Greater Cambridge Local Plan Preferred Options

The overall intent and policy direction of this policy is welcomed and supported.

However we note that “It will also need to continue to recognise that in some cases development on open space may be appropriate if it has limited qualities and would lead to overall quality or quantity improvements.” We do not support this approach where applied to private benefit. More green space is needed, as identified elsewhere. We do not believe that a circumstance can exist whereby the only way to improve the quality of an open space is by allowing private development on it. There are other ways of raising funds to support open space improvements. The draft plan should include a policy that any loss of open space to private development must be offset by the provision of at least an equal amount and quality, within the adjacent neighbourhood.

Raising funds or the stewardship of the ongoing maintenance of open spaces is a challenge and an issue of national concern. One of the ways that funds can be raised for this work is through offering the public a service, for example a café in a park. The wording of this policy should allow for developments that would provide a public benefit and support the ongoing maintenance of the open space (eg café).

The supporting text notes:
‘Access to a range of open spaces for different activities, for all ages is an essential part of sustaining healthy communities, supporting the local environment, and encouraging social interaction with local people.’

Open space also performs a valuable function in reducing recreational pressure on other vulnerable sites, especially where there is sensitive wildlife. We comment further on this in respect of Policy BG/EO and the provision and enhancement of open spaces.

Many open spaces also have an important heritage function, either directly or as a contribution to the setting of the historic city and/or individual heritage assets. We would like to see this recognised within the wording of the draft Plan.

The overall intent and policy direction of this policy is welcomed and supported.

The supporting text notes a number of reasons why this policy is required and the many benefits it can deliver. We also believe there is a direct link between the provision of open spaces to ensure easing the recreational pressure on other sensitive areas of countryside such as important wildlife sites.

Recreational pressure on sensitive wildlife sites is only likely to increase and it is vital that other adequate alternative greenspace is provided and secured to avoid any adverse effects. The use of Suitable Alternative Natural Green Space (SANG) is discussed in the recent Greater Cambridge Shared Planning Biodiversity Supplementary Planning Document - Consultation Draft July 2021. In our comments on that document we stated:

"Whilst it is appreciated that current Local Plan policies do not set out requirements in respect of SANG, Local Authorities should also take the lead in future development plans with clear overarching policies that provision of SANG may be required for certain residential developments. "

This comment applies equally to the current First Proposals.

In our research for the Cambridge Nature Network (http://cambridgenaturenetwork.org/) we identified that the creation of new accessible green space in Cambridgeshire has not kept pace with the increase in population over the past 20 years and this has been one of the main drivers of recreational impact on wildlife sites. In addition, many green space sites in Cambridgeshire are wetlands, meaning that although they might cover a large area, the amount of land that can actually be used by the public is often small or limited to paths. Unlike other counties Cambridgeshire does not have large areas of public access woodlands, downland/moorland/heathland or coastline and as a consequence there is poor access to countryside. Our research also identified that larger scale development (such as Cambourne) were providing larger areas of new greenspace but smaller developments were not and therefore it is these that are contributing most towards the problem as they have made up around 50% of the development in Cambridgeshire over the past 20 years. If the Local Plan is to be sustainable (ie not increase recreational impacts more than has already occurred) then ALL new development will need to make a contribution towards creating new strategic greenspace (if none is created through the development). The Local Plan should set out how these contributions are to be collected and the amount that would be required per person. We refer you to the submission by the s106 Officer for South Cambridgeshire District Council who has calculated that this should be £498 per dwelling.

It is important to consider that some public open spaces are not green spaces, such as the Market Square or Quayside but they should still be subject to similar policies that seek to protect and enhance their important features.

Protecting and enhancing the Historic Environment is not only key to creating and providing Great Places but a vital part of Wellbeing.

We agree that creating Great Places intersects with other themes. This must also include:
A great place is somewhere which sits well within its landscape (as covered by policy GP/LC).

The Great Places paper refers to Heritage Assets, but does not adequately recognise that the city of Cambridge is a heritage asset of worldwide significance which meets UNESCO’s Outstanding Universal Value criteria for World Heritage status. This significance derives from the combination of its built and natural heritage. We would like the draft Plan to recognise the vital role which this special character plays in making Cambridge a great place to live in, work, study, and visit.

The structuring of the consultation creates a separation between Landscape and Townscape (Objective 6) and Historic Environment (Objective 7), which for Cambridge creates a risk that there is not adequate consideration and valuation of the historic city in its historic landscape setting, with historic landscape and open spaces considered as green infrastructure but not as historic environment.

Cambridge’s special character (which is what makes it a great place) will be put under significant pressure by the scale of growth proposed (73,000 extra residents). Cambridge Past, Present & Future is very concerned about the “limits to growth” capacity in trying to accommodate the 21st century demands this will create within the built fabric and spaces of a medieval market town. The fundamental conflicts between growth on the one hand and environmental capacity and special character on the other must be recognised as a key challenge for the draft Local Plan. We are concerned that the evidence base does not include an assessment of the cumulative impacts on the historic centre and what the likely impacts of this might be – without this it is impossible to reach a judgement. Para 3.2.4 of the Strategic Heritage Impact Assessment: baseline includes the statement that “3.2.4 Future growth in Cambridge has the potential to strengthen and reinforce these characteristics, enabling the City to meet contemporary environmental, economic and social drivers without undermining its economic identity" but we could not find any evidence to support this statement.

We strongly support this.

One of the challenges is that trees are needed to screen developments and maintain the green edge to Cambridge and its villages. It will typically take at least 30 years for them to grow large enough to achieve any meaningful screening. As Cambridge is growing rapidly there is a risk of significant cumulative impacts. For example, the developments at Trumpington, Cambridge Biomedical Campus and Wort’s Causeway mean that nearly the entire south eastern fringe of the city will lose its screening for 30 years. Add to this Cambridge East and the developments at west and northwest Cambridge and the impact is clearly significant. We would argue that previous policy has not been effective at protecting the setting of Cambridge from the cumulative impacts of development. As a minimum we would like the policy to require the planting of large trees so that the time taken for them to provide screening is reduced. As a good example we would highlight the trees planted in the courtyard at the new Astra Zeneca head quarters.

Cambridge Past, Present & Future strongly supports the green belt purposes.

We also support the Greater Cambridge Green Belt Assessment but raise concerns that some historic buildings were omitted during the assessment despite the fact that they could potentially contribute towards the historic setting of Cambridge.

The proposed policy direction is supported. The policy should be linked to policy CC/NZ and buildings designed with climate mitigation in mind such as the orientation of buildings, window sizes etc.

Cambridge is a city of international heritage significance. It is therefore considered that the historic environment has been considered in the local plan far too narrowly. This policy needs to be linked to the wellbeing policies WS/HD as safeguarding and enhancing the historic environment is a key part of Wellbeing and creating healthy developments.

The definition of sustainable development must be broadened to include Culture (since 2010 the UN has included culture as the 4th pillar of sustainable development). Cambridge’s historic environment is a cultural asset of worldwide significance which must recognised when developing sustainable policies and development.

Concerns are raised on the Heritage Impact Assessment (2021). There is considered to be a flaw in the Baseline Study which does not assess and record the SIGNIFICANCE, as opposed to weighting, of the City as a whole or of any undesignated areas within and around it. This is a direct consequence of the study's approach to the Historic Environment in terms of considering only the setting of designated heritage assets, rather than taking a holistic strategic view.

It appears that the study has only taken a superficial look at the baseline information.
• The baseline study confines itself to stages 1 (“identify the historic assets” and 2 (“define and analyse the settings”) of Historic England’s ”Settings of Heritage Assets: Good Practice Guide”, without considering the dynamic of the city as a whole: what has been happening in its recent years?,and what are the potential impacts of the large scale growth that is planned? It is almost as if the Council asked for an updated version of the 1971 publication “Cambridge Townscape”, whilst completely disregarding the award-winning conservation plan approach of the 2006 Historic Core Appraisal which sought to understand not just the physical character of Cambridge but its dynamic, and threats and opportunities, as part of shaping policies.
• The HIA identifies Conservation Area Appraisals as data to inform the assessment. However, not all the conservation areas have a CAA (indeed the majority of Conservation Areas in South Cambs District do not have up-to-date CAA) and therefore there is a gap in the available data.
• The Baseline study does not mention the Suburbs and Approaches Studies.
• The Baseline study does not consider the strategic extent, or lack of, designations for example the extent to which Cambridge’s historic or cultural landscape (including the river corridor from Byron’s pool to Baits Bite Lock) is or is not protected.

We feel that the study fails to assess the significance of Cambridge as a whole. Dennis Rodwell’s “Conservation and Sustainability in Historic Cities” puts Cambridge on a similar level of international significance to Venice.

The “Strategic Heritage Impact Assessment” references a “Vu-City” model for assessing the impacts of tall buildings. We request that this modelling is made available for the public to see and assess both proposals, and the credibility of the Vu-City approach.

Concerns are raised on the failings of the “view” photos within the study, and that they don’t show the “eye-catching” impact on a viewer’s perception of a contrasting feature such as a tall building in a landscape.

Cambridge’s special character (which is what makes it a great place) will be put under significant pressure by the scale of growth proposed (73,000 extra residents). Cambridge Past, Present & Future is very concerned about the “limits to growth” capacity in trying to accommodate the 21st century demands this will create within the built fabric and spaces of a medieval market town. The fundamental conflicts between growth on the one hand and environmental capacity and special character on the other must be recognised as a key challenge for the draft Local Plan. We are concerned that the evidence base does not include an assessment of the cumulative impacts on the historic centre and what the likely impacts of this might be – without this it is impossible to reach a judgement. Para 3.2.4 of the Strategic Heritage Impact Assessment: baseline includes the statement that “3.2.4 Future growth in Cambridge has the potential to strengthen and reinforce these characteristics, enabling the City to meet contemporary environmental, economic and social drivers without undermining its economic identity" but we could not find any evidence to support this statement.

A third-party, holistic overview is recommended, to identify and try to resolve some of these key strategic issues and balances. In relation to heritage, growth is seriously threatening what makes Cambridge Special. It is recommended that Historic England’s Historic Places Panel are invited to visit Cambridge and provide strategic recommendations which can inform the Local Plan.

Moving from strategic issues to safeguarding individual heritage assets and their settings, there are serious questions in relation to the effectiveness of existing policies which are proposed to be carried forward. A case in point is the former Mill Road Library, a grade II listed building of high public significance, which was recognised to be “at risk” but excluded during the development and approval of the adjacent City Depot site. This was an excellent opportunity to protect and enhance a heritage asset, which would not have been missed had the City complied with its own Local Plan policy regarding heritage assets. While the County has belatedly refurbished the former Library, it has not been integrated as a public building within the new development. It appears that the County may now be offering this public building, built for the public, for private sale!

This is supported but should relate to all buildings of traditional construction, and needs some updating. Needs direct read-across to CC/NZ.

It would be useful for the policy and/or supporting text to provide clear policy on the appropriate location of solar panels on heritage assets / on buildings within conservation areas.

To help safeguard public houses in the villages the supporting text to the policy could encourage nominations as assets of community value.