S/NEC: North east Cambridge

Marshall recognises the approach that the GCSP are taking regarding the timescales for the Local Plan relative to the North East Cambridge allocation.

Whilst the approach to the Local Plan and North East Cambridge AAP / DCO is acknowledged, there is a risk that the relocation waste water treatment plant proposals could be delayed, which in turn will influence the remaining stages of the Local Plan process, should the Local Plan continue to be contingent on Anglian Water’s DCO. The GCSP should consider accelerating the Local Plan ahead of the DCO if this begins hold up the progress of the Local Plan.

Marshall is continuing to work proactively with Anglian Water to consider opportunities to interlink the new waste water treatment plant site with Cambridge East. This includes looking at opportunities to join-up connectivity through walking / cycling routes and opportunities to deliver green infrastructure and biodiversity net gain.

The NECAAP Area is expected to deliver a total of up to 8,350 dwellings, including around 4,000 during the Local Plan Period to 2041.

This is a strategic-scale residential allocation which is focused on a relatively small and highly constrained development site. High densities and high building heights would be required to enable the capacities that are envisaged, and we are of the view that the stated numbers will not be deliverable, particularly within the timescales that are envisaged. The relocation of the existing sewage works and associated site remediation works, which are subject of a Development Consent Order (DCO)(unlikely to be determined until 2023 at the earliest), are just one of a number of factors which could negatively impact on timescales and reduce the delivery of housing completions within the plan period.

We consider that the Councils should review both the overall quantum of residential development to be allocated to the NECAAP Area, and the ability of the site to deliver within the Local Plan Period to 2041. This should take into account the likely lead-in times of recent strategic-scale developments in the Greater Cambridge area (e.g. Waterbeach) and both local and national housebuilding rates, to inform what the site can realistically deliver within the period to 2041. The site’s contribution to the housing trajectory should be revised downwards, accordingly.

Policy S/NEC: North East Cambridge
I object to the inclusion of this area for development. There is no operational reason to relocate the current water treatment works other than to enrich the current owners, which includes the City Council. The proposed sites for the new water treatment facility are all located in the green belt. The net result of this proposal will therefore be the reduction of the green belt. The further expansion of the Trinity Science Park further exacerbates the need of housing in Cambridge and is unnecessary.

Savills (UK) Ltd are instructed by their client, Brockton Everlast, to make necessary and relevant representations to the emerging Greater Cambridge Local Plan which has been published at Regulation 18 stage. This new Local Plan will be the first joint Local Plan prepared by Cambridge City and South Cambridgeshire District Council and reflects the strong symbiotic relationship between the built-up area of the City and the surrounding rural settlements. The two administrative areas effectively act as one planning unit since the City acts as a focus for many living within South Cambridgeshire who look to Cambridge for their daily employment, retail, leisure and recreation needs. The new Local Plan consequently has to acknowledge the characteristics within this wide geographic area and acknowledge the very real development pressures that pertain within and around Cambridge.

As such, a development strategy that acknowledges the role of Cambridge as the focus for growth needs to be a key integral part of any new plan and in such a context it is vital that land as a scarce resource is fully assessed to ensure that best use is made of such areas within such a sustainable location.

Brockton Everlast is a property investment company formed back in 2006 and more recently has acquired significant new land holdings at Cambridge Science Park and on the western and eastern side of Milton Road, all of which fall within that area identified as North East Cambridge and which is the subject of an emerging Area Action Plan.

The publication of the Greater Cambridge Local Plan – First Proposals places significant weight on North East Cambridge to deliver significant number of new jobs, homes and community infrastructure in the plan period up to 2041 and in such a context it is entirely appropriate that Brockton continue to work with the Councils to deliver such sites as part of the strategic approach within this new Local Plan.

This is consistent with national planning policy (paragraphs 81 and 82 of the NPPF) which requires local plans to support economic growth and productivity and in such a context the Council is proposing the “medium” level of jobs (58,500 jobs) to represent the objectively assessed need for jobs in Greater Cambridge for the plan period to 2041.

These new jobs are likely to come forward within the following employment clusters:

• Life sciences (Including healthcare, biotechnology and biomedical activities)
• Information Technology and communications (ICT)
• Professional services
• High-tech/advanced manufacturing

The above sectors are not exclusive since many other types of industry, together with the agriculture and tourism sectors play an important role to ensure a variety of jobs and services for local people.

The land at North East Cambridge( and including land controlled by our clients) will play an absolutely critical part of the delivery of new jobs and homes and reflects the need for any development strategy for the Greater Cambridge area to identify an approach which looks firstly at the densification of existing urban areas – the primary location of development within the urban area is at North East Cambridge.

This is the major brownfield site within Cambridge urban area which has been taken forward separately via an Area Action Plan. The whole area has clear potential to accommodate significant redevelopment having regard to its access to services, facilities, public transport links, established employment hubs and the main commercial and retail centres, resulting in positive benefits in terms of health, climate change mitigation, air quality, economy and employment.

It is this concentration of development in this part of the urban area that represents fewer environmental impacts on the wider greater Cambridge area.

The acknowledgement that the NEC will play a key part in the delivery of homes and jobs is supported and in this context the policy direction is for a higher density development in order to achieve the vision of a compact, walkable and mixed-use City district. As a major landowner within North East Cambridge, Brockton Everlast will be bringing forward new development sites to help deliver the policies and proposals within the emerging Local Plan and the emerging Area Action Plan. It is noted that prior to Brockton securing its new ownerships off Milton Road, the previous landowners had not submitted the new floorspace figures to reflect the redevelopment potential of those sites and consequently the Councils will need to acknowledge that higher employment figures may well be achieved as a result of new redevelopment proposals on those sites.

Separate to the joint Local Plan, the councils are also preparing an Area Action Plan for North East Cambridge which will provide a detailed planning framework containing site specific policies and key requirements which will be of equal status to those in the Local Plan once adopted. St John’s College has welcomed the opportunity to engage throughout this process and looks forward to continuing engagement. It is important that developments that will not prejudice the ambitions of the plan continue to be considered on their own merits whilst the specific policies are evolving.

Too much reliance is placed on this site in the development strategy to deliver a significant quantum of housing especially when considering its complex nature, high infrastructure costs and the uncertainty around the timing and assessment of the WWTW relocation. We are of the view that the quantum of development is far too high for the size of the area allocated for housing and the various site constraints.

We raise several questions in our attached comments regarding the biodiversity net gain, townscape impacts, implementation of the trip budget and the robustness of the viability appraisal.

The RSPB was very pleased to see that the Biodiversity Net Gain provision in the submission draft of the NE Cambridge Action Plan has been increased to 20% in line with Greater Cambridge’s ambitions under the OxCamArc Environment Principles. Although the new biodiversity policy BG/BG will set out a 20% target, it would be worth cross referencing this requirement in any supporting text. In addition, although this is dealt with in more detail in the action plan, we believe that there should also be headline targets or objectives within the allocation policy related to water demand, green infrastructure and sustainable urban drainage, or appropriate references to requirements set out in the associated climate change and great places policies.

Axis Land Partnerships wish to object to the assumed housing trajectory lead in time and build out rates for site allocation S/NEC. Please see Station Fields Representations Report December 2021 (submitted under response to Policy S/DS) - Section 2 and Appendix 1 Tables 1 – 4 - ID: 59040

We are of the view that the quantum of development is far too high for the size of the area allocated for housing and the various site constraints.

This gives rise to significant challenges in terms of townscape impacts, biodiversity net gain, sustainable drainage, open space provision and transport mitigation.

Furthermore, the remediation of the site and DCO process is likely to negatively impact on delivery timescales and affordable housing provision.

I note you considered and rejected the alternative of retaining a consolidated Waste Water Treatment Works on the present site. I am doubtful whether the benefits of the proposed relocation justify the disruption and loss of Green Belt land inevitably resulting from relocation of the Waste Water Treatment Plant.

Policy S/NEC and the policy direction is supported. The early commercial and residential phases at Cambridge North provides an opportunity to meet an identified need for commercial uses and mixed tenure, Build to Rent housing. The Site also presents a significant opportunity for redevelopment whilst still being able to respond to local character. They have the potential to create a scheme of high design quality that would make a significant contribution to the emerging city district at Cambridge North. They will both generate the critical mass that generate exciting new places.

The exclusion of a draft allocation for CSPN at this stage is regrettable and it is TCC’s view that following a review of both the supporting evidence bases for the JLP and North East Cambridge Action Plan (NECAAP), that neither documents current aims are deliverable without CSPN being allocated.

Procedurally, the evidence base for Policy S/NEC was published on the 22nd November, only allowing 3 weeks for responses.
Deliverability of Policy NEC AAP and the impact on adopted Policy E/1.
Concerns regarding the jobs growth proposed, and evidence base.
Deliverability of S/NEC without a strategic intervention to address unresolved transport concerns.
The open space deficit, and deliverability of S/NEC without the strategic scale public formal and informal open space proposed at CSPN.
Out of date and / or inaccurate evidence base in support of the policy.

The National Trust has concerns about the sustainability of development at this location. This high-density allocation will not deliver the councils aspirations for ‘biodiversity & green space’ or ‘great places’. It is also one of the key motivators to damage the Green Belt by moving the sewage treatment plant. Existing infrastructure is under enormous pressure on this side of the city, including green infrastructure, tourist destinations such as Anglesey Abbey, Wicken Fen & Milton Country Park and the A10.

The delivery of development in this location is reliant upon the relocation of the Cambridge Waste Water Treatment Plant. For clarity and transparency we consider that the proposals map should identify the location of the site of the proposed new Waste Water Treatment Plant. The Plan should also make it clearer in its Development Strategy (Policy S/DS) that the proposed site for the new treatment plant is located in the Green Belt. Therefore, although North East Cambridge is a brownfield site, its delivery is reliant on the release of land from the Green Belt to facilitate the relocation of the waste water treatment plant.

It is also unclear what the alternative would be if Development Consent for the relocation of the waste water treatment plan was not granted. There is currently uncertainty about the deliverability of North East Cambridge for the number of homes proposed.

Existing infrastructure is under enormous pressure on this side of the city, including green infrastructure, tourist destinations such as Anglesey Abbey, Wicken Fen & Milton Country Park and the A10.

Cambridge urban area
14. CPRE considers that some of the regeneration proposed within the Cambridge urban area, for example the
Travis Perkins site, is welcome. However, there are other proposals which seem badly thought out and not
in the best interest of the city or its residents.
15. The level of boring, high rise, slab development around the station has already turned this into a
characterless area without charm or visual interest. It could be anywhere. More, similar development will
only worsen an already bad situation.
16. CPRE are most concerned about the nature and scale of the North East Cambridge proposals. They are
predicated on Anglian Water moving the only modernised sewage treatment plant in the area with spare
capacity, into the Green Belt. The planned developments appear too high, characterless and lacking in a
practical base for a thriving community, so close to the expanded A14. Discussion with Anglian Water on
how they might reduce the environmental footprint and physical area of their existing site could still yield
some land for industrial and housing development. The Anglian Water site would form a convenient
barrier between new developments and the A14. It is also strange that proximity to the existing Guided
Busway is given as a positive factor. Are the people living here expected to commute to St Ives? Because
from Milton the busway ceases and its vehicles run on the city streets.
17. We are concerned that the area around Shire Hall and in particular the Castle Mound, with its view of Ely
Cathedral on a clear day, will not be damaged by the type of unsympathetic development which has
occurred elsewhere in the city.

Infrastructure policies
86. CPRE are very concerned about current infrastructure proposals for the Cambridge region and the damage and cost they are likely to cause.
87. CPRE strongly opposes the proposed move of the existing Cambridge Waste Water Treatment plant from
its current location into the Green Belt. Anglian Water claim in their submission to the Planning
Inspectorate requesting a Scoping Opinion that it is local planning authority pressure for the developments
in North East Cambridge which is forcing the move. However, in the Scoping Opinion for the proposed
relocation prepared by the Planning Inspectorate, on page 6 of Appendix 2, the Shared Planning Service
response states: “We would like to clarify that the relocation of the Cambridge WWTP is not a
“requirement” of the North-East Cambridge Area Action Plan and must not be referred to as such. This is
because we are not requiring the relocation, but the NEC AAP7 and the emerging joint Local Plan have
identified the opportunity that the relocation creates for homes and jobs in the North-East Cambridge
area.” So, we can only assume that the North East Area Action Plan can be progressed without the
financially and environmentally costly move of the WWTP. This is very welcome news.
88. CPRE believes that the current local government structure in Cambridge and South Cambridgeshire with
four different authorities claiming responsibility for some aspects of transport planning and delivery,
coupled with the divided responsibility for rail infrastructure between Network Rail and East West Rail
Company Ltd, prevents any form of joined-up thinking about transport.
89. CPRE believes that all public transport planning in the county should be practically and actually brought
under the control of the Combined Authority with delivery by the County Council, National Highways and
Network Rail as appropriate.
90. CPRE are particularly concerned by the activities of the unelected Greater Cambridge Partnership (GCP). Its
proposed busways will be a disaster for the countryside and communities and an expensive duplication of
facilities that could be provided by road and rail using mostly existing infrastructure. The responsibilities of
this body should be re-allocated to those identified in paragraph 89 above in order that the GCP can be
disbanded.
91. CPRE are concerned that East-West Rail has failed to consider local transport needs in its planning and as a
consequence is currently following a route in Cambridgeshire and Bedfordshire which will maximise
damage to the countryside, deliver the least useful local transport facility and not integrate well with the
main rail network. Local MPs have taken up this case with government but so far to no avail. The danger is
that the Treasury will halt the project because of lack of return on investment and Cambridge will be left
without the core of what could have been a climate-friendly metro service.
92. There is a desperate need for an integrated transport plan for the whole county and the current approach
will not realise one.
93. CPRE supports Policy I/DI: Digital infrastructure.

Thank you for consulting Historic England on the First Proposals Public Consultation for the Greater Cambridge Local Plan. As the Government’s adviser on the historic environment Historic England is keen to ensure that the protection of the historic environment is fully considered at all stages and levels of the local planning process.

Cambridge is a beautiful, compact and historic city. It is also an historic seat of learning with a very high concentration of highly graded heritage assets. Much of the city is covered by Conservation Area status. The river corridor, green fingers and open spaces, with cows grazing in meadows even at the heart of the city, shape the character of the townscape and landscape.

Although a relatively flat landscape, the elevated positions to the west and south of the Cambridge afford important views across the city skyline, which is one of extensive tree cover and emerging spires. The flatter Fens landscape to the north and east provides very long-distance views of the City and the big east Anglian skies.

The surrounding rural hinterland of South Cambridgeshire comprises over 100 villages, each with their own unique character and heritage. New settlements are an important feature of the district, with their own special identity and are growing rapidly.

We recognise the area faces intense pressure for growth, driven by both the economic success and the attractiveness of the area, in large part a consequence of

its rich architectural and cultural heritage. This growth must be carefully managed to ensure that the very things that contribute to its success are not harmed in the process.

It is for this reason that Historic England is keen to ensure that the emerging plan gives full consideration to the historic environment, both in the choice of site allocations and policy criteria for sites, as well as through a robust and clear suite of historic environment and other policies that seek to both protect but also enhance the historic environment.

We have reviewed the Draft Plan and consultation material with a view to providing advice on heritage matters.

As a general comment, Historic England welcomes emerging plan and work undertaken to date. We have however identified below some of the key issues to be addressed in progressing the next iteration of the Plan: This should be read in conjunction with Appendix A which provides more detailed comments on these and other more minor issues.

a) Site Assessment and the need for Heritage Impact Assessments

We are pleased to note that a degree of site assessment has already been undertaken in relation to the historic environment. These are set out in the HELAA Report, especially Appendix 4.

To date, the assessment of sites is fairly high level and brief but provides a useful starting point, in particular helping to identify immediate showstoppers. We note that many of the sites are shown as amber.

As we have discussed previously, the need for further assessment of heritage in terms of significance, impact on that significance, potential mitigation and enhancements etc will be needed for the site allocations. There is currently an insufficient evidence base in this regard. We therefore welcome your commitment to undertake Heritage Impact Assessments for site allocations. These should be prepared prior to the next draft of the Local Plan.

This further assessment, known as Heritage Impact Assessment (HIA) should follow the 5 step methodology set out in out in our advice note, HEAN 3 on Site Allocations in Local Plans https://historicengland.org.uk/images- books/publications/historic-environment-and-site-allocations-in-local-plans/.

HIAs should be proportionate (both to the scale of the site and the assets affected). All potential sites will need to be appraised against potential historic environment

impacts. It is imperative to have this robust evidence base in place to ensure the soundness of the Plan. We recommend that the appraisal approach should avoid merely limiting assessment of impact on a heritage asset to its distance from, or inter-visibility with, a potential site.

Site allocations which include a heritage asset (for example a site within a Conservation Area) may offer opportunities for enhancement and tackling heritage at risk, while conversely, an allocation at a considerable distance away from a heritage asset may cause harm to its significance, rendering the site unsuitable.

Impacts on significance are not just based on distance or visual impacts, and assessment requires a careful judgment based on site visits and the available evidence base. Cumulative effects of site options on the historic environment should be considered too.

The following broad steps might be of assistance in terms of assessing sites:

• Identify the heritage assets on or within the vicinity of the potential site allocation at an appropriate scale
• Assess the contribution of the site to the significance of heritage assets on or within its vicinity
• Identify the potential impacts of development upon the significance of heritage asset
• Consider how any harm might be removed or reduced, including reasonable alternatives sites
• Consider how any enhancements could be achieved and maximised
• Consider and set out the public benefits where harm cannot be removed or reduced

The HIAs should assess the suitability of each area for development and the impact on the historic environment. Should the HIA conclude that development in the area could be acceptable and the site be allocated, the findings of the HIA should inform the Local Plan policy including development criteria and a strategy diagram which expresses the development criteria in diagrammatic form.

Which sites require HIA?

Ideally all sites should have an HIA, albeit proportionate to the site and heritage sensitivities.

For existing allocations being carried forward into this Local Plan, the HIA is less about the principle of development (that has already been established through previous plan allocation) and more about exploring capacity, height, density and any heritage mitigation and enhancement opportunities so that these can then be

included in the updated policy wording.

For new allocations, the HIA will be a more holistic view and consider both the principle of development as well as the other matters identified above.

b) Policy Wording for sites

If, having completed the heritage impact assessments, it is concluded that a site is suitable for allocation, we would remind you to include appropriate policy criteria for the historic environment in the policy. Please refer to the advice we give on policy wording in the attached table.

It can be helpful to refer to an HIA in the policy wording. Concept diagrams can also be useful to include in the plan to illustrate key site considerations/ recommendations.

c) Edge of Cambridge sites

The Plan proposes carrying forward a number of partially built out allocations on the edge of the City as well as some minor extensions to these. The Plan also proposes revisiting the dwelling capacity/density for some of these sites e.g. Eddington.

Proposals for North East Cambridge are very high density and also quite tall.

The Plan also includes a very large new allocation at East Cambridge (previously released from the Green Belt and allocated in the 2006 Plan, although not in the 2018 Plan). The number of dwellings now being proposed represents a significant increase in density from the 2006 Plan.

We have some concerns regarding these densities and heights on edge of Cambridge sites. Development at very high densities/heights and the potential impact on the overall setting of this historic city. HIAs should give careful consideration to the issue of development and site capacity and height – we will be looking for evidence in this regard.

d) Historic Environment Policy

We welcome your intention to include a policy for the Historic Environment. This should cover both designated and non-designated heritage assets. Policy wording should be in line with the NPPF but we are also looking for a local flavour.

Policies should be spatially specific, unique to the area, describing the local characteristics of the area and responding accordingly with policies that address the local situation.

You should also include a policy for Heritage at Risk and a policy for historic shopfronts. For further detail see Appendix A.

e) Design Policy

We welcome the proposals for a design policy on the plan. We note that this policy is also intended to address tall buildings. We are concerned that the policy might become overly long and detailed, given it is covering such a wide and important range of issues and wonder whether separating out tall buildings into a separate policy might be helpful?

f) Tall Buildings Study and Policy

Related to the above, given the growth pressures that we would anticipate Cambridge is likely to experience over the coming years, we are pleased to see that the matter of Tall buildings and the skyline will be addressed in policy.

We had understood that you were commissioning a study in relation to tall buildings and the skyline policy. Is this still proposed to inform the policy in the next draft of the Local Plan?

See our advice note HEAN 4 and the consultation draft of HEAN 4. Any policy should indicate what considerations are needed for taller buildings, where buildings may or may not be appropriate etc. and in particular consider in the impact on the historic environment.

We broadly welcome policy 60 and Appendix F of the 2018 Cambridge City Local Plan. However, we consider that this could be further supplemented to indicate which areas may or may not be suited to taller buildings. Our advice note in relation to tall buildings provides further guidance in this respect

We have been having discussions with the team preparing The North East Area Action Plan in relation to tall buildings studies and have provided a detailed advice letter in that regard. Please refer to our advice letters in relation to NEA Action Plan and tall buildings for further information on our position.

g) Other Supporting Evidence

We welcome the preparation of the HELAA although consider that further, more detailed evidence is needed in relation to heritage impact and so welcome your intention to prepare HIAs for site allocations.

We broadly welcome the Strategic Heritage Impact Assessment including the baseline study of the setting of Cambridge. However, we have expressed some concerns regarding some aspects of this baseline, in particular the weighting given to some of the key characteristics and aspects of setting of Cambridge including views. Further detail is given in Appendix A.

We welcome the evidence in relation to landscape character assessment. We do however continue to suggest that it would also be helpful to commission Historic Landscape Characterisation work for inform this Plan and future growth in the area.

We welcome the production of the Sustainability Appraisal. We would comment however that since many of the site allocations are grouping together under particular policies, the different impacts for individual sites are not always drawn out in the assessment tables – this sometimes has the effect of neutralising the scoring.

Historic England – Ox Cam research work

Historic England has commissioned consultants to undertake some work looking at development in the OxCam Arc. ‘Measuring Impact: Managing Change’ looks at the question, ‘How should the form of growth in the Oxford-Cambridge arc positively respond to the Historic Environment’. This research is due to report in the next few months and we hope to be able to share this with you at that time as it may provide useful evidence to inform your Local Plan work.

Other comments

In preparation of the forthcoming Greater Cambridge Local Plan, we encourage you to draw on the knowledge of local conservation officers, archaeologists and local heritage groups.

Please note that absence of a comment on an allocation or document in this letter does not mean that Historic England is content that the allocation or document forms part of a positive strategy for the conservation and enjoyment of the historic environment or is devoid of historic environment issues. Where there are various options proposed for a settlement, identification of heritage issues for a particular

allocation does not automatically correspond to the support for inclusion of the alternative sites, given we have not been able to assess all of the sites.

Finally, we should like to stress that this opinion is based on the information provided by the Council in its consultation. To avoid any doubt, this does not affect our obligation to provide further advice and, potentially, object to specific proposals, which may subsequently arise where we consider that these would have an adverse effect upon the historic environment.

We trust that these comments are helpful to you in developing the Local Plan. Should you have any queries, please do not hesitate to contact us.

We suggest it might be helpful to set up a meeting to discuss our comments and, in particular, heritage impact assessments and policy wording for site allocations.
Please feel free to suggest some dates.

Compendium of Environment Agency Comments

Vision and aims
The vision on page 20 is positive bringing to the forefront decreasing climate impacts, minimising carbon emissions, increasing nature, wildlife and green spaces. Reflecting on the paragraph on page 18, you outline the aim for the Local Plan is simple: to ensure sustainable development. This means planning for homes, jobs and supporting infrastructure in the right places, alongside protecting and enhancing the environment. We recommend the vision reflects this objective of ‘sustainable development.’ For example, we suggest the following revision as follows: New development must be sustainable: minimise carbon emissions and reliance on the private car; create thriving neighbourhoods with the variety of jobs and homes we need; increase nature, wildlife and green spaces; and safeguard our unique heritage and landscapes. This will align closely to the aims of the NPPF (paragraphs 7 and 8) and also demonstrate the importance of this for Greater Cambridge given the unique challenges and opportunities the area faces.

We support the references within the aims to highest achievable standard for water use and resilient to current and future climate risks. The biodiversity and green spaces aim is also positive in its focus on improving the network of habitats and ensuring development leaves the natural environment better than it was before. All these aims will help GC achieve the stated vision and it’s important that the interrelationship and interdependencies between these aims are recognised. Recognising the interdependencies will strengthen and ultimately achieve better outcomes for GC. One example is the ecological health and water quality of rivers and water dependant habitats (e.g. wetlands) is also dependent on the availability of water in addition to the contribution developments will make in creating and enhancing habitats and green space. Healthier rivers and water dependant habitats will in turn restore nature, improve the health and wellbeing of communities and have economic benefits. Serving the environment in tandem with growing communities is mutually beneficial and secures long-term resilience. This also reflects the paragraph 153 of the NPPF: ‘plans should take a proactive approach to mitigating and adapting to climate change, taking into account the long-term implications for flood risk, coastal change, water supply, biodiversity and landscapes’ etc.

S/DS Development Strategy
We welcome the section on ‘Ensuring a deliverable plan – water supply’ on pages 41 and 42, which recognises this as a significant issue for the Local Plan. We remain genuinely concerned about whether the growth proposed (48,800 new homes inclusive of 10% buffer and 37,200 from previous plans) can be sustainable without causing further deterioration to the water environment. We understand the regional and water company water resource planning is still ongoing and the next version of the IWMS Detailed WCS will be updated as these plans come to fruition. We offer our support to work collaboratively with all the parties involved.

Current levels of abstraction (not just in Cambridge) are causing environmental effects. Increase in usage within existing licenced volumes will increase the pressure on a system that is already failing some environmental targets. The Anglian River Basin Management Plan shows many waterbodies do not have the flow required to support the ecology. Abstraction licencing reductions are likely to reduce the supplies available to water companies in our efforts to prevent deterioration of the water environment. As the plan and evidence base progresses it will need to be clearly demonstrated that the water companies plans can meet the needs of growth without causing deterioration.

As a best case scenario the strategic water infrastructure (new Fenland reservoir) would be available from the mid-2030s and its foreseeable this could be later i.e. the 2040s. It is the short to medium term period coinciding with the majority of the plan period for which rapid and viable interim solutions are needed. There is currently uncertainty about whether water supplies can be provided (both supply and demand management) in a way that is both sustainable and sufficient for the proposed growth over the plan period.

We support the idea of development limited to levels that can be supported by a sustainable water supply (phased delivery) until the time the strategic infrastructure is in place, though we are mindful this may lead to heavily back loaded delivery. If the Council approaches neighbouring local planning authorities as you already recognise it is likely they will have similar issues, though some may have more options for interim solutions. This highlights the importance of cooperating across planning boundaries and growth plans being considered in the context of the combined pressure on water supplies at a regional scale. As previously mentioned, 2050 may be a more appropriate end date for the plan period given the challenges being faced which in reality require a longer lead in time to support development, e.g. strategic water resources infrastructure, climate change resilience, etc. This would also align with paragraph 153 of the NPPF ‘plans should take a proactive approach to mitigating and adapting to climate change, taking into account the long-term implications for flood risk, coastal change, water supply, biodiversity and landscapes’ etc.

Integrated Water Management Study – Outline Water Cycle Strategy
The WCS will rely on further evidence coming forward from both regional and water company water resource plans. The WCS will need to demonstrate that feasible and deliverable mitigation measures are available for the interim period until new strategic water resources options will come online.

As noted, the WCS will need to base its assessment on the forthcoming water resource plans (WRMP24) rather than the existing, as this will have a more accurate picture of the water resources situation taking into account abstraction licence reductions. Both Cambridge Water and Anglian Water are likely to require further sustainability reductions in PR24. This could mean some or all of the current water surplus’s (available headroom) are no longer available for transfer.

The reliance on demand management options is currently high-level. These will require assessment of feasibility, effectiveness and how implementation will be monitored and measured corrected if they are not working.

In facing what is collectively a significant challenge we offer our support to work collaboratively with the interested parties ahead (and beyond) the next consultation in 2022.

S/NEC: North East Cambridge
We note the intention of the policy is to set out the place-making vision and a robust planning framework for the comprehensive development of this site. There are both environmental risks and opportunities to developing this site sustainably. Ensuring sustainable water supplies, improving water quality and the effective remediation of land contamination will be key considerations in achieving this. The proposed policy direction anticipates the site (once developed in full, which will extend beyond the Local Plan period of 2041) will deliver 8,350 new homes. The IWMS Detailed WCS will need to provide evidence the new homes (and employment) can be sustainably supplied with water in time for the development phases.

The existing site at Fen Road, Chesterton continues to be a source of ongoing local water quality and environmental health problems due to inadequate foul drainage provision. There have been a number of reports of foul sewage from the site discharging into the River Cam, causing chronic on-going pollution. The relocation of the existing Milton sewage works and extensive redevelopment of North East Cambridge presents the opportunity to incorporate mains drainage connection into the Fen Road site.

Policy S/NS: Existing new settlements
With regard to the existing allocations NS/3 and SS/5 Northstowe, we are investigating flood risk management options to reduce the risk of flooding in Oakington. This will take account of measures looking to attenuate water upstream (on the upper reaches of Oakington Brook and as part of the Northstowe development), potential channel modifications and natural flood management. We note that early phases of Northstowe are under construction. We recommend the emerging policies include this as an opportunity both in terms of delivering flood risk management measures or securing financial contributions towards this project.

CC/WE: Water efficiency in new developments
We support stringent water efficiency in water stressed areas. We recommend reviewing the document The State of the Environment: Water Resources (2018) prepared by the Environment Agency. This document outlines the challenges we now face summarised as follows. Water supply (resource) is under increasing pressure from population growth, land use change, and climate change (including hotter weather increasing evaporation, less rainfall in summer, and intense rainfall events not recharging aquifers efficiently). Without increasing our supply, reducing demand, and cutting down on wastage many areas will face significant deficits by 2050, if not sooner. If not addressed this represents an immediate and measurable blocker to future growth. We need to consider development in the context of available water resources, balancing economic growth with protecting and enhancing the water environment. We will need to ensure that there is enough water for both people and the environment, that water is used efficiently, that water is protected as a precious resource, and that wastewater is treated efficiently to cut associated carbon emissions.

We agree the evidence of the water resources situation in Greater Cambridge justifies the tighter standard of 80 litres/person/day for housing. The risk of this standard not being met is an increase in abstraction risking deterioration of associated water bodies. As page 150 recognises (with reference to the Deregulation Act 2015) GC Council will need to be satisfied that this standard can be legally and practically implemented in the context of current legislation (Water Industry and Development Industry), national policy and building regulations. This affects the practical implementation of this policy. It would need to be determined the evidence/metric applicants would be expected to submit to demonstrate this standard has been achieved. It would also need to be evidenced how the policy standards would be implemented, and how this would be monitored to ensure the policy is effective.

A positive standard is proposed for non-residential development, which we support. Water neutrality should also be explored, noting the references made to water reuse and offsetting.

The Integrated Water Management Study (IWMS) states that 80 litres/person/day is achievable by making full use of water efficient fixtures and fittings, and also water re-use measures on site including surface water and rainwater harvesting, and grey water recycling. It comments that the cost effectiveness improves with the scale of the project, and that a site-wide system is preferable to smaller installations.

Currently the policy direction has a caveat of ‘unless demonstrated impracticable.’ This should be explored further in the WCS so the Council has clear guidance on the circumstances where achieving this standard would be impracticable. This will help ensure planning applications can be fairly and reasonably assessed. This will also help ensure the overall goal of the policy is not weakened or undermined. Similarly this evidence needs to be drawn out for the non-residential standard. The WCS should also set out the backstop position should the standard of 80 litres/person/day be practicably unachievable.

Although we support water efficiency measures in new development, we consider that the plan is currently unlikely to achieve the kinds of reductions in demand needed to keep the proposed levels of growth within sustainable levels. As noted with policy S/DS, the evidence base (IWMS Detailed WCS) will need to demonstrate how the water companies’ plans can meet the needs of growth without causing unsustainable abstraction and associated deterioration. We offer our support to work on this collaboratively with the interested parties both ahead of the next consultation in 2022 and beyond.

Page 150 references the Shared regional principles for protecting, restoring and enhancing the environment in the Oxford-Cambridge Arc. We recommend this is also considered and referenced elsewhere in the plan with regards to net zero, net gain, tree cover and strategic resource infrastructure provision.

CC/DC: Designing for a changing climate
The proposed policy intends to set out how the design of developments should take account of our changing climate, for example, extreme weather events including flash flooding. We welcome the reference (p. 152/153) to site wide approaches to reduce climate risks, including sustainable drainage systems as part of landscape design, urban greening, increased tree canopy cover and integrating green spaces into new developments. In the context of flooding and climate change it would also be appropriate to reference flood resistance and resilience measures (see PPG: https://www.gov.uk/guidance/flood-risk and-coastal-change#Flood-resilience-and-flood-resistance). Site wide approaches should also include adaptive measures such as setting a development away from a river so it is easier to improve flood defences in the future. In addition, making space for water to flood and be stored will be critical to long term adaptation. Planning to avoid future flood risk is as much about creating storage or contributing to nature based flood risk reduction measures (e.g. creating wetland habitats) as it is avoiding flooding to new properties.

In shaping this policy, we recommend GC Council also consider the ADEPT local authority guidance on preparing for a changing climate (2019) and the new TCPA The Climate Crisis, A Guide for Local Authorities on Planning for Climate Change (October 2021).

The Fens Baseline Report (available at https://www.ada.org.uk/knowledge/future-fens/) indicates that rising sea levels to 2115 will mean water will not drain by gravity to the sea, requiring the pumping of vast quantities of water. The carbon and engineering implications of this are significant but not yet calculated. There is a compelling case for surface water to infiltrate into permeable ground ensuring that water resources are not depleted of water. In areas of less permeable geology, net gains in surface water attenuation and re-use of the water as ‘green water’ in homes, businesses or agriculture has been considered through this study.

CC/FM: Flooding and integrated water management
We welcome the inclusion of Policy CC/FM. We agree a policy that responds to the local water management issues is needed. As climate change will intensify the existing pressures on water availability, water quality, drainage and flood risk an integrated approach to water management will be essential. As stated this should include a robust approach to drainage and water management. The proposed policy direction is a good starting point but given the water challenges (our comments to Policy S/DS) it should strive to secure both mitigation and betterment through growth.

The local policy approach should be informed by the IWMS Water Cycle Studies, the Level 1 SFRA and other relevant strategies. We would expect to see the policy content evolve with the following considerations:

1) Though the policy direction indicates that policies will require that the risk of flooding is not increased elsewhere, it should seek to secure betterment and reduce flood risk overall, wherever possible, as part of GC’s strategy to adapt to climate change. This aligns with our previous comment that making space for water to flood and be stored will be critical to long-term adaptation. Floodplain storage, natural flood management and surface water attenuation are all measures that will contribute. Protection of potential flood storage land (including functional floodplain/Flood Zone 3b) and financial contributions towards flood risk schemes could also benefit communities at risk of flooding are also much needed options. Although many sites are located in Flood Zone 1 (low probability of flooding from rivers) there are also many sites located on the fringes of Flood Zones 2 and 3 meaning these are at risk of reducing (potentially eliminating) future flood storage options for adapting to climate change. In the background, urban creep and small infill developments which do not attenuate for surface water impact drainage systems and watercourses downstream. In planning to manage future flood risk in GC, creating extra storage to allow space for flood waters is a vital element of that plan.

2) We expect the policy to include provision for water supply and waste water infrastructure, ensuring water quality and treating and re-using waste water. We recommend that the provisions of Policy CC/7, ‘Water Quality’, of the South Cambridgeshire Local Plan 2018 are considered and brought forward into the Greater Cambridge Local Plan. Site policies may also need to include specific infrastructure requirements. These should become apparent, and be informed by, assessments carried out in the IWMS Detailed Water Cycle Study.

3) There needs to be a policy approach that recognises a clear integration encompassing water resources, water quality, flood risk and recognising the role of green infrastructure. Although the value of green infrastructure and river corridors is recognised in policy BG/GI and BG/RC, it is worthwhile including it as part of the integrated water management policy. The Greater Cambridge Green Infrastructure Opportunity Mapping Study touches upon this relationship under the Water Storage bullet as follows: Our rivers are a source of flood risk. Restoration of natural flood plains where practicable and provision of green infrastructure can help reduce flood risk along the rivers itself and beyond. Wet woodland will self set and grow where conditions are right and management allows. Providing the right conditions for trees to grow in appropriate locations in river corridors can support flood risk mitigation and biodiversity.

Integrated Water Management Study – Outline Water Cycle Strategy (WCS)
For water quality we welcome that the Outline WCS has been amended based on our previous feedback. However a number of issues raised remain unresolved which we can expand upon in a more detailed response to the Council’s consultants. Some of the information presented does not represent the proper ‘baseline’ for subsequent assessments and the extent of the challenge of delivering the quantum of growth proposed in the Local Plan. For example, 2019 WFD classification data is presented but waterbody objectives are from 2015, also the information in chapter 6 does not take account of river quality improvements delivered by AMP6 or AMP7 schemes. The identified assessment methods need to be sufficiently robust, and potential mitigation actions will need to be shown to be viable. The Detailed WCS will need to provide evidence to demonstrate the delivery of foul drainage provision can be provided whilst protecting water quality of rivers.

Climate change topic paper (IWMS Level 1 Strategic Flood Risk Assessment)
We have reviewed the Level 1 SFRA. The majority of sites are in fluvial Flood Zone 1 with a proportion of sites with partial Flood Zone 2 and 3 either within the site boundaries or close to boundaries. Surface water flood risk also affect most of the sites to a limited or greater extent. Flood risk and climate change adaptation is an important consideration of the Local Plan in view of the predicted impacts of climate change on flood risk. Page 39 of the Climate Change Topic Paper states that the Level 1 SFRA (2021) has been used to support the selection of development sites through the application of the Sequential Test. This statement within the topic paper is helpful, however, it does need to be more obviously demonstrated how the Sequential Test and sequential approach to all forms of flooding has been applied. The Planning Practice Guidance advises a number of options for this including a standalone report, Sustainability Appraisal commentary, etc. This will need to be produced in time for the next draft plan consultation so it is clear how the test has been applied and demonstrated.

Page 42 explains that where necessary a Level 2 SFRA of sites in the draft plan will be carried out to ensure that designs and capacity fully reflect management of flood issues. We think that a Level 2 SFRA is necessary particularly for those sites located on the fringes of Flood Zones 2 and 3, or partially within those zones. In predominantly flat or fenland areas, breaches in flood defences can cause flooding in Flood Zone 1 due to the concentration of floodwater in one part of the floodplain, for example, the Waterbeach New Town allocation. Some sites have unmapped ordinary watercourses running alongside or through them and often these have not been modelled as part of the indicative flood map due to their limited upstream catchment size. As such there is some uncertainty over the level of flood risk to the site, with the potential that fluvial flood risk may be greater than the Flood Map for Planning. These sites will 7 require further investigation to better refine the flood extents (including climate change) preferably by flood risk modelling or utilising the Flood Map for Surface Water (FMfSW). For some sites, fluvial climate change assessment is required as this is not modelled.

A Level 2 SFRA could also identify suitable land or techniques that could be used for flood storage to adapt to climate change and urban creep. Even if these cannot be brought forward at this stage in the plan, these could be protected for future plans or for infrastructure to bring forward at the appropriate time. The LLFA may also have areas of surface water flooding to be further investigated. The Level 2 will help determine whether the site can be developed safely, mitigation measures required, sequential approach and applying the Exceptions Test (NPPF paragraph 164). The Level 2 SFRA should inform the site specific polices within the plan that will form the planning framework for the sites. We can provide a separate list of the sites we think would require L2 SFRA assessment if helpful.

BG/BG: Biodiversity and geodiversity
This policy will control biodiversity impacts from development and set out Biodiversity Net Gain requirements (aiming for 20% BNG). We welcome and support the Council’s policy direction on this. It should be clear that BNG is in addition to the standard requirements of the mitigation hierarchy i.e. avoid harm where possible, mitigate for the effects or compensate (paragraph 180 of NPPF). We recommend that local authorities adopt a natural capital evidence approach to underpin their local plan. This is mentioned briefly in the evidence base within the green spaces topic paper. Information can be found here. Natural Cambridgeshire have done some work in this area, looking at opportunity mapping. Also, the recent Oxfordshire Plan 2050 (Reg 18) had some good natural capital and ecosystem services wording (policy option 09) that we recommend you consider. Preparation of a natural capital evidence base and policy is something we (and likely Natural England) could advise on in advance of the next consultation stage.

Wider environmental net gains is also identified as a potential policy requirement which we support, and pending further guidance from a national level. We recommend that geodiversity is also considered.

We recommend ambitious maintenance requirements to protect and ensure longevity of net gain enhancements. The Environment Bill mandates 30 years but ‘in perpetuity’ should be aimed for where possible.

The proposed policy direction includes that off-site measures must be consistent with the strategic aims of the Greater Cambridge green infrastructure network strategic initiatives. We welcome the GI initiatives so far identified within the GC Green Infrastructure Mapping which include revitalising the chalk stream network, the River Cam corridor and enhancement of the fens.

This work can also help to inform a future Local Nature Recovery Strategy in identifying valuable sites, sustainable land management and how the loss and/or fragmentation of existing habitats should be avoided as much as possible. The creation of bigger, better and joined-up habitats will be beneficial to wildlife, contributing towards the local plan’s objective of doubling nature. The creation of large networks will also support ecological resilience to predicted future impacts from climate change and are likely to overlap with net gains in flood risk management.

We recommend this policy also acknowledge the significance of invasive non-native species (INNS) and their impacts on wildlife and the environment. INNS are considered one of the top five threats to the natural environment. They can impact on wildlife, flood risk, water quality and recreation. Costs to the economy are estimated at £1.8 billion per year. Prevention through adopting biosecurity measures can help to reduce the spread and impacts of INNS.

BG/GI: Green infrastructure
We support the policy direction which will require all development to include green infrastructure, and protect/enhance water environments. We welcome the list of green infrastructure initiatives on page 8 173/174 which includes revitalising the chalk stream network and references the River Cam. It’s positive that developments will be expected to help deliver or contribute towards these to enhance the existing green infrastructure network.

In addition, we consider ‘connectivity’ as a key component of this policy. As noted in the Sustainability Appraisal (Non-Technical Summary p. 15) fragmentation and erosion of habitats can be detrimental to wildlife. Existing and new habitats and greenspaces should be retained and enhanced, in connection with existing habitats and the wider countryside, establishing a coherent ecological network, as per the NPPF. We support the references to ‘providing links’ and connecting to the wider ecological network as part of this policy, as this will be invaluable to both green infrastructure provision and nature recovery.

Existing areas of habitat and green spaces within proposed development footprints should be protected and incorporated within landscape designs where possible. As well as protecting existing areas of habitat, mitigation and environmental enhancements can be delivered through appropriate design that includes creation of new habitats and green spaces. New habitats should be representative of and complement the local landscape character, whilst being linked to existing features and the wider countryside, creating joined-up, resilient ecological networks

BG/RC: River corridors
We support the inclusion of a policy to manage development that has an impact on river corridors and proposes to protect, enhance and restore natural features, supporting re-naturalisation. This is particularly important for Cambridge due to the presence of chalk streams and the role rivers and their associated floodplains play in managing flood risk and provision of habitats. The proposed policy direction includes ‘ensure that the location, scale and design of development, protects and enhances the character’ and we recommend this includes the provision of appropriate setback of developments from rivers to provide sufficient space for flood waters as well as safeguarding the integrity of the river banks and the development itself. Rivers unless they have been artificially straightened move through their landscapes through natural processes of erosion and deposition. Although river migration occurs over long time periods, developments should be set back generously to account for this alongside climate change. Natural flood management also has the potential to deliver multiple benefits. Tall buildings can have an adverse effect if located too close to a watercourse by introducing overshadowing impacts and artificial lighting which disrupts natural diurnal rhythms of wildlife such as bats.

Wellbeing and inclusion – general comments
We recommend reviewing the document The State of the Environment: Health, People and the Environment (2020).This report, prepared by the Environment Agency, highlights the substantial body of evidence indicating the physical and mental health benefits of spending time in the natural environment. Access to the natural environment is not equally distributed, those living in deprived areas often have poorer quality environments with less accessible green and blue space. The GC Local Plan presents an opportunity to level-up communities, tackling this green inequality at scale and improving the health and wellbeing of those living and working in the GC area, by creating and contributing to healthier, greener, and more accessible environments. This must, however, be achieved in balance with the need to protect the environment, by providing appropriate wildlife refuges from human disruption and interference.

WS/HS: Pollution, health and safety
We would welcome a policy that details how land contamination should be considered, ensuring the land is suitable for the end use but also ensuring that water quality of the underlying aquifers is protected.

There are some plans and strategies that will be relevant to inform this policy. In 2018 the Government committed through the 25 Year Environment Plan to ‘achieve clean air’ and to ‘minimise waste, reuse materials as much as we can and manage materials at the end of their life to minimise the impact on the environment’. The State of the Environment: Health, People and the Environment (2020) highlights the extent of the threat that air quality poses to health in the UK, shortening tens of thousands of lives each year. Analysis also shows that areas of higher deprivation and those with high proportions of ethnic minorities are disproportionately affected by high levels of air pollution. Growth plans provide the opportunity to address these inequalities by improving the quality of the environment and strategically planning the location of land use types.

We welcome that the policy will provide protection to and from hazardous installations. However, Waste management facilities also have the potential to pollute the environment, cause nuisance or amenity issues through dust and particulate emissions to air, release to ground and surface water, and to leave a legacy of contaminated land. Studies have found that more deprived populations are more likely to be living closer to waste sites, and can therefore at times be subject to greater impacts such as noise, litter, dust, odours, or increased vehicular traffic. Strategic planning of waste and resource use provides the opportunity to address this issue.

H/RC: Residential caravans
This policy will set out the criteria to be used when considering proposals for new residential caravan sites. Annex C ‘Flood risk vulnerability classification’ of the National Planning Policy Framework (NPPF) classifies caravans, mobile homes and park homes intended for permanent residential use as highly vulnerable. Permanent caravans, mobile homes and park homes if located adjacent to rivers are at significant risk from being inundated very quickly from floodwaters, without sufficient warning or adequate means of escape. There are additional dangers from the potential for floating caravans (if they become untethered), cars and objects/debris becoming trapped beneath the caravans will increase the risk by displacing floodwater elsewhere.

Page 295 states that an accommodation needs assessment is currently being developed. The Sequential Test (paragraph 161 of the NPPF) should also be applied to the accommodation needs assessment to avoid where possible locating accommodation sites in areas at risk of flooding. This should be informed by the Level 1 and where necessary a Level 2 SFRA. We recommend given the high vulnerability of this type of accommodation that flood risk is a key consideration within the policy criteria.

H/GT: Gypsy and Traveller and Travelling Show People sites
The proposed policy direction includes ‘Sites are capable of providing an appropriate environment for residents in terms of health, safety and living conditions.’ Similar to our comments to Policy H/GT above, Annex C ‘Flood risk vulnerability classification’ of the NPPF classifies ‘caravans, mobile homes and park homes intended for permanent residential use’ as highly vulnerable. Sites used for holiday or short let caravans and camping (subject to a specific warning and evacuation plan) are classified as more vulnerable. We recommend given the higher vulnerability of this type of accommodation that flood risk is a key consideration within the policy criteria.

Page 298 states that a joint accommodation needs assessment is currently being developed. The Sequential Test (paragraph 161 of the NPPF) should also be applied to the accommodation needs assessment to avoid where possible locating accommodation sites in areas at risk of flooding. This should be informed by the Level 1 and where necessary a Level 2 SFRA.

The existing site at Fen Road continues to be a source of ongoing local water quality and environmental health problems due to inadequate foul drainage provision. There have been a number of reports of foul sewage from the site discharging into the River Cam, causing chronic on-going pollution. Water quality and ensuring appropriate drainage infrastructure is also an important consideration for these sites, both in terms of protecting the environment and safeguarding the health of the site occupiers. Policy H/23 ‘Design of Gypsy and Traveller Sites and Travelling Showpeople Sites’ in the South Cambridgeshire Local Plan 2018 provides an example of this, with the following wording: d. All necessary utilities can be provided on the site including mains water, electricity supply, drainage, sanitation and provision for the screened storage and collection of refuse, including recyclable materials;” Policy H/GT should include provision for mains foul drainage and protection of water quality as part of the policy criteria.

Infrastructure – general comments
Infrastructure and connectivity improvements, must be achieved in balance with the need to protect natural spaces, providing both accessibility and retaining restricted access refuges for wildlife. There is the opportunity to achieve both if, for example, cycle and pedestrian networks are considered strategically and systematically alongside green infrastructure and natural capital networks. A holistic approach to connectivity and infrastructure should be adopted, considering the multifunctional possibilities that provision of new transport and utilities infrastructure provide. For example, by integrating new road or rail schemes with flood resilience measures, energy generation, and green infrastructure enhancements.

I/SI: Safeguarding important infrastructure
We welcome the intention to work with infrastructure providers to consider whether planned strategic infrastructure or future land should be safeguarded. This should also include land for flood storage and flood risk infrastructure which is likely to include river corridors. Managing flood risk both now and in the future will require the plan taking a pro-active approach taking into account climate change. Your SFRA evidence base can inform this identification for safeguarding. The functional floodplain (Flood Zone 3b) is a zone comprising land where water has to flow or be stored in times of flood, identified in SFRAs and deemed to be the most at risk of flooding from rivers or sea. The SFRA should also gather information on flood risk management projects. The GOSIS (formerly Great Ouse Storage and Conveyance study) will assess how flood risk within the catchment can be managed now and into the future, giving a high-level evaluation of the costs of benefits of providing large storage volumes in the catchment. The GOSIS project will look for areas for flood risk management and draft outputs from this likely to be available towards the end of GC Local Plan process. There is also the Girton Flood Alleviation Scheme (Washpit Brook catchment) and flood risk management options at Oakington Brook (the latter referenced in our comments to Policy

As mentioned for Policy CC/FM, although a sequential approach has been considered there many sites proposed on the fringes of Flood Zones 2 and 3. This reduces and potentially eliminates future flood storage options for adapting to climate change. It’s important the L2 SFRA assesses these sites for their deliverability but also a broad perspective is taken to planning for flood risk both now and in the future. Creating extra flood storage to allow space for flood waters will be a vital component of that plan. We’d also expect safeguarding to include what is required for water infrastructure more broadly (water supply and waste) and green infrastructure/biodiversity.

I/ID: Infrastructure and delivery
We support the policy direction to propose to only permit development if there is, or will be, sufficient infrastructure capacity to support and meet all the requirements arising from the new development. The developer certainly has a role in this, beneath a robust and deliverable strategic framework led by the Council and other strategic infrastructure providers (informed by evidence).

As noted for Policy S/DS, we support the idea of development limited to levels that can be supported by a sustainable water supply (phased delivery) until the time the strategic infrastructure is in place. It is important that development is sustainable and the environment is protected throughout the process of infrastructure planning.

SUPPORT densification of existing Employment Uses and increase at former sidings and existing brownfield land in an excellent area for increased sustainable travel to work. Support also for some increases in affordable and social housing on land outside existing and in revised WWTW buffer zone since this will assist shortages in both LA’s.
OBJECT to redevelopment all of the existing sewage works area and its buffer zone for high density housing within the Plan period. This now translates to proposals to destroy part of the Green Belt by relocating the Works.
Other modern works in UK have been amended or built to minimise their odour and traffic footprint and allow a much smaller buffer zone (ref Deephams WWTW as one example). A realistic alternative would be to amend the works. The option to relocate the sludge treatment section should be explored (ref Eastbourne WWTW as one example).
Greater Cambridge Shared Planning, in response to the CWWTP Scoping Report, has themselves stated they would like to clarify that the relocation of the Cambridge WWTP is not a “requirement” of the North-East Cambridge Area Action Plan and must not
be referred to as such - see Page 6
https://infrastructure.planninginspectorate.gov.uk/wpcontent/ipc/uploads/projects/WW010003/WW010003-000028-WW010003%20-%20Scoping%20Opinion.pdf. The Plan must not be ambiguous on this point.
The proposal to create some kind of greenwashed country park as mitigation appears to be an underhand attempt at carbon offsetting on what is much needed, productive, carbon sequestrating farmland.

Relocation of Sewage works

Cop26 and the pandemic should change the priority for this unnecessary move.
The reason Wicken Fen vision arose was the lack of road access to this area. If the sewage works are relocated to this area, further development will undoubtedly follow. Cambridge and the people will be the losers.
This area with the highest biodiversity in the country should be top of everyone's priority for protection.

The Cambridgeshire Development Forum brings together a diverse range of organisations with a shared commitment to the delivery of high-quality developments in the Cambridgeshire region. We include promoters, developers, housebuilders, housing associations, planners, advisers, law firms, design companies, transport planners and related professionals in our membership. We do not promote individual sites and are focused on achieving more effective delivery of plans in our region. We value the engagement we receive from local planning authorities, the Combined Authority and Central Government. We welcome this opportunity to respond to the consultation on the Local Plan.

These representations reflect shared views among our members but should not be interpreted as representing the views of any individual member organisation in membership of the Forum.

Responses:

Q1: the additional 550 homes a year should be regarded as a minimum figure, which should be reviewed regularly in relation to the growth in jobs within the travel-to-work areas

Q2: the spatial strategy for development should focus the larger development sites in locations which offer public transport options to reach major employment centres. Development in rural locations of an appropriate scale should not be deterred as and when more sustainable personal transport options are available, eg EVS using renewable energy.

Q3: The Cambridge East Development should be connected directly to the City centre and the inner urban ring of development at the Biomedical campus, North Cambridge and the Science Park, Eddington and West Cambridge. But it should not be a wholly residential development. It should be a mixed development including commercial, residential and leisure/ retail options. It should be envisaged as a distinct place, with its own character. It could include high-rise apartments suitable for the younger workers who comprise many Cambridge area workforces.

Q4: North-East Cambridge should offer a residential opportunity for those employed in the technology sectors around Cambridge, including a significant component of affordable housing for market sale, market rent, shared ownership, and social housing.

Q5: development in and close to the biomedical campus should be prioritised for the healthcare, research, and technology cluster; significant adjacent sites should not be developed for large-scale residential purposes.

Q6: Cambourne should provide jobs near the new homes and include more employment space potentially including a commercial hub based on any new railway station above the A428.
Outside this commercial and retail hub, Cambourne should be focused on the large-scale offering of homes for families of those working across the Cambridge area.

Q7: in the southern rural cluster, opportunities for development on brownfield sites and for rural diversification, with small business-related developments should not be excluded.
Related residential development on smaller sites should also be accommodated, taking account of the Neighbourhood Plans. A priority should be given to sites in villages on rail routes, at public transport nodes and within public transport corridors. Subject to the decisions to be made concerning the East-West Rail Link, the option for significant growth and/or new settlement in appropriate locations that maximises the use of all forms of public transport should be considered as additions to the sites proposed.

[Q8-13 omitted]


We have welcomed the engagement with the Greater Cambridge Shared Planning team, and look forward to this continuing through this process in future discussions.

Cambridgeshire Development Forum December 2021

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.

NORTH-EAST CAMBRIDGE ‘CORE SITE’, COWLEY ROAD,
CAMBRIDGE


GREATER CAMBRIDGE LOCAL PLAN 'FIRST PROPOSALS' (REG 18)

Written Response on behalf of U&I PLC / TOWN

Monday, 13 December 2021


Classification L2 - Business Data



CONTENTS




0.0 INTRODUCTION 1
1.0 POLICY RESPONSE 2


0.0 INTRODUCTION

0.1 This document sets out written representations on behalf of U+I / TOWN, to a formal consultation by Greater Cambridge Shared Planning Services (‘GCSP’) on the Greater Cambridge Local Plan ‘First Proposals’ (Preferred Options, Regulation 18, 2021) (‘First Proposals’).
0.2 U+I and TOWN have been selected by Anglian Water and Cambridge City Council (as landowners) to act as Master Developer for the comprehensive redevelopment of the existing Waste Water Treatment Works (‘WWTW’), council depot and golf driving range (to be referred collectively as ‘the Core Site’), for the delivery of approximately 5,500 homes, 23,500m2 of new business space, 13,600m2 of new shops, community, leisure and recreation space (as currently set out in the North East Cambridge Area Action Plan (‘NEC AAP’) Proposed Submission Regulation 19 document). For the avoidance of doubt, these representations are submitted on behalf of U+I and TOWN as master developers rather than the landowners themselves.

0.3 Regeneration of the Core Site will be facilitated by the relocation of the WWTW, which will be funded from the Homes England’s Housing Infrastructure Fund, and which is currently going through a Development Consent Order approval process. Anglian Water will be submitting separate representations to the First Proposals, on this specific element.

0.4 U+I/TOWN have been actively involved in the policy formation process of the NEC AAP and are therefore looking to ensure there is policy consistency between the NEC AAP Proposed Submission and First Proposals documents.

0.5 Consideration will need to be given to the prospect of policy inconsistencies between the Greater Cambridge Local Plan (‘GCLP’) and NEC AAP.

0.6 As a point of broad principle, we would request that relevant GCLP policy (particularly where performance standards are stated) provides appropriate wording that defers to more area/site-specific policy, where it is being formed in other Development Plan Documents, such as NEC AAP. In the event of any inconsistency, this will ensure that there is a clear understanding over which policy takes preference. For instance, if a 20% biodiversity net gain (‘BNG’) target is ultimately adopted in GCLP policy, and a minimum 10% BNG is sought in NEC AAP, then there would be a clear signal in the GCLP policy that the NEC AAP policy is the correct standard to apply.



1.0 POLICY RESPONSE

Policy S/JH: Level of Jobs and Housing
OBJECT
1.1 The Cambridgeshire and Peterborough Devolution Deal committed to delivering substantial economic growth and to double economic output during the next 25 years. The Cambridge and Peterborough Combined Authority and the Greater Cambridge Greater Peterborough Enterprise Partnership acknowledge and support the economic growth potential of the Greater Cambridge area and consider that there is a need to substantially increase housing delivery in order to support economic growth (that is needed to meet the objective of doubling GVA by 2040) and address the significant housing affordability issues that exist (Cambridgeshire and Peterborough Independent Economic Review). At present there is an imbalance between rates of economic growth and housing delivery in Greater Cambridge.
1.2 These factors support a significantly higher number of homes than are proposed in the preferred ‘medium plus’ growth option of Policy S/JH. It is considered that the ‘medium plus’ growth option makes insufficient upward adjustments to the housing requirement (from Section Id.2a of the Planning Practice Guidance) to take into account growth strategies, strategic infrastructure improvements and housing affordability in Greater Cambridge.
1.3 It is suggested that the emerging GCLP should have selected the higher growth level option to support economic growth, address housing affordability, and reduce in-commuting. A higher growth level option would be consistent with the Government’s aspirations for the Oxford to Cambridge Arc.
1.4 It is requested that housing and jobs requirements in Policy S/JH are based on delivering the higher growth level option.


Policy S/DS: Development Strategy

SUPPORT

1.5 We broadly support this approach, given that it identifies North-East Cambridge for the creation of new compact city district on brownfield land, noting that it has already been identified for homes and jobs growth.
1.6 However, we are extremely concerned by the ‘Homes’ target for NEC that is stated in the table on page 32, which refers to 3,900 homes between 2020 and 2041. Fundamentally, this is at odds to the trajectory that has been agreed with Homes England as a pre-requisite for the substantial public funding that has been agreed in principle to relocate the WWTW.
1.7 We would therefore instead support a policy that recognises 5,600 homes will be provided on the Core Site by 2041. Consideration will also then need to be given to other housing that is expected to come forward within the NEC AAP.



Policy S/NEC: North-East Cambridge

SUPPORT

1.8 We support this approach but would request that GCLP policy for S/NEC is entirely consistent with NEC AAP. A simple policy that specifies reference to NEC AAP will enable GCLP policy to remain up to date, as and when changes are made through the examination and adoption process.
1.9 We would note that Policy 1 of the NEC AAP Proposed Submission states ‘approximately 8,350 new homes, 15,000 new jobs’, as opposed to ‘up to’ as set out in S/NEC.
1.10 S/NEC policy should therefore be amended to refer to ‘approximately’ and provide a clearer link to NEC AAP.


Policy BG/BG: Biodiversity and Geodiversity

OBJECT

1.11 The policy wording suggests that there will be a requirement for development to achieve a minimum 20% biodiversity net gain, which has been based on the South Cambridgeshire District Council Doubling Nature Strategy (2021), the draft Cambridge City Council Biodiversity Strategy 2021 – 2030, and the Oxford-Cambridge Arc Environment Principles (2021).
The Environment Act 2021, however, states that a minimum of 10% Biodiversity Net Gain should be achieved, and specifies the three forms for doing so:

- Post-development biodiversity value of the onsite habitat;

- the biodiversity value, in relation to the development, of any registered offsite biodiversity gain allocated to the development;

- the biodiversity value of any biodiversity credits purchased for the development;

1.12 Whilst U+I/TOWN recognise the importance in providing significant biodiversity improvements through development, it is considered that the mandatory minimum limit should reflect the legislative target. However, policy could still actively encourage schemes to exceed the minimum, recognising that those that do will be considered as a planning ‘benefit’ of development in sustainability terms (the greater the increase, the greater the weight attached to the assessment of benefit in any planning balance).
1.13 In terms of implications for the Core Site in North-East Cambridge, the NEC Ecology Study (2020) recommended that a target for a net gain of 10% is applied for all developments within NEC. Where this is not achievable within the site boundary then offsite measures should be provisioned.
1.14 By way illustration, a 20% gain to the 36.76 biodiversity units that have been identified in the Ecology Study would result in the need to achieve 44.112 biodiversity credits, in order to satisfy policy requirements. This seems highly ambitious, given the level of density that will need to be achieved across the Core Site to meet NEC strategy objectives. We will continue to make representations on this point as the NEC AAP progresses. GCSP must also consider alternatives to on-site provision where the necessary biodiversity net gain cannot be achieved on site. This could include a range of options including biodiversity net gain ‘credits’ being able to be purchased from other sites.



1.15 Ultimately, the aim of BNG is to leave the natural environment in a measurably better condition than beforehand. Therefore, if it can be robustly demonstrated that on-site provision is not achievable, the opportunity to measurably improve the natural environment of other appropriate receptor sites through off-site provision should still have a significant value attached to it.

Policy WS/HD: Creating Healthy New Developments

SUPPORT

1.16 We broadly support the 10 principles for creating healthy places. The vision for North-East Cambridge is of a healthy, inclusive, walkable, low-carbon new city district with a vibrant mix of high quality homes, workplaces, services and social spaces, fully integrated with surrounding neighbourhoods.
1.17 One of the five strategic objectives of the NEC AAP is for a healthy and safe neighbourhood and notes the principles of the Health New Towns programme.

Policy WS/MU: Meanwhile Uses During Long Term redevelopments

SUPPORT

1.18 We support the inclusion of a Meanwhile Use policy and agree that it can play an important role on strategic development sites. Phases of development can occur over a significant period of time, and therefore utilisation of vacant/redundant land/buildings for social and/or economic purposes can help activate an area and provide short/medium term benefits that might not otherwise be realised.

Policy GP/LC: Protection and Enhancement of Landscape Character

COMMENT

1.19 The policy notes that ‘the edges of Cambridge and the villages are an important area of transition which require sensitive landscaping to protect the setting of the settlements and to provide a well- defined edge which respects townscape and the countryside beyond’.
1.20 The Core Site at North-East Cambridge will need to be planned to a high density in order to fully achieve the the strategic objectives of the NEC AAP, as well as to hit the quantum of development required under Homes England’s Housing & Infrastructure Fund. This will require a number of buildings that are taller than may otherwise be commonly found in the north of Cambridge (including surrounding villages, such as Milton). The masterplan for the Core Site will take great care in how its development edges interface with the landscape and setting of nearby settlements, as well as adjoining ‘bad neighbour’ uses currently in existence. The policy will need to recognise the strategic objectives of NEC AAP and avoid imposing conditions that could unreasonably restrict development.

Policy GP/QD: Achieving High Quality Development

SUPPORT



Policy GP/QP: Establishing High Quality Landscape and Public Realm

SUPPORT


Policy J/NE: New Employment Development Proposals

SUPPORT

1.21 We broadly support the intent of the policy but consider it essential that GCSP takes a more ambitious approach in seeking to capture and accommodate the substantial demand in office, R&D, lab and associated manufacturing space in the Greater Cambridge area. There is a need to provide sufficient supply in order to meet the balanced homes/jobs requirements and to reflect the high employment density and employment skills these uses engender.
1.22 The Greater Cambridge Local Plan Strategic Spatial Options Assessment (Housing and Employment Relationships Nov 2021), upon which the homes and jobs growth of the First Proposals has been based (‘Central Growth’), considered a Higher Growth option of 78,742 jobs in the Plan Period. It
noted that ‘this is a plausible but more aspirational growth outcome’. We believe that the Higher Growth option should be pursued to reflect the Combined Authority’s commitment to doubling GVA by 2040 and capitalise on the significant appetite for research/knowledge-based, commercial development in the City.

Policy J/AW: Affordable Workspace and Creative Industries

SUPPORT

Policy H/HD: Housing Density

SUPPORT

Policy H/CB: Self and Custom-build Homes

OBJECT

1.23 The concern we have with this policy is the ability for the Core Site scheme to comply with the amount of Self-build/custom build being sought, given the high-density development that is envisaged. We would seek reference in the policy to wording that reflects the relevant policy in the NEC AAP i.e. to support ‘custom-finish’ as well.


Policy I/ST: Sustainable Transport and Connectivity
SUPPORT

Vision and development strategy
Vision and aims
THE VISION
The vision is contradictory, misconceived and undemocratic, unquestioning, unachievable, and based on inadequate evidence. The draft Plan and this whole consultation are premature.

It is contradictory in that the vision of a big decrease in climate impacts is totally undermined by blindness to fundamental incompatibilities between growth and carbon reduction. Its claims of sustainability and Net Zero are not credible given that the carbon costs of construction are not included in the Plan’s definition of a Net Zero Carbon building.

It is misconceived and undemocratic in that it claims to want “the variety of homes and jobs we need” when all the proposed options involve levels of growth dictated by a combination of Government fiat (through both imposed housing targets and four growth corridors led by the Ox Cam Arc) and the ambitions of a local oligarchy (exemplified by Cambridge Ahead) which is unrepresentative of the people of Greater Cambridge. The Arc proposals are in direct conflict with the “levelling up” agenda, will not deliver “levelling up” in terms of Cambridge’s inequalities (notably affordable housing) and should not be taken as justification for the level of growth being proposed (https://smartgrowthuk.org/wp-content/uploads/2021/09/The_Overheated_Arc_Part_3_September_2021.pdf).

The Plan’s “predict and provide” approach fails to even question the desirability or deliverability of this imposed growth. Nor does it begin to tackle the severe challenges arising from past and present growth, notably in terms of affordability (in the most unequal city in England), and transport capacity issues (first identified by Holford 70 years ago), both of which have been exacerbated by growth, and will be further exacerbated, not diminished, by the growth now proposed.

It is unachievable in that
a) it ignores environmental capacity limits, most immediately in relation to water issues, but also in relation to the physical character of Greater Cambridge, and the capacity challenges of accommodating the intense activity of a 21st century city within the built fabric and spaces of a historic University town and its hinterland.
b) its claims to increase nature, wildlife and green spaces rely on a quantum of development that, considered holistically, will have an opposite effect.
c) the Plan’s growth proposals will compound the damaging impacts of current growth on our unique heritage and landscapes.

Its evidence base is incomplete and inadequate. Inexcusably, it has no assessment whatever of environmental capacity (a fundamental issue for the Plan) other than in relation to water supply. The Climate change evidence is inadequate and misleading, notably because it uses a definition of Net Zero Building which omits the embodied carbon of construction. There is no review or assessment of the success or failure of current local plan or other policies. This is compounded by the woefully inadequate historic environment evidence base, which has no strategic consideration of Cambridge as a world famous historic city, and is so incomplete that it only mentions one Conservation Area Appraisal (the Historic Core) when all the city’s Conservation Areas are covered by Appraisals, and fails to use the readily available evidence contained within them.
The draft Plan and the whole consultation are premature pending
1) A thorough understanding and appreciation of the current character of Greater Cambridge and its environmental capacity
2) The forthcoming Water Resources East consultation on the Regional Water Plan, on which these proposals depend
3) Transport solutions which can be accommodated in the space available, including those currently and imminently out for consultation on transport capacity and links within and outside the city.

THE AIMS
The Plan’s aims do not include what is arguably the most vital: how to maintain, enhance, and provide more equitable access to what makes Cambridge special, in the face of the combined challenges of growth and Climate Change. This should be a key priority of the Historic Environment Strategy which is required by the NPPF, but absent from the First Proposals.

As someone from the Tech industry said in a meeting last year with Stephen Kelly, Director of Planning: “Malta has concrete high rises, no one goes there. The Tech sector comes here because it’s a nice place to be. If Cambridge takes a predict and provide approach, it will accelerate into catastrophe.”

How much development, and where – general comments
No more development allocations until issues arising from existing approved growth have been identified and tackled. This means waiting for the Regional Water Plan and coherent publicly-endorsed proposals for tackling existing congestion and capacity issues, challenging the assumptions underlying the Ox Cam Arc, and carrying out a holistic assessment of environmental capacity and the limits to growth. All in line with the principles of Doughnut Economics which the City Council says that it has adopted.

The evidence base is seriously inadequate in relation to environmental capacity. There is no evaluation of the success or failure of existing policies in maintaining the special character of Cambridge, an aim which the new Plan seeks to maintain. Such consideration needs to include not only impacts of the form, scale and location of new development, but also of the transport and other infrastructure required by it. Current growth is putting massive, and unresolved pressures on the capacity of existing transport links, and the physical capacity of Cambridge’s roads system and public realm.

The GCP’s Making Connections proposals, currently under consultation, attempt to resolve some of the challenges, but have no detailed assessment of the capacity of Cambridge’s streets to take the extra volumes of bus and cycle traffic being proposed. Given that Cambridge’s congestion problems are historic, and compounded by growth, this consultation on Local Plan proposals for additional growth is premature in the absence of credible and detailed proposals to tackle current capacity issues.
S/DS: Development strategy
How can the proposals aim for net zero with this sheer volume of proposed development (while whole-life costing of large new proposals is welcome, what about the carbon cost of developments in the pipeline? - see above and comments on CC/NZ below).
No mention of impacts of transport links required for these proposals. Need to ensure that these are brought forward in concurrently with the Local Plan proposals.
Cambridge urban area
Cambridge urban area - general comments

Massive environmental capacity issues, with inadequate space in City streets and public realm to cater for existing traffic, let alone approved growth already in the pipeline – even before considering these First Proposals. The capacity issues have to be tackled, with additional growth allowed only if they can be resolved.

No mention of Covid and opportunities for city centre residential / other uses resulting from potential radical changes in retail.
No new cultural or provision for other “city-scale” needs, so putting the city centre under even greater pressure.

S/NEC: North East Cambridge
Vividly illustrates the issues. Gross over development.
Edge of Cambridge
Edge of Cambridge - general comments
The Green Belt assessment is not fit for purpose, because it ignores historic environment designations and landscape character constraints.

This highlights a vital flaw of the Plan, its failure to take a holistic view of the combination of different elements (including historic and natural environment) which make up the character of Greater Cambridge. The Government may have tried to artificially separate the natural and built environment with its Environment Act, but that doesn’t mean this approach should be followed in Cambridge!

Climate change
Climate change - general comments

The definition of a Net Zero Carbon building set out in the Evidence Base does not include its embodied carbon: this is a very serious omission which undermines all claims made about the sustainability of new development, and raises questions about the claimed sustainability credentials of all the Growth options being proposed.

Already out of date in terms of Government targets (e.g. the Heat and Buildings Strategy, not mentioned in the draft Plan), and rapidly developing guidance and best practice.
Support regular reviews to keep pace with developing technology, standards, Government targets (e.g. the Heat and Buildings Strategy, not mentioned in the draft Plan), and rapidly developing guidance and best practice. There are also serious quality control challenges in relation to whether aspirational aims are actually delivered. How will this be done? Outline planning permissions must be subject to the aspirations articulated in draft local plan. How will this be done?
Projects proposed to help achieve net zero need to be both delivered and SAFEGUARDED, throughout the Plan period, to ensure that the aims are delivered (e,g, need to ensure that biodiversity / natural capital / “doubling nature” (sic) and any other such schemes are protected from subsequent inappropriate changes of use or management)
Agree that development should be located so that low carbon transport links can be accessed. However, such locations should not be chosen based on proposed busways – the delivery of these is uncertain and their construction generates carbon emissions through the embodied carbon in the building materials, tree felling reducing carbon capture, maintenance and serving works, and lighting, contrary to the Council’s net zero carbon agenda.

CC/NZ: Net zero carbon new buildings
The definition of a Net Zero Carbon building set out in the Evidence Base does not include its embodied carbon: this is a very serious omission which undermines all claims made about the sustainability of new development, and raises questions about the claimed sustainability credentials of all the Growth options being proposed.

Support recognition of embodied carbon, also whole life carbon (see CC/CE). build for future re-use, including requiring use of lime mortar not cement to enable re-use of fired and quarried materials.

Where possible, existing buildings should be re-used (“The greenest building is the one that already exists”– Carl Elefante https://www.architectsjournal.co.uk/news/opinion/the-greenest-building-is-the-one-that-already-exists quoted in the Architect’s Journal Retrofirst campaign https://www.architectsjournal.co.uk/news/opinion/join-our-retrofirst-campaign-to-make-retrofit-the-default-choice)

Require whole-life assessments whenever demolition of an existing building is proposed. (e.g. false net zero claims made for new Kings College development on Barton Rd – no mention of the embodied carbon of the buildings demolished to make way; same applies to the Flying Pig replacement) .

CC/CE: Reducing waste and supporting the circular economy
Support recognition of embodied carbon, also whole life carbon (see CC/CE). build for future re-use, including requiring use of lime mortar not cement to enable re-use of fired and quarried materials.

Where possible, existing buildings should be re-used (“The greenest building is the one that already exists”– Carl Elefante https://www.architectsjournal.co.uk/news/opinion/the-greenest-building-is-the-one-that-already-exists quoted in the Architect’s Journal Retrofirst campaign https://www.architectsjournal.co.uk/news/opinion/join-our-retrofirst-campaign-to-make-retrofit-the-default-choice)

Require whole-life assessments whenever demolition of an existing building is proposed. (e.g. false net zero claims made for new Kings College development on Barton Rd – no mention of the embodied carbon of the buildings demolished to make way; same applies to the Flying Pig replacement) .

Incredibly, no mention of retrofit in the Climate Change topic paper! The Council’s apparent view that retrofit is not within the scope of the Plan is mistaken. The only place in which retrofit is mentioned, and far too narrowly, is in policy GP/CC in the Great Places paper. This is one of several instances where a holistic approach should require read-across between Policies in different sections (e.g. also between historic environment and natural environment).

Retrofit will be within the direct scope of the Plan (guiding planning decisions) whenever it involves works which could potentially require planning permission or listed building consent.
[Case in point is the new Institute for Sustainability Leadership building (conversion of former telephone exchange) on Regent St. Major impact on appearance of building which makes (or made) a positive contribution to the Conservation Area, not a heritage asset but requiring planning permission. The submitted justification included every possible assessment criterion apart from townscape / heritage impact (shockingly not even considered by the applicants!). What has been approved and is now being built involved losing the window detailing which was a key part of the building’s character. Since that scheme was approved, PAS 2038 (non-domestic retrofit guidance) has come into force: it would have required a more comprehensive approach by the applicants, and might have led to a different decision. ]

Retrofit is also within the scope of the Sustainable Design and Construction SPD, which needs to be updated to include embodied carbon, over the whole life cycle of construction (including retrofit and refurbishment), as set out in British Standard BS EN 15978:2011:
SEE ATTACHED
(slide by Alice Moncaster)

This Climate Change section should include specific policies covering retrofit, which will feature ever more strongly as Govt targets for Band C etc bite. These targets present serious challenges now, and will get ever more serious during the Plan period, with high risks of carbon (and money) being wasted on inappropriate works. Yet Net Zero Carbon for existing buildings is mentioned only cursorily, on a single page (35) of the Local Plan’s Net Zero Carbon Evidence Base.

There is no mention whatsoever of the need for a different approach to buildings of traditional solid wall construction. These form at least a quarter of the existing stock; this proportion should have been considered and assessed as part of the Evidence Base. It could even be as high as 35%, the proportion quoted in the BRE study “Solid wall heat losses and the potential for energy saving” published by DECC in 2015.

The specific challenges of traditional buildings , and the risks of unforeseen consequences (and of consequent waste, rather than saving, of carbon and money) are highlighted in PAS2035, the Government’s guidance on domestic retrofit, which is referenced in Policy GP/CC. However the reference to PAS 2035 in the Policy is futile in its draft form because the PAS (although Government guidance) is not freely available, but published by the British Standards Institute, costing £190, and so is inaccessible to home owners and others who need the guidance.

The Climate Change section of the Plan should quote key principles and guidance* from PAS 2035 and its non-domestic counterpart PAS 2038 (and reference other freely available advice including from the STBA and IHBC as well as the Government’s own guidance to Private Sector Landlords) in sufficient detail to ensure that people dealing with ALL traditional buildings (not only heritage assets) have access to the appropriate advice and skills to ensure that their buildings are put in good repair, and then suitable retrofit measures are applied as appropriate. See https://stbauk.org/whole-house-approach/. This is essential to achieve the aims of the PASs and to minimise unintended consequences.
*including (e.g.) section 0.1.1 of PAS 2035:
SEE ATTACHED

Biodiversity and green spaces
Biodiversity and green spaces - general comments
Serious environmental capacity issues (see above), particularly in relation to intensification of pressures on green spaces..

BG/BG: Biodiversity and geodiversity
Projects proposed to help achieve net zero need to be both delivered and SAFEGUARDED, throughout the Plan period, to ensure that the aims are delivered (e,g, need to ensure that biodiversity / natural capital / “doubling nature” and any other such schemes are protected from subsequent inappropriate changes of use or management)

BG/GI: Green infrastructure
Flawed in that green infrastructure and historic environment re considered separately (see comments on Edge of Cambridge, River corridors, and Protecting open spaces). A holistic approach is essential – see NPPF definition of the historic environment..

BG/RC: River corridors
The River Cam Corridor initiative does not mention the historic environment, historic environment designations, or conservation area appraisals. High risks of more intensive use. no mention of environmental capacity issues or recognition that there may be capacity limits to growth or access by either/both local people and visitors (impacts of punt operators on Cam, etc). No mention of historic environment designations. No consideration of areas under particular threat. No consideration of historic / characteristic uses and land management. The whole river corridor from Byron’s Pool to Baits Bite, and its historic uses are vital parts of the historic and cultural as well as landscape character of Cambridge and should be safeguarded. Grantchester Meadows, one of the key river corridor historic and cultural spaces, is the only vital section of the corridor currently without Conservation Area designation; it is currently threatened by visitor pressures and by possible removal of the grazing cattle which play a vital part in traditional water meadow management.

BG/PO: Protecting open spaces
No mention that many open spaces are historic, and form part of the historic environment (see NPPF definition of the historic environment) need to consider their significance as a whole, not just in terms of green infrastructure. Historic environment and local identity are vital elements of the wellbeing identified here

BG/EO: Providing and enhancing open spaces
Open space is not just green space - what about the market square, Quayside etc etc? Need to manage existing pressures, and avoid harmful intensification of use, on all open spaces, and ensure that new development does not increase these pressures. The river corridor is particularly vulnerable.


Wellbeing and inclusion
Wellbeing and inclusion - general comments
There are no documents in the Document Library to support this theme. Why not?

The Topic Paper highlights the importance of place and space, but its text is focused on new developments, and does not mention the contribution made to wellbeing by the beauty and special character of existing places, including the city of Cambridge, the towns and villages, and valued countryside. The historic environment is a vital part of wellbeing.

Nor is Covid mentioned, even though the pandemic has highlighted the vital importance of access to local green space, and to local fresh food. Small local producers have continued to provide when the supermarkets supply chains fail. Cambridge market, and the local producers who sell from it, continues to provide a lifeline of health and wellbeing for many people, as well as providing vital opportunities for business start-ups including makers as well as food sellers.

There is no assessment of existing cultural activities, of current demands for space, or of demands for new space arising from either existing approved growth or that now proposed. Nor is there any assessment of related opportunities in terms of under-used retail space post-Covid. This is a totally inadequate baseline for a credible Plan.

The forthcoming Cultural Infrastructure Strategy for Greater Cambridge will need to recognise Cambridge’s international cultural significance in terms of both its historic environment (which meets UNESCO’s Outstanding Universal Value criteria for World Heritage sites), and its past and present cultural activities. The Local Plan should include policies to protect this significance, and specifically to support cultural activities, and to provide for, and safeguard, public and private spaces for arts and other activities.

Great places policies
Great places – general comments

The Great Places paper refers to Heritage Assets, but completely fails to recognise that the city of Cambridge is a heritage asset of worldwide significance which meets UNESCO’s Outstanding Universal Value criteria for World Heritage status. This significance derives from the combination of its built and natural heritage. The draft Plan fails to recognise the vital role which this special character plays in making Cambridge a great place to live in, work, study, and visit.

The draft Plan also fails to recognise the historic relationships between Cambridge as a market town, its market, and its productive hinterland.

The draft Plan’s approach involves a false separation between Landscape and Townscape (Objective 6) and Historic Environment (Objective 7), which for Cambridge has resulted in inadequate consideration and valuation of the historic city in its historic landscape setting, with historic landscape and open spaces considered as green infrastructure but not as historic environment.

Cambridge’s special character has been, and continues to be, under severe threats from the quantum of already approved growth (built developments and pressures on both streets and green spaces). There are severe environmental capacity issues in trying to accommodate the demands of a 21st century city within what remains the built fabric and spaces of a medieval market town. These fundamental conflicts between growth on the one hand and environmental capacity and special character on the other should have been recognised as a key challenge for the draft Local Plan. so why wasn’t the Historic Environment Baseline Study prioritised, and published as part of the Nov 2020 tranche?

But the draft Plan documents include no assessment of current pressures, let alone the impacts of the draft First Proposals.

Instead, para 3.2.4 of the Strategic Heritage Impact Assessment: baseline makes a totally unevidenced statement that:
“3.2.4 Future growth in Cambridge has the potential to strengthen and reinforce these characteristics, enabling the City to meet contemporary environmental, economic and social drivers without undermining its economic identity".

Overall, the Evidence base for Great Places is inadequate, and the proposals are premature pending a thorough review of the success or failure of existing policies.


GP/LC: Protection and enhancement of landscape character
Over-intensification of use is a major threat to landscape character.

GP/GB: Protection and enhancement of the Cambridge Green Belt
I strongly support protection of the Green Belt, but the Green Belt assessment is not fit for purpose, because it ignores historic environment designations and landscape character constraints.

The Council appears to have forgotten that the Green Belt was set up to protect the setting of the historic University city.

GP/QP: Establishing high quality landscape and public realm
Serious issues of street capacity.

GP/HA: Conservation and enhancement of heritage assets
A vital issue given totally inadequate consideration and priority. The historic environment (not just heritage assets) is a vital part of Cambridge, not just in terms of Great Places, but also for Wellbeing, and for the city’s prosperity.

The historic environment, and its capacity (or not) to withstand existing growth (let alone new growth proposed) should have been considered at the start of the Great Places chapter. Understand what you have, then consider its capacity for change
Fails to consider anything other than designated heritage assets. No consideration of heritage significance of Cambridge as a whole, or of the heritage significance of undesignated buildings, spaces, and intangible heritage –notably Cambridge’s market, which pre-dates the University, and Grantchester meadows.
The Heritage Impact Assessment is not fit for purpose, and clearly written by consultants who have limited knowledge of Cambridge, and of issues, policies, and initiatives relating to its historic environment. There is no mention of any Conservation Area appraisal apart from the Historic Core, and no cumulative assessment of significance and issues identified in these Appraisals.
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The “Strategic Heritage Impact Assessment: baseline” is woefully inadequate in both its scope and its approach:
a) In its scope, because it confines itself to stages 1 (identify the historic assets” and 2 (“define and analyse the settings”) of Historic England’s ”Settings of Heritage Assets: Good Practice Guide”, without considering the dynamic of the city as a whole, what has been happening in its recent years, or the potential impacts of currently approved growth. It is almost as if the Council asked for an updated version of the 1971 publication “Cambridge Townscape”, whilst completely disregarding the award-winning conservation plan approach of the 2006 Historic Core Appraisal which sought to understand not just the physical character of Cambridge but its dynamic, and threats and opportunities, as part of shaping policies.

b) while the document references the Historic Core Conservation Area Appraisal, it does not even mention other Conservation Area Appraisals (ignoring the complete Appraisal coverage of the City's Conservation Areas) or issues and opportunities identified therein. Nor does it mention the Suburbs and Approaches Studies. It is all too clear that the consultants have taken only a superficial look at the baseline information.

c) I would have expected consultants preparing this “high level” document to consider the historic environment, and the extent of designations, strategically (a great opportunity for this combined Plan) - but the document does not even consider the extent to which Cambridge’s historic and cultural landscape (including the river corridor from Byron’s pool to Baits Bite Lock) is or is not protected.

d) The study completely fails to assess the significance of Cambridge as a whole. Dennis Rodwell’s “Conservation and Sustainability in Historic Cities” puts Cambridge on a similar level of international significance to Venice.

e) For the options involving development in and adjacent to Cambridge, it seems to assume that most problems can be resolved by Design, completely ignoring environmental capacity issues. At a most immediate level, what if any detailed assessment has been made of the wider visual impacts of tall buildings on the North-East Cambridge site?

There are fundamental environmental capacity issues in terms of pressures on the character and spaces of the historic core and surrounding landscape, due to not only the additional volumes of development, people and traffic being generated by the proposed additional growth, but all of these arising from existing approved growth plus the transport links required to enable it.

There is no assessment whatever of the cumulative impacts on landscape, townscape and environmental capacity of all the GCP and other proposals including busways, City Access, Greenways, Active Travel schemes etc.

A third-party, holistic overview is essential to identify and try to resolve some of these key strategic issues and balances, and consider to what extent further growth is viable. In relation to heritage, growth is seriously threatening what makes Cambridge Special. I suggest that Historic England’s Historic Places Panel are invited to visit Cambridge and provide strategic recommendations which can inform the Local Plan.

The flaws in the current approach are exemplified by a claim in the Strategic Heritage Impact Assessment: baseline:
“3.2.4 Future growth in Cambridge has the potential to strengthen and reinforce these characteristics, enabling the City to meet contemporary environmental, economic and social drivers without undermining its economic identity"
This statement can only be described as unevidenced, shockingly ignorant and ludicrously complacent.
Moving from strategic issues to safeguarding individual heritage assets and their settings, there are serious questions in relation to the effectiveness of existing policies which are proposed to be carried forward.

A case in point is the former Mill Road Library a grade II listed building of high public significance, which was recognised to be “at risk” but ignored by both the City and County Councils during the development and approval of the City’s Depot site redevelopment. This was a massive opportunity which would not have been missed had the City complied with its own Local Plan policy regarding heritage assets. While the County has belatedly refurbished the former Library, it has not been integrated as a public building within the new development. It appears that the County may now be offering this public building, built for the public, for private sale!

GP/CC: Adapting heritage assets to climate change
This policy is basically very good -but should relate to all buildings of traditional construction, and needs some updating. Needs direct read-across to CC/NZ. See my comments on CC/NZ.
Supporting documents on which we are consulting
Sustainability Appraisal (incorporating the requirements of the Strategic Environmental Assessment)

The Sustainability Appraisal fails to tackle the key environmental capacity issues arising from existing growth, let alone that now proposed.

The whole definition of “Sustainable Development” is too narrow given that since 2010 the UN has included Culture as the 4th pillar of Sustainable Development - and Cambridge's historic environment is a cultural asset of worldwide significance.

Within the current UK sustainability assessment process (dating from 2004 and excluding culture), there is a separation between Landscape and Townscape (Objective 6) and Historic Environment (Objective 7), which for Cambridge has resulted in inadequate consideration and valuation of the historic city in its historic landscape setting, with historic landscape and open spaces considered as green infrastructure but not as historic environment.

The Federation of Cambridge Residents’ Associations (FeCRA) is a grassroots civic voice for everyone in Cambridge and for its environment. Residents want a say in shaping Cambridge’s development to ensure that the city grows in a way that is sustainable and inclusive, achieves balanced communities and addresses the issues of climate change and health, social equality and quality of life. Residents know their areas well, and they want to be involved in evidence gathering and data collection.

Over the last years residents' associations have organised successful discussions on parking, local election hustings, Greater Cambridge transport schemes, neighbourhood planning, heritage and public realm and green spaces and the river and biodiversity.

FeCRA’s well attended AGM events are organised on the same basis, featuring presentations from prominent experts including leading landscape architect Kim Wilkie, George Ferguson, former Mayor of Bristol and the distinguished Oxford ecologist Professor David Rogers. More recently, the Supersize Cambridge event which attracted 230 people and involved community reps from all over Cambridge highlighted concerns about employment led growth and the global interests driving this. FeCRA’s strength is in its network of members in all city neighbourhoods and good channels of communication with villages across South Cambs, along with the five OxCam Arc counties and Norfolk, Suffolk, Hert and Essex. The Federation is entirely voluntary and self funded.

A sense of neighbourhood and wellbeing and belonging and mutual support is especially important in a city which has earned the unenviable title of the most unequal city in the UK.

Draft Local Plan
How much development and where
Many residents are shocked at the level of growth proposed in the new Draft Local Plan and what they see as the plan’s failure to consider the overall environmental capacity and climate change impact and the effect on the historic environment (built and natural) in a holistic way. There is no mention of Covid and opportunities for city centre residential and/or other uses resulting from potential radical changes in retail and office working.
There is no consideration or assessment of current growth in the pipeline or of the success or failure of current Local Plan policies, no assessment of the cumulative impact of current growth, especially in terms of delivering the claimed nature and quality of development.

There is a complete dearth of new cultural or provision for other ‘city-scale’ needs which will put the city centre under even greater pressure.

Where is the overall vision of what Cambridge will be like in the future? Who is the city for? This plan does not make clear.

The question of how much development and where is premature pending the January 2022 consultation on the Regional Water Plan and the investigation of sewage infrastructure and sewage dumping by Anglian Water.

Inadequate Water Supply

Cambridge City and South Cambridgeshire already have an unsustainable supply of potable water. In August 2020, the Environment Agency, in response to a query on the viability of water supply to Northstowe Phase 3A wrote to Monica Hone of Friends of the Cam that 'current levels of abstraction are causing environmental damage. Any increase in use within existing licenced volumes will increase the pressure on a system that is already failing environmental targets', and 'many waterbodies did not have the flow to support the ecology.'
On the 1st July 2021, DEFRA announced that chalk streams would be given enhanced environmental protection, and published the Environment Agency document titled “Water stressed areas – final classification 2021” which included the fact that the supply areas of Cambridge Water and Anglian Water are areas of serious water stress, page 6.
According to Appendix 3, Cambridge Water needs to reduce abstraction by 22 megalitres per day from levels current at 1st July 2021, and Anglian Water needs to reduce abstraction by 189 megalitres per day from levels current at 1st July 202

Yet, one of Anglian Water’s proposed ‘solutions’ to this problem is to pump water from North Lincolnshire, which is also classified by the Environment Agency in the above report as a water stressed area.

The expectation that ‘green’ growth and River Cam Corridor nature tourism can fund a system of water management without addressing over- abstraction and sewage in the rivers

The local sewage system is currently inadequate. The inadequacy of the sewage system is evidenced by the number of sewage spills by smaller Anglian Water sewage works into the Cam Valley. Currently, there are no plans to improve failing combined sewer overflows (csos), just promises to monitor them more accurately. The Cam Valley upstream of Cambridge saw 622 hours of untreated wastewater enter the rivers in 2020, yet Anglian Water is proposing to move the one sewage works in the area which has been upgraded and has sufficient capacity until 2050, the main Cambridge works, into the Green Belt and to spend at least £227 million of public money to do so. This will be the subject of only a partial public inquiry because it has been submitted as a National Infrastructure project in order to minimise public scrutiny.

To date there have been no upgrades at any of the smaller works in the area while more and more taps are still being connected. The Environment Agency has already warned at least one Cambridgeshire local planning authority, East Cambs District Council, that they must stop looking at the sewage requirements of single planning applications and instead look at the cumulative effects.

How can anyone talk about ‘green’ growth and nature tourism when the water companies are over-abstracting and filling the Cam chalk streams with sewage.
New jobs and homes – the plan proposes 58,500 jobs and 44, 400 homes

The way in which this consultation is framed and the fact that it does not address how the region’s water crisis and wastewater and emission problems will be resolved ignores both environmental constraints and the failure of current policies to provide affordable housing. It does not give a true picture of the cost of such high employment growth for the UK’s driest city with a water crisis whose world famous river is drying up and dumped full of sewage.

It undermines the Government’s policy of ‘levelling up.
It completely ignores how the plan will ensure that new developments are for local people and not dormitories for London commuters or just opportunities for foreign investors.

New communities take time to emerge, if they do at all, but the issue is that many new developments are injected into places with existing communities that may suffer as a result, an issue this plan does not assess.

Professor Dieter Helm, Chair of the National Capital Committee has stressed the importance of long-term risk assessment in ensuring net environmental gain, in perpetuity, despite development. There is no evidence that this has been done.

There are massive environmental capacity issues which the Draft Local Plan does nothing to address, with inadequate space in city streets and public realm to cater for existing traffic, let alone approved growth already in the pipeline – even before considering these First Proposals. The capacity issues have to be tackled, with additional growth allowed only if they can be resolved.

Green Belt Assessment

The Green Belt assessment is not fit for purpose, because it ignores historic environment designations and landscape character constraints.

On the edge of Cambridge the serious landscape impacts of the Cambridge BioMedical Campus expansion southwards into the Green Belt open countryside towards the Gogs will severely damage this lovely setting of the city with its beautiful chalk downland views. The expansion and likely increase in footfall will hugely impact the small nature reserve of Ninewells, the reserve’s unique character and boskiness and farmland birds.
Building NE Cambridge will indirectly destroy the Green Belt by displacing the sewage works and using a lot of concrete which has a very high carbon footprint.
There is no operational need to move the treatment works as Anglian Water has confirmed. The relocation is taking place to enable development within Cambridge in which the water company is a beneficiary as co-developer. The current site is more than adequate for at least another 30 years and could be upgraded at far less cost. The existing treatment works at Milton is effective and has spare capacity. It was upgraded only recently, at a cost of £21 million in 2015, in order to support planned development in Cambridge and the surrounding area until 2050 and is being vacated only to enable redevelopment. We understand that the Milton Plant is currently only running at approximately 50% capacity. The CO2 cost embedded in the new structure and emitted in demolition and construction is sizable.

Many residents question why the works are being moved given the impact on the Green Belt, the loss of valuable farmland, and the harm to local communities, all of which are united in their opposition. They question how this complies with the guidance outlined in the HM Treasury’s Green Book Valuation of Wellbeing Guidance for Appraisal https://www.gov.uk/government/publications/green-book-supplementary-guidance-wellbeing especially as the Stantec Report prepared as part of the review of the Local Plan and the letter from the Environment Agency https://www.fecra.org.uk/docs/Env%20Agency%20re%20Northstowe%207%20August%202020.pdf make clear that any further development beyond that already planned is unsustainable as ‘current levels of abstraction are causing environmental damage. Any increase in use within existing licensed volumes will increase the pressure on a system that is already failing environmental targets’.

There is no mention in these plans of how relocation of the wastewater plant will address any of the concerns about all the sewage being dumped in the Cam or how Anglian Water proposes to make the River Cam clean and safe for all users. If you were going to spend £200m plus, or even a fraction of it, it should be spent on improving and updating the small local sewage works based around villages etc, which release sewage in the Cam via its tributaries, not on rebuilding something that is working well. In the case of these small poorly functioning sewage systems Anglian Water is almost solely responsible and that is what residents tell us this company should be focusing on, not this grandiose money-making scheme. The chair of Water Resources East, Dr Paul Leinster, is a member of the new Office for Environmental Protection. He is on public record as stating that what to do with the wastewater is one of the biggest problems for development in the region proposed by the government for the Oxford Cambridge Arc.
There are a number of SSSI’s close to the site which could be affected by its construction and operation: Brackland Rough, Cam Washes, Cherry Hinton Pit, Chippenham Fen and Snailawell Poors Fen (a RAMSAR site), Devils Dyke, Felan Dyke, Fulbourn Fen, Gog Magog Golf course, Great Wilbraham Common, Histon Road, Roman Road, Snailwell Meadows, Stow-cum-Quy Fen, Upware South Pit and Wicken Fen, which is another RAMSAR site.

Anglian Water recognises the likelihood that the surface water originating at the works at the Honey Hill site will drain towards Quy Waters protected waterbody and could contaminate it. Yet they have ignored the fact that contaminated groundwater in the chalk aquifer beneath the site could pollute these other receptors and protected rights (local well users) as well as other parts of the surface water drainage network.

The Honey Hill site is in the National Trust Wicken Fen Vision. This is a National Nature Reserve and a Nature Conservation Review site. It is a designated RAMSAR, SAC wetland site of international importance and part of the Fenland Special Area under the Habitats Directive. How does a scheme which robs East Cambridgeshire villages of their green belt and medieval river landscape setting and which impacts the Wicken Fen Vision correlate with protecting Green Belt land which is specifically designed to preserve the historic character of Cambridge and its green belt setting and the River Cam?
Democratic deficit in the process and evidence basis for the Draft Local Plan

Water Resources East have stated that their regional water plans which include plans for natural capital align with the Government's plans for growth. Sewage in rivers and chalk streams is a matter of national concern, yet Water Resources East say that sewage is not part of their remit. They have also said that there will not be public consultation on the regional water plan.

Meanwhile, the public consultation for the Draft Local Plan is taking place now, yet the consultation for the Regional Water Plan is not due until summer 2022. The public and councillors are forced to respond to Local Plan proposals with no idea whether, and if so, how, the water and sewage challenges can be resolved or what trade-offs have been proposed.

South Cambs. MP Anthony Browne has rightly expressed concerns about the Local Plan process and about water issues and transparency.

The Draft Local Plan has been prepared by the Greater Cambridge Shared Planning Service, but it appears to be inordinately influenced by the unelected Greater Cambridge Partnership which has business interests represented on its board.

Much of the text of the Draft Local Plan appears to be consistent with announcements made by the self- appointed Arc Leaders Group promoting the so-called Ox-Cam Arc. This flawed concept has been criticised for lack of transparency or accountability right across the five affected counties and one county, Buckinghamshire, has withdrawn entirely from this completely undemocratic, self-selecting, body.

At a presentation of growth scenarios for Cambridge Futures3 given by the Vice Chair of Cambridge Ahead Matthew Bullock and Dr Ying Jin in June 16, 2018 the audience pointed out that all of the scenarios for Cambridge Future 3 led to Cambridge having a much higher level of growth.

They highlighted that the growth scenarios made no mention of environmental capacity issues, nothing on climate change, quality of life, affordable housing or why people chose to live in and around Cambridge for cultural and green spaces reasons etc. At the presentation it was made clear that Cambridge Ahead & Cambridge University planned to monetise the model they had come up with.

So the model was not in any sense charitable work, it was completely commercial.
Bullock stressed how complex the model was that Dr Ying Jin and his team had come up with and that they would need to come up with a price for running the model with different input parameters.

This meant that Cambridge Ahead and Cambridge University controlled access to the model, limiting detailed scrutiny and testing by independent third parties.
Those working on the growth scenarios included officers and consultants from SQW – the same consultancy employed along with the real estate consultants GL Hearn by the planners to assess the modelling for the Draft Local Plan as ‘they were not conflicted’.

The presenters Matthew Bullock and Dr Yin Jing said that changing elements of the model and programming scenarios was technically challenging and slow, making it difficult or impossible to test a large number of scenarios.

They also said that they intended to monetise the model, e.g. by charging planning authorities, ONS (the Office of National Statistics) and developers to use it.

The business group Cambridge Ahead had a strong commercial motive for this modelling and the modelling evidence for a much higher level of growth and lots more houses to be built, gives a strong lead on where development should take place. Attendees at the Case for Cambridge Future 3 meeting pointed out that the pre-set "no holds barred" scenarios defined by Cambridge Ahead and Cambridge University and officers and consultants working with them would thus become the only options, even though there were likely to be many other scenarios that would produce better outcomes.
Thus the modelling that has been used to inform the Cpier Strategy cited in the Greater Cambs Employment Land and Economic Development Study Draft Local Plan does not take account of social justice, regional landscape strategy or address environmental capacity issues including those of the river, the city centre and the city’s green spaces. Nor does it consider how people want to live, respecting what communities value, and the issues of climate change, the natural world, water shortage, sewage etc.

This Draft Local Plan reflects those pre-determined scenarios of building on the urban fringes and transport corridors to support the high employment growth defined by Cambridge Ahead and the interests funding the research.

At the Case for Cambridge Future 3 meeting attendees referred to "No holds barred scenarios" and a number of people noted the 'densification' scenario assumed that Trumpington Meadows would be developed alongside Cambridge South station as a location for high density development which would assume a planning approach of creating new development which you “mitigate” by reserving areas of green spaces as ‘wild belt’. They pointed out the approach was to sell housing on that basis and then take it back afterwards for infill and that this was already happening at Cambourne.
The same point about infill and wild belt was made by David Plank of the Trumpington Residents Association regarding the recent presentation by the planners of the Draft Local Plan and the BioMedical Campus Expansion plans round Ninewells to the South Area Committee.
In August 2019 the FeCRA Committee wrote to the Deputy Leader of Cambridge City Council to express concern that the Shelford Local Plan workshop for city residents, cited as the formal first stage of public engagement on the Draft Local Plan had been organised at very short notice and with very little opportunity for city residents to engage in the first formal stage of the Local Plan Process.

FeCRA filmed all f the Local Plan Presentation on the 2018 Local Plan. The film is available for everyone to see. There was very positive feedback from Residents Association members but the presentation also flagged up major concerns about the ‘growth agenda’ and the apparent lack of transparency and democratic input around it.

We were told at that meeting that there would be an opportunity for residents to contribute to early discussions about the next LP, yet this Local Plan workshop was arranged at such short notice and at a time and place that made it difficult for many city residents to attend. Consequently very few city residents attended.

Green Infrastructure Modelling Workshops
In June 2020 Deputy Director of Greater Cambridge Shared Planning, Paul Frainer, writing to the FeCRA Committee, said:
‘Ahead of and separate to the Local Plan process, the Local Nature Partnership (as a separate body albeit with some local authority input) has identified priority projects it would support if funding were to become available in the short term, but no decisions have been made through the Local Plan process about which green spaces to prioritise.

The Local Plan green space evidence base study will identify priority projects, and will advise which should be included in the Local Plan, and which should be delivered through land management as opposed to development processes. This priority list will in future also inform biodiversity net gain offsetting, and bids for funding from other sources’.

The minutes for the June 2020 Natural Cambridgeshire board meeting states that the board will:
• ‘Work with developers to enhance nature either on site or through offsets’ –Cameron Adams, the Environment Agency
• ‘Consider how best to engage with farmers and other landowners, and help them get better returns from their investments’ –Rob Wise NFU
• ‘Collaborate with Natural Capital East’ –Cameron Adams
• ‘Review progress of Doubling Nature at end 2020’ –Richard Astle - Athene Communications
On 26 July 2020 the FeCRA Committee wrote to MPs, copied to the planners and Lead Councillors to express concern about the Greater Cambridge Green Infrastructure Online Survey - 27 July which had been framed again in a way that excluded residents from having a say, particularly about the river and its historic environment. They asked why this survey was linked to funding bids, S106 development sites and future parks accelerator plans and why there had been no assessment of impacts and issues arising from current and already approved growth on green spaces at this stage?

“Why is there no engagement with strategic environmental capacity issues as a vital part of the evidence base for the new Plan?” The Committee pointed out that the government’s plan for sustaining high growth and building one million houses in the OxCamArc is underpinned by Natural Cambridgeshire’s vision for “doubling local nature”, with urban fringe parks in the green belt. Plans for ‘linear river parks’ feature in council and development plans but there had been no consultation with friends or river groups or local councillors.

The River Cam is the only river in the country that is not back to normal flows, yet exponential growth fuels huge pressure upon our natural water supplies. Concerns about the impact of over-abstraction on the River Cam have been expressed but large development keeps getting approved.

Stage 3 of this Local Plan Green infrastructure consultation featured technical workshops, themed around the benefits that green infrastructure provides, to discuss the issues and opportunities arising from the survey responses.

Community reps and residents who had not been able to engage with this survey or who didn’t have funding bids with developers and NGO’s were not able to get a say at the next stage.

This letter followed concerns expressed to Greater Cambs Planners and Cllrs Katie Thornburrow and Bridget Smith that many residents had not been able to access the on line Green Infrastructure consultation hub and the inaccuracy of the mapping and data, highlighted by experienced university conservationists.

Addressing the challenges of climate change and health, social equality and quality of life benefits from local knowledge and the involvement of residents who know about water, flooding, wildlife and nature and managing green spaces and local resources in their areas, working with their elected councillors. Residents say that decisions about land use and ecology have been made by business and interest groups without local knowledge or accountability

The inspirational town planner Jan Gehl advocates that to build communities that work well where people, not cars, occupy the pavement, the evidence needs to be shown and environmental capacity issues need to be addressed. One should count all the pedestrians, cyclists and strollers going by, just as highway planners have long tallied up road users in vehicles and the number of people using the river and its green spaces.
Where is the evidence that this has been done in the Draft Local Plan? It has not been demonstrated that there is sufficient water supply within Greater Cambridge to support future development and existing ground water abstraction is impacting water flows within chalk streams in the region anday need to be reduced, especially in the light of climate change.

The situation with groundwater around Cambridge is critical: the whole Cam river system is in crisis
Using water more efficiently is important, but efficiency will not increase the maximum volume of water that can be supplied on a sustainable basis without impacting the environment.

As such REFUSAL of developments is necessary where there is no available water to supply them and/or the environmental impacts caused from supplying that water outweigh benefits of the grant of that permission.
A similar point applies to discharge, especially where this is to groundwater. Where a European site is affected, alternative locations and OROPI ( Overriding Reasons of Public Interest ) may need to be considered prior to any planning decision.

NPPF para 7 makes this point: "The purpose of the planning system is to contribute to the achievement of sustainable development. At a very high level, the objective of sustainable development can be summarised as meeting the needs of the present without compromising the ability of future generations to meet their own needs. "

The presumption in favour of sustainable development cannot be determined without sufficient information on the water demands of a development, how these will be met and the implications for the environment and future generations.

We strongly suggest that all planning applications should at application stage confirm their total required annual water usage and have accompanying documentation to confirm that such water can be supplied and discharged where applicable in a manner.

We suggest that all developments are subject to Habitat Regulations Assessment based on their cumulative and in-combination impacts on the available water supply.

Biodiversity
Conservation is essential to sustainable development and together with enhancement of biodiversity should be considered as a key element of good planning and design. 'Doubling nature', Biodiversity Net Gain (BNG) and Natural Capital Accounting (NCA) are being used as bargaining chips by developers. That broadly amounts to saying, 'No development means no funding for nature'. This is the antithesis of John Lawton's 2010 plea in 'Making Space for Nature' of significant funding for Nature conservation without any strings attached.
The concept of doubling nature is ill-defined - doubling what, exactly? The Draft Local Plan needs to define exactly how the concept will be understood and measured.

The global experience of Biodiversity Net Gain, reviewed by zu Ermgassen of DICE, University of Kent, is that it fails twice as often as it succeeds, even though it had the lower bar of No Net Loss, NNL rather than BNG.
The same group more recently showed that 95% of early-adopters of BNG practices in England are carrying out on site offsetting (something not covered at all in the new Environment Law), where the developer is the judge, jury and executioner of any offsetting plans. In any case, on site offsetting will not encourage many forms of wildlife and will be prone to the dog-fouling and trampling that harms many wildlife areas, even those remote from housing. Meanwhile, off-site off-setting is already damaging local communities in some rural areas.
Natural Capital Accounting is an untested concept. The monetary assessment of ecosystem services (the 'yields') is recognised as being inadequate at present, while assessing the monetary value of ecosystem stocks is more or less impossible (Ian Bateman, communicated to David Rogers). Yet the resulting monetary assessments may be used to trade away environmental for economic assets with a greater yield, for example a factory in a water meadow.

The natural environment is our vital life support system, and it is a dangerous delusion to imagine that it can be rendered easily into any economic framework, let alone the pre Dasgupta framework that gives GDP/GVA primacy over all other forms of stocks and yields.
Dasgupta defines wealth as the sum of natural, human and economic capitals and yields, and sustainability as the condition where this sum is either stable or increasing. Economic growth at the expense of natural capital and yields is therefore unsustainable.
We request that the Cambridge Local Plan adopts the Dasgupta definition of sustainability, i.e. definitely not the NPPF's false definition of 'sustainability', with the caveats mentioned above, especially the false or under-valuation of natural capital. This would provide a better starting point, and the Plan should be reworked in this context.

Sea level rise
Large areas of Cambridgeshire, including parts of the City of Cambridge, are subject to continuously increasing flood risk. Indeed, not only is sea level rising, the rate of sea level rise is increasing rapidly. For many years, since measurement began, sea level in the Wash was rising at a rate of 3mm per year. In 2019 it was measured by the Environment Agency in the Wash, and confirmed by IPCC figures globally, that the annual rate was now 3.3mm per year. In 2014, the IPCC report estimated a sea level rise of 1 metre by 2100. In 2019, the IPCC increased this estimate to 1.1 metres by 2100. In 2021, the IPCC has increased its estimate again, to a terrifying 2.4 metres by 2100. Meanwhile, the meteorological partnership Climate Central estimates a 4.7 metre sea level rise by 2100 if global temperatures rise by 2°C. Both the IPCC 2021 and the COP26 leadership have confirmed that the world is currently on track for a 2.4°C global temperature rise.

The other solution to Cambridgeshire’s water shortages being proposed by Water Resources East and Anglian Water is to build two reservoirs in the Fens, one in South Lincolnshire, the other in Cambridgeshire near the River Great Ouse. However, there is little point in building reservoirs in the Fens when it is clear that there is a high risk they will be flooded by saline water within decades.
As flood risk increases, the Fens will initially be subject to occasional and then annual flooding caused by water in its tidal rivers meeting increased volume of run-off from development. Eventually, the tidal inflow will prevail and flooding will become permanent as the sea level inexorably increases. However, even the first stage will have a significant negative effect on agriculture. The Treasury Green Book assumes loss of cropping for one year if sea water inundation occurs. In fact, as was found in the 1947 and 1953 floods, reduced crop yields last up to seven years due to the presence of a nematode in sea water.

Climate Change
We support regular reviews to keep pace with developing technology, standards, Government targets (e.g. the Heat and Buildings Strategy, not mentioned in the draft Plan) and rapidly developing guidance and best practice. There are also serious quality control challenges in relation to whether aspirational aims are actually delivered. Outline planning permissions must be subject to the aspirations articulated in the Draft Local Plan.

How will this be done?
The definition of a Net Zero Carbon building set out in the evidence Base does not include its embodied carbon: this is a very serious omission which undermines all claims made about the sustainability of new development, and raises questions about the claimed sustainability credentials of all the Growth options being proposed.

Projects proposed to help achieve net zero need to be both delivered and safeguarded throughout the Plan period, to ensure that the aims are delivered (e.g. need to ensure that biodiversity / natural capital / “doubling nature” ( sic) and any other such schemes are protected from subsequent inappropriate changes of use or management)

For all of these reasons we strongly object to the level of growth proposed in the new Draft Local Plan
Local government should not be planning more economic and population growth in this area or more housing than current government targets require, but prioritising social housing and new water infrastructure to reduce stress on our rivers and wildlife. It should be supporting the national ‘levelling up’ policy. It should be consistent with the government’s ‘brownfield first’ objective which will deliver badly needed homes faster. It should take into account the growing flood risk to large parts of the county and consequences for national food supply. It also needs to take into account the as yet, unknown, long-term effects on employment and travel behaviours of the COVID pandemic.

We request that this flawed Draft LP is rejected, re-written and re-submitted for full public consultation.

Context for this consultation

The current situation nationally and internationally with respect to Covid 19 could not have been foreseen when the review of the South Cambrdgeshire and Cambridge Local Plans commenced in 2019. The economic and social consequences of the pandemic and, at some point in the future, its aftermath, could be significant in both the short term and long term, yet no assessment of any possible future changes are built into the proposals set out in this consultation.

Given that certain major housing developments , such as Northstowe and Waterbeach are well underway and planning applications regarding new employment (such as at Granta Park and the Babraham Research Campus) are coming forward, is this consultation so time critical that it could not be delayed for, say,12 to 18 months ?

The location of at least some types of jobs could be affected by more remote working than pre-2020 and this, in turn, could mean that some individuals would no longer need to live close to the company or organisation for which they work, and this would have an impact on travel to work and commuting patterns.

A delay would give time for some indications of impacts relating to local jobs and housing to emerge and to be integrated into the emerging Plan prior to consultations such as this..


Location of housing

Much of the housing development the plan period will come from sites that are already in the current planning pipeline (that is, land already allocated for housing in the approved 2018 Local Plans or when developments has already commenced as , for example, at Northstowe, at Waterbeach and on the edge of Sawston).

However, I wish to comment on two of the new allocations.

I am concerned that the move of Marshalls from the airport site as this will lead to a reduction in the range of job opportunities available in the Greater Cambridge area. However, I accept that Marshalls do seem set to move, so development of the airport site (a brownfield site) is appropriate.

I am very concerned about housing on the waste water treatment plant site. It does not seem to me to be good use of more than £100 million of public money to move the waste water treatment plant about one mile in order to build houses on the present plant site. In fact, there is no need to build houses on the plant site. If the Councils were to revise their housing numbers to bring them more into line with government figures, then this site could be removed from the sites needed for housing development.


The Rural Southern Cluster

The First Proposals consultation includes policy areas for the Babraham Research Campus and for the Genome Campus. Given further likely developments at Granta Park, it is surprising to see that there is no such specific Policy Area for Granta Park.

Planning applications submitted over time are considered on an individual basis, but this approach fails to take into account the cumulative impacts of successive developments on Granta Park. In addition, successive planning applications that each involve building hundreds of car parking spaces do not seem to align with reducing dependence on motor vehicles.

Having a Policy Area covering the Granta Park site could provide a locally agreed framework for future development

INTRODUCTION
1.1 This representation has been prepared by Strutt & Parker on behalf of Gonville & Caius College to support the promotion of land at Rectory Farm, Milton as part of the Greater Cambridge First Proposals Consultation 2021.

1.2 In September 2021 Greater Cambridge Shared Planning Service published the Greater Cambridge HELAA, which provided an initial assessment of the sites put forward for allocation as part of the Call for Sites consultation within Greater Cambridge.

1.3 This representation provides a response to the ‘First Proposals’ Consultations and covers the following topic. The representation has been structured to respond to relevant questions as set out within the First Proposals Consultation. In addition, a detailed assessment is provided in respect of the HELAA Assessment for the site.

1.4 The HELAA excludes the Rectory Farm site from allocation primarily on the basis of landscape issues and highways issues.

1.5 The site was originally submitted as part of the Call for Sites for up to 1,500 dwellings and 30,000 m2 of employment. For reasons explained at Call for Sites stage and set out within this representation it is considered that the site is suitable and deliverable in the medium term for a development of that scale.

1.6 It is considered that several of the assessments criteria, particularly regarding the landscape impact and the transport impact on the A14 should be re-categorised. This is particularly the case given that HELAA assessment appears to have been undertaken in isolation and has not given due consideration to the major transport projects being promoted along the A10 corridor. Further analysis of this is set out within section 7 of this report.

2. QUESTION: Do you agree that we should plan for an extra 550 homes per year, so that housing keeps up pressure with increased jobs in our area?

2.1 We agree that it is very important that housing delivery keeps up with demand for increased jobs within the area.

2.2 As part of the preparation of the emerging Greater Cambridge Local Plan, the Shared Planning Service has identified a need for 2,321 dwellings to be built per year. A significant proportion of this growth is made up of existing allocations within the Local Plan.

2.3 The initial evidence base and spatial options assessment for the emerging Local Plan, set three growth options; ‘minimum’ (40,300 dwellings - based upon standard methodology); ‘medium’ (46,200 dwellings- based upon economic forecast based upon long term historic employment) and ‘maximum’ (67,700 dwellings – based upon fast economic growth in the recent past). In view of this, the housing delivery target of 44,400 new homes over the plan period alongside 58,500 new jobs would fall between the ‘minimum ‘and ‘medium’ growth scenarios previously suggested.

2.4 As acknowledged within the Development Strategy Topic Paper, that accompanies this consultation it is acknowledged that the Greater Cambridge economy is dynamic and does not readily align with national or regional forecasts for job growth. In particular, it has a world- renowned life sciences cluster which has the potential to drive growth beyond typical regional or national rates. It is also acknowledged that in the recent past employment growth within the region has been significantly higher than predicted.

2.5 Accounting for the evidence set out within the Development Strategy Topic Paper, it is not clearly justified why only 44,400 new homes and 58,500 new jobs are proposed over the plan period. It is considered that this approach should be re-visited to increase both housing and employment allocations within the Local Plan. It is considered that the delivery of housing should be significantly increased, in line with the ‘maximum’ growth forecast, to align with economic growth within the recent past. The case for maximum growth forecast is further supported by significant transport investment within the area over the plan period. This includes schemes such as East- West Rail, Cambridge South Station and the delivery of a number of Rapid Transit Routes proposed by the Greater Cambridge Partnership.

2.6 The provision for lower growth scenarios does also not appear to be consistent with the government’s objectives for the Ox- Cam Arc as a centre for housing and employment growth.

3. QUESTION: Do you agree that new development should mainly focus on sites where car travel, and therefore emissions, can be minimised?

3.1 Yes, in principle the proposal to focus development on sites where car travel can be minimised is supported. National policy is clear within paragraph 79 of the NPPF that planning policies should identify opportunities for villages to grow and thrive, especially where they will support local services. The updated NPPF (2021), also provides additional emphases on the suitability of providing significant extensions to villages, provided that they are well located and designed.

3.2 The site at Rectory Farm is located in a very sustainable location, with the development not overly reliant on car travel, with many public transport options easily accessible. It is located centrally along a key growth corridor within the emerging Local Plan. To the north, is Waterbeach New Town, which has planning consent and an allocation for the delivery of over 5,000 dwellings within the plan period and the delivery of a further 4,000 dwellings after the end of the plan period. To the south is the North- East Cambridge Major area of change, which has a draft allocation for the delivery of 3,900 dwellings within the Local Plan period and 8,350 dwellings in total, along with the delivery of 15,000 new jobs.

3.3 It is clear from both the adopted and emerging Local Plan, that the A10 corridor from north- east Cambridge to Waterbeach is a key focus for growth. We fully support this approach. Consistent with this objective, it is considered that further growth should be provided on land to the west of Milton, at Rectory Farm. Rectory Farm is a particularly sustainable option for growth, given that it immediately adjoins the existing park & ride to the south of the site. In addition, the proposed ‘central option’ of the Cambridge to Waterbeach Rapid Transit Route immediately dissects Rectory Farm and has the ability to provide a bus stop within Rectory Farm, which could serve both the existing village of Milton and new job and housing growth at Rectory Farm. There is also the ability to provide ease of cycle access into the City from the site, via Waterbeach Greenway.

4. QUESTION: We think that the area of Milton Road in North-East Cambridge (including the current waste water treatment plant) can be developed into a lively and dense city district, after the water treatment plant relocated. What housing, jobs, facilitates or open spaces do you think this site should provide?

4.1 We support the proposed allocation and redevelopment of north- east Cambridge in principle and as set out in section 3 above, we consider that the corridor between north- east Cambridge and Waterbeach provides a sustainable transport corridor and should provide a focus for growth. However, we do consider that the GCSPS have taken an inconsistent approach in terms of the scoring of North- East Cambridge site within the HELAA than they have for land adjacent to Rectory Farm. Land within North- East Cambridge has a draft allocation for development, despite the fact that it is to a large extent reliant on the relocation of the Waste Water Treatment Works, which is subject to a complicated Development Consent Order approval process.

4.2 The Local Plan also references that the sustainability of North- East Cambridge will improve as a result of planned infrastructure projects such as the Chisholm Trail, Waterbeach to Cambridge Public Transport Corridor and Waterbeach Greenway. We fully support and agree that the delivery of these three important projects will improve the sustainability not only of North- East Cambridge, but also the settlements of Milton and Waterbeach. Within the HELAA Land at Rectory Farm has been deemed unsuitable on the basis of additional traffic pressure on the A14, however Cambridge North- East, which is both a significantly larger development and closer to the A14 has been deemed suitable on transport grounds. It is therefore unclear, why a different approach appears to have been taken between Cambridge North- East and land at Rectory Farm in this regard, which is not justified or sound in planning terms

4.3 Further analysis of this point is set out within our response to the HELAA, within section 7 of this report.

5. QUESTION: We think we should be very limited about the development we allow in villages, with only a few allocated sites in villages, with good public transport connections and local services. Which villages do you think should see new development of any kind?

5.1 The proposed strategy focuses on locating new development in and around Cambridge City, growing existing new settlements, with a small degree of growth in the rural southern clusters.

5.2 It is considered that additional growth should be provided within the most sustainable and largest villages within South Cambridgeshire, such as Milton. As set out in detail within our Call for Sites submission (which has been appended to this representation), Milton is arguably the most sustainable of the Minor Rural Service centres, given its very close proximity to Cambridge, its range of services and the ability to travel from Milton to Cambridge by sustainable transport means. Rectory Farm, is particularly sustainable given that it abuts Milton Park & Ride, which provides for direct and convenient bus access to the City.

5.3 The delivery of major transport schemes along the Waterbeach to Cambridge corridor will further improve the sustainability of Milton, particularly on its western side. The sustainability of Milton will be further enhanced by the additional of 15,000 jobs in north- east Cambridge, which will be very easily accessible by both bike and bus from land at Rectory Farm.

5.4 It is therefore considered that appropriate growth should be provided within the more sustainable, larger villages such as Milton.

6. QUESTION: What housing, jobs, facilities or open spaces do you think should be provided in and around these villages?

6.1 It is important that a range of housing, jobs and facilities are provided within larger villages as part of new allocations to allow them to thrive and remain vibrant. Gonville and Caius College are fully committed, to engagement with the Greater Cambridge Shared Planning Service and Milton Parish Council regarding the mix and type of housing to be delivered land at Rectory Farm.

6.2 The size of the site also means that there is capacity for up to 30,000 m2 of employment floor space included within the site. The College are flexible regarding the type of employment space to be delivered as part of the allocation, in order to meet the extensive demand for job growth along this corridor.

7. QUESTION: Are there any sites which you think should be developed for housing or business use, which we haven’t got on our map so far? Yes, the site at Rectory Farm should be allocated for mixed use development and would be a sound allocation as part of the emerging Local Plan.

7.1 The site was promoted originally at Call for Sites stage for a residential-led mixed use development for 1,500 dwellings and up to 30,000m2 of employment space. This section of the report re-assesses the sites suitability, and demonstrates that it is a suitable location for mixed use development. The site has scored red in the HELAA Assessment in respect of Landscape and Townscape Impact and Strategic Transport Matters. For reasons set out within this section, it is considered that these sections need to be re- scored within the HELAA.

At page 29 of Draft Local Plan the Councils’ set out the proposed development strategy for Greater Cambridge. The Plan states that the top priority is to reduce carbon emissions and to that end provide jobs and homes in close proximity to one another and major public transport routes.
To provide for these new homes in the Plan period, the proposed development strategy for Greater Cambridge is to focus the majority of development on larger scale sites within and around the edge of Cambridge and at new settlements as follows:
•North East Cambridge – redevelopment of the existing waste water treatment works to deliver 8,350 new homes.
•Cambridge East – development of the Marshalls airport site to deliver approximately 7,000 new homes.
•Intensification of Development at North West Cambridge – review of the site wide masterplan to deliver between 1,000 and 1,500 additional new homes.
•Expansion of Cambourne to around 2,000 new homes; and
•Continuing development at the new settlements of Northstowe, Waterbeach and Bourn – but at faster housing delivery rates so that more homes are provided by 2041.
South Cambridgeshire is a rural district council with no large towns, rather, a number of rural centres (classified within the Plan as either rural centres or minor rural centres) together with a distribution of smaller village centres. A soundly based spatial strategy for such a district should therefore primarily seek to strengthen and enhance all these existing rural centres as part of any district-wide or wider Cambridge growth strategy. The submitted spatial strategy however fails to do this as it primarily focuses growth towards strategic sites and new settlements and is therefore completely inflexible.
Paragraph 11(a) of the NPPF states that plans should positively seek opportunities to meet the development needs of their area, and be sufficiently flexible to adapt to rapid change. Miller do not object in principle to the inclusion large strategic sites and new settlement as part of the development strategy. However, it should also be recognised that due to the significant infrastructure requirements and lead in times associated with new settlements and strategic sites, it is critical that a range of smaller and medium sized sites, such as Land off Shelford Road, Fulbourn are brought into the spatial mix of the Plan. Such sites provide the opportunity to deliver more homes earlier in the Plan period and thus complement the longer-term delivery that can be achieved at the larger strategic sites and new settlements.
The need for greater flexibility is particularly important given the unresolved concerns around the deliverability of Cambridge East and North East Cambridge. The Site at Cambridge was identified in the Cambridge Structure Plan (2003) for a new community of 10,000 – 12,000 dwellings. Following the adoption of the Cambridge East AAP in 2008, Marshalls then announced in 2010 that they did not have a deliverable relocation option and that they intended to remain at Cambridge Airport for the foreseeable future, which at the time they confirmed to be not before 2031.
Following the previous consultation on the Local Plan in January 2020, Marshalls then announced in October 2020 that the firm had signed an option agreement for the potential relocation to Cranfield University’s proposed airport development, which was granted outline planning permission by Central Bedfordshire Council in April 2018. The Council anticipate that the site can start delivering housing from 2031. However, the relocation of the airport is a significant undertaking and an ‘option agreement’ in our view, does not provide sufficient justification that the site will be available for the development of housing by 2031.
North East Cambridge is a large brownfield opportunity identified to deliver 8,350 new homes and 15,000 additional jobs. The development is predicated on the relocation of the existing Waste Water Treatment Works, a process being led by Anglian Water. The deliverability of this scheme is therefore very dependent on the outcome of the Development Consent Order proposals for the Cambridge Waste Water Treatment Plant Relocation Project. The project is currently in the pre-application phase for a Development Consent Order (DCO) and it is not anticipated that the application will be submitted till late 2022/early 2023.
Despite the fact that the application for the relocation of the waste water treatment works has not even been submitted, the Councils’ have estimated that from 2026 the site can deliver housing at a rate of 100 dwellings per annum and at its peak deliver 350 dwellings per annum by 2033. In view of the average length of time it takes to achieve a DCO consent is around 2 years from submission and the significant remediation that will be required prior to the construction of housing, we have strong reservations with regards to the draft trajectory set out in the Development Strategy Topic Paper.
Although Miller has no objection to these two sites in principle, there are existing impediments to development which will likely take a considerable amount of time to overcome. On this basis, we would strongly urge the Council to take a more pragmatic approach in relation to the housing land supply over the plan period and provide for a greater mix of sites, specifically smaller and medium sized sites, which can make an important contribution to meeting the housing requirement of an area, and are often built-out relatively quickly.
Notwithstanding our concerns with regards to the deliverability of some of the larger strategic sites, regardless of these larger sites coming forward we do not consider that the development strategy as currently drafted will promote sustainable development in rural areas and maintain the vitality of rural communities. Paragraph 79 of the NPPF states that:
“Planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services.”
Contrary to national planning guidance, the Councils development strategy states at page 39 that their evidence shows that the villages ‘should play only a limited role in meeting future development needs’. Firstly it is not clear what ‘evidence’ the Councils’ are referring to which justifies proposing very little and in many cases no growth in Greater Cambridge’s most sustainable villages. At page 122 the Council state that:
“We want our rural villages to continue to thrive and sustain their local services, but we don’t want to encourage lots of new homes in places where car travel is the easiest or only way to get around. We therefore propose some development in and around villages that have good transport links and services, while in smaller villages, we propose that only small-scale infill development and affordable housing would be permitted.”
Despite having excellent public transport links and dedicated cycle routes into the City Centre and Cambridge Biomedical Campus, including Addenbrooke’s Hospital, the Councils have not proposed any new site allocations around Fulbourn. It is critical that the Councils’ revise their strategy to provide the correct balance of housing. The development of small to medium scale sites can benefit existing communities through the provision of new facilities and green infrastructure that will benefit both new and existing residents. As currently drafted the development strategy is not responsive to the local circumstances of its rural areas and as such is considered inconsistent with national planning policy and ‘unsound’.

At page 29 of Draft Local Plan the Councils’ set out the proposed development strategy for Greater Cambridge. The Plan states that the top priority is to reduce carbon emissions and to that end provide jobs and homes in close proximity to one another and major public transport routes.
To provide for these new homes in the Plan period, the proposed development strategy for Greater Cambridge is to focus the majority of development on larger scale sites within and around the edge of Cambridge and at new settlements as follows:
•North East Cambridge – redevelopment of the existing waste water treatment works to deliver 8,350 new homes.
•Cambridge East – development of the Marshalls airport site to deliver approximately 7,000 new homes.
•Intensification of Development at North West Cambridge – review of the site wide masterplan to deliver between 1,000 and 1,500 additional new homes.
•Expansion of Cambourne to around 2,000 new homes; and
•Continuing development at the new settlements of Northstowe, Waterbeach and Bourn – but at faster housing delivery rates so that more homes are provided by 2041.
South Cambridgeshire is a rural district council with no large towns, rather, a number of rural centres (classified within the Plan as either rural centres or minor rural centres) together with a distribution of smaller village centres. A soundly based spatial strategy for such a district should therefore primarily seek to strengthen and enhance all these existing rural centres as part of any district-wide or wider Cambridge growth strategy. The submitted spatial strategy however fails to do this as it primarily focuses growth towards strategic sites and new settlements and is therefore completely inflexible.
Paragraph 11(a) of the NPPF states that plans should positively seek opportunities to meet the development needs of their area, and be sufficiently flexible to adapt to rapid change. Miller do not object in principle to the inclusion large strategic sites and new settlement as part of the development strategy. However, it should also be recognised that due to the significant infrastructure requirements and lead in times associated with new settlements and strategic sites, it is critical that a range of smaller and medium sized sites, such as Land south of Cambridge Road, Melbourn are brought into the spatial mix of the Plan. Such sites provide the opportunity to deliver more homes earlier in the Plan period and thus complement the longer-term delivery that can be achieved at the larger strategic sites and new settlements.
The need for greater flexibility is particularly important given the unresolved concerns around the deliverability of Cambridge East and North East Cambridge. The Site at Cambridge was identified in the Cambridge Structure Plan (2003) for a new community of 10,000 – 12,000 dwellings. Following the adoption of the Cambridge East AAP in 2008, Marshalls then announced in 2010 that they did not have a deliverable relocation option and that they intended to remain at Cambridge Airport for the foreseeable future, which at the time they confirmed to be not before 2031.
Following the previous consultation on the Local Plan in January 2020, Marshalls then announced in October 2020 that the firm had signed an option agreement for the potential relocation to Cranfield University’s proposed airport development, which was granted outline planning permission by Central Bedfordshire Council in April 2018. The Council anticipate that the site can start delivering housing from 2031. However, the relocation of the airport is a significant undertaking and an ‘option agreement’ in our view, does not provide sufficient justification that the site will be available for the development of housing by 2031.
North East Cambridge is a large brownfield opportunity identified to deliver 8,350 new homes and 15,000 additional jobs. The development is predicated on the relocation of the existing Waste Water Treatment Works, a process being led by Anglian Water. The deliverability of this scheme is therefore very dependent on the outcome of the Development Consent Order proposals for the Cambridge Waste Water Treatment Plant Relocation Project. The project is currently in the pre-application phase for a Development Consent Order (DCO) and it is not anticipated that the application will be submitted till late 2022/early 2023.
Despite the fact that the application for the relocation of the waste water treatment works has not even been submitted, the Councils’ have estimated that from 2026 the site can deliver housing at a rate of 100 dwellings per annum and at its peak deliver 350 dwellings per annum by 2033. In view of the average length of time it takes to achieve a DCO consent is around 2 years from submission and the significant remediation that will be required prior to the construction of housing, we have strong reservations with regards to the draft trajectory set out in the Development Strategy Topic Paper.
Although Miller has no objection to these two sites in principle, there are existing impediments to development which will likely take a considerable amount of time to overcome. On this basis, we would strongly urge the Council to take a more pragmatic approach in relation to the housing land supply over the plan period and provide for a greater mix of sites, specifically smaller and medium sized sites, which can make an important contribution to meeting the housing requirement of an area, and are often built-out relatively quickly.
Notwithstanding our concerns with regards to the deliverability of some of the larger strategic sites, regardless of these larger sites coming forward we do not consider that the development strategy as currently drafted will promote sustainable development in rural areas and maintain the vitality of rural communities. Paragraph 79 of the NPPF states that:
“Planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services.”
Contrary to national planning guidance, the Councils development strategy states at page 39 that their evidence shows that the villages ‘should play only a limited role in meeting future development needs’. Firstly it is not clear what ‘evidence’ the Councils’ are referring to which justifies proposing very little and in many cases no growth in Greater Cambridge’s most sustainable villages. At page 122 the Council state that:
“We want our rural villages to continue to thrive and sustain their local services, but we don’t want to encourage lots of new homes in places where car travel is the easiest or only way to get around. We therefore propose some development in and around villages that have good transport links and services, while in smaller villages, we propose that only small-scale infill development and affordable housing would be permitted.”
Despite having excellent public transport links and a good range of services, the development strategy as currently drafted proposes relatively limited growth around Melbourn. It is critical that the Councils’ revise their strategy to provide the correct balance of housing. The development of small to medium scale sites can benefit existing communities through the provision of new facilities and green infrastructure that will benefit both new and existing residents. As currently drafted the development strategy is not responsive to the local circumstances of its rural areas and as such is considered inconsistent with national planning policy and ‘unsound’.

I am writing to object to the Draft Local Plan on the grounds
1) There is an insufficient water supply for the number of dwellings proposed. The Government has allocated a large sum of money to protect the rare chalk streams that are found in this area. The fact is that the only way to give proper protection to our chalk streams is to stop excessive extraction of water from the underground waters that supply the streams and us with water.

2) Do NOT move the sewerage works. These works were upgraded in 2015 and are capable of further upgrading on the present site. To move them would cost at least £227 million of taxpayers money: would take local green belt land out of food production and release vast quantities of carbon into the atmosphere in contravention of the Government’s own stated aim of reducing carbon emissions.
We need local food production to ensure food security.

IF it ain’t broke don’t fix it!!!

3) The consultation process has been undemocratic.
The promise of the discovery centre is is like offering sweets to children. It is blatant bribery.