Question 3: In this chapter have we correctly identified the physical characteristics of the North East Cambridge area and its surroundings?

Showing comments and forms 1 to 16 of 16

Support

North East Cambridge Area Action Plan Issues and Options 2019

Representation ID: 32523

Received: 14/03/2019

Respondent: Prof Aled Jones

Representation:

Yes under current constraints and assumptions.

Full text:

Yes under current constraints and assumptions.

Comment

North East Cambridge Area Action Plan Issues and Options 2019

Representation ID: 32567

Received: 15/03/2019

Respondent: Alison Finn

Representation:

This question asks about the physical characteristics, but none of the headings of information are that. It should be noteworthy that the Stagecoach bus depot is within the area, though the Park and Ride has been moved across the A14.

Full text:

This question asks about the physical characteristics, but none of the headings of information are that. It should be noteworthy that the Stagecoach bus depot is within the area, though the Park and Ride has been moved across the A14.

Comment

North East Cambridge Area Action Plan Issues and Options 2019

Representation ID: 32813

Received: 24/03/2019

Respondent: Dr Robert Norton-Wright

Representation:

Yes, the assessment is largely correct. Especially the permeability issue is a potentially major barrier to encouraging walking and cycling. The guided busway / business park line is currently very limiting in this respect.

Full text:

Yes, the assessment is largely correct. Especially the permeability issue is a potentially major barrier to encouraging walking and cycling. The guided busway / business park line is currently very limiting in this respect.

Support

North East Cambridge Area Action Plan Issues and Options 2019

Representation ID: 32829

Received: 24/03/2019

Respondent: Jeremy Bickerstaffe

Representation:

Yes I believe so.

Full text:

Yes I believe so.

Support

North East Cambridge Area Action Plan Issues and Options 2019

Representation ID: 32839

Received: 24/03/2019

Respondent: Mr Andrew Parker

Representation:

Seems correct

Full text:

Seems correct

Comment

North East Cambridge Area Action Plan Issues and Options 2019

Representation ID: 32850

Received: 24/03/2019

Respondent: Mrs Anna Williams

Representation:

I agree with the majority of the chapter; however I would say that the statement about "local bus connections that focus on providing north-south connections on Milton Road" is not entirely correct as Milton Road itself is not well served. The no. 2 bus turns down Green End Road for example.

Full text:

I agree with the majority of the chapter; however I would say that the statement about "local bus connections that focus on providing north-south connections on Milton Road" is not entirely correct as Milton Road itself is not well served. The no. 2 bus turns down Green End Road for example.

Object

North East Cambridge Area Action Plan Issues and Options 2019

Representation ID: 33092

Received: 25/03/2019

Respondent: Mrs Sasha Wilson

Representation:

I object to the amount of importance that is being given to the Guided Busway when my local bus (Citi2) does the most tortuous journey from Mitcham's Corner to get to Cambridge North Station with many hold ups at the numerous traffic lights.
Also, the number 9 in Milton Road only goes once an hour and no longer goes to Cambridge North Station.
There needs to be more constructive thinking about the public transport system to alleviate the number of cars that use the local roads.

Full text:

I object to the amount of importance that is being given to the Guided Busway when my local bus (Citi2) does the most tortuous journey from Mitcham's Corner to get to Cambridge North Station with many hold ups at the numerous traffic lights.
Also, the number 9 in Milton Road only goes once an hour and no longer goes to Cambridge North Station.
There needs to be more constructive thinking about the public transport system to alleviate the number of cars that use the local roads.

Comment

North East Cambridge Area Action Plan Issues and Options 2019

Representation ID: 33258

Received: 25/03/2019

Respondent: The Master Fellows and Scholars of the College of Saint John the Evangelist in the University of Cambridge

Agent: Savills

Representation:

Surprising that no reference is made to the A14 and the elevated nature of that route at the A10 roundabout. This roundabout and its elevated position is relevant to townscape analysis since it remains an important approach towards the City having regard to the bordering of those of edges with the St John's Innovation Park and the Cambridge Science Park. As such, it is the gateway into North East Cambridge from the trunk road and is a prominent location in that respect.

Note that the Odour Report that has recently been published does not preclude development subject to technical assessments.

Object

North East Cambridge Area Action Plan Issues and Options 2019

Representation ID: 33364

Received: 25/03/2019

Respondent: Mr John Latham

Representation:

No. There is no mention of the lack of Secondary Schools, and those matrked onb the map are incorrectly positioned.

Full text:

Q 2. Is the proposed boundary the most appropriate?

No. The proposed boundary should include the area to the East of the railway line, along Fen Road.

This area has suffered for years from a range of well-known social and related problems. Closure of the level crossing would require that part of Fen Road to be connected to the northern end of Milton Road, or directly to the Milton Road/A14 junction with a bridge over the railway line.

Q 3. Have the physical characteristics of the area been correctly identified

No. There is no mention of the lack of Secondary Schools, and those matrked onb the map are incorrectly positioned.

Q 11. Are there particular land uses that should be accommodated?

Yes, there should be a Secondary School and as much as possible of the area between the railway line and the river should be designated as a Riverside Country park

Q 15. Should clusters of taller buildings for part of the design

Not without very specific constraints on height. Six storeys should be set as an absolute limit.

Q 17. Explore delivery of a cycling and pedestrian bridge over the railway line?

Yes, certainly, but there should also be a new road and bridge to link with Fen Road so that the level crossing can be closed

Q 20. and 21. a and b
No I do not agree with proposals to include low levels of car parking. They will cause the surrounding residential streets to be swamped with displaced cars belonging to residents of the proposed new development.
Car parking provision should be close to one parking space per residential unit. Until adequate public transport is provided it is not feasible to reduce the number of car parking spaces on the Science Park.

Q. 24. Green space
The provision of adequate green space must be explicit, controlled by the City Council and not delegated to developers.

I strongly support combination of all of the proposed elements and rigorous enforcement on developers.

Q. 27. Trip budget and reduction of car use
This can only be affective where a proper system of public transport is in place. That means something other than buses, for example a tram, or if a proper tram cannot be achieved then the 'CAM'. Buses, especially conventional diesel buses, do not provide a viable, sustainable or attractive alternative to cars.
The integration of the AAP with a tramway or CAM is an essential prerequisite. The guided busway in its present form is almost completely irrelevant to what is proposed, other than for a small number of trips from Northstowe, Histon/Impington and Darwin Green/Eddington to the Science Park.

Q. 28. Low and reduced car parking ?
No, see above

Qs. 29 and 30
Yes, cycle parking must be prioritised and made obligatory

Q. 33 Innovative connections between Cambridge North and the Science Park
The guided busway is not adequate or attractive. A tram or CAM is needed.

Q. 37 Industrial uses to be retained?

Existing light industrial uses should be moved next to the A14, facilitated by a new road connection along the top of the site connecting to Milton Road on the A 14 junction. That could include the bus depot. Railway sidings should also be retained for future needs.
Q. 38 Mix of dwelling sizes
Yes, a mix of sizes, and family units should be included. That is essential to achieve a balanced stable community

Q. 39, 40,41 Housing for essential local workers
Yes, certainly. Absolutely vital and should be adhered to and enforced. No side deals for substitution with student accommodation etc.

Q. 43 HMO?
I am not at all convinced by this, so without further detail, no.

Qs 44- 46 PRS
I recommend involving a local housing association.

Q. 51 and 53 and 54
The highest/best local and national standards should be applied, so that no compromises are made away from the largest possible internal space, best direct access to private amenity space, and highest standards of accessibility.

Q. 55
There must be adequate provision for independent retail, which should be prioritised over national chains. There is no need to attempt to duplicate city centre/other major leisure and retail provision.

Q. 57
Use the Trumpington/Eddington models for community centre/library/medical. Include a secondary school. Faiths should be given proper allocation of space.

Q. 59 Space provision: Quality and functionality not quantity
No. Adequate quantity is essential, see above re riverside park.

Q. 67 Net gain in biodiversity ?
Go to Eddington for methods. Appoint an ecology chief for the area from the start.

Q.69 Underground waste system
Yes, again use the Eddington example.

Q. 84 Any other comments
The AAP proposals have evolved into a massive addition to the urban fringe of Cambridge.
There is no acceptable reason why residential building density and height need to be imposed on a scale that is out of character with the rest of Cambridge, on a site which will be visible from various places including the historic and invaluable riverside, parts of the city and Chesterton, and Fen Ditton.
If excessive height and density is the only basis on which funding can be obtained to move the Sewage Works, then it would be better to leave the Sewage Works where it is until an appropriate alternative approach can be found to redevelopment that is not alien to Cambridge.

Object

North East Cambridge Area Action Plan Issues and Options 2019

Representation ID: 33443

Received: 25/03/2019

Respondent: Mr Sohrab Moini

Representation:

The plan is to build 5000 - 8000 houses in this area which will bring a minimum of 15,000 new residents to this area which currently lacks any infrastructure to accommodate such numbers in other scenarios we are looking at double this figure.

All the needs for planning and future expansion of such a development are well documented in Urban Planning guidelines which none were present for discussion and my understanding from my conversations with representatives was that it is panned to heavily rely and borrow from the neighboring residential area.

Full text:

I attended your presentation at Nuns Way pavilion regarding the future of the North East Development of Cambridge.

It was very disappointing to see vague information without details and not honestly sharing information with public. It all seemed a done deal and the consultation felt as tick box exercise.

No feedback was collected at the presentation and I was refereed to a website and email address when I asked how can I comment which is not at all adequate for such large and long lasting development of Cambridge.

By much probing and persistence I found out that the plan is to build 5000 - 8000 houses in this area which will bring a minimum of 15,000 new residents to this area which currently lacks any infrastructure to accommodate such numbers in other scenarios we are looking at double this figure.

The plan on display did not show any of the basic information regarding planning a town which this development by it own means is a small town.

All the needs for planning and future expansion of such a development are well documented in Urban Planning guidelines which none were present for discussion and my understanding from my conversations with representatives was that it is panned to heavily rely and borrow from the neighboring residential area.

This development needs Nurseries, School's, Heath Centres, Shopping Centres, Care Homes, A small Hospital with A&E, Ambulance Stations, Police Station, Library, pubs, Clubs, Restaurants, Parking Facilities, Parks, Library, Community Centres, and many other facilities to make it a striving and self sustaining development not just flats and houses that will all depend on Cambridge City Centre or Milton Village and surroundings.

The traffic from this development is alarming, with the nature of this development being attracting population from outside Cambridge and the prices of properties in Cambridge each house hold will have a least one car and the in the case of many of these houses becoming HMO's and the affordability of the tenants this figures will be significantly higher which all will need parking spaces and additional parking spaces for visitors.

Milton Road and Kings Hedges Road are already under tremendous stress and can not cope with additional traffic. When speaking to the planning representatives they were not keen on my suggestion of connecting Science Park and the proposed development both to the motorway and a road going through the development cross the river to Fen Ditton of McDonalds roundabout connecting North to South Cambridge, the idea of passing through traffic did not go down well.

In conclusion of this consultation I had the feeling that I was just being told that many more houses on the way and the neighboring areas are expected to deal with the consequences.

I am very concerned about this development and it is the right of everyone living in the area to be presented with the Blue Print of this development and be given the true opportunity to debate and comment of the future of the North East of Cambridge which will affect all of us and Cambridge for decades if not centuries .

Object

North East Cambridge Area Action Plan Issues and Options 2019

Representation ID: 33495

Received: 24/03/2019

Respondent: Mr Ben Bradnack

Representation:

There are major physical constraints on 3 sides of the site which severely limit vehicular access to the site, and contribute to Milton Rd congestion

Full text:

Q2: Paragraph 3.6 of the Issues and Options consultation document is not agreed because this paragraph seems to assume that the AAP reflects not only that the land east of the railway is 'different in character' from the AAP area, (which it is) but that this means it can be treated as a separate entity (which it should not be, because of the issue of the only vehicular access to the area being via the Fen Road level crossing). The proposed boundary should therefore include the vehicular rail crossing on Fen Road as a material constraint on what should be permitted in other parts of the AAP area.

Para 7.6 of the consultationdocument refers to changes taking place in rail use, including increases in the north of the city which will inevitably have the impact of increasing train use of the Fen Road level crossing. These changes require consideration of alternative vehicular access to the area referred to (but then precluded from further consideration) in paras 3.6 and 4.7 of the consultation document

Current rail lobby and Lib Dem policy proposals to close the Fen Road level crossing to motor vehicles wouild leave those homes to the east of the railway along Fen Rd without vehicular access, unless opportunties are left open within the eastern section of the AAP to create an alternative vehicular access

Q3: This section fails to identify clearly the major physical constraints on the eastern part of the AAP area which are constituted by the A14, the railway, and constraining features on the south side including Bramblefields, the allotments, the current boundary with the Trinity Farm trading estate, the guided busway and the public drain, which combine to make Milton Rd and Cowley Rd effectively the only vehicular access to this part of the AAP site. These issues are referred to, but not adequately addressed in para 4.12: 'The NEC area has close connections to the A14 trunk road, and the A10, ..... Highway access to the site is mainly served via local junctions off Milton Road. Nuffield Road Industrial Estate is served fromGreen End Road. Parts of the highway network frequently operate at or nearcapacity, particularly in the morning and evening peaks with queuing and delays prevalent on Milton Road, as well as the A10 and A14, particularly at he Milton Interchange to the north'. But

These features are reduced to 'locational context' whereas they are evidently major physical constraints and should be included, referred to and addressed as such. The inference should be drawn that the eastern AAP site will suffer severe constraints on vehicular access to the site which will significantly constrain what development can take place within the AAP area.

Q4: The issues and options identified in this section fail to recognize either the impermeable physical constraints imposed on the original AAP area by the A14, the railway, the current frontier between Nuffield Rd and Cowley Park guided bus route, and the heavily used and frequently gridlocked Milton Road urban highway; or the fact that Milton Rd provides the only vehicular access to the eastern side of the AAP site Only an act of faith will persuade a reader (or, more importantly, an investor) that these constraints can somehow be addressed by more cycling and walking. Making a virtue out of such 'community cohesion' as this lack of permeability may create, appears to be making a silk purse out of a sow's ear. Paragraph 1.13 of the consultation document glosses over contradictions by referencing the Ely to Cambridge Transport study, but this Study does not address the constraints imposed by existing Milton Rd congestion, but only what would be the best development options for the AAP site to minimise transport difficulties. Para 1.13 concedes that 'the Milton Road area is already 'congested', yet it is asserted that the AAP site is 'highly accessible'. The eastern half of the AAP area is only vehicle-accessible via Milton Road. It is therefore by definition 'congested' and not 'highly accessible' . It is not clear that opening up access to the eastern side of the AAP site via Nuffield Rd would improve that situation. An earlier (2002?) proposal to access the eastern side of the site directly from a slip road off the A14 roundabout appears to have been ignored or forgotten.

The 'highway trip budget' proposed is supported 'faut de mieux', but evidence is not forthcoming that development of the eastern part of the site by any combination of residential, commercial or exployment uses can achieve the appropriate level of 'balance' that para 1.12 suggests is required. All uses are likely to have broadly the same consequences in terms of unacceptable levels of congestion unless alternative transport access routes to this part of the site are opened up.

Q5 & Q6: The 'Vision' and 'Objectives' listed constitute a wish-list of desirable aspirations which do not evidently reflect the realities, and particularly the economic or transport realities, of such a heavily constrained site. For example, Objective 5 - integration with surrounding communities - though probably desirable, is likely to be exceptionally difficult to achieve within the eastern part of the AAP area in a context which is so physically constrained, which will be subject to pressures for the community to be extremely self-contained. These constraints are likely to force a high degree of separation on the eastern part of the AAP site, rather than integration with the area surrounding it.

Q14: Cambridge Regional Colege should be a major partner in the development of the AAP site, particularl in respect of the eastern secytion which will require major community develpoment input to achieve a viable community identity, to which CRC could make a significant contribution if it chose to take that responsibility seriously.

Q17: It is important that some form of vehicular mode of crossing the railway is established from within the AAP area, rather than just the cycling and pedestrian bridge proposed in para 6.25. One option would be to establish an access route to the AAP site from the A14 roundabout, and extend this across a bridge to Fen Road . Unless that option is properly considered, it is difficult to attach significance or meaning to the point in para 6.26 of 'an opportunity to reduce the dominance of Milton Rd'. How, if not by introducing an alternative route into and through the AAP site ?. This could also enable reduced pressure on the Fen Rd railway level crossing.

Q25: The chapter on Transport in the Issues and Options consultation paper rests on extremely shaky assumptions and lacks serious supporting evidence that any of the transport proposals being considered in the AAP are attainable. The Ely to Cambridge transport study proposes that 'the development of these sites will need to deliver measures that significantly reduce the car mode share for trips to and from the area through a combination of demand-side mechanisms such as parking restraint, and investment in measures to support non-car transport'. Para 7.2 of the consultation document concedes that 76% of work trips to the North East Cambridge area are currently made by car. There may be 'a real opportunity to improve this situation'; but despite the measures in place in para 7.8, those intended or being undertaken in para 7.5, and those wider improvements listed in para 8.9, the local authorities have not established the actual sustainable transport capacity which these and any other proposed measures will provide either for the Cambridge sub-region as a whole, or for the AAP area in particular, as required by NPPF paras 102,103 and 104 . 'Ambition' such as that referred to in 7.10 in respect of the Mayor's proposals is no substitute for the evidence of what might constitute the optimal possible 'balance' that can actually be achieved in this respect

The local authorities should establish first what sustainable transport capacity exists or can exist, both for this AAP area and for the Cambridge sub-region as a whole, in line with the National Planning Policy Framework

One way to relieve transport pressure on Milton Road could be to create an access to the AAP site directly off the A14 roundabout, which could also provide a bridge across the railway which could relieve the ptressure already experienced by vehicles using the Fen Rd level crossing (see response to qu 17).

Q26: While an ambition to achieve in the AAP area a low share of journeys made by car is supported, very little evidence is presented (or indeed available for comparable developments in our region ?) that this ambition is attainable or compatible with the proposal to develop 8,500 dwellings on the AAP site. Overall sustainable transport levels have never been established on the basis of evidence for the Cambridge sub-region, and until they have been and have been shown to match both existing realities on the ground and what can be sustainable in the future, this aspiration is just that: an aspiration, not evidently attainable

Q27: The 'highway trip budget' proposed is supported. This appears to be the most serious effort that the local aiuthorities have made to 'put transport first' in the the identification of development capacity of sites - an approach which the local authorities should have adopted from the start in identifying and supporting sites for development in their most recent Local Plans by establishing overall sustainable transport capacity across the local authorities' areas and using that information to compare all possible development options.

So this approach is supported 'faut de mieux', despite the fact that evidence is not forthcoming that development of the eastern part of the site by any combination of residential, commercial or employment uses can achieve the appropriate level of 'balance' that para 1.12 suggests is required. While The Ely to Cambridge Transport Study is used to justify a particular balance of uses including substantial residental development, all uses seem likely to have broadly the same consequences in terms of unacceptable levels of congestion of Milton Rd unless alternative transport access routes to this part of the site are opened up. It is not clear why (for example) an alternative access directly off the A14 roundabout has not been given consideration

Q55 & Q56: Responses to these two questions have been linked because both appear to be premised on the same assumption about the economic viability of commercial outlets within the AAP site which are highly questionable. The physical characteristics of the AAP area, and the aspiration (derived to a large extent from that constrained characer) for 'higher levels of internalised trip-making' must surely work against the likelihood of the sort of shopping self-sufficiency which is required to - or could even hope to - 'fully meet local needs' as sought in para 10.1. The record of local shopping centres in Cambridge remaining viable is not robust. It seems extremely unlikely that commercial outlets opetrating within such physical constraints and planning aspirations can hope to be economically viable, much less to be competent to 'fully meet local needs'

Q84: The possibility of moving the activities of Anglian Water away from the AAP site, and the possibility of consolidating their activities on a smaller site, has provided a very welcome stimulus to the local authorities to consider how the whole eastern part of the site might be re-configured. Added stimulus has come from the completion of Cambridge North station, the rerouting of public transport services to visit the new station, and the recent change to enable the City Council and SCDC to act jointly in respect of The eastern part of the AAP development sites.. All this is very welcome and is supported

But the exist ing area is the mess that it is for good reasons, not all of which pertain to the Anglian Water facility being located there, significant though that presence is. Because of its relat ive inaccessibility and the impermeability of its boundaries it is a convenient place to dump less desirable neighbours The area constitutes a hostile environment in itself which invites and encourages various forms of urban detritus: ugly buildings, car parking chaos, roadway congestion, large stretches of land effectively quarantined by lack of proper controls; and transport challenges unmet..

Unfortunately changing such features as Anglian Water Company does not alter the fact that all the original external constraints on the site still apply. These will be exacerbated by any increase in vehicle use of that section of |Milton Road which governs, and is likely to govern, access to the easter part of the AAP site.

Transforming such an unattractive and inherently disadvantaged area into a model of urban regeneration on the scale proposed can only be carried out with a massive investment of financial resources. These are only likely to be forthcoming as part of a level of growth which is fundamentally unattractive to many, and to which it is not evident that Cambridge residents have so far 'signed up' .

So objections are on two broad grounds
1. The inherent difficulties and expense of what is proposed in the 'vision' can only be addressed by raising the resources from levels of urban growth on a wider canvass which local people are unlikely to wish to support
2. The local authorities have not shown that the particular transport challenges which the proposals will pose for Milton Road can be addressed, or will be addressed, until the local authorities achieve a proper understanding of what levels of transport activity the Cambridge sub-region can sustain

Comment

North East Cambridge Area Action Plan Issues and Options 2019

Representation ID: 33552

Received: 25/03/2019

Respondent: Ridgeons Timber & Builders Merchants and Turnstone Estates

Agent: Carter Jonas

Representation:

Generally yes, however it would be beneficial for additional information to be provided regarding environmental constraints associated with Ridgeon's Nuffield Road operations e.g. noise, air quality, odour.

Comment

North East Cambridge Area Action Plan Issues and Options 2019

Representation ID: 33604

Received: 25/03/2019

Respondent: U+I Group PLC

Agent: Carter Jonas

Representation:

We consider it might be beneficial to include more information about the composition of site areas. E.g., on the employment parks, providing details about site area, total floorspace of buildings on the park and the range of authorised planning, estimated no. of employees, audit of authorised car parking spaces, audit of public open space (estimated total hectares). This would help to inform a baseline of land use within NEC, and then contribute in developing future strategy e.g. highway trip budget, employment strategy, connectivity and green infrastructure etc.

It would be beneficial to have mapping information available relating to the environmental constraints identified e.g. noise, air quality, odour, important habitats.

Finally, it would also be beneficial to show the broader extents of key infrastructure for NEC.

Full text:

Introduction

Cambridge City Council and South Cambridgeshire District Council is consulting on Issues & Options for the North East Cambridge AAP. The consultation deadline is 25th March 2019. The draft response on behalf of U+I Group PLC ('U+I') is set out below. U+I have been selected by the landowners Anglian Water and Cambridge City Council as Master Developer for land outlined in red in the accompanying Site Plan ('the Site'). It is noted that Cambridge City Council also own other land beyond the Site, which may be the subject of other representations.

The representations contained herein relate primarily to the development intentions for the Site, but also in the context of the wider AAP area (as sites within the AAP boundary are largely intrinsically linked).

Representations

Question 1: Do you agree with changing the name of the plan to the 'North East Cambridge Area Action Plan'?

It is recognised that there is a need for a collective reference for the AAP area. This will provide consistency and clearer definition as the process evolves. Whilst it is inevitable that sub-areas of the AAP will emerge with different branding names and strategies, this will have more relevance to the individual sub-area concerned, in creating identity when publicising forthcoming planning applications through to marketing/sales disposals.

Question 2: Is the proposed boundary the most appropriate one for the AAP?

Generally, we support the proposed boundary for the AAP area. We would, however, make two observations/comments.

Firstly, it seems logical to include the site of Cambridge Regional College ('CRC') within the boundary. It is noted that in paragraph 3.5 comment is made that it is not expected to undergo major change in the way other sites across NEC are. However, CRC considers itself to be 'one of the best Further Education Colleges in the country for 16-18 year old level 3 achievement and a leading apprenticeship provider, with thousands of full time students and apprentices currently in training'. The significant range of vocational courses it offers could be positively utilised to support the long-term construction process around NEC (e.g. architectural technology, mechanical engineering, electrical, carpentry, bricklaying courses and apprenticeships), and then the on-going operational phases of the different sub-areas of NEC (e.g. from courses relating to biological science for industry, laboratory technicians and computing technologies, to business and catering and hospitality). It therefore has the potential to play an important learning and development role in the future NEC area. The built form of the current campus appears to be relatively low density, with large areas of used for surface level car parking. Buildings are predominantly 2-3 storeys in height. With the transformation of NEC, recognising the different approaches to internalised trips/reduced car parking, and taller buildings, it would seem likely that the estate management of CRC might change in the future, and if so, it should be included in the AAP.

Secondly, we would comment that, owing to the nature of NEC, development is likely to be high density, optimising the use of all land to work efficiently and effectively. The strategy for on-site Public Open Space is likely to focus on qualitative provision, than quantitative, with a stronger emphasis on formal recreational and leisure space than informal open space. Access to the latter however, is likely to be facilitated through new and improved connections to the east (potentially including land to the east of the railway line north of Cambridge North Train Station, to the river) and north (potentially including land to the north of the A14, such as Land to the south of Cambridge Road, and land including/extending Milton Country Park) of NEC. We would therefore simply pose the question about whether there is a need to include within the AAP boundary additional land that could provide informal open space, biodiversity and drainage functions, which might otherwise not be achievable within the single control of the NEC boundary. It is considered that land to the north and east of the current AAP boundary would primarily be used to facilitate access to green infrastructure for NEC.

Question 3: In this chapter have we correctly identified the physical characteristics of the North East Cambridge area and its surroundings?

Generally, yes. However, we consider it might be beneficial to include more information about the composition of site areas. For instance, on the employment parks, providing details about site area, total floorspace of buildings on the park (including extant planning consents) and the range of authorised planning uses e.g. % B1a uses, %B1b uses, estimated no. of employees, audit of authorised car parking spaces, audit of public open space (estimated total hectares). This would help to inform a baseline of land use within NEC, and then contribute in developing future strategy e.g. highway trip budget, employment strategy, connectivity and green infrastructure etc.
We would also note that it would be beneficial to have mapping information available relating to the environmental constraints identified e.g. noise, air quality, odour, important habitats.
Finally, it would be beneficial to show the broader extents of key infrastructure for NEC, including the full Chisholm Trail link (connecting NEC to Cambridge City, and the south of Cambridge (Addenbrookes), committed routes for other new cycle, pedestrian and public transport in and around the City, and the proposed Greenways link to Waterbeach).

Question 4: Have we identified all relevant constraints present on, or affecting, the North East Cambridge area?

In general, yes. However, we note that there is no reference to Archaeology and Heritage, and would suggest that comment is given about this, even if it is considered that NEC has limited archaeological significance. In terms of heritage, whilst we believe that there are no listed buildings, conservation areas, or other notable heritage constraints within NEC, the intention for taller buildings in NEC will need to be more widely considered in respect of longer-distant views and townscape issues (historic core of Cambridge). Taller buildings may also have potential implications for Air Safeguarding Zones (consultation required with Marshall Airport and the Ministry of Defence on structures over 15m in height), and the Mullard Radio Astronomy Observatory (consultation with the University of Cambridge). We acknowledge that the issue of building heights and taller buildings is likely to be assessed as part of the on-going Landscape Character and Visual Impact Assessment that is being undertaken by Cambridge City Council (it is understood that a 'Stage 1' exercise has already been commissioned), and that the findings are then likely to inform future stages of this AAP process.

We would also suggest consideration be given to the inclusion of Green Belt boundaries around NEC. This will help provide clarity to interested parties that all land envisaged for development and associated physical infrastructure will be accommodated on non-Green Belt land. It will also help to provide reassurance that the development aspirations for NEC will not automatically lead to further development beyond the identified boundaries, unless it is deemed to be 'appropriate development' (i.e. not 'inappropriate' as defined in the National Planning Policy Framework'), or that exceptional circumstances are demonstrated in future Local Plans, or a Very Special Circumstances argument is made to support development via a planning application process. In all cases, strict mechanisms for controlling additional future development beyond NEC will apply.

Reference should also be made to the presence of UKPN's overhead power cables (132KV) that span across the AAP boundary. In terms of ensuring optimum reuse of the Site (and indeed other sites, including Cambridge Science Park), we would support a policy seeking their diversion underground.

Question 5: Do you agree with the proposed Vision for the future of the North East Cambridge area? If not, what might you change?

Yes, we support the proposed Vision for NEC. The addition of the word 'culturally' might benefit this Vision further (in the context of 'North East Cambridge - a socially, culturally, and economically inclusive....)

Question 6: Do you agree with the overarching Objectives? If not, what might you change?

Generally, we support the overarching Objectives. The addition of the words 'Natural Capital' might benefit Objective 7 further (in the context of '...connecting and improving biodiversity to achieve a Natural Capital net gain....)

Question 7: Do you support the overall approach shown in the Indicative Concept Plan? Do you have any comments or suggestions to make?

It is noted that the Concept Plan can only be treated as indicative at this stage in the AAP process, until the outcomes of the various Supporting Studies are known (notably Landscape Character and Visual Impact Assessment, Development Capacity Study, NEC AAP Transport Assessment, NEC Development Viability Assessment, NEC Infrastructure Delivery Plan), and wider consultation with relevant interested parties (e.g. landowners, developers, local communities, local authority bodies etc) has been carried out.

We support the residential-led mixed use allocation for the Site. We support the aspiration to create high quality pedestrian, cycle and public transport connectivity across the AAP area. We support the indication that a Mixed Use District Centre will be provided on the Site though we would suggest that its optimal location can only be determined after further study and masterplanning work. There may also be a need to include an additional Mixed Use Local Centre in the northern half of the Site (subject to further Masterplanning and an assessment on accessibility). We support the intention to provide and integrate Green Infrastructure throughout the AAP boundary, but what provision is made (and how/where it will be provided) will need to be determined following further studies/assessment and Masterplanning. Further consideration will need to be given to the suggested Industrial Development Sites in the north east corner of the Site, to understand what the rationale is for proposing to relocate existing industrial land at Nuffield Road and Cowley Road, to another part of the AAP site. It is assumed that the suggestion is made on the basis that it will provide noise abatement from the A14 to the new residential elements of the Site. However, we consider that there may be other more preferable solutions for controlling noise and, in Masterplanning terms it is less desirable bringing industrial-related traffic through a predominantly residential site. In the absence of clear justification for seeking relocation of industrial uses, we cannot support the industrial element of the proposal.

We aren't yet persuaded that the proposed location and quantum of industrial use is optimal. In particular we have concerns that this is currently shown at the furthest point from strategic highway connections. We also believe that different models and formats of industrial development should be further explored, specifically whether this should be concentrated in a single location, or whether it might be incorporated within a mixed-use approach throughout the Site.

We do not necessarily agree that the Site represents the best opportunity with the overall AAP area to accommodate a significant concentration of industrial uses in a single location.

We would suggest that the Cambridge Business Park is shaded as an Opportunity for Employment Intensification.

In addition to our response for Question 2, we would suggest that the CRC land we would suggest that this land is included within the AAP boundary, and that a new shading is applied that refers to an Opportunity for Education Intensification.

Question 8: Do you agree that outside of the existing business areas, the eastern part of the North East Cambridge AAP area (i.e. the area east of Milton Road) should provide a higher density mixed use residential led area with intensified employment, relocation of existing industrial uses and other supporting uses?

Generally, we support the initial development intentions for the area east of Milton Road. It is considered that this area could accommodate a high density mixed use residential-led development following the relocation of the existing Cambridge Water Recycling Centre and other industrial uses (subject to viability and finding suitable relocation site(s)) from the Site. A comprehensive, design-led, approach across the AAP will help maximise the redevelopment potential of a significant brownfield site in a highly sustainable location.

Question 9: Should Nuffield Road Industrial Estate be redeveloped for residential mixed use development?

Yes, we agree that consideration should be given to relocating existing industrial uses on the Nuffield Road Industrial Estate, in preference for higher density residential-led mixed use redevelopment. Consideration should be given to the viability of doing so (industrial land values are currently relatively high), and where existing businesses will be relocated. An Industrial Relocation Strategy might be appropriate, in order to understand what factors are important to businesses e.g. last mile strategies and what alternative sites might be available to accommodate relocation requirements. ]

As outlined in Question 7, the suggestion to relocate industrial uses from Nuffield Road Industrial Estate to the north east corner of the Site needs to be explained and justified. At this stage we do not support the suggestion to relocate industrial uses to the north-east corner of the Site.

Question 10: Do you agree that opportunities should be explored to intensify and diversify existing business areas? If so, with what sort of uses?

Yes, we broadly support this suggestion, subject to the establishment of a robust and equitable approach to Highways Trip Budget apportionment and s106 tariff system across the wider AAP area. The Cambridge Science Park was first established on the principle of accommodating 1-2 storey, low density commercial buildings within an attractive strategic landscape/parkland setting. Whilst much of the strategic landscaping remains, latter phases of the Science Park have sought to intensify development density, with taller buildings, lower car parking provision, and limited on-plot landscaping (other than to lessen/soften the impact of new development). This approach has been complemented by the introduction of Cambridge North Station Interchange, which has significantly improved accessibility via non-car modes. The growth aspirations now anticipated for the AAP area signals a radical change in approach to new development. New residential communities will be supported by existing and intensified employment and educational opportunities, potentially providing live and work/learning opportunities within walking/cycling distance of each other. Furthermore, access to inter alia Cambridge North, the Guided Busway, and the Chisholm Trail will support accessibility to existing business areas from a much wider catchment, therefore helping to improve the means of accessing work without the need to do so by car.

Opportunities to provide a greater quantum and diversity of employment should be encouraged. This will consolidate and strengthen the concept of the Cambridge Phenomenon, by creating a greater range and quantum of high quality accommodation for new businesses, in close proximity to a critical mass of similar businesses, thereby helping to support knowledge sharing and collaboration through co-location.

In order to promote diversity of employment types, planning policy consideration might be given to encouraging a certain percentage of 'affordable employment', to support the growth of new start-up businesses that require the same close links with similar businesses but cannot afford (and do not currently need) accommodation that becomes available.

Question 11: Are there any particular land uses that should be accommodated in the North East Cambridge area?

The North East Cambridge area should support any use that demonstrably contributes to the Vision and Objectives of the AAP area.
The AAP provides a significant opportunity to create thousands of new homes in a highly sustainable location. The growth of housing in this area will be supported by the economic benefits derived from the long-established science, innovation and business parks (many of which will be intensified), that have collectively grown from the success of clustering knowledge-based industries in close proximity of one another. The housing element of the Site will improve supply and affordability of high quality new homes to the many thousands of employees on these parks, helping to reduce the number of car movements on Milton Road. New homes and jobs on the scale envisage will need to be served by a number of social, retail, community, health, education, leisure and recreation facilities,

Question 12: What uses or activities should be included within the North East Cambridge AAP area which will create a district of culture, creativity and interest that will help create a successful community where people will choose to live and work and play?

It is considered that the inclusion of schools, community facilities, retail and leisure uses, open space, and transport services, in conjunction with walking and cycling connections to neighbouring areas will provide the attributes of a successful community.

The NEC AAP must recognise the wider role it plays in creating opportunities for surrounding communities, of which two neighbouring wards - East Chesterton and Kings Hedges - currently suffer from high levels of deprivation (included in the top three of most deprived wards in Cambridgeshire). The benefits of the AAP area should extend to these areas, to create new employment, education, social, leisure and recreation, health and community opportunities. Where new facilities are introduced to areas experiencing deprivation, a key challenge for optimising use of such facilities is affordability. Free or subsidised charging mechanisms should therefore be considered when providing new facilities for instance e.g. hire of sports pitches, meeting rooms etc.

It should, however, be recognised (and indeed it is in Question 79) that the ambitious development aspirations for the Site and wider AAP area will take a number of years to comprehensively plan and deliver. Certain elements will be possible to deliver early. Notwithstanding this, there is the opportunity to introduce 'meanwhile/worthwhile' uses the area as the transition progresses. Meanwhile/worthwhile uses offer creative and innovative ways of optimising sites on a stop-gap basis, creating a temporary opportunity to capture economic and/or social benefits for the wider area in the period between the closure/or reduction of an existing site operation and the commencement of the intended new development.

Question 13: Should the AAP require developments in the North East Cambridge AAP area to apply Healthy Towns principles?

NEC will provide a considerable opportunity for creating a healthy new community, and supporting neighbouring communities, through access to high quality housing, a design approach founded on sustainable modes of travel (walkable neighbourhoods), and improved employment, shopping, health, education, leisure and recreational opportunities. We also support the intended preparation of the Health Impact and Needs Assessment for NEC, which will take account of the wider deprivation challenges faced in the neighbouring wards of East Chesterton and Kings Hedges.

Question 14: How should the AAP recognise and make best use of the existing and potential new links between the AAP area and the CRC (Cambridge Regional College)?

Please see our response to Question 2.

Question 15: Should clusters of taller buildings around areas of high accessibility including district and local centres and transport stops form part of the design-led approach to this new city district?

We strongly support the principle that the greatest development densities should be located in the areas of greatest accessibility and public amenity. This maximises the potential for sustainable travel patterns and establishes a critical weight of local demand for leisure, cultural and retail uses.

It is important to note that 'high-density' does not automatically mean 'tall' and that compact mid-rise development can often be denser than taller development, particular where the latter is compensated for by a smaller overall development footprint. Compact mid-rise also typically enables a wider range of dwelling types and external amenity space, meeting a wider range housing needs.

We favour a 'transect' based approach to masterplanning which will ensure the density, scale, typology, and uses of development are allocated across the site as a whole and within each neighbourhood in a coordinated way, following the accessibility principle described above and responding to the opportunities and constraints of the Site. This may not mean 'clusters' - it could for example mean that the highest densities are located in 'corridors' along the primary streets, and/or at edges where having denser development acts to shelter lower-scale development from adjacent visual or noise intrusion. The masterplan will be backed up by a design code that will identify/mandate appropriate typologies for achieving the requisite densities in ways that are acceptable in other respects.

In addition to accessibility and other local factors, it is important to note that the extent and location of denser development will be affected by a range of detailed studies and appraisals (including Landscape Character and Visual Impact Assessment), that will recognise - and then balance - the challenges of creating areas of higher density and taller buildings in a highly sustainable location that is, nonetheless, on the edge of Cambridge with areas of open countryside beyond. This may also militate against achieving density through height.

Question 16: Should the AAP include any or a combination of the options below to improve pedestrian and cycling connectivity through the site and to the surrounding area?

A - Create a strong east-west axis to unite Cambridge North Station with Cambridge Science Park across Milton Road. This pedestrian and cycle corridor would be integrated into the wider green infrastructure network to create a pleasant and enjoyable route for people to travel through and around the site. The route could also allow other sustainable forms of transport to connect across Milton Road.

Yes. A strong east-west axis should be included to connect the different parts and proposed uses within NEC, and to encourage movement within the site by sustainable modes of transport.

B - Improve north-south movement between the Cowley Road part of the site and Nuffield Road. Through the redevelopment of the Nuffield Road area of NEC, it will be important that new and existing residents have convenient and safe pedestrian and cycle access to the services and facilities that will be provided as part of the wider North East Cambridge area proposals.

Yes.
C - Upgrade connections to Milton Country Park by both foot and cycle. This would include improving access to the Jane Coston Bridge over the A14, the Waterbeach Greenway project including a new access under the A14 (see Transport Chapter), as well as the existing underpass along the river towpath.

Yes. It is considered that improvements to connections with Milton Country Park and with existing and proposed pedestrian and cycle routes will be important for the success of development within the AAP. It is anticipated that NEC will provide a high density residential development, to take advantage of the close proximity of employment areas and public transport services, but which might limit opportunities for large scale open space/recreation areas. Therefore, it will be important to ensure that any proposal for an underpass will maximise connectivity through the Site, capitalising on permeability and wider Green Infrastructure initiatives (e.g. Waterbeach Greenway, Chisholm Trail, improving the public realm function of the 1st Drain etc).

D - Provide another Cambridge Guided Bus stop to serve a new District Centre located to the east side of Milton Road.

We support the suggestion to improve public transport accessibility around NEC but further work should be undertaken to determine whether an additional 'guided' busway stop is required or whether a 'normal' bus service, which could feasibly use the same buses as those on the Busway, could deliver the same benefits.

E - Increase ease of movement across the sites by opening up opportunities to walk and cycle through areas where this is currently difficult, for example Cambridge Business Park and the Cambridge Science Park improving access to the Kings Hedges and East Chesterton areas as well as the City beyond.

We very much support opportunities to increase the ease and convenience of walking and cycling movements across sites in NEC, as this will strengthen the concept of promoting internalised trips and reduce the reliance on travel by car.

Question 17: Should we explore delivery of a cycling and pedestrian bridge over the railway line to link into the River Cam towpath?

It is noted that the River Cam towpath is identified as a route within the Waterbeach Greenway project, and it would be appropriate to take the opportunity to provide a pedestrian and cycling connection from this route into NEC, subject to the availability of funding.

The high density redevelopment of NEC is unlikely to achieve the level of Public Open Space that might otherwise be required under local plan policy. The focus is instead likely to be on securing high quality, flexible-use open space on-site, and improving/providing new connections to informal open space networks to the north and east of the AAP area (including the Waterbeach Greenway). Accordingly, an appropriate means of accessing off-site Green Infrastructure for NEC will be required, and the suggestion of a pedestrian/cycle bridge would facilitate this.

Please see our responses to Questions 2 and 7.

Question 18: Which of the following options would best improve connectivity across Milton Road between Cambridge North Station and Cambridge Science Park?
A - One or more new 'green bridges' for pedestrians and cycles could be provided over Milton Road. The bridges could form part of the proposed green infrastructure strategy for NEC, creating a substantial green/ecological link(s) over the road.
B - Subject to viability and feasibility testing, Milton Road could be 'cut-in' or tunnelled below ground in order to create a pedestrian and cycle friendly environment at street level. This option would allow for significant improvements to the street which would be more pleasurable for people to walk and cycle through.
C - Milton Road could be significantly altered to rebalance the road in a way that reduces the dominance of the road, including rationalising (reducing) the number of junctions between the Guided Busway and the A14 as well as prioritising walking, cycling and public transport users.
D - Connectivity across Milton Road could be improved through other measures. We would welcome any other suggestions that would improve the east-west connectivity through the site.
E - Other ways of improving connections (please specify)

In response to all five options listed above, we generally support the principle for securing high quality east-west connectivity. However, the means of crossing Milton Road will involve a range of complex issues, which cannot be determined at this stage. The crossing solution(s) should not ultimately be compromised by concerns about short-term disruption and inconvenience. The east-west axis will be fundamental in the overall success of NEC, and the justification for internalising trips will be partly made on the basis that pedestrian and cycle connectivity across NEC will be safe and convenient (and therefore likely to be commonly used as a means of travel).

Option A is considered to be the preferred option as it provides the opportunity to create a substantial green link over the road without adversely affect the flow of traffic on Milton Road, which has existing network capacity issues. It will also limit the impact on the operation of the Milton Road during construction when compared with either Option B and C.

Option B would likely result in significant disruption to the road network during construction and would likely require the lowering or redirecting or Statutory Undertakers Utilities. Both Option B and C would result in alterations to the access junctions into the Science Park and the Site, both of which have limited access opportunities for their respective sizes.

Question 19: Should development within the North East Cambridge area be more visible from Milton Road, and provide a high quality frontage to help create a new urban character for this area?

We generally support the suggestion of making new development within NEC more visible from Milton Road and providing a high quality frontage to create a new urban character for the area. Milton Road is currently a highly car dominated environment, with a number of confusing junctions serving Cambridge Science Park and Cowley Road. However, it is noted that Milton Road acts as a key north / southbound route into and out of Cambridge, and the Milton Interchange forms part of the Strategic Road Network and connects Cambridge to the A14 (a major east to west route, which has recently been upgraded to improve capacity). Given the level of traffic using this stretch of the Milton Road to access the Strategic Road Network at this location, the potential to reduce traffic to provide a high quality new urban character for the area may be limited in the short term. Notwithstanding this, where Milton Road runs southwards the nature of the road starts to change and becomes more urban in nature, potentially becoming more conducive to active frontage and activity on the footway.

Question 20: Do you agree with proposals to include low levels of parking as part of creating a sustainable new city district focusing on non-car transport?

Yes, we generally support this principle NEC provides an opportunity to reduce levels of parking, as part of a package of transport measures including new and additional walking and cycling routes, public transport services, and car share schemes. However, we would also suggest that interim car parking strategies might need to be considered, to support 'pioneer' uses/development during transitional phases of NEC i.e. until the full package of transport infrastructure and initiatives can be fully realised. As new infrastructure/initiatives are introduced, interim car parking can be gradually phased out.

Question 21a: In order to minimise the number of private motor vehicles using Milton Road, should Cambridge Science Park as well as other existing employment areas in this area have a reduction in car parking provision from current levels?

We very much support opportunities to reduce the reliance on travel by car in and around NEC, and instead increase the ease and convenience of walking and cycling movements across sites in NEC, as this will strengthen the concept of promoting internalised trips.

Question 21b: Should this be extended to introduce the idea of a reduction with a more equitable distribution of car parking across both parts of the AAP area?

Yes, as part of a package of transport measures to encourage travel by sustainable modes of transport.

Question 22: Should the AAP require innovative measures to address management of servicing and deliveries, such as consolidated deliveries and delivery/collection hubs?

Yes, subject to further understanding of the requirements of businesses and the needs of residents. The North East Cambridge area could include a number of delivery/collection hubs.

Question 23: Should development within the North East Cambridge area use car barns for the storage of vehicles?

We support the idea of using car barns, as part of a wider package of parking solutions across NEC. Whilst it is recognised that private on-plot parking is unlikely to be widely encouraged, there will inevitably be demand from some residents to have access to the use of a car/secure car parking but this should be priced accordingly to the end user. Car barns provide communal access to parking, and are typically located in less convenient locations in order to discourage frequent use. As an example, if a car was needed to do a weekly shop, the resident would park outside their property to unload their car and then move the car to a car barn. Car barns can also be used by 'car clubs', so that a resident can book a car for a certain period of time but not have the long-term cost and use commitment to owning a private car. The versatility of car barns should also be recognised, as parking can be let on a temporary basis and, as trends change, can be converted into alternative uses to reduce car usage further.

Question 24: Within the North East Cambridge area green space can be provided in a number of forms including the following options. Which of the following would you support?
A - Green space within the site could be predominately provided through the introduction of a large multi-functional district scale green space. Taking inspiration from Parker's Piece in Cambridge, a new large space will provide flexible space that can be used throughout the year for a wide range of sport, recreation and leisure activities and include a sustainable drainage function. The sustainable drainage element would link into a system developed around the existing First Public Drain and the drainage system in the Science Park. The green space could be further supported by a number of smaller neighbourhood block scale open spaces dispersed across the site.
B - Green spaces within the site could be provided through a series of green spaces of a neighbourhood scale that will be distributed across the residential areas. These green spaces will also be connected to the green infrastructure network to further encourage walking and cycling. Again, these spaces will include a sustainable drainage function and link into the existing First Public Drain and the Science Park drainage system.
C - Enhanced connections and corridors within and beyond the site to improve the biodiversity and ecological value as well as capturing the essential Cambridge character of green fingers extending into urban areas. These corridors could also be focussed around the green space network and sustainable drainage and would reflect the NPPF net environmental gain requirement.
D - Green fingers to unite both sides of Milton Road and capitalise on the existing green networks.
E - Consideration of the site edges - enhancement of the existing structural edge landscape and creating new structural landscape at strategic points within and on the edge of NEC. This would also enhance the setting to the City on this important approach into the City.
F - Creation of enhanced pedestrian and cycle connectivity to Milton Country Park and the River Cam corridor.

In response to all six options listed above, we support the principle for securing high quality green infrastructure across NEC. Subject to further capacity testing and Masterplanning, on-site provision might feasibly take the form of a larger green space for the whole NEC and complemented by smaller 'neighbourhood scale' spaces and enhanced connections and corridors to off-site green infrastructure. We aren't persuaded that Parkers Piece is an appropriate comparable for the size and function of this space but do consider that the green space should draw lessons from existing green spaces in Cambridge. However, in supporting the theme of innovation at all stages of the development it will be important to consider smart solutions for the open space strategy, maximising flexibility across all areas of on-site open space. For instance, playing fields associated with on-site school provision should be available to the wider community, at times when it is not required by the school. Management and security issues will need to be carefully considered in this regard. Landscape vegetation should encourage biodiversity, whilst also performing softening/screening functions. Formal playspace should be able to accommodate multi-use activities during the day and evening and throughout the year. Green infrastructure might incorporate elements of food growing e.g. fruit trees, herbs, and vegetables, enabling free access to foods that help promote healthier lifestyles.

In terms of the suggestion of how open space will be provided (and in what format and amount), this cannot be determined at this stage of the process. A series of studies and assessments have been or are being commissioned by Cambridge City Council, which will help inform development principles and Masterplanning. Consultation will also need to be carried out with a number of interested parties, including landowners, developers, local communities and local authority bodies. Therefore, we are neither supporting nor objecting to any of the suggested options at this stage.

Question 25: As set out in this chapter there are a range of public transport, cycling and walking schemes planned which will improve access to the North East Cambridge area. What other measures should be explored to improve access to this area?

We generally support the suggested options for improving public transport, cycling and walking accessibility around NEC. The proposed Waterbeach Greenway should be directed through the Site, to create a coherent route from Waterbeach to the station. This will allow future residents of the Site to cycle to the station helping to providing a means of travel for the 'first mile / last mile' of the journey to / from the station.

A new route for a busway from the proposed Waterbeach development should be routed through the Site down to Cambridge North Station. Stops on the route could form transport interchanges linking to other bus routes and cycle routes. High quality cycle links should be implemented to connect into existing infrastructure such as the Chisholm Trail.

The route of these two transport spines through the Site will help develop a single coherent sustainable transport corridor down to the station allowing seamless interchanges between transport modes where the routes intersect with one another. The interchanges will be located within a high-quality urban environment close to high density district centres and attractive locations encouraging linked trips and improving access to the district centres by public transport.
It will important to ensure that consideration is always given to promoting access beyond the AAP boundary (as currently shown), such as recognising the education/social role that CRC plays in the west, the retail and leisure/recreational/biodiversity roles of Tesco and Milton Country Park in the north, the leisure/recreational/biodiversity role of the river and green corridors in the east, and the existing Cambridge communities in the south.

Question 26: Do you agree that the AAP should be seeking a very low share of journeys to be made by car compared to other more sustainable means like walking, cycling and public transport to and from, and within the area?

We support the concept of encouraging a greater share of non-car modes of travel for NEC, but note that it is a concept that will need to be accepted by all landowners/occupiers in the AAP boundary in order for it to be successfully implemented. This is broadly in accordance with the advice from the Ely to Cambridge Transport Study, and will be further tested in the NEC AAP Transport Assessment work (due to be commissioned).

Question 27: Do you have any comments on the highway 'trip budget' approach, and how we can reduce the need for people to travel to and within the area by car?

We support the principle of a 'trip budget' as there is limited scope for large scale engineering interventions to create more capacity on the road network. However, the trip budget must be carefully considered and tested to ensure that it is both suitable and realistic. Appropriate measures will need to be employed if the trip budget is exceeded. The monitoring process will need to be carefully considered, as various land uses across the AAP site will be allocated a share of the trip budget.

Question 28: Do you agree that car parking associated with new developments should be low, and we should take the opportunity to reduce car parking in existing developments (alongside the other measures to improve access by means other than the car)?

We generally support the concept of encouraging a greater share of non-car modes of travel for NEC. This is broadly in accordance with the advice from the Ely to Cambridge Transport Study, and will be further tested in the NEC AAP Transport Assessment work (due to be commissioned). It is recognised that many existing employment uses, such as those in Cambridge Science Park, St John's Innovation Park and Cambridge Business Park, will have authorised car parking at significantly higher levels than what is now intended for NEC. We would support the Councils working with various landowners in exploring innovative/incentivised ways of reducing car usage from those sites.

Question 29: Do you agree that we should require high levels of cycle parking from new developments?

We support the suggestion of requiring high levels of cycle parking from new developments. This approach will be supported by the new cycling infrastructure that is planned for Cambridge, including the Chisholm Trail and Waterbeach Greenways. Cycling helps support healthy lifestyles, and is a viable means of travelling around a compact city, assuming that safe and convenient routes and secure/covered parking can be provided. New and existing workplaces can be encouraged to provide showers, changing facilities and lockers to encourage staff to cycle into work.

Question 30: Should we look at innovative solutions to high volume cycle storage both within private development as well as in public areas?

Cycling is key to achieving a mode split and demand must be met, and therefore we support the suggestion of innovative solutions to cycle parking. As part of further capacity testing, Masterplanning and detailed design, consideration will be given to innovative storage solutions (using domestic and international examples) that enables cycle parking to be integrated appropriately into the public realm. The concept of micromobility should also be embraced, with provision made for parking dockless bikes to ensure that they are not left in inconsiderate locations such as the footway.

Question 31: What additional factors should we also be considering to encourage cycling use (e.g. requiring new office buildings to include secure cycle parking, shower facilities and lockers)?

New office buildings should include covered, secure cycle storage, showers and lockers. The cycle parking should also be conveniently located at basement/ground floor level or within easy access of lifts capable of transferring bikes between levels. Where possible segregated access for cyclists should be provided to minimise the conflict with pedestrians and vehicles accessing buildings.

Question 32: How do we design and plan for a place that makes the best use of current technologies and is also future proofed to respond to changing technologies over time?

Energy strategies
We will expect development on the Site to have a very low 'in use' energy demand, through robust design of built fabric and services. This will make it easier to meet more of the scheme's energy demand from renewable and low carbon energy sources - and in some case may allow a 'net positive' energy balance to be achieved. Implications for wider energy networks should also be considered, with consideration of energy storage and demand control options at building and community level.

Form and fabric

Development within the Site will be designed, at both masterplan and building scale, to result in minimal energy use through sensitive consideration of site conditions and a robust approach to fabric performance, using passive design strategies to achieve good comfort, day-lighting and air-quality.

Building services

Developments should ensure they build on high quality design of form and fabric by specifying robust and efficient building services. If care has been taken in the design of the built fabric, it should be simpler for efficient building services to meet the needs of those who live and work in a building.

Energy generation and supply

Once the gross energy demand for the proposed development has been reduced through efficient built form and services, it will become possible to evaluate how a greater proportion of its needs can be met through renewable and low carbon energy sources.

Provision for electric charging points for vehicles should be implemented to ensure that both residents and workers have access to electric car charging points. Way-finding points and real time journey time information should be implemented across the Site to ensure people have accurate up to date travel information.

Delivery hubs should be provided on the periphery of the site to intercept large delivery vehicles from accessing the site. This will also help to consolidate deliveries and reduce the need for large vehicles to enter the Site, with smaller electric vehicles providing the final leg of the journey to the front door of the residence or workplace.

Subterranean bins should be provided on the Site to minimise space requirements for waste storage and provide a secure location for the bins.

Question 33: What sort of innovative measures could be used to improve links between the Cambridge North Station and destinations like the Science Park?

It is considered unlikely that an at grade crossing can be located to link the Science Park with the station due to capacity constraints on Milton Road. A well-designed overpass for pedestrians and cyclists may provide the best option to effectively reduce severance caused by Milton Road and link the station with the Science Park. The journey from the station to the Science Park, will be the last / first mile of commuter journey and micromobility solutions such as dockless e-bikes should be provided to support the movement on this link.

Question 34: Are there specific types of employment spaces that we should seek to support in this area?

The knowledge-based cluster around Cambridge Science Park, St John's Innovation Park, and Cambridge Business Park is internationally recognised, and the significant economic role that it offers to NEC must be fully harnessed to encourage complementary industries (Artificial Intelligence, R+D and laboratories for smaller emerging businesses that need the cluster benefits, maker-space etc) and optimise further employment opportunities. We would therefore expect a range (in terms of use and size) of employment spaces across NEC, including Science, Research & Development and Technology-related employment. However, in advocating innovation throughout NEC, policy limitations should not be imposed that unduly restrict any particular use at this stage.

Question 35: In particular, should the plan require delivery of:
A - a flexible range of unit types and sizes, including for start-ups and Small and Medium Sized Enterprises (SMEs);
B - Specialist uses like commercial laboratory space;
C - hybrid buildings capable of a mix of uses, incorporating offices and manufacturing uses.
D - shared social spaces, for example central hubs, cafes.
E - Others (please specify).

We generally support all of the suggested options at this stage, and would seek inclusion of corporate headquarters within category A. These options should equally be applied to proposals for meanwhile/worthwhile uses, in order to optimise economic development benefits and promote innovation at the earlier stages of the development process for NEC.

Question 36: Which of the following approaches should the AAP take to existing industrial uses in the North East Cambridge area?
A - seek to relocate industrial uses away from the North East Cambridge area?
NEC represents a significant and unique opportunity to create a new and innovative high-density, high quality, mixed use Quarter for Cambridge and its surrounding area. The opportunity is dependent on Housing Infrastructure Funding that will facilitate the relocation of the Water Treatment Works, and optimise the quantum of new housing across the Site. Whilst it is recognised that other, non-residential uses, will also be needed in NEC in order to promote multi-functioning mixed communities and internalised trips, capacity testing and Masterplanning will need to carefully identify what uses (and how much) will be appropriate. Whilst the prospect of utilising some of the Site for industrial use has not, at this stage, been discounted, justification for the need and location of such a use will need to be very carefully considered. A greater understanding of industrial need is therefore required, and in particular how essential it is for certain businesses to be in Cambridge. Consideration should also be given to whether existing businesses are compatible with residential neighbourhoods, as if so, there may be scope to incorporate industrial (i.e. b1c) accommodation within a mixed use development. This might, for instance, include ground floor workshops/maker spaces where noise, odour, other forms of pollution, and type of deliveries will not give rise to unacceptable living conditions for neighbouring properties. For existing businesses where there is not a demonstrable need to be in Cambridge, relocation options outside the NEC should be considered.

B - seek innovative approaches to supporting uses on site as part of a mixed use City District?
See response to A, above.

Question 37: Are there particular uses that should be retained in the area or moved elsewhere?

See response to A, above. The AAP should set out the strategy for determining the needs of individual businesses (and whether there is an operational imperative to be closely related to Cambridge, and how the relocation of existing industrial uses can be appropriately implemented..

Question 38: Should the AAP require a mix of dwelling sizes and in particular, some family sized housing?

The residential ambitions and opportunities in NEC (and particularly the Site) will need to be fully understood and embraced in order for the Vision and Objectives of the AAP to be realised. For the high density levels of new housing envisaged, innovation will be essential at all stages and in all forms. Traditional approaches to housing in Cambridge are unlikely to be appropriate. Housing will be made available for a much wider market than might otherwise be expected for a new settlement/strategic urban extension elsewhere in the county (e.g. Northstowe, Waterbeach, Cambourne), including that which is more aligned to smaller household sizes e.g. students, post-graduates, young professionals, and older persons looking to downsize. Where family housing is to be provided, it will require 'smarter-space' solutions to reflect the Site-wide high density approach.
A greater understanding of need and demand, market trends and viability will be needed to define housing requirements for NEC in later stages of the AAP process.

Question 39: Should the AAP seek provision for housing for essential local workers and/or specific housing provided by employers (i.e. tethered accommodation outside of any affordable housing contribution)?

Yes, see response to Question 38.

Question 40: Should the AAP require 40% of housing to be affordable, including a mix of affordable housing tenures, subject to viability?

We generally support the suggestion of having a challenging target for the provision of affordable housing. There is a chronic shortfall of affordable housing in South Cambridgeshire and Cambridge City, and the residential growth aspirations of NEC could make a significant contribution in reducing housing shortfall. It is also important to ensure that there are a range of homes of different sizes and tenures to achieve mixed and balanced communities. However, it is also important to ensure that the policy is sufficiently flexible to address viability challenges, and takes a pragmatic approach when recognising how different types of housing are provided and thereafter managed and maintained e.g. less reliance on traditional approaches of 'pepper-potting' etc. There is a significant cost in delivering the level and type of development envisaged and it will be essential to ensure that delivery of the development can be secured on a viable basis. Consideration must also be given to exploring other means of making housing more widely accessible, such as through PRS for instance.

Question 41: Should an element of the affordable housing provision be targeted at essential local workers?

We generally support this suggestion, but a more detailed understanding of housing need and demand in the area, and indeed an understanding of what key employers in the area require, should be undertaking before developing an AAP-specific affordable housing policy.

Question 42: Should the AAP require a proportion of development to provide custom build opportunities?

We generally support this suggestion, but again a greater understanding of demand, need and viability is required. Consideration should be given to examples where successful custom-build housing has been delivered, such as Marmalade Lane, Cambridge's first co-housing community made up of 42 custom build homes.

Question 43: Should the AAP allow a proportion of purpose built HMOs and include policy controls on the clustering of HMOs?

We support the suggestion of creating more shared living and co-living housing opportunities, as these can help improve variety and access to more affordable, good quality accommodation. This type of housing typically incorporates shared services and facilities and can benefit both younger and older aged groups. However, again a greater understanding of demand, need and viability is required.

Question 44: Should the AAP include Private Rented Sector (PRS) as a potential housing option as part of a wider housing mix across the North East Cambridge area?

We generally support this suggestion, as it typically lends itself to earlier delivery, it can be part of an affordable housing mix, and may suit the needs of the adjoining employment base. Similar to HMO's, PRS development needs to be well-managed to integrate successfully. Again a greater understanding of demand, need and viability is required.

Question 45: if PRS is to be supported, what specific policy requirements should we consider putting in place to manage its provision and to ensure it contributes towards creating a mixed and sustainable community?

We would suggest that this needs to be considered in greater detail, including need and demand, management of facilities, services, and amenities should be well defined and required.

Question 46: Should PRS provide an affordable housing contribution?

Subject to viability, policy requirements will need to reflect the distinct economics of this tenure. In most cases (as in London) this is acknowledging that a form of Discounted Market Rent (capped at 80% of Open Market Rents) is most applicable, as this can be managed by a non-Registered Provider and therefore enables tenure blind blocks to be delivered by PRS operators.

Question 47: What 'clawback' mechanisms should be included to secure the value of the affordable housing to meet local needs if the homes are converted to another tenure?

Typically a profit sharing mechanism up to an agreed cap (cap to be reflective of the affordable housing contribution possible for open market sale units - i.e. the value difference between a private for sale scheme at 40% and a PRS scheme at 30%)

Question 48: What would be a suitable period to require the retention of private rented homes in that tenure and what compensation mechanisms are needed if such homes are sold into a different tenure before the end of the period?

We would suggest a period of 15 years with clawback as outlined in Questions 46 and 47. This period is proposed in the London Plan and is generally accepted by institutional investors

Question 49: What type of management strategy is necessary to ensure high standards of ongoing management of PRS premises is achieved?

We consider that this should be agreed with each operator, and should be brief and relevant to planning matters. This could ensure all prospective tenants are offered the option of a three year tenancy.

Question 50: Should the area provide for other forms of specialist housing (including older people, students & travellers), either onsite or through seeking contributions for off-site provision?

We generally support this suggestion, but again a greater understanding of demand, need and viability is required. A comprehensive analysis of the demographic portrait of Cambridge and its surrounding environs over the next 25 years should be undertaken to assess how new policy interventions - such as NEC (intensified housing and employment uses; new housing 'products' to promote affordability and variety), new transport initiatives to improve access to employment, shopping, leisure and recreation etc, may affect demand and supply of different forms of housing for the local population catchment. In terms of 'housing mix', this might then manifest into redefining 'mainstream' housing, to expand into other groups such as students/graduates, first-time buyers, those requiring good quality rental properties, downsizers, elderly care.

Question 51: Should the AAP apply the national internal residential space standards?

We generally support this suggestion. This is a standard that ensures appropriate homes are delivered that meet the needs of the occupants. However, there may be some formats where exceptions may be appropriate - for example co-living formats including student and young professional accommodation, housing for 'downsizers' etc. These groups may prefer smaller homes with greater shared space and it may be appropriate to provide for this need in the context of a balanced housing offer. However, in these cases we would expect there to be clear requirements around the nature and quality of shared space. We would also encourage pilot testing (on a smaller scale) of more innovative solutions to housing, which might include other micro-living models that have not yet been used in Cambridge but have proved successful in other UK/international cities.

Question 52: Should the AAP develop space standards for new purpose built HMOs?

All new housing should meet the Technical Housing Standards and offer adequate shared spaces to not only provide adequate space in a HMOs scenario but above all provide homes that are future proofed as people's lifestyle changes and needs such as working from home also emerge. Future-proofed housing is to offer adequate space for a wide range of scenarios, not only HMOs. A specifically-developed space standards for new purpose built HMOs may prove unnecessary or irrelevant if HMOs within the AAP is then not delivered through a purpose-built type. Please see our response to Question 51.

Question 53: Should the AAP apply External Space Standards, and expect all dwellings to have direct access to an area of private amenity space?

We support the principle of ensuring that all homes have adequate and appropriate access to outdoor space and support the aspiration for most homes to have some private outdoor space. We would, at this stage, question whether it is realistic to expect that 100% of dwellings will have direct access to an area of private amenity space, given the quantum of development envisaged and the range of different housing typologies that will be necessary to deliver this quantum. In situations where it isn't appropriate to deliver private outdoor space, convenient access to high quality communal and public spaces would be provided. Ultimately, a flexible approach to residential amenity space must be taken, incorporating elements such as roof gardens and balconies as well as elements such as private gardens.

Question 54: Should the AAP apply the Cambridge Local Plan accessibility standards?

We generally support this suggestion in principle. This standard is meeting Part M of the Building Regulations, however due to the requirements of meeting a higher than normal housing number target on the Site, we require flexibility on how the standard is applied. It is important that the Cambridge Local Plan accessibility standards offers flexibility on how the standards are achieved across the many elements of the new masterplanned scheme. While designing for and incorporating accessibility standards is also accepted as a progressive way to future-proof new housing, it is important the standards do not affect the ability of the scheme to meet the density and the target housing required. Currently the Cambridge Local Plan has adopted the optional standard Part M4(2) and has also adopted M4(3) based on a percentage, which is still higher than the national standards, this may have an adverse impact on our scheme.

Question 55: Do you agree with the range of considerations that the AAP will need to have regard to in planning for new retail and town centre provision in the North East Cambridge area? Are there other important factors we should be considering?

The ambitious intentions for NEC are likely to see the creation of thousands of new homes and intensified employment opportunities forming part of new mixed, balanced and prosperous new communities. This new 'Quarter' will therefore require district and local centres to help support and sustain it. Non-residential uses will help create vitality and vibrancy to NEC.

Question 56: Should the Councils be proposing a more multi-dimensional interpretation of the role of a town centre or high street for the North East Cambridge area, where retail is a key but not solely dominant element?

We generally support this suggestion. We would highlight the importance of seeking innovative, creative and flexible solutions across the Site and this will be applied when considering how a District or Local Centre is planned and delivered. Longer term trends (national, regional and local) relating to retail and leisure uses will need to be carefully considered in arriving at a strategy that will support the long term vitality and vibrancy of NEC.

Question 57: What community facilities are particularly needed in the North East Cambridge area?

Opportunities will exist to provide access to new services and facilities for residents of NEC and existing surrounding local communities. In terms of the latter, where there are higher levels of deprivation, the cost of using new facilities will need to take account of affordability issues to ensure the cost of use is not prohibitive to those on no/low incomes.
Provision will need to be informed by the NEC Community Facilities Audit, whilst also taking account of the growth assumptions of NEC (including sizes and tenures of housing, as this will have potentially very different outcomes on need). Provision of facilities should offer flexibility and multi-functional spaces.

Question 58: It is recognised that maximising the development potential of the North East Cambridge area may require a different approach to meeting the sport and open space needs of the new community. How might this be achieved?

See our response to Question 24. Owing to the ambitious development aspirations of the Site (and NEC) it will be necessary to consider a comprehensive package of solutions (on and off-site) for open space and recreational strategy. This strategy will be complemented by the various improvements to green infrastructure provision in and beyond the AAP boundary, facilitating greater access opportunities by walking and cycling.

Question 59: Should open space provision within the North East Cambridge area prioritise quality and functionality over quantity?

See our response to Question 24.

Question 60: Should open space provision within the North East Cambridge area seek to provide for the widest variety of everyday structured and unstructured recreational opportunities, including walking, jogging, picnics, formal and informal play, casual sports, games, dog walking and youth recreation?

We generally support this suggestion. It will be important to ensure that all spaces within the Site are fully optimised, and creative/innovative solutions should be considered to allow for flexible/multi-functional uses.

Question 61: Where specific uses are required to provide of open space as part of the development, should the AAP allow for these to be met through multiple shared use (for example school playing fields & playing pitches for the general public)?

See our response to Question 24.

Question 62: Within this overall approach, in particular, which option do you prefer in relation to carbon reduction standards for residential development?
A - a 19% improvement on 2013 Building Regulations (the current Cambridge Local Plan standard); or
B - a requirement for carbon emissions to be reduced by a further 10% through the use of on-site renewable energy (the current South Cambridgeshire Local Plan standard); or
C - a 19% improvement on 2013 Building Regulations plus an additional 10% reduction through the use of on-site renewable energy (combining the current standards in the Local Plans); or
D - consider a higher standard and develop further evidence alongside the new joint Local Plan.

At this stage we support Option D. This is a complex area of policy setting due to the current grid decarbonisation and emerging guidance from different bodies such as the UKGBC task force, and the GLA London Plan. The context of the electricity grid decarbonisation should be considered to ensure that any targets set do not create perverse outcomes in the future over the timescales of the development and should consider the appropriateness of energy efficiency targets as well as carbon targets.

The AAP should aim to be exemplar while also drawing on the most up to date emerging evidence.

Question 63: Do you support the approach to sustainable design and construction standards suggested for the AAP?

Yes, we generally support the AAP sustainable design and construction approaches set out. However with regard to water recycling we think that while water recycling can be an important part of reducing water consumption if used inappropriately can be unsustainable. Therefore we would expect a rounded view to be taken as to when it is most appropriate to apply the highest levels of water recycling (as required by the maximum BREEAM credits for water efficiency), including an understanding of maintenance and carbon efficiency.
Question 64: Do you support the proposal for the AAP to be clear that review mechanisms should be built into any planning permissions in order to reflect changes in policy regarding sustainable design and construction standards in local and national policy? What other mechanisms could be used?

Yes we think it is important to recognise that not all future scenarios are foreseeable and that in order to avoid perverse outcomes in future it may be necessary to reappraise the policy requirements so that the most up to date and relevant standards are applied where necessary, reasonable and practicable.

It may also be advisable to follow guidance from notable charities and NGOs (e.g. UKGBC)

Question 65: Do you support the plan requiring delivery of site wide approaches to issues such as energy and water, as well as the use of BREEAM Communities International Technical Standard at the masterplanning stage?

Subject to further Masterplanning, technical assessment and feasibility testing, we generally support the approach to site wide water proposed and support the approach to innovate energy infrastructure such as smart energy grids. We support the view that infrastructure necessary for decentralised energy should be explored early on in consultation with relevant parties and that consideration should be given to a range of technologies and approaches to ensure the approach with the lowest carbon overall can be identified and supported.

We fully support the principles in BREEAM Communities and believe that while certification often brings a certainty of outcomes it does not always. The effective outcomes of applying BREEAM communities at this stage should be subject to further consideration.

Question 66: Are there additional issues we should consider in developing the approach to deliver an exemplar development?

Consideration should be given to the embodied impacts of buildings and infrastructure installed as well as opportunities to support the circular economy. Consideration should also be given to embracing and supporting innovative smart-tech and infra-tech initiatives where feasible and viable to do so.

Question 67: What approach should the AAP take to ensure delivery of a net gain in biodiversity?

In terms of the Site, owing to the on-going uses of land e.g. Water Recycling Centre, driving range, former Park and Ride site, it is considered likely that it will have limited biodiversity value. It will be necessary, at the relevant stage in the process, to carry out site specific investigations on the potential suitability of habitat for protected species, and to consider mitigation where appropriate. If the assumption is correct, it seems reasonable to believe that the Site can deliver net gains in biodiversity. Notwithstanding this, sites within NEC may be asked to consider biodiversity collectively, to show how habitat mosaics and corridors can be delivered on a more strategic basis. In this event, the AAP will need to provide greater clarity on what process is likely to be followed, and how this will be applied to individual development schemes.

Consideration will also need to be given to increasing the amount of tree canopy cover in NEC.

Consideration should be given to where biodiversity enhancements opportunities exist in nearby areas as well so that the best opportunities for linkages beyond the site boundary are identified as well as ensuring the best opportunities locally can be realised if necessary to meet the net gain requirements.

Question 68: Should the AAP require developments in the area to integrate SMART technologies from the outset?

We generally support the suggestion that NEC should seek to integrate SMART technologies from the outset. As we have previously noted, we will seek to encourage innovative, creative and adaptable solutions throughout all elements of development on the Site. It will be important to consider preparation of a digital strategy for NEC, to seek optimum speeds for broadband/fibre, opportunities to integrate SMART technology in homes, businesses and other development around NEC.

Question 69: Should the AAP require the use of an underground waste system where it is viable?

We support innovation throughout all elements of development on the Site (and indeed NEC). Rather than committing to any specific type of solution at this stage, it will be necessary to understand whether innovative systems used on other sites, such as North West Cambridge, can be applied on the Site.

Question 70: Do you agree that the AAP should prioritise land that can feasibly be developed early? Are there any risks associated with this proposed approach?

The obvious challenge with sites seeking early release/delivery is how they demonstrate that development will not prejudice the wider delivery aspirations of NEC. Where landowners/developers can explain how development can be carried out in a coordinated/comprehensive manner, it seems reasonable to expect that early delivery can be achieved. A coordinated/comprehensive approach must fully ensure that all development complies with s106 tariff/highways trips budgets, in an equitable manner.

As discussed later in Questions 79 and 80, we would encourage a positive policy approach be taken in supporting temporary/meanwhile uses in order to activate the Site in its earlier development phases, and to optimise economic and social benefits in the local area.

Question 71: Should the AAP include a relocation strategy in preference to leaving this to the market to resolve?

The representations of landowners and occupiers will inform the approach. It is considered that the AAP will need to identify and define a strategy for key sites/uses to be relocated, but maintain flexibility for others. Notwithstanding this the NEC has significant potential to deliver economic, social and environmental benefits, and whilst there are a relatively small number of landowners, the strategic opportunities must not be compromised by one or more parties that are unwilling to support the delivery of the NEC. Accordingly, the Councils cannot discount the possibility of using their CPO powers if required.

Question 72: Do you agree with an approach of devising a Section 106 regime specifically for the North East Cambridge area? If not, what alternative approach should we consider?

An infrastructure delivery plan should be prepared for the North East Cambridge Area to identify the infrastructure required and the costs associated with those projects, in order to inform discussions on planning obligations. It would be reasonable to expect all development within the area to contribute towards the required infrastructure, where it benefits the AAP area as a whole rather than individual sites/landownerships

Question 73: What approach do you consider the most appropriate basis on which to apportion the cost of the infrastructure requirements arising from different land uses to ensure an equitable outcome?

We consider that this should form part of a specific study that includes, inter alia, the following considerations:
*Identify the infrastructure required across the AAP area that is necessary to delivering the comprehensive vision. This might include key routes, connections, bridges / underpasses, transport, education, energy/utilities, social etc.
*Identify where these are most appropriately located to meet the AAP vision.
*Establish a cost base for these, including appropriate cost of land recognising that in some cases it would be otherwise used for residential or other development
*Establish an appropriate equalisation formula across the AAP, levied on all new development. This could be one or a combination of a tariff per m2, per net acre etc and may be varied by use class.
*Set this out in a policy / legal framework with an appropriate indexing mechanism

Question 74: How should the AAP take into account potential changes over time, both positive and negative, that might affect development viability?

We consider that this should form part of a specific study that includes, inter alia, the following considerations
*ensuring that development continues steadily over potentially a number of economic cycles - this possibility should be acknowledged and planned for at the outset
*Any viability test whereby s106 or AH requirements would be reduced would need to be carefully calibrated to ensure that infrastructure is protected.
*A review mechanism within the S106 Agreement would allow viability to be reassessed if circumstances change.

Question 75: Do you agree with the proposal to require land assembly where it can be demonstrated that this is necessary for delivering the agreed masterplan for the North East Cambridge area and/or the proper planning of development?

Yes. This does not directly affect U+I. Land assembly will help to ensure the delivery of comprehensive redevelopment of NEC.

Question 76: Should the AAP state that the Councils will consider use of their Compulsory Purchase powers? If so, should the AAP also set out the circumstances under which this would appropriate?

The NEC has significant potential to deliver economic, social and environmental benefits, and whilst there are a relatively small number of landowners, the strategic opportunities must not be compromised by one or more parties that are unwilling to support the delivery of the NEC. It therefore seems appropriate for the AAP to specify how the Councils will use their CPO powers if required, and the circumstances for doing so. This will need to include the viability and timescales of pursuing a CPO process.

Question 77: Should the Councils actively seek to facilitate joint working between the various landowners/developers within the North East Cambridge area? If so, what specific matters could we target for joint working?

Yes. There are a range of stakeholders and landowners involved in the development at the North East Cambridge area, and the successful delivery of NEC will require a coordinated approach. This will need to consider a range of issues including connectivity, infrastructure locations, parking/trip budget, smart-city coordination, delivery programmes, design principles, energy/utilities and waste etc.

Question 78: Do you agree with the Councils' proposed approach to dealing with planning applications made ahead of the AAP reaching a more formal stage of preparation?

Yes. It is agreed that a coordinated approach is required and decisions on applications should be made against the AAP with appropriate, equitable contributions made.

Question 79: What types of 'meanwhile uses' should the AAP support for the North East Cambridge area?

We would suggest a range of 'meanwhile uses' could be appropriate for NEC, and would not expect policy to impose any particular restriction on types of use. The emphasis should be on promoting innovation and creativity, with meanwhile uses serving to provide early foundations for the new Quarter that will emerge and subsequently replace the meanwhile uses in the coming years. Meanwhile uses could therefore provide start-up/incubator accommodation for emerging/expanding sectors, pop-up/small-scale A class uses, community space to begin community cohesion with surrounding neighbourhoods etc. A positive policy approach to obligations and planning requirements will be needed to encourage temporary/meanwhile activation, helping to avoid onerous situations that might otherwise render creative initiatives unviable.

Question 80: Should there be any limit on the scale of a proposed 'meanwhile use'?

It seems unnecessary to impose a limitation on the scale of a proposed 'meanwhile use', as the purpose of a meanwhile use is, fundamentally, to make optimum use of a site that will otherwise be under-utilised for many years. This can have many short-term economic and social benefits. A policy limitation may stifle innovation and creativity. It is considered likely that many of the meanwhile use proposals will require formal planning consent, which will provide the Local Planning Authority with the ability to control and enforce development that is deemed inappropriate.

Question 81: Do you think it appropriate to set a maximum period for how long a 'meanwhile use' could be in operation?

No. A minimum period should be based on the need and timetable for the permanent development. For the most successful meanwhile initiatives a reasonable period of operation is required in order to recoup the initial capital investment.

Question 82: Should the AAP also include a requirement for 'meanwhile uses' to demonstrate how they will add vibrancy and interest and/or deliver on the wider development outcomes and vision for the North East Cambridge area?

No. 'Meanwhile' uses are temporary in nature and an approach that seeks to make efficient use of land, in a compatible manner with surrounding uses, should be encouraged.

Question 83: What negative or positive impacts might the proposed plans have on residents or visitors to Cambridge with low incomes or who have particular characteristics protected under the Equality Act 2010? (The protected characteristics are age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex, and sexual orientation.)

We strongly support the intention of the Vision for NEC and Objective 5, to ensure social and economic inclusion, and as stated in our response to Question 5, would seek the addition of the word 'culturally' within the Vision i.e. 'North East Cambridge - a socially, culturally, and economically inclusive...'

It is recognised that NEC lies within close proximity of two highly deprived wards in Cambridgeshire, and that regeneration on the scale envisaged will create significant socio-economic opportunities for a wider catchment beyond the AAP boundary. Development on the Site, for instance, will create long term employment across a multitude of sectors and skill ranges, improved connectivity around the NEC and access to new services and facilities. We support the intention of the Councils to undertake a Health Needs and Impact Assessment, across an appropriate study area for the NEC, in order to better understand the challenges and issues faced in neighbouring wards, so as to link into opportunities that will arise in NEC.

As stated within our response to Question 5 we generally support the application of local plan accessibility in the NEC. This standard is meeting Part M of the Building Regulations, however due to the requirements of meeting a higher than normal housing number target on the Site, we require flexibility on how the standard is applied. It is important that the Cambridge Local Plan accessibility standards offers flexibility on how the standards are achieved across the many elements of the new masterplanned scheme. While designing for and incorporating accessibility standards is also accepted as a progressive way to future-proof new housing, it is important the standards do not affect the ability of the scheme to meet the density and the target housing required. Currently the Cambridge Local Plan has adopted the optional standard Part M4(2) and has also adopted M4(3) based on a percentage, which is still higher than the national standards, this may have an adverse impact on our scheme.

Question 84: Do you have any other comments about the North East Cambridge area and/or AAP? Are there other issues and alternatives that the councils should consider? If you wish to make suggestions, please provide your comments.

We would encourage a specific section on education and health provision within the NEC, noting the likelihood that if on-site provision is required, it may require different formats/approaches on how such provision is made i.e. traditional forms of provision in Cambridgeshire are unlikely to be suitable in a high density urban regeneration scheme of this nature.

If off-site provision is considered to be more appropriate, comment should be given on how and where need is expected to be accommodated (for instance it may be more appropriate to extend existing or proposed schools in Cambridge, to create additional Forms of Entry, rather than have a lower number of Forms of Entry on-site that falls below the recommended minimum sizes).

Comment

North East Cambridge Area Action Plan Issues and Options 2019

Representation ID: 33687

Received: 21/03/2019

Respondent: British Horse Society

Representation:

There are many reasons for the provision of off road access for equestrians in North East Cambridge with that of safety being the most important.

The British Horse Society puts forward that equestrian access is currently available at Milton Country Park. Safe equestrian access, therefore, can be readily extended in this scheme.

Full text:

I attended the Nun's Way Consultation last week and spoke with your Officers.

Having explained that I represent the British Horse Society (BHS), it became clear that equestrian access had been excluded from the project for a number of reasons including the fact that Officers were unsure what provision was needed and how it could be delivered.

I have provided a very detailed response, including information on why equestrian access should be included. I have provided this information to enable officers to understand what is required and how it can be provided.

I am aware that the project is at a very early stage but it is essential that the mindset going forward is for multi user access and not shared pedestrian and cyclist access.

I trust that this response is helpful but if I have not provided all the information you require, please let me know.

North East Cambridge Area Action Plan

Consultation Response on behalf of the British Horse Society


I am the British Horse Society (BHS) County Access & Bridleways Officer - Cambridgeshire. I would comment on the above consultation as follows:

Firstly, I would like to say that I am very pleased to see that equestrianism has been acknowledged in the Consultation document but very disappointed to see that no equestrian access has been included in the project. Having met with Cambridge City Planning and Development Officers at the Nun's Way consultation, I understand that this may be partly due to the fact that the project officers do not know how equestrian access could be provided and have asked for guidance from the BHS.

There are many reasons for the provision of offroad access for equestrians with that of safety being the most important.

What are the BHS seeking to be provided in this project:

* all routes linking to settlements or rights of way which are currently proposed as shared cycle and pedestrian should be delivered as multiuser (pedestrian, cyclists and equestrian) paths.
* peripheral routes around significant green spaces should be multi user routes.
* all crossings over, under or around barriers such as roads, railways or rivers should be multi user.

The obvious linking opportunities are:

* the Guided Bus bridleway at Milton Road to Waterbeach and Milton Country Park via the Waterbeach Greenway or any other proposed cycle and pedestrian routes
* Waterbeach to Byway 162/3 Milton via the Guided Bus bridleway via the Waterbeach Greenway or any other proposed cycle and pedestrian routes
* Links to Ditton Meadows or any other communities to the East.

The existing Guided Bus bridleway is shown on the above map which highlights how easily the site could provide a safe, off road link between the proposed Waterbeach Greenway and the bridleway.
Having reviewed the Consultation document, I would make the following specific comments:

Green infrastructure A network of multi-functional green space, urban and rural, which is capable of delivering a wide range of environmental and quality of life benefits for local communities
This should include equestrian access. An advantage of the presence of equestrians has been reported by Landscape Architects is that including equestrian access around public spaces discourages antisocial behaviour - the appearance of a horse and rider has more impact on those engaging in antisocial behaviour than say a pedestrian or a cyclist.

Sustainable modes of transport: Any efficient, safe and accessible means of transport with overall low impact on the environment, including walking and cycling, low and ultra low emission vehicles, car sharing and public transport
Sustainable transport includes horse riding.

4.6. Milton Country Park, which provides access to woodlands and lakes, as well as a visitor centre and children's play areas, is located across the A14 to the north. The River Cam corridor, to the east of NEC, includes walking and cycling opportunities.
Equestrian access is also available at Milton Country Park.

NEC will provide a new model for low car dependency living, through maximising the use of and integrating with public transport, walking and cycling infrastructure.
Transport includes journeys for leisure which includes horse riding.

NEC will integrate with surrounding communities, spreading the benefits it delivers to surrounding areas.
The opportunity to link equestrians in Waterbeach to Histon and beyond would provide a benefit.

NEC will be a healthy place, with a focus on creating a new community with good health and wellbeing.
The health benefits of equestrianism is well documented and noted below.

6.3. The NEC Indicative Concept Plan (at Figure 6.1) begins to describe the kind of place that could be created with the successful regeneration of the area. Movement and the ability to do so easily on foot, by bike or on public transport is central to making the area a well-connected place that reduces the need to travel by car. A high quality green route that supports sustainable transport modes will improve connections from the Cambridge North Station to the Cambridge Science Park, and reduce the barrier that is Milton Road.
Access across Milton Road should be multi user.

6.6. Green infrastructure capitalises on the network of existing trees and landscape but also extends this to create an overall framework to improve biodiversity and linkages to the wider countryside. Embedded into this framework will be the water management network that improves the First Drain and adds richness to the landscape. A new green space at a district scale will enrich the heart of this new place and provide the kind of multifunctional space that is so typical of Cambridge and central to public life.
Linkages to the wider countryside hould include equestrian access - public money should be spent to benefit the widest range of users.

6.14. Cambridgeshire County Council has produced a Housing Developments and the Built Environment Joint Strategic Needs Assessment, which emphasises the relationship between planning and health and wellbeing of new communities. The draft AAP will need to include health related policies. A range of issues addressed in this issues and options report would contribute to making the NEC a healthy and safe place.
The health benefits of equestrianism are well known and noted in the Case for the Inclusion of Equestrian Access below.

6.15. Recently the new town of Northstowe has been part of the NHS Healthy Towns Initiative. This considered how health, and the delivery of healthy communities, could be a key driver in the planning and design process for a new community. It provided an opportunity to explore innovation and best practice. The principles it explored included promoting inclusive communities, good access to health services, walkable neighbourhoods, high quality public transport and cycling links, and opportunities for physical activity. There are opportunities to apply similar principles in North East Cambridge.
Planners and Homes England have worked closely with the BHS at Northstowe and a network of bridleways / multi user routes are included in this project.

Local movement and connectivity

6.21. Chapter 7 of this Issues & Options report considers the wider transport implications of the regeneration of NEC. At the local level, and intrinsically linked into the placemaking led approach, are decisions around movement and connectivity within the NEC area and linkages to the surrounding area. Improvements could establish new or upgraded walking, cycling and public transport connections between Cambridge North Station, the employment areas, Cambridge Regional College, and the surrounding neighbourhoods. In addition, leisure and active routes for walking cycling and equestrians which integrate with the wider countryside beyond are crucial in achieving a shift away from private car dependent forms of development, and towards a 'walkable district'. This would allow and encourage easy change between sustainable modes and influences the way that the place will work and meet the needs of those that live and work in the area.
Equestrian access which integrates with the wider countryside is identified in the report and mentioned in this Clause as 'crucial' yet it is not included anywhere in the project. This needs to be rectified.

6.22. A number of projects would help to establish improved connectivity to NEC, including the Chisholm Trail and Waterbeach Greenways. These would be delivered as part of separate projects and would connect Cambridge North Station with Cambridge Station, Cambridge Biomedical Campus and Addenbrooke's Hospital. In addition, they provide linkages to Northstowe and the planned new town north of Waterbeach.
Wherever links are proposed between communities for pedestrian and cyclists, equestrians should be included unless there is good reason for them not to be. The BHS is the authoritative body to make these decisions. The Greenways are multi user routes - it is very disappointing to see that equestrian access mentioned in the preamble has not been included at this level.

Issue: Local movement and connectivity Question 16:
Should the AAP include any or a combination of the options below to improve pedestrian and cycling connectivity through the site and to the surrounding area?

A - Create a strong east-west axis to unite Cambridge North Station with Cambridge Science Park across Milton Road. This pedestrian and cycle corridor would be integrated into the wider green infrastructure network to create a pleasant and enjoyable route for people to travel through and around the site. The route could also allow other sustainable forms of transport to connect across Milton Road.
Multi user access required not the provision of restrictive cycle and pedestrian access.

C - Upgrade connections to Milton Country Park by both foot and cycle. This would include improving access to the Jane Coston Bridge over the A14, the Waterbeach Greenway project including a new access under the A14 (see Transport Chapter), as well as the existing underpass along the river towpath.
Multi user access required not the provision of restrictive cycle and pedestrian access.

E - Increase ease of movement across the sites by opening up opportunities to walk and cycle through areas where this is currently difficult, for example Cambridge Business Park and the Cambridge Science Park improving access to the Kings Hedges and East Chesterton areas as well as the City beyond.
Equestrian access required on the inter community links.

Issue: Crossing the railway line Question 17: Should we explore delivery of a cycling and pedestrian bridge over the railway line to link into the River Cam towpath?

Green Space
6.34. The site is in close proximity to Milton Country Park and the River Cam Corridor. There will be a requirement for development in NEC to improve pedestrian and cycle connectivity to these well used spaces. As part of this strategy, a strong green infrastructure network will be introduced through the site which will connect north towards Waterbeach new town, west through the Science and into Cambridge Regional College, and east to the River Cam and the fenland landscape beyond (see Transport Chapter).
Any such infrastructure must be multiuser - to do otherwise would be contrary to the Cambridgeshire Rights of Way Improvement Plan since the creation of restrictive pedestrian and cycle only access further fragments the already inadequate bridleway network.

6.35. If NEC is to make a significant contribution to Greater Cambridge's employment and housing needs, maximising the benefits to be realised from the new rail station and Guided Busway, it will be critical that the AAP requires enhanced pedestrian and cycle connectivity to Milton Country Park and the River Cam corridor.
This should be multi user for all the reasons already quoted.

6.36. Green Infrastructure provision will help to structure and soften this new city district. It has a key role in providing space for sustainable drainage systems (SUDS), which will be important in this area. They also provide social spaces which support community activities and healthy activities.
Must be multiuser for all the reasons already quoted.

F - Creation of enhanced pedestrian and cycle connectivity to Milton Country Park and the River Cam corridor.

7.12. Comprehensive high quality pedestrian and cycle networks should permeate the area and link to the surrounding area. There are a range of connectivity issues within the North East Cambridge area that will need to be addressed.

7.13. NEC is well placed to link into the cycle network that crosses the city, as well as routes that serve destinations beyond the city, such as towards Northstowe. Improvements are already planned which will improve access to the area further:

* The Chisholm Trail, creating a mostly off-road and trafficfree route between Cambridge Station, via Abbey, and the new Cambridge North Station, and beyond to St. Ives and Huntingdon.
* Waterbeach Greenway. The Greenways will provide cycling, walking and equestrian routes into Cambridge from the larger villages surrounding the city. Route options for Waterbeach Greenway cross through the NEC site.

7.12 and 7.13 must be multiuser for all the reasons already quoted.

Issue: Non Car Access Question 25:

As set out in this chapter there are a range of public transport, cycling and walking schemes planned which will improve access to the North East Cambridge area. What other measures should be explored to improve access to this area?
Include bridleway provision in the S.106 Agreement.

THE CASE FOR THE INCLUSION OF EQUESTRIAN ACCESS

The BHS (British Horse Society)

* The British Horse Society (BHS), together with the membership of its Affiliated Riding Clubs and Bridleway Groups is the largest and most influential equestrian charity in the UK.
* The BHS represents the interests of the 3 million people in the UK who ride or who drive horse-drawn vehicles.
* The BHS works for safer on and off-road riding and carriage driving through an improved public rights of way network, and seeking to create new opportunities of lawful off road riding and carriage driving, and safer use of our roads by all road users.

Between 2010 and 2017 the BHS horse accidents website has recorded:

230 horses died on the roads and 840 were injured, 5 severely

39 riders killed, 10 severely injured
* 3,863 horse riders and carriage drivers in England and Wales were admitted to hospital for 'animal-rider or occupant animal-drawn vehicle injured in transport accident' in 2016-17 (source: NHS Hospital Episodes Statistics)
* Only 1 in 10 horse related road accidents are reported (source: British Horse Society)

The regions with the highest number of incidents are: West Yorkshire, South West and the East of England

These figures demonstrate how important it is that planning authorities, developers, Highways and Strategic Transport understand the requirement for safe access for equestrians on the roads and the links to PROW (Public Rights of Way Network)

The Equestrian Industry's Impact on the Economy

* The contribution made by the equine sector to the UK economy in 2017 excluding the racing industry was £4.3 billion
(source: British Equestrian Trade Association).
* The Equestrian Industry is the second largest rural employer after the agricultural sector in the UK
(source: British Horse Industry Confederation 2017 Mid-Sector Manifesto).

Health and Well-being - Benefits of Horse Riding : Research undertaken by the University of Brighton and Plumpton College on behalf of The British Horse Society:

* The majority of horse riders are women (90%) with more than a third being over 45.
* Horse riding and activities associated with horse riding, such as mucking out, expend sufficient energy to be classed as moderate intensity exercise.
* Horse riders with a long-standing illness or disability who took part in the survey are able to undertake horse riding and associated activities at the same self-reported level of frequency and physical intensity as those without such an illness or disability

Active women raise active children.

Equestrianism falls into the category of 'Active Travel'

The importance and benefits of regular exercise and being outdoors are well known and established. The majority of horse riders are female whereas the majority of cyclists are male. Riding is a sport which you can participate in at any age. Despite the popular view that horse riding is elitist, the reality is that people from all walks of life ride horses with a strong social network.

Exercise as part of family life installs good lifetime standards. Getting back to riding their horse often motivates women to recover more quickly from serious illnesses and surgery.

For some disabled people, their only opportunity to access the countryside is on horseback or horse drawn carriage which gives them a freedom they cannot achieve in their everyday lives. On horseback, a disabled person is at the same eye level as other riders something which wheelchair bound people rarely achieve, giving a feeling of belonging and inclusivity.

The psychological and social benefits of horse riding :

* Horse riding stimulates mainly positive psychological feelings.
* Horse riders are strongly motivated to take part in riding by the sense of well-being they gain from interacting with horses. This important positive psychological interaction with an animal occurs in a very few sports.
* Many differently abled children, such as those coping with Autism, have also benefitted from working with horses.
* Being outdoors and in contact with nature is an important motivation for the vast majority of horse riders.

Research is showing that the old pun 'horse people are stable people' may be more factual than previously understood because of the positive psychological feelings which being around horses generates. One little boy in South Cambs refuses to speak although he will talk to the horse during his Riding for the Disabled session.

Riders and drivers often say that having the opportunity to spend part of every day outdoors tending their horses is their 'chill' time and allows them the opportunity to 'recharge their batteries' away from the stresses of daily life. As Winston Churchill, allegedly said: "There is something about the outside of a horse that is good for the inside of man."

The Guided busway St. Ives to Cambridge

The bridleway created alongside the guided busway which was instigated by Swavesey Bridleways Group was inspired - a fantastic facility created on a service track.

Just to be clear, bridleways have always been available to pedestrians and horse riders and since 1968, with the support of equestrians, bicycles were included as rightful users. On a bridleway, horse riders must give way to pedestrians and cyclists must give way to pedestrians and cyclists.

What is a good design of an NMU (non motorised user pedestrians, cyclists AND horse riders) path? Simple ....

Don't put the cycle path down the centre of the route leaving two narrow, useless grass verges either side, combine the two verges and put the cycle path to one side. It was established at the Cambridgeshire Planning Committee when the Que to Lode shared cycle and pedestrian path was being considered, that it costs no more to build an NMU path than a shared cycle and pedestrian path.

It really is that easy - on NMU paths we are not asking for new paths or new routes - simply a good design and not to be excluded.

The DNA path alongside the railway In Great Shelford was a good idea in its time but the flaws and lost opportunity are clear. The grass clippings from the mower fall on to the tarmac from both sides where it decomposes and allows herbage to establish and reduces the width of the hard top path forcing users on to a narrow section increasing the potential for conflict. The clippings on the path also become very slippery in wet weather and are a problem for cyclists.

Having a decent grass verge is a refuge for pedestrians to get out of the way of cyclists, is a more pleasant walk for dogs and is appreciated by runners who like horse riders, are concerned about the impact of a hard surface on joints.

The DNA path does raise another issue - that of maintenance. Failure to maintain a path is poor use of public capital expenditure. Clever design would take into account the optimum width for the mowers to ensure that the grass can be kept to a useful length.

Perceived barriers to including equestrians on NMU paths

* Horses pose a danger - No evidence
* Horse droppings - No danger to humans
* Potential Conflict - No evidence
* Landowners refuse equestrian access - we will check!
* Reality is that best use of public funds is for access facilities to be available to as many users as possible.

There are no recorded incidents of third party injury caused by horses being ridden on any public right of way.

Horse poo presents no danger to human health and quickly disperses. However, we do encourage riders to remove droppings from path.
Conflict with cyclists is often held as a reason to exclude us. This rarely has anything to do with the bicycle - its just an inconsiderate person who happens to be on a bike (or horse!) that day. Horse riders and cyclists as two vulnerable road user groups have far more in common with each other than differences.

Conflict with commuter cyclists who want to cycle quickly is also cited a reason to exclude horses however, commuter traffic is time of day related and tidal. Riders chose to avoid peak traffic times on paths in the same way as going into town in a car. According to CamCycle, there is a speed limit of 15 mph on cycle paths - bikes with motors are governed to 15 mph - any which have been altered to travel more quickly are not allowed on cycle paths.

Vulnerable Road Users

* Historically vulnerable road users have been considered to be pedestrians and cyclists.

* British Horse Society working at all levels to ensure horse-riders vulnerability is recognised. Horses are now recognised as the most vulnerable road user.

* November 2018 at the Parliamentary Debate on Road Safety in Westminster, the Under Secretary of State for Transport, Jesse Norman said: 'We should be clear that the cycling and walking strategy may have that name but is absolutely targeted at vulnerable road users, including horse-riders.'

Historically, vulnerable road users have been identified as pedestrians and cyclists. Highways, Rail Infrastructure Planners, Planners, Agents and Applicants, have been educated to cater for pedestrians and cyclists precisely because they are vulnerable road users. However, change is afoot.

Statistics demonstrate how vulnerable horse-riders are on the road. These aren't just theoretical examples. Conflict between horses and cars happens every day on the roads.

Personal examples are:
'a car drove by so fast and so close that the car hit my leg with its wing mirror as I was riding along the road.'

'a car was driving down a 60mph road so fast that the driver couldn't slow down sufficiently without hitting my horse on the road so the driver had to drive the wrong way around traffic calming bollard in the road - thankfully no one was coming the other way.'

Horse riders have to accept it could and probably will happen to them but with nowhere to hack out other than the roads, there is little choice but to take the risk. It shouldn't be like this.

The British Horse Society has been working at all levels to ensure this vulnerability is recognised.

In November 2018 Jesse Norman confirmed 'We should be clear that the cycling and walking strategy may have that name but is absolutely targeted at vulnerable road users, including horse-riders.'

The current RoW Network

* The length of the public right of way network currently amounts to 188,700km, consisting of
* 146,600km of footpaths,
* 32,400km of bridleways,
* 3,700km of byways and 6,000km of restricted byways.
* Horse riders currently only have access to 22% of public rights of way and horse-drawn vehicle drivers only 5%.
* The Cambridgeshire Rights of Way Improvement Plan - bridleway network is fragmented and in need of improvement. Development and the creation of shared pedestrian / cycle paths further fragments the network

Across the UK Horse riders are currently excluded from 78% of the Rights of Way network and carriage drivers are excluded from 95%.

Going forward, the only way to improve things for the future is to secure new inclusive rights of way which cater for pedestrians, cyclists and horses.

What needs to be included in the Project

* Joining up of any severed PROW's.
* All crossings of access barriers need to be NMUs.
* Optimise opportunities to provide missing links to improve the PROW network.
* Surfaces to be suitable for all users - the BHS can provide specifications and information.
* Consult with the BHS throughout the development process to ensure that riders' needs are included - public money must be spent to the benefit of as many users as possible.
* Where possible, ensure that PROW's are kept open or alternative routes provided during the construction period.

There are a great many local and national planning policies and strategies which support the inclusion of equestrians in new projects including:

NPPF: 92,96, 98, 141
The Government's Strategy for the Horse Industry in England and Wales
The Highway Code
Highways England Accessibility Strategy
South Cambridgeshire District Local Plan HQ/1:f, TI/1:2.b, TI/1:2.c; NH/6 Green
Infrastructure
South Cambs Design Guide 4.12, 4.13
Cambs ROWIP - Policies SOA1, SOA2, SOA3, SOA4, SOA5 and Future Programme


Should you wish the BHS to provide you with this further information, I would be happy to do so. This could be provided in the form of a presentation if you feel it would be of assistance.

Comment

North East Cambridge Area Action Plan Issues and Options 2019

Representation ID: 33761

Received: 24/03/2019

Respondent: Veolia and Turnstone Estates

Agent: Carter Jonas

Representation:

Generally yes, however it would be beneficial for additional information to be provided regarding environmental constraints associated with the Veolia business operation e.g. noise, air quality, odour. Veolia provide environmental services and operate a waste transfer station from the site, however the document has only made reference to the Waste Water Recycling Centre.

Full text:

North East Cambridge Area Action Plan (AAP) - Issues and Options Consultation February 2019

Response on behalf of Veolia and Turnstone Estates

Cambridge City Council and South Cambridgeshire District Council is consulting on Issues and Options for the North East Cambridge AAP. The consultation deadline is 25th March 2019. This response has been prepared on behalf of Veolia and Turnstone Estates for land at Cowley Road, Cambridge outlined in red on the accompanying Site Location Plan.
The representations contained herein relate primarily to the development intentions for the Cowley Road site, but also in the context of the wider AAP area. Cambridge City Council own the freehold of the site where Veolia have a long leasehold interest in the land from which they operate waste transfer station which serves Cambridge and its sub-region.
There are a total of 84 Questions covering a range of themes provided within the consultation document and those considered relevant to the Veolia site at Cowley Road are summarised below:

Question 2: Is the proposed boundary the most appropriate one for the AAP?

We are generally supportive of the proposed boundary for the AAP area. However, land in close proximity should be included to provide relocation opportunities for existing established businesses within the area.

Question 3: In this Chapter have we correctly identified the physical characteristics of the North East Cambridge Area and its surroundings?

Generally yes, however it would be beneficial for additional information to be provided regarding environmental constraints associated with the Veolia business operation e.g. noise, air quality, odour. Veolia provide environmental services and operate a waste transfer station from the site, however the document has only made reference to the Waste Water Recycling Centre.

Question 4: Have we identified all relevant constraints present on, or affecting, the North East Cambridge Area?

Consideration has not been given or reference made to the existing Veolia business operation on Cowley Road. Careful consideration needs to be given to noise, air quality and odour as these may pose a significant constraint to development of the surrounding area.

There are commercial reasons for Veolia to be located on Cowley Road and some future uses such as residential would not be compatible with their business operation should they remain on site. There is a requirement for them to be located within the area.

We would also suggest that consideration is given to the inclusion of sites on the edge of the proposed NEC. If some of the existing industrial uses are to be relocated as part of the redevelopment proposals, these businesses are important to the Cambridge Sub-region and need to be located in close proximity to Cambridge.

Question 5: Do you agree with the proposed Vision for the future of the North East Cambridge area? If not, what might you change?

Yes, the proposed vision is generally supported, however this may need to modified should Veolia remain where they currently are on Cowley Road.

Question 6: Do you agree with the overarching Objectives? If not, what might you change?

Yes generally, however careful consideration needs to be given to existing established businesses within the area such as Veolia.

Question 7: Do you support the overall approach shown in the Indicative Concept Plan? Do you have any comments or suggestions to make?

It is noted that the Concept Plan can only be treated as indicative at this stage in the AAP process, until the outcomes of the various supporting studies are known and wider consultation with relevant interested parties has taken place.

The land to the north of Cowley Road is allocated for residential-led mixed use development. As outlined, the existing Veolia use constitutes a constraint to the surrounding land coming forward for residential purposes. The existing Veolia waste transfer use is not compatible with the movements and activities associated with a residential use, particularly due to environmental constraints such as noise, air quality and noise. Unless a viable relocation site is found, the vision and concept plan should be modified to enable Veolia to remain on site. The potential relocation to the north east corner of the site might be broadly supported, however further information on this needs to be provided. It is considered that the area would also constitute a suitable location for employment intensification. It is clear that further supporting studies need to take place before the concept plan can be finalised.

Question 8: Do you agree that outside of the existing business areas, the eastern part of the North east Cambridge AAP area (i.e. the area east of Milton Road) should provide a higher density mixed use residential led area with intensified employment, relocation of existing industrial uses and other supporting uses?

Outside of the existing business areas, we are generally supportive of the initial development intentions for the area east of Milton Road. However, careful consideration needs to be given to the needs and requirements of the existing Veolia business. If Veolia remains on site, this would be a constraint to the future residential led redevelopment of the area. No information has been provided on the relocation of the existing industrial uses. As outlined above, the Veolia business provides an invaluable service to Cambridge and needs to be conveniently located within the City.

Question 11: Are there any particular land uses that should be accommodated in the North East Cambridge Area?

The AAP provides a significant opportunity to create thousands of new homes in a highly sustainable location. However, careful consideration needs to be given to the needs and requirements of the Veolia and other established businesses within the area as these are of paramount importance to the continued growth of the Cambridge sub region. Veolia is an established Cambridge business that needs to be located in close proximity to Cambridge. These industrial uses need to be considered at the outset and if they are to be relocated, any future site needs to be conveniently located and also represent a viable alternative.

Question 16: Should the AAP include any or a combination of the options below to improve pedestrian and cycling connectivity through the site and to the surrounding area?

The options to create a strong east-west axis to unite Cambridge North Station with the Science Park is supported. This can successfully be achieved on Cowley Road without impacting on the Veolia site and operation. The options to improve connectivity between Cowley Road and Nuffield Road are also supported and this will ensure safe and convenient travel through the wider site ensuring coordinated development.

Question 20: Do you agree with proposals to include low levels of parking as part of creating a sustainable new city district focusing on non-car transport?

The sustainable approach towards car parking and the focus on non-car transport is broadly supported. However consideration needs to be given towards the requirements of the Veolia use. The Veolia operation needs to be conveniently located and given the industrial nature of the business, car parking for staff and customers along with access for various forms of vehicles (HGV's etc.) needs to be taken on board.

Question 28: Do you agree that car parking associated with new development should be low, and we should take the opportunity to reduce car parking in existing developments (alongside the other measures to improve access by means other than the car)?

The concept of encouraging non-car modes of travel is supported. However, as outlined above, consideration of the business requirements for the Veolia use is important.

Question 36: Which of the following approaches should the AAP take to existing industrial uses in the north east Cambridge Area?

As acknowledged within the Consultation Document, the existing industrial uses within the area are important to the Cambridge economy. If the uses are to remain in situ, careful consideration does need to be given to the compatibility with adjoining future uses such as residential.
The Veolia operation needs to be located within Cambridge and provides an invaluable service to a wide range of Cambridge businesses.

Question 37: Are there particular uses that should be retained in the area or moved elsewhere?
As outlined in the response to Question 36, it is imperative that the Veolia use remains within the area.

Comment

North East Cambridge Area Action Plan Issues and Options 2019

Representation ID: 33788

Received: 25/03/2019

Respondent: Trinity College, Cambridge

Agent: Bidwells

Representation:

As for Cambridge Science Park [CSP], it should more fully reflect the walking and cycling routes around the loop-road and through the central park. It should recognise the 'plaza' link from the CGB route to the south east of CSP; this will be a strategic pedestrian and cycle link into CSP that will be a high-quality public realm that will encourage more people to enter the park (on foot and cycle) through the plaza; this is part of the construction of the nearly completed CSP 22 and CSP 25 new buildings.

Full text:

Please see attached representation