S/RSC: Village allocations in the rural southern cluster

Grosvenor's new proposal at Whittlesford would provide 300 Net Zero homes early in the plan period. The representation and appendices describe and illustrate a sustainable addition to the Village. Appendix 1 shows how the site can be integrated with the village, and provide a new woodland edge to the settlement. A network of greenspaces would be created which would provide an alternative sustainable cycle/ footpath route connecting the two parts of the village. The creation of a woodland edge would form a long-term defensible boundary of the GB. Appendix3 concludes that the proposals would secure a Net Gain in Biodiversity.

Having attended the Drop In provided by the Shared Planning team, holding a joint public meeting with Stapleford Parish Council, GSPC and the residents of both villages, residents have strong feelings on this development which are listed as follows:
• With there only being an allocation of 100 houses, it does not need to take a further 6 hectares from the greenbelt. This should remain greenbelt under all circumstances as it does not meet the requirements of the ‘exceptional circumstances’ of the NPPF.
• The Planning Authority is basing the allocation on the promise of transport initiatives which have not yet been approved, or in some cases, even entered a planning application stage such as CSET.
• There is one access point to this development. With the Highways calculation of 4.5 vehicle movements per day, per dwelling, this is an increase of 450 vehicles onto Mingle Lane every day. This will increase the traffic congestion and pollution already experienced by Great Shelford and Stapleford due to the traffic in the villages already.
• The affordability of houses in the area is already an issue for our local children who wish to stay in the area. The Parish Council cannot see how any of these dwellings would be truly affordable and will instead become homes for those commuting to Cambridge, London, etc.

The land between Hinton Way and Mingle Lane, Great Shelford is not suitable for 100 new homes. Not only is this greenbelt land (once it's gone, it's gone), the roads near the Hinton Way level crossing get chaotically congested at peak travel times due to the length of time that the crossing is shut. If the queue length increases, and more cars want to turn right onto Mingle Lane, there is a danger that traffic will sieze up over the crossing, leading to an accident.

In Fig. 33, the land between Hinton Way and Mingle Lane, Great Shelford (Policy S/RSC site HW) is marked in orange as an existing site when it should be purple as a proposed new site allocation.

In Fig. 36, the land between Hinton Way and Mingle Lane, Great Shelford (Policy S/RSC site HW) is marked in orange as an existing site when it should be purple as a proposed new site allocation.

I do not accept this new housing allocation, even with your proposed constraints.
1. 100 homes are too small a housing target to justify Green Belt release and is insignificant in relation to your overall housing needs assessment.
2. Great Shelford generates significant housing windfall. See, for example, the continuing sequence of planning applications along Cambridge Road and Hinton Way. If this trend continues, as is likely, the number of new homes will almost certainly exceed 100 over the plan period of 2020-2014.
3. If only 100 homes are allowed on a 10 hectare site, prices per home will be high to justify the developer's costs.
4. A developer will push for more than one vehicular access in order to build more homes, which will increase the damage to the Green Belt.
5. I am not clear where the vehicular access is. If it is into Hinton Way, the road is already a significant bottleneck in peak hours and it is doubtful if the route can handle the additional traffic load. Increase of traffic in Mingle Lane will significantly reduce the amenity value of the existing houses, even with a 20 mph speed limit.
6. Development is incompatible with your Policy J/AL Protecting the best agricultural land.
7. The connectivity of the site is not enormous and will be seriously reduced if, as is likely, Cambridge South Station becomes an origin station, as opposed to a destination one
8. If the present proposals for East West Rail materialise, they are likely to diminish access to Cambridge and the Cambridge Biomedical Campus from Shelford station.
9. The route currently proposed for Cambridge Southeast Busway does not provide reasonable access from Great Shelford and should be discounted. The Busway is also incompatible with your Policy J/AL Protecting the best agricultural land.

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 writing to you and your cohorts on behalf of myself and other less able impacted village residents who are very surprised and concerned that land within Great Shelford and Stapleford may be allocated for housing development within another new Local Plan.

My family and I personally have been residents of Hinton Way since 2001. We have lived and worked a couple of yards from the meadow grassland within the proposed area and it has been a constant joy. This land has been lightly grazed and/or left fallow for decades, and as a result has built up significantly diverse flora and fauna, many of which are listed as having a UK conservation status of red, and as meadow have one of the highest nature ratings in the European Monitoring of Biodiversity in Agricultural Landscapes (EMBAL) Survey Manual 2017. To wilfully include the meadow in a plan but only include a tiny fraction of what is a huge swathe of heavily used agricultural land with between very low and rather low nature value suggests that the plan must be ill-conceived, and it certainly goes against the local planning mantra that supporting biodiversity is at its core. As a keen naturalist, I have record of a huge variety of mammals, birds, reptiles and insects that inhabit the fields, and I would very much like to see the biodiversity surveys undertaken that form the reasoning behind destroying the meadow and its inhabitants as part of this proposal, and look forward to receiving detailed guidance on this matter.

Aside from the environmental damage this plan will cause, the Green Belt that is under attack has already been considered and dismissed as unsuitable for development in the 2018 Local Plan. May I remind you of some of the previous reasons and comment that a smaller site than the one previously proposed would not mitigate against the following issues:
1. Adverse impact on the Green Belt that will change the linear character of this area of the village, resulting in backland development and encroachment into the transitional area of the fields that provide a softer edge of the village.
2. Development of the site is likely to have an adverse effect on the adjoining Conservation Area due to intensification to create a vehicular entrance.
3. Significant adverse impact on the landscape and townscape of the area, due to considerable encroachment of the built development into the strongly rolling chalk hills rising from the village edge, with a development contrary to the ribbon development character of this part of the village.
4. There is a great deal of local opposition to development of the site.
5. The site is not well located to local services and facilities.

In support of these findings, your own Greater Cambridge Green Belt Assessment (GCGBA) report states:
1. The purpose of Green Belt is to "prevent communities merging into one", preserve "landscape that retains a strong rural character", "prevent further coalescence of settlements" and "prevent communities in the environs of Cambridge from merging into one another".
This proposed development lies exactly on the boundary between the parishes of Great Shelford and Stapleford, and will clearly contribute to the merging of the two villages into one continuous settlement - one of the many reasons why the land was rejected in 2018.
1. "The more fragile the gap the larger the potential contribution of any intervening open land".
The proposed busway at the top of the neighbouring fields must be considered when assessing this land for suitability, as if the busway is built the value of the intervening fields in distinguishing the edge of the settlements will be further increased. Similarly, were the proposed housing allocation permitted this would weaken the argument for maintaining this boundary of fields.
Please also note that as the previously rejected retirement village on the rolling chalk hills has gone to appeal, the case for reversing the prior rejection will only be strengthened if the council advocates building housing in a contiguous field.
There is no mention of either the busway, or the proposed retirement village in the Local Plan report, yet the draft Local Plan discusses both proposals of East-West Rail and the Cambridge South Station.
1. The impact of development should consider the "degree of activity from the development (e.g. by traffic generation)".
100 houses will contribute a significant increase in traffic (potentially >200 cars), in an already congested area. The houses are very likely to be sold at a premium by the developers with new residents attracted to Cambridge's many private schools which they will access for drop off/pick up by car, further exacerbating the congestion problems in the village.

Additional to the GCGBA, we do not understand the motivation behind looking at this site again and are very concerned about the responses received from the Planning Officer when questioned about this:
1. "We need to explore development needs and opportunities afresh for each plan review, and consider what is the appropriate development strategy".
This is not relevant as there must be "exceptional circumstances" for release of Green Belt land. Those are not exceptional circumstances as has been proven in case law (Gallagher Homes Ltd v Solihull Borough Council [2014] EWHC 1283, finding "Preparing a new local plan is not, of itself, an exceptional circumstance justifying alteration to a green belt boundary").
1. "Development will impact on Green Belt purposes".
Your own Greater Cambridge Green Belt Assessment (GCGBA) report states the impact on Green Belt of use of this parcel of land as 'Moderate-High', and the 2018 Local Plan noted that due to release of Green Belt land for the current adopted plan, the value of remaining Green Belt is increased.
1. "The site included in the First Proposals is at a rural centre which has a range of services."
Shelford and Staplefords services are already recognised to be stretched and over-subscribed, problems that would only be exacerbated by the proposed large development.
1. "Access to the south provides suitable access to serve the number of dwellings proposed".
This appears to be founded on the Fire Authority assessment, that requires a development of greater than 100 houses to have two access points even though suitability for fire access does not equate to suitable access. As your own surveys will be well aware, Mingle Lane is a narrow 20 mph restricted lane and accessed either through particularly tight roads through the conservation area, or from Hinton Way, and is not suitable for any more houses and resultant traffic. Furthermore, the significant traffic increase onto Hinton Way will exacerbate congestion issues from vehicles queuing for the railway crossing, which now regularly reach up past the proposed land boundary behind Hinton Way.
1. "The site provides an opportunity for rounding off and creation of a new village edge".
This is possibly the most illuminating comment, as we regard it as more suited to a developer than a planning officer. It is clear that there is obviously considerable financial benefit to developers from building on this site with it being in one of the more sought after villages near to Cambridge, and rounding off village edges is not relevant to local interests when the development looks to build upon long standing grasslands and Green Belt.

As far we can establish from the very limited information provided, the sole new circumstance that might warrant re-assessment of this land is the vague statement that the development will benefit from Cambridge South station and East West Rail, neither of which are based on fact. As you must be aware, there will be no benefit to Shelford or Stapleford from either of these rail projects:
1. Few are ever likely to use the Shelford station to commute to Cambridge South. Existing residents working in that area either cycle or drive as the time lost walking to the station and getting there early enough to cross the line in case the barriers go down beforehand, then walk at the other end, plus the cost for such a short journey does not appeal to many at all.
2. The East West Rail project will not stop in Shelford, and has only adverse impact on the village due to the associated construction/development work and additional rumbling heavy goods noise.

We are not alone in this concern, as when reviewing the public responses to your own consultation we note that:
1. 65% of respondents say 'No' to removal of land from Green Belt.
2. 48% say to keep the current approach (i.e. the 2018 Local Plan) to housing numbers, with 24% saying they should be further restricted.
3. Only 14% thought Green Belt at the edge of Cambridge should be used.

It is of huge local and environmental importance that the above issues are fully taken into consideration, and this flawed decision is not arbitrarily waved through to consultation. As residents, there are a number of questions that the Planning Officers must answer, including:
1. What is the new 'exceptional circumstance' required by planning law to reassess this area?
2. How have you assessed the poor quality access to this site?
3. How has the proposed bus-way and retirement village been factored into the Green Belt release assessment?
4. How have you modelled your suggestion that residents will use East-West rail and the Cambridge South Station?
5. What is the assessment of impact on local services (e.g. schooling, GPs etc)?
6. What is the environmental impact of building over long term bio-diverse grassland?

This endless and continual re-opening of the question of developing this land is of considerable stress to local residents which is why there is a legal barrier to such actions, which appear to have been bypassed in this case. It would be sensible to remove this proposal from the draft local plan prior to consultation, as it is only likely to cause considerable future legal hold-up. It is also worth observing that the allocation of 100 houses is insignificant to the full Local Plan at only 0.2% of the 49,000 total planned, and destroying the biodiverse meadow would be even less.

We look forward to your full response to our questions, and as our council representatives hope for a strong voice opposing this development, for the reasons outlined above.

Barrington Parish Council (BPC) is pleased to have the opportunity to respond to the Greater Cambridge (GCP) Local Plan First Proposals (FP).

1. Overall
1.1. BPC supports the FP development strategy in general terms and supports the principles of plan-led, sustainable development that underpin the FP. BP also supports the general themes of responding to climate change, biodiversity and green spaces, well-being and social inclusion, and great places.

1.2. The wording of many of the proposed policies is incomplete and as always, the devil is in the detail - especially regarding Jobs, Homes and Infrastructure which have the greatest potential impact on the quality of the local environment. BPC is of the view that while these issues are obviously central to any Development Plan, mitigating potentially detrimental effects on rural communities in South Cambridgeshire needs to be managed through effective, carefully worded policies in the Plan.

1.3. BPC particularly welcomes the recognition of and need for reinforcement of the distinctive character of South Cambridgeshire villages.

1.4. However, BPC wishes to make some general strategic and some specific comments as follows.

2. Strategic Issues
2.1. The 2018 Local Plan for South Cambridgeshire is to be succeeded by a Local Plan for a much wider constituency developed by a Partnership for “Greater Cambridge”. This inevitably creates tensions between the interests of the city and those of the surrounding, primarily rural areas. It has to be acknowledged that development pressures in and from the city of Cambridge have significant effects upon the surrounding areas and not all of these are positive and beneficial.

2.2. The First Proposals also seek to support both the Oxford Cambridge Arc Spatial Framework and the proposed East West Rail connection - both of which introduce additional development pressures and significant environmental impacts upon South Cambridgeshire.

2.3. The First Proposals are therefore in a key sense no longer for a “Local” Development Plan but in effect have been transformed into a Regional Development Plan where the local interests and concerns of villages such as Barrington lie at the bottom of the hierarchy of interest and control.

2.4. Policy S/DS. BPC has already placed on record and wishes to re-state its fundamental opposition to both the Oxford Cambridge Arc Spatial Framework and the proposed East West Rail southern route into Cambridge. BPC has concerns that these may lead to central government-imposed rather than locally-agreed development in South Cambridgeshire which will be highly detrimental to the area.

3. Specific Matters
3.1. Policy S/DS BPC agrees that brownfield development should be prioritised and in locally - agreed not nationally targeted locations. Development “around” the villages is not considered sustainable.

3.2. Policy S/SH. BPC supports the retention of the settlement hierarchy, and the definition of Group Villages should be retained as proposed from the 2018 Local Plan, possibly reinforced with stronger wording to restrict exceptional development of up to 15 dwellings only on brownfield sites.

3.3. Policy S/ JH. BPC has concerns about the notion of “Windfall Development”. Either we have a Development Plan or not – the notion of “unplanned” “windfall” or “opportunistic” development – especially if it were to be determined by officers as opposed to councillors – is not compatible with “plan-led development”. The opening the door to opportunistic applications that run counter to the direction of the Development Plan.

3.4. Policy GP/GB. Similarly, BPC opposes development intrusion into the Green Belt. Development “creep” – even for “nationally significant” development should be resisted.

3.5. Policy S/SRC. BPC is concerned about the definition and implications of the “Rural Southern Cluster” and this requires much more detailed elucidation, explanation and justification.

3.6. Policy WS/CF. BPC believes that Community Healthcare facilities should be prioritised as they have been poorly provided for under the current Plan. Much stronger policy definition is required.

3.7. Policy CC/WE. The FP recognise that availability of water resources is a major issue in Greater Cambridge and that the level of growth has significant constraints with regards to water supply. BPC shares these concerns. Policy should address this issue more comprehensively.

4. The Consultation Process
4.1. BPC is pleased to have the opportunity to engage to the extent that it is able with the FP consultation.

4.2. However, GCP’s consultation on the Local Plan is a convoluted process. The material is voluminous, there are 60 policies and the maps are often difficult to interpret electronically, and this militates against inclusion of the diverse age and socio-economic groups in a rural population. It comes across as an IT driven process designed for an urban sophisticated readership. Further thought needs to be put into reducing the complexity but increasing the inclusion, accessibility, and meaningfulness of this consultation.

Vision and aims
I support the vision and aims of the Local Plan and the general direction of the development strategy, but am concerned about the overall scale of development and the continuing high levels of growth which are driven by technical economic growth forecasts.

How much development, and where – general comments
I recognise that Greater Cambridge has a strong and nationally important economy, but I do not support the continuing pace and scale of high levels of growth that has increasing cumulative impacts on the environment, water supply, heritage and carbon emissions.
I would argue that the growth of the Cambridge and the impacts of that level of growth on South Cambridgeshire are disproportionately high (a third higher than the government targets) compared with other Local Plans, because the scale of growth is driven by technical economic forecasts studies and the desire to continue to stoke the engine of growth yet again.
The area over the last 30 years has absorbed major levels of development which has brought many benefits and disbenefits.
But the time has come with this Plan, in a new era having to seriously address the causes and impacts of climate change and net zero carbon goals to set t Cambridge on a different course.
The development strategy should with this Plan start to reduce the scale of growth to more manageable levels, perhaps towards the Low option so as to set the direction of travel for the next planning round in the era of climate change .

S/JH: New jobs and homes
The level of new homes proposed in the Plan is driven by the need to enhance economic growth, so much so that it is 37% higher than the Government targets for the area.
This proposes larger amounts of housing growth in the surrounding South Cambridgeshire District to serve Cambridge and the surrounding area.
A large amount of new development proposed in the housing pipeline is already allocated to known sites. A moderated target would lessen the uncertainty of deliverability, ease of the identified water supply issue and give time to for water companies to decide and implement sound options, and reduce climate impacts.
Even a moderate reduction in the housing target, which goes so far beyond what the Government requires, could provide more reserve housing sites, providing flexibility to maintain a five year housing supply, reduce pressure on villages and start to slow the pace of change in an area, which has seen so much cumulative change over the recent decades.

S/DS: Development strategy
I generally support the Development Strategy that supports sustainable development and proposes compact active neighbourhoods in Cambridge, development and /or expansion of new towns connected by good public and active transport and the proposals for very limited new development in the rest of the rural area.

S/SH: Settlement hierarchy
I support the proposed Settlement hierarchy policy area as a means of planning and directing new development towards the most suitable and sustainable locations.
In my comment on the rest of rural area, I am concerned about the impact of unallocated housing windfalls being used by possible speculative planning applications contrary to the development strategy to direct development to the most sustainable locations.
I would suggest that the word indictive in the proposed policy SS/SH is omitted to strengthen and add clarity to the proposed policy in the light of the revised annual windfall target.
Support the reclassification of Cottenham and Babraham villages to provide locations for development and new jobs on good public transport routes.

S/SB: Settlement boundaries
I support the work on the development of Settlement boundaries, especially to protect the open countryside from gradual encroachment around villages and on high quality agricultural land.
The work on settlement boundaries should include the involvement of Parish Councils at an appropriate stage in the development of the Policy because of their local data and knowledge of past development.

Cambridge urban area - general comments
Support in Cambridge urban area for good designed, active compact new developments, reuse of brownfield land and continued development of larger neighbourhoods where possible.

S/NEC: North East Cambridge
Support the development of NE Cambridge as a sustainable neighbourhood with good public transport and active transport into Cambridge

Edge of Cambridge - general comments
Support edge of Cambridge planned new neighbourhoods and new sustainable developments and settlements of sufficient size to cater for daily needs and with good access to public and active transport

New settlements - general comments
Support for new settlements of substantial size to cater for more than local needs. I particularly support the growth of Cambourne which can provide good rail access into Cambridge and to the West in the mid-term from new East West rail infrastructure.

S/BRC: Babraham Research Campus
Support the release of land from the Green Belt to support nationally important R and D and life science jobs located near to public transport routes and active transport.

S/RSC: Village allocations in the rural southern cluster
NB, Policy has different name on map page.
In accordance with reducing carbon emissions, and supporting access to the existing rail network the villages of Shelford and Whittlesford could be locations for more sustainable development, despite Green Belt locations

S/SCP: Policy areas in the rural southern cluster
Support existing site allocations to be carried forward including the expansion of Babraham research campus using Green Belt land

Rest of the rural area - general comments
I support the development strategy approach which directs new development to a limited number of sites in the most sustainable development locations supporting the sustainability of villages.
There is still the matter of the unallocated housing windfall development identified in the strategy Topic Paper of 5345 homes for 2021-2041 which is not included in the additional allocated land target of the 11596.
The anticipated dwellings per year for SCDC is between 240 and 255 dwellings a year. Notwithstanding the proposed policy SS/SH, there is a risk that developers will seek speculative permission in the open countryside greenfield sites contrary to the development strategy using the windfalls allocation and I have made a comment on this on Policy SS/SH.

Climate change - general comments
All new development will have impacts relating to increasing carbon emissions and require adaptation responses. A Local Plan can only seek to mitigate these impacts and by far the most impacts are from the existing development, their use and getting around using carbon fuelled transport.
The rate of change in and around Cambridge over the past 30 years has been significantly greater than for just local needs, mainly to develop nationally important economic development. This Plan continues this approach despite the issue of climate change and water supply and large amounts on new development still to be implemented from current Local Plans.
I would argue that the time has now come to step back from this direction of travel and begin to reduce the scale of growth around Cambridge using the Low option as a first step.
I was hoping, given the aims of the Plan and the input of the Net Zero Carbon study for a more radical Plan which addressed climate change and zero carbon targets through aiming to reduce the total amount of new development to meet local needs need and move to a position which is in line with Government targets in the next planning round.

CC/NZ: Net zero carbon new buildings
Support in general
Although I have concerns about how for example heat pump technology can be installed and used at reasonable cost in new development.

CC/WE: Water efficiency in new developments
Support, important given the water supply issues coming forward up to 2041

CC/DC: Designing for a changing climate
Support especially with regards balancing insulation and overheating with increasing hot to very hot summers risk brought about through a changing climate.
Site wide approaches should include appropriate lower densities through good design which allow for beyond minimum garden space and space for Suds and open space and greening.

CC/FM: Flooding and integrated water management
Support
Especially permeable surfaces and integration of water management with enhancements to biodiversity and greening.

CC/CS: Supporting land-based carbon sequestration
Support the creation of land for use as carbon sinks through the development process. Perhaps a suitable use of land in the Green Belt or on lower grade agricultural land.

Biodiversity and green spaces - general comments
Support the identification of 14 strategic GI initiatives and enhancing the linkages between GI and open spaces to provide corridors for wildlife.

BG/BG: Biodiversity and geodiversity
Support delivery of a minimum 20% biodiversity net gain.
I would comment that funding for long term management of biodiversity assets is key for the long-term benefits from such a policy.
I could also emphasis the creation of winter wet areas, water space and Suds designed to benefit enhanced biodiversity should be planned in to developments at an early stage

BG/GI: Green infrastructure
Support the use of a GI standard, particularly on larger developments.
In particular early identification of GI and biodiversity assets and potential gains as an early part of the design process and /or planning brief

BG/TC: Improving Tree canopy cover and the tree population
Support increasing tree and woodland cover, ensuring right tree(s) in right places and species futureproofed for lifetime changing climate adaptation.
A particular opportunity is the rural field margins of agricultural land to help increase the linkages and biodiversity gains and in specific places the creation of woodland belts in the open countryside, green belt land and around villages.
In Cambridge urban areas, where there are existing trees there is a need to plan their replacement with adaptation species to gradually adapt to a changing climate.
Also, to provide sufficient future tree cover to mitigate the urban heat island effect, provide shade and mitigate microclimatic effects.

BG/RC: River corridors
Support the protection and enhancement of river corridors and restoration of natural features and use of GI to support the alleviation of flooding risk.
Support the delivery of the continuous Cam Valley Trail.

BG/PO: Protecting open spaces
Support the protection of the wide variety of open spaces and use of Local Green Space designation in appropriate locations

BG/EO: Providing and enhancing open spaces
Support the provision of open space and recreation provision, including appropriate play space.

WS/HD: Creating healthy new developments
Support the use of health impact assessments in proposals.
I would comment that with the increase in ride on electric vehicles and increasing older communities there are opportunities to coordinate with transport professional the delivery of smooth pathways with minimal dropped kerbs which gives smoother access to local centres and bus stops linked to older persons housing and also can prevent falls.

GP/PP: People and place responsive design
Support the requirement of inclusion of a comprehensive design and access statement and recognise the importance of good design tailored to the local area and involving local communities and Parish Councils particularly in villages.

GP/LC: Protection and enhancement of landscape character
Support the use of landscape character assessment to enhance the setting of Cambridge and protect and enhance the setting of villages.

GP/GB: Protection and enhancement of the Cambridge Green Belt
National guidance places great importance on Green Belt policy and sets out how planning proposals should be considered.
I support the use of GI and other opportunities to provide access and increase tree and woodlands where appropriate in the Green Belt.
But I think where there are locations where there is good public transport especially rail access or future rail access there is a good case to consider the special circumstances judgment.
I think it is time to question if this national policy is still relevant to the situation Greater Cambridge in the period up to the middle of the century. Further Green Belt assessments may be better served by considering sustainable development and the extension of the Green Belt to prevent coalescence around villages beyond the current Green Belt boundary which was made before most of the new development (over 70%) is beyond the current outside boundary or further modification of this policy to enable growth to be planned for the 21st century rather than the conditions which related to the last century.

Jobs – general comments
I am concerned about the scale of economic growth in the area and its use to drive large amounts of housing growth well about what would be required in other planning areas.
However, I support the life science sector and its national importance and the appropriate development in science parks including their expansion using Green Belt land

J/AL: Protecting the best agricultural land
Support the restriction of development on the best agricultural land as supported in the Sustainability Appraisal.

Homes – general comments
Support the objective for planning enough housing to meet our needs, including affordable housing to rent or buy.
I object to needs being directly driven by future economic assessments, the direction of travel of the plan should be as much balanced by the climate change as future economic demand.

H/HD: Housing density
Support design led approach to determine optimum capacity of sites and appropriate density to respond to local character, especially in villages.

H/GL: Garden land and subdivision of existing plots
Support for controlling the use of gardens for new development.

I think it is outrageous that 100 houses are being proposed on the site along Mingle Lane / Hinton Way , the site is in the green belt and there appear to be no exceptional circumstances for this site to go ahead.

Proposed Mingle Lane/Hinton Way site

While the principle of expanding the housing stock in our villages by 100 homes over the next 20 years is reasonable, local residents are understandably concerned about building them on the green belt. The principal question is: is it worth incursion on the green belt to deliver such a small percentage of the overall additional projected housing needs?

Furthermore, if 100 houses are needed, why is such a large area (10 hectares) proposed for development?

Local concern is that a second access route would result in a much large number of houses being built on the proposed site. The Local Plan explains that the housing supply must meet the evidential need. As only 100 houses are required within the Shelfords and Stapleford to meet that need, why propose a site that might accommodate many more houses?

We call on the Greater Cambridge Shared Planning Service to either (1) reduce the area of land proposed for development is OR (2) designate a Local Green Space the area of the 10-hectare plot beyond that which is necessary for 100 houses, thereby protecting it from development and offering the potential of park land with play facilities to the east of Great Shelford and Stapleford. This would represent a significant benefit to families living in the area.

Proposed Mingle Lane/Hinton Way site

While the principle of expanding the housing stock in our villages by 100 homes over the next 20 years is reasonable, local residents are understandably concerned about building them on the green belt. The principal question is: is it worth incursion on the green belt to deliver such a small percentage of the overall additional projected housing needs?

Furthermore, if 100 houses are needed, why is such a large area (10 hectares) proposed for development?

Local concern is that a second access route would result in a much large number of houses being built on the proposed site. The Local Plan explains that the housing supply must meet the evidential need. As only 100 houses are required within the Shelfords and Stapleford to meet that need, why propose a site that might accommodate many more houses?

We call on the Greater Cambridge Shared Planning Service to either (1) reduce the area of land proposed for development is OR (2) designate a Local Green Space the area of the 10-hectare plot beyond that which is necessary for 100 houses, thereby protecting it from development and offering the potential of park land with play facilities to the east of Great Shelford and Stapleford. This would represent a significant benefit to families living in the area.

This policy is considered to only illustrate further that despite this Rural Southern Cluster Area having been identified by the Council as a growth area, there is in fact limited residential development proposed within this area to support the level of employment growth. Delivering more housing within this area will provide development with opportunities for sustainable travel to the Genome Campus and Babraham Research Campus.
Residential allocations within the Rural Southern Cluster include a carried forward allocation in Sawston, along with new allocations S/RSC/HW in Great Shelford which will deliver no more than 100 homes and S/RSC/MF at Duxford which will deliver around 60 homes. For an area that is identified for growth to support significant employment development, 160 homes is a very small contribution. Linton is equidistant to the Babraham Research Campus compared to Great Shelford and Duxford, and Linton is closer to the Genome Campus than Great Shelford.
Whilst we do not comment on the appropriateness of the proposed allocations themselves at this juncture, it is notable that Duxford is a lower order settlement in the hierarchy than Linton however it receives an allocation whereas Linton does not.
The evidence base is clear that the Rural Southern Cluster is an appropriate location for focusing development as part of the Council strategy. The Greater Cambridge Local Plan: First Proposals Sustainability Appraisal (October 2021) states that development in this area ‘will help to ensure housing is well-located in relation to existing centres of employment’.
The Greater Cambridge Local Plan Development Strategy Options – Summary Report (November 2020) sets out work undertaken to assess further whether the spatial choices set out in the Greater Cambridge Local Plan: First Conversation consultation were indeed reasonable; and to identify whether there are any additional reasonable spatial options that should be added to the First Conversation choices. The assessment identified the following two options as being reasonable and substantively different to the six First Conversation options:
• Supporting a high-tech corridor by integrating homes and jobs (southern cluster); and
• Expanding a growth area around transport nodes (western cluster).
Consequently, eight choices were taken forward for testing as strategic options, which included:
‘Spatial Option 7: Supporting a high-tech corridor by integrating homes and jobs (southern cluster) - this approach would focus new homes close to existing and committed jobs within the life sciences cluster area around the south of Cambridge, including homes at existing villages and at new settlements.’
The assessment noted that opportunities for this area included a good relationship between jobs and homes. It however appears that more limited growth has been directed to this area due to anticipated high carbon emissions due to dispersed village homes. However, this is considered to be a rather general statement and does not focus in on specific settlements within the cluster that benefit from better sustainable travel opportunities.
As set out earlier, Linton offers highly sustainable travel opportunities for residents and these are being further enhanced through ongoing improvements. Residents within Linton are able to access Babraham Research Campus by regular bus service with a journey time of around 15 minutes. Whilst the Genome Campus is not directly accessible by bus, this is only a 10 minute drive. It is therefore considered that the conclusion that development in the southern cluster would result in high carbon emissions is not representative of Linton.
Furthermore, Taylor Wimpey launched their Environment Strategy in 2021. This sets out how they will help protect our environment for future generations, partner with suppliers to reduce the impact of the homes and developments built, and make it easier for their customers to live a sustainable lifestyle. The strategy focuses on the key environmental impacts for the business: climate change, nature, resources and waste. As such the development of Land north of Cambridge Road, Linton could be delivered sustainably, with reduced carbon impact.
It is therefore considered that the Council should look to deliver more homes in this important employment area, with the Land north of Cambridge Road, Linton providing a suitable site in a sustainable location for accessing jobs.

1) I have strong concerns about the water supply. It has been reported that Cambridge Water has failed to acknowledge how serious the water situation is in Cambridgeshire and that there is an over-abstraction of water as a result of rapid city development. Chalk streams are threatened. The current level of abstraction is unsustainable.

For that alone, I object to 100 new homes on Mingle Lane.

2) The homes will be built on green belt land. Such land is precious as development claims more and green belt land is diminished.

For that reason, I also object to 100 homes on Mingle Lane.

3) Finally, as I live on Mingle Lane, I experience traffic being halted when one car or van is parked on the road. The same is the case for Hinton Way. Cars also back up when the level crossing barriers are down.

100 homes means at least 100 cars, possibly as many as 200. The only access is on Mingle Lane. Even if one member of the family takes public transport, it is likely one will drive a car for convenience to get to work or do grocery shopping.

Despite plans, which have not yet been approved, for public transport, people will always use their cars.

100 or 200 extra cars on Mingle Lane and Hinton Way makes this proposed site unworkable.

These are my objections: water supply, green belt land, massive increase in cars.

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).

Land at Balsham Road, Linton
Gladman are promoting a site in Balsham Road, Linton. The site is 3.07 hectares and capable of delivering approximately up to 65 dwellings. We would welcome an opportunity to discuss the site with the Councils and the development it could deliver.
The site is capable of delivering up to 65 new homes, including up to 26 affordable homes, a programme of ecological and biological enhancement, and new green infrastructure and recreation routes. The site is suitable for development as it is sustainably located near to local services and facilities, within Flood Zone 1, well contained by existing landscape features and will not adversely impact any heritage assets. Measuring 3.07 hectares, the site is an ideal opportunity to provide much needed market and affordable housing in Linton, alongside recreational green space, and wider economic benefits such as increased spending in local shops.
The site is sustainably located within the settlement, with the secondary and infant schools, pharmacy, pub, newsagents, health centre and Co-op food store all being between 0.8-1.6km from the site, meaning that many will be accessible by foot. A bus stop is located in the centre of the village where buses to Cambridge and Haverhill are available.

Land at Back Road, Linton
Gladman are promoting a site in Back Road, Linton. The site is 3.98 hectares and capable of delivering approximately up to 95 dwellings. We would welcome an opportunity to discuss the site with the Councils and the development it could deliver.
Gladman consider that the development could deliver 95 homes, including 38 new affordable homes and a programme of ecological enhancement. The provision of recreational green space and the potential economic benefits of development in this location makes this an ideal sustainable location for growth. Safe access can be achieved off Back Road and the site is within Flood Zone 1.
The site is sustainably located within the settlement, with the secondary and infant schools, pharmacy, pub, newsagents, health centre and Co-op food store all being between 1.1-1.6km from the site, meaning that many will be accessible by foot. A bus stop is located 1.2km away where buses to Cambridge and Haverhill are available.

Land to the East of the A11, Mill Road, Great Wilbraham (HELAA site 40130)

Additional information has been submitted through the call for sites proforma.

Currently the Councils assessment of the proposal indicates three red flag issues. Since the original call for sites submission the landowner has engage4d with a development promoter and further site proposal details have been considered. The primary plan for the site is to have an electric vehicle charging station at the front of the site with commercial use behind We are currently assessing the utility provisions and grid capacity for the site and whether there is any possibility of tying the energy requirements into the adjacent solar and wind farms we are actively looking for an occupier for the commercial element of the site and we are discussing the possibility of an anaerobic digester on site to assist with the energy requirements of the proposed uses.

Cheffins has been instructed by Mr David Wright to promote their interests in 'Land to the South of Shelford Road and Cambridge Road, Fulbourn, CB21 SHQ' (HELAA Site Reference: 48064). We propose a phased development that will create attractive open spaces for the settlement and deliver approximately 150 - 200 dwellings of mixed type and tenure in a sustainable location proximal to employment centres. The site extends to 8.45 hectares and comprises greenfield land located immediately to the south of Shelford Road and Cambridge Road in Fulbourn. The location of the site is shown on the site location plan, which accompanies this representation.

The direction of policy provides some flexibility for providing development in the countryside, while ensuring the setting is not adversely affected. The suitability rating of site 40302 under the HELAA has been decided based on the potential landscape impact, should the whole site be developed. The Council is requested to reassess the landscape impacts of the proposal based on the proposal submitted. It is not the intention to develop the whole site, but rather the full extent of land is put forward to the Local Plan so that any land allocation can include areas of landscaping and open space.

Cheffins has been instructed by Ms C Sawyer Nutt to promote their interests in Land North of Pampisford Road, Great Abington (HELAA site reference: 40539). We propose a phased development that will deliver approximately 135 dwellings of mixed type and tenure in a sustainable location proximal to major employment centres and create attractive open spaces for the village.

Although much of the Greater Cambridge area has a dispersed settlement pattern, the draft plan does not support the 'organic' growth of smaller settlements. To ensure that local housing needs can be fulfilled and prevent any further loss of key local services, a more flexible and tolerant approach is needed towards development in the rural area.
Through the application of tightly drawn settlement boundaries, development is strictly controlled on sites in the 'open countryside'. But it is not logical to treat all sites equally in policy terms. Although sites within sensitive valued landscapes and the green belt should receive a high level of protection, the sensitive development of some sites on the edge of a village would cause no significant harm (e.g. Whittlesford). Such a pragmatic approach is often taken at appeal; rounding off development where there is a defensible physical boundary or allowing a high-quality development with extensive landscaping that would soften an existing harsh area of built form can be acceptable in certain locations.
Furthermore, for Group Villages such as Whittlesford and Whittlesford Bridge, the current strategy to restrict developments to an indicative maximum of 8 dwellings (or 15 dwellings where this would make the best use of a single brownfield site) within settlement boundaries will not deliver the quantum of development required to meet the existing need for affordable homes or the projected need that could follow nearby business park expansions. As a result, the affordability crisis will deepen in the rural area. For example, to deliver 25 affordable homes within Whittlesford, a minimum of 63 dwellings will need to be permitted as part of major developments. With limited scope for development within the tightly drawn settlement boundary, it will be necessary to find suitable locations on the edge of the village. To discourage the development of less suitable sites and assist in the delivery of much­ needed affordable housing, the most logical approach is to allocate further sites on the edge of sustainable settlements such as Whittlesford Bridge.
Overall, a carefully worded criteria-based policy which was supportive of organic growth adjacent to existing built-up areas should not perpetuate unfettered incremental growth.

LAND NORTH OF HINXTON COURT, HINXTON

This letter is in reply to the Greater Cambridge Local Plan – First Proposals consultation and is written
on behalf of Mr & Mrs M Bishop pursuant to Land North of Hinxton Court, Hinxton.

The site was submitted as part of the Call for Sites exercise in 2019, and further representations were made to the Regulation 18 consultation in February 2020. Within the Housing and Economic Land Availability Assessment (HELAA) document 2021, the site is labelled as site 40080.

The land was considered to be appropriate for either additional housing or employment land in order to support the growth in employment within this strategic arc, which includes the Genome Campus, Chesterford Research Park, the Babraham Campus and Granta Park. The area is a key growth area for employment within the District, supported by the expansion to the Wellcome Trust at Hinxton for employment floorspace and 1,500 dwellings.

The purpose of this letter is to confirm that the site remains available for development and should therefore be considered as an option for the Greater Cambridge Partnership as they seek to allocate land to provide sustainable development across the area. The site remains well-placed to support the AgriTech Park site proposed directly to the south. This will ensure opportunities in research and development are maximised in this south Cambridge cluster. It would bring high quality employment opportunities which would benefit from the proximity to existing facilities.

If the Agritech Park were to become an allocation within the Plan to meet employment demand, then Land North of Hinxton Court should also be allocated given its ability to provide land for either further employment or supplementary residential uses.