Greater Cambridge Local Plan Preferred Options

Climate change – development issues
40. CPRE largely supports Policy CC/NZ: Net zero carbon new buildings. However, to be effective it needs to be
taken in conjunction with three further policies which we have not discovered in the draft Local Plan,
namely:
• a ‘brownfield first’ policy for new building
• a policy to minimise the number of new buildings and developments in the Greater Cambridge
region
• a policy to halt the use of scarce farm land for solar energy generation and instead ensure that solar
installations are mandated on all industrial buildings, new and existing. Policy CC/RE: Renewable
energy projects and infrastructure, is totally ineffective in this respect.
41. The draft Local Plan is not consistent with national government policy because it does not follow a
'brownfield first' approach. It is also concerning that the Plan is seeking to build more houses in the
Cambridge area than required by current planning legislation and the ‘five-year land supply’.
42. As stated above, the Plan assumes the development of the Ox-Cam Arc, which is leading to more greenfield
building which maximises carbon emissions. The Local Plan should not be accepting the Arc, instead the
local planning authorities should be firmly resisting this outdated idea of ‘clustering’ of science-based
businesses. These businesses operate globally, increasingly using the internet to minimise business travel
and they can operate anywhere. The development of vaccines during the pandemic has proved the
effectiveness of remote collaborative working on a global scale.
43. Rather than encouraging further building on precious high grade farm land around Cambridge all
responsible local organisations involved in planning, including the University and businesses, should be
encouraging and enabling redevelopments in other regions, where there are up to 1 million empty homes
and space for 1.3 million more on registered brownfield sites.
44. Embedded carbon emissions arising from construction appear to be ignored in the Plan. Cement
manufacture contributes 8% of global carbon emissions which is more than three times the impact of
aviation fuel. Iron and steel production accounts for another 8%. Between them they account for more
emissions than the USA and are second only to China as greenhouse gas emitters.
45. According to the recent Cambridge and Peterborough Climate Commission report, at the present rate the
Region will have used up its entire carbon budget, allocated to meet its legal obligation to reach zero carbon
by 2050, in less than six years; due to the level of planned growth, emissions will accelerate further.
46. The Climate Change Committee, led by Lord Deben, has argued in its 2018, 2019 and 2020 Annual Reports
to Parliament that UK local and imported emissions arising from construction, must be reduced if the UK is
to meet its now legal emission targets. Yet this Plan is seeking to increase construction.
47. Large areas of some ‘brownfield’ sites, such as old airfields like Oakington, Waterbeach and Bourn, are not
brownfield at all. Only their disused runways, hard-standing and associated buildings are brownfield and
most of their area is already turned back to use as productive farmland. It is unacceptable that local
planning authorities are blindly ignoring this fact.
48. All unsustainable growth must be halted as a matter of global and national emergency, yet the level of
building and infrastructure growth contained in the draft Local Plan breaches all obligations for sustainable
development other than those arising from future operation.
49. Policy CC/DC: Designing for a changing climate, is closing the stable door after the horse has bolted.

Climate change – development issues
40. CPRE largely supports Policy CC/NZ: Net zero carbon new buildings. However, to be effective it needs to be
taken in conjunction with three further policies which we have not discovered in the draft Local Plan,
namely:
• a ‘brownfield first’ policy for new building
• a policy to minimise the number of new buildings and developments in the Greater Cambridge
region
• a policy to halt the use of scarce farm land for solar energy generation and instead ensure that solar
installations are mandated on all industrial buildings, new and existing. Policy CC/RE: Renewable
energy projects and infrastructure, is totally ineffective in this respect.
41. The draft Local Plan is not consistent with national government policy because it does not follow a
'brownfield first' approach. It is also concerning that the Plan is seeking to build more houses in the
Cambridge area than required by current planning legislation and the ‘five-year land supply’.
42. As stated above, the Plan assumes the development of the Ox-Cam Arc, which is leading to more greenfield
building which maximises carbon emissions. The Local Plan should not be accepting the Arc, instead the
local planning authorities should be firmly resisting this outdated idea of ‘clustering’ of science-based
businesses. These businesses operate globally, increasingly using the internet to minimise business travel
and they can operate anywhere. The development of vaccines during the pandemic has proved the
effectiveness of remote collaborative working on a global scale.
43. Rather than encouraging further building on precious high grade farm land around Cambridge all
responsible local organisations involved in planning, including the University and businesses, should be
encouraging and enabling redevelopments in other regions, where there are up to 1 million empty homes
and space for 1.3 million more on registered brownfield sites.
44. Embedded carbon emissions arising from construction appear to be ignored in the Plan. Cement
manufacture contributes 8% of global carbon emissions which is more than three times the impact of
aviation fuel. Iron and steel production accounts for another 8%. Between them they account for more
emissions than the USA and are second only to China as greenhouse gas emitters.
45. According to the recent Cambridge and Peterborough Climate Commission report, at the present rate the
Region will have used up its entire carbon budget, allocated to meet its legal obligation to reach zero carbon
by 2050, in less than six years; due to the level of planned growth, emissions will accelerate further.
46. The Climate Change Committee, led by Lord Deben, has argued in its 2018, 2019 and 2020 Annual Reports
to Parliament that UK local and imported emissions arising from construction, must be reduced if the UK is
to meet its now legal emission targets. Yet this Plan is seeking to increase construction.
47. Large areas of some ‘brownfield’ sites, such as old airfields like Oakington, Waterbeach and Bourn, are not
brownfield at all. Only their disused runways, hard-standing and associated buildings are brownfield and
most of their area is already turned back to use as productive farmland. It is unacceptable that local
planning authorities are blindly ignoring this fact.
48. All unsustainable growth must be halted as a matter of global and national emergency, yet the level of
building and infrastructure growth contained in the draft Local Plan breaches all obligations for sustainable
development other than those arising from future operation.
49. Policy CC/DC: Designing for a changing climate, is closing the stable door after the horse has bolted.

Climate change – water supply issues
50. Policy CC/WE: Water efficiency in new developments, is not going to solve the potable water crisis
affecting Cambridgeshire, a crisis which is only likely to deepen if the report written by Stantec for the
Shared Planning Service is ignored.
51. The Environment Agency document titled “Water stressed areas – final classification 2021”, published in
July 2021 by DEFRA, 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 of this document, 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 2021.
52. Anglian Water’s proposed solution to this problem, pumping water from North Lincolnshire, appears
completely impracticable because the Environment Agency, in the same report, has also classified North
Lincolnshire as an area of serious water stress.
53. Another solution being considered by Anglian Water, according to Water Resources East, is to build two
reservoirs in the Fens. However, this idea seems to completely ignore the fact of sea level rise which will
likely cause much, if not all, of the Fens to be flooded by seawater within decades.

Climate change – flooding issues
54. CPRE finds Policy CC/FM: Flooding and integrated water management to be totally inadequate in the face
of the increasing flood risks arising in the county, the greatest of which is the likely loss of a high
percentage of the Fens to flooding within decades, as referred to above.
55. The river Great Ouse is tidal up to Brownshill Staunch between Earith and St Ives. This means that areas
such as Cottenham Lode, which extends to the A14 and the edge of Cambridge, are at future high risk of
tidal flooding as well as the fluvial flooding experienced in winter 2020/21 in places such as Cottenham, St
Ives and St Neots. There is also increasingly high risk of flash flooding in these low-lying areas due to the
increased intensity of rainfall arising from climate change. Such flooding was experienced in several areas
of the county, including Peterborough, during 2021.
56. The inexorable and increased rate of sea level rise means that the Fens will initially be subject to occasional
and then annual flooding. The annual flood risk will be increased by the additional volume of run-off from
development coming downstream. Eventually, the tidal inflow will cause permanent flooding and large
areas of the Fens will be returned to saltmarsh. However, even the first stage of annual flooding will have a
significant negative effect on agriculture and national food supply. It was found after the 1947 and 1953
floods that crop yields were reduced for seven years due to the presence of a nematode in seawater.
57. To illustrate this situation numerically, the Environment Agency has been measuring sea level (AOD) in the
Wash for many years. It was rising at a rate of 3 mm per year. In 2019 it was agreed that measurements by
the Environment Agency and by IPCC indicated that the annual rate of sea level rise had increased to 3.3
mm per year. The IPCC2014 report predicted global sea level rise of 1 metre by 2100. The IPCC2019 report
predicted sea level rise of 1.1 metres by 2100. In 2021, IPCC increased its estimate again to 2.4 metres by
2100. Climate Central estimates sea level rise of 4.7 metre by 2100 if global temperatures rise by 2°C.
Worryingly, in 2021 both the IPCC and the COP26 leadership have confirmed that the world can expect a
2.4°C global temperature rise.
58. Evidence shows that any increase in artificial surfaces, such as buildings and roads, leads to a decrease in
water in the environment. Development also leads to a decrease in the amount of land that can absorb
rainwater and recharge water bodies. According to the Royal Horticultural Society, 70% of ponds have been
8
lost from the UK countryside since 1970. The River Cam has lost on average half its flow. In 2019, the River
Granta dried up completely. Freshwater biodiversity populations have declined by 84%.
59. By continuing to build on the scale planned, Cambridgeshire is sowing the seeds of its own destruction.
Firstly, it is creating avoidable carbon emissions which will contribute to global temperature rise. Secondly,
that temperature rise will cause large parts of the county to flood permanently. Thirdly, the additional runoff from development will increase the risk of flooding and bring forward the date of permanent flooding of
large parts of the county. This issue must be taken far more seriously than the token gesture of Policy
CC/FM

Climate change – reducing waste and supporting the circular economy
60. While CPRE supports and positively encourages the principle of reducing waste and supporting the circular
economy, it deems Policy CC/CE far too weak. Worse, the draft Local Plan is not in accordance with the
first principles quoted in this policy: “construction waste will be addressed following the waste hierarchy
and the 5 r’s of waste management: Refuse, Reduce, Reuse, Repurpose, Recycle.”
61. All unnecessary construction should be Refused and all construction Reduced. This includes the excessive
building across South Cambridgeshire proposed by the draft Plan.
62. Existing constructions should be Reused, Repurposed or Recycled. This applies not just within the
Cambridge region but right across the country with Cambridgeshire doing whatever it can to encourage the
reusing, repurposing and recycling of the nearly 1 million empty homes in the UK and the recycling of the
1.3 million brownfield sites across the UK before permitting further greenfield construction around
Cambridge.
63. These principles apply to construction as a whole, not just to construction waste. Their proper application
will have a major effect in reducing greenhouse gas emissions.

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

Biodiversity and green spaces
66. The stated aim “Increase and improve our network of habitats for wildlife, and green spaces for people,
ensuring that development leaves the natural environment better than it was before.” clearly demonstrates
that this draft Local Plan is adopting a green-washing approach to bio-diversity.
67. Except in the case of some brownfield sites which can be restored, or existing sites where greenspace can
be improved, development will always damage the natural environment. Even the supply of building
materials will likely damage the natural environment elsewhere, whether obtained locally, nationally or
internationally.
68. The best possible treatment for the natural environment is to leave it undeveloped and in its natural state.
There are steps that can be taken to improve the biodiversity of unbuilt land with appropriate planting and
management. These are steps which should be encouraged.
The next few sub-paragraphs are taken from the submission of The Friends of the Cam and are statements
which CPRE fully supports and has signed up to:
a. Concepts such as Natural Cambridgeshire’s 'Doubling Nature' ambition, Biodiversity Net Gain (BNG)
and Natural Capital Accounting (NCA) are being used as bargaining chips in the developers' casino
that broadly amounts to saying 'no development means no funding for nature'. This is the antithesis
9
of John Lawton's 2010 plea in 'Making Space for Nature' of significant funding for Nature
conservation without any strings attached.
b. 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.
c. 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.
d. 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.
e. 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.
f. 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).
g. 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.
h. 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.
69. CPRE repeats the request made in paragraph h) above.
70. CPRE are disappointed that we can find very little mention of hedgerows in this part of the plan or
elsewhere. Hedgerows are significant contributors to bio-diversity, as was demonstrated by the work of Dr
Norman Moore. In addition, hedgerows are more effective carbon sequestrators per unit area than tree
plantations, certainly in the first ten years of growth if not longer. With six to seven tree plants per metre in
a hedge, it stands to reason they will be most effective carbon sinks.

Great places policies
71. CPRE supports the principles expressed in this section and its accompanying policies. Indeed, we are
pleased to see expressed the established local purposes of the Cambridge Green Belt, which are to:
• preserve the unique character of Cambridge as a compact, dynamic city with a thriving historic
centre
• maintain and enhance the quality of its setting
• prevent communities in the environs of Cambridge from merging into one another and with the
city.
72. However, CPRE does not believe that the draft Local Plan is adhering to these principles, particularly in the
case of proposals to remove several sites from the Green Belt.
73. We are also concerned that some of the developments that have already occurred around Cambridge are
visually intrusive and, in some cases, aesthetically unappealing. We would not want to see these mistakes
repeated.

Great places policies
71. CPRE supports the principles expressed in this section and its accompanying policies. Indeed, we are
pleased to see expressed the established local purposes of the Cambridge Green Belt, which are to:
• preserve the unique character of Cambridge as a compact, dynamic city with a thriving historic
centre
• maintain and enhance the quality of its setting
• prevent communities in the environs of Cambridge from merging into one another and with the
city.
72. However, CPRE does not believe that the draft Local Plan is adhering to these principles, particularly in the
case of proposals to remove several sites from the Green Belt.
73. We are also concerned that some of the developments that have already occurred around Cambridge are
visually intrusive and, in some cases, aesthetically unappealing. We would not want to see these mistakes
repeated.

Jobs policies
74. It is clear that the draft Local Plan is focused on the continuation of ‘growth’ in the Cambridge area. CPRE
believes this is a mis-guided approach. The Greater Cambridge area is one which DHSS would consider to
have effectively full employment, with just the usual rotation of people out of work or seeking work.
Therefore, any growth in jobs will require inward migration to fill them. Inward migration creates pressure
on local housing availability and prices, and hence pressure for more house-building. It is an anti-climate
cycle.
75. As stated above CPRE would like to see the skills and resources of Cambridge-based organisations used to
encourage employment and redevelopment in other regions of the country where housing and water
capacity already exist and, in doing so, greenhouse gas emissions would be minimised.
76. CPRE are concerned by policies J/RE: Supporting the rural economy and J/AL: Protecting the best
agricultural land. We think both of these policies should be strengthened and properly enforced. The rural
economy can be diversified but at its core are farmers and their interests must be protected. For example,
the opening up of tracks and bridleways on the scale proposed by the Greater Cambridge Partnership will
cause increasing levels of damage to farms and farm equipment and increased security risk to farm
properties. It will make illegal activities such as hare-coursing easier and the police enforcement job
harder.
77. We think it is in the national interest to stop building on South Cambridgeshire farm land, most of which is
Grade 2 with some Grade 3a. http://publications.naturalengland.org.uk/publication/127056 This land is already needed to assist the minimisation of food imports and it will be even more needed when the Fens
flood and national food supply is reduced by an estimated 20 – 25%.
78. According to the NFU, the Fens produce one third of England’s fresh vegetables, 20% of England’s potatoes,
more than 20% of England’s flowers and bulbs, 20% of England’s sugar beet as well as a significant
percentage of the country’s cereal, oilseed rape and protein crops. Agriculture in the Fens employs 80,000
people and produces £3bn pa for the rural economy.
79. The government recognises that the UK currently imports 45% of its food; however, some sources estimate
this to be as much as 80%. The Environmental Audit Committee has already warned government that the
UK cannot continue to rely on food imports on this scale because climate change is going to damage foodgrowing areas further south.
80. Building on good Cambridgeshire farm land just does not make sense. There may be short-term economic
pressures to do so but it is not in the national interest.
81. CPRE supports Policy J/PB: Protecting existing business space and Policy J/RW: Enabling remote working.
We also recognise that local affordable workspace can reduce commuting and increase local employment
opportunities, Policy J/AW: Affordable workspace and creative industries. We are concerned to ensure
that existing buildings which could be used for employment are not demolished to make way for maximum levels of housing and maximum profit for developers as we are aware has occurred in some districts.
82. With respect to Policy J/RC: Retail and centres, CPRE are aware of increasing levels of internet shopping
and decreasing footfall in retail centres. This may lead to re-purposing for housing under “Permitted
Development”. CPRE is believes that all such development should be brought back under local authority building control and not be the appalling low-quality free-for-all that it is now.