Draft North East Cambridge Area Action Plan

Comment

Representation ID: 55736

Received: 05/10/2020

Respondent: Brookgate

Agent: Bidwells

Neutral:
Policy 12b states that development should ensure there is no net loss of B2 (general industrial)
and B8 (storage or distribution) floorspace in North East Cambridge. It continues in stating that
the redevelopment of existing premises and the provision of new industrial floorspace should
consolidate current activities and promote a mix of uses that includes light industrial, offices,
storage and distribution.

The Policy identifies the following development areas in respect of the Chesterton Sidings site:
● 4,800 sqm of B2 (General Industrial) (min. floorspace)
● 4,000 sqm of B8 (Storage and Distribution) (min. floorspace)

Brookgate are broadly supportive of the aims of Policy 12b in terms of no net loss of B2 and B8
floorspace in North East Cambridge, subject to ongoing market conditions. However, as referred to
under Policy 12a, the quantum and distribution of employment floorspace across the NEC site should
be informed by both market conditions and successful place-making and bespoke solutions to maximise
economic and employment benefits should be secured as part of individual
applications rather than through a generic and inflexible policy approach.

Comment

Representation ID: 55737

Received: 05/10/2020

Respondent: Brookgate

Agent: Bidwells

Neutral:
The AAP makes provision for at least 8,000 net dwellings.
The Policy states that residential units in addition to the table above will need to be
considered alongside the other policies of the Area Action Plan and adopted local
development plan.
Brookgate are broadly supportive of Policy 13a and that the housing provision
figures are regarded as a minimum. It is important to take a flexible and positive
approach and be clear that the AAP does not impose a ceiling on the amount of
housing development that may come forward.
As referred to above, there is a target of doubling the regional economic growth
(GVA) of Greater Cambridge over the next 25 years. In order to deliver this ‘step
change’ in economic performance, there is clearly a need to provide for a high level
of housing to take account of the pressing and worsening affordability issue and to
support the aspiration to grow the Greater Cambridge economy and double the
GVA across the Greater Cambridgeshire and Peterborough area.
The Chesterton Sidings site (Land at Cambridge North) has the potential to
continue the successful transformation of this part of the city and address a specific
need for more housing to serve the private rented sector, thus making a significant
contribution to meeting housing needs within Greater Cambridge in a manner that
would diversify housing choices within the market.

Comment

Representation ID: 55738

Received: 05/10/2020

Respondent: Brookgate

Agent: Bidwells

Neutral:
Policy 13b states that the AAP requires 40% of new homes to be delivered as
affordable housing.
Subject to viability testing, the 40% requirement is supported in terms of being
applied to the NEC AAP as a whole. The very heavy infrastructure costs and
brownfield nature of the land with associated remediation costs must however be
recognised and viability is of key importance.
The Policy also recognises that Build to Rent Schemes deliver fewer than 40%
affordable homes, and that this shortfall needs to be made up for by other schemes
coming forward in North East Cambridge. This fundamentally misunderstands the
contribution BTR makes to housing supply in Cambridge and the LPA must take a
more nuanced approach to housing tenures.

Object

Representation ID: 55739

Received: 05/10/2020

Respondent: Brookgate

Agent: Bidwells

Policy 13c states that Build to Rent (BtR) should be provided in a balanced way
across North East Cambridge without being the dominant typology of homes in any
location to ensure that specific areas contain mixed housing types and tenures. To
achieve this, it is proposed that no more than 10% of the total housing across the
Area Action Plan should be Build to Rent, i.e a maximum of 800 homes across
North East Cambridge. This approach is fundamentally flawed. The 10% cap is an
arbitrary number and is not supported by evidence.
Brookgate support the aims of Policy 13c and the recognition that BtR
developments can play an important role in providing overall housing choice within
North East Cambridge. However, the restriction on the quantum of BtR units and
that they should not be a dominant typology in any location is not supported.
The AAP instead needs to remain flexible in order to be able to respond to change
and take a positive approach to housing development.
BtR housing responds to a particular local housing need and provides a means of
widening housing choice for tenants, particularly those who may be renting long
term, and also to deliver much needed housing within a faster timescale.
Contrary to popular opinion, the private rented sector is not dominated by allstudent
households, which account for only 7.5% of private rented households, as
most students live in dedicated communal establishments. Rather, the Cambridge
private rented sector is quite unique with a population profile characterised by
young adults and many are in professional or other senior occupations, despite the
young age profile.
These young professional households make-up a considerable proportion of the
population and are people who often do not meet the criteria for social rented
housing but cannot afford to buy their own home. The private rented sector can
provide such accommodation.
The redevelopment of Land at Cambridge North offers an opportunity to provide a
significant amount of rented accommodation in a highly sustainable location,
making the best possible use of a brownfield site that is already allocated for
residential development.
The Homes for Londoners Affordable Housing and Viability SPG (2017) confirms
the significant benefits that BtR developments can secure in terms of their
particular contribution to increasing housing supply, as outlined below:
● attract investment into housing market that otherwise would not be there,
particularly since Build to Rent is attractive to institutional investors seeking longterm,
inflation-tracking returns;
● accelerate delivery on individual sites as they are less prone to ‘absorption
constraints’ that affect the build-out rates for market sale properties;
● more easily deliver across the housing market cycle as they are less
impacted by house price downturns;
● provide a more consistent and at-scale demand for off-site manufacture;
● offer longer-term tenancies and more certainty over long-term availability;
● ensure a commitment to, and investment in, place making through single
ownership; and
● provide better management standards and higher quality homes than other
parts of the private rented sector.
Of particular relevance here is the reference to development at scale. In order to be
attractive to investors and in turn ensure the development is commercially viable,
BtR needs to be of sufficient scale and size. This critical mass is also important not
just in terms of the nature of BtR but also in terms of management. Therefore,
pepper potting as proposed in the Draft NEC AAP is the wrong approach. The
approach others are taking, such as the Greater London Authority, demonstrates a
greater understanding of the economics of BtR. More research needs to be
undertaken by the Councils to inform the NEC AAP and to recognise the
contribution that BtR can make in this location.
The Cambridge North site is the optimal location for BtR within the NEC AAP site
given its proximity to the Cambridge North station and transport interchange. This
is a prime requirement for BtR operators.

Support

Representation ID: 55740

Received: 05/10/2020

Respondent: Brookgate

Agent: Bidwells

Policy 13d states that developments including affordable private rent as part of their affordable
housing allocation should demonstrate how these homes will be targeted to meet local worker need.
Development proposals for purpose built Private Rented Sector homes such as Build to Rent, which
are offered to employers within and adjacent to North East Cambridge on a block-lease basis, will
be supported.
Land at Cambridge North has the potential to provide key worker accommodation
to support the concentration of healthcare services in and around Cambridge.

Object

Representation ID: 55741

Received: 05/10/2020

Respondent: Brookgate

Agent: Bidwells

The proposed on-site education provision has been informed by an Education
Topic Paper prepared by the education authority for the area. The Topic Paper
indicates that presently, development at North East Cambridge is not projected to
generate sufficient numbers of pupils to warrant the need for a secondary school
on-site. Nevertheless, for the proper and long term planning of the area, the
Councils consider a cautious approach should be taken and have safeguarded land
for a secondary school if it is needed. This is located within Cowley Road
Neighbourhood Centre alongside a primary school. Local secondary school
provision is to be kept under review throughout the Plan period to determine
whether a secondary school at North East Cambridge is required and when it will
need to be delivered. Based on the housing trajectory for the Area Action Plan, it is
anticipated that if it is required, then it is likely to be delivered towards the end of
the Plan period.
Land at Cambridge North is proposing to include for a Specialist Maths School. 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.
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Policy 14 as currently drafted only provides policy support where there is
recognised ‘local needs’. This is overly restrictive and does not align with the
objectives of the NPPF which is to take a proactive, positive and collaborative
approach to ensuring that a sufficient choice of school places is available to meet
the needs of communities and that LPAs should give great weight to the need to
create, expand or alter schools to widen choice in education (paragraph 94).
It is therefore requested that Policy 14 includes the following wording;
“State funded education infrastructure which is capable of meeting wider regional
needs will also be supported where this is deliverable and sustainable.”

Object

Representation ID: 55742

Received: 05/10/2020

Respondent: Brookgate

Agent: Bidwells

Policy 9 sets out expected building heights and densities across the area and how
the scale and massing (shape) of buildings should consider its impact on the
skyline.
To understand the potential impact of development, the Councils have undertaken
a Landscape Character and Visual Impact Appraisal to inform Policy 9 but are also
commissioning a Heritage Impact and Townscape Assessment to inform a wider
Townscape Strategy for North East Cambridge.
Policy 9 states that ‘development densities and building heights should not exceed
those identified on Figure 21 and Figure 23. Densities and intensification of
appropriate uses will increase around highly accessible parts of the Area Action
Plan area taking into account wider development sensitives, and activity clusters
such as the District Centre and Cambridge North Station.’
Brookgate object to Policy 9 in that the Policy is overly restrictive in stating that
building heights ‘should not exceed’ those identified on Figure 21. 4-5 or 5-6 typical
building height in an area around an existing station and public transport
interchange is particularly low. Figure 21 also fails to take account of the building
heights of the consented hotel and office adjacent to the station (both 7 storeys).
Both of these detailed applications demonstrated through detailed technical
evidence the acceptability of 7 storeys in this location.
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Furthermore, the maximum heights proposed in Figure 21 are assuming a
residential storey height as opposed to an office typical level and do not appear to
allow sufficient additional ground floor height for active frontage and alternative
uses. It should also be noted that office storey heights have recently increased to
be in line with developing national space standards and therefore they may be a
small increase when comparing to existing precedents.
Setting overly restrictive maximum height limits in certain locations and without the
proper consideration of the wider planning potential of development sites and wider
implications of not maximising those opportunities (by displacing development to
other locations that may not be best placed to accommodate it) is a risk to the
current approach set out in the NEC AAP. Such a displacement effect presents a
lost opportunity in key urban areas of high demand for new accommodation,
whether that is for living, working, leisure or other requirements in the built
environment.
With particular reference to Cambridge North, the Site is bounded by the railway
line to the east, the A14 to the north, the Cambridge Science Park to the west and
the suburban Chesterton to the south. The City Centre is some 3.5km from the site.
This physical context presents an opportunity to investigate heights and densities
which might not be supported in other locations in Cambridge: taller buildings
would have no impact on any existing residential properties with regard to sunlight
and daylight but could;
● Make optimal and efficient use of the capacity of the site and release
significant development pressure from the historic core of the City;
● Optimise the effectiveness of substantial investment in public transport
infrastructure and mobility corridors in terms of improved and more sustainable
mobility choices and enhanced opportunities and choices in access to housing,
jobs, community and social infrastructure;
● Create an opportunity to define the north east corner of the City with striking
buildings visible from the A14;
● Support the additional uses and amenities that will make this a selfsupporting
district; and
● Assist in reinforcing and contributing to a sense of place, such as indicating
the main centres of activity, important street junctions, public spaces and transport
interchanges. In this manner increased building height is a key factor in assisting
modern placemaking and improving the overall quality of our urban environments.
The NPPF confirms, at paragraph 118, that planning policies should “give
substantial weight to the value of using suitable brownfield land within settlements
for homes and other identified needs” and “promote and support the development
of under-utilised land and buildings”. The NPPF continues, at paragraph 112, in
advising that planning policies should support development that makes efficient use
of land, taking into account, inter alia, the identified need for different types of
housing and other forms of development, and the availability of land suitable for
accommodating it.
The NEC AAP is the largest brownfield site in Cambridge and is served by
excellent public transport infrastructure. It therefore presents a significant
opportunity to transform into a high-quality gateway to the city and act as a catalyst
for the regeneration of the wider area. Opportunities for densification of existing
urban areas in locations well served by public transport should therefore be
maximised wherever possible.
The tax payer, through the construction of the Station and the relocation of the
water treatment works, will contribute over £300M towards the regeneration of the
area. It is therefore imperative that a proper return is achieved on this massive
investment in the area and if the Mayor’s CAM comes to fruition, further tax payers
monies will be secured.
A high density development would represent efficient use of land in a sustainable
location and create the opportunity for people to live close to where they work. A
higher density of people also helps to form a critical mass and sense of place to
support the range of ancillary retail uses, services and facilities that would come
forward alongside the residential and employment accommodation.
The need for densification in urban parts of Cambridge and adjoining transport
hubs is also supported by the Cambridge and Peterborough Independent
Economic Review (CPIER), published in September 2018. One of the key
recommendations from the review, at 2.3, is to consider some densification,
particularly in Cambridge, away from the historic centre, and more on the edges, as
and where new development sites comes forward. The CPIER report specifically
states that the east side of Cambridge offers significant scope for housing and
commercial development:
“Such development would have the advantage of being close to the principal
centres of employment and the existing rail infrastructure whilst also opening up
opportunities for new transport links to connect the main centres of employment
more effectively. Most significantly, it includes land which has previously been
safeguarded for development and is within the boundaries of the existing urban
area so would proving opportunities in line with the existing spatial strategy.”

Comment

Representation ID: 55743

Received: 05/10/2020

Respondent: Brookgate

Agent: Bidwells

Neutral:
Policy 8 sets out how the AAP area is proposed to create a functional and beautiful
open space network, including improving existing open spaces and making the
most of assets such as the First Public Drain. Regard is proposed to be had to the
Cambridge City local standards of provision of all relevant types of open space
(see Cambridge Local Plan 2018, Appendix I or any future replacement) and the
Councils’ open space and sports strategies, where applicable.
Policy 8 states ‘for development proposals requiring the provision of strategic open
space, this must secure in the first instance the siting and amount of strategic open
space shown in Figure 19’.
The expectation is that all open space requirements will be met on-site. However,
Policy 8 states that any underprovision in the total amount of strategic open space
required of a development, beyond that provided as per Figure 19, can be met
through new or enhanced offsite provision, including:
● Bramblefields Local Nature Reserve (way-finding)
● Milton Country Park (increasing capacity and way-finding)
● Chesterton Fen (way-finding and accessibility to River Cam including
pedestrian and cycle bridge crossing over railway)
The potential locations for off-site provision are broadly supported but this should
not preclude alternative off-site locations coming forward.
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For non-strategic open space requirements, where there are deficiencies in certain
types of open space provision in the area surrounding a proposed development,
the Councils will seek to prioritise those open spaces deficient in the area.
The regard to the Cambridge City Council standards is broadly supported but
applying the standards uniformly across the NEC AAP area fails to recognise the
very different character and functionality of public open space around a major
transport interchange and its hinterland. There are numerous examples of
successful urban schemes where public open space has been limited in terms of
quantum but is of high quality. Small intimate spaces often create the most
successful urban experiences.
The emerging Cambridge North proposals accommodate an area of public open
space broadly in the location of ‘Station Place’. However, it should be stated that
Figure 19 is indicative only and development proposals should instead be informed
by successful place making with solutions to open space and public realm secured
as part of individual applications rather than through a strict policy approach.
The proposals for the next phases at Cambridge North offer a series of public open
spaces, creating a green network that would include:
● The existing public realm at Cambridge North Station and extension of the
tree avenue along Cowley Road;
● A central triangular park of informal open space, south of Cowley Road;
● A green hub at the ‘knuckle’;
● A spine of linear green spaces, north of Cowley Road; and
● Secondary pocket parks, green walking routes, areas of natural and equipped
children’s play spaces, and private communal garden and rooftop amenity spaces.
These spaces will form a comprehensive, high quality landscape, that integrates
with the proposed new residences, shops, cafes and offices. Cambridge North
proposals to the north of Cowley Road, still the in early stages of design, will
ensure that new green spaces form a coherent and legible network with other AAP
proposed spaces and wider existing spaces such as Milton Park. Green
infrastructure proposals would comprise a balanced mix of planting, tree
infrastructure, amenity lawn, biodiverse rooftop planting, and hard materials in
order to complement and assimilate the building structures into the site and local
context; the use of high quality hard materials; a range of street furniture with
multiple seating areas; vibrant planting mixes; and trees of varying levels of
maturity, including specimens at key junctions.
In regards to qualitative elements of Policy 8, in addition to the high standards of
quality, the green spaces will generally reach standards for low maintenance, water
efficiency use and climate resilience, through careful selection of materials and
plant species and through well-considered maintenance specifications. The green
spaces will be publicly accessible and appealing throughout the year, with some
exceptions within the residence courtyards and rooftops.
In terms of the reference to the ‘retained and enhanced landscape buffer to
infrastructure’, shown on Figure 19, and the provision within Policy 8 to protect this
area for the purpose of environmental amenity and landscaping, again it should be
acknowledged that Figure 19 is indicative only and bespoke solutions are capable
of being delivered under individual applications.
Furthermore, it is assumed that this ‘buffer’ includes the area between the bus road
through the Cambridge North site and the station. We support the principles here
of, ‘no development’ on this section of land however the emerging proposals for
management of surface water on the Cambridge North site include some SUDS
(swales) within this area. We consider that these proposals are appropriate for
this area of the site and would suggest that the use of SUDS measures be included
in the list of supported ‘ancillary development’ in these areas.

Comment

Representation ID: 55744

Received: 05/10/2020

Respondent: Brookgate

Agent: Bidwells

Neutral:
Policy 5 sets out how new development will achieve biodiversity net gain and
measurably improve the biodiversity network across the wider area. It states that
development proposals will be required to deliver a minimum of 10% net gain in
biodiversity value and shall follow the mitigation hierarchy.
Where on-site provision is not feasible, greenspace and biodiversity enhancement
will need to be provided in alternative ways and/or accommodated off-site. The
Councils are proposing a sequential approach to mitigating adverse impacts on
biodiversity resources. This is proposed to be achieved on-site in the first instance
and then in areas adjacent to North East Cambridge, such as Milton Country Park
and Chesterton Fen, before considering wider mitigation measures across the city
and further afield.
As referred to under question 7 in respect of Policy 8, the potential locations for offsite
provision are broadly supported but this should not preclude alternative off-site
locations coming forward.
Brookgate broadly support Policy 5. They acknowledge that the existing local policy
framework supports the 10% biodiversity net gain requirement even though the
legislative framework is not yet in place. The proposals for the next phases at
Cambridge North will be able to meet or exceed this target and follow the mitigation
hierarchy. Furthermore, green corridors will be designed into the Site to contribute
to the creation of a coherent on-site and off-site, high quality ecological network,
particularly along the rail corridor N/S axis. The existing vegetation along the
guided busway, the northern boundary of the Site and the narrow corridor along the
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railway fencing are the key features that the Cambridge North proposals will work
with.
On-site mitigation should however be reflective of the baseline ecological
conditions. For example, at Cambridge North where the railway sidings context has
created habitat that is unusual within the AAP area, mitigating for open mosaic
habitat (OMH) is required and this necessitates mainly brown roof planting mixed
with a small proportion of green roof.
Brookgate acknowledge the sequential approach to mitigation set out in Policy 5,
with off-site measures to form part of the mitigation strategy and the aspiration to
agree improvement projects with the Councils which could include enhancements
to Milton Country Park and/or Chesterton Fen. Given the habitats present within the
Cambridge North Site, full on-site mitigation is not practicable. However, it is
expected that the AAP developments as a whole may require the identification of
other additional/alternative sites both within the wider local area, and then other
sites elsewhere within Greater Cambridge.
Brookgate recognise the importance of improving the natural environment and
Land at Cambridge North has the potential to provide areas of high quality public
realm which recognises the very different character and functionality of public open
space around a major transport interchange and its hinterland.
The proposed residential and commercial quarters at Land at Cambridge North can
deliver a successful urban scheme where, despite public open space being limited
in terms of quantum can still deliver spaces of high quality, providing green spaces
to relax and socialise. Indeed, small intimate spaces often create the most
successful urban experiences. New areas of green infrastructure also provide
opportunities to mitigate against climate change, through creating resilient new
habitats. Strategic off-site opportunities also offer the opportunity to significantly
increase biodiversity other than providing site specific biodiversity improvements.

Comment

Representation ID: 55745

Received: 05/10/2020

Respondent: Brookgate

Agent: Bidwells

Neutral:
This policy sets out the range of measures that are proposed to be an integral part
of the design of new development proposals, in order to ensure that new
development responds to the climate emergency. These measures are to ensure
that development in North East Cambridge addresses the twin challenges of
climate change mitigation and adaptation, in a way that enhances the
environmental and social sustainability of the development.
Brookgate broadly support Policy 2. However, climate change policy and good
practice is changing quickly, and the Plan will need to build in suitable flexibility to
accommodate these changes within the lifetime of the plan. Climate change
scenarios predict extensive changes by 2050, much of which is dependent on
government and human action so there is substantial uncertainty over outcomes.
Allowing for changing technologies and approaches should also help with viability
as technology and approaches improve and are more widely adopted, thereby
reducing costs. Escalating targets and policies may be able to accommodate these
changes, while providing clarity to developers on the costs of development over
time.
Policy 2, part (b), states that development must be climate-proofed to a range of
climate risks, including flood risk, overheating and water availability. Specific
guidance is then given on how to minimise the risk of overheating and that
overheating analysis must be undertaken to include consideration of future climate
scenarios using 2050 Promethesus weather data. However this data is based on
UKCP09 data rather than UKCP18 climate change projections which are the most
recent data.
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Policy 2, part (b) also states that all flat roofs must contain an element of green roof
provision. This section of the Policy needs to be more flexible to allow on-site
mitigation to be reflective of the baseline ecological conditions. For example, at
Cambridge North where the railway sidings context has created habitat that is
unusual within the AAP area, mitigating for open mosaic habitat (OMH) is required.
The Cambridge North proposals will include a mix of green and brown roof planting
but with the majority being brown roof because this is closer to the OMH habitat
lost. These brown roofs or a combination of brown and green roof planting will form
part of the overall mitigation strategy. Ecologically biodiverse brown roof planting
mixed with a small proportion of green roof is more appropriate for the Cambridge
North Site given the OMH baseline and this is the strategy that the Councils have
approved previously for the consented office and hotel developments.