Chapter 4: Consultation and Next Steps

Comment

Representation ID: 50055

Received: 24/02/2020

Respondent: John Preston

The Sustainability Appraisal and Scoping Report are inadequate in terms of both process and content.
While the Scoping Report notes (1.15 “Baseline Information”) that “It is a requirement of the Strategic Environmental Assessment process that consideration should be given to the current state of the environment”, there is little recognition of current environmental capacity issues (apart from “over-abstraction of water in this region is a key issue”) and constraints, and no evaluation of successes or failures of the current Local Plans.
The Sustainability Appraisal considers each of the required SA categories separately. It does not consider cumulative and synergistic significant effects on the environment as required by schedule 2 of the SEA Regulations. This oversight has left severe current and future environmental capacity issues affecting Greater Cambridge as a whole, and the Local Plan as a whole, out of Sustainability Appraisal consideration.

But the cumulative impacts of recent and currently approved growth, including related transport proposals, are key issues for the SA and Scoping Report. How can further additional growth be accommodated if that already in the pipeline is unresolved? These impacts are neither assessed nor taken into account in the SA. Baseline information as required by the SEA should include assessments of key existing unmet demands (including, e.g., city centre cycle parking) and of demands arising from current transport proposals (Busways and Greenways). The capacity of both the historic city centre and historic green spaces to accommodate these and other existing demands needs to be assessed.

The SA then has to assess the additional and cumulative impacts of this growth already in the system, in combination with the quantum of growth agreed under the Devolution deal , plus further external (Government, Ox-Cam Arc) and internally generated (Universities, Cambridge Ahead, etc) growth pressures. It has done none of these.

The consequence is that SA has failed to test the draft Issues and Options in relation to a fundamental issue: the environmental and physical capacity limits to the growth of Greater Cambridge. This should be a key Theme of the Issues and Options (and should have already been identified as such).

The SA has also failed to identify, or test, the draft Issues and Options in relation to a second, related key issue: how to manage the conflicting imperatives of economic growth and the preservation and enhancement of the historic city of Cambridge in its historic landscape setting?

The SA and Scoping Report note that all the Options will have negative effects on the historic environment, but without identifying or prioritising issues. There is inadequate recognition of Cambridge’s national and international significance as a historic city and “one of the loveliest cities in Western Europe” (David Attenborough). They do not mention that Cambridge meets at least 3 of the Outstanding Universal Value criteria (i, ii, iv) for World Heritage Site status, or suggest its historic environment should be valued accordingly. It is this level of international cultural and historic significance, expressed in the beauty of the historic city, which attracts students, workers, and visitors from all over the world. In this context historic Cambridge includes its whole associated landscape, including the upper Cam as far as Byron’s Pool and the lower Cam along the length of the Lents and Mays course as far as Baits Bite. The lower Cam section, although fully covered by Conservation Area designations, has been threatened by growth-related transport proposals; so have the West Fields. The arguably even more significant cultural landscape between Cambridge and Grantchester and beyond has no formal protection, with the Grantchester Conservation Area boundary narrowly drawn and no Appraisal. While Grantchester Meadows are owned by Kings’ College, this ownership neither provides direct protection from developments beyond their boundary, nor has any force in planning terms. The need for such protection is highlighted by the impacts on the Meadows of the combined height and bulk of the CB1 development.

This outstanding significance of Cambridge’s historic environment is at high risk from growth pressures.

Cambridge’s historic environment is also threatened by Climate Change challenges (including mitigation and adaptation) and Government targets for meeting them. These are also high risk factors for Cambridge’s historic environment, with difficult choices to be made. A baseline assessment of the implications for Greater Cambridge of current Government retrofit targets is urgently needed.

These issues should be identified and prioritised in both baseline information and the key Themes.

Comment

Representation ID: 50214

Received: 24/02/2020

Respondent: Campaign to Protect Rural England (CPRE)

The Town Hall, Market Hill, The Old Riverport, St Ives, Cambs. PE27 5AL
01480 396698 www.cprecambs.org.uk
Registered charity number 242809
Responses To Consultation.
Greater Cambridge Local Plan Habitats Regulations Assessment Scoping Report
1. CPRE finds the Habitats Regulations Assessment Scoping Report to be comprehensive and clear.
2. Statutory Habitats Regulations Assessment is limited to impact upon wildlife sites of international designation and importance and these appear to have been correctly identified in the Scoping Report.
3. However, Cambridgeshire contains many important and complementary wildlife sites with national designations. For example the Berry Fen SSSI near Earith which is used by species from the Ouse Washes RAMSAR site.
For a full list of SSSIs in Cambridgeshire, see below:
• Alder Carr
• Aversley Wood
• Balsham Wood
• Barnack Hills & Holes
• Bassenhally Pit
• Bedford Purlieus
• Berry Fen
• Bonemills Hollow
• Brackland Rough
• Brampton Meadow
• Brampton Racecourse
• Brampton Wood
• Buff Wood
• Caldecote Meadows
• Cam Washes
• Carlton Wood
• Castor Flood Meadows
• Castor Hanglands
• Cherry Hinton Pit
• Chettisham Meadow
• Chippenham Fen and Snailwell Poor's Fen
• Delph Bridge Drain
• Dernford Fen
• Devil's Dyke
• Dogsthorpe Star Pit
• Elsworth Wood
• Ely Pits and Meadows
• Eversden and Wimpole Woods
• Fleam Dyke
• Fowlmere Watercress Beds
• Fulbourn Fen
• Furze Hill
• Gamlingay Wood
• Godmanchester Eastside Common
• Gog Magog Golf Course
• Grafham Water
• Great Stukeley Railway Cutting
• Great Wilbraham Common
• Hardwick Wood
• Hayley Wood
• Hemingford Grey Meadow
• Hildersham Wood
• Holland Hall (Melbourn) Railway Cutting
• Holme Fen
• Houghton Meadows
• Kingston Wood and Outliers
• L-Moor, Shepreth
• Langley Wood
• Little Catworth Meadow
• Little Paxton Pits
• Little Paxton Wood
• Madingley Wood
• Monks Wood and The Odd Quarter
• Nene Washes
• Orton Pit
• Orwell Clunch Pit
• Ouse Washes
• Out and Plunder Woods
• Overhall Grove
• Papworth Wood
• Park Wood
• Perry Woods
• Portholme
• Roman Road
• Sawston Hall Meadows
• Snailwell Meadows
• Soham Wet Horse Fen
• Southorpe Meadow
• Southorpe Paddock
• Southorpe Roughs
• St Neots Common
• Stow-Cum-Quy Fen
• Sutton Heath and Bog
• Ten Wood
• Thriplow Meadows
• Thriplow Peat Holes
• Upware North Pit
• Upwood Meadows
• Wansford Pasture
• Warboys and Wistow Woods
• Waresley Wood
• Weaveley and Sand Woods
• West, Abbot's and Lound Woods
• Whitewater Valley
• Whittlesford - Thriplow Hummocky Fields
• Wicken Fen
• Wilbraham Fens
• Woodwalton Fen
• Woodwalton Marsh
• Adventurers' Land
• Barrington Chalk Pit
• Barrington Pit
• Ely Pits and Meadows
• Eye Gravel Pit
• Histon Road
• Shippea Hill
• Traveller's Rest Pit
• Upware Bridge Pit North
• Upware South Pit
• Warboys Clay Pit
4. Cambridgeshire contains 51 City Wildlife Sites and 368 County Wildlife Sites. Many of these locally designated sites are significant for protection of rare and endangered species. Full details of these locally designated sites can be obtained from the County Council web site: https://www.cambridgeshire.gov.uk/residents/libraries-leisure-culture/arts-green-spaces-activities/nature-conservation-sites
5. Whilst CPRE fully understands that these sites will not be considered by a statutory HRA Assessment, we do consider that a list of those which are likely to be affected by the GCP Local Plan should be constructed and the potential effects upon them should be assessed by a competent body such as part of the next stage of the Local Plan process.
6. CPRE is very aware of the positive effects upon wildlife (and residents) of dark skies and tranquility. Note CPRE’s national Tranquility Resources at https://www.cpre.org.uk/resources/tranquility-map-england/ . We consider that the negative effects of the proposed GCP Local Plan on both tranquility and dark skies should be considered in both the statutory HRA and national/local wildlife site risk assessment.
7. Although not a statutory requirement, CPRE considers that any impacts on the proposed UNESCO designation of the Fens Biosphere https://fenlandbiosphere.wordpress.com/the-fenland-biosphere-journey/ should also be considered as part of the HRA process.
8. Habitat assessors should avail themselves with information from the Cambridgeshire and Peterborough Environmental Records Office to help them to ensure comprehensive studies are undertaken.
9. The effects of proposed businesses, schools, shops etc. on strategic habitats should also be considered. Current practice is to focus assessment on the number of dwellings.