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

Thank you for consulting Historic England on the First Proposals Public Consultation for the Greater Cambridge Local Plan. As the Government’s adviser on the historic environment Historic England is keen to ensure that the protection of the historic environment is fully considered at all stages and levels of the local planning process.

Cambridge is a beautiful, compact and historic city. It is also an historic seat of learning with a very high concentration of highly graded heritage assets. Much of the city is covered by Conservation Area status. The river corridor, green fingers and open spaces, with cows grazing in meadows even at the heart of the city, shape the character of the townscape and landscape.

Although a relatively flat landscape, the elevated positions to the west and south of the Cambridge afford important views across the city skyline, which is one of extensive tree cover and emerging spires. The flatter Fens landscape to the north and east provides very long-distance views of the City and the big east Anglian skies.

The surrounding rural hinterland of South Cambridgeshire comprises over 100 villages, each with their own unique character and heritage. New settlements are an important feature of the district, with their own special identity and are growing rapidly.

We recognise the area faces intense pressure for growth, driven by both the economic success and the attractiveness of the area, in large part a consequence of

its rich architectural and cultural heritage. This growth must be carefully managed to ensure that the very things that contribute to its success are not harmed in the process.

It is for this reason that Historic England is keen to ensure that the emerging plan gives full consideration to the historic environment, both in the choice of site allocations and policy criteria for sites, as well as through a robust and clear suite of historic environment and other policies that seek to both protect but also enhance the historic environment.

We have reviewed the Draft Plan and consultation material with a view to providing advice on heritage matters.

As a general comment, Historic England welcomes emerging plan and work undertaken to date. We have however identified below some of the key issues to be addressed in progressing the next iteration of the Plan: This should be read in conjunction with Appendix A which provides more detailed comments on these and other more minor issues.

a) Site Assessment and the need for Heritage Impact Assessments

We are pleased to note that a degree of site assessment has already been undertaken in relation to the historic environment. These are set out in the HELAA Report, especially Appendix 4.

To date, the assessment of sites is fairly high level and brief but provides a useful starting point, in particular helping to identify immediate showstoppers. We note that many of the sites are shown as amber.

As we have discussed previously, the need for further assessment of heritage in terms of significance, impact on that significance, potential mitigation and enhancements etc will be needed for the site allocations. There is currently an insufficient evidence base in this regard. We therefore welcome your commitment to undertake Heritage Impact Assessments for site allocations. These should be prepared prior to the next draft of the Local Plan.

This further assessment, known as Heritage Impact Assessment (HIA) should follow the 5 step methodology set out in out in our advice note, HEAN 3 on Site Allocations in Local Plans https://historicengland.org.uk/images- books/publications/historic-environment-and-site-allocations-in-local-plans/.

HIAs should be proportionate (both to the scale of the site and the assets affected). All potential sites will need to be appraised against potential historic environment

impacts. It is imperative to have this robust evidence base in place to ensure the soundness of the Plan. We recommend that the appraisal approach should avoid merely limiting assessment of impact on a heritage asset to its distance from, or inter-visibility with, a potential site.

Site allocations which include a heritage asset (for example a site within a Conservation Area) may offer opportunities for enhancement and tackling heritage at risk, while conversely, an allocation at a considerable distance away from a heritage asset may cause harm to its significance, rendering the site unsuitable.

Impacts on significance are not just based on distance or visual impacts, and assessment requires a careful judgment based on site visits and the available evidence base. Cumulative effects of site options on the historic environment should be considered too.

The following broad steps might be of assistance in terms of assessing sites:

• Identify the heritage assets on or within the vicinity of the potential site allocation at an appropriate scale
• Assess the contribution of the site to the significance of heritage assets on or within its vicinity
• Identify the potential impacts of development upon the significance of heritage asset
• Consider how any harm might be removed or reduced, including reasonable alternatives sites
• Consider how any enhancements could be achieved and maximised
• Consider and set out the public benefits where harm cannot be removed or reduced

The HIAs should assess the suitability of each area for development and the impact on the historic environment. Should the HIA conclude that development in the area could be acceptable and the site be allocated, the findings of the HIA should inform the Local Plan policy including development criteria and a strategy diagram which expresses the development criteria in diagrammatic form.

Which sites require HIA?

Ideally all sites should have an HIA, albeit proportionate to the site and heritage sensitivities.

For existing allocations being carried forward into this Local Plan, the HIA is less about the principle of development (that has already been established through previous plan allocation) and more about exploring capacity, height, density and any heritage mitigation and enhancement opportunities so that these can then be

included in the updated policy wording.

For new allocations, the HIA will be a more holistic view and consider both the principle of development as well as the other matters identified above.

b) Policy Wording for sites

If, having completed the heritage impact assessments, it is concluded that a site is suitable for allocation, we would remind you to include appropriate policy criteria for the historic environment in the policy. Please refer to the advice we give on policy wording in the attached table.

It can be helpful to refer to an HIA in the policy wording. Concept diagrams can also be useful to include in the plan to illustrate key site considerations/ recommendations.

c) Edge of Cambridge sites

The Plan proposes carrying forward a number of partially built out allocations on the edge of the City as well as some minor extensions to these. The Plan also proposes revisiting the dwelling capacity/density for some of these sites e.g. Eddington.

Proposals for North East Cambridge are very high density and also quite tall.

The Plan also includes a very large new allocation at East Cambridge (previously released from the Green Belt and allocated in the 2006 Plan, although not in the 2018 Plan). The number of dwellings now being proposed represents a significant increase in density from the 2006 Plan.

We have some concerns regarding these densities and heights on edge of Cambridge sites. Development at very high densities/heights and the potential impact on the overall setting of this historic city. HIAs should give careful consideration to the issue of development and site capacity and height – we will be looking for evidence in this regard.

d) Historic Environment Policy

We welcome your intention to include a policy for the Historic Environment. This should cover both designated and non-designated heritage assets. Policy wording should be in line with the NPPF but we are also looking for a local flavour.

Policies should be spatially specific, unique to the area, describing the local characteristics of the area and responding accordingly with policies that address the local situation.

You should also include a policy for Heritage at Risk and a policy for historic shopfronts. For further detail see Appendix A.

e) Design Policy

We welcome the proposals for a design policy on the plan. We note that this policy is also intended to address tall buildings. We are concerned that the policy might become overly long and detailed, given it is covering such a wide and important range of issues and wonder whether separating out tall buildings into a separate policy might be helpful?

f) Tall Buildings Study and Policy

Related to the above, given the growth pressures that we would anticipate Cambridge is likely to experience over the coming years, we are pleased to see that the matter of Tall buildings and the skyline will be addressed in policy.

We had understood that you were commissioning a study in relation to tall buildings and the skyline policy. Is this still proposed to inform the policy in the next draft of the Local Plan?

See our advice note HEAN 4 and the consultation draft of HEAN 4. Any policy should indicate what considerations are needed for taller buildings, where buildings may or may not be appropriate etc. and in particular consider in the impact on the historic environment.

We broadly welcome policy 60 and Appendix F of the 2018 Cambridge City Local Plan. However, we consider that this could be further supplemented to indicate which areas may or may not be suited to taller buildings. Our advice note in relation to tall buildings provides further guidance in this respect

We have been having discussions with the team preparing The North East Area Action Plan in relation to tall buildings studies and have provided a detailed advice letter in that regard. Please refer to our advice letters in relation to NEA Action Plan and tall buildings for further information on our position.

g) Other Supporting Evidence

We welcome the preparation of the HELAA although consider that further, more detailed evidence is needed in relation to heritage impact and so welcome your intention to prepare HIAs for site allocations.

We broadly welcome the Strategic Heritage Impact Assessment including the baseline study of the setting of Cambridge. However, we have expressed some concerns regarding some aspects of this baseline, in particular the weighting given to some of the key characteristics and aspects of setting of Cambridge including views. Further detail is given in Appendix A.

We welcome the evidence in relation to landscape character assessment. We do however continue to suggest that it would also be helpful to commission Historic Landscape Characterisation work for inform this Plan and future growth in the area.

We welcome the production of the Sustainability Appraisal. We would comment however that since many of the site allocations are grouping together under particular policies, the different impacts for individual sites are not always drawn out in the assessment tables – this sometimes has the effect of neutralising the scoring.

Historic England – Ox Cam research work

Historic England has commissioned consultants to undertake some work looking at development in the OxCam Arc. ‘Measuring Impact: Managing Change’ looks at the question, ‘How should the form of growth in the Oxford-Cambridge arc positively respond to the Historic Environment’. This research is due to report in the next few months and we hope to be able to share this with you at that time as it may provide useful evidence to inform your Local Plan work.

Other comments

In preparation of the forthcoming Greater Cambridge Local Plan, we encourage you to draw on the knowledge of local conservation officers, archaeologists and local heritage groups.

Please note that absence of a comment on an allocation or document in this letter does not mean that Historic England is content that the allocation or document forms part of a positive strategy for the conservation and enjoyment of the historic environment or is devoid of historic environment issues. Where there are various options proposed for a settlement, identification of heritage issues for a particular

allocation does not automatically correspond to the support for inclusion of the alternative sites, given we have not been able to assess all of the sites.

Finally, we should like to stress that this opinion is based on the information provided by the Council in its consultation. To avoid any doubt, this does not affect our obligation to provide further advice and, potentially, object to specific proposals, which may subsequently arise where we consider that these would have an adverse effect upon the historic environment.

We trust that these comments are helpful to you in developing the Local Plan. Should you have any queries, please do not hesitate to contact us.

We suggest it might be helpful to set up a meeting to discuss our comments and, in particular, heritage impact assessments and policy wording for site allocations.
Please feel free to suggest some dates.

Thank you for consulting Historic England on the First Proposals Public Consultation for the Greater Cambridge Local Plan. As the Government’s adviser on the historic environment Historic England is keen to ensure that the protection of the historic environment is fully considered at all stages and levels of the local planning process.

Cambridge is a beautiful, compact and historic city. It is also an historic seat of learning with a very high concentration of highly graded heritage assets. Much of the city is covered by Conservation Area status. The river corridor, green fingers and open spaces, with cows grazing in meadows even at the heart of the city, shape the character of the townscape and landscape.

Although a relatively flat landscape, the elevated positions to the west and south of the Cambridge afford important views across the city skyline, which is one of extensive tree cover and emerging spires. The flatter Fens landscape to the north and east provides very long-distance views of the City and the big east Anglian skies.

The surrounding rural hinterland of South Cambridgeshire comprises over 100 villages, each with their own unique character and heritage. New settlements are an important feature of the district, with their own special identity and are growing rapidly.

We recognise the area faces intense pressure for growth, driven by both the economic success and the attractiveness of the area, in large part a consequence of

its rich architectural and cultural heritage. This growth must be carefully managed to ensure that the very things that contribute to its success are not harmed in the process.

It is for this reason that Historic England is keen to ensure that the emerging plan gives full consideration to the historic environment, both in the choice of site allocations and policy criteria for sites, as well as through a robust and clear suite of historic environment and other policies that seek to both protect but also enhance the historic environment.

We have reviewed the Draft Plan and consultation material with a view to providing advice on heritage matters.

As a general comment, Historic England welcomes emerging plan and work undertaken to date. We have however identified below some of the key issues to be addressed in progressing the next iteration of the Plan: This should be read in conjunction with Appendix A which provides more detailed comments on these and other more minor issues.

a) Site Assessment and the need for Heritage Impact Assessments

We are pleased to note that a degree of site assessment has already been undertaken in relation to the historic environment. These are set out in the HELAA Report, especially Appendix 4.

To date, the assessment of sites is fairly high level and brief but provides a useful starting point, in particular helping to identify immediate showstoppers. We note that many of the sites are shown as amber.

As we have discussed previously, the need for further assessment of heritage in terms of significance, impact on that significance, potential mitigation and enhancements etc will be needed for the site allocations. There is currently an insufficient evidence base in this regard. We therefore welcome your commitment to undertake Heritage Impact Assessments for site allocations. These should be prepared prior to the next draft of the Local Plan.

This further assessment, known as Heritage Impact Assessment (HIA) should follow the 5 step methodology set out in out in our advice note, HEAN 3 on Site Allocations in Local Plans https://historicengland.org.uk/images- books/publications/historic-environment-and-site-allocations-in-local-plans/.

HIAs should be proportionate (both to the scale of the site and the assets affected). All potential sites will need to be appraised against potential historic environment

impacts. It is imperative to have this robust evidence base in place to ensure the soundness of the Plan. We recommend that the appraisal approach should avoid merely limiting assessment of impact on a heritage asset to its distance from, or inter-visibility with, a potential site.

Site allocations which include a heritage asset (for example a site within a Conservation Area) may offer opportunities for enhancement and tackling heritage at risk, while conversely, an allocation at a considerable distance away from a heritage asset may cause harm to its significance, rendering the site unsuitable.

Impacts on significance are not just based on distance or visual impacts, and assessment requires a careful judgment based on site visits and the available evidence base. Cumulative effects of site options on the historic environment should be considered too.

The following broad steps might be of assistance in terms of assessing sites:

• Identify the heritage assets on or within the vicinity of the potential site allocation at an appropriate scale
• Assess the contribution of the site to the significance of heritage assets on or within its vicinity
• Identify the potential impacts of development upon the significance of heritage asset
• Consider how any harm might be removed or reduced, including reasonable alternatives sites
• Consider how any enhancements could be achieved and maximised
• Consider and set out the public benefits where harm cannot be removed or reduced

The HIAs should assess the suitability of each area for development and the impact on the historic environment. Should the HIA conclude that development in the area could be acceptable and the site be allocated, the findings of the HIA should inform the Local Plan policy including development criteria and a strategy diagram which expresses the development criteria in diagrammatic form.

Which sites require HIA?

Ideally all sites should have an HIA, albeit proportionate to the site and heritage sensitivities.

For existing allocations being carried forward into this Local Plan, the HIA is less about the principle of development (that has already been established through previous plan allocation) and more about exploring capacity, height, density and any heritage mitigation and enhancement opportunities so that these can then be

included in the updated policy wording.

For new allocations, the HIA will be a more holistic view and consider both the principle of development as well as the other matters identified above.

b) Policy Wording for sites

If, having completed the heritage impact assessments, it is concluded that a site is suitable for allocation, we would remind you to include appropriate policy criteria for the historic environment in the policy. Please refer to the advice we give on policy wording in the attached table.

It can be helpful to refer to an HIA in the policy wording. Concept diagrams can also be useful to include in the plan to illustrate key site considerations/ recommendations.

c) Edge of Cambridge sites

The Plan proposes carrying forward a number of partially built out allocations on the edge of the City as well as some minor extensions to these. The Plan also proposes revisiting the dwelling capacity/density for some of these sites e.g. Eddington.

Proposals for North East Cambridge are very high density and also quite tall.

The Plan also includes a very large new allocation at East Cambridge (previously released from the Green Belt and allocated in the 2006 Plan, although not in the 2018 Plan). The number of dwellings now being proposed represents a significant increase in density from the 2006 Plan.

We have some concerns regarding these densities and heights on edge of Cambridge sites. Development at very high densities/heights and the potential impact on the overall setting of this historic city. HIAs should give careful consideration to the issue of development and site capacity and height – we will be looking for evidence in this regard.

d) Historic Environment Policy

We welcome your intention to include a policy for the Historic Environment. This should cover both designated and non-designated heritage assets. Policy wording should be in line with the NPPF but we are also looking for a local flavour.

Policies should be spatially specific, unique to the area, describing the local characteristics of the area and responding accordingly with policies that address the local situation.

You should also include a policy for Heritage at Risk and a policy for historic shopfronts. For further detail see Appendix A.

e) Design Policy

We welcome the proposals for a design policy on the plan. We note that this policy is also intended to address tall buildings. We are concerned that the policy might become overly long and detailed, given it is covering such a wide and important range of issues and wonder whether separating out tall buildings into a separate policy might be helpful?

f) Tall Buildings Study and Policy

Related to the above, given the growth pressures that we would anticipate Cambridge is likely to experience over the coming years, we are pleased to see that the matter of Tall buildings and the skyline will be addressed in policy.

We had understood that you were commissioning a study in relation to tall buildings and the skyline policy. Is this still proposed to inform the policy in the next draft of the Local Plan?

See our advice note HEAN 4 and the consultation draft of HEAN 4. Any policy should indicate what considerations are needed for taller buildings, where buildings may or may not be appropriate etc. and in particular consider in the impact on the historic environment.

We broadly welcome policy 60 and Appendix F of the 2018 Cambridge City Local Plan. However, we consider that this could be further supplemented to indicate which areas may or may not be suited to taller buildings. Our advice note in relation to tall buildings provides further guidance in this respect

We have been having discussions with the team preparing The North East Area Action Plan in relation to tall buildings studies and have provided a detailed advice letter in that regard. Please refer to our advice letters in relation to NEA Action Plan and tall buildings for further information on our position.

g) Other Supporting Evidence

We welcome the preparation of the HELAA although consider that further, more detailed evidence is needed in relation to heritage impact and so welcome your intention to prepare HIAs for site allocations.

We broadly welcome the Strategic Heritage Impact Assessment including the baseline study of the setting of Cambridge. However, we have expressed some concerns regarding some aspects of this baseline, in particular the weighting given to some of the key characteristics and aspects of setting of Cambridge including views. Further detail is given in Appendix A.

We welcome the evidence in relation to landscape character assessment. We do however continue to suggest that it would also be helpful to commission Historic Landscape Characterisation work for inform this Plan and future growth in the area.

We welcome the production of the Sustainability Appraisal. We would comment however that since many of the site allocations are grouping together under particular policies, the different impacts for individual sites are not always drawn out in the assessment tables – this sometimes has the effect of neutralising the scoring.

Historic England – Ox Cam research work

Historic England has commissioned consultants to undertake some work looking at development in the OxCam Arc. ‘Measuring Impact: Managing Change’ looks at the question, ‘How should the form of growth in the Oxford-Cambridge arc positively respond to the Historic Environment’. This research is due to report in the next few months and we hope to be able to share this with you at that time as it may provide useful evidence to inform your Local Plan work.

Other comments

In preparation of the forthcoming Greater Cambridge Local Plan, we encourage you to draw on the knowledge of local conservation officers, archaeologists and local heritage groups.

Please note that absence of a comment on an allocation or document in this letter does not mean that Historic England is content that the allocation or document forms part of a positive strategy for the conservation and enjoyment of the historic environment or is devoid of historic environment issues. Where there are various options proposed for a settlement, identification of heritage issues for a particular

allocation does not automatically correspond to the support for inclusion of the alternative sites, given we have not been able to assess all of the sites.

Finally, we should like to stress that this opinion is based on the information provided by the Council in its consultation. To avoid any doubt, this does not affect our obligation to provide further advice and, potentially, object to specific proposals, which may subsequently arise where we consider that these would have an adverse effect upon the historic environment.

We trust that these comments are helpful to you in developing the Local Plan. Should you have any queries, please do not hesitate to contact us.

We suggest it might be helpful to set up a meeting to discuss our comments and, in particular, heritage impact assessments and policy wording for site allocations.
Please feel free to suggest some dates.

Thank you for consulting Historic England on the First Proposals Public Consultation for the Greater Cambridge Local Plan. As the Government’s adviser on the historic environment Historic England is keen to ensure that the protection of the historic environment is fully considered at all stages and levels of the local planning process.

Cambridge is a beautiful, compact and historic city. It is also an historic seat of learning with a very high concentration of highly graded heritage assets. Much of the city is covered by Conservation Area status. The river corridor, green fingers and open spaces, with cows grazing in meadows even at the heart of the city, shape the character of the townscape and landscape.

Although a relatively flat landscape, the elevated positions to the west and south of the Cambridge afford important views across the city skyline, which is one of extensive tree cover and emerging spires. The flatter Fens landscape to the north and east provides very long-distance views of the City and the big east Anglian skies.

The surrounding rural hinterland of South Cambridgeshire comprises over 100 villages, each with their own unique character and heritage. New settlements are an important feature of the district, with their own special identity and are growing rapidly.

We recognise the area faces intense pressure for growth, driven by both the economic success and the attractiveness of the area, in large part a consequence of

its rich architectural and cultural heritage. This growth must be carefully managed to ensure that the very things that contribute to its success are not harmed in the process.

It is for this reason that Historic England is keen to ensure that the emerging plan gives full consideration to the historic environment, both in the choice of site allocations and policy criteria for sites, as well as through a robust and clear suite of historic environment and other policies that seek to both protect but also enhance the historic environment.

We have reviewed the Draft Plan and consultation material with a view to providing advice on heritage matters.

As a general comment, Historic England welcomes emerging plan and work undertaken to date. We have however identified below some of the key issues to be addressed in progressing the next iteration of the Plan: This should be read in conjunction with Appendix A which provides more detailed comments on these and other more minor issues.

a) Site Assessment and the need for Heritage Impact Assessments

We are pleased to note that a degree of site assessment has already been undertaken in relation to the historic environment. These are set out in the HELAA Report, especially Appendix 4.

To date, the assessment of sites is fairly high level and brief but provides a useful starting point, in particular helping to identify immediate showstoppers. We note that many of the sites are shown as amber.

As we have discussed previously, the need for further assessment of heritage in terms of significance, impact on that significance, potential mitigation and enhancements etc will be needed for the site allocations. There is currently an insufficient evidence base in this regard. We therefore welcome your commitment to undertake Heritage Impact Assessments for site allocations. These should be prepared prior to the next draft of the Local Plan.

This further assessment, known as Heritage Impact Assessment (HIA) should follow the 5 step methodology set out in out in our advice note, HEAN 3 on Site Allocations in Local Plans https://historicengland.org.uk/images- books/publications/historic-environment-and-site-allocations-in-local-plans/.

HIAs should be proportionate (both to the scale of the site and the assets affected). All potential sites will need to be appraised against potential historic environment

impacts. It is imperative to have this robust evidence base in place to ensure the soundness of the Plan. We recommend that the appraisal approach should avoid merely limiting assessment of impact on a heritage asset to its distance from, or inter-visibility with, a potential site.

Site allocations which include a heritage asset (for example a site within a Conservation Area) may offer opportunities for enhancement and tackling heritage at risk, while conversely, an allocation at a considerable distance away from a heritage asset may cause harm to its significance, rendering the site unsuitable.

Impacts on significance are not just based on distance or visual impacts, and assessment requires a careful judgment based on site visits and the available evidence base. Cumulative effects of site options on the historic environment should be considered too.

The following broad steps might be of assistance in terms of assessing sites:

• Identify the heritage assets on or within the vicinity of the potential site allocation at an appropriate scale
• Assess the contribution of the site to the significance of heritage assets on or within its vicinity
• Identify the potential impacts of development upon the significance of heritage asset
• Consider how any harm might be removed or reduced, including reasonable alternatives sites
• Consider how any enhancements could be achieved and maximised
• Consider and set out the public benefits where harm cannot be removed or reduced

The HIAs should assess the suitability of each area for development and the impact on the historic environment. Should the HIA conclude that development in the area could be acceptable and the site be allocated, the findings of the HIA should inform the Local Plan policy including development criteria and a strategy diagram which expresses the development criteria in diagrammatic form.

Which sites require HIA?

Ideally all sites should have an HIA, albeit proportionate to the site and heritage sensitivities.

For existing allocations being carried forward into this Local Plan, the HIA is less about the principle of development (that has already been established through previous plan allocation) and more about exploring capacity, height, density and any heritage mitigation and enhancement opportunities so that these can then be

included in the updated policy wording.

For new allocations, the HIA will be a more holistic view and consider both the principle of development as well as the other matters identified above.

b) Policy Wording for sites

If, having completed the heritage impact assessments, it is concluded that a site is suitable for allocation, we would remind you to include appropriate policy criteria for the historic environment in the policy. Please refer to the advice we give on policy wording in the attached table.

It can be helpful to refer to an HIA in the policy wording. Concept diagrams can also be useful to include in the plan to illustrate key site considerations/ recommendations.

c) Edge of Cambridge sites

The Plan proposes carrying forward a number of partially built out allocations on the edge of the City as well as some minor extensions to these. The Plan also proposes revisiting the dwelling capacity/density for some of these sites e.g. Eddington.

Proposals for North East Cambridge are very high density and also quite tall.

The Plan also includes a very large new allocation at East Cambridge (previously released from the Green Belt and allocated in the 2006 Plan, although not in the 2018 Plan). The number of dwellings now being proposed represents a significant increase in density from the 2006 Plan.

We have some concerns regarding these densities and heights on edge of Cambridge sites. Development at very high densities/heights and the potential impact on the overall setting of this historic city. HIAs should give careful consideration to the issue of development and site capacity and height – we will be looking for evidence in this regard.

d) Historic Environment Policy

We welcome your intention to include a policy for the Historic Environment. This should cover both designated and non-designated heritage assets. Policy wording should be in line with the NPPF but we are also looking for a local flavour.

Policies should be spatially specific, unique to the area, describing the local characteristics of the area and responding accordingly with policies that address the local situation.

You should also include a policy for Heritage at Risk and a policy for historic shopfronts. For further detail see Appendix A.

e) Design Policy

We welcome the proposals for a design policy on the plan. We note that this policy is also intended to address tall buildings. We are concerned that the policy might become overly long and detailed, given it is covering such a wide and important range of issues and wonder whether separating out tall buildings into a separate policy might be helpful?

f) Tall Buildings Study and Policy

Related to the above, given the growth pressures that we would anticipate Cambridge is likely to experience over the coming years, we are pleased to see that the matter of Tall buildings and the skyline will be addressed in policy.

We had understood that you were commissioning a study in relation to tall buildings and the skyline policy. Is this still proposed to inform the policy in the next draft of the Local Plan?

See our advice note HEAN 4 and the consultation draft of HEAN 4. Any policy should indicate what considerations are needed for taller buildings, where buildings may or may not be appropriate etc. and in particular consider in the impact on the historic environment.

We broadly welcome policy 60 and Appendix F of the 2018 Cambridge City Local Plan. However, we consider that this could be further supplemented to indicate which areas may or may not be suited to taller buildings. Our advice note in relation to tall buildings provides further guidance in this respect

We have been having discussions with the team preparing The North East Area Action Plan in relation to tall buildings studies and have provided a detailed advice letter in that regard. Please refer to our advice letters in relation to NEA Action Plan and tall buildings for further information on our position.

g) Other Supporting Evidence

We welcome the preparation of the HELAA although consider that further, more detailed evidence is needed in relation to heritage impact and so welcome your intention to prepare HIAs for site allocations.

We broadly welcome the Strategic Heritage Impact Assessment including the baseline study of the setting of Cambridge. However, we have expressed some concerns regarding some aspects of this baseline, in particular the weighting given to some of the key characteristics and aspects of setting of Cambridge including views. Further detail is given in Appendix A.

We welcome the evidence in relation to landscape character assessment. We do however continue to suggest that it would also be helpful to commission Historic Landscape Characterisation work for inform this Plan and future growth in the area.

We welcome the production of the Sustainability Appraisal. We would comment however that since many of the site allocations are grouping together under particular policies, the different impacts for individual sites are not always drawn out in the assessment tables – this sometimes has the effect of neutralising the scoring.

Historic England – Ox Cam research work

Historic England has commissioned consultants to undertake some work looking at development in the OxCam Arc. ‘Measuring Impact: Managing Change’ looks at the question, ‘How should the form of growth in the Oxford-Cambridge arc positively respond to the Historic Environment’. This research is due to report in the next few months and we hope to be able to share this with you at that time as it may provide useful evidence to inform your Local Plan work.

Other comments

In preparation of the forthcoming Greater Cambridge Local Plan, we encourage you to draw on the knowledge of local conservation officers, archaeologists and local heritage groups.

Please note that absence of a comment on an allocation or document in this letter does not mean that Historic England is content that the allocation or document forms part of a positive strategy for the conservation and enjoyment of the historic environment or is devoid of historic environment issues. Where there are various options proposed for a settlement, identification of heritage issues for a particular

allocation does not automatically correspond to the support for inclusion of the alternative sites, given we have not been able to assess all of the sites.

Finally, we should like to stress that this opinion is based on the information provided by the Council in its consultation. To avoid any doubt, this does not affect our obligation to provide further advice and, potentially, object to specific proposals, which may subsequently arise where we consider that these would have an adverse effect upon the historic environment.

We trust that these comments are helpful to you in developing the Local Plan. Should you have any queries, please do not hesitate to contact us.

We suggest it might be helpful to set up a meeting to discuss our comments and, in particular, heritage impact assessments and policy wording for site allocations.
Please feel free to suggest some dates.

Thank you for consulting Historic England on the First Proposals Public Consultation for the Greater Cambridge Local Plan. As the Government’s adviser on the historic environment Historic England is keen to ensure that the protection of the historic environment is fully considered at all stages and levels of the local planning process.

Cambridge is a beautiful, compact and historic city. It is also an historic seat of learning with a very high concentration of highly graded heritage assets. Much of the city is covered by Conservation Area status. The river corridor, green fingers and open spaces, with cows grazing in meadows even at the heart of the city, shape the character of the townscape and landscape.

Although a relatively flat landscape, the elevated positions to the west and south of the Cambridge afford important views across the city skyline, which is one of extensive tree cover and emerging spires. The flatter Fens landscape to the north and east provides very long-distance views of the City and the big east Anglian skies.

The surrounding rural hinterland of South Cambridgeshire comprises over 100 villages, each with their own unique character and heritage. New settlements are an important feature of the district, with their own special identity and are growing rapidly.

We recognise the area faces intense pressure for growth, driven by both the economic success and the attractiveness of the area, in large part a consequence of

its rich architectural and cultural heritage. This growth must be carefully managed to ensure that the very things that contribute to its success are not harmed in the process.

It is for this reason that Historic England is keen to ensure that the emerging plan gives full consideration to the historic environment, both in the choice of site allocations and policy criteria for sites, as well as through a robust and clear suite of historic environment and other policies that seek to both protect but also enhance the historic environment.

We have reviewed the Draft Plan and consultation material with a view to providing advice on heritage matters.

As a general comment, Historic England welcomes emerging plan and work undertaken to date. We have however identified below some of the key issues to be addressed in progressing the next iteration of the Plan: This should be read in conjunction with Appendix A which provides more detailed comments on these and other more minor issues.

a) Site Assessment and the need for Heritage Impact Assessments

We are pleased to note that a degree of site assessment has already been undertaken in relation to the historic environment. These are set out in the HELAA Report, especially Appendix 4.

To date, the assessment of sites is fairly high level and brief but provides a useful starting point, in particular helping to identify immediate showstoppers. We note that many of the sites are shown as amber.

As we have discussed previously, the need for further assessment of heritage in terms of significance, impact on that significance, potential mitigation and enhancements etc will be needed for the site allocations. There is currently an insufficient evidence base in this regard. We therefore welcome your commitment to undertake Heritage Impact Assessments for site allocations. These should be prepared prior to the next draft of the Local Plan.

This further assessment, known as Heritage Impact Assessment (HIA) should follow the 5 step methodology set out in out in our advice note, HEAN 3 on Site Allocations in Local Plans https://historicengland.org.uk/images- books/publications/historic-environment-and-site-allocations-in-local-plans/.

HIAs should be proportionate (both to the scale of the site and the assets affected). All potential sites will need to be appraised against potential historic environment

impacts. It is imperative to have this robust evidence base in place to ensure the soundness of the Plan. We recommend that the appraisal approach should avoid merely limiting assessment of impact on a heritage asset to its distance from, or inter-visibility with, a potential site.

Site allocations which include a heritage asset (for example a site within a Conservation Area) may offer opportunities for enhancement and tackling heritage at risk, while conversely, an allocation at a considerable distance away from a heritage asset may cause harm to its significance, rendering the site unsuitable.

Impacts on significance are not just based on distance or visual impacts, and assessment requires a careful judgment based on site visits and the available evidence base. Cumulative effects of site options on the historic environment should be considered too.

The following broad steps might be of assistance in terms of assessing sites:

• Identify the heritage assets on or within the vicinity of the potential site allocation at an appropriate scale
• Assess the contribution of the site to the significance of heritage assets on or within its vicinity
• Identify the potential impacts of development upon the significance of heritage asset
• Consider how any harm might be removed or reduced, including reasonable alternatives sites
• Consider how any enhancements could be achieved and maximised
• Consider and set out the public benefits where harm cannot be removed or reduced

The HIAs should assess the suitability of each area for development and the impact on the historic environment. Should the HIA conclude that development in the area could be acceptable and the site be allocated, the findings of the HIA should inform the Local Plan policy including development criteria and a strategy diagram which expresses the development criteria in diagrammatic form.

Which sites require HIA?

Ideally all sites should have an HIA, albeit proportionate to the site and heritage sensitivities.

For existing allocations being carried forward into this Local Plan, the HIA is less about the principle of development (that has already been established through previous plan allocation) and more about exploring capacity, height, density and any heritage mitigation and enhancement opportunities so that these can then be

included in the updated policy wording.

For new allocations, the HIA will be a more holistic view and consider both the principle of development as well as the other matters identified above.

b) Policy Wording for sites

If, having completed the heritage impact assessments, it is concluded that a site is suitable for allocation, we would remind you to include appropriate policy criteria for the historic environment in the policy. Please refer to the advice we give on policy wording in the attached table.

It can be helpful to refer to an HIA in the policy wording. Concept diagrams can also be useful to include in the plan to illustrate key site considerations/ recommendations.

c) Edge of Cambridge sites

The Plan proposes carrying forward a number of partially built out allocations on the edge of the City as well as some minor extensions to these. The Plan also proposes revisiting the dwelling capacity/density for some of these sites e.g. Eddington.

Proposals for North East Cambridge are very high density and also quite tall.

The Plan also includes a very large new allocation at East Cambridge (previously released from the Green Belt and allocated in the 2006 Plan, although not in the 2018 Plan). The number of dwellings now being proposed represents a significant increase in density from the 2006 Plan.

We have some concerns regarding these densities and heights on edge of Cambridge sites. Development at very high densities/heights and the potential impact on the overall setting of this historic city. HIAs should give careful consideration to the issue of development and site capacity and height – we will be looking for evidence in this regard.

d) Historic Environment Policy

We welcome your intention to include a policy for the Historic Environment. This should cover both designated and non-designated heritage assets. Policy wording should be in line with the NPPF but we are also looking for a local flavour.

Policies should be spatially specific, unique to the area, describing the local characteristics of the area and responding accordingly with policies that address the local situation.

You should also include a policy for Heritage at Risk and a policy for historic shopfronts. For further detail see Appendix A.

e) Design Policy

We welcome the proposals for a design policy on the plan. We note that this policy is also intended to address tall buildings. We are concerned that the policy might become overly long and detailed, given it is covering such a wide and important range of issues and wonder whether separating out tall buildings into a separate policy might be helpful?

f) Tall Buildings Study and Policy

Related to the above, given the growth pressures that we would anticipate Cambridge is likely to experience over the coming years, we are pleased to see that the matter of Tall buildings and the skyline will be addressed in policy.

We had understood that you were commissioning a study in relation to tall buildings and the skyline policy. Is this still proposed to inform the policy in the next draft of the Local Plan?

See our advice note HEAN 4 and the consultation draft of HEAN 4. Any policy should indicate what considerations are needed for taller buildings, where buildings may or may not be appropriate etc. and in particular consider in the impact on the historic environment.

We broadly welcome policy 60 and Appendix F of the 2018 Cambridge City Local Plan. However, we consider that this could be further supplemented to indicate which areas may or may not be suited to taller buildings. Our advice note in relation to tall buildings provides further guidance in this respect

We have been having discussions with the team preparing The North East Area Action Plan in relation to tall buildings studies and have provided a detailed advice letter in that regard. Please refer to our advice letters in relation to NEA Action Plan and tall buildings for further information on our position.

g) Other Supporting Evidence

We welcome the preparation of the HELAA although consider that further, more detailed evidence is needed in relation to heritage impact and so welcome your intention to prepare HIAs for site allocations.

We broadly welcome the Strategic Heritage Impact Assessment including the baseline study of the setting of Cambridge. However, we have expressed some concerns regarding some aspects of this baseline, in particular the weighting given to some of the key characteristics and aspects of setting of Cambridge including views. Further detail is given in Appendix A.

We welcome the evidence in relation to landscape character assessment. We do however continue to suggest that it would also be helpful to commission Historic Landscape Characterisation work for inform this Plan and future growth in the area.

We welcome the production of the Sustainability Appraisal. We would comment however that since many of the site allocations are grouping together under particular policies, the different impacts for individual sites are not always drawn out in the assessment tables – this sometimes has the effect of neutralising the scoring.

Historic England – Ox Cam research work

Historic England has commissioned consultants to undertake some work looking at development in the OxCam Arc. ‘Measuring Impact: Managing Change’ looks at the question, ‘How should the form of growth in the Oxford-Cambridge arc positively respond to the Historic Environment’. This research is due to report in the next few months and we hope to be able to share this with you at that time as it may provide useful evidence to inform your Local Plan work.

Other comments

In preparation of the forthcoming Greater Cambridge Local Plan, we encourage you to draw on the knowledge of local conservation officers, archaeologists and local heritage groups.

Please note that absence of a comment on an allocation or document in this letter does not mean that Historic England is content that the allocation or document forms part of a positive strategy for the conservation and enjoyment of the historic environment or is devoid of historic environment issues. Where there are various options proposed for a settlement, identification of heritage issues for a particular

allocation does not automatically correspond to the support for inclusion of the alternative sites, given we have not been able to assess all of the sites.

Finally, we should like to stress that this opinion is based on the information provided by the Council in its consultation. To avoid any doubt, this does not affect our obligation to provide further advice and, potentially, object to specific proposals, which may subsequently arise where we consider that these would have an adverse effect upon the historic environment.

We trust that these comments are helpful to you in developing the Local Plan. Should you have any queries, please do not hesitate to contact us.

We suggest it might be helpful to set up a meeting to discuss our comments and, in particular, heritage impact assessments and policy wording for site allocations.
Please feel free to suggest some dates.

Thank you for consulting Historic England on the First Proposals Public Consultation for the Greater Cambridge Local Plan. As the Government’s adviser on the historic environment Historic England is keen to ensure that the protection of the historic environment is fully considered at all stages and levels of the local planning process.

Cambridge is a beautiful, compact and historic city. It is also an historic seat of learning with a very high concentration of highly graded heritage assets. Much of the city is covered by Conservation Area status. The river corridor, green fingers and open spaces, with cows grazing in meadows even at the heart of the city, shape the character of the townscape and landscape.

Although a relatively flat landscape, the elevated positions to the west and south of the Cambridge afford important views across the city skyline, which is one of extensive tree cover and emerging spires. The flatter Fens landscape to the north and east provides very long-distance views of the City and the big east Anglian skies.

The surrounding rural hinterland of South Cambridgeshire comprises over 100 villages, each with their own unique character and heritage. New settlements are an important feature of the district, with their own special identity and are growing rapidly.

We recognise the area faces intense pressure for growth, driven by both the economic success and the attractiveness of the area, in large part a consequence of

its rich architectural and cultural heritage. This growth must be carefully managed to ensure that the very things that contribute to its success are not harmed in the process.

It is for this reason that Historic England is keen to ensure that the emerging plan gives full consideration to the historic environment, both in the choice of site allocations and policy criteria for sites, as well as through a robust and clear suite of historic environment and other policies that seek to both protect but also enhance the historic environment.

We have reviewed the Draft Plan and consultation material with a view to providing advice on heritage matters.

As a general comment, Historic England welcomes emerging plan and work undertaken to date. We have however identified below some of the key issues to be addressed in progressing the next iteration of the Plan: This should be read in conjunction with Appendix A which provides more detailed comments on these and other more minor issues.

a) Site Assessment and the need for Heritage Impact Assessments

We are pleased to note that a degree of site assessment has already been undertaken in relation to the historic environment. These are set out in the HELAA Report, especially Appendix 4.

To date, the assessment of sites is fairly high level and brief but provides a useful starting point, in particular helping to identify immediate showstoppers. We note that many of the sites are shown as amber.

As we have discussed previously, the need for further assessment of heritage in terms of significance, impact on that significance, potential mitigation and enhancements etc will be needed for the site allocations. There is currently an insufficient evidence base in this regard. We therefore welcome your commitment to undertake Heritage Impact Assessments for site allocations. These should be prepared prior to the next draft of the Local Plan.

This further assessment, known as Heritage Impact Assessment (HIA) should follow the 5 step methodology set out in out in our advice note, HEAN 3 on Site Allocations in Local Plans https://historicengland.org.uk/images- books/publications/historic-environment-and-site-allocations-in-local-plans/.

HIAs should be proportionate (both to the scale of the site and the assets affected). All potential sites will need to be appraised against potential historic environment

impacts. It is imperative to have this robust evidence base in place to ensure the soundness of the Plan. We recommend that the appraisal approach should avoid merely limiting assessment of impact on a heritage asset to its distance from, or inter-visibility with, a potential site.

Site allocations which include a heritage asset (for example a site within a Conservation Area) may offer opportunities for enhancement and tackling heritage at risk, while conversely, an allocation at a considerable distance away from a heritage asset may cause harm to its significance, rendering the site unsuitable.

Impacts on significance are not just based on distance or visual impacts, and assessment requires a careful judgment based on site visits and the available evidence base. Cumulative effects of site options on the historic environment should be considered too.

The following broad steps might be of assistance in terms of assessing sites:

• Identify the heritage assets on or within the vicinity of the potential site allocation at an appropriate scale
• Assess the contribution of the site to the significance of heritage assets on or within its vicinity
• Identify the potential impacts of development upon the significance of heritage asset
• Consider how any harm might be removed or reduced, including reasonable alternatives sites
• Consider how any enhancements could be achieved and maximised
• Consider and set out the public benefits where harm cannot be removed or reduced

The HIAs should assess the suitability of each area for development and the impact on the historic environment. Should the HIA conclude that development in the area could be acceptable and the site be allocated, the findings of the HIA should inform the Local Plan policy including development criteria and a strategy diagram which expresses the development criteria in diagrammatic form.

Which sites require HIA?

Ideally all sites should have an HIA, albeit proportionate to the site and heritage sensitivities.

For existing allocations being carried forward into this Local Plan, the HIA is less about the principle of development (that has already been established through previous plan allocation) and more about exploring capacity, height, density and any heritage mitigation and enhancement opportunities so that these can then be

included in the updated policy wording.

For new allocations, the HIA will be a more holistic view and consider both the principle of development as well as the other matters identified above.

b) Policy Wording for sites

If, having completed the heritage impact assessments, it is concluded that a site is suitable for allocation, we would remind you to include appropriate policy criteria for the historic environment in the policy. Please refer to the advice we give on policy wording in the attached table.

It can be helpful to refer to an HIA in the policy wording. Concept diagrams can also be useful to include in the plan to illustrate key site considerations/ recommendations.

c) Edge of Cambridge sites

The Plan proposes carrying forward a number of partially built out allocations on the edge of the City as well as some minor extensions to these. The Plan also proposes revisiting the dwelling capacity/density for some of these sites e.g. Eddington.

Proposals for North East Cambridge are very high density and also quite tall.

The Plan also includes a very large new allocation at East Cambridge (previously released from the Green Belt and allocated in the 2006 Plan, although not in the 2018 Plan). The number of dwellings now being proposed represents a significant increase in density from the 2006 Plan.

We have some concerns regarding these densities and heights on edge of Cambridge sites. Development at very high densities/heights and the potential impact on the overall setting of this historic city. HIAs should give careful consideration to the issue of development and site capacity and height – we will be looking for evidence in this regard.

d) Historic Environment Policy

We welcome your intention to include a policy for the Historic Environment. This should cover both designated and non-designated heritage assets. Policy wording should be in line with the NPPF but we are also looking for a local flavour.

Policies should be spatially specific, unique to the area, describing the local characteristics of the area and responding accordingly with policies that address the local situation.

You should also include a policy for Heritage at Risk and a policy for historic shopfronts. For further detail see Appendix A.

e) Design Policy

We welcome the proposals for a design policy on the plan. We note that this policy is also intended to address tall buildings. We are concerned that the policy might become overly long and detailed, given it is covering such a wide and important range of issues and wonder whether separating out tall buildings into a separate policy might be helpful?

f) Tall Buildings Study and Policy

Related to the above, given the growth pressures that we would anticipate Cambridge is likely to experience over the coming years, we are pleased to see that the matter of Tall buildings and the skyline will be addressed in policy.

We had understood that you were commissioning a study in relation to tall buildings and the skyline policy. Is this still proposed to inform the policy in the next draft of the Local Plan?

See our advice note HEAN 4 and the consultation draft of HEAN 4. Any policy should indicate what considerations are needed for taller buildings, where buildings may or may not be appropriate etc. and in particular consider in the impact on the historic environment.

We broadly welcome policy 60 and Appendix F of the 2018 Cambridge City Local Plan. However, we consider that this could be further supplemented to indicate which areas may or may not be suited to taller buildings. Our advice note in relation to tall buildings provides further guidance in this respect

We have been having discussions with the team preparing The North East Area Action Plan in relation to tall buildings studies and have provided a detailed advice letter in that regard. Please refer to our advice letters in relation to NEA Action Plan and tall buildings for further information on our position.

g) Other Supporting Evidence

We welcome the preparation of the HELAA although consider that further, more detailed evidence is needed in relation to heritage impact and so welcome your intention to prepare HIAs for site allocations.

We broadly welcome the Strategic Heritage Impact Assessment including the baseline study of the setting of Cambridge. However, we have expressed some concerns regarding some aspects of this baseline, in particular the weighting given to some of the key characteristics and aspects of setting of Cambridge including views. Further detail is given in Appendix A.

We welcome the evidence in relation to landscape character assessment. We do however continue to suggest that it would also be helpful to commission Historic Landscape Characterisation work for inform this Plan and future growth in the area.

We welcome the production of the Sustainability Appraisal. We would comment however that since many of the site allocations are grouping together under particular policies, the different impacts for individual sites are not always drawn out in the assessment tables – this sometimes has the effect of neutralising the scoring.

Historic England – Ox Cam research work

Historic England has commissioned consultants to undertake some work looking at development in the OxCam Arc. ‘Measuring Impact: Managing Change’ looks at the question, ‘How should the form of growth in the Oxford-Cambridge arc positively respond to the Historic Environment’. This research is due to report in the next few months and we hope to be able to share this with you at that time as it may provide useful evidence to inform your Local Plan work.

Other comments

In preparation of the forthcoming Greater Cambridge Local Plan, we encourage you to draw on the knowledge of local conservation officers, archaeologists and local heritage groups.

Please note that absence of a comment on an allocation or document in this letter does not mean that Historic England is content that the allocation or document forms part of a positive strategy for the conservation and enjoyment of the historic environment or is devoid of historic environment issues. Where there are various options proposed for a settlement, identification of heritage issues for a particular

allocation does not automatically correspond to the support for inclusion of the alternative sites, given we have not been able to assess all of the sites.

Finally, we should like to stress that this opinion is based on the information provided by the Council in its consultation. To avoid any doubt, this does not affect our obligation to provide further advice and, potentially, object to specific proposals, which may subsequently arise where we consider that these would have an adverse effect upon the historic environment.

We trust that these comments are helpful to you in developing the Local Plan. Should you have any queries, please do not hesitate to contact us.

We suggest it might be helpful to set up a meeting to discuss our comments and, in particular, heritage impact assessments and policy wording for site allocations.
Please feel free to suggest some dates.

Thank you for consulting Historic England on the First Proposals Public Consultation for the Greater Cambridge Local Plan. As the Government’s adviser on the historic environment Historic England is keen to ensure that the protection of the historic environment is fully considered at all stages and levels of the local planning process.

Cambridge is a beautiful, compact and historic city. It is also an historic seat of learning with a very high concentration of highly graded heritage assets. Much of the city is covered by Conservation Area status. The river corridor, green fingers and open spaces, with cows grazing in meadows even at the heart of the city, shape the character of the townscape and landscape.

Although a relatively flat landscape, the elevated positions to the west and south of the Cambridge afford important views across the city skyline, which is one of extensive tree cover and emerging spires. The flatter Fens landscape to the north and east provides very long-distance views of the City and the big east Anglian skies.

The surrounding rural hinterland of South Cambridgeshire comprises over 100 villages, each with their own unique character and heritage. New settlements are an important feature of the district, with their own special identity and are growing rapidly.

We recognise the area faces intense pressure for growth, driven by both the economic success and the attractiveness of the area, in large part a consequence of

its rich architectural and cultural heritage. This growth must be carefully managed to ensure that the very things that contribute to its success are not harmed in the process.

It is for this reason that Historic England is keen to ensure that the emerging plan gives full consideration to the historic environment, both in the choice of site allocations and policy criteria for sites, as well as through a robust and clear suite of historic environment and other policies that seek to both protect but also enhance the historic environment.

We have reviewed the Draft Plan and consultation material with a view to providing advice on heritage matters.

As a general comment, Historic England welcomes emerging plan and work undertaken to date. We have however identified below some of the key issues to be addressed in progressing the next iteration of the Plan: This should be read in conjunction with Appendix A which provides more detailed comments on these and other more minor issues.

a) Site Assessment and the need for Heritage Impact Assessments

We are pleased to note that a degree of site assessment has already been undertaken in relation to the historic environment. These are set out in the HELAA Report, especially Appendix 4.

To date, the assessment of sites is fairly high level and brief but provides a useful starting point, in particular helping to identify immediate showstoppers. We note that many of the sites are shown as amber.

As we have discussed previously, the need for further assessment of heritage in terms of significance, impact on that significance, potential mitigation and enhancements etc will be needed for the site allocations. There is currently an insufficient evidence base in this regard. We therefore welcome your commitment to undertake Heritage Impact Assessments for site allocations. These should be prepared prior to the next draft of the Local Plan.

This further assessment, known as Heritage Impact Assessment (HIA) should follow the 5 step methodology set out in out in our advice note, HEAN 3 on Site Allocations in Local Plans https://historicengland.org.uk/images- books/publications/historic-environment-and-site-allocations-in-local-plans/.

HIAs should be proportionate (both to the scale of the site and the assets affected). All potential sites will need to be appraised against potential historic environment

impacts. It is imperative to have this robust evidence base in place to ensure the soundness of the Plan. We recommend that the appraisal approach should avoid merely limiting assessment of impact on a heritage asset to its distance from, or inter-visibility with, a potential site.

Site allocations which include a heritage asset (for example a site within a Conservation Area) may offer opportunities for enhancement and tackling heritage at risk, while conversely, an allocation at a considerable distance away from a heritage asset may cause harm to its significance, rendering the site unsuitable.

Impacts on significance are not just based on distance or visual impacts, and assessment requires a careful judgment based on site visits and the available evidence base. Cumulative effects of site options on the historic environment should be considered too.

The following broad steps might be of assistance in terms of assessing sites:

• Identify the heritage assets on or within the vicinity of the potential site allocation at an appropriate scale
• Assess the contribution of the site to the significance of heritage assets on or within its vicinity
• Identify the potential impacts of development upon the significance of heritage asset
• Consider how any harm might be removed or reduced, including reasonable alternatives sites
• Consider how any enhancements could be achieved and maximised
• Consider and set out the public benefits where harm cannot be removed or reduced

The HIAs should assess the suitability of each area for development and the impact on the historic environment. Should the HIA conclude that development in the area could be acceptable and the site be allocated, the findings of the HIA should inform the Local Plan policy including development criteria and a strategy diagram which expresses the development criteria in diagrammatic form.

Which sites require HIA?

Ideally all sites should have an HIA, albeit proportionate to the site and heritage sensitivities.

For existing allocations being carried forward into this Local Plan, the HIA is less about the principle of development (that has already been established through previous plan allocation) and more about exploring capacity, height, density and any heritage mitigation and enhancement opportunities so that these can then be

included in the updated policy wording.

For new allocations, the HIA will be a more holistic view and consider both the principle of development as well as the other matters identified above.

b) Policy Wording for sites

If, having completed the heritage impact assessments, it is concluded that a site is suitable for allocation, we would remind you to include appropriate policy criteria for the historic environment in the policy. Please refer to the advice we give on policy wording in the attached table.

It can be helpful to refer to an HIA in the policy wording. Concept diagrams can also be useful to include in the plan to illustrate key site considerations/ recommendations.

c) Edge of Cambridge sites

The Plan proposes carrying forward a number of partially built out allocations on the edge of the City as well as some minor extensions to these. The Plan also proposes revisiting the dwelling capacity/density for some of these sites e.g. Eddington.

Proposals for North East Cambridge are very high density and also quite tall.

The Plan also includes a very large new allocation at East Cambridge (previously released from the Green Belt and allocated in the 2006 Plan, although not in the 2018 Plan). The number of dwellings now being proposed represents a significant increase in density from the 2006 Plan.

We have some concerns regarding these densities and heights on edge of Cambridge sites. Development at very high densities/heights and the potential impact on the overall setting of this historic city. HIAs should give careful consideration to the issue of development and site capacity and height – we will be looking for evidence in this regard.

d) Historic Environment Policy

We welcome your intention to include a policy for the Historic Environment. This should cover both designated and non-designated heritage assets. Policy wording should be in line with the NPPF but we are also looking for a local flavour.

Policies should be spatially specific, unique to the area, describing the local characteristics of the area and responding accordingly with policies that address the local situation.

You should also include a policy for Heritage at Risk and a policy for historic shopfronts. For further detail see Appendix A.

e) Design Policy

We welcome the proposals for a design policy on the plan. We note that this policy is also intended to address tall buildings. We are concerned that the policy might become overly long and detailed, given it is covering such a wide and important range of issues and wonder whether separating out tall buildings into a separate policy might be helpful?

f) Tall Buildings Study and Policy

Related to the above, given the growth pressures that we would anticipate Cambridge is likely to experience over the coming years, we are pleased to see that the matter of Tall buildings and the skyline will be addressed in policy.

We had understood that you were commissioning a study in relation to tall buildings and the skyline policy. Is this still proposed to inform the policy in the next draft of the Local Plan?

See our advice note HEAN 4 and the consultation draft of HEAN 4. Any policy should indicate what considerations are needed for taller buildings, where buildings may or may not be appropriate etc. and in particular consider in the impact on the historic environment.

We broadly welcome policy 60 and Appendix F of the 2018 Cambridge City Local Plan. However, we consider that this could be further supplemented to indicate which areas may or may not be suited to taller buildings. Our advice note in relation to tall buildings provides further guidance in this respect

We have been having discussions with the team preparing The North East Area Action Plan in relation to tall buildings studies and have provided a detailed advice letter in that regard. Please refer to our advice letters in relation to NEA Action Plan and tall buildings for further information on our position.

g) Other Supporting Evidence

We welcome the preparation of the HELAA although consider that further, more detailed evidence is needed in relation to heritage impact and so welcome your intention to prepare HIAs for site allocations.

We broadly welcome the Strategic Heritage Impact Assessment including the baseline study of the setting of Cambridge. However, we have expressed some concerns regarding some aspects of this baseline, in particular the weighting given to some of the key characteristics and aspects of setting of Cambridge including views. Further detail is given in Appendix A.

We welcome the evidence in relation to landscape character assessment. We do however continue to suggest that it would also be helpful to commission Historic Landscape Characterisation work for inform this Plan and future growth in the area.

We welcome the production of the Sustainability Appraisal. We would comment however that since many of the site allocations are grouping together under particular policies, the different impacts for individual sites are not always drawn out in the assessment tables – this sometimes has the effect of neutralising the scoring.

Historic England – Ox Cam research work

Historic England has commissioned consultants to undertake some work looking at development in the OxCam Arc. ‘Measuring Impact: Managing Change’ looks at the question, ‘How should the form of growth in the Oxford-Cambridge arc positively respond to the Historic Environment’. This research is due to report in the next few months and we hope to be able to share this with you at that time as it may provide useful evidence to inform your Local Plan work.

Other comments

In preparation of the forthcoming Greater Cambridge Local Plan, we encourage you to draw on the knowledge of local conservation officers, archaeologists and local heritage groups.

Please note that absence of a comment on an allocation or document in this letter does not mean that Historic England is content that the allocation or document forms part of a positive strategy for the conservation and enjoyment of the historic environment or is devoid of historic environment issues. Where there are various options proposed for a settlement, identification of heritage issues for a particular

allocation does not automatically correspond to the support for inclusion of the alternative sites, given we have not been able to assess all of the sites.

Finally, we should like to stress that this opinion is based on the information provided by the Council in its consultation. To avoid any doubt, this does not affect our obligation to provide further advice and, potentially, object to specific proposals, which may subsequently arise where we consider that these would have an adverse effect upon the historic environment.

We trust that these comments are helpful to you in developing the Local Plan. Should you have any queries, please do not hesitate to contact us.

We suggest it might be helpful to set up a meeting to discuss our comments and, in particular, heritage impact assessments and policy wording for site allocations.
Please feel free to suggest some dates.

I am having issues with the online system, and therefore write to strongly object any development on site S/CBC-A.

Notably, the site proposed is at present wholly within the Cambridge green belt and outside of the development framework. Any development here would substantially weaken the divide between the city and rural landscapes creating an urban space that goes right to the Granham's Rd area creating a stark divide rather than the current blending achieved. It is clear that there are other less impactful and non-green belt options available for expansion of the Biomedical Campus nearer to the Cambridge south station site. Other brownfield options are available that do not impact on the green belt in the same way.

Notably, the proposed site comes significantly close to the nature reserve and would also impact wildlife and the biodiversity at this previous Site of Special Scientific Interest. The proposed development right up to this area may detrimentally impact on the aim of re-creating the conditions favourable for a possible re-introduction of the rare species previously lost. It occurs to me that we should be seeking to expand the nature reserve, creating a place of recreational utility for the wellbeing of people and nature as a whole, rather than developing right up to the reserve.

Indeed, as I understand it, the development proposed is largely laboratory and office facilities with some residential capacity and will heavily intrude on the character of the area, while adding additional traffic. Despite the station and cycling paths, which are not fully developed, we know many drive into the CBC and continue to do so as housing process preclude many from buying adjacent properties. The area is already heavily congested and cycling fatalities have evidenced a significant need to overhaul the infrastructure before further pressure is added. The congestion of the additional traffic through the proposed developments is likely to have significant environmental impacts and the proximity to the chalk conduit site cannot being overlooked. The environmental impacts will be substantial.

Assessments published of the area also highlight the flood risk and it is unclear whether mitigation will be able too offset the elevated risk to residents already on the site like those at Ninewells. Building on the fields will be connected to greater surface water and assessments suggest significant impacts and risks.

With the existing biomedical site not yet fully utilised and it unclear how work and life balances (including working from home) will play out in the post-COVID world, it appears the risks would outweigh the benefits in terms of this site proposal at the current time. Much greater consideration of the spill over effects of further development on wildlife and the wider community are needed. I therefore strongly oppose the proposal.

Policy S/CE: Cambridge East refers to the importance of the GCP Cambridge Eastern Access scheme Phase B being in place which will provide high quality public transport connections. Whilst the motives for this are well-intentioned, it has to be recognised that, despite every attempt, cars remain the preferred choice of many people to get to work, even if it means large traffic jams. Even if walking/cycling is an individual’s preferred means of transport, enthusiasm can disappear in the event of rain, wind, ice and snow and any transport plan must recognise the worst-case scenario. It is therefore imperative that road links between Cambridge East and the three southern campuses are improved. The road structure beyond the Robin Hood crossroads is simply not fit for purpose. Access to the Cambridge Biomedical Campus is limited to the use of Queen Edith’s Way, which is a comparatively narrow main road whilst access to the Babraham and Genome Campuses is via Lime Kiln Road, which was never designed for large volumes of traffic.
(Pages 85-90) Policy S/CBC: Cambridge Biomedical Campus (including Addenbrooke’s Hospital).
Whilst Policy Direction is driven from outside the local area, Queen Edith’s should be proud to be part of such a prestigious international development. I welcome the Proposed policy direction, provided the activities are closely monitored to avoid inappropriate development on the site.
Nevertheless, there are significant dangers associated with such a powerful neighbour and it is important that these are recognised and mitigated. The CBC Vision 2050 is still at an early stage of development, and it is essential that the Local Plan incorporates sufficient flexibility to respond appropriately to this. As a first step, I welcome the aim of CBC to be a good neighbour and to include members of the Queen Edith’s Community Forum on their Vision 2050 Liaison Group.
As mentioned in 3.1, I welcome the concept of key worker accommodation on site but would not support any housing which is offered to the general public.
Why is this Policy needed? (Page 89). I welcome the sensitive approach to the Green Belt issues. Whilst it is important that we respect and protect nature and our environment, it is important to recognise that, as a species, we also compete for survival and that nature can be hostile (not least in creating human diseases such as Covid via bats in a Chinese cave and Avian flu). It is therefore important to weigh the benefits of the life sciences against the importance of protecting the environment and I believe that the proposals for this Policy strike a good balance.
Whilst I appreciate the need for expansion, I believe that it would also be important, not least for residents of Trumpington and Great Shelford, to make it clear that there is no prospect of expanding across Granham’s Road and to initiate a discussion between CBC and the southern campuses, including Fulbourn East regarding alternative ways in which the life sciences can be accommodated in south-east Cambridge.
It will be important to explore with local life sciences businesses the nature of collaboration:
· Who collaborates with whom and why?
· How dependent is it on being on the same site?
· How is collaboration impacted by having sites a few miles apart?
· What proportion of the workforce benefit from close collaboration? How often should such collaborative action take place in an ideal world?
· How far have work practices changed as a consequence of Zoom and other features forced by the pandemic?
I also like the concept of a “green edge” to the city, which should not only be green on the ground, but soften the view, avoiding the current harshness of both Eddington and Trumpington Meadows as you approach.
The provision of water to the site, the high-water table and surface water flooding issues are critical and a potential show-stopper for further development unless and until they are fully resolved. These are addressed in 2.3 above and will not be repeated here.
(page 43) Transport strategy The willingness to work with other authorities to progress local plan evidence is welcome. Please ensure that, for reasons given in 2.3 and 3.2, the issues of Lime Kiln Road are fully addressed.
(page 94) Policy S/EOC: Other site allocations on the edge of Cambridge. Biomed Reality, which recently made an application for planning permission for the 6.9ha Fulbourn Road East site, indicated that were planning for 2,700 jobs and 1,362 parking spaces. The 4.4ha Fulbourn Road West (GB3 and GB4) is located nearby and simple scaling suggests that this might add a further 1,700 jobs and 868 parking spaces.
The Fulbourn sites are major developments and have the potential to create major traffic problems into and out of Queen Edith’s Way and Cherry Hinton Road, which will be greatly exacerbated when the Cambridge East development comes on stream. A full infrastructure assessment as part of Policy I/ID: Infrastructure and delivery must be made of the impact of traffic on these roads and at the Robin Hood junction.

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.

Broadly supportive since the Biomedical Campus reflects Cambridge’s specific strengths and should be supported to meet growth aspirations.
Cambridge South will enhance sustainable travel from within and outside GC.

The Cambridgeshire Development Forum brings together a diverse range of organisations with a shared commitment to the delivery of high-quality developments in the Cambridgeshire region. We include promoters, developers, housebuilders, housing associations, planners, advisers, law firms, design companies, transport planners and related professionals in our membership. We do not promote individual sites and are focused on achieving more effective delivery of plans in our region. We value the engagement we receive from local planning authorities, the Combined Authority and Central Government. We welcome this opportunity to respond to the consultation on the Local Plan.

These representations reflect shared views among our members but should not be interpreted as representing the views of any individual member organisation in membership of the Forum.

Responses:

Q1: the additional 550 homes a year should be regarded as a minimum figure, which should be reviewed regularly in relation to the growth in jobs within the travel-to-work areas

Q2: the spatial strategy for development should focus the larger development sites in locations which offer public transport options to reach major employment centres. Development in rural locations of an appropriate scale should not be deterred as and when more sustainable personal transport options are available, eg EVS using renewable energy.

Q3: The Cambridge East Development should be connected directly to the City centre and the inner urban ring of development at the Biomedical campus, North Cambridge and the Science Park, Eddington and West Cambridge. But it should not be a wholly residential development. It should be a mixed development including commercial, residential and leisure/ retail options. It should be envisaged as a distinct place, with its own character. It could include high-rise apartments suitable for the younger workers who comprise many Cambridge area workforces.

Q4: North-East Cambridge should offer a residential opportunity for those employed in the technology sectors around Cambridge, including a significant component of affordable housing for market sale, market rent, shared ownership, and social housing.

Q5: development in and close to the biomedical campus should be prioritised for the healthcare, research, and technology cluster; significant adjacent sites should not be developed for large-scale residential purposes.

Q6: Cambourne should provide jobs near the new homes and include more employment space potentially including a commercial hub based on any new railway station above the A428.
Outside this commercial and retail hub, Cambourne should be focused on the large-scale offering of homes for families of those working across the Cambridge area.

Q7: in the southern rural cluster, opportunities for development on brownfield sites and for rural diversification, with small business-related developments should not be excluded.
Related residential development on smaller sites should also be accommodated, taking account of the Neighbourhood Plans. A priority should be given to sites in villages on rail routes, at public transport nodes and within public transport corridors. Subject to the decisions to be made concerning the East-West Rail Link, the option for significant growth and/or new settlement in appropriate locations that maximises the use of all forms of public transport should be considered as additions to the sites proposed.

[Q8-13 omitted]


We have welcomed the engagement with the Greater Cambridge Shared Planning team, and look forward to this continuing through this process in future discussions.

Cambridgeshire Development Forum December 2021

Water supply for the plan consultation on idea of 48,000 new households during building and completion after estimated 20 years:
a)Water to supply such a project is unsustainable. We are already in a place of deficit - the flow of the river Cam is substantially reduced due to increase in the area’s population.
. Anglia Water is driven to plan new sewage works on green belt land which was promised to not be touched - ie Green Belt.
. Any plans to “create green spaces and nature reserves in the area” would need water for plant/tree life, currently this is hard to sustain and we know drought in summer will only increase.
. Any idea that we take water from other areas of the UK is magical thinking - they will also be suffering water shortages.
. Building reservoirs in the Fens is way out as with climate crisis it is envisaged they will be flooded with salt water.

b)Ecological issues regarding development around the Biomedical Site/Addenbrookes/SCBC/A Nine wells etc - will have a negative impact on bio-diversity that will be difficult to mitigate. More loss on insect, plant & wild life bring a further loss to falling farm bird populations. It’ll be hard to irrigate the plantations.
. We need every bit of land to grow our food in order to be secure when markets for our food importation might change. We import more than 50 per cent of our needs. The area around nine-wells Trumpington etc was historically excellent for agriculture. I have knowledge of south Cambridgeshire villages and the land is a major farming area for grain.

c) We already have a need for housing for key workers and we are not organised enough to achieve this. Developers and planning is not on top of this problem. Hopefully residential development opportunity at Marshals Airport will help but that brings up the transport problem.

d) Travel south up Babraham Rd and up on the Gogs, look back on Cambridge and often one sees a grey fog - Cambridge is in a dip which one reason for pollution being so high here. We are top in the nation for traffic jams, these are pollution machines, even electric cars produce toxic emissions. We need some of the measures proposed to dissuade car use in the area. Yes, I would agree to road charges that bring a noticeable reduction in car use. There could be a badge scheme for vans that have to carry tools and equipment.

To sum up: Such growth for the sake of the economy is not what we should be looking at in this way at this time. The climate crisis, covid and other pandemics that will follow is changing our work and travel pattern. It is changing our needs regarding water and land use and "levelling up”. Also consider AI as a big factor , many of the implications are unknown.

The area is too complicatedly organised by local government divisions with no satisfactory overview. We need to work on the many existing problems (some mentioned above) first before we totally fall for the Government’s hopeful plans for the south East and the Arc that are not regarding the complications realistically.

The Federation of Cambridge Residents’ Associations (FeCRA) is a grassroots civic voice for everyone in Cambridge and for its environment. Residents want a say in shaping Cambridge’s development to ensure that the city grows in a way that is sustainable and inclusive, achieves balanced communities and addresses the issues of climate change and health, social equality and quality of life. Residents know their areas well, and they want to be involved in evidence gathering and data collection.

Over the last years residents' associations have organised successful discussions on parking, local election hustings, Greater Cambridge transport schemes, neighbourhood planning, heritage and public realm and green spaces and the river and biodiversity.

FeCRA’s well attended AGM events are organised on the same basis, featuring presentations from prominent experts including leading landscape architect Kim Wilkie, George Ferguson, former Mayor of Bristol and the distinguished Oxford ecologist Professor David Rogers. More recently, the Supersize Cambridge event which attracted 230 people and involved community reps from all over Cambridge highlighted concerns about employment led growth and the global interests driving this. FeCRA’s strength is in its network of members in all city neighbourhoods and good channels of communication with villages across South Cambs, along with the five OxCam Arc counties and Norfolk, Suffolk, Hert and Essex. The Federation is entirely voluntary and self funded.

A sense of neighbourhood and wellbeing and belonging and mutual support is especially important in a city which has earned the unenviable title of the most unequal city in the UK.

Draft Local Plan
How much development and where
Many residents are shocked at the level of growth proposed in the new Draft Local Plan and what they see as the plan’s failure to consider the overall environmental capacity and climate change impact and the effect on the historic environment (built and natural) in a holistic way. There is no mention of Covid and opportunities for city centre residential and/or other uses resulting from potential radical changes in retail and office working.
There is no consideration or assessment of current growth in the pipeline or of the success or failure of current Local Plan policies, no assessment of the cumulative impact of current growth, especially in terms of delivering the claimed nature and quality of development.

There is a complete dearth of new cultural or provision for other ‘city-scale’ needs which will put the city centre under even greater pressure.

Where is the overall vision of what Cambridge will be like in the future? Who is the city for? This plan does not make clear.

The question of how much development and where is premature pending the January 2022 consultation on the Regional Water Plan and the investigation of sewage infrastructure and sewage dumping by Anglian Water.

Inadequate Water Supply

Cambridge City and South Cambridgeshire already have an unsustainable supply of potable water. In August 2020, the Environment Agency, in response to a query on the viability of water supply to Northstowe Phase 3A wrote to Monica Hone of Friends of the Cam that 'current levels of abstraction are causing environmental damage. Any increase in use within existing licenced volumes will increase the pressure on a system that is already failing environmental targets', and 'many waterbodies did not have the flow to support the ecology.'
On the 1st July 2021, DEFRA announced that chalk streams would be given enhanced environmental protection, and published the Environment Agency document titled “Water stressed areas – final classification 2021” which included the fact that the supply areas of Cambridge Water and Anglian Water are areas of serious water stress, page 6.
According to Appendix 3, Cambridge Water needs to reduce abstraction by 22 megalitres per day from levels current at 1st July 2021, and Anglian Water needs to reduce abstraction by 189 megalitres per day from levels current at 1st July 202

Yet, one of Anglian Water’s proposed ‘solutions’ to this problem is to pump water from North Lincolnshire, which is also classified by the Environment Agency in the above report as a water stressed area.

The expectation that ‘green’ growth and River Cam Corridor nature tourism can fund a system of water management without addressing over- abstraction and sewage in the rivers

The local sewage system is currently inadequate. The inadequacy of the sewage system is evidenced by the number of sewage spills by smaller Anglian Water sewage works into the Cam Valley. Currently, there are no plans to improve failing combined sewer overflows (csos), just promises to monitor them more accurately. The Cam Valley upstream of Cambridge saw 622 hours of untreated wastewater enter the rivers in 2020, yet Anglian Water is proposing to move the one sewage works in the area which has been upgraded and has sufficient capacity until 2050, the main Cambridge works, into the Green Belt and to spend at least £227 million of public money to do so. This will be the subject of only a partial public inquiry because it has been submitted as a National Infrastructure project in order to minimise public scrutiny.

To date there have been no upgrades at any of the smaller works in the area while more and more taps are still being connected. The Environment Agency has already warned at least one Cambridgeshire local planning authority, East Cambs District Council, that they must stop looking at the sewage requirements of single planning applications and instead look at the cumulative effects.

How can anyone talk about ‘green’ growth and nature tourism when the water companies are over-abstracting and filling the Cam chalk streams with sewage.
New jobs and homes – the plan proposes 58,500 jobs and 44, 400 homes

The way in which this consultation is framed and the fact that it does not address how the region’s water crisis and wastewater and emission problems will be resolved ignores both environmental constraints and the failure of current policies to provide affordable housing. It does not give a true picture of the cost of such high employment growth for the UK’s driest city with a water crisis whose world famous river is drying up and dumped full of sewage.

It undermines the Government’s policy of ‘levelling up.
It completely ignores how the plan will ensure that new developments are for local people and not dormitories for London commuters or just opportunities for foreign investors.

New communities take time to emerge, if they do at all, but the issue is that many new developments are injected into places with existing communities that may suffer as a result, an issue this plan does not assess.

Professor Dieter Helm, Chair of the National Capital Committee has stressed the importance of long-term risk assessment in ensuring net environmental gain, in perpetuity, despite development. There is no evidence that this has been done.

There are massive environmental capacity issues which the Draft Local Plan does nothing to address, with inadequate space in city streets and public realm to cater for existing traffic, let alone approved growth already in the pipeline – even before considering these First Proposals. The capacity issues have to be tackled, with additional growth allowed only if they can be resolved.

Green Belt Assessment

The Green Belt assessment is not fit for purpose, because it ignores historic environment designations and landscape character constraints.

On the edge of Cambridge the serious landscape impacts of the Cambridge BioMedical Campus expansion southwards into the Green Belt open countryside towards the Gogs will severely damage this lovely setting of the city with its beautiful chalk downland views. The expansion and likely increase in footfall will hugely impact the small nature reserve of Ninewells, the reserve’s unique character and boskiness and farmland birds.
Building NE Cambridge will indirectly destroy the Green Belt by displacing the sewage works and using a lot of concrete which has a very high carbon footprint.
There is no operational need to move the treatment works as Anglian Water has confirmed. The relocation is taking place to enable development within Cambridge in which the water company is a beneficiary as co-developer. The current site is more than adequate for at least another 30 years and could be upgraded at far less cost. The existing treatment works at Milton is effective and has spare capacity. It was upgraded only recently, at a cost of £21 million in 2015, in order to support planned development in Cambridge and the surrounding area until 2050 and is being vacated only to enable redevelopment. We understand that the Milton Plant is currently only running at approximately 50% capacity. The CO2 cost embedded in the new structure and emitted in demolition and construction is sizable.

Many residents question why the works are being moved given the impact on the Green Belt, the loss of valuable farmland, and the harm to local communities, all of which are united in their opposition. They question how this complies with the guidance outlined in the HM Treasury’s Green Book Valuation of Wellbeing Guidance for Appraisal https://www.gov.uk/government/publications/green-book-supplementary-guidance-wellbeing especially as the Stantec Report prepared as part of the review of the Local Plan and the letter from the Environment Agency https://www.fecra.org.uk/docs/Env%20Agency%20re%20Northstowe%207%20August%202020.pdf make clear that any further development beyond that already planned is unsustainable as ‘current levels of abstraction are causing environmental damage. Any increase in use within existing licensed volumes will increase the pressure on a system that is already failing environmental targets’.

There is no mention in these plans of how relocation of the wastewater plant will address any of the concerns about all the sewage being dumped in the Cam or how Anglian Water proposes to make the River Cam clean and safe for all users. If you were going to spend £200m plus, or even a fraction of it, it should be spent on improving and updating the small local sewage works based around villages etc, which release sewage in the Cam via its tributaries, not on rebuilding something that is working well. In the case of these small poorly functioning sewage systems Anglian Water is almost solely responsible and that is what residents tell us this company should be focusing on, not this grandiose money-making scheme. The chair of Water Resources East, Dr Paul Leinster, is a member of the new Office for Environmental Protection. He is on public record as stating that what to do with the wastewater is one of the biggest problems for development in the region proposed by the government for the Oxford Cambridge Arc.
There are a number of SSSI’s close to the site which could be affected by its construction and operation: Brackland Rough, Cam Washes, Cherry Hinton Pit, Chippenham Fen and Snailawell Poors Fen (a RAMSAR site), Devils Dyke, Felan Dyke, Fulbourn Fen, Gog Magog Golf course, Great Wilbraham Common, Histon Road, Roman Road, Snailwell Meadows, Stow-cum-Quy Fen, Upware South Pit and Wicken Fen, which is another RAMSAR site.

Anglian Water recognises the likelihood that the surface water originating at the works at the Honey Hill site will drain towards Quy Waters protected waterbody and could contaminate it. Yet they have ignored the fact that contaminated groundwater in the chalk aquifer beneath the site could pollute these other receptors and protected rights (local well users) as well as other parts of the surface water drainage network.

The Honey Hill site is in the National Trust Wicken Fen Vision. This is a National Nature Reserve and a Nature Conservation Review site. It is a designated RAMSAR, SAC wetland site of international importance and part of the Fenland Special Area under the Habitats Directive. How does a scheme which robs East Cambridgeshire villages of their green belt and medieval river landscape setting and which impacts the Wicken Fen Vision correlate with protecting Green Belt land which is specifically designed to preserve the historic character of Cambridge and its green belt setting and the River Cam?
Democratic deficit in the process and evidence basis for the Draft Local Plan

Water Resources East have stated that their regional water plans which include plans for natural capital align with the Government's plans for growth. Sewage in rivers and chalk streams is a matter of national concern, yet Water Resources East say that sewage is not part of their remit. They have also said that there will not be public consultation on the regional water plan.

Meanwhile, the public consultation for the Draft Local Plan is taking place now, yet the consultation for the Regional Water Plan is not due until summer 2022. The public and councillors are forced to respond to Local Plan proposals with no idea whether, and if so, how, the water and sewage challenges can be resolved or what trade-offs have been proposed.

South Cambs. MP Anthony Browne has rightly expressed concerns about the Local Plan process and about water issues and transparency.

The Draft Local Plan has been prepared by the Greater Cambridge Shared Planning Service, but it appears to be inordinately influenced by the unelected Greater Cambridge Partnership which has business interests represented on its board.

Much of the text of the Draft Local Plan appears to be consistent with announcements made by the self- appointed Arc Leaders Group promoting the so-called Ox-Cam Arc. This flawed concept has been criticised for lack of transparency or accountability right across the five affected counties and one county, Buckinghamshire, has withdrawn entirely from this completely undemocratic, self-selecting, body.

At a presentation of growth scenarios for Cambridge Futures3 given by the Vice Chair of Cambridge Ahead Matthew Bullock and Dr Ying Jin in June 16, 2018 the audience pointed out that all of the scenarios for Cambridge Future 3 led to Cambridge having a much higher level of growth.

They highlighted that the growth scenarios made no mention of environmental capacity issues, nothing on climate change, quality of life, affordable housing or why people chose to live in and around Cambridge for cultural and green spaces reasons etc. At the presentation it was made clear that Cambridge Ahead & Cambridge University planned to monetise the model they had come up with.

So the model was not in any sense charitable work, it was completely commercial.
Bullock stressed how complex the model was that Dr Ying Jin and his team had come up with and that they would need to come up with a price for running the model with different input parameters.

This meant that Cambridge Ahead and Cambridge University controlled access to the model, limiting detailed scrutiny and testing by independent third parties.
Those working on the growth scenarios included officers and consultants from SQW – the same consultancy employed along with the real estate consultants GL Hearn by the planners to assess the modelling for the Draft Local Plan as ‘they were not conflicted’.

The presenters Matthew Bullock and Dr Yin Jing said that changing elements of the model and programming scenarios was technically challenging and slow, making it difficult or impossible to test a large number of scenarios.

They also said that they intended to monetise the model, e.g. by charging planning authorities, ONS (the Office of National Statistics) and developers to use it.

The business group Cambridge Ahead had a strong commercial motive for this modelling and the modelling evidence for a much higher level of growth and lots more houses to be built, gives a strong lead on where development should take place. Attendees at the Case for Cambridge Future 3 meeting pointed out that the pre-set "no holds barred" scenarios defined by Cambridge Ahead and Cambridge University and officers and consultants working with them would thus become the only options, even though there were likely to be many other scenarios that would produce better outcomes.
Thus the modelling that has been used to inform the Cpier Strategy cited in the Greater Cambs Employment Land and Economic Development Study Draft Local Plan does not take account of social justice, regional landscape strategy or address environmental capacity issues including those of the river, the city centre and the city’s green spaces. Nor does it consider how people want to live, respecting what communities value, and the issues of climate change, the natural world, water shortage, sewage etc.

This Draft Local Plan reflects those pre-determined scenarios of building on the urban fringes and transport corridors to support the high employment growth defined by Cambridge Ahead and the interests funding the research.

At the Case for Cambridge Future 3 meeting attendees referred to "No holds barred scenarios" and a number of people noted the 'densification' scenario assumed that Trumpington Meadows would be developed alongside Cambridge South station as a location for high density development which would assume a planning approach of creating new development which you “mitigate” by reserving areas of green spaces as ‘wild belt’. They pointed out the approach was to sell housing on that basis and then take it back afterwards for infill and that this was already happening at Cambourne.
The same point about infill and wild belt was made by David Plank of the Trumpington Residents Association regarding the recent presentation by the planners of the Draft Local Plan and the BioMedical Campus Expansion plans round Ninewells to the South Area Committee.
In August 2019 the FeCRA Committee wrote to the Deputy Leader of Cambridge City Council to express concern that the Shelford Local Plan workshop for city residents, cited as the formal first stage of public engagement on the Draft Local Plan had been organised at very short notice and with very little opportunity for city residents to engage in the first formal stage of the Local Plan Process.

FeCRA filmed all f the Local Plan Presentation on the 2018 Local Plan. The film is available for everyone to see. There was very positive feedback from Residents Association members but the presentation also flagged up major concerns about the ‘growth agenda’ and the apparent lack of transparency and democratic input around it.

We were told at that meeting that there would be an opportunity for residents to contribute to early discussions about the next LP, yet this Local Plan workshop was arranged at such short notice and at a time and place that made it difficult for many city residents to attend. Consequently very few city residents attended.

Green Infrastructure Modelling Workshops
In June 2020 Deputy Director of Greater Cambridge Shared Planning, Paul Frainer, writing to the FeCRA Committee, said:
‘Ahead of and separate to the Local Plan process, the Local Nature Partnership (as a separate body albeit with some local authority input) has identified priority projects it would support if funding were to become available in the short term, but no decisions have been made through the Local Plan process about which green spaces to prioritise.

The Local Plan green space evidence base study will identify priority projects, and will advise which should be included in the Local Plan, and which should be delivered through land management as opposed to development processes. This priority list will in future also inform biodiversity net gain offsetting, and bids for funding from other sources’.

The minutes for the June 2020 Natural Cambridgeshire board meeting states that the board will:
• ‘Work with developers to enhance nature either on site or through offsets’ –Cameron Adams, the Environment Agency
• ‘Consider how best to engage with farmers and other landowners, and help them get better returns from their investments’ –Rob Wise NFU
• ‘Collaborate with Natural Capital East’ –Cameron Adams
• ‘Review progress of Doubling Nature at end 2020’ –Richard Astle - Athene Communications
On 26 July 2020 the FeCRA Committee wrote to MPs, copied to the planners and Lead Councillors to express concern about the Greater Cambridge Green Infrastructure Online Survey - 27 July which had been framed again in a way that excluded residents from having a say, particularly about the river and its historic environment. They asked why this survey was linked to funding bids, S106 development sites and future parks accelerator plans and why there had been no assessment of impacts and issues arising from current and already approved growth on green spaces at this stage?

“Why is there no engagement with strategic environmental capacity issues as a vital part of the evidence base for the new Plan?” The Committee pointed out that the government’s plan for sustaining high growth and building one million houses in the OxCamArc is underpinned by Natural Cambridgeshire’s vision for “doubling local nature”, with urban fringe parks in the green belt. Plans for ‘linear river parks’ feature in council and development plans but there had been no consultation with friends or river groups or local councillors.

The River Cam is the only river in the country that is not back to normal flows, yet exponential growth fuels huge pressure upon our natural water supplies. Concerns about the impact of over-abstraction on the River Cam have been expressed but large development keeps getting approved.

Stage 3 of this Local Plan Green infrastructure consultation featured technical workshops, themed around the benefits that green infrastructure provides, to discuss the issues and opportunities arising from the survey responses.

Community reps and residents who had not been able to engage with this survey or who didn’t have funding bids with developers and NGO’s were not able to get a say at the next stage.

This letter followed concerns expressed to Greater Cambs Planners and Cllrs Katie Thornburrow and Bridget Smith that many residents had not been able to access the on line Green Infrastructure consultation hub and the inaccuracy of the mapping and data, highlighted by experienced university conservationists.

Addressing the challenges of climate change and health, social equality and quality of life benefits from local knowledge and the involvement of residents who know about water, flooding, wildlife and nature and managing green spaces and local resources in their areas, working with their elected councillors. Residents say that decisions about land use and ecology have been made by business and interest groups without local knowledge or accountability

The inspirational town planner Jan Gehl advocates that to build communities that work well where people, not cars, occupy the pavement, the evidence needs to be shown and environmental capacity issues need to be addressed. One should count all the pedestrians, cyclists and strollers going by, just as highway planners have long tallied up road users in vehicles and the number of people using the river and its green spaces.
Where is the evidence that this has been done in the Draft Local Plan? It has not been demonstrated that there is sufficient water supply within Greater Cambridge to support future development and existing ground water abstraction is impacting water flows within chalk streams in the region anday need to be reduced, especially in the light of climate change.

The situation with groundwater around Cambridge is critical: the whole Cam river system is in crisis
Using water more efficiently is important, but efficiency will not increase the maximum volume of water that can be supplied on a sustainable basis without impacting the environment.

As such REFUSAL of developments is necessary where there is no available water to supply them and/or the environmental impacts caused from supplying that water outweigh benefits of the grant of that permission.
A similar point applies to discharge, especially where this is to groundwater. Where a European site is affected, alternative locations and OROPI ( Overriding Reasons of Public Interest ) may need to be considered prior to any planning decision.

NPPF para 7 makes this point: "The purpose of the planning system is to contribute to the achievement of sustainable development. At a very high level, the objective of sustainable development can be summarised as meeting the needs of the present without compromising the ability of future generations to meet their own needs. "

The presumption in favour of sustainable development cannot be determined without sufficient information on the water demands of a development, how these will be met and the implications for the environment and future generations.

We strongly suggest that all planning applications should at application stage confirm their total required annual water usage and have accompanying documentation to confirm that such water can be supplied and discharged where applicable in a manner.

We suggest that all developments are subject to Habitat Regulations Assessment based on their cumulative and in-combination impacts on the available water supply.

Biodiversity
Conservation is essential to sustainable development and together with enhancement of biodiversity should be considered as a key element of good planning and design. 'Doubling nature', Biodiversity Net Gain (BNG) and Natural Capital Accounting (NCA) are being used as bargaining chips by developers. That broadly amounts to saying, 'No development means no funding for nature'. This is the antithesis of John Lawton's 2010 plea in 'Making Space for Nature' of significant funding for Nature conservation without any strings attached.
The concept of doubling nature is ill-defined - doubling what, exactly? The Draft Local Plan needs to define exactly how the concept will be understood and measured.

The global experience of Biodiversity Net Gain, reviewed by zu Ermgassen of DICE, University of Kent, is that it fails twice as often as it succeeds, even though it had the lower bar of No Net Loss, NNL rather than BNG.
The same group more recently showed that 95% of early-adopters of BNG practices in England are carrying out on site offsetting (something not covered at all in the new Environment Law), where the developer is the judge, jury and executioner of any offsetting plans. In any case, on site offsetting will not encourage many forms of wildlife and will be prone to the dog-fouling and trampling that harms many wildlife areas, even those remote from housing. Meanwhile, off-site off-setting is already damaging local communities in some rural areas.
Natural Capital Accounting is an untested concept. The monetary assessment of ecosystem services (the 'yields') is recognised as being inadequate at present, while assessing the monetary value of ecosystem stocks is more or less impossible (Ian Bateman, communicated to David Rogers). Yet the resulting monetary assessments may be used to trade away environmental for economic assets with a greater yield, for example a factory in a water meadow.

The natural environment is our vital life support system, and it is a dangerous delusion to imagine that it can be rendered easily into any economic framework, let alone the pre Dasgupta framework that gives GDP/GVA primacy over all other forms of stocks and yields.
Dasgupta defines wealth as the sum of natural, human and economic capitals and yields, and sustainability as the condition where this sum is either stable or increasing. Economic growth at the expense of natural capital and yields is therefore unsustainable.
We request that the Cambridge Local Plan adopts the Dasgupta definition of sustainability, i.e. definitely not the NPPF's false definition of 'sustainability', with the caveats mentioned above, especially the false or under-valuation of natural capital. This would provide a better starting point, and the Plan should be reworked in this context.

Sea level rise
Large areas of Cambridgeshire, including parts of the City of Cambridge, are subject to continuously increasing flood risk. Indeed, not only is sea level rising, the rate of sea level rise is increasing rapidly. For many years, since measurement began, sea level in the Wash was rising at a rate of 3mm per year. In 2019 it was measured by the Environment Agency in the Wash, and confirmed by IPCC figures globally, that the annual rate was now 3.3mm per year. In 2014, the IPCC report estimated a sea level rise of 1 metre by 2100. In 2019, the IPCC increased this estimate to 1.1 metres by 2100. In 2021, the IPCC has increased its estimate again, to a terrifying 2.4 metres by 2100. Meanwhile, the meteorological partnership Climate Central estimates a 4.7 metre sea level rise by 2100 if global temperatures rise by 2°C. Both the IPCC 2021 and the COP26 leadership have confirmed that the world is currently on track for a 2.4°C global temperature rise.

The other solution to Cambridgeshire’s water shortages being proposed by Water Resources East and Anglian Water is to build two reservoirs in the Fens, one in South Lincolnshire, the other in Cambridgeshire near the River Great Ouse. However, there is little point in building reservoirs in the Fens when it is clear that there is a high risk they will be flooded by saline water within decades.
As flood risk increases, the Fens will initially be subject to occasional and then annual flooding caused by water in its tidal rivers meeting increased volume of run-off from development. Eventually, the tidal inflow will prevail and flooding will become permanent as the sea level inexorably increases. However, even the first stage will have a significant negative effect on agriculture. The Treasury Green Book assumes loss of cropping for one year if sea water inundation occurs. In fact, as was found in the 1947 and 1953 floods, reduced crop yields last up to seven years due to the presence of a nematode in sea water.

Climate Change
We support regular reviews to keep pace with developing technology, standards, Government targets (e.g. the Heat and Buildings Strategy, not mentioned in the draft Plan) and rapidly developing guidance and best practice. There are also serious quality control challenges in relation to whether aspirational aims are actually delivered. Outline planning permissions must be subject to the aspirations articulated in the Draft Local Plan.

How will this be done?
The definition of a Net Zero Carbon building set out in the evidence Base does not include its embodied carbon: this is a very serious omission which undermines all claims made about the sustainability of new development, and raises questions about the claimed sustainability credentials of all the Growth options being proposed.

Projects proposed to help achieve net zero need to be both delivered and safeguarded throughout the Plan period, to ensure that the aims are delivered (e.g. need to ensure that biodiversity / natural capital / “doubling nature” ( sic) and any other such schemes are protected from subsequent inappropriate changes of use or management)

For all of these reasons we strongly object to the level of growth proposed in the new Draft Local Plan
Local government should not be planning more economic and population growth in this area or more housing than current government targets require, but prioritising social housing and new water infrastructure to reduce stress on our rivers and wildlife. It should be supporting the national ‘levelling up’ policy. It should be consistent with the government’s ‘brownfield first’ objective which will deliver badly needed homes faster. It should take into account the growing flood risk to large parts of the county and consequences for national food supply. It also needs to take into account the as yet, unknown, long-term effects on employment and travel behaviours of the COVID pandemic.

We request that this flawed Draft LP is rejected, re-written and re-submitted for full public consultation.

The quality of life in our world does not depend on the conflicts that arise, but on our response to them.
Widad Akrawi

If you don't set a baseline standard for what you'll accept in life, you'll find it's easy to slip into behaviours and attitudes or a quality of life that's far below what you deserve.
Tony Robbins

THERE IS NO BASELINE ON OUR STREETS AS TO WHAT IS ACCEPTABLE BEHAVIOURS AND WHEN CONFLICT ARISES THERE IS NOT A ROBUST PROACTIVE RESPONSE THAT SUPPORTS THIS COMMUNITY JUST A REACTIVE REPONSE IF THE COMMUNITY COMPLAINS AND EVEN THEN SOME ISSUES TAKE YEARS

RARA WANT A PAM

The previous expansion of the cAMBRIDGE Biomedical Campus and Addenbrooke's/Rosie/Papworth has impacted negatively on the surrounding communities, CBC are still not able to manage the consequences of the unintended consequences of their growth and policies/procedure. How can they expand without robust

PREVENTION

E.g. some examples Signage direct footfall/vehicles away from RedCross Areas, module filters slowing through traffic, modale filers signage no motorbikes into CBC through cycle path same Greenlands to Ninewells, take Red Cross Lane off CBC/Hospital maps, add P&R with cycle route into CBC site, move cycle path around Ninewells so it does not direct traffic through Greenlands which was a cul-de-sac only has 32 houses only 4 road side taking thousands passing by weekly 24/7, letters to patients/staff/contractors /visitors no waiting or parking in RedCross Area

ACTION

E.g some examples Funding, staffing to be community rangers identifying and resolving issues weekly on the ground, resources, on a regular basis not a one off as issues are dealt with by the community they subside just to erupt 2-3 weeks later the onus must change from community complaints to get action for CBC to stop negative impacts on the communities surrounding it as it expands exponentially and out of proportion to the community it sits within


MONITORING

E.g. some examples APR camera on CBC cycle path to Red Cross Lane, CCTV down RCL and Greenlands

Cambridge Biomedical Campus Vision 2021 – 2051 - Partnership with RedCross Areas Vision for Safer Streets Now in 2021
i. CBC VISION 2021 - 2051
The RedCross Areas Residents Association (RARA) welcome the Cambridge Biomedical Campus Vision 2021 - 2051 and developments in terms of job opportunities, research and health care – welcoming the open and collaborative approach outlined in your Vision. With this in mind RARA would like to open a channel of communication to the benefit of all parties. CBC states is a globally important life sciences engine, and has come together to demonstrate its commitment to Cambridge through a new Vision for its campus, renewing its role in the city and beyond. We hope this extends to accountability for the staff and users of the site to ensure the emotional well-being and safety of their near neighbours living in residential communities on all sides surrounding their site.

ii. GROWTH OF CBC
From 1967 the site has developed alongside the building of homes on the three streets Red Cross Lane, Stansgate Avenue and Greenlands, making up RedCross Areas, and over the last 21 years Addenbrooke’s and the Cambridge Biomedical Campus has expanded exponentially. The history of this has appeared to the outsider as piecemeal at best and as insular at its worst – witnessing the haphazard development of Addenbrooke's site by its immediate neighbours. This approach and model has not kept pace with today's thinking particularly in context of green agendas, sustainability, air quality/pollution/noise and travel/connectivity. The insularity of approach has been particularly felt in a negative way in the local residential community that abuts the site. Until very recently thanks to the work of a young new resident with the NHS CE Team the needs and legitimate aspirations of local people for a safe environment has been compromised by the unchecked growth of Addenbrooke’s and the Cambridge Biomedical site.

Iii. ADDENBROOKE’S SMOKING POLICY & UNINTENDED CONSEQUENCES
For example, as attitudes and health issues particularly smoking have changed, Addenbrooke’s response has been short sighted in its interpretations. Because the needs of the local community have not had sufficient consideration and weight accorded them. The unintentional consequences of the Smoking Policy has left in its wake an increase in aggressive and anti social behaviour from staff from the Cambridge Biomedical Campus in residential areas not just RedCross as you are aware from concerns raised by other near neighbours surrounding the Campus with staff who are forced off the site to smoke as provision on the campus is not adequate. It has improved since one of our younger residents identified and engaged with the NHS CE Office during 2019 and RARA connected with the NHS and 1 private Contractor in 2020. But it is now with the good weather becoming a cause of concern yet again for those neighbouring the Addenbrooke’s and Biomedical site with examples daily of smokers coming off site to smoke, sitting in private greens/communal drives/drives and sitting on and blocking pavements and road access and leaving their masks, litter and butts in their wake stating “There are not enough sites/seats on the Biomedical site”. RARA does not want to return to recruiting neighbours t put in 500 hours litter picking as they did through 2020 with additional cleans weekly by the NHS and Bell School plus community clean ups with the Council, SOS and community pay back schemes,. In 2/3 months of 2021 100 hours were put in and when CBC cars could not park when double yellow lines went down February 2021 RARA was able to stand down 8 litter pickers as litter, PPE, butts, fly tipping dropped by 90%. As the CBC staff are coming back onto RedCross Areas in May/June 2021 to illegal trail, idle, park and loiter major clean up operations have had to take place due to PPE, litter, butts and broken bottles affecting the young children who use our streets for their school run.

Cmbridge Biomedical Campus – Impact from your Smoking Policy on your neighbours
2006 -2009 “The first ban on smoking on site ran from 2006 to 2009, but was withdrawn when it was ignored”.
2014 “A smoking ban has been put in place across the Addenbrooke's Hospital site in Cambridge. From the start of 2014, people can no longer smoke anywhere on the site, whether they are inside or outside. It applies to all staff, visitors and patients”
“The Queen Elizabeth and James Paget hospitals in Norfolk also tried going smoke-free, but the ban was largely ignored. In the end, the hospitals built new smoking shelters”.
2015 “More than 11,000 people have been challenged by security staff at the Addenbrooke's site since the smoking ban was introduced just over a year ago. Eleven thousand!!”
2016 “Visitors caught lighting up are advised to put it out and directed to the nearest site boundary by the NHS” - blighting residents and your neighbours lives
The Trust said “about 400 people a month are caught smoking on the site but are “mostly visitors” rather than patients or staff”.
2019 In one week the count of smokers with NHS lanyards smoking in RedCross Areas (Red Cross Lane, Stansgate Avenue, Greenlands) was 400 & In RedCross Areas in 1 year all smokers spoken to have been staff, not just individuals but big groups blighting residents lives and blocking pavements, roads and access, dropping litter, butts. PPE and there have been many unpleasant outbursts to residents from smokers especially on Red Cross Lane resulting in NHS and Police Incident reports
2020 In one week the informal and not total count of smokers with NHS lanyards smoking in RedCross Areas (Red Cross Lane, Stansgate Avenue, Greenlands) was 600, in Greenland’s in one full day they counted 200 (so the weekly total is 600+) even sitting on private greens
(The Trust back in 2016 stated Professor Patrick Maxwell, Regius Professor of Physic, said at a 2016 board meeting “Putting up more signage would make it much easier to get to those people - we could signpost them to places to where they could smoke off site” - In 2016 Dr Mike Knapton, non- executive director, said: “Most of our smokers are visitors not patients, most who are from further away and not aware of the culture of this hospital. If in Year 1 2015 of the No Smoking Policy 11,000 were spoken to for smoking on site back in 2016 it was noted “Particularly a challenge will be in 18 months’ time when the site gets bigger. People will have to walk further to get off the site”)
In 2021 where does this massive number of people go - onto our streets blighting residents lives for over 7 years
2020/21 CE Team started work on issues which was commended by residents and this now needs a long term strategy embedding it in the Cambridge Biomedical Campus Vision
As from 2016 it has not been visitors or patients found to be smoking in RedCross Areas the majority coming into our streets areYOUR staff

iv. NHS CAR PARKING POLICY & UNINTENDED CONSEQUENCES
The same issues apply to car parking in the local area over the last 11 years, in 2014-16 the Trust RARA is informed made a total of £108,421 from parking charges whilst at he same time residents say anti social behaviours of people parking in RedCross Areas hit an all time high. As pressure on Addenbrooke’s and the Biomedical site has increased, then it has overspilled on local streets bringing with it 24 hour 7 days a week. CBC was fully aware of the pressures in Red Cross Lane as Your Transport Survey (2016) found Red Cross Lane had 165% occupancy of the on street parking with 76-100% being CBC staff (not residents). Tenants past and present informed RARA that they have had groups and other car drivers intimidate and abuse them when trying to park in the street and told in no uncertain terms that the street parking is for the NHS and they need to park on their own drives (ironically many of the tenants are NHS employees themselves and are then put at a disadvantage as they feel unable to demand their colleagues stop these behaviours and do not feel confident to be whistle blowers). This has been confirmed by long term residents of 10 – 60 years and by RARA’s own experience, with Cambridge being a small interconnected community with many of the community and near neighbours working at the CBC at all levels. RARA has had first hand, both factual and anecdotal feedback of both the Residents Association, membership, groups in the community, families and even individuals having unprofessional conduct not just by individuals but also by agents and organisations connected to or part of the CBC demonising any effort by any of these locals to challenge illegal or anti social behaviours. Very disappointing from a Global Partnership with a new Vision “..bringing together its role in Cambridge life … We want to develop CBC in a way that is inclusive rather than exclusive, and contribute to making Cambridge an even better place”.

Historically for 11 years the community has experiences incidents of aggressive and anti social behaviours, culminating in August 2019 as an ACT/Cheffins tenant was so exasperated they reported a local worker parked illegally all day on their drive to the Police and put the information on social media. From this 80% of the community over the next 6 months came forward with examples of 10 years of incidents from damaging their garages, gate posts, fences, drives, cars, car tyres, hate crime, antisocial behaviours etc. always a day after asking someone to remove themselves from parking illegally on their drives/blocking their drives or being illegally parked on Greenland’s communal drives. The worst being individuals being driven at by these illegally parked cars when they had phoned the Police to request they move. On many occasions the individual was reported to be at or admitted themselves that they worked at the Hospitals on the Cambridge Biomedical Campus. Even now when on street parking is illegal it is increasing exponentially every week. There was a recent incident where a young woman and her young child were nearly run off their bikes by a person waiting illegally in their car on double yellow lines (not a one off this individual had been parking illegally for 4 weeks running and had previously had had the new yellow lines on other roads explained) they stated they were there to pick up a Hospital staff member and were allowed to park. On this occasion they were asked if they would consider moving which they did, but being so engaged at swearing at the residents the driver did not look where they were driving. This resulted in this young girl being doubly upset as a car was coming toward them with total disregard for their safety whilst a male driver was swearing and making rude hand gestures. The community had to think carefully and decide to cancel organising a Playing Out event for children and families as the car drivers connected with the Cambridge Biomedical Campus are behaving in a way that is not enabling RedCross Areas to have Safer Streets.

CBC 2016 Travel Survey stated “demand for car parking on-site is currently significantly over-capacity …. with over 1,106 cars parked on local streets … and residential areas are seeing increasing levels of tidal traffic during the peak hours” in 2018 CBC Report which said “People travel to CBC from locations across east and south-east England and beyond”. What can be seen in May 2021 is that the Trust is seeing an additional 500 staff park on site every day. As this is not being addressed strategically the staff who do not meet the NHS eligibility parking criteria are now being forced off site. This means more negative impact on RedCross Areas where the Council Parking Enforcement are fighting a valiant daily battle to manage the tidal wave of additional cars coming in to the area to trail and park illegally. There needs to be finance from the CBC for monitoring/enforcement via CCTV, patrols daily 24/7 and enforcement/accountability for those form the CBC blighting the lives of thise that live in RedCross Areas to keep the community and those travelling through safe with a strategic vision for Safer Streets.

In the context of this history of expansion of the CBC site bringing with it problems that were not managed or mitigated for it is imperative that the latest Vision learn the lessons e.g.
If in 2018 CBC knew parking by CBC staff resulted in “Occupancy exceeding capacity on roads south of Mill Road including Red Cross Lane” with “76% - 100% non-residential parking on streets in the immediate vicinity of CBC” and “the streets surrounding CBC are dominated by non-residential parking during the morning and afternoon periods, particularly on Red Cross Lane” with no planning put in place for the 30-40% increase predicted in cars to CBC in 2019. If CBC knew from 2016 about the impacts likely on the local communities and have not been able to mitigate these over the past 5 years how can they be entrusted with a 30 year plan of expansion.

v. What’s Needed-Safer Streets
What’s Needed - Safer Streets, good public transport, more cycling provision, safe walking routes, discourage cars to trail, illegally wait, idle and park by offering adequate parking on site, adequate taxi/Private Hire Vehicle ranks on site, adequate drop off and pick up points on site for staff, visitors and patients, more smoking shelters with seating. Please have routes of accountability for staff not upholding your core values, communication regularly to promote and move car drivers and smokers away from residential areas as Red Cross Lane (would be beneficial to see if other areas are too?) as it is experiencing anti social behaviours yet again from the Biomedical and Addenbrooke’s site encroaching on their homes and safety. Finance is needed from the CBC for signage into the site for parking/drop off/taxis &PHVs, signage on roads abutting the site saying no route through to Biomedical/Addenbrooke’s/Hospitals/no trailing, waiting, idling or parking. Funding from the Biomedical site to enable the residential roads surrounding your site to have consultations/installation of requested no loading, bollards, signage, modal filters, safe cycle routes, pavements pedestrians/disabled/wheelchairs/pushchairs can use - not blocked by staff groups to embed your Vision with an Active Travel Route that does not disadvantage your neighbours with noise, pollution, littering/fly tipping, illegal idling/waiting and parking including pavement parking nd trailing cars disadvantaging the disabled/families with buggies, antisocial and behaviours that do not comply with the Governments Safer Streets.

With plans will inevitably come pressures on the local area and environment particularly in relation to transport. Potentially many thousands of extra staff on top of the 21,000 2020 and additional 5000 2021 (envisaged by CBC in 2019 to reach 41,387 on an average weekday this year 2021 before any expansion) presently will be travelling through RedCross streets to reach the CBC site. Traditionally this has been primarily by car and in 2018 your own Biomedical Campus Transport Review Part 1 and 2 report noted a 30-40% increase in car use from the CBC expansion primarily happening in 2019 and no provision was made by the CBC for this and no assistance was allocated or given to communities such as RedCross Areas that suffered significantly due to this. The current expansions have put pressure on the Biomedical / Addenbrooke’s site and historically the solutions have been for staff to flood the local residential streets in search of free, convenient parking 24 hours a day. This has resulted in anti social behaviour and dangerous driving including trailing, waiting, idling, parking on pavements blocking disabled/school run access, parking on people’s drives, blocking residents access, driving at speed, reversing, blocking junctions and parking illegally, blocking access for emergency vehicles. A person attending Addenbrooke’s recently parked illegally for half a day and was requested by the Police to move his car, when asked why he parked illegally he cited he did not wish to pay for parking on the Biomedical / Addenbrooke’s site, then became abusive to a female. Just a few weeks ago a pavement parked car had to be asked to move on Greenland’s as an ambulance was due and would not have been able to access the property of the elderly resident.

To avoid a repeat of this your Vision must take account of historical mistakes which have caused Police Incidents, illegal actions, verbal abuse, anti social behaviours and much upset among local residents over an extended period and take account of RedCross Areas being a main thoroughfare for your staff, visitors and patients. CBC report (2018) “With new developments, the demand for parking is likely to increase. Red Cross Lane – has reached 165% occupancy. So there is likely to be a deficit in the intervening period depending on the phasing of site development until 2025”. This is a projection prior to current and future 30 year Vision for further expansion. Plus in 2018 CBC identified “Both car and cycling parking levels are currently over capacity” and what has been actioned on CBC site to address this over the past 3 years as demand has grown.

Vii. GOING FOWARD
A multi agency approach is required including for example local Councillors, Community Groups, local Cycling Campaigns, local Neighbourhood Watch and Residents Associations, local residents including tenants (who traditionally have informed groups they feel insecure in their contracts and tenancies so do not feel able to raise their own issues), the Local Authority, Police, national groups with relevant expertise to name just a few as you knew in 2018 that “the likely future pinch points would continue to be Addenbrooke’s Road and Babraham Road” both of which surround RedCross Areas to take forward CBC findings of 2016 and 2018 that RedCross Areas needs “On-street parking controls”. CCTV seems the only solution as staff ignore the double yellow lines.

Poor communication that does not effectively take all parties concerns into account leads to poor planing outcomes with unintended consequences that disproportionately negatively impact on local people.

viii. RedCross Areas needs an SAE

S Safer Streets- Funding from CBC for CCTV and fund more Parking Enforcement Patrols for 24/7 monitoring/better night time lighting for nurses/night shift workers/signage to site/signage encouraging traffic away from RedCross Areas and remove loitering, littering, fly tipping and illegally waiting, idling, pavement and on street parking from RedCross Areas streets

A Accountability– Cambridge Biomedical Campus Companies taking responsibility for CCTV/ Parking Patrols/Funding - informing and managing their staff, patients, visitors, taxis, private hire vehicles with an aim to stopping illegal, anti-social, aggressive, bullying behaviours that impact adversely on health to the communities neighbouring your site

E Enforcement– CBC leading Enforcement not the community reporting illegal & anti-social actions. Routes to report/Policies/Procedures enforce (A) achieving (S)

Funding and an SAE directly from the Cambridge Biomedical Campus organisations

ix. Current CBC Organisations - UC/UCSCM/UCMS/NIHR/UAHCC/RPNHST/R(MH)/ AHNHST/CPFT /ACCI/DC/ ACT/ MRC/GSK&CPU/AZMRSR&DC/AC/CRUKCI/WT/ MRC/ LMB/H&LRI/IS/IOTAPO/CAST

Please see our first draft RedCross Areas Vision which the neighbourhood hope the CBC will sign up to work with relevant agencies to take forward and incorporate into immediate 2021 actions and future expansion plans as Girlguiding’s CEO Angela Salt OBE, Chief Guide Amanda Medler and Chair of the Board of Trustees Catherine Irwin (2021) 'Women and girls have a right to feel and be safe at all times of the day and night”. their Survey identified that “A quarter (26%) of girls aged 7 to 10 feel unsafe when they go outdoors, increasing to two in five (41%) 17 to 21 year olds. All these measure were higher for girls and young women who identify as disabled or LBGQ+”. When an illegally parked car last week at nearly midnight by a residents home is looked at by an elderly disabled 5ft woman (as a very close by neighbours home - an elderly 91 year old disabled woman her daughter and a 5 year old grand daughter who were at home - was entered by an unknown male a few days previously so naturally the community was concerned) and the woman returned to their home to be accosted by the 6ft male car driver coming out of the Biomedical Campus with clenched fists shouting at them, this does not create a Safe Street/Space and neighbourhood surrounding the Cambridge Biomedical Campus.

x. To conclude we leave you with RedCross dream for 2021 as stated nationally by Kit Malthouse MP (2021) “As Minister for Crime and Policing, I am committed to ensuring that our citizens can live comfortably in the knowledge that their communities and streets are safer and free of crime” and locally by a vision by our new Mayor Nik Johnson saying "He will encourage people to live healthier lifestyles .... and will be making a priority of compassion, cooperation and community to be at the source of all policy decisions”.

Our biggest neighbour CBC with the most impact on the health and well being of RedCross Areas and other neighbourhoods could learn from Nik's words they certainly give our and the wider communities across Cambridgeshire hope.

Cambridge Draft RedCross Areas Vision 2021 – 2051 linking to Cambridge Biomedical Campus Organisations & Their 30 Year Vision 2021 - 2051
No VISION REQUEST WHOM TO ACTION NEEDED
1
Safer Streets • More street and key area lighting, (CCTV junction with Red Cross Lane and Greenlands), pavement bollards by dropped kerbs to stop illegal driving onto pavements, no loading at junctions (Create a signposted/road marking junction at Red Cross Lane & Greenlands), stop dangerous waiting at junctions/pavement parking) for current and future nos of staff to keep roads/pavements safe for CBC staff and those that live and travel through the RedCross area, no motorbike signs cyle path into CBC and Greenlands to Ninewells
• Adequate break/smoking areas with seating on site therefore freeing up our streets for all including pedestrians/disabled/ pushchairs/ wheelchairs/cyclists etc. – for those who live here and travel through to work, visit or have treatments on the CBC
• It is intimidating using roads and pavements when unable to pass large groups of CBC/NHS staff on roads/ sitting on pavements/parked on pavements or double yellow lines 24/7
• Extend Ninewells Cycle path around Ninewells (not through it) and connect to cycle path by Helicopter pad – linking Park & Ride/Trumpington and give a Safer Active Travel Route for the increasing numbers of staff going into the Biomedical Campus
• Please for the CBC staff nearly 75% female and our community create Safer Streets
RED CROSS AREAS WANT AN SAE - Safer Streets - Accountability & Enforcement CBC/NHS/UC/Council/Councillors/Mayor/GCP/Police/Bell/Agents/Owners & Multi Agency Joined Up Working


CBC/NHS/UC

CBC/NHS/UC

CBC/NHS/UC/Council/Councillors/Mayor/GCP/Police/Bell/Agents/Owners & Multi Agency Joined Up Working
CBC/NHS/UC/Council/Councillors/Mayor/GCP/Police/Bell/Agents/Owners Multi Agency Working NOW

NOW & CBC VISION ongoing

NOW & CBC VISION ongoing

NOW & CBC VISION ongoing


NOW
2

Smoking • More smoking shelters/seating/move away shelter from Red Cross Lane/alternatively close or a gate (?one with ease of access wheelchairs/pushchairs/mobility/sight)pavement entrance to denote CBC/Addenbrooke’s (with lighting/APR) from the residential street - cycle route open
• Signs on current posts (future gates) containing message from current NHS Large Sign
• CBC / NHS Induction, continually rolling programme of monthly all staff email, monthly management/team meeting agenda item/Awareness work with the Council & pocket ashtrays
• Accountability, policies in place to monitor, manage and uphold Best Practice/Values of orgs CBC/NHS/ UC


CBC/NHS/ UC
CBC/NHS/ UC/Council

CBC/NHS/UC NOW


NOW
NOW & CBC VISION ongoing

NOW
3

Cars • Signage on entrance to RCL NO TROUGH ROUTE TO HOSPITALS/CBC – maps to site REMOVE Red Cross lane add P&R cycle path to CBC cutting out Greenlands
• Signage by No 1 RCL/Hospital site– No STAFF DROP OFF OR PICK UP/Waiting/Parking
• Fund Council consultation and installation of any agreed e.g. double yellow kerb blips, mini bollards, modal etc. to reduce dangerous &/or illegal cars waiting/parking/pavement parking
• Enough Blue Badge disabled parking by each area of the hospital so no need to park at a distance and cause those most vulnerable additional stress attending Clinics and Treatments
• Easy access pick up/drop off on site areas for staff/patients on CBC – promoted monthly
• Publicise on offer of appointment letters to staff and appointment letters to patients-visitors
• Induction, monthly all staff email, monthly management/team meeting agenda Re: RCA
• Accountability policies in place to monitor, manage and uphold Best Practice/Values of orgs CBC
CBC/NHS/UC /Council
CBC/NHS/ UC/Council/Councillors/Mayor/GCP

CBC/NHS/ UC

CBC/NHS/ UC
CBC/NHS/ UC
CBC/NHS/ UC
CBC/NHS/ UC NOW
NOW
NOW

NOW & CBC VISION ongoing

NOW
NOW & CBC VISION ongoing
NOW
NOW & CBC VISION ongoing
4
Taxis
Private Hire Vehicles Adequate Taxi Bays on CBC/for NHS etc.– Publicised and Promoted Continually no parking in RCA
Adequate Private Hire Vehicle Bays on CBC/for NHS/Patients booking them for collection – P&PC
Lets support the small business person have breaks wait for fares most coming from the CBC CBC/NHS/UC Council/Councillors/Mayor/GCP
CBC/NHS/UC Council/Councillors/Mayor/GCP NOW & CBC VISION ongoing
NOW & CBC VISION ongoing
5
Fly tipping /Littering By actioning the above and below this should decrease and have routes of accountability Accountability policies in place to monitor, manage and uphold Best Practice/Values of all orgs CBC/NHS/UC Council/Councillors/GCP/Police/Bell/Agents/Owners NOW & CBC VISION ongoing
6

Anti Social Behaviours Policies in place to monitor, manage, have accountability of agencies for anyone bringing them into disrepute/not upholding their Behaviour Policies of all orgs–onus taken away from community complaints
Process to report and gain feedback on any of the issues/those involved in the above to each agency
RARA WANTS A PAM Prevention Action Monitoring CBC/NHS/UC Police/Bell/Man & Letting Agents/ Licencing / Council / Owners & Multi Agency
CBC/NHS/UC NOW & CBC VISION ongoing

NOW
7

Infrastructure • CBC needs a Station – please stop cars using RedCross Areas as a pick up/drop off site now
• If the site infrastructure does not support expansion, power, water, cable – let neighbours know and your plans for addressing these shortfalls & impact on their neighbourhoods/lives
• Consult with the neighbours this will impact on – e.g. station, expansion, road closures/road works/ disruption/ noise/gas pipes/water pipes/sewage/digital cabling etc. etc. etc. etc. etc. CBC/NHS/ UC
CBC/NHS/UC Mayor/Council/ Councillors/ Police/ GCP/Bell/Agents/ Owners & Multi Agency

“ NOW & CBC VISION ongoing
NOW

NOW & CBC VISION ongoing

Dear Sir/Madam,

I am writing in a personal capacity to strongly object to the Draft Local Plan, and to any development on site S/CBC, 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
• flood risk to the proposed site and surrounding roads
• the site is currently Green Belt, and should stay that way
• negative impact on the Nine Wells SSSI nature reserve

I also 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

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

With reference to the Cambridge local plan, S/CBC/A which suggests a ‘Major Change’ by encroaching on 40 hectares of Green Belt to accommodate further development of the Biomedical Campus.

The local plan of 2018 has no indication of such an enormous change and these new proposals contradict your own preferences on protecting the entrance to the City and the Green Belt.

You have already allocated extra land on Dame Mary Archer Way, and that has been accepted. If more is definitely required, that area could be extended round Ninewells, which would have to be carefully landscaped, to the south, while maintaining and enhancing existing hedgerows.

If you were to develop the field to the north east, adjacent to Babraham Road and Granhams Rd. you would be completely breaking your own rules about providing a ‘Sensitive transition between the urban fringe and the open countryside’.

This field also floods regularly.
Your ambitious plans for development on that field would be completely out of keeping with gentle landscape now in place which provides some of the best views in the county. Despoiling this and suggesting that your development would ‘ improve green and natural spaces which are accessible for everyone to enjoy’ is disingenuous. This countryside, and these views are already accessible via the new cycle path, Granhams Rd. and the approach to Cambridge from the East. I’m sure more could be done to enhance accessibility and the wild life as suggested by John Meed in his compelling and scholarly research over 10 years.

Our MP, Anthony Browne, has done a lot of work on the water supply in Cambridge.
It is at a seriously low level. Surely that should influence your plans ?

You have suggested that the new proposed Cambridge South Station demands further development of the biomedical campus, but unfortunately the station design does not seem adequate for existing demands, with poor connections from town, inadequate bus connections and no Parking apart from disabled slots.

The serious delays and congestion in Cambridge have been compounded by a lack of forward planning over the last 20 years. We are not impressed and expect to see some workable, affordable, transport solutions in place before any more major building takes place. Charging people for access to Cambridge would be good for the Council but not for anyone else, and we would all like to see a real commitment from the planners for a top class transport system.

I do not see that ‘Exceptional Circumstances’ are in place to justify your local plan and the consultation since 2018 has been inadequate.

1. INTRODUCTION

1.1 This representation has been prepared by Strutt & Parker on behalf of Countryside Properties (UK) Ltd to support the promotion of land to the north-west of Balsham Road, Linton as part of the Greater Cambridge First Proposals Consultation 2021.

1.2 In September 2021 Greater Cambridge Shared Planning Service published the Greater Cambridge Housing and Economic Land Availability Assessment (HELAA), which provided an initial assessment of the sites put forward for consideration for allocation as part of the Call for Sites consultations within Greater Cambridge.

1.3 This representation provides a response to the ‘First Proposals’ Preferred Options Consultation and has been structured to respond to relevant questions as set out within the First Proposals Consultation. In addition, a detailed assessment is provided in respect of the HELAA Proforma for the site.

1.4 The HELAA excludes the Balsham Road site from allocation primarily on the basis of landscape issues, notably that the proposed development “would have substantial and unacceptable landscape and visual impacts that would not be sufficiently mitigated by the proposed landscape treatments”.

1.5 The site was submitted as part of the Call for Sites for circa 300 dwellings and a rural business park. In response to the HELAA consultation, an updated Landscape Technical Note and Opportunities and Constraints Plan has been prepared by Barton Willmore to respond to the landscape and townscape comments regarding the sensitivity of the site. As a result, it is proposed to set development back from the northern boundary and provide key landscape corridors through the site. The site is considered to have capacity for the provision for up to 300 dwellings and up to 1 hectare of employment land. The Technical Note by Barton Wilmore on the landscape and visual impact has been provided within appendix A of this response.

1.6 The Opportunities and Constraints Plan demonstrates where the most and least sensitive areas within the site are. This has been produced in conjunction with the Technical Note on landscape and visual impact and the Council’s Landscape Character Assessment (2021). This has informed a reduced developable area. The revised scheme has been set back from the north, with clear landscape corridors, to allow clear landscape views to the Grade II Listed Water Tower to be fully maintained. The proposed development area represents a logical rounding off and extension to the large Minor Rural Centre of Linton which is a well-served village with a number of existing services and facilities.

1.7 Therefore, in view of the above, it is considered that several of the assessments criteria, particularly regarding the landscape impact should be re-categorised. It has been demonstrated in the supporting information provided that the allocation of this site would not have a significant adverse impact the landscape and townscape such that the site should be considered as a suitable, achievable and deliverable site for housing and should therefore be put forward for allocation in the emerging Local Plan. Further analysis of this is set out within section 7 of this report.

1.8 In support of this report, the following documents have been prepared; • Landscape and Visual Technical Advice Note – Barton Willmore; and • Opportunities and Constraints Plan – Barton Willmore.

1.9 In addition to the above documents, where relevant reference is also made to documents prepared and submitted previously as part of earlier rounds of consultation on the Local Plan.

2. QUESTION: Do you agree that we should plan for an extra 550 homes per year, so that housing keeps up pressure with increased jobs in our area?

2.1 We agree that it is very important that housing delivery keeps up for demand for increased jobs within the area.

2.2 As part of the preparation of the emerging Greater Cambridge Local Plan, the Shared Planning Service has identified a need for 2,321 dwellings to be built per year. A significant proportion of this growth is made up of existing allocations within the Local Plan.

2.3 The initial evidence base and spatial options assessment for the emerging Local Plan, set three growth options; ‘minimum’ (40,300 dwellings - based upon standard methodology); ‘medium’ (46,200 dwellings- based upon economic forecast based upon long term historic employment) and ‘maximum’ (67,700 dwellings – based upon fast economic growth in the recent past). In view of this, the housing delivery target of 44,400 new homes over the plan period alongside 58,500 new jobs would fall between the ‘minimum ‘and ‘medium’ growth scenarios previously suggested.

2.4 The Development Strategy Topic Paper, that accompanies this consultation acknowledges that the Greater Cambridge economy is dynamic and does not readily align with national or regional forecasts for job growth. In particular, it has a world-renowned life sciences cluster which has the potential to drive growth beyond typical regional or national rates. It is also acknowledged that in the recent past employment growth within the region has been significantly higher than predicted.

2.5 Accounting for the evidence set out within the Development Strategy Topic Paper, it is not clearly justified why only 44,400 new homes and 58,500 new jobs are proposed over the plan period. It is considered that this approach should be re-visited to increase both housing and employment allocations within the Local Plan. It is considered that the delivery of housing should be significantly increased, in line with the ‘maximum’ growth forecast, to align with economic growth within the recent past. The case for maximum growth forecast is further supported by significant transport investment within the area over the plan period. This includes schemes such as East-West Rail, Cambridge South Station and the delivery of a number of Rapid Transit Routes proposed by the Greater Cambridge Partnership.

2.6 The provision for lower growth scenarios does also not appear to be consistent with the Government’s objectives for the Ox-Cam Arc as a focus for housing and employment growth with associated infrastructure

3. QUESTION: Do you agree that new development should mainly focus on sites where car travel, and therefore emissions, can be minimised?

3.1 Yes, in principle the proposal to focus development on sites where car travel can be minimised is supported. Consistent with this strategy, it is considered to be very important that some growth is delivered in the larger more sustainable villages that are located outside of the Green Belt, such as Linton. National policy is clear within paragraph 79 of the National Planning Policy Framework (NPPF) that planning policies should identify opportunities for villages to grow and thrive, especially where they will support local services. The updated NPPF (2021), also provides additional emphases on the suitability of providing significant extensions to villages, provided that they are well located and designed.

3.2 The CPIER report, which is referenced as a key document within the evidence base provides a detailed analysis regarding the potential benefits of focusing growth along key transport corridors. The proposed Cambridge South-East Transport Project (CSET), proposes significant sustainable transport improvements between Cambridge and Haverhill. This includes significantly improved public transport, including an off-road rapid transit bus route, along with significant cycleway improvements along the A1307, some of which have already been implemented. For ease of reference appendix D of this representation provides accessibility plans, prepared by Richard Jackson Partnership, which were previously submitted as part of the Issues and Options Consultation. The Accessibility Plans demonstrate the significant transport improvement measures within Linton and in between Linton and Cambridge.

3.3 In addition, Linton, benefits from being a sustainable settlement in its own right. As referred to within our previous representation at Issues and Options Stage (refer to Appendix C), Linton is the largest Minor Rural Service Centre (As defined within the adopted and emerging Local Plan) that is not situated within the Green Belt. It is also benefits from both primary and secondary education facilities and a large range of services, including shops, pubs, restaurants and community facilities.

3.4 Linton did also not receive any allocations within the 2018 Local Plan and therefore provision for additional growth as part of the Local Plan 2041 would be appropriate and assist with maintaining viability and vibrancy of the village by sustaining and enhancing rural services.

3.5 For the above reasons, it is considered that additional growth within Linton would be consistent with the objective of the Local Plan, which seeks to minimise car travel. Of the 6 sites submitted within Linton as part of the Call for Sites process, land to the north-west of Balsham Road, is considered to be a particularly sustainable and suitable site for residential development.

3.6 It is suggested that the provision for increasing the range of sites modestly to include smaller and medium sites in the rural area would provide significant benefits. For example, they could be delivered more quickly without requiring additional infrastructure, provide choice and flexibility in the housing market and secure affordable housing more immediately. This is a point recognised by the Inspector that examined the 2018 Local Plan for South Cambridgeshire as referenced within paragraph 31 of the report: “In order to arrive at a sound strategy, we consider that as a primary consideration, the Council would need to allocate more small and medium sized sites that could deliver homes in the short to medium term and help to bolster the 5-year HLS, until the Garden Communities begin to deliver housing. This would have the benefit of providing flexibility and choice in the market and the earlier provision of more affordable housing” (paragraph 114).

4. QUESTION: We feel that we should support the development of the Cambridge Biomedical Campus, with space for more healthcare facilities, research and housing. What housing, facilities or open spaces should be created around the campus?

4.1 We strongly agree that supporting the development and further expansion of Cambridge Biomedical Campus should be one of the key principles of the new Local Plan. To support this objective, it is imperative therefore that a proportion of new housing growth is located along sustainable transport corridors from the Biomedical Campus, to support the objective of the Local Plan outlined above (in section 3 of this statement), which seeks to minimise car travel.

4.2 It is also very important that the emerging Local Plan 2041 aligns housing and employment growth, with major transport schemes that are being promoted in and around Cambridge. The First Proposals provide a number of references to East-West Rail and the provision for Cambridge South Station, both of which are important new transport infrastructure projects. However, additional focus needs to be given the major infrastructure projects being promoted by the Greater Cambridge Partnership. Of particularly relevance to the Biomedical Campus expansion, is the Cambridge South East Rapid Transit Route (CSET), which is proposed to provide a rapid transit route from the Biomedical Campus to the market town of Haverhill, the majority of which will be provided as an off-road bus way route. It is considered important that substantial housing growth is provided to the south east of Cambridge along this rapid transit route, to ensure ease of access to the Biomedical Campus by sustainable transport means.

4.3 It is understood that the CSET Project has progressed significantly since the Issues and Options Consultation in 2020. It is understood that the Greater Cambridge Partnership are intending to submit a Transport for Works Order in early 2022. It is also an identified route within the current Local Transport Plan.

4.4 Linton is one of the largest settlements with South Cambridgeshire that will be served by the CSET route. Therefore, growth in this settlement would be consistent with one of the key objectives of the Local Plan, which seeks to minimise car travel by focusing growth on locations with good transport infrastructure. Linton is situated outside of the Green Belt and therefore it is considered that Linton should be the focus for growth ahead of settlements that lie within this designation such as Sawston.

5. QUESTION: What housing, jobs, facilities or open spaces do you think should be provided in and around these villages?

5.1 It is important that a range of housing, jobs and facilities are provided within larger villages as part of new allocations to allow them to thrive and remain vibrant. Countryside Properties are responsible for the promotion of land to the north-west of Balsham Road, Linton and have a track record of delivering high quality housing developments, which provide a mix of dwellings and tenures to meet objectively assessed housing needs. Countryside Properties are fully committed, to engagement with the Greater Cambridge Shared Planning Service and Linton Parish Council regarding the mix and type of housing to be delivered on land to the north-west of Balsham Road. The proposals also include the provision for the delivery of a substantial area of public open space with associated landscaping and Countryside Properties are flexible on the proposed use of this open space.

5.2 The submission of the site, also includes the provision for a Rural Business Centre of up to 1 hectare in size. This Rural Business Centre has the ability to ensure that jobs are provided within the application site and to support smaller start-up businesses within the local area. This further strengthens the sustainability case for development of this site.

5.3 It should however be noted that Linton is strategically well located to provide housing growth in close proximity to large employment generators and jobs such as the Genome Campus, Granta Park, Haverhill, the Biomedical Campus as demonstrated by the attached accessibility plan, prepared by Richard Jackson Partnership, that is provided within Appendix D.

6. QUESTION: Are there any sites which you think should be developed for housing or business use, which we haven’t got on our map so far?

6.1 Yes, land to the north-west of Balsham Road, Linton should be allocated for development and would be a sound allocation as part of the emerging Local Plan being brought forward by a housebuilder that has a good track record for delivery. Countryside is a leading national housebuilder and has established a strong reputation for delivering high-quality mixed-tenure housing developments and award-winning places to live and are committed to delivering a landscape led development at Balsham Road, Linton.

6.2 The land to the north-west of Balsham Road, Linton is being promoted for a residential-led mixed use development which comprises an employment area. The proposals consist of up to 300 dwellings and a rural business centre of up to 1 hectare in size.

6.3 Having reviewed the settlement morphology, the area of proposed built form is now concentrated away from the northern boundary, thereby extending the village in such a way that respects the more sensitive landscape views in the northern part of the site.

6.4 The proposed development is focussed towards the south of the site which is the least visible from the surrounding landscape, and will comprise of up to 300 dwellings. To the east the site is well screened by the existing scrap yard and structural vegetation.

6.5 Medium to long distant views are available of only the northern parts of the site and as such these areas are proposed as open green space, in order to protect the character of the rolling Chalkland, as well as views of the listed Rivey Hill Water Tower, as a prominent feature on the horizon above Linton, as seen from the landscape to the south, which is identified in the Greater Cambridge Landscape Character Assessment.

6.6 The opportunity and constraints plan also allows provision for clear views to the water tower, along green corridors within the site. This will also help protect views of the water tower to the north. The aim of integrating the settlement with the rural landscape is also furthered by the inclusion of lower density housing towards the northern parts of the area proposed for development, forming an outward-facing, transitional porous settlement edge.

6.7 Structural vegetation is proposed along the western extents of the southern boundary, in order to provide a buffer between the proposed development and the existing housing to the south, as well as the western boundary in order to reinforce and strengthen the existing vegetated buffer to the bridleway. Further structural vegetation is proposed along the northern boundary, following the natural contours of the land form in order to soften the artificially straight line of the hedgerow that cuts across the landscape. Belts of structural 10 vegetation running broadly east/west more centrally within the site similarly follow the existing contours in order to soften the proposed development and integrate it within the surrounding rural landscape - see The Landscape and Visual Opportunities and Constraints plan (LN-LP-04 Rev A).

4. QUESTION: We feel that we should support the development of the Cambridge Biomedical Campus, with space for more healthcare facilities, research and housing. What housing, facilities or open spaces should be created around the campus?

4.1 We strongly agree that supporting the development and further expansion of Cambridge Biomedical Campus should be one of the key principles of the new local plan. To support this objective, it is imperative therefore that new housing growth is located along sustainable transport corridors from the Biomedical Campus, to support the objective of the local plan outlined above (in section 3 of this statement), which seeks to minimise car travel.

4.2 It is also very important that the emerging Local Plan 2041 aligns housing and employment growth, with major transport schemes that are being promoted in and around Cambridge. The First Proposals provide a number of references to East- West Rail and the provision for Cambridge South Station, both of which are important new transport infrastructure projects. Of particularly relevance to the Biomedical Campus expansion, is the Cambridge South Station which is the subject of a Transport for Works Order which is currently under consideration by the Secretary of State. Once built the Cambridge South Station would create a high-speed sustainable transport link between the Biomedical Campus and Meldreth Station. It is considered important that substantial housing growth is provided to the south-west of Cambridge, with access to the railway, to ensure ease of access to the Biomedical Campus by sustainable transport means. Therefore, growth in Melbourn would be consistent with one of the key objectives of the Local Plan, which seeks to minimise car travel by focusing growth on locations with good transport infrastructure.

We agree that supporting the development and further expansion of Cambridge Biomedical Campus should be one of the key principles of the new local plan. To support this objective, it is imperative therefore that new housing growth is located within areas that are accessible to the Biomedical Campus. In this regard Orwell is within ease of commuting distance to the Biomedical Campus, with ease of access from the south- west side of Cambridge. Orwell also benefits from good transport connectivity to the proposed Cambridge South Station on the Biomedical Campus, via Shepreth, which is a short cycle from Orwell.

It is also very important that the emerging Local Plan 2041 aligns housing and employment growth, with major transport schemes that are being promoted in and around Cambridge. The First Proposals provide a number of references to East- West Rail and the provision for Cambridge South Station, both of which are important new transport infrastructure projects. It is considered important that substantial housing growth is provided within the villages to the south east of Cambridge which will benefit from these new transport links and will ensure ease of access to the Biomedical Campus by sustainable transport means.

QUESTION: We feel that we should support the development of the Cambridge Biomedical Campus, with space for more healthcare facilities, research and housing. What housing, facilities or open spaces should be created around the campus?
We strongly agree that supporting the development and further expansion of Cambridge Biomedical Campus should be one of the key principles of the new local plan. To support this objective, it is imperative that new housing growth is located in areas with sustainable transport links to the Campus.
The site is within half an hour cycling distance of the Campus and bus links are also available. It is considered important that substantial housing growth is provided in close proximity to the Biomedical Campus to support its growth and so it can be accessed by sustainable transport means. Therefore, growth in Girton would be consistent with one of the key objectives of the Local Plan, which seeks to minimise car travel by focusing growth on locations with good transport infrastructure.

QUESTION: We feel that we should support the development of the Cambridge Biomedical Campus, with space for more healthcare facilities, research and housing. What housing, facilities or open spaces should be created around the campus?
We strongly agree that supporting the development and further expansion of Cambridge Biomedical Campus should be one of the key principles of the new local plan. To support this objective, it is imperative that new housing growth is located in areas with sustainable transport links to the campus.
The site is within half an hour cycling distance of the campus and bus links are also available. It is considered important that substantial housing growth is provided in close proximity to the Biomedical Campus to support its growth and so it can be accessed by sustainable transport means. Therefore, growth in Impington would be consistent with one of the key objectives of the Local Plan, which seeks to minimise car travel by focusing growth on locations with good transport infrastructure.

Cambridge Biomedical Campus
In line with our overall comments on the scale of growth planned for Greater Cambridge, we do not support the expansion of the campus. A priority for us in this area is the protection of Nine Wells nature reserve, including indirect impacts from development adjacent to the site itself.