Draft North East Cambridge Area Action Plan

Comment

Representation ID: 55726

Received: 05/10/2020

Respondent: Brookgate

Agent: Bidwells

Neutral:
Brookgate broadly support the aims of Policy 1, the Spatial Framework and Land
Use Plan. However, as referred to under Section 1 of these representations, the
supporting diagrams as currently drafted are too precise. They should instead be
clearly marked as indicative.
Both the Spatial Framework and Land Use Plan also need to recognise the
potential for an educational facility within the Cambridge North site, a 16-19 offer in
the form of specialist Maths School. This is capable of coming forwards separately
to the proposed primary school sites and the potential safeguarded land for a
secondary school.
It also needs to be recognised that the adopted plans of South Cambridgeshire
District Council and Cambridge City Council make it clear that planning applications
are capable of being submitted and granted planning permission in advance of the
AAP being adopted (South Cambridgeshire Local Plan Policy SS/4 and Cambridge
City Local Plan Policy 15). Under both policies, the Cambridge North Site is
allocated for high quality mixed-use development, primarily for employment uses
such as B1, B2 and B8, as well as a range of supporting commercial, retail, leisure
and residential uses (subject to acceptable environmental conditions).
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The approach in the recently adopted local plan in respect of early submissions
should not be watered down through the AAP process, indeed, through the AAP
process the opportunity to bring Brookgate land forward early should be explicitly
acknowledged as beneficial to the regeneration of the area, creating a sense of
place and arrival around the new Station and evidencing in commercial terms how
the low parking ratios might work.

Comment

Representation ID: 55727

Received: 05/10/2020

Respondent: Brookgate

Agent: Bidwells

Neutral:
Brookgate support the basis of Policy 16. There is a need for area wide non-car
interventions to cater for these trips and ensure sites can come forward in
accordance with AAP car trip/parking budgets.
Creating new and improved walking and cycling connectivity to the NEC is
essential in creating a development that is not reliant on the car as the primary
means of transport. These measures are welcomed. There appears to be an over
emphasis on new walking and cycling routes and not enough consideration of
improving existing walking and cycling infrastructure in the area.
In particular:
● Improving existing links to Milton P&R site to Milton Village and the NEC by
improving the existing footbridge over the A10 to allow cycle access. Improvement
to cycle and walking routes on Milton High Street and connectively to Jane Coston
Bridge and the NEC.
● A greater emphasis on the existing very well used walking and cycling route
to the south of the site via Moss Bank and the River Cam. This is by far the most
direct and safe ‘off road’ route for pedestrians and cyclist from Cambridge City
Centre to the whole of the NEC. And will only become more popular when the
Chisholm Trail is opened allowing high quality ‘off road’ access to the east and
south of Cambridge.
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In terms of new cycle links we note that there are no proposals to provide better
permeability between the NEC and East Chesterton between the existing Nuffield
Road / CGB footway / cycleway link to the north and Moss Bank to the south. This
creates an impenetrable barrier along the south western side of the NEC in excess
of 600m.
Brookgate consider this to be a missed opportunity and maintains the current
barriers between the NEC and established residential areas. We strongly suggest
that a footway / cycleway link is provided through the Bramblefields area (not just
wayfinding to the site which would be a very long walk and impractical for most
people).
This will not only provide better connectively between the established residential
areas of East Chesterton and the NEC but will also provide easy access to
residents and workers on the NEC to enjoy the established areas of public open
space at Bramblefields.
This is a similar approach to the proposals to provide a link from the north of the
NEC to Milton Country Park. Clearly any footways and/or cycleway through
Bramblefields would need to be design sympathetically within the established
parkland, as would be the case for the proposed links to Milton Country Park. We
would suggest that a route adjacent to the southern boundary of the allotments
(minimising any impact on the established wildlife area) linking in with the
established network of path through Bramblefields is included in the NEC
proposals.

Comment

Representation ID: 55728

Received: 05/10/2020

Respondent: Brookgate

Agent: Bidwells

Neutral:
The possible interventions shown on Figure 37 and identified in Policy 17 are
broadly similar to those in Table 55 of Transport Evidence Base AAP Report
(September 2019).
Brookgate support the proposed internal and external interventions identified in
Policy 17 which will help sites come forward in accordance with the aspirations of
the AAP and within the trip/parking budgets. The emphasis must be the promotion
of non-car and active modes of travel and delivering a highly connected, and
accessible development by walking, cycling and public transport.
However, blanket financial contributions by developers towards an overall package
of interventions may not be appropriate given the geography of the AAP study
area, the range of interventions proposed and the delay associated with
implementing any charging schedule or equivalent. The current AAP developers
forum and emerging transport assessment process will assist developers in
understanding the value of interventions for their sites. This will help inform which
interventions developers should target for funding

Support

Representation ID: 55729

Received: 05/10/2020

Respondent: Brookgate

Agent: Bidwells

This policy sets out the standards and quantities of cycle parking that new
development must provide. It states that cycle parking should be provided in
excess of the minimum standards set out in Appendix L of the adopted Cambridge
Local Plan (2018) and at least 5-10% of cycle parking provision should be designed
to accommodate non-standard cycles and should consider appropriate provision for
electric charging points.
Brookgate support the application of the minimum cycle parking standards from the
Cambridge Local Plan across the AAP area.
Cycle parking provision will be very important in encouraging sustainable transport
and to assist in delivering on low car use development. Brookgate consider that
cycle parking provision above ‘minimum standards’ may be necessary (depending
on demand) and will need to be evidenced as part of the overall transport strategy
and assessment work for each development site.
Opportunities for shared cycle parking between deference land uses is welcomed
and supported. The efficient use of cycle parking will be key to responding to the
future demands for cycling in the NEC.
Cycle parking numbers and type will be provided for future phases of Cambridge
North in accordance with these standards and detailed within specific transport
assessments.

Object

Representation ID: 55730

Received: 05/10/2020

Respondent: Brookgate

Agent: Bidwells

Policy 19 ensures that land is safeguarded for the CAM and other public transport
hubs.
The north portal for the central core section of the CAM is likely to be located within
the North East Cambridge AAP boundary. An area of land in close proximity of
Cambridge North station (shown on Figure 38) is proposed to be safeguarded for
the operation of the CAM, including land for the portal/tunnel entrance as well as
for construction and maintenance.
The indicative area safeguarded for CAM portal construction includes the existing
station turning circle, bus stops and cycle parking. It also includes land to the west
of the guided busway associated with utilities/drainage for the consented office and
hotel development at Cambridge North and the next phases of development.
It is acknowledged that the proposed safeguarding land for CAM is indicative at this
stage, However, as it is currently shown in figure 38, the shaded area is wholly
Network Rail owned land including Network Rail’s station lease area and
operational railway land. Any proposed safeguarding of the land would need to be
agreed with Network Rail and further engagement with Network Rail is required on
this matter as and when it progresses.
Brookgate understand the aspirations of the Combined Authority to provide a new
rapid transport system of Cambridge. However, they are concerned over the lack
of information on this important issue and the extensive area of land that is
considered necessary to be ‘safeguarded’.
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There is no information within the document on the justification for the extent of the
area proposed to be ‘safeguarded’ or its intended use, as tunnel portals or station
concourse or construction compounds etc. Brookgate would expect that an
evidenced based approach would be driving this exercise and that the area
indicated on the plan would be based on the requirements to deliver the CAM
scheme.
Providing a ‘safeguarding’ area without any detail of what the area is to be used for
or indeed why it is required is very unhelpful and will lead to uncertainties during
the masterplanning of the area around the station, and significantly affect the ability
of the landowners in this area to effectively plan this very important area, to
enhance the existing transport interchange (a key requirement of NEC AAP policy)
and necessary to achieve further support and enhance sustainable transport
modes in the area.
The land should not be safeguarded in any planning document unless it is clear
that CAM Metro is deliverable and funded, any formal designation of land prior to
this would be premature. In this context Brookgate would therefore welcome
discussions with all stakeholders to understand the extent and scope of land
potentially safeguarded in the context of existing/future development in this area.
The AAP will be subject to external scrutiny and it is clear from the North Essex
Examination that the presiding Inspector will scrutinise the deliverability of the CAM
metro.

Support

Representation ID: 55731

Received: 05/10/2020

Respondent: Brookgate

Agent: Bidwells

Policy 20 sets out where the Councils expect delivery hubs to be located and what
they should provide. A delivery hub has been identified within Cambridge Science
Park Local Centre, as set out in Policy 10c. An additional hub could be located
close to Milton Road where it can be accessed directly from the primary street to
reduce vehicle movements within the Area Action Plan area.
Brookgate would support the policy for smaller scale servicing, where appropriate.

Comment

Representation ID: 55732

Received: 05/10/2020

Respondent: Brookgate

Agent: Bidwells

Neutral:
Policy 21 describes the primary and secondary street network, and how these
streets should be designed to lower vehicle speeds, and with excellent provision for
walking and cycling to ensure these remain the travel mode of choice. It also sets
out how space efficient car parking should be provided in ‘car barns’ so that
residents and workers who need to occasionally use cars, can access private or
shared cars.
The Policy states that NEC should be designed to manage vehicle movements in
accordance with the street hierarchy shown in Figure 40 and the design principles
described in Policy 7 and shown in Figures 16, 17 and 18. This shows a
realignment of the current primary access route along the east-west section of
Cowley Road to Cambridge North Station further north so as to avoid HGV, bus
and other vehicle movements through the proposed District Centre.
Chesterton Partnership support priority being given to non-car movements and a
permeable layout being provided for walking and cycling throughout the AAP area.
However, any realignment of Cowley Road would likely impact on future
development aspirations across a number of sites.
Early engagement will therefore be needed with Cambridgeshire County Council to
understand possible alignment and impact on development mix and interaction with
highway and interaction with highway, railway uses activities and operations.
Careful planning and phasing of the proposed new road layout and network,
particularly proposals for Cowley Road, is needed to ensure all access
requirements across the site are met at the required times

Object

Representation ID: 55733

Received: 05/10/2020

Respondent: Brookgate

Agent: Bidwells

Policy 10d sets out more detailed policy guidance for the Station Approach Local
Centre, including acceptable land uses, indicative development capacity, phasing
and development and design requirements.
The extent of the land parcel for the Station Approach Local Centre is not clear
from Figure 24 but Brookgate broadly support the proposed land uses and
indicative development capacities set out in Policy 10d, with the exception of the
100m2 for community and cultural uses.
The next phase at Cambridge North is proposing to include for a Specialist Maths
School of 200 pupils (opening with 100 initially). The Government has committed to
having a 16-19 maths school in every region, 11 in total. The Department for
Education (DfE), through the Learning Alliance, has identified the Cambridge North
site as an ideal location for this, due to regional accessibility and wider economy
and skills concentration.
The inclusion of a Maths School is compatible and complimentary to the other uses
being brought forward in the wider allocation and will not affect the ability to bring
forward wider residential and commercial development.
LocatED is an Arms-Length Body to the Department for Education. It is responsible
for buying and developing sites in England to help deliver much needed new school
places for thousands of children. It was commissioned to identify and acquire a site
within Cambridge to facilitate the school, of c.2,450 sq m.
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An extensive site search was undertaken originally in 2017 and a follow up search
in 2018/20 which demonstrated the challenges of land availability and suitability. In
2020, further to this review search (which identified 16 sites), a shortlist of four sites
was drawn up. A high level discussion was then held in March 2020 between
LocatED’s Jacqueline Nixon and the Assistant Director of Planning at GCP
(Sharon Brown) to discuss the four shortlisted sites. The Cambridge North site was
then chosen as the most suitable.
The site is the most sustainably located of all of the sites appraised as part of the
site search. This is due to its proximity to Cambridge North Station and busway
interchange. Maths Schools are expected to have regional accessibility and
therefore this is an optimum location for accessibility and sustainability
Policy 10d therefore needs to recognise the potential to accommodate a Specialist
Maths School within the Local Centre of circa 2,450 sq. m.
Brookgate, in dialogue and agreement with Network Rail, also support the
requirement for the existing station car park to be re-provided in a more efficient
multi-storey car barn as part of a mixed-use higher density development proposal.
This will be included in a future phase of Cambridge North and will involve dialogue
with Network Rail, the Train Operating Company (TOC) and Cambridgeshire
County Council as appropriate throughout the design and planning process.
Policy 10d states that development proposals should consider taking the First
Public Drain overflow out of its culvert which extends into ‘the Knuckle’ (the area
around the bend in Cowley Road) and flows through to Chesterton Fen.
5.15 The FPD overflow is culverted where it crosses the Cambridge North site.
The FPD has already been diverted (and retained in a culvert) as part of the
Cambridge North Station project. Brookgate do not consider it appropriate to carry
out further works on this drainage asset. The culverted section of the FPD through
the Cambridge North site is quite deep and any proposals to ‘open up’ a section of
the drain would be difficult to achieve without steep sided slopes and would
inevitably lead to H&S and maintenance issues in perpetuity. Brookgate is
supportive of introducing ‘soft’ SUDS across the whole of the NEC site and to
provide visual ‘clues’ to how surface water is managed through the introduction of
swales, water bodies and rain gardens. However as discussed above given the
practical issues with the existing FPD diversion we do not consider it appropriate to
‘open up’ this section of the drain.
Policy 10d states that a new public open space (Station Place) along Station
Approach should be provided to create an informal space which offers
opportunities for people to dwell and interact. Brookgate are broadly supportive of
this although the exact siting and quantum of space will need to be determined as
part of the future design and planning process.
The Policy also states that the development and design requirements for the
Station Approach Local Centre includes safeguarding land to accommodate the
CAM (including interim construction site) adjacent to Cambridge North Station to
facilitate a transport hub. Brookgate would welcome discussions with all
stakeholders to understand the extent and scope of land safeguarded in the
context of existing/future development in this area.

Object

Representation ID: 55734

Received: 05/10/2020

Respondent: Brookgate

Agent: Bidwells

The supporting text to Policy 10e states that ‘Beyond the District Centre, a new pedestrian and
cycling bridge will connect over Milton Road to Cambridge Science Park’.

Brookgate do not support the concept of a bridge over the Milton Road corridor, and are surprised
that it is categorically stated in the draft. Brookgate’s transport consultants have consistently
made the case (as have other NEC landowners) during the workshops on the NEC AAP that improvements
to the ‘at grade’ pedestrian and cycle crossings both at the Science Park entrance and the CGB
junction be looked at in more detail before any decision of a bridge is taken forward. Brookgate
had thought that this had been agreed by all parties.

The fundamental targets of the Greater Cambridge Partnership (GCP) is to reduce vehicle movements
into the city centre of Cambridge by up to 20%. This clear policy target should be seen in the
context of highway intervention proposed on the Milton Road corridor. Reduced ‘through traffic’
on Milton Road provides the opportunity to give improved priority to pedestrian and cycle movements
(a key policy of the draft NEC) and to ‘humanise’ the Milton Rod corridor.

A grade separated bridge is an outdated 1960s concept and would create an inhospitable vehicle
dominated spaces at ground level with people ‘inconvenienced’ on detours over bridges, ramps etc.
The proposed bridge on Milton Road is at a location where pedestrians and cyclists need to access
the bridge from the north, south, east and west. How can a bridge facilitate all these
movements with ramps in excess of 100m long?

Object

Representation ID: 55735

Received: 05/10/2020

Respondent: Brookgate

Agent: Bidwells

The Policy states that applications which create new employment floorspace and
promote increased jobs and job densities in the Area Action Plan area will be
supported where they are consistent with the other policies of the Area Action Plan
and adopted Local Development Plan.
Overall, up to 234,500 sqm of additional B1 floorspace is proposed in the NEC AAP
area.
The Policy states that ‘proposals that exceed these figures will need to be justified
in terms of the impact on the trip budget and Area Action Plan wide infrastructure
and where the character, role and function of an area will not be compromised’
Brookgate support the aims of Policy 12a in terms of creating new employment
floorspace and promoting increased jobs and job densities in the AAP area.
However, mix and quantum of new employment floorspace should be informed by
both market conditions and successful place-making. Bespoke solutions to
maximise economic and employment benefits should therefore be secured as part
of individual applications rather than through a generic and inflexible policy
approach.
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Indeed, initial assessment and design work together with its location adjoining an
existing transport hub has indicated that the Chesterton Sidings is capable of
accommodating greater than 36,500 m2 of additional B1 floorspace whilst having
no adverse impact on the trip budget or compromising the character, role and
function of the area.
It should also be noted that as of 1 September 2020, the Town and Country
Planning (Use Classes) (Amendment) (England) Regulations 2020 amend the
Town and Country Planning (Use Classes) Order 1987. Classes A, B1 and D1
applicable to retail, office and non-residential institutions are removed and a new
Class E ‘commercial’ use has been introduced in their place.
The Chesterton Sidings site (Land at Cambridge North) is capable of providing
significant additional capacity of commercial, Class E, floorspace than that
identified in Policy 12a to support the growing office and R&D market, with
associated increase in job creation.
There is a lack of Grade A office space in Cambridge. For the R&D and business
services sector, the location decisional drivers are access and ability to recruit the
right skill sets. Land at Cambridge North provides this, but the lack of available
space and lack of development pipeline puts that resilience at risk and could
undermine the growth of the R&D sector. Developing land at Cambridge North can
help address the demand and supply imbalance for quality office stock by bringing
forward Grade A space in close proximity to an existing transport hub.
A flexible and positive approach to employment growth should also be adopted in
the NEC AAP and considered in light of the CPIER and the target of doubling the
regional economic growth (GVA) of Greater Cambridge over the next 25 years.
This requires the area going beyond what it has achieved in the past (to double an
economy over twenty-five years requires an average annual growth rate of 2.81%.
Historically, since 1998, the local economy has only grown at around 2.5%.).
Achieving this requires employment growth and more importantly productivity
growth, as we are already at comparatively high levels of employment.
The Science and Technology sector is the engine of the Cambridge Phenomenon
that has driven the economy and it will remain an important part of the local
economy and job market. Alongside, it is important to have all types of commercial
space to provide for a wide range of job opportunities and to serve Greater
Cambridge at close quarters to not overly rely on long-distance travel to service the
area with goods and services. Further prime office floorspace in high quality
developments is also needed to consolidate and expand the world class facilities
which have recently put CB1 on the international property investment map.
The CPIER states that locations with high levels of public transport access, such as
Land at Cambridge North, should be identified for businesses with high
employment densities. This would include sites within walking distance of train
stations, travel hubs and along transport corridors.
“by ensuring good quality public transport is in place before development, the
number of those new residents who will use the transport is maximised. This is also
likely to be the best way to stretch some of the high-value businesses based within
and around Cambridge out into wider Cambridgeshire and Peterborough. These
companies will not want to be distant from the city, but these clusters could ‘grow’
out along the transportation links, providing connection to other market towns.”
Taller prime office buildings should be located close to Cambridge North station in
order to focus development at transport hubs; keeping the city compact, but
supporting the demand for high quality office space.