CNFE AAP - Interim Sustainability Appraisal Report
ENVIRON UK Ltd has been commissioned to undertake a Sustainability Appraisal (SA) of the options being considered as part of the Cambridge Northern Fringe East Area Action Plan (CNFE AAP). A Scoping Report was produced in August 2014 and this has been amended in line with consultee comments received.
This report is the Interim SA Report which outlines the results of an appraisal of the sustainability effects of the plan’s options (also referred to as reasonable alternatives). The SEA Directive and transposing SEA Regulations require the identification, description and evaluation of the likely significant effects on the environment of “reasonable alternatives” taking into account the objectives and the geographical scope of the plan or programme” (Reg 12 (1(b)). This report is not the formal SA Report which will be prepared once an assessment of the Draft Plan has been undertaken.
Stage A (scoping) of the SA is completed. The SA Scoping Report for the CNFE AAP can be accessed via the Cambridge City Council and South Cambridgeshire District Council websites.
The main output of Stage A was an SA Framework of sustainability objectives developed specifically for the CNFE AAP area. The SA is now in Stage B (Developing and refining options and assessing effects).
The SA has examined three key elements of the Issues and Options document. These are:
- The CNFE AAP Vision, Development Principles and Development Objectives;
- The Spatial Redevelopment Options (plus a ‘Do Nothing/Committed Development Option which is based on the existing site uses and committed developments (see Section 3 of the main report); and
- Proposed Policy Approaches.
The above elements of the CNFE AAP have been appraised against the SA Framework and potential impacts associated with the options have been identified. The appraisal findings are presented for consultation alongside the CNFE AAP Issues and Options consultation document and will be used to inform the selection of a preferred option and the development of the draft AAP.
CNFE AAP Vision, Development Principles and Development Objectives
A consistency check has been undertaken between the CNFE Vision, Development Principles and Development Options and the SA Framework, the check has mainly recorded consistency. Two opportunities to improve the vision have been identified: reference could be made to ensuring that the CNFE is resilient to climate change and that it supports addressing inequalities within the area.
Potential conflicts identified within the matrix reflect tensions between the Development Objectives and Principles and the SA Objectives. Development Objective 3: Maximise the Employment Opportunities could potentially conflict with SA Objectives relating to air and noise pollution, water pollution, biodiversity, landscape and townscape and provision of open space as these factors could potentially be compromised at higher levels of development. Tensions between objectives are inevitable and it will be up to the AAP to ensure that all objectives can be met through either spatial planning or policy wording.
Spatial Redevelopment Options
The ‘Do Nothing/Committed Developments’ option does not perform particularly well against the SA Framework; mainly neutral and minor beneficial impacts have been recorded. No significant impacts have been recorded in the appraisal of this option.
There are a number of factors common to all of the redevelopment Options 1-4. For each of the Options 1-4, green space is included along the northern and eastern boundaries which should help to reduce adverse impacts on the Green Belt.
There are a number of uncertainties common to Options 1-4 and therefore they perform similarly against some of the SA Objectives. These uncertainties are:
- There is uncertainty over the type and location of contamination. Cambridge City Council is undertaking borehole surveys of ground contamination in order to provide additional information to feed into the development of the draft AAP. Further investigation will also be required through the planning application process to determine appropriate mitigation. See mitigation below.
- Information is not available on potential air quality and noise impacts relating to each of the options as transport modelling is not completed. However, the assessments of each option have identified the potential benefits of the location and therefore the opportunities available to seek a high modal share of non-car modes for all of the options. In addition, the assessments of the options which include higher levels of development (options 3 and 4) have identified the potential for them to generate higher levels of traffic.
- Each of the options 1-4 proposes redevelopment of a part of the Chesterton Sidings, the ecological value of which is uncertain but it could be important for biodiversity.
- Landscape character and visual impacts with regards to the Cambridge Green Belt and the City Townscape are to be assessed shortly but findings will not be available to inform Issues and Options. The AAP area has significant potential for townscape improvements. The impacts of development will need to be considered, in particular building height and design on the wider area. However, there is potential for beneficial impacts.
- Each of the Options 1-4 has the potential to reduce vulnerability to future climate change through the use of SUDS, green infrastructure and design and layout of the development. However, policies are yet to be developed in order to ensure that these are integrated into the development.
- Information is not available on potential traffic impacts relating to the options as transport modelling is not completed and therefore the appraisals against SA Objective 16 (see Section 2 of the main report) cannot be completed at this stage. The assessments of the Options 1-4 have identified uncertainty with regards to this SA Objective and potential adverse impacts with regards to traffic generation, particularly associated with the higher levels of development (i.e. options 3 and 4). However, there are also potential beneficial impacts associated with each of the options, from taking advantage of the opportunity for intensive land uses around the new transport interchange and encouraging the use of sustainable modes of travel. The CNFE AAP area will be one of the most accessible sites by non-car modes in the Cambridge area.
Mitigation measures are put forward to address these areas of uncertainty. Enhancement measures are also put forward for each of the redevelopment options in order to improve their performance.
Option 1 represents a low level of growth and mainly performs well with regards to the SA Framework. Most SA objectives are supported by Option 1. No significant beneficial or adverse impacts have been identified in the appraisal, however, uncertainties identified in sub-section 4.3.2 apply to all of the Options 1-4 and once information is available to reduce these uncertainties, it is possible that adverse impacts could be identified, for example, in relation to air quality and traffic impacts. With regards to the potential beneficial impacts identified, Option 1 does not perform as well as Options 2-4.
Option 2 involves a medium level of growth. It performs well with regards to the SA Objectives, with a number of significant beneficial impacts being identified as well as the uncertainties common to all of the Options 1-4 (listed in sub-section 4.3.2). As for Option 1, and once information is available to reduce these uncertainties, it is possible that adverse impacts could be identified, for example, in relation to air quality and traffic impacts. Option 2 includes some residential development (440 dwellings) and might therefore require mitigation measures to avoid adverse impacts on new residents such as in relation to noise. This spatial option has been designed to avoid adverse impacts in relation to odour associated with the WRC.
Option 3 involves a high level of growth and a more intense redevelopment of the AAP area. With regards to beneficial impacts, Option 3 performs well with regards to the SA Objectives, with more significant beneficial impacts compared with Option 2. However, it should be noted that there are uncertainties common to all of the Options 1-4 (listed in sub-section 4.3.2) and therefore potential adverse impacts, for example, in relation to air quality, noise and traffic are currently unclear. Option 3 represents a more intense redevelopment than options 1 and 2 and therefore risks of adverse impacts occurring could be greater. Option 3 also includes some residential development (630 dwellings) and might therefore require mitigation measures to avoid adverse impacts on new residents such as in relation to noise. The spatial option has been designed to avoid adverse impacts in relation to odour associated with the WRC.
Option 3 should deliver net gains in biodiversity and will improve habitat connectivity, resulting in an enhanced and more comprehensive green infrastructure network (compared to Options 1 and 2) across the site which links into the new open space on the site and the existing open space to the south of the AAP boundary. In Option 3, as for Option 4, the green infrastructure network proposed on the AAP site covers a larger area compared to Options 1 and 2 and the ‘Do Nothing/Committed Development’ option.
It is assumed that Options 3 and 4 will have the potential to significantly improve energy efficiency of operations of the site and significant renewable energy generation will be incorporated into the development. The proposed policy approach to renewable and low carbon energy generation (1a) would particularly support Options 3 and 4 as the development of the policy would include consideration of the types of energy generation that could be suitable for the area and whether an area based approach could be used.
Options 3 and 4 will provide a significant amount of new employment opportunities (25,800 new jobs in Option 3 and 27,600 new jobs in Option 4) as well as new housing and community facilities. It will allow for a comprehensive network of walking and cycling access across the site integrated with a green infrastructure network and significant open space.
Option 3 has been designed around constraints posed by potential odour impacts from the WRC facility. In this option, it is assumed that significant investment in the WRC can allow it to function on a much smaller site than present.
Options 3 and 4 will provide significant amounts of new office and R&D space and a net increase in industry/storage but requires existing industrial and storage businesses to relocate which will have a potential impact on their efficiency, vitality and economic performance. This will have an adverse impact on those businesses in the short term. This mixed performance is also recorded for Option 2, although it provides less new office, R&D space and industry/storage than Options 3 and 4.
The performance of Option 4 against the SA Framework compared with Option 3 is not markedly different. Option 4 represents a more comprehensive redevelopment of the AAP area which may be made possible if an alternative location for the WRC can be identified. Option 4 does not provide any additional residential development compared with Option 3. However, the uncertainties common to all of the Options 1-4 (listed in sub-section 4.3.2), which relate to factors such as air quality, ecology, landscape and townscape, and traffic could be associated with adverse impacts, once information is available on which to appraise such impacts. It should therefore be noted that although Options 3 and 4 are associated with a greater number of potentially significant beneficial impacts, they could also be associated with adverse impacts, once further information becomes available in forthcoming months (see Section 6 for further details). Option 4 represents the most intense level of redevelopment of all of the options 1-4 and therefore could pose the highest risks of adverse impacts occurring in relation to townscape, traffic, air quality, noise and ecology (specifically relating to the Chesterton Sidings).
Option 4 proposes the relocation of the Water Recycling Centre (WRC), which would free up land for further redevelopment. A site for the relocated works is not identified, but would be outside the AAP area. This would be subject to a separate planning process. Impacts on sustainability objectives of this relocation are uncertain as it would depend on the location and nature of the site. Potential indirect and cumulative effects would need to be considered in more detail should this option be taken forward.
Each of the Options 1-4 proposes redevelopment of a part of the Chesterton Sidings, the ecological value of which is uncertain but it could be important for biodiversity. Option 4 proposes the largest part of Chesterton Sidings for redevelopment of all of the options and therefore poses the greatest risk of adverse impacts on biodiversity. However, the ecological value of the Chesterton Sidings requires confirmation through survey and there is potential for enhancements to be put in place to ensure that a net gain in biodiversity is achieved across the whole site.
Proposed policy approaches
The policy options have been appraised against the SA Framework. When carrying out the appraisal the team has considered how the approaches / options would work towards or against the various SA Objectives and whether any mitigation or enhancements need to be addressed whilst the policies are being developed.
The majority of the policy approaches posed did not have alternative options presented. These policy approaches all had positive impacts on the SA objectives, many of them significantly beneficial. No adverse impacts were recorded.
Some of the policy approaches were presented with alternative options and the results of the appraisal of these are summarised below:
- Building heights: Option A was seen as significantly beneficial in safeguarding the form and character of the area. Option B and C were less likely to do this and Option C in particular posed a risk to the character of the City as no maximum building heights are prescribed in this option.
- Change of use from office to residential or other purposes: Option A could potentially undermine efforts to regenerate the area. Option B, however could provide protection and help with regeneration efforts.
- Cambridge Science Park: Option A could lead to missed opportunities with regard to regeneration. Option B, however, could encourage greater intensification of use on the Cambridge Science Park and therefore, more sustainable development.
- Change of use from industrial to other purposes at Nuffield Road: Option A will have a neutral performance against the SA Objectives. Options B and C should result in beneficial impacts with regard to health and pollution but may result in negative impacts in relation to the local economy should spatial option 2 be taken forward because the option involves a net loss in industrial/storage uses.
- Hotel & conferencing facilities: Option A will have a neutral impact on the SA objectives. Options B and C perform similarly in that, by providing a hotel with or without conferencing facilities, the options would support the achievement of a number of the SA Objectives. Option C could perform marginally better than Option B, through the provision of more facilities to support local businesses.
- Private rented accommodation: Both options could have a positive impact on health and well-being and provision of more affordable housing. If, through further work, it is clear that if there is a demand for private rented accommodation in the area which will fulfil a housing need, then Option B will perform the best.
- Student housing: Option A would prevent response to any demand for student accommodation. Options B, C and D could all have positive impacts if developed using an up to date evidence base. However, a risk in developing student housing is that it could have the impact of reducing the overall supply of affordable housing as sites are developed for students and not the general population. Options B and D would seem to be the most effective in reducing this risk and therefore, have the potential to have the most positive impact. Option C would appear to pose the most risk to jeopardising the provision of affordable housing.
- Modal share target: Option C is likely to cause adverse impacts because it will not seek to constrain road traffic from the site which is likely to cause increases in road traffic which will cause increases in noise, air pollution, CO2 and nuisance. This is also likely to constrain economic growth in the medium and long term. Options A and B are likely to have beneficial impacts on many of the SA Objectives. There may be some concern that higher modal share targets might inhibit some commercial demand for new floor space when linked with restricted car parking if some find it difficult to use their car. Therefore, Options A and B may have a slight adverse impact on Objective 14 in the short term. Options A and B are likely to have a beneficial impact on Objective 14 in the medium and long term as the travel options in the area significantly improve and users of the site become more used to alternative modes of travel. High modal share targets are likely to become more the norm in Cambridge and this site will have a competitive advantage because of its accessibility.
- Vehicular access and road layout: Option A would not appear to be a practical solution due to the congestion this will cause and the impacts this will have on the character of the site as Cowley Road is expected to serve as a green boulevard. Options B and C are likely to perform better both in terms of congestion and in terms of urban design principles.
- Parking at transport interchange: The current (and consented) interchange proposals (Option A) include parking for 450 cars and around 1000 bicycles at ground level and would have beneficial impacts in relation to pollution, climate change and the economy. Option B (provision of a multi storey car park) would have similar beneficial impacts but could potentially have a negative visual impact on houses to the east of the CNFE area.
- Car parking provision: Three options are presented with varying degrees of restriction in relation to car parking standards. All of the options are likely to have beneficial impacts on issues such as air quality, sustainable transport and climate change. Without specific traffic modelling on the impacts of different modal shares (and without further details on what would be needed to make the area an exemplar scheme) the significance of the impacts cannot be judged.
- Cycling parking provision: Three options are presented with varying degrees of restriction in relation to cycle parking standards. All of the options are likely to have beneficial impacts on issues such as air quality, sustainable transport and climate change. Options B and C are likely to have more beneficial impacts than Option A. However, the success of the standards is dependent on the transport strategy developed for the site.
- Sustainable design and construction and flood risk: It is not possible to state exactly how the sustainability performance of the options would differ because at this stage it is not clear what mix of development is likely to come forward. There are some conclusions that can be drawn however from the comparison of Options A and B. Option A (relying on district policies) may lead to uncertainty and it is less likely that the site will deliver development to the same standards with relation to sustainable design and construction and climate change as that which would be specified under Option B. Option B (developing a bespoke policy) would provide more clarity to developers and would be clearer in terms of the exact provisions required. However, if Option B is taken forward the councils should ensure that the most stringent provisions are applied to the site.
- Phasing and delivery approach: Option A states that the AAP will provide a sufficiently detailed development framework for the whole area with appropriate apportionment of infrastructure requirements across the area identified. Option B states that the AAP will require the planning application for the first phase of development to provide a masterplan for the whole AAP area. As long as an effective masterplan is developed the precise nature of the mechanism used is not important for the SA.
This report will be consulted on alongside the CNFE AAP Issues and Options consultation document between 8th December 2014 and 2nd February 2015. The findings of the SA and the comments received will be taken into account within the next stage of work which will involve the development and appraisal of a preferred option for the CNFE. This will form Stages B3-B6 of the SA as set out in Table 2.1.