[Members] URGENT - Deadline to submit Local Plan Modification Comments 5pm this Friday, Feb 16
Wendy Blythe
wendy.blythe.fecra at gmail.com
Mon Feb 12 18:07:43 GMT 2018
Update February 12, 2108
Dear All,
*Urgent. Deadline to submit comments on the Local Plan Modifications is 5pm
this Friday!*
This email is long because members want us to share with you their insights
(see below).
Link here is the quickest way in .There is information also on the fecra.org
website.
https://cambridge.jdi-consult.net/localplan/readdoc.php?doci
d=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 *
1. 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 *
a) the urgent need for updating of management plans and policies to
manage pressures on heritage assets, and
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 *
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 "Dev'ment 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
Best wishes,
Wendy
Wendy Blythe
Chair, FeCRA
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