CC/CS: Supporting land-based carbon sequestration

This policy will protect important land based carbon sinks such as peatland and woodland projects whilst encouraging new development to promote biodiversity and carbon sequestration.
We recognise the importance of peatlands and woodland to carbon sequestration and agree that these should be protected where possible. It is important to note however that with respect to new development, there can often be many carbon sequestration benefits associated with the creation of multi-functional green infrastructure and on-site planting which should be recognised when considering the overall ‘carbon performance’ of new development.
Countryside therefore believe that the draft policy should contain text to support new development if it can be demonstrated that the green infrastructure and woodland it provides will sequester carbon. We believe this should be recognised as one of the many environmental benefits that new development can provide.

Climate change – Supporting land-based carbon sequestration
64. We are puzzled by Policy CC/CS: Supporting land-based carbon sequestration while supporting the
principles. There is very little undrained peat in South Cambridgeshire or Cambridge City.
65. Could this be the policy that is aimed at justifying re-flooding the Fens due to the effects of greenhouse gas
emissions and increased run-off which the level of increased construction will cause?

Support the aspiration but OBJECT to the Plan as stated. So much is imprecise generalisation. What is ‘rewilding’? Does grain or meat production by some methods have a better footprint than other methods or foodstuffs or displacing production elsewhere. It is not automatic that the suggested actions in the Plan will always be improvements. Land quality must be taken into account.

Contents
1. Introduction 1
2. Taylor Wimpey’s Corporate Commitment to creating a more sustainable business 2
3. The Greater Cambridge Local Plan Policies 4
4. Summary of Representations 12










































Colin Morrison colin.morrison@turley.co.uk
Client
Taylor Wimpey Strategic Land
Our reference
TAYS3107

December 2021

1. Introduction

1. These representations to the Greater Cambridge Local Plan (GCLP) have been produced by Turley Sustainability on behalf of Taylor Wimpey with respect to their existing and potential future land interests within the Greater Cambridge Area. These representations are focused on the Climate Change Theme of the GCLP and specifically the following policies:

1.1.1 CC/NZ: Net Zero Carbon in New Buildings

1.1.2 CC/WE: Water Efficiency in New Developments

1.1.3 CC/DC: Designing for a changing climate

1.1.4 CC/ FM: Flooding and Integrated Water Management

1.1.5 CC/ RE: Renewable Energy projects and infrastructure

1.1.6 CC/ CE: Reducing Waste and supporting the local economy

1.1.7 CC/ CS: Supporting land-based carbon sequestration

2. Taylor Wimpey fully supports the strategic commitment by the GCLP to positively address the issue of climate change mitigation and adaptation within the plan period and welcome the opportunity to comment on the draft policies to ensure they evolve to meet the tests of soundness and are both deliverable and viable whilst supporting the delivery of much needed high quality, private and affordable homes within Greater Cambridge.

2. Taylor Wimpey’s Corporate Commitment to creating a more sustainable business

3. Taylor Wimpey have a strong corporate commitment to sustainability, environmental and social governance as can be seen from the recent publications on their website of their 2020 Sustainability Report1 and their 2021 Environment Strategy2.

4. Launched in 2021 the Environment Strategy sets out the company’s long term commitment to protecting the environment for future generations by reducing their environmental impact and making it easier for their customers to live a sustainable lifestyle.

5. The strategy focuses on the environmental impacts that are deemed critical to the business which are set our below along with some of the key targets to reduce these impacts:

1.5.1 Climate Change: Protect our planet and our future by playing our part in the global fight to stop climate change:

1.5.1.1 Achieve our science-based carbon reduction target through a range of measures which include reducing operational carbon emission intensity by 36% by 2025 from a 2019 baseline and reducing carbon emissions intensity from our supply chain and customer homes by 24% by 2030, from a 2019 baseline.

1.5.2 Nature: Improve access to and enable enjoyment of nature for customers and communities by regenerating the natural environment on our developments:

1.5.2.1 Increase natural habitats by 10% on new sites from 2023 and include our priority wildlife enhancements from 2021 which includes hedgehog highways, bug hotels and creating 20,000 more nature friendly gardens by 2025

1.5.3 Resources and waste. Protect the environment and improve efficiency for our business and our customers by using fewer and more sustainable resources:

1.5.3.1 Cut our waste intensity by 15% by 2025 and use more recycled materials. By 2022 publish ‘a towards zero waste’ strategy for our sites.

6. One of the key targets within the GCLP is to transition to a net zero carbon Cambridge by 2050. As stated above Taylor Wimpey have a strong corporate commitment to reducing their carbon footprint and have adopted science based carbon reduction targets against which there has been significant progress to date in the form of:

1.6.1 30% reduction in carbon emission intensity since 2013

1 https://www.taylorwimpey.co.uk/corporate/sustainability/2020-sustainability-review
2 https://www.taylorwimpey.co.uk/corporate/sustainability/2020-sustainability-review

1.6.2 39% reduction in absolute carbon emissions since 2013; and

1.6.3 58% green electricity purchased for their sites and corporate emissions;

7. These corporate commitments are resulting in more efficient and environmental friendly construction sites where there is a continued focus to reduce energy use, waste generation and improve our nature and biodiversity impacts.

3. The Greater Cambridge Local Plan Policies

8. Taylor Wimpey have reviewed each of the draft policies within the climate change section of the GCLP and have provided representations for each policy which we hope is of assistance to the Greater Cambridge Shared Planning authorities. Our focus is to ensure that each policy is both viable and deliverable whilst facilitating a shared objective of delivering more high quality affordable and private homes in an area with current and growing demand.

9. Where necessary these representations make reference to the GCLP Climate Change Topic Paper3 which summarises the evidence to support each of the policies and is hereafter referred to as the Topic Paper.

10. For draft Policy CC/ NZ, we have also reviewed the evidence base supporting these specific policies which is the Greater Cambridge Net Zero Carbon Evidence Base Non- Technical Summary and which is hereafter referred to as the Evidence Base document. Unfortunately a more detailed review of the full evidence is not possible as only the non-technical summary has been published and therefore Taylor Wimpey reserve the right to amend our representations once this material has been reviewed.

11. Taylor Wimpey welcome the opportunity to comment on these draft policies and would be happy to discuss our comments in greater detail with the authorities. We also recognise that these are currently policy options which will be informed by consultation feedback. Taylor Wimpey look forward to reviewing the next iteration of the draft GCLP.

Policy CC/ NZ: Net Zero Carbon New Buildings

12. This policy introduces new levels of energy use that will be allowed for new development and how renewable energy should be used to meet that energy need. It also introduces requirements for the assessment of whole life carbon by new development and address the potential issue of carbon offsetting.

13. The policy introduces the following parameters for energy use for new buildings in order to achieve Net Zero for Operational emissions:

1.13.1 A space heating demand of 15-20kwh per meter square per year for residential and non-residential buildings.

1.13.2 All heating provided through low carbon sources and not fossil fuels with no new development connected to the gas grid.

1.13.3 All buildings should achieve a total Energy Use Intensity (EUI) target for both regulated and unregulated energy of no more than 35kWh per m2 per year with a range of different EUI targets for non-domestic buildings as set out in the policy.


3 https://consultations.greatercambridgeplanning.org/sites/gcp/files/2021- 08/GCLP%20Climate%20Change%20Topic%20Paper.pdf

1.13.4 New development should generate at least the same amount of renewable energy (preferably on-plot) as they demand over the course of a year and this should include all regulated and un-regulated energy. In large developments the energy generation can be averaged across the development to compensate for the inability of specific dwellings to meet the target

1.13.5 Offsetting can only be used as a last resort and the building should be future proofed to allow residents or tenants to enable the achievement of net zero dwellings.

1.13.6 To target Net Zero for Construction residential developments of greater than
150 dwellings or 1,000m2 should calculate the whole life carbon of the development and present measures to reduce these.

14. Whilst Taylor Wimpey recognise the importance of addressing climate change, we do have a number of concerns that draft Policy CC/ NZ is unsound on the basis that it is not viable or deliverable and may reduce the delivery of much needed affordable and private housing within the Greater Cambridge (GC) area. We have summarised our concerns below which we hope are helpful to the authorities in their search for sound and effective climate change policies within the GCLP.

1.14.1 It is noted that the dwelling energy efficiency targets within draft Policy CC/ NZ go significantly beyond building regulations including the proposed Future Homes Standard 2025 although the Topic Paper (page 17) states that the standards proposed are not as onerous as the passivhaus standard but do go beyond the proposed FHS. The passivhaus standard is widely recognised as the highest construction standard that is currently available in the UK for residential development as it requires complex construction techniques and therefore carries a cost premium . Analysis of this standard and others compared to the targets within Policy CC/ NZ have identified the following:

1.14.1.1 The passivhaus standard4 requires an EUI of less than 120 kWh m2 per annum compared to the policy target of 35KWh per m2-thereby suggesting that the draft policy target is in fact considerably more onerous than passivhaus.

1.14.1.2 The EUI within the draft policy CC/NZ appears to have been taken from the recommendations from the London Energy Transformation Initiative (LETI) climate emergency guide5 which was created to introduce higher standards in Greater London where new development is dominated by low/ high rise apartments that are inherently more energy efficient than typical single and family housing types.

1.14.1.3 The passivhaus standard6 requires a space heating demand of 15 kWh m2 per annum compared to a draft policy target of 15 – 20

4 https://www.passivhaustrust.org.uk/what_is_passivhaus.php#2
5 https://www.leti.london/_files/ugd/252d09_3b0f2acf2bb24c019f5ed9173fc5d9f4.pdf
6 https://www.passivhaustrust.org.uk/what_is_passivhaus.php#2

kWh m2 thereby suggesting close alignment between the two on this specific issue.

1.14.1.4 Draft Policy CC/NZ requires applicants to address both regulated and unregulated energy as opposed to the FHS which deals with regulated energy alone. The Government have made this important differentiation because the use of unregulated energy (e.g. power used by televisions and appliances) is the responsibility of the homeowner and not the housebuilder and is extremely difficult to quantify accurately at construction stage.

1.14.1.5 To hit the EUI target of 35KWh per m2 the Evidence base document estimates that the following will be required although no exact details are available:

(a) Low U-values that exceed the requirements of the proposed FHS

(b) Mechanical Ventilation with Heat Recovery (MVHR) to recover waste heat from the dwellings

(c) A high level of air-tightness to prevent cold air ingress and heat loss from the dwelling

All of the measures identified above are characteristic of implementing the passivhaus standard.

1.14.1.6 The cost of implementing Policy CC/ NZ has been estimated at between 10% and 13% above that required to build to current Building Regulations. No detailed analysis of the assumptions behind this calculation were available however. It is claimed that this cost is achievable on the basis that significant costs are required to implement the FHS and therefore the costs identified by the Evidence base are an over-estimate and are therefore acceptable. Taylor Wimpey believe it is extremely important to obtain the detailed evidence behind these costs as in our experience the cost of building to passivhaus standards (or extremely close) is likely to be significantly higher than those quoted in the Evidence base paper.

1.14.2 Given the above it would appear that the Policy CC/ NZ is implementing on- site energy efficiency standards much more closely aligned to passivhaus which presents significant challenges to the housebuilding industry for the following reasons:

1.14.2.1 Building to passivhaus requires a complete transformation of the on-site construction process and supply chain which would significantly delay housing delivery and increase costs of new dwellings particularly for the small and medium sized house builders.

1.14.2.2 The cost of constructing houses to passivhaus is likely to be significantly higher than that identified in the evidence base although a direct comparison is difficult in the absence of the detail behind the assumptions in the Evidence Base. Achieving air- tightness levels close to passivhaus and installing MVHR are extremely costly forms of construction and is likely to contribute to a significant cost increase above current Building Regulations that has not been identified by the Evidence base.

15. The GCLP states that it has considered alternatives to the draft policy and targets with one being the use of the Government’s FHS as the principal metric for sustainable housing. Taylor Wimpey fully support the introduction of the FHS in 2025 as it will deliver many of the strategic requirements of draft Policy CC/ NZ which include:

1.15.1 An all-electric energy strategy thereby allowing the carbon footprint of the dwelling to fall each year in line with grid decarbonisation

1.15.2 Dwellings will have very high levels of insulation and likely require triple glazing to ensure maximum heat retention.

1.15.2.1 Each home built to the FHS will require the extensive use of renewable energy technologies in which are likely to include Air Source Heat Pumps and Photovoltaic cells.

1.15.2.2 There would a consistent, deliverable standard for all new dwellings in Greater Cambridge thereby providing a level playing field for all housing developers.

16. Whilst the detailed energy demand / performance metrics for the FHS is unknown at this time the Government have confirmed that dwellings built to this standard will reduce carbon emissions by 75% compared to those built under the current 2013 Building Regulation.

17. Taylor Wimpey therefore believe that Policy CC/ NZ of the GCLP should utilise the FHS as the main metric for the construction of energy efficient housing. The use of this standard will also provide greater support to the small and medium (including self- build) housing sector which we believe is critical to ensure greater supply and diversity of affordable housing to the consumer.

18. In addition to the concern’s with respect to the on-site standards presented in draft Policy CC/ NZ, Taylor Wimpey also have reservations with respect to other aspects of the Policy which are:

1.18.1 It is unreasonable to prohibit all new developments to connect to the gas grid as it is possible that for buildings such as care homes and health facilities gas may still be the most suitable fuel for heating given the bespoke heating requirement of these health facilities. Given that some of Taylor Wimpey’s sites are large enough to permit the delivery of critical social infrastructure such as schools and health facilities, there may be a technical requirement for gas in some form to our large sites.

1.18.2 The requirement for new dwellings to generate at least the same amount of renewable energy as they demand over the course of the year is extremely challenging given that it must include both regulated and unregulated energy for which it is difficult to estimate the exact quantum of energy needed given it is entirely dependent on the occupiers use of appliances.

1.18.3 The offsetting policy (although lacking in detail) would appear to be based on the cost of providing additional PV cells to generate the quantum of energy that remains from the development site after all on-site measures have been deployed. At this time however there appears to be no data with respect to the cost of this offsetting policy and how any money will be spent with absolute certainty to ensure ‘additionality’. Without any costs or viability information this aspect of the policy fails the test of soundness. It is evident however that this policy will add a significant (albeit unknown at this time) cost to new housing which ultimately will feed into higher house prices and greater affordability challenges. We look forward to seeing the detail of this policy but would urge the authorities to fully explore the viability of this carbon offsetting and its impact upon the delivery of affordable housing before it is adopted.

1.18.4 The requirement to calculate Whole Life Carbon (WLF) in construction would increase the importance of reducing embodied carbon within the supply chain, particularly for small and medium sized developers. For Taylor Wimpey however, we are already committed to reducing our embodied (scope 3 emissions) within the supply chain have set ambitions targets to reduce these over time. The requirement to submit a WLC assessment for each TW application places an unnecessary burden upon our new development activities as this work is already part of our corporate commitments. To ensure this policy does not negatively affect housing delivery we would request that the acceptable evidence to demonstrate policy compliance could be details of our corporate commitment and progress to date.

Summary of Representations to Policy CC/ NZ:

19. In summary, Taylor Wimpey support the strategic objective of the GCLP to positively address climate change through progressive policies in the plan. We are concerned however that the policies as they stand are unsound as they propose to introduce some of the highest sustainability requirements in the country without a complete evidence base. In order to make this policy sound and facilitate the delivery of much needed high-quality affordance and private housing we recommend the following amendments to Policy CC/ NZ:

1.19.1 Publication of a complete and full evidence base for stakeholder comments before these draft policies are developed further.

1.19.2 Adoption of the FHS as the energy efficiency target for new housing and remove the requirement for additional renewable energy deployment.

1.19.3 Allow flexibility with respect to the use of gas in new developments where gas use is necessary for health/ occupant wellbeing

Policy CC/ WE: Water Efficiency in new developments.

20. This policy introduces requirements for water efficiency in new domestic and non- domestic development in the form of the following:

1.20.1 80 litres per person per day for domestic development; and

1.20.2 Full BREEAM credits for Wat 01 for non-domestic development

21. Taylor Wimpey acknowledge that the Greater Cambridge area is under water stress and there is a strong encouragement for all new development to improve water efficiency however with respect to draft Policy CC/ WE we have the following comments:

1.21.1 We agree with the statement on Page 26 of the Topic Paper that the highest water efficiency standard that can be requested by local authorities is 110 l per person per day (pppd).

1.21.2 We also agree that achieving 80lppd will require either rainwater harvesting and/ or greywater recycling. Both systems introduce significant maintenance requirements (and therefore cost) for homeowners and introduce technology that has not been tested ‘en-masse’. Taylor Wimpey’s experience of trialling grey water recycling is that it is unreliable and likely to cause maintenance issues for homeowners

1.21.3 Given the unreliability of greywater recycling TW believe the only practical mechanism to achieve the 80lpppd would be through the use of rainwater harvesting systems which have the following constraints;

1.21.3.1 Such systems are more difficult for flats given that communal harvesting tanks (which are more expensive) would be necessary; and

1.21.3.2 Greater Cambridge is already one of the driest areas in the UK7 and climate change is predicated to reduce rainfall in Greater Cambridge by 47% it is highly likely that rainwater harvesting will not capture sufficient rain to meet the policy target and will therefore be ineffective.

1.21.4 Given the above, TW believe that the GCLP should implement the Government’s technical standard for water efficiency for Policy CC/ WE which is 110 lpppd. This would be viable, deliverable and achievable for all new dwellings within GC. Should technology such as grey water recycling become viable during the lifetime of the plan then this could be considered as a means to improve water efficiency beyond the target of 110 lpppd.

Policy CC/ DC Designing for a Changing Climate.


7 https://consultations.greatercambridgeplanning.org/sites/gcp/files/2021-
08/GCLP%20Climate%20Change%20Topic%20Paper.pdf. Page 20, Section 5.1

22. This draft Policy introduces requirements to design buildings in accordance with the Good Homes Alliance Overheating in New Homes Tool and Guidance8. Taylor Wimpey recognise the fact that all buildings will need to be designed to adapt to a warming climate and that, depending on the building type and location, this may necessitate the use of a range of measures as recommended in the Good Homes Alliance toolkit such as shading, thermal mass and different modes of ventilation. The policy requires new development to complete the Good Homes Alliance toolkit and implement the cooling hierarchy to minimise the impact of overheating.

23. Taylor Wimpey believe that this policy may be ineffective as it requires each developer to implement the guidance in a manner that is appropriate for their site and which therefore may differ from one development to the next.

24. In January 2021, the Government confirmed the introduction of the FHS and also consulted on the introduction of a range of new building regulation requirements one of which was the introduction of an overheating testing requirement9 for residential development. This will require all new homes to undergo modelling during detailed design to identify any impact from overheating and then implement mitigation measures accordingly.

25. As this requirement is proposed to be introduced with the revised changes to the Building Regulation in 2022, Taylor Wimpey believes that the policy would be unsound on the basis that it is introducing an unnecessary additional burden on development given that it duplicates the requirement of the building regulations.

26. Taylor Wimpey believe that to reduce the planning and administrative burden upon the housebuilding sector in Greater Cambridge, Policy CC/ DC should be deleted on the grounds that its objectives will be required via Building Regulations.

Policy CC/ CE: Reducing Waste and Supporting the Circular Economy

27. This policy places requirements upon new development to manage their waste and embrace the principles of the circular economy. The policy requires the following from new development proposals:

1.27.1 The submission of a Construction Environmental Management Plan (CEMP) proportionate to the size and scale of development

1.27.2 Provision of adequate waste and material storage facilities on site in accordance with the RECAP Waste Management Design Guide (or successor)

1.27.3 Submission of a Circular Economy Statement with each application

28. Taylor Wimpey fully support the strategic objective of the policy in terms of its objectives to reduce waste and, perhaps more importantly, encourage circular economy principles in development. As explained earlier in these representations,

8 https://goodhomes.org.uk/wp-content/uploads/2019/07/GHA-Overheating-in-New-Homes-Tool-and- Guidance.pdf
9https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_d
ata/file/953752/Draft_guidance_on_heating.pdf

reducing waste intensity is one of our key objectives and one in which progress is clearly being made on our sites.

29. We fully support the requirement to submit a CEMP for our sites as this is something that we already commit to as part of our best practice approach to waste management and environmental protection.

30. With respect to the provision of waste management facilities on site, Taylor Wimpey agree that the correct storage and handling of waste and raw materials is a critical step to responsible management of materials and the prevention of pollution. All of our construction sites deploy best practice measures for the prevention of pollution and provide facilities for the separation and recycling of waste. We therefore support this objective of draft Policy CC/ CE but would ask that the policy recognises that large housebuilders such as Taylor Wimpey with large and efficient supply chains may use bespoke techniques and practices on site which are not referenced in any guidance but which fully comply with all legislation and best practice.

31. With respect to the submission of a circular economy statement, Taylor Wimpey are happy to provide such information with an application although we would request that this is proportionate to the size and scale of the development in question.

Policy CC/ CS Supporting land-based carbon sequestration.

32. This policy will protect important land based carbon sinks such as peatland and woodland projects whilst encouraging new development to promote biodiversity and carbon sequestration.

33. Protecting nature and biodiversity is one of Taylor Wimpey’s key objectives within its Environment Strategy. We recognise the importance of peatlands and woodland to carbon sequestration and agree that these should be protected where possible. It is important to note however that with respect to new development, there can often be many carbon sequestration benefits associated with the creation of multi-functional green infrastructure and on-site planting which should be recognised when considering the overall ‘carbon performance’ of new development.

34. Taylor Wimpey therefore believe that the draft policy should contain text to support new development if it can be demonstrated that the green infrastructure and woodland it provides will sequester carbon. We believe this should be recognised as one of the many environmental benefits that new development can provide.

4. Summary of Representations

35. Taylor Wimpey are pleased to provide our representations to the GCLP in order to ensure the policies are sound and deliverable and facilitate the delivery of much needed private and affordable homes within Greater Cambridge.

36. Taylor Wimpey have a strong corporate commitment to positively address the causes of climate change and reduce our environmental impact and we believe we are making positive progress towards our targets.

37. We fully support many of the strategic objectives of the policy but do feel that some of the detailed targets and requirements within each policy (and specifically Policy CC/ NZ) will bring significant additional financial and technical burden to the house building industry and particularly those in the small, medium and self-build sectors. These policies are likely to have a significant impact upon the land value as these additional costs must result in lower land prices to accommodate the additional construction costs.

38. If the recommendations contained within these representations are implemented then we believe this will create a policy framework capable of meeting the significant demand for housing within the region.

39. We would be pleased to discuss our representations in greater detail with the joint authorities.

Thank you for consulting Natural England on the above in your letter dated 1 November 2021.

Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.

Natural England’s key comments
We are pleased that many of our comments at the Issues and Options stage, in our letter dated 24 February 2020 (ref. 304246), are reflected in the First Proposals Plan, helping to strengthen the Plan’s approach to the ‘big themes’ including climate change, biodiversity and green spaces, wellbeing and social inclusion. Natural England supports the general thrust of the Plan in directing development to where it will have least environmental impact and provide opportunities for enhancements.

Natural England’s previous advice highlighted the need for the Plan to address uncertainties relating to water resources and infrastructure needed to support new growth, in light of evidence that current levels of abstraction are already damaging the natural environment. We also signalled the need for the establishment of a strategic green infrastructure network that is resilient to the scale of proposed Plan development, capable of meeting people’s needs and addressing adverse impacts to the natural environment. We therefore welcome that the First Proposals Plan recognises the challenges in identifying long-term and interim solutions to the current water resource crisis to enable sustainable development without further detriment to the natural environment. We support the Plan’s progress, through the Green Infrastructure Recommendations (LUC, September 2021), in presenting opportunities for the Plan to deliver /contribute towards delivery of strategic green infrastructure.

Notwithstanding the above, Natural England believes significant additional work is required through the next stages of Plan preparation to progress these ‘solutions’ and demonstrate that development can be delivered sustainably. We have major concerns with the scale of proposed Plan development, and the 2041 timeframe for delivery, given the damage already being inflicted on the natural environment and the lengthy lead-in time for identification and delivery of measures to address the water resource issue and to implement strategic green infrastructure. Some of this Plan development is already progressing, through the adopted strategy, prior to solutions being identified and implemented; the natural environment is already being impacted. The Plan should consider how these impacts and spiralling environmental deterioration can be retrospectively

mitigated.

The section on ‘Ensuring a Deliverable Plan – Water Supply’ recognises the challenge relating to water resources; however, the Councils need to act urgently, in collaboration with relevant stakeholders, to identify strategic and interim water resource/infrastructure solutions to ensure any level of proposed development is delivered sustainably. There are currently no measures in place to mitigate the adverse effects of current development on the natural environment i.e., more water is being abstracted from the aquifer to serve this development, depleting groundwater resources and causing further declines in the condition of designated sites and supporting habitat.

Potential solutions to address Greater Cambridge’s green infrastructure deficit, and the recreational pressure effects of development, lie within the Green Infrastructure Initiatives identified in LUC’s Opportunity Mapping Recommendations Report. Natural England fully supports the Initiatives identified; however, these aspirational areas must be progressed into real projects that are happening on the ground by the time the Plan is adopted. Robust Plan policy requirements should secure funding for the delivery and long-term management of these projects from all major development.

We have provided additional comments on the Plan’s key themes and policies below; however, reference should be made to the detailed advice provided in our response to the Issues and Options consultation.

Vision and aims
We support the Plan vision and aims for decreases in our climate impacts and increase in quality of life for communities, minimising carbon emissions and reliance on the private car, increases in nature, wildlife, greenspaces and safeguarding landscapes focusing on what is unique to Greater Cambridge embracing bold new approaches.

Natural England strongly recommends that the vision should advocate a more holistic approach to securing multi-functional benefits through the protection and enhancement of the natural environment. In accordance with paragraphs 17 and 109 of the National Planning Policy Framework (NPPF) the Plan should encourage multiple benefits from the use of land in urban and rural areas, recognising that land can deliver a wide range of ecosystem services required for sustainable development including climate change mitigation, flood management, improved water resources and water quality, biodiversity net gain, accessible high quality green infrastructure and associated health and wellbeing benefits, enhanced landscapes and soil resources.

The Plan should contribute to and enhance the natural and local environment by recognising the wider benefits of ecosystem services, considering a natural capital evidence approach and making strong links to the Nature Recovery Network and the Cambridge Nature Network. National Habitats Network mapping is available to view at www.magic.defra.gov.uk.

Development Strategy
The Plan will deliver around 44,400 new homes and provide for approximately 58,500 new jobs. We welcome that the new development strategy aims to meet our increased need for new homes in a way that minimises environmental impacts and improves the wellbeing of our communities.
The strategy proposes 19 additional sites for development, along with sites already allocated in the adopted 2018 Local Plans, along with associated infrastructure including green spaces.

We support proposals to direct development to where it has the least climate impact, where active and public transport is the natural choice, where green infrastructure can be delivered alongside new development, and where jobs, services and facilities can be located near to where people live. The vision includes creating new city neighbourhoods which have the critical mass of homes, jobs and services to create thriving communities, making best use of brownfield and safeguarded land and making the most of public transport links.

Natural England welcomes the use of evidence including the Employment Land and Economic Development Evidence Study and the Greater Cambridge Housing and Employment Relationships

Report to understand the relationship between future jobs and housing growth. We note that these studies found that planning for the standard method housing figure set by government would not support the number of jobs expected to arise between 2020 and 2041. Planning for this housing figure would risk increasing the amount of longer distance commuting into Greater Cambridge, with the resulting impacts on climate change and congestion. On this basis planning for a higher jobs figure and planning for government’s standard method local housing need figure have been rejected as reasonable alternatives.

We note that high-level consideration has been given to the potential impacts of COVID-19 on the economy of Greater Cambridge, to inform this First Proposals consultation. We support the proposal to gather evidence to consider the potential longer-term quantitative impacts of COVID- 19 prior to the Draft Plan stage to understand any implications for the objectively assessed need for jobs and homes for the plan.

Natural England has no objection in principle to the proposed Plan development strategy; however, this is subject to: 1) the identification of strategic water supply solutions and / or interim measures; and 2) development of deliverable strategic GI initiatives and developer requirements and funding mechanisms being secured through the Plan.

Policy S/DS: Development strategy
Figure 6: Map shows proposed sites to be included in the Plan including existing planning permissions alongside a limited number of new sites in the most sustainable locations. We welcome that the sustainability merits, opportunities and constraints for each of the nine potential strategy choices have been considered through the Sustainability Appraisal. Alongside considering the best locations for new homes and jobs, consideration has also been given to the best locations to restore the area’s habitat networks and provide more green spaces for people providing health and wellbeing benefits. Natural England fully supports the identification of 14 Strategic Green Infrastructure Initiatives, through the Green Infrastructure evidence, to help achieve this. We welcome the approach to preparing the preferred development strategy / draft allocations and green infrastructure initiatives in parallel.

We support the general policy direction to focus development where it will have the least climate impact, where it can be aligned with active and public transport, opportunities for delivery of green infrastructure and where jobs, services and facilities can be located nearby whilst ensuring all necessary utilities can be provided in a sustainable way. We support the approach to using less land for development to reduce carbon emissions and allow more space for nature and wildlife.
The strategy focuses on opportunities to use brownfield land and opportunities created by proposed major new infrastructure.

We note that delivery of the adopted strategy is progressing well with development permitted/underway /completed at the edge of Cambridge sites and new settlement sites including Northstowe and Waterbeach New Town. Natural England is aware that these schemes are being delivered in the absence of adequate sustainable water supply infrastructure to serve the development without adverse impact to the natural environment including statutorily designated sites. Many of these schemes are also unlikely to deliver sufficient level of accessible high quality green infrastructure to meet the needs of new residents without adverse recreational pressure impacts to the existing ecological network including statutorily designated sites. These issues need to be addressed urgently through further stages of Plan preparation as discussed in our advice above and below.

Ensuring a deliverable plan – water supply
We welcome the Councils’ recognition that water supply is a significant issue for the deliverability of the Local Plan and we fully support preparation of the Integrated Water Management Study: Outline Water Cycle (WCS) by Stantec (August 2021) to address this. The WCS has identified the need for new strategic water supply infrastructure, such as a new fens reservoir, to provide for longer term needs, and to protect the integrity of the chalk aquifer south of Cambridge, in addition to a range of interim demand management measures. The draft Sustainability Appraisal also identifies significant environmental impacts if the issue is not resolved. This is a major concern for

Natural England in light of proposed growth levels and the damaging effects that groundwater abstraction is already having on the natural environment including water-dependent designated sites and important chalk stream habitats. Natural England has provided its detailed advice on this matter, and highlighted the statutorily designated sites potentially affected, in our response to the consultation on the WCS. These ‘Designated Sites of Concern’ are listed in Appendix B of the August 2021 report.

We are aware that Water Resources East is currently preparing its Water Management Plan for the region and that this will help to identify long-term measures to address the issue. However, these strategic measures, including a new fens reservoir, are unlikely to be available until the 2030’s hence interim measures are required to enable some level of sustainable growth. We welcome the suggestion of including Plan policies to phase delivery of development that can be supported by a sustainable water supply until new strategic infrastructure is in place; however, it will need to be clearly demonstrated that interim solutions are sustainable and will not cause further environmental decline. The risk is that it may not be possible to demonstrate delivery of the full objectively assessed needs within the plan period.

Natural England appreciates that pressure on water supplies is a regional issue. We share the Councils’ aspirations that the water industry, supported by government, will set out its intentions for positively addressing this key infrastructure issue at an early point in the ongoing plan making process, to provide confidence that adequate water supply will be available to support delivery of the preferred options allocations, before the next stage of a full draft Local Plan. In our view the Councils need to act urgently, in collaboration with relevant stakeholders, to identify strategic and interim water resource/infrastructure solutions, including demand management measures, to ensure any level of proposed development is delivered sustainably.

We have serious concerns that Plan development is already being progressed, through the adopted strategy, without sustainable water supply measures in place. More water will be abstracted from the aquifer to serve this development, depleting groundwater resources and causing further declines in the condition of designated sites and supporting habitat. The Plan will need to consider the impacts of this development and identify measures to address adverse environmental impact.

Natural England fully supports the concerns raised by the Environment Agency, as lead authority on this matter, including the high degree of uncertainty as to whether sufficient sustainable water supplies can be provided for the proposed growth over the plan period without further detriment to the natural environment. Further development of the WCS, informed by evidence from regional and water company water resource plans, will need to demonstrate that appropriate deliverable mitigation measures can support sustainable growth until new strategic water supply infrastructure becomes operational. We agree with the Environment Agency that it in the face of current challenges it may be appropriate to consider an extended timeframe for delivery of Plan development to limit further environmental degradation until new strategic measures become available. This would allow further time for the identification of truly sustainable options that build in resilience to climate change and robust mitigation and monitoring measures to address impacts to the natural environment and restore habitat condition.

Duty to Cooperate
Natural England welcomes consideration of how the Plan fits with other plans and strategies including cross boundary projects such as the Ox Cam Arc. We support recognition of the Plan to be prepared within a wider regional context noting the Councils’ legal duty to cooperate with key stakeholders and surrounding areas of cross boundary issues. We agree that the development of a clear and positive vision for the future of the Greater Cambridge area can help to shape the proposals for the Ox Cam Arc, noting that the outcome of the Oxford-Cambridge framework is currently awaited.

We particularly support the Councils’ recognition that the water supply challenge discussed above is a serious issue to be resolved.

Natural England will be pleased to engage with the Councils in the preparation and development of a draft Statement of Common Ground.

Transport Strategy
Natural England welcomes that the proposed strategy is heavily informed by the location of existing and committed public transport schemes. We support the use of transport modelling to understand whether additional infrastructure and policies are required to address the transport impacts of the preferred development strategy.

Transport policies should include requirements for projects to undertake robust ecological impact assessment and application of the ecological mitigation hierarchy.

Site allocation policies
Proposed site allocation policies are described through sections 2.2 – 2.5. Natural England has no objection in principle to the existing and new allocations, areas of major change or opportunity areas being taken forward for development. However, this is subject to:
• identification of strategic water supply infrastructure and/or feasible interim solutions to demonstrate that development can be delivered sustainably and without adverse impact to the natural environment;
• establishment of a framework and robust plan policies to deliver the 14 Strategic Green Infrastructure initiatives ahead of development, to meet development needs and to address the effects of recreational pressure on sensitive sites and habitats.

The site allocation policies will need to include robust requirements to secure delivery of biodiversity net gain and on-site accessible green infrastructure to meet people’s need and to contribute towards the Plan’s 20% BNG targets and delivery of the Nature Recovery Network / Cambridge Nature Network. Our advice is that major allocation policies should set a framework for development to maximum opportunities for environmental gains.

Climate Change
We welcome the proposed policies relating to net zero carbon and water efficiency, designing for climate change, flooding and integrated water management, renewable energy projects, reducing waste and supporting land-based carbon sequestration. We particularly support the proposed requirement for residential developments to be designed to achieve a standard of 80 litres/person/ day; however, we support the Environment Agency’s concerns as to whether the Plan is likely to achieve the reductions in demand required to support sustainable growth. As indicated above the WCS will need to demonstrate how water, to meet growth needs, will be supplied sustainably without adverse impact to the natural environment.

Proposed requirements for developments to provide integrated water management, including sustainable drainage systems (SuDS) where possible and for SuDS and green /brown roofs to provide multiple benefits (including biodiversity and amenity) are welcomed.

We support requirements for renewable energy projects to consider impacts on biodiversity, geodiversity, landscape and water quality.

Natural England welcomes a proposed policy to support the creation of land and habitats that play a role as carbon sinks and protect existing carbon sinks from development, particularly peatlands such as those remaining in the north of South Cambridgeshire district. We welcome recognition of the importance of peatlands as a carbon store and the role of other habitats such as woodlands and grasslands, noting loss and degradation of natural habitats results in the direct loss of carbon stored within them.

As indicated above we recommend that the Plan takes a more holistic approach to securing multi- functional benefits for climate change, flood management, water resources and water quality through the protection and enhancement of the natural environment. Natural solutions can achieve significant additional benefits for biodiversity, green infrastructure and associated health and wellbeing benefits, enhanced landscapes and soil resources.

Biodiversity and green spaces
We strongly support the proposed biodiversity and green spaces policies and the inclusion of Figure 53 depicting the existing Greater Cambridge green infrastructure network including designated sites.

We welcome that these policies will help to deliver the aims of the Ox Cam Arc of doubling the area of land managed primarily for nature and to deliver a minimum 20% biodiversity net gain on development sites, beyond the mandatory 10% biodiversity net gain requirements of the Environment Act 2021. We agree that Greater Cambridge has a relatively low level of designated sites and priority habitats, highlighting the need for development to deliver net gains beyond the 10% proposed nationally, hence we are fully supportive of minimum 20% BNG ambitions. Our advice is that the Councils, working with key partners, should identify BNG opportunities through the next phases of Plan preparation. This should take the form of a BNG opportunities / requirements map building on the foundations of the Nature Recovery Network and the Cambridge Nature Network. National Habitats Network mapping is available to view at www.magic.defra.gov.uk.

The Councils should also set a landscape / GI framework for the Site Allocations to maximise opportunities for delivery of GI and BNG within the development sites.

BG/BG: Biodiversity and geodiversity
Natural England fully supports this policy and requirements for development to achieve a minimum 20% biodiversity net gain, delivered on site where possible and calculated using the Defra Metric
3.0 or its successor. Requirements for off-site measures to be consistent with the strategic aims of the Greater Cambridge green infrastructure network strategic initiatives are welcomed.

The policy should take a natural capital evidence approach and recognise the wider benefits of ecosystem services for climate change, flood risk management, green infrastructure and health and wellbeing, in addition to biodiversity. They main thrust of this policy should be the Plan’s contribution to the Nature Recovery Network / Cambridge Nature Network and the establishment of a framework for the development of a Local Nature Recovery Strategy.

We support proposed requirements for development to avoid adverse impact to site of biodiversity or geological importance and development to mitigate recreational pressure on statutorily designated sites, applying Natural England’s SSSI Impacts Risk Zones (IRZs). The Plan’s biodiversity policy should recognise the hierarchy of international, nationally and locally designated sites across Greater Cambridge. This should be accompanied by a map of the existing ecological network and enhancement opportunity areas to guide site allocations / development away from more sensitive areas and to identify opportunities for developers to deliver net biodiversity gain enhancements.

We welcome that the policy will seek wider environmental net gains. These should focus on measures to restore ecological networks, enhance ecological resilience and provide an overall increase in natural habitat and ecological features.

Reference should be made to the detailed advice provided in our response to the Issues and Options consultation with regard to protecting and enhancing biodiversity including designated sites, priority habitats, ecological networks and priority and/or legally protected species populations. This includes additional detailed advice on embedding biodiversity net gain into the Greater Cambridge Local Plan policies.

BG/GI: Green infrastructure
We welcome the comprehensive and thorough approach taken in developing the GI evidence base for the Greater Cambridge Local Plan, including the Opportunity Mapping and the identification of 14 Strategic GI initiatives. The multifunctional benefits of GI are fully recognised, as well as the links between GI provision and the delivery of other strategic policy areas including the wider natural environment, sustainable transport and social inclusion. These threads/links

should continue through future drafts to ensure the value of GI for people and the natural environment is fully reflected in the Local Plan.

The Strategic GI initiatives are comprehensive and capture a wide variety of GI opportunities within the 14 proposals; this range of GI elements and habitats will help to maximise benefits for people and nature through the strategic planning and delivery of GI across Greater Cambridge. We support the emphasis given to blue infrastructure in Strategic Initiatives 1 and 2 given the considerable pressures on Cambridgeshire’s chalk streams and aquifer from agriculture and development. The Chalk Stream Strategy Report1 recently published by CaBA identifies a number of recommendations to protect/restore chalk stream habitats, including those in areas of high population density such as Cambridge. This report may be a useful reference in planning and progressing strategic blue infrastructure initiatives as part of the Greater Cambridge Local Plan.

We support the proposed approach to have a distinct GI policy within the Local Plan, rather than a stand-alone SPD. As noted in the Topic Paper, we agree that the policy should require all developments to contribute towards GI and that it should be incorporated into design from an early stage and through all phases of development, with a longer-term plan in place for its management and maintenance. As well as a GI policy, Green Infrastructure should be integrated into other strategic policy areas and Local Plan themes where relevant. This will give weight to the multifunctional role of GI and demonstrate where it can contribute to policy delivery and outcomes (e.g., in climate change adaptation, supporting healthy communities etc). It will also support the role of GI in implementing other mechanisms and tools, such as Biodiversity Net Gain, and may help in targeting and prioritising opportunities for GI creation and enhancement.

In addition to securing GI within individual developments, the Local Plan should also provide a framework for proposals to contribute to / link up with the wider Strategic Initiatives, including the ‘dispersed initiatives’ 10-14 (e.g., ‘Expanding the Urban Forest’). Consideration should also be given to potential join-ups on cross-boundary projects and, in time, how the strategic GI network in Greater Cambridge may contribute to greenspace at the regional level (as one of the 5 Ox-Cam counties). There may also be overlaps with other initiatives, such as the Nature Recovery Network, where Cambridgeshire’s GI resource can make an important contribution (such as that highlighted in Strategic Initiative 3 for the Gog Magog Hills and Chalkland fringe).

We note from the Part 2 Recommendations Report that there are several points for further consideration, including the funding mechanisms required to ensure that all developments include GI and contribute towards the strategic initiatives. Funding mechanisms (e.g., developer contributions) should be embedded in policy where required and should be identified as early as possible to ensure that benefits are secured long-term. For example, the policies for major allocations will need to include specific requirements for the funding / delivery of the strategic GI ahead of the developments being occupied so that these are clear from the outset. The report presents a number of potential funding sources, including land use planning obligations (e.g., S106) agri-environment streams (such as ELMS) and any ad-hoc opportunities that may arise through partnership working. The increasing emphasis on nature-based solutions may also bring in new revenue streams to support strategic projects, given that many NBS will require a landscape scale / ‘ecosystem’ approach. The costings for the delivery of the GI and biodiversity aspects of the Local Plan could be included in the IDP so that the investment required to bring about delivery is clear and transparent from an early stage and factored into development proposals. Given the significant scale of the work required, consideration should also be given to how the land will be secured to deliver the GI initiatives, whether through direct purchase, lease or management agreements. A long-term approach to the management and maintenance of GI (ideally in perpetuity) also needs to be factored in from an early stage.

Alongside its value for natural capital and placemaking, green infrastructure provides alternative natural greenspaces that can help alleviate and buffer recreational pressures on protected sites. We welcome the recognition of the recreational pressure impacts across Greater Cambridge, and

1 1 Catchment Based Approach (October 2021) Chalk Stream Restoration Strategy: Main Report. See: New strategy launched to protect chalk streams - GOV.UK (www.gov.uk)

the Strategic Initiatives aimed at addressing these (e.g., the Coton corridor and multifunctional GI corridors, Strategic Initiatives 7-8). We support the development of clear policy requirements to address these significant pressures (as suggested in the Topic Paper).

Given the Local Plan’s strong emphasis on GI and the widespread benefits that it can achieve, we feel there is clear value in having a recognised GI standard in place. A standard would help to guide and inform GI planning and delivery and provide a consistent benchmark on quality across different scales/locations of development. It would also support the recommendation in the report for a GI-led design approach to new development. A standard could be supported by other documents, e.g., Local Design Guides, to ensure that nature is fully built into design through the provision of high-quality green infrastructure. Natural England is currently developing a Green Infrastructure Framework to set standards for green space and access to natural greenspaces, as well as a Design Guide and mapping data2 to support this work. We would encourage the use of these resources to guide and inform development of strategic Green Infrastructure and policies for Greater Cambridge. The Framework of GI Standards and products are due for launch in summer/autumn 2022, with a pre-release of the beta mapping and the principles of good green infrastructure in December 20213.

Natural England fully supports the proposed inclusion of policies to improve tree canopy cover, enhance river corridors and protect and enhance open spaces. We advise that robust policy requirements should be included to secure delivery of enhancements through development to ensure the achievement of multi-functional benefits for climate change, biodiversity, water quality, access. As indicated in our comments at the Issues and Options stage tree planting needs to be targeted in appropriate locations and considered in the context of wider plans for nature recovery. Consideration should be given to ecological impacts and the opportunities to create alternative habitats that could deliver better enhancements for people and wildlife, and store carbon effectively. Where woodland habitat creation is appropriate, consideration should be given to natural regeneration, and ‘rewilding’ for the economic and ecological benefits this can achieve.
Any tree planting should use native and local provenance tree species suitable for the location. Natural England advocates an approach which seeks to increase biodiversity and green infrastructure generally, not simply planting of trees, and protecting / enhancing soils, particularly peat soils.

For further advice and guidance on green infrastructure please refer to our comments at the Issues and Options consultation stage.

Wellbeing and inclusion
Natural England is fully supportive of the proposed policies including WS/HD: Creating healthy new developments. Our advice is that the policy should include strong links to the importance of adequate level and quality of accessible green infrastructure for people’s physical and mental health and wellbeing.

Great places
Natural England supports the proposed Great Places policies. We welcome the establishment of a Place and Design Quality Panel to conduct a site typologies study to understand, protect, utilise and enhance the valued characteristics of different areas in the plan, with the intention of using this information to raise design standards to ensure development reflects and enhances Cambridge’s distinctive landscape and townscape character.

We support Policy GP/LC Protection and enhancement of landscape character. Natural England is pleased to see that the Greater Cambridge landscape character assessments have been updated and will provide an up-to-date evidence base for the development of policy GP/LC. Existing retained policies form the South Cambridgeshire Local Plan NH/1, NH/2 and NH/13 and policy 8 of the Cambridge Local Plan should be reviewed and updated in the light of these updated landscape

2 See the GI Framework Mapping Portal: https://designatedsites.naturalengland.org.uk/GreenInfrastructure/Home.aspx 3 How Natural England’s Green Infrastructure Framework can help create better places to live - Natural England (blog.gov.uk)

character assessments to ensure they reflect the most recent baseline evidence.

Policy GP/LC seeks to identify, protect and enhance locally valued landscapes. Any locally designated landscapes, e.g., Areas of Greater Landscape Value, should be identified within the plan and given appropriate policy protection to protect and enhance them and to ensure that development reflects their distinctive character. It is not the role of Natural England to define locally valued landscapes – this is for LPAs and their communities. However, it should be noted that NE considers World Heritage Sites designated for their natural interest, local landscape designations and Inheritance Tax Exempt land to be locally valued. Therefore, these areas should be identified and included on policy maps showing locally designated landscapes along with any ‘Protected views’.

The Strategic Spatial Options Assessment appears to have considered a wide range of options based on up-to-date evidence on landscape and townscape character considerations. We support this approach which is useful in identifying and considering key landscape issues early in the Plan- making process, to feed into the Sustainability Appraisal. We note that the appraisal of the strategic spatial options is based on the interim draft findings of the emerging Landscape Character Assessment. We trust that the preliminary conclusions will be updated following completion of this work. The analysis also notes that recommendations are provided for strategic landscape mitigation and enhancement for each of the strategic spatial options. Natural England supports the proposal to identify specific mitigation as part of more detailed studies in locating and designing future development.

We are generally supportive of policies to protect and enhance the Cambridge Green Belt, achieve high quality development and establish high quality landscape and public realm.

Jobs
Natural England supports proposed policy J/AL: Protecting the best agricultural land. We welcome recognition of soil as a valuable resource and key element of the environmental ecosystem which requires protection, in accordance with paragraph 174 of the NPPF. We note that the protection of peat soils is addressed under the climate change theme discussed above.

Beyond the wider water resource / supply issue, discussed above, we have no substantive comments on the other proposed policies. However, policies will need to include appropriate requirements to ensure that all development avoids adverse impact to the natural environment and delivers net gains for biodiversity in accordance with the requirements of policy BG/BG: Biodiversity and geodiversity.

Homes
Beyond the wider water resource / supply issue we have no specific comments to make on these proposed policies subject to the inclusion of appropriate requirements to ensure that all development avoids adverse impact to the natural environment and delivers net gains for biodiversity in accordance with the requirements of policy BG/BG: Biodiversity and geodiversity. Residential development should also contribute towards delivery of the Strategic GI Initiatives.

Infrastructure
Natural England supports proposed policy I/ST: Sustainable transport and connectivity for the environmental and health benefits this could achieve including reduced emissions, air quality and climate change benefits.

We have no substantive comments on the other proposed policies subject to the inclusion of appropriate requirements to ensure that all development avoids adverse impact to the natural environment and delivers net gains for biodiversity in accordance with the requirements of policy BG/BG: Biodiversity and geodiversity.

Habitats Regulations Assessment (HRA)
Natural England supports preparation of the HRA Report by LUC (August 2021). We welcome that this incorporates a screening assessment and Appropriate Assessment. The Screening stage

identifies likely significant effects on European sites, either alone or in combination with other policies and proposals, for several plan policies. These include:
• Physical damage and loss (offsite) – in relation to Eversden and Wimpole Woods SAC.
• Non-physical disturbance (offsite) – in relation to Eversden and Wimpole Woods SAC.
• Recreation – in relation to Wicken Fen Ramsar SAC and Fenland SAC.
• Water Quantity and Quality – in relation to Ouse Washes SAC, SPA and Ramsar site, Wicken Fen Ramsar site, Chippenham Fen Ramsar site, Fenland SAC and Portholme SAC.
The Appropriate Assessment concludes no adverse effect on site integrity as follows: Eversden and Wimpole Woods SAC
Subject to the following safeguards and mitigation measures being implemented:
• Completion of bat surveys for site allocations identified with moderate or high potential to support barbastelle to determine the ecological value of these sites in relation to this bat species and to inform specific mitigation proposals.
• There is a commitment in the plan that proposed development will avoid key habitat features likely to be used by this species and to create and enhance suitable habitat for this species.
• It is also recommended that policy wording in the plan is strengthened to include specific inclusion of the safeguard measures detailed above and that Policy BG/BG Biodiversity and geodiversity is strengthened to include specific reference that mitigation provided should be suitable to the level of protection afforded to designated sites.

Wicken Fen Ramsar site and Fenland SAC
The Appropriate Assessment concludes no adverse effect on integrity as a result of increased recreational pressure provided that the following safeguards and mitigation measures are required by the plan and successfully implemented:
• A commitment in the plan to ensure that development within 20km of the Ramsar site and SAC to provide sufficient suitable alternative natural greenspace in line with advice from Natural England and that there should be specific detail on the policy on the appropriate quantity and quality of open spaces and how delivery and management in perpetuity will be secured.

The Appropriate Assessment is currently unable to conclude no adverse effect on the integrity of the Ouse Washes SAC, SPA and Ramsar, Wicken Fen Ramsar site, Chippenham Fen Ramsar site, Fenland SAC and Portholme SAC, with regard to water quantity and quality, pending the provision of further evidence through the Greater Cambridge IWMS and the WRE IWMP.

We welcome that the HRA has provided a detailed consideration of air quality impacts, associated with Plan development, for the relevant European sites. This is based on best practice Highways England Design Manual for Road and Bridges (DMRB) LA 105 Air quality guidance and considers the potential for traffic-related emissions on the affected road network based on traffic modelling data, in line with the advice provided by Natural England at the Issues and Options stage. Whilst the assessment has ruled out likely significant effects on all relevant European sites Natural England has been unable to carry out a detailed review of this information and will provide comments at the next stage of Plan consultation.

Please note that Natural England is reviewing the Impact Risk Zone (IRZ) for Eversden and Wimpole Woods SAC to take into account the findings of emerging SAC barbastelle tracking surveys being undertaken for major development schemes. It will also take into consideration the availability of suitable foraging resource which is considered to be quite scarce in the local area. In the meantime, until the IRZ is formally amended, and accompanying guidance prepared, we welcome application of a precautionary 20km buffer zone for SAC barbastelles in line with Natural England’s current local guidance.

Natural England is generally supportive of the interim findings of the HRA and will provide further

advice as the HRA is updated in line with the development of Plan policies and further evidence.

Sustainability Appraisal
Through the Sustainability Appraisal (LUC, October 2021) the preferred policy approaches for the Local Plan have been subject to appraisal against the SA objectives. A range of reasonable alternative options has also been assessed, including alternatives to the preferred policy approaches, Strategic Spatial Options and site options. We welcome that the findings of the HRA will be incorporated into the SA and will provide further insight into biodiversity impacts specifically at designated sites, presenting the opportunity to limit adverse impacts at these locations.

We support recognition of the over-abstraction of water in this region as a serious concern. We welcome acknowledgement that action is required now to ensure the availability of water for future uses without detrimental impact on the environment. Natural England agrees that water resource availability and water quality are inter-related and that these are likely to be exacerbated by the effects of climate change.

The new Local Plan presents the opportunity for new development to come forward at the most appropriate locations in order to avoid detrimental impacts on biodiversity assets. However, we support recognition of potential risks to the ecological network including statutorily designated sites, through degradation and other impacts associated with development.

We agree that the new Local Plan provides the opportunity to promote biodiversity gain and to improve the overall ecological network. Natural England also agrees that opportunities identified through the Green Infrastructure Study (2020) could support delivery of Natural England's Habitat Network nearby opportunity zones and support pollinator corridors. Robust plan policies will need to be developed to secure delivery of these enhancements through all relevant development.

The report concludes that overall, the proposed direction of the Local Plan performs well in sustainability terms with a strong focus on providing an appropriate amount of development and policies focused on minimising carbon emissions, particularly through minimising the need to travel, using land efficiently and making the most of existing and planned sustainable transport links. Natural England suggests this is a premature conclusion in the current absence of strategic water supply infrastructure and sustainable interim measures. Development through the adopted strategy is already being progress without these measures in place. Further development of the Green Infrastructure Initiatives is also required to ensure adequate GI to meet development needs and to alleviate recreational pressures on some of our most sensitive sites habitats. Robust plan policies, to secure timely delivery of this strategic green infrastructure, will be required to demonstrate the Plan’s sustainability.

We generally welcome the policy recommendations presented within Chapter 5 of the SA report including reference to the mitigation hierarchy within Policy BG/BG: Biodiversity and geodiversity and stronger commitments to protect and enhance biodiversity within this and the site allocation policies. However, in our view SA recommendations should focus on the urgent requirement for the identification of strategic and interim water resource/infrastructure solutions and further work to progress the GI Initiatives into real projects.

Natural England will provide further advice as the SA is updated in line with the development of Plan policies and further evidence.

We hope our comments are helpful. For any queries relating to the specific advice in this letter only please contact Janet Nuttall on […]. For any new consultations, or to provide further information on this consultation please send your correspondences to consultations@naturalengland.org.uk.

Vision and aims
I support the vision and aims of the Local Plan and the general direction of the development strategy, but am concerned about the overall scale of development and the continuing high levels of growth which are driven by technical economic growth forecasts.

How much development, and where – general comments
I recognise that Greater Cambridge has a strong and nationally important economy, but I do not support the continuing pace and scale of high levels of growth that has increasing cumulative impacts on the environment, water supply, heritage and carbon emissions.
I would argue that the growth of the Cambridge and the impacts of that level of growth on South Cambridgeshire are disproportionately high (a third higher than the government targets) compared with other Local Plans, because the scale of growth is driven by technical economic forecasts studies and the desire to continue to stoke the engine of growth yet again.
The area over the last 30 years has absorbed major levels of development which has brought many benefits and disbenefits.
But the time has come with this Plan, in a new era having to seriously address the causes and impacts of climate change and net zero carbon goals to set t Cambridge on a different course.
The development strategy should with this Plan start to reduce the scale of growth to more manageable levels, perhaps towards the Low option so as to set the direction of travel for the next planning round in the era of climate change .

S/JH: New jobs and homes
The level of new homes proposed in the Plan is driven by the need to enhance economic growth, so much so that it is 37% higher than the Government targets for the area.
This proposes larger amounts of housing growth in the surrounding South Cambridgeshire District to serve Cambridge and the surrounding area.
A large amount of new development proposed in the housing pipeline is already allocated to known sites. A moderated target would lessen the uncertainty of deliverability, ease of the identified water supply issue and give time to for water companies to decide and implement sound options, and reduce climate impacts.
Even a moderate reduction in the housing target, which goes so far beyond what the Government requires, could provide more reserve housing sites, providing flexibility to maintain a five year housing supply, reduce pressure on villages and start to slow the pace of change in an area, which has seen so much cumulative change over the recent decades.

S/DS: Development strategy
I generally support the Development Strategy that supports sustainable development and proposes compact active neighbourhoods in Cambridge, development and /or expansion of new towns connected by good public and active transport and the proposals for very limited new development in the rest of the rural area.

S/SH: Settlement hierarchy
I support the proposed Settlement hierarchy policy area as a means of planning and directing new development towards the most suitable and sustainable locations.
In my comment on the rest of rural area, I am concerned about the impact of unallocated housing windfalls being used by possible speculative planning applications contrary to the development strategy to direct development to the most sustainable locations.
I would suggest that the word indictive in the proposed policy SS/SH is omitted to strengthen and add clarity to the proposed policy in the light of the revised annual windfall target.
Support the reclassification of Cottenham and Babraham villages to provide locations for development and new jobs on good public transport routes.

S/SB: Settlement boundaries
I support the work on the development of Settlement boundaries, especially to protect the open countryside from gradual encroachment around villages and on high quality agricultural land.
The work on settlement boundaries should include the involvement of Parish Councils at an appropriate stage in the development of the Policy because of their local data and knowledge of past development.

Cambridge urban area - general comments
Support in Cambridge urban area for good designed, active compact new developments, reuse of brownfield land and continued development of larger neighbourhoods where possible.

S/NEC: North East Cambridge
Support the development of NE Cambridge as a sustainable neighbourhood with good public transport and active transport into Cambridge

Edge of Cambridge - general comments
Support edge of Cambridge planned new neighbourhoods and new sustainable developments and settlements of sufficient size to cater for daily needs and with good access to public and active transport

New settlements - general comments
Support for new settlements of substantial size to cater for more than local needs. I particularly support the growth of Cambourne which can provide good rail access into Cambridge and to the West in the mid-term from new East West rail infrastructure.

S/BRC: Babraham Research Campus
Support the release of land from the Green Belt to support nationally important R and D and life science jobs located near to public transport routes and active transport.

S/RSC: Village allocations in the rural southern cluster
NB, Policy has different name on map page.
In accordance with reducing carbon emissions, and supporting access to the existing rail network the villages of Shelford and Whittlesford could be locations for more sustainable development, despite Green Belt locations

S/SCP: Policy areas in the rural southern cluster
Support existing site allocations to be carried forward including the expansion of Babraham research campus using Green Belt land

Rest of the rural area - general comments
I support the development strategy approach which directs new development to a limited number of sites in the most sustainable development locations supporting the sustainability of villages.
There is still the matter of the unallocated housing windfall development identified in the strategy Topic Paper of 5345 homes for 2021-2041 which is not included in the additional allocated land target of the 11596.
The anticipated dwellings per year for SCDC is between 240 and 255 dwellings a year. Notwithstanding the proposed policy SS/SH, there is a risk that developers will seek speculative permission in the open countryside greenfield sites contrary to the development strategy using the windfalls allocation and I have made a comment on this on Policy SS/SH.

Climate change - general comments
All new development will have impacts relating to increasing carbon emissions and require adaptation responses. A Local Plan can only seek to mitigate these impacts and by far the most impacts are from the existing development, their use and getting around using carbon fuelled transport.
The rate of change in and around Cambridge over the past 30 years has been significantly greater than for just local needs, mainly to develop nationally important economic development. This Plan continues this approach despite the issue of climate change and water supply and large amounts on new development still to be implemented from current Local Plans.
I would argue that the time has now come to step back from this direction of travel and begin to reduce the scale of growth around Cambridge using the Low option as a first step.
I was hoping, given the aims of the Plan and the input of the Net Zero Carbon study for a more radical Plan which addressed climate change and zero carbon targets through aiming to reduce the total amount of new development to meet local needs need and move to a position which is in line with Government targets in the next planning round.

CC/NZ: Net zero carbon new buildings
Support in general
Although I have concerns about how for example heat pump technology can be installed and used at reasonable cost in new development.

CC/WE: Water efficiency in new developments
Support, important given the water supply issues coming forward up to 2041

CC/DC: Designing for a changing climate
Support especially with regards balancing insulation and overheating with increasing hot to very hot summers risk brought about through a changing climate.
Site wide approaches should include appropriate lower densities through good design which allow for beyond minimum garden space and space for Suds and open space and greening.

CC/FM: Flooding and integrated water management
Support
Especially permeable surfaces and integration of water management with enhancements to biodiversity and greening.

CC/CS: Supporting land-based carbon sequestration
Support the creation of land for use as carbon sinks through the development process. Perhaps a suitable use of land in the Green Belt or on lower grade agricultural land.

Biodiversity and green spaces - general comments
Support the identification of 14 strategic GI initiatives and enhancing the linkages between GI and open spaces to provide corridors for wildlife.

BG/BG: Biodiversity and geodiversity
Support delivery of a minimum 20% biodiversity net gain.
I would comment that funding for long term management of biodiversity assets is key for the long-term benefits from such a policy.
I could also emphasis the creation of winter wet areas, water space and Suds designed to benefit enhanced biodiversity should be planned in to developments at an early stage

BG/GI: Green infrastructure
Support the use of a GI standard, particularly on larger developments.
In particular early identification of GI and biodiversity assets and potential gains as an early part of the design process and /or planning brief

BG/TC: Improving Tree canopy cover and the tree population
Support increasing tree and woodland cover, ensuring right tree(s) in right places and species futureproofed for lifetime changing climate adaptation.
A particular opportunity is the rural field margins of agricultural land to help increase the linkages and biodiversity gains and in specific places the creation of woodland belts in the open countryside, green belt land and around villages.
In Cambridge urban areas, where there are existing trees there is a need to plan their replacement with adaptation species to gradually adapt to a changing climate.
Also, to provide sufficient future tree cover to mitigate the urban heat island effect, provide shade and mitigate microclimatic effects.

BG/RC: River corridors
Support the protection and enhancement of river corridors and restoration of natural features and use of GI to support the alleviation of flooding risk.
Support the delivery of the continuous Cam Valley Trail.

BG/PO: Protecting open spaces
Support the protection of the wide variety of open spaces and use of Local Green Space designation in appropriate locations

BG/EO: Providing and enhancing open spaces
Support the provision of open space and recreation provision, including appropriate play space.

WS/HD: Creating healthy new developments
Support the use of health impact assessments in proposals.
I would comment that with the increase in ride on electric vehicles and increasing older communities there are opportunities to coordinate with transport professional the delivery of smooth pathways with minimal dropped kerbs which gives smoother access to local centres and bus stops linked to older persons housing and also can prevent falls.

GP/PP: People and place responsive design
Support the requirement of inclusion of a comprehensive design and access statement and recognise the importance of good design tailored to the local area and involving local communities and Parish Councils particularly in villages.

GP/LC: Protection and enhancement of landscape character
Support the use of landscape character assessment to enhance the setting of Cambridge and protect and enhance the setting of villages.

GP/GB: Protection and enhancement of the Cambridge Green Belt
National guidance places great importance on Green Belt policy and sets out how planning proposals should be considered.
I support the use of GI and other opportunities to provide access and increase tree and woodlands where appropriate in the Green Belt.
But I think where there are locations where there is good public transport especially rail access or future rail access there is a good case to consider the special circumstances judgment.
I think it is time to question if this national policy is still relevant to the situation Greater Cambridge in the period up to the middle of the century. Further Green Belt assessments may be better served by considering sustainable development and the extension of the Green Belt to prevent coalescence around villages beyond the current Green Belt boundary which was made before most of the new development (over 70%) is beyond the current outside boundary or further modification of this policy to enable growth to be planned for the 21st century rather than the conditions which related to the last century.

Jobs – general comments
I am concerned about the scale of economic growth in the area and its use to drive large amounts of housing growth well about what would be required in other planning areas.
However, I support the life science sector and its national importance and the appropriate development in science parks including their expansion using Green Belt land

J/AL: Protecting the best agricultural land
Support the restriction of development on the best agricultural land as supported in the Sustainability Appraisal.

Homes – general comments
Support the objective for planning enough housing to meet our needs, including affordable housing to rent or buy.
I object to needs being directly driven by future economic assessments, the direction of travel of the plan should be as much balanced by the climate change as future economic demand.

H/HD: Housing density
Support design led approach to determine optimum capacity of sites and appropriate density to respond to local character, especially in villages.

H/GL: Garden land and subdivision of existing plots
Support for controlling the use of gardens for new development.

This should be key to all development and this could go further in terms of sustainability
We endorse net zero carbon in new builds and this should be a priority.
We are concerned about the lack of water in South Cambridgeshire so water efficiency is a priority.
A priority for all developments. Further research needs to be undertaken to understand the future challenges we face.
A priority for all developments
A priority for all developments we need to keep ahead of new renewable technologies and review these yearly.
Key. (See document)
Key

This policy will protect important land based carbon sinks such as peatland and woodland projects whilst encouraging new development to promote biodiversity and carbon sequestration.
We recognise the importance of peatlands and woodland to carbon sequestration and agree that these should be protected where possible. It is important to note however that with respect to new development, there can often be many carbon sequestration benefits associated with the creation of multi-functional green infrastructure and onsite planting which should be recognised when considering the overall ‘carbon performance’ of new development.
Countryside therefore believe that the draft policy should contain text to support new development if it can be demonstrated that the green infrastructure and woodland it provides will sequester carbon. We believe this should be recognised as one of the many environmental benefits that new development can provide.

We strongly welcome this policy because protecting carbon stocks is critical to averting climate disaster. We urge that this policy does not focus solely on peatland but on all land-based carbon stocks (as set out in Natural England Research Report NERR094 which we note is one of the studies cited). Grassland (including urban green spaces), scrub, hedgerows etc all store carbon.
We would also reiterate the important distinction between a carbon sink (actively drawing down carbon from the atmosphere) and a carbon stock (carbon that is already locked away). It is vital to protect our carbon stocks even if they are not currently carbon sinks (see also our response under Climate Change - general
comments).