover the whole Campus and the effects on the surrounding region.
All development must coordinate in both time and space with all the local and regional transport, housing and industrial proposals. For example, you refer to the proposed Cambridge South Railway Station. Network Rail's current proposals will not provide sufficient capacity for the Campus even in the immediate future, never mind the significant expansion envisaged in Policy S/CBC.

You refer to a network of cycle and pedestrian routes, apparently within the Campus. As a cyclist myself, I recognise that there are a significant number of people who cannot use bicycles or even walk easily and they must be provided for.

A major issue is journeying to and from the Campus. A problem with all campus type development is that it tends to generate significant car travel. It is essential that there is a comprehensive network of rapid, accessible and cheap public transport provisions both within the Campus and along the feeder routes. No development can be permitted before such a network is operational. I repeat my comment about the necessity for co-ordination with the various local and regional transport proposals..

I appreciate the national importance of the Campus may justify release of an additional area from the Green Belt but it is not clear whether the neighbourhood can support the inevitable increase in population, housing and travel. I repeat my comment on Policy S/CE that relevant development of the Eastern Quarter will relieve the pressure on the Southern Fringe resulting from expansion of the Cambridge Biomedical Campus.

I note your statement on p 60 that it is not proposed to carry forward the Area of Major Change identified in the adopted 2018 Cambridge Local Plan Policy 18: Southern Fringe Areas of Major Change. The safeguards you list on p 86 and pp 88 - 89 are essential and must be vigorously enforced. In particular there must be no encroachment into the Green Belt before the existing Campus is fully utilised.

I do not understand why the adjoining areas of White Hill and Nine Wells are included in the Area of Major Change while remaining within the Green Belt, especially as they are particularly environmentally sensitive.

Area of concern- Queen Ediths Cambridge – Biomedical campus. “Permitted Further Campus expansion” and “Proposed Further Campus expansion”. These areas are south of Addenbrookes Hospital.
Themes of concern - Sustainability – Flood Risk – Lost opportunity to increase biodiversity
The areas of concern are at risk of river and surface water flooding. www.gov.uk/check-long-term-flood-risk. I used post code CB2 0AP to get the following screen shots this evening 8th December 2021. As you can see there is a “Flood alert” this evening . The area is at risk of surface water flooding.

As you can see the Papworth Hospital is in a flow path. With Climate change and uncertainty this risk will only increase. We should be protecting the Campus which is already constructed including the new childrens hospital with a “natural based” solution which will hold back the water. These ateas could be “Green Belt Enhamcement” This could improve biodiversity geatly especially if the area links Nine Well Local Nature Reserve to Beechwood creating B-Lines etc. Ideally for biodiversity the proposed housing between Worts Causeway and Babraham Road should be an extension to the green belt.
(Please note SuDS do not protect against the surface water flooding as shown on the government maps. SuDS reduces the runoff from a development so it does not increase the flooding elsewhere.)
I hope COP26 is being taken into account.
Businesses will leave if they are flooded regularly. Addenbrookes flooded in 2015 in the area where it touches the flow path. It is best to protect what is already here.

Edge of Cambridge
18. The development of Cambridge East is predicated on closure of Cambridge Airport. The airport area is one
of, if not the largest employers in Cambridge. Where will these skilled engineering staff find employment?
Additionally, if Cambridge is to be such a significant centre of international business, why would it not need
its own airport, providing flights to national and international hub destinations?
19. Further development in North West Cambridge will cause development to completely dominate this green
space between Huntingdon Road and the M11. This green space is important for the existing residents and
to the character of the area. Further major development in this area polluted by the M11 and A14 and
their major intersection is unwise.
20. With respect to Policy S/CBC, CPRE objects strongly to the release of further Greenbelt land, identified as
the area S/CBC-A. The existing allocation of land around the Addenbrokes site has not been built out. Land
that has been built on recently has been used profligately. There is indication that since BREXIT and the
move of the European Medicines Agency from London to Amsterdam, there will be less interest by major
pharmaceutical companies in moving to anywhere in the UK including Cambridge. The UK is now a
‘secondary’ market in the priority of new pharmaceutical product registrations. It is more likely that
companies based in the UK will move at least some of their activities to the Netherlands, especially now
that the EU and the USA have reached a Mutual Recognition Agreement for drug manufacturing
inspections.
21. CPRE agrees with the findings of the Greater Cambridge Green Belt Study (2021) which identifies that
release of the areas proposed would result in very high harm to the Green Belt and that there are concerns
regarding biodiversity and landscape impacts from the scale of development proposed by the Campus.
22. CPRE also objects to the apparent attempt to turn the “Proposed Area of Major Change” into some kind of
greenwashed country park as compensation. This appears to be an underhand attempt at carbon off-
setting on what is much needed, productive, farm land. Such “compensatory improvements” are a
developers’ myth. Once the released land has been developed it is gone.
23. With respect to Policy S/WC: West Cambridge, this area is already well developed and further infill within
the outlined boundary is sensible. However, CPRE is concerned to ensure there will be no further spread
south onto the green fields between Cambridge and the M11.
24. CPRE are concerned by the retention of the two allocations between Huntingdon Road and Histon Road
(Darwin Green). These are significant areas of green space on the northern edge of the city which help
retain the character of the city’s integration with its rural surroundings.
25. CPRE are concerned by proposed further development along Fulbourn Road on highly productive farm land at S/EOC/E/3: Fulbourn Road East, even though this is a retained policy.