Local Plan update 12th Feb

Urgent. Deadline to submit comments on the Local Plan Modifications is 5pm this Friday!

Some members want us to share with you their insights (see below).

https://cambridge.jdi-consult.net/localplan/readdoc.php?docid=190&chapter=4#topofdoc

If there is an area that you are interested in, and want to comment on you will need to refer back to the original Local Plan documents

www.cambridge.gov.uk/local-plan-review

www.scambs.gov.uk/localplan

You need to sign into the system, and use the “comment” icons to have your say on each item. Alternatively there is a form you can download and fill in by hand.

Members insights

John Preston Former Historic Environment Manager Cambridge City on Proposed Main Modifications to the Cambridge Local Plan

Overview of heritage considerations:

The most significant omission from the Submission Draft was of a Historic Environment Strategy as required by para 126 of the NPPF.  This was and is a fundamental issue for Cambridge, given the tremendous current growth pressures (7% per annum employment), the lack of priority given to the historic environment in the Submission Draft, or in the work of the Cambridgeshire and Peterborough Combined Authority and the Greater Cambridge Partnership.  The proposed Modifications, like the Submission Draft, give no consideration to Cambridge as an internationally significant historic city, whose historic environment is a vital ingredient of its economic success, but is now threatened by growth pressures.

MM 142, while including some welcome text changes, shows no strategic awareness or consideration of the city of Cambridge as a heritage asset as a whole, whose survival depends on the balancing of growth pressures with historic fabric and environmental capacity.  MM 143 and 144 (produced only belatedly in response to representations, and not subject to public consultation until now) attempt to provide a so-called Historic Environment Strategy, but are woefully inadequate in approach, understanding, and content.  Notably, there is no consideration of heritage assets at risk.  The absence of an effective Historic Environment Strategy for Cambridge is so serious that it brings the soundness of the whole draft Local Plan into question.

MM16 is a comparably inadequate attempt to provide a Natural Environment Strategy.  There is no consideration of the need to join up the Historic Environment and Natural Environment, with no awareness that Cambridge’s open spaces are of historic as well as nature conservation interest.

Other modifications belatedly remedy omissions of heritage considerations (again, symptomatic of the from the Submission Draft.  Many of the new or improved references to heritage considerations are good, e.g. in MM 13, 22, 27, 28, 64, 67, 69, and 71.

Specific comments:

MM013   welcome greater focus on preservation and historic character MM016  welcome addition of “open spaces”, but failure to mention the historic character and importance of these  – separate rather than holistic treatment of natural and historic environment.  Fig 2.2.  rag-bag of policies, strategies and guidance rather than a strategy – all info to be taken into account in preparing a strategy but no substitute for a strategy (see MM 144 and 145).

MM018 welcome para 2.76, but this should include specific reference to the environmental capacity of Cambridge

MM022 Policy 11   Fitzroy/ Burleigh/ Grafton  welcome reference to character and setting of historic core and heritage assets

MM027   Policy 13  welcome references to heritage assets

MM028  para 3.24  Welcome additional text re preservation, enhancement, and retaining buildings making a positive contribution

MM050    high quality urban edge  welcome

MM 064   welcome  new text

MM 067   welcome additional text re historic character and conservation area

MM 069 welcome additional marking on fig 3.10 historic frontages

MM 070 welcome change to fig 3.10 to show former Library Building, but this needs to be shown as a Listed Building at Risk.  In the Hearing for Matter CC2F the Council officer denied, in the face of a statement in the Council’s own Conservation Area Appraisal, that the former Mill Road Library is a listed Building at Risk. This issue remains unacknowledged and untackled in the Council’s Development Brief and current planning application for the Mill Road depot site. The Design and Access Statement for this says only that “the building is of special architectural and historic interest and will be retained as part of the re- development of the site. The impact of the proposed development on the setting of the building has been carefully considered.”  – but ignoring the fact that the Library has no external curtilage.

MM 071   welcome addition of Conservation Area boundary

MM 072  welcome clear showing of access improvements – but these and their impacts on the listed building are not included in the current application for the Depot site!!

MM 076  welcome reference to Historic Core Appraisal taking precedence in respect of heritage assets

MM 107 and 108 Language School growth – support changes, but needs to be even stronger?

MM 114 student housing –  welcome text in final para

MM 116  needs reference to environmental capacity???

MM 134  welcome additional text  on food productionMM140 welcome changed text re tall building MM 141   – revised first para is confusing – replace “opportunities” with “proposals” and placed only in suitable locations

MM142  welcome additional text, but no sense of Cambridge as a whole being a heritage asset

MM143 fails to recognise the international and national significance of Cambridge as an historic city,  and the importance of this to its tourism.  It also fails to recognise the importance of conserving the city’s built environment to its international competitiveness, especially in the high-tech sector: conserving Cambridge’s  heritage is fundamental to maintaining the city’s prosperity. The revised text does not resolve the basic contradiction, and conflict, within the sentence .  “against the backdrop of a successful, growing city” has to be deleted.

MM144  There is no strategy – this is a rag-bag of disparate, disconnected and sometimes conflicting documents, strategies, and guidance, as shown in the new Fig 7.1.  There is no strategic assessment of Cambridge’s historic significance, vulnerabilities, or threats, and no consideration of its capacity for change or how to manage pressures.   For a city of such national and international heritage significance as Cambridge, this failure is calamitous, and risks “killing the goose that lays the golden eggs”.  This fundamental flaw is so serious that it renders the Plan unsound.

The Plan’s, and the Council’s in preparing it, failure to give proper regard to the historic environment is further evidenced by the series of modifications (MM 13, 22, 27, 28, 69, 70, 71, 142) belatedly adding heritage considerations which should have been included from the outset.

MM145   Fig 7.1 is misleading. It does not represent a strategy; it merely shows existing disparate guidance, policies, plans and strategies, and the potential actors involved, with no overview or indication of how conflicts or inadequacies are to be resolved.

This so-called “strategy” does not comply with para 126 of the NPPF, which requires “a positive strategy for the conservation and enjoyment of the historic environment, including heritage assets most at risk through neglect, decay or other threats”.

Omissions from Fig 7.1:

Notwithstanding para 126 of the NPPF, Fig 7.1 notably fails to mention, let alone include any assessment of, heritage at risk.  This omission is crucial given the pressures of growth on Cambridge and its heritage assets. The Council’s lack of regard for heritage at risk was shown at the Hearing for Matter CC2F, when the Council officer denied, in the face of a statement in the Council’s own Conservation Area Appraisal, that the former Mill Road Library is a listed Building at Risk (see MM 070); this disregard subsequently confirmed in successive iterations of the Council’s proposals for its own Mill Road Depot site which, while paying lip service to the preservation of the listed building, have failed to assess or provide for its external space, and other needs which are essential for securing its future.

Contents of Fig 7.1:The contents of Fig 7.1 do not withstand scrutiny, as would have been highlighted fully in the Matter CC1A Hearing if the Deputy Inspector had allowed the opportunity.

To take just some of the items listed:

Conservation Plans e.g. Parker’s Piece: these Conservation Plans for Open Spaces, compiled in 2001, are in urgent need of review and updating, but some are no longer even accessible on the Council’s website. The only Conservation Plans available are those for Parkers Piece, and Coe Fen and Sheep’s Green; both of which are under threat from pressure of increased activities, and City Deal cycle ways respectively.

Suburbs and Approaches Studies: these studies were discontinued before considering Milton Road and Histon Road, the City Deal proposals for which have been incredibly contentious, leading to the greatest growth Cambridge has ever seen in the membership of residents’ associations.

Both of the above highlight

  1. a) the urgent need for updating of management plans and policies to manage pressures on heritage assets, and
  2. b) the damaging impacts of transport proposals arising from the City Deal (now Greater Cambridge Partnership). Fig 7.1 wrongly shows the City Deal as “delivering” the Historic Environment Strategy, when it is responsible for the most damaging transport proposals, including busways across the West Fields and Ditton Fields as well as cycleways through some of Cambridge’s most constrained historic environments (Senate House Passage, Garret Hostel Lane, Mill Pit etc).

MM 148  welcome revised text

MM 149, 150, 151   welcome revised text; need to also require compliance with British Standard BS 7913:2013

MM 191   (site R10 Mill Rd Depot)  vehicular access “subject to detailed testing” – need to add “ including providing for the access and servicing needs of the former Mill Road Library”.

MM196  (Betjeman House) welcome additional text  (environmental capacity)

MM199  (Old Press Site) welcome additional text  (environmental capacity)

MM 210  (Appendix F – tall buildings)  object  to deletion of final sentence.  Reinstate “Given the relatively modest scale of buildings in Cambridge, this increased height has the potential to impact on both the immediate and wider skyline”.

MM215    (Tall Buildings F 31) welcome additional text, but suggest additional  wording:  “within or impacting on the Historic Core…”

MM 216, 217, 218 (tall buildings)  all welcome

MM 223   (designed landscapes) welcome

MM224    Local heritage assets  – all welcome

MM 249  Glossary  – support changes to description of heritage assets

 

Member 2 – Flags up concerns re Changes to Tall Buildings  policy 60 and Appendix F  – Document here

The most important is probably CC-MM140 (the first in the PDF) as that is where the critical fixed heights (13m/4 storeys) have been removed and replaced with a “significantly taller than” entry.  This replaces a specified fixed value with an unspecified subjective measure with all of the opportunities for developers that that presents’.

The result of this change will be developers may be able to build a lot higher than 4 storeys outside the historic core i.e. in the predominantly 2-storey suburban areas in which many of us live.

Am concerned about the consequences of leaving it up to developers to determine what constitutes “appropriate” when it comes to ‘tall’. ‘“City “should not render itself a hostage to fortune by watering down existing policy from the outset.

Our understanding about the LP was that the aim was to retain Cambridge’s special character as a city of predominantly low-rise profile interspersed with “slender” interruptions (spires etc) .

Tall buildings surely represent the biggest threat to this character? If people are concerned ‘it is very important that you register significant concerns about this change in policy

Member 2 has ‘filleted out the relevant sections into PDF form from the otherwise complex LP main alterations webpage (see attached PDF – note I’ve concatenated several sections into one attachment.  The Mod Ref. value in the first column is the one to search for an comment on in the main online document.  The most important is probably CC-MM140 (the first in the PDF) as that is where the critical fixed heights (13m/4 storeys) have been removed and replaced with a “significantly taller than” entry.  This replaces a specified fixed value with an unspecified subjective measure with all of the opportunities for developers that that presents, and undoes in a stroke much of the hard work and negotiation that took place to put the last Tall Buildings SPD in place several years ago.

 

Member 3 – with a specific interest in the River and Heritage

SCDC Local Plan- The proposed modifications need to be viewed with the 2014 draft local plan document, which can be accessed on the SCamb’s Planning Website.  Of particular relevance is Policies CC/7-9 covering water quality, sustainable drainage and flood risk, and Chapter 6- Protecting and enhancing the Natural and Historic Environment clauses 6.1-6.63 pages 107-126.  The modifications seem to, in the main, strengthen the policies of protection and enhancement. But crucially there are 86 Conservation Areas within South Cambs.  Only 15 of these have had an appraisal since 2000, and the only appraisal adopted within the last 10 years was for the Papworth Everard CA in July 2011.  An update appraisal and proposed extension of Foxton CA is currently under public consultation, but this is largely lead by the local community.  There are no registers of Local Heritage Assets or Building of Local Interest (BLIs) and information about Listed Buildings is only generic. It has been suggested that the case needs to be made for registering assets and that this is something we as community could do.

 

–          Policy 7 relates to the River Cam, and there are modifications proposed to this.  It might be suggested that the need to preserve and enhance the water quality of the rivers and streams could be inserted in the modifications to this policy.

–          Policy 27 relates to new homes and the proposed modifications represent a significant relaxation on their sustainability requirements.  Unfortunate that this may be, it is understandable as onerous requirements do add to costs which conflicts with the pressing need for affordable housing.

–          Policy 33- Contaminated land- A number of modifications are proposed to this.  They relate to protecting the acquifer from historic and potential future contamination, (pages 69-71 of the modifications document.)

–          Policies 47-51- Significant changes are proposed regarding the policies for student housing, provisions for travellers and gypsies, housing in multiple occupation and lifetime accessable homes, these are set out in pages 93-108 of the modifications document.

Policy 62- Local Heritage Assets- The supporting text for this section is inconsistent with the reality, and the proposed modifications could be changed to correct this.  The only local heritage assets that I was able to view on line was the list of over 1000 Buildings of Local Interest (BLIs).  It states that this is updated annually, however the list is dated 2011.  Some changes to the list are proposed in the modifications document appendix G, but these don’t include Castle End Mission and 56 DeFreville Avenue, Also the Annexe to the Mond Laboratory was demolished last year, so it should be taken of the list, as should Fen Court, Peterhouse, as that is Grade 2 listed

 

Member 4

CCMM015 “Development on urban edge … will only be supported where it: a. responds to, conserves and enhances the setting and special character of the city” . ‘Landscape’ & ‘approaches’ deleted – significant

CCMM054 re NIAB site. Deletion of requirement to “compensate adequately for the loss of the existing Christ’s and Sidney Sussex sports grounds” – significant?

CCMM057 Addition of investigation of eastern access to the railway station 🙂

CCMM063 Some protection against excessive height on East Road added

CCMM065 Mill Road no longer to aim for ‘more generous’ pavements, but ‘improved’

CCMM105 Heads up to expect additional changes at several university sites including include the Sidgwick Site, the Old Addenbrooke’s Site, the Downing Site, the former Scroope House Site (Department of Engineering), and the Department of
Chemistry (Lensfield Road

CCMM106 Added “The use of family dwellinghouses to accommodate students of specialist colleges and/or language schools only is not appropriate

CCMM110 Added “However, following assessment of development viability across the city, the affordable housing requirement is not applied to planning applications for student accommodation” Did this need saying? Is it a change of policy?

CCMM114 Weaker wording regarding cars at specific student accommodation ..

CCMM115 puts “a number other educational establishments” on a par with the two universities

[the Land Economy Report commissioned by the City Council did not go out for consultation]

CCMM116 Growth in student numbers at the unis and these mysterious ‘other educational establishments’ to total 3104 by 2026(

[Ask if Cambridge City Council has a list of these other educational establishments? ]

CCMM120 Tightening up on requirement to demonstrate lack of market need before ‘specialist housing’ (care homes and the like) can be granted change of use

CCMM122 No need for a specific Traveller site before 2031 *but* CCMM125 advocates inclusion of pitches in major developments

CCMM136 Adds (in considerable detail) how to do surveys to assess ‘parking stress’ in a neighbourhood

CCMM141 Adds “While there has been a move to build a number of taller buildings across the city in recent years, further opportunities to create new taller buildings in the city must be carefully considered and placed in the right locations.” Hmm

CCMM148 Adds “Proposals for any works that would lead to harm or substantial harm to a non-designated heritage asset should be supported by detailed analysis of the asset that demonstrates the wider public benefit of the proposal”

From CCMM152 (page 119) onwards there is a lot of stuff about impact on open spaces which needs careful reading …

CCMM183 “Any development that will require regular loading or servicing must avoid causing illegal or dangerous parking, by providing appropriate off-street facilities” But how can/will that be enforced.

CCMM186, CCMM188 – *reduction* in desired housing density at GB1/2 (Wort’s Causeway)

CCMM199 Mill Lane/Old Press site loses 150 houses, gains 350 student rooms

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