Greater Cambridge Local Plan Preferred Options

We strongly object to the new draft Local Plan for the following reasons: our inadequate water supply, it fails to minimize climate change, it has a detrimental effect on national food security and on ecosystems. It will lead to high levels of carbon emissions from construction and the manufacture of construction materials. In addition, there is a lack of an integrated transport system, it undermines the Government policy of `leveling up’ and there is a lack of democracy in the process behind this plan and in its evidence base. We believe that the following factors will be exacerbated or caused by the high levels of development you propose. Locally we feel that certain provisos need to be added to Babraham Institute being released from the Green Belt which have not been adequately addressed in the plan.
Over-development The report “How Many Homes” by CPRE Devon, demonstrates how the ONS population projections are seriously flawed and that this is leading to over estimation of housing need in all areas of the country. Using the government’s methodology, the study demonstrates that the housing need is around 213,000 additional houses per year. The government’s target is 300,000 – a 40% overstatement. See CPRE Devon website.
https://www.cpredevon.org.uk/the-government-wants-to-build-more-than-3million-new-homes-than-are-needed/
We were dismayed at the GCP proposed levels of development so it is disturbing that our District and City councils are proposing to bring forward housing developments and build a further approximately 49,000 houses. MP Anthony Browne carried out a survey regarding the proposed developments related to the Ox-Cam Arc in South Cambs and found that a very high proportion of residents did not want further housing developments in this area and we can assume that they will also oppose the developments you propose.
The Cambridge Greenbelt is continually under attack and has already been nibbled away by the weakened Local Plan process which placed protection of the greenbelt into the hands of local planning authorities and not the Secretary of State. The Greenbelt of South Cambs will be further eroded by your proposed Local Plan eg. locally the Mingle Lane proposed development. Cambridge Greenbelt has two purposes, to stop urban sprawl and to protect the setting of the City. Further major developments around it will put the Greenbelt under even greater pressure because of the major damage being done to the essentially rural landscapes beyond the Greenbelt.
The Cambridge area has a very high level of employment so it’s not as if we need more businesses, and hence housing developments, coming to this area. We have a historical and beautiful City surrounded by picturesque villages and wonderful countryside which you should be protecting and not planning to blight with housing developments.

Inadequate water supply.
There is a lack of sustainable water supply in Cambridgeshire and the levels of development you propose will severely exacerbate this situation. The Stantec Integrated Water Management Study to the GCP showed that only the lowest level of housing provision around Cambridge was possible. This is even re-iterated in Objective 10 of your own Greater Cambridge Local Plan, Strategic Spatial Options Assessment Sustainability Appraisal (November 2020). Objective 10 Page 96 onwards, Section 3.333 especially.
https://www.greatercambridgeplanning.org/media/1393/gclp-strategic-spatial-options-assessment-sustainability-appraisal-nov2020.pdf
Any further development would put even more strain on what is already an unsustainable situation. Plans to route water from areas further north have been shown by the CPRE to be both expensive and unable to meet even GCP levels of growth and housing let alone the additional levels proposed by this plan. Indeed North Lincolnshire, one of the proposed areas to route water from, the Environment Agency has now classed as a `water stressed area.’
On 1st July, 2021 DEFRA in “Water stressed areas – final classification 2021” stated that chalk streams would be given enhanced environmental protection. On page 6 of this document it states that the supply areas of Cambridge Water and Anglian Water were areas of serious water stress. It stated that Cambridge Water needed to reduce levels of abstraction by 22 megalitres per day from levels on1st July, 2021 and Anglian Water needed to reduce abstraction levels by 189 megalitres from the same date.
In August 2020, the Environment Agency, in response to a query regarding the viability of the Northstowe Phase 3A development, replied to Ms. Hone that `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…many waterbodies did not have the flow to support the ecology.’
In short, the development proposed in this Local Plan would damage our rivers, chalk streams, our ecology and our farming because we simply do not have sufficient water supplies at present, a point a previous Local Plan had made. Water supplies certainly will not support the proposed level of development and piping it in from an area that is also Water Stressed makes no sense.
Inadequate sewerage infrastructure The draft Local Plan will lead to new building when the local sewerage system is currently inadequate. This is evidenced by the reported number of sewerage spills by Anglian Water into the Cam Valley; upstream of Cambridge saw 622 hours of untreated sewerage enter the rivers in 2020. There are currently no plans to improve the sewerage system to prevent these outflows, just to monitor them more adequately. To date there have been no upgrades at small sewerage work in the area. The only work in this area is to move the one major sewerage works in the area (at Waterbeach) one that has been future proofed until 2050, to land prone to flooding at huge expense to prevent it from flooding and subsequent pollution of the area, in order to make way for a housing development. If it was to make way for a larger sewerage works this would have been sensible and might have prevented the outflow of untreated sewerage into the delicate ecosystems of our rivers.
In short, our sewerage system is inadequate and further development will put additional strain on it, increasing the risk of sewerage outflows into rivers.


Threat to National Food Security
Any further development around Cambridge, will necessarily take scarce grade 2 and 3a land out of production. Developments in Fen land will deprive us of grade 1 agricultural land. Grade 1 designation is reserved almost solely for the peat-based soils of the drained fens. Your proposed developments around the Waterbeach area are therefore thought to be very unwise. This land is already needed for food production in a country which imports c. 60% of its food supply. Nationally, we do not have food security According to the NFU, the Fens produce one third of England’s fresh vegetables; 20% of our potatoes, over 20% of our flowers and bulbs, 20% of our sugar beet as well as a large percentage of our cereal crops. Agriculture employs 80,000 people and produces £3bn pa for the rural economy.
Farmers can only produce food when they have sufficient water, which we currently don’t have, when land is protected for food security and is not covered in solar panels, housing or business developments. Inward migration to Cambridgeshire will lead to the loss of high and the best quality agricultural land due to building. The increased water usage of those coming to the region is put at about a further 16 megalitres of water a day (based on the additional 49,000 houses proposed hence about 100,000 additional people). This is when we are already in dire need of additional water supplies.
Due to climate change there is an anticipated sea level rise of at least 1.1 metre by 2100 (IPCC 2019) and possibly up to 4.7 metres (Surging Seas) in the Wash and hence the Rivers Great Ouse and Cam. This is likely to lead to the permanent loss of much of the UK food supply as the Fens will become frequently and, eventually permanently flooded. Grade 2 and 3a land is therefore an increasingly valuable national asset which must be protected and whose protection is already documented in the NPPF paragraph 170. Such land exists in an arc around the Fens, much of it around Cambridge.
There is the suggestion of building reservoirs in the Fens to supply water for the proposed increase in population in this part of the county. However, there is little point in building reservoirs in the Fens when it is clear they will be flooded by saline water within decades.
In short, we have to protect this valuable agricultural land from over-development as climate change is likely to decrease its availability and pose a threat to our food security.

Damage to ecosystems The Cambridgeshire countryside, despite intensive farming, is a wildlife-rich area. The Greater Cambridge proposed Local Plan supports a high level of business and housing developments and makes statements suggesting that development will help nature to thrive when evidence shows that the increase in artificial surfaces leads to a decrease in water in the environment and in the amount of land that can absorb rainwater and recharge bodies of water. The river Cam has lost half its flow since the 70s and in 2019 the river Granta completely dried up. Partly as a consequence, freshwater biodiversity populations have declined by 84% (Friends of the Cam).
Concepts such as `doubling nature’, Biodiversity Net Gain and Natural Capital Accounting are used to support large development projects when the global experience of Biodiversity Net Gain (Zu Ermgasssen of University of Kent) is that it fails twice as often as it succeeds even though this study used the lower standard of No Net Loss rather than Biodiversity Net Gain. You don’t “Double Nature” by planting a few green spaces between the concrete, tarmac and bricks, whose construction has of course destroyed it.
The same investigation found that 95% of Biodiversity Net Gain adopters in England were carrying out on site offsetting (which is not covered in the new Environmental Law) where the developer is the only judge of the offsetting plans. On site offsetting does not encourage many forms of wildlife due to high levels of human use.
Monetarising nature can be used to trade environmental assets for economic ones but how we put a price on natural environments is subjective. 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 (Friends of the Cam). Economic growth at the expense of natural capital is unsustainable.
In short, we request that Greater Cambridge adopts the Dasgupta definition of sustainability and not undervalue natural capital and that biodiversity offsetting should be the last resort and seen as a failure. If it is carried out it should be very carefully monitored and penalties available if it does not succeed over time i.e. some kind of warranty system.
Carbon emissions as a result of development The proposed Local Plan does not follow a `brownfield first’ approach hence it goes contrary to the National Government policy expressed by the Prime Minister. Greenfield building maximizes carbon emissions. Greater Cambridge should be working with Government to encourage Cambridge businesses to move north in line with `leveling up’ the north and south frequently expressed by the Prime Minister.
In the north there are up to 1 million empty homes and room for 1 million more on brownfield sites. It is far less environmentally damaging to re-use existing buildings and infrastructure wherever possible. The Campaign for the Protection of Rural England (CPRE) has shown that building on brownfield sites is generally much quicker than developing greenfield ones because land clearance and leveling is not required and often reusable infrastructure is in place. Renovation/rebuilding empty homes is even less environmentally damaging as infrastructure is already in place. A much greater emphasis on using brownfield sites right across the country, before any greenfield building, would be welcomed.
The massive building and infrastructure developments in the proposed Local Plan breaches all obligations for sustainable development as embodied carbon emissions are ignored in the plan. Cement manufacture contributes 8% of global carbon emissions, over 3 times the impact of aviation fuel, iron and steel manufacture contributes a further 8%, and together they are responsible for more carbon emissions than the USA.
The recent Cambridge and Peterborough Climate Commission report stated that at the present rate this area will have used up its entire carbon budget, allocated so it can reach its legal obligation to reach zero carbon, by 2050 and due to the high level of planned growth the use of our carbon budget with accelerate. The obvious conclusion is that all unsustainable growth in this area needs to be curbed.


No plan for Integrated Public Transport
The current local government structure 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 is an impediment to any form of joined up thinking about an integrated transport system.

The Greater Cambridge Local Plan supports the CSET Babraham P and R and guided busway, which a university representative stated in a GCP Executive Meeting, `is only to serve the Bio-Medical Campus.’ It is fairly obvious that it is not designed to serve the villages it passes as bus stops are on the edges of villages thus encouraging on-street parking of anyone living any distance from busway stops who wish to use it. Environmental damage and damage to villages have not been taken into account in the planning of this project and it does not constitute part of an integrated transport system as, as stated, it was designed to only serve the Bio-Medical Campus.

We propose that this should be replaced with the opening up of the old Haverhill railway along which a light railway system could operate with less environmental damage than the CSET scheme and which could serve the local communities it passes, again unlike the CSET scheme. This could link to the mainline railway system and be extended to Haverhill thus giving them the railway station and access to mainline rail stations they are crying out for and need. This would constitute an integrated public transport system, in contrast with the CSET scheme.

The Local Plan is discriminatory in that, when proposing congestion charging, emissions charging and increasing parking charges, it does not take into account that the elderly, disabled and those in rural areas not within walking distance of a bus stop, need to use their cars and would be disproportionately disadvantaged in comparison with those fit enough to walk or cycle or within a reasonable distance of a bus stop. It does not consider that bus fares are expensive to some, as would be all the proposed charges. Visits to, for example, opticians, could become prohibitively expensive to the groups mentioned if you take all these additional charges into account so they could be put off with possible health implications. You suggest that emission charging would encourage people to buy electric or hybrid vehicles but buying another vehicle would be prohibitively expensive for most on low incomes or pensions. The effect all these charges could have is that shopping in Cambridge is replaced by out-of-town or online shopping resulting in a dire effect on Cambridge shops and the hollowing out of the City centre.

Democratic deficit in the process and evidence basis
Water Resources East have stated that their regional water plans align with the government’s plans for growth. However, whilst sewage outflows and the state of chalk streams is of major concern, Water Resources East state that sewage in not part of their remit. The consultation for the Regional Water Plan is not due until summer 2022 yet the public consultation for Greater Cambridge draft Local Plan is going ahead when we have no idea if and how water and sewerage challenges can be met and what trade-offs have been proposed. Therefore you had insufficient information on which to base your draft Local Plan and responders have insufficient information to base responses on.

The draft Local Plan has been prepared by the Greater Cambridge Shared Planning Service but it appears to be inordinately influenced by the unelected GCP which has business interests and ambitions represented on its board and no counteracting resident’s interests. Much of the text of the draft Local Plan appears to be consistent with announcements made by the self-appointed Arc Leaders Group which promotes the Ox-Cam Arc. The flawed concept of the Arc has been criticized for its lack of transparency or accountability across the five affected counties.

Even making full responses to the Local Plan in the way you requested would be a highly labour intensive process because of the requirement to respond to sections and sub-sections of the Local Plan then to cut and paste responses into a further document. As well as being labour intensive it would force responses into your template thinking. For these reasons we, like some others we know of, have chosen to respond in a format of our choosing. It could almost be suggested that you wish to make it as difficult as possible for affected groups to make meaningful responses.

Conclusion
This is the wrong Plan at the wrong time. There’s a climate, biodiversity and water emergency globally and locally. Local government should not be planning more economic and population growth in this area but prioritizing social housing and a new water infrastructure to reduce stress on our rivers and wildlife. It should seek to protect the Green Belt and our local countryside and not concentrate on economic development at any cost. It should be supporting the government `leveling up’ policy and `brownfield first’ policy. It should take into account the growing flood risk to large parts of this county and the consequences for national food security. We request that the Plan is rejected, rewritten, addressing the points made above, then re-submitted for full public consultation.

Babraham Parish Council.

We strongly object to the new draft Local Plan for the following reasons: our inadequate water supply, it fails to minimize climate change, it has a detrimental effect on national food security and on ecosystems. It will lead to high levels of carbon emissions from construction and the manufacture of construction materials. In addition, there is a lack of an integrated transport system, it undermines the Government policy of `leveling up’ and there is a lack of democracy in the process behind this plan and in its evidence base. We believe that the following factors will be exacerbated or caused by the high levels of development you propose. Locally we feel that certain provisos need to be added to Babraham Institute being released from the Green Belt which have not been adequately addressed in the plan.
Over-development The report “How Many Homes” by CPRE Devon, demonstrates how the ONS population projections are seriously flawed and that this is leading to over estimation of housing need in all areas of the country. Using the government’s methodology, the study demonstrates that the housing need is around 213,000 additional houses per year. The government’s target is 300,000 – a 40% overstatement. See CPRE Devon website.
https://www.cpredevon.org.uk/the-government-wants-to-build-more-than-3million-new-homes-than-are-needed/
We were dismayed at the GCP proposed levels of development so it is disturbing that our District and City councils are proposing to bring forward housing developments and build a further approximately 49,000 houses. MP Anthony Browne carried out a survey regarding the proposed developments related to the Ox-Cam Arc in South Cambs and found that a very high proportion of residents did not want further housing developments in this area and we can assume that they will also oppose the developments you propose.
The Cambridge Greenbelt is continually under attack and has already been nibbled away by the weakened Local Plan process which placed protection of the greenbelt into the hands of local planning authorities and not the Secretary of State. The Greenbelt of South Cambs will be further eroded by your proposed Local Plan eg. locally the Mingle Lane proposed development. Cambridge Greenbelt has two purposes, to stop urban sprawl and to protect the setting of the City. Further major developments around it will put the Greenbelt under even greater pressure because of the major damage being done to the essentially rural landscapes beyond the Greenbelt.
The Cambridge area has a very high level of employment so it’s not as if we need more businesses, and hence housing developments, coming to this area. We have a historical and beautiful City surrounded by picturesque villages and wonderful countryside which you should be protecting and not planning to blight with housing developments.

Inadequate water supply.
There is a lack of sustainable water supply in Cambridgeshire and the levels of development you propose will severely exacerbate this situation. The Stantec Integrated Water Management Study to the GCP showed that only the lowest level of housing provision around Cambridge was possible. This is even re-iterated in Objective 10 of your own Greater Cambridge Local Plan, Strategic Spatial Options Assessment Sustainability Appraisal (November 2020). Objective 10 Page 96 onwards, Section 3.333 especially.
https://www.greatercambridgeplanning.org/media/1393/gclp-strategic-spatial-options-assessment-sustainability-appraisal-nov2020.pdf
Any further development would put even more strain on what is already an unsustainable situation. Plans to route water from areas further north have been shown by the CPRE to be both expensive and unable to meet even GCP levels of growth and housing let alone the additional levels proposed by this plan. Indeed North Lincolnshire, one of the proposed areas to route water from, the Environment Agency has now classed as a `water stressed area.’
On 1st July, 2021 DEFRA in “Water stressed areas – final classification 2021” stated that chalk streams would be given enhanced environmental protection. On page 6 of this document it states that the supply areas of Cambridge Water and Anglian Water were areas of serious water stress. It stated that Cambridge Water needed to reduce levels of abstraction by 22 megalitres per day from levels on1st July, 2021 and Anglian Water needed to reduce abstraction levels by 189 megalitres from the same date.
In August 2020, the Environment Agency, in response to a query regarding the viability of the Northstowe Phase 3A development, replied to Ms. Hone that `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…many waterbodies did not have the flow to support the ecology.’
In short, the development proposed in this Local Plan would damage our rivers, chalk streams, our ecology and our farming because we simply do not have sufficient water supplies at present, a point a previous Local Plan had made. Water supplies certainly will not support the proposed level of development and piping it in from an area that is also Water Stressed makes no sense.
Inadequate sewerage infrastructure The draft Local Plan will lead to new building when the local sewerage system is currently inadequate. This is evidenced by the reported number of sewerage spills by Anglian Water into the Cam Valley; upstream of Cambridge saw 622 hours of untreated sewerage enter the rivers in 2020. There are currently no plans to improve the sewerage system to prevent these outflows, just to monitor them more adequately. To date there have been no upgrades at small sewerage work in the area. The only work in this area is to move the one major sewerage works in the area (at Waterbeach) one that has been future proofed until 2050, to land prone to flooding at huge expense to prevent it from flooding and subsequent pollution of the area, in order to make way for a housing development. If it was to make way for a larger sewerage works this would have been sensible and might have prevented the outflow of untreated sewerage into the delicate ecosystems of our rivers.
In short, our sewerage system is inadequate and further development will put additional strain on it, increasing the risk of sewerage outflows into rivers.


Threat to National Food Security
Any further development around Cambridge, will necessarily take scarce grade 2 and 3a land out of production. Developments in Fen land will deprive us of grade 1 agricultural land. Grade 1 designation is reserved almost solely for the peat-based soils of the drained fens. Your proposed developments around the Waterbeach area are therefore thought to be very unwise. This land is already needed for food production in a country which imports c. 60% of its food supply. Nationally, we do not have food security According to the NFU, the Fens produce one third of England’s fresh vegetables; 20% of our potatoes, over 20% of our flowers and bulbs, 20% of our sugar beet as well as a large percentage of our cereal crops. Agriculture employs 80,000 people and produces £3bn pa for the rural economy.
Farmers can only produce food when they have sufficient water, which we currently don’t have, when land is protected for food security and is not covered in solar panels, housing or business developments. Inward migration to Cambridgeshire will lead to the loss of high and the best quality agricultural land due to building. The increased water usage of those coming to the region is put at about a further 16 megalitres of water a day (based on the additional 49,000 houses proposed hence about 100,000 additional people). This is when we are already in dire need of additional water supplies.
Due to climate change there is an anticipated sea level rise of at least 1.1 metre by 2100 (IPCC 2019) and possibly up to 4.7 metres (Surging Seas) in the Wash and hence the Rivers Great Ouse and Cam. This is likely to lead to the permanent loss of much of the UK food supply as the Fens will become frequently and, eventually permanently flooded. Grade 2 and 3a land is therefore an increasingly valuable national asset which must be protected and whose protection is already documented in the NPPF paragraph 170. Such land exists in an arc around the Fens, much of it around Cambridge.
There is the suggestion of building reservoirs in the Fens to supply water for the proposed increase in population in this part of the county. However, there is little point in building reservoirs in the Fens when it is clear they will be flooded by saline water within decades.
In short, we have to protect this valuable agricultural land from over-development as climate change is likely to decrease its availability and pose a threat to our food security.

Damage to ecosystems The Cambridgeshire countryside, despite intensive farming, is a wildlife-rich area. The Greater Cambridge proposed Local Plan supports a high level of business and housing developments and makes statements suggesting that development will help nature to thrive when evidence shows that the increase in artificial surfaces leads to a decrease in water in the environment and in the amount of land that can absorb rainwater and recharge bodies of water. The river Cam has lost half its flow since the 70s and in 2019 the river Granta completely dried up. Partly as a consequence, freshwater biodiversity populations have declined by 84% (Friends of the Cam).
Concepts such as `doubling nature’, Biodiversity Net Gain and Natural Capital Accounting are used to support large development projects when the global experience of Biodiversity Net Gain (Zu Ermgasssen of University of Kent) is that it fails twice as often as it succeeds even though this study used the lower standard of No Net Loss rather than Biodiversity Net Gain. You don’t “Double Nature” by planting a few green spaces between the concrete, tarmac and bricks, whose construction has of course destroyed it.
The same investigation found that 95% of Biodiversity Net Gain adopters in England were carrying out on site offsetting (which is not covered in the new Environmental Law) where the developer is the only judge of the offsetting plans. On site offsetting does not encourage many forms of wildlife due to high levels of human use.
Monetarising nature can be used to trade environmental assets for economic ones but how we put a price on natural environments is subjective. 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 (Friends of the Cam). Economic growth at the expense of natural capital is unsustainable.
In short, we request that Greater Cambridge adopts the Dasgupta definition of sustainability and not undervalue natural capital and that biodiversity offsetting should be the last resort and seen as a failure. If it is carried out it should be very carefully monitored and penalties available if it does not succeed over time i.e. some kind of warranty system.
Carbon emissions as a result of development The proposed Local Plan does not follow a `brownfield first’ approach hence it goes contrary to the National Government policy expressed by the Prime Minister. Greenfield building maximizes carbon emissions. Greater Cambridge should be working with Government to encourage Cambridge businesses to move north in line with `leveling up’ the north and south frequently expressed by the Prime Minister.
In the north there are up to 1 million empty homes and room for 1 million more on brownfield sites. It is far less environmentally damaging to re-use existing buildings and infrastructure wherever possible. The Campaign for the Protection of Rural England (CPRE) has shown that building on brownfield sites is generally much quicker than developing greenfield ones because land clearance and leveling is not required and often reusable infrastructure is in place. Renovation/rebuilding empty homes is even less environmentally damaging as infrastructure is already in place. A much greater emphasis on using brownfield sites right across the country, before any greenfield building, would be welcomed.
The massive building and infrastructure developments in the proposed Local Plan breaches all obligations for sustainable development as embodied carbon emissions are ignored in the plan. Cement manufacture contributes 8% of global carbon emissions, over 3 times the impact of aviation fuel, iron and steel manufacture contributes a further 8%, and together they are responsible for more carbon emissions than the USA.
The recent Cambridge and Peterborough Climate Commission report stated that at the present rate this area will have used up its entire carbon budget, allocated so it can reach its legal obligation to reach zero carbon, by 2050 and due to the high level of planned growth the use of our carbon budget with accelerate. The obvious conclusion is that all unsustainable growth in this area needs to be curbed.


No plan for Integrated Public Transport
The current local government structure 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 is an impediment to any form of joined up thinking about an integrated transport system.

The Greater Cambridge Local Plan supports the CSET Babraham P and R and guided busway, which a university representative stated in a GCP Executive Meeting, `is only to serve the Bio-Medical Campus.’ It is fairly obvious that it is not designed to serve the villages it passes as bus stops are on the edges of villages thus encouraging on-street parking of anyone living any distance from busway stops who wish to use it. Environmental damage and damage to villages have not been taken into account in the planning of this project and it does not constitute part of an integrated transport system as, as stated, it was designed to only serve the Bio-Medical Campus.

We propose that this should be replaced with the opening up of the old Haverhill railway along which a light railway system could operate with less environmental damage than the CSET scheme and which could serve the local communities it passes, again unlike the CSET scheme. This could link to the mainline railway system and be extended to Haverhill thus giving them the railway station and access to mainline rail stations they are crying out for and need. This would constitute an integrated public transport system, in contrast with the CSET scheme.

The Local Plan is discriminatory in that, when proposing congestion charging, emissions charging and increasing parking charges, it does not take into account that the elderly, disabled and those in rural areas not within walking distance of a bus stop, need to use their cars and would be disproportionately disadvantaged in comparison with those fit enough to walk or cycle or within a reasonable distance of a bus stop. It does not consider that bus fares are expensive to some, as would be all the proposed charges. Visits to, for example, opticians, could become prohibitively expensive to the groups mentioned if you take all these additional charges into account so they could be put off with possible health implications. You suggest that emission charging would encourage people to buy electric or hybrid vehicles but buying another vehicle would be prohibitively expensive for most on low incomes or pensions. The effect all these charges could have is that shopping in Cambridge is replaced by out-of-town or online shopping resulting in a dire effect on Cambridge shops and the hollowing out of the City centre.

Democratic deficit in the process and evidence basis
Water Resources East have stated that their regional water plans align with the government’s plans for growth. However, whilst sewage outflows and the state of chalk streams is of major concern, Water Resources East state that sewage in not part of their remit. The consultation for the Regional Water Plan is not due until summer 2022 yet the public consultation for Greater Cambridge draft Local Plan is going ahead when we have no idea if and how water and sewerage challenges can be met and what trade-offs have been proposed. Therefore you had insufficient information on which to base your draft Local Plan and responders have insufficient information to base responses on.

The draft Local Plan has been prepared by the Greater Cambridge Shared Planning Service but it appears to be inordinately influenced by the unelected GCP which has business interests and ambitions represented on its board and no counteracting resident’s interests. Much of the text of the draft Local Plan appears to be consistent with announcements made by the self-appointed Arc Leaders Group which promotes the Ox-Cam Arc. The flawed concept of the Arc has been criticized for its lack of transparency or accountability across the five affected counties.

Even making full responses to the Local Plan in the way you requested would be a highly labour intensive process because of the requirement to respond to sections and sub-sections of the Local Plan then to cut and paste responses into a further document. As well as being labour intensive it would force responses into your template thinking. For these reasons we, like some others we know of, have chosen to respond in a format of our choosing. It could almost be suggested that you wish to make it as difficult as possible for affected groups to make meaningful responses.

Conclusion
This is the wrong Plan at the wrong time. There’s a climate, biodiversity and water emergency globally and locally. Local government should not be planning more economic and population growth in this area but prioritizing social housing and a new water infrastructure to reduce stress on our rivers and wildlife. It should seek to protect the Green Belt and our local countryside and not concentrate on economic development at any cost. It should be supporting the government `leveling up’ policy and `brownfield first’ policy. It should take into account the growing flood risk to large parts of this county and the consequences for national food security. We request that the Plan is rejected, rewritten, addressing the points made above, then re-submitted for full public consultation.

Babraham Parish Council.

We strongly object to the new draft Local Plan for the following reasons: our inadequate water supply, it fails to minimize climate change, it has a detrimental effect on national food security and on ecosystems. It will lead to high levels of carbon emissions from construction and the manufacture of construction materials. In addition, there is a lack of an integrated transport system, it undermines the Government policy of `leveling up’ and there is a lack of democracy in the process behind this plan and in its evidence base. We believe that the following factors will be exacerbated or caused by the high levels of development you propose. Locally we feel that certain provisos need to be added to Babraham Institute being released from the Green Belt which have not been adequately addressed in the plan.
Over-development The report “How Many Homes” by CPRE Devon, demonstrates how the ONS population projections are seriously flawed and that this is leading to over estimation of housing need in all areas of the country. Using the government’s methodology, the study demonstrates that the housing need is around 213,000 additional houses per year. The government’s target is 300,000 – a 40% overstatement. See CPRE Devon website.
https://www.cpredevon.org.uk/the-government-wants-to-build-more-than-3million-new-homes-than-are-needed/
We were dismayed at the GCP proposed levels of development so it is disturbing that our District and City councils are proposing to bring forward housing developments and build a further approximately 49,000 houses. MP Anthony Browne carried out a survey regarding the proposed developments related to the Ox-Cam Arc in South Cambs and found that a very high proportion of residents did not want further housing developments in this area and we can assume that they will also oppose the developments you propose.
The Cambridge Greenbelt is continually under attack and has already been nibbled away by the weakened Local Plan process which placed protection of the greenbelt into the hands of local planning authorities and not the Secretary of State. The Greenbelt of South Cambs will be further eroded by your proposed Local Plan eg. locally the Mingle Lane proposed development. Cambridge Greenbelt has two purposes, to stop urban sprawl and to protect the setting of the City. Further major developments around it will put the Greenbelt under even greater pressure because of the major damage being done to the essentially rural landscapes beyond the Greenbelt.
The Cambridge area has a very high level of employment so it’s not as if we need more businesses, and hence housing developments, coming to this area. We have a historical and beautiful City surrounded by picturesque villages and wonderful countryside which you should be protecting and not planning to blight with housing developments.

Inadequate water supply.
There is a lack of sustainable water supply in Cambridgeshire and the levels of development you propose will severely exacerbate this situation. The Stantec Integrated Water Management Study to the GCP showed that only the lowest level of housing provision around Cambridge was possible. This is even re-iterated in Objective 10 of your own Greater Cambridge Local Plan, Strategic Spatial Options Assessment Sustainability Appraisal (November 2020). Objective 10 Page 96 onwards, Section 3.333 especially.
https://www.greatercambridgeplanning.org/media/1393/gclp-strategic-spatial-options-assessment-sustainability-appraisal-nov2020.pdf
Any further development would put even more strain on what is already an unsustainable situation. Plans to route water from areas further north have been shown by the CPRE to be both expensive and unable to meet even GCP levels of growth and housing let alone the additional levels proposed by this plan. Indeed North Lincolnshire, one of the proposed areas to route water from, the Environment Agency has now classed as a `water stressed area.’
On 1st July, 2021 DEFRA in “Water stressed areas – final classification 2021” stated that chalk streams would be given enhanced environmental protection. On page 6 of this document it states that the supply areas of Cambridge Water and Anglian Water were areas of serious water stress. It stated that Cambridge Water needed to reduce levels of abstraction by 22 megalitres per day from levels on1st July, 2021 and Anglian Water needed to reduce abstraction levels by 189 megalitres from the same date.
In August 2020, the Environment Agency, in response to a query regarding the viability of the Northstowe Phase 3A development, replied to Ms. Hone that `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…many waterbodies did not have the flow to support the ecology.’
In short, the development proposed in this Local Plan would damage our rivers, chalk streams, our ecology and our farming because we simply do not have sufficient water supplies at present, a point a previous Local Plan had made. Water supplies certainly will not support the proposed level of development and piping it in from an area that is also Water Stressed makes no sense.
Inadequate sewerage infrastructure The draft Local Plan will lead to new building when the local sewerage system is currently inadequate. This is evidenced by the reported number of sewerage spills by Anglian Water into the Cam Valley; upstream of Cambridge saw 622 hours of untreated sewerage enter the rivers in 2020. There are currently no plans to improve the sewerage system to prevent these outflows, just to monitor them more adequately. To date there have been no upgrades at small sewerage work in the area. The only work in this area is to move the one major sewerage works in the area (at Waterbeach) one that has been future proofed until 2050, to land prone to flooding at huge expense to prevent it from flooding and subsequent pollution of the area, in order to make way for a housing development. If it was to make way for a larger sewerage works this would have been sensible and might have prevented the outflow of untreated sewerage into the delicate ecosystems of our rivers.
In short, our sewerage system is inadequate and further development will put additional strain on it, increasing the risk of sewerage outflows into rivers.


Threat to National Food Security
Any further development around Cambridge, will necessarily take scarce grade 2 and 3a land out of production. Developments in Fen land will deprive us of grade 1 agricultural land. Grade 1 designation is reserved almost solely for the peat-based soils of the drained fens. Your proposed developments around the Waterbeach area are therefore thought to be very unwise. This land is already needed for food production in a country which imports c. 60% of its food supply. Nationally, we do not have food security According to the NFU, the Fens produce one third of England’s fresh vegetables; 20% of our potatoes, over 20% of our flowers and bulbs, 20% of our sugar beet as well as a large percentage of our cereal crops. Agriculture employs 80,000 people and produces £3bn pa for the rural economy.
Farmers can only produce food when they have sufficient water, which we currently don’t have, when land is protected for food security and is not covered in solar panels, housing or business developments. Inward migration to Cambridgeshire will lead to the loss of high and the best quality agricultural land due to building. The increased water usage of those coming to the region is put at about a further 16 megalitres of water a day (based on the additional 49,000 houses proposed hence about 100,000 additional people). This is when we are already in dire need of additional water supplies.
Due to climate change there is an anticipated sea level rise of at least 1.1 metre by 2100 (IPCC 2019) and possibly up to 4.7 metres (Surging Seas) in the Wash and hence the Rivers Great Ouse and Cam. This is likely to lead to the permanent loss of much of the UK food supply as the Fens will become frequently and, eventually permanently flooded. Grade 2 and 3a land is therefore an increasingly valuable national asset which must be protected and whose protection is already documented in the NPPF paragraph 170. Such land exists in an arc around the Fens, much of it around Cambridge.
There is the suggestion of building reservoirs in the Fens to supply water for the proposed increase in population in this part of the county. However, there is little point in building reservoirs in the Fens when it is clear they will be flooded by saline water within decades.
In short, we have to protect this valuable agricultural land from over-development as climate change is likely to decrease its availability and pose a threat to our food security.

Damage to ecosystems The Cambridgeshire countryside, despite intensive farming, is a wildlife-rich area. The Greater Cambridge proposed Local Plan supports a high level of business and housing developments and makes statements suggesting that development will help nature to thrive when evidence shows that the increase in artificial surfaces leads to a decrease in water in the environment and in the amount of land that can absorb rainwater and recharge bodies of water. The river Cam has lost half its flow since the 70s and in 2019 the river Granta completely dried up. Partly as a consequence, freshwater biodiversity populations have declined by 84% (Friends of the Cam).
Concepts such as `doubling nature’, Biodiversity Net Gain and Natural Capital Accounting are used to support large development projects when the global experience of Biodiversity Net Gain (Zu Ermgasssen of University of Kent) is that it fails twice as often as it succeeds even though this study used the lower standard of No Net Loss rather than Biodiversity Net Gain. You don’t “Double Nature” by planting a few green spaces between the concrete, tarmac and bricks, whose construction has of course destroyed it.
The same investigation found that 95% of Biodiversity Net Gain adopters in England were carrying out on site offsetting (which is not covered in the new Environmental Law) where the developer is the only judge of the offsetting plans. On site offsetting does not encourage many forms of wildlife due to high levels of human use.
Monetarising nature can be used to trade environmental assets for economic ones but how we put a price on natural environments is subjective. 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 (Friends of the Cam). Economic growth at the expense of natural capital is unsustainable.
In short, we request that Greater Cambridge adopts the Dasgupta definition of sustainability and not undervalue natural capital and that biodiversity offsetting should be the last resort and seen as a failure. If it is carried out it should be very carefully monitored and penalties available if it does not succeed over time i.e. some kind of warranty system.
Carbon emissions as a result of development The proposed Local Plan does not follow a `brownfield first’ approach hence it goes contrary to the National Government policy expressed by the Prime Minister. Greenfield building maximizes carbon emissions. Greater Cambridge should be working with Government to encourage Cambridge businesses to move north in line with `leveling up’ the north and south frequently expressed by the Prime Minister.
In the north there are up to 1 million empty homes and room for 1 million more on brownfield sites. It is far less environmentally damaging to re-use existing buildings and infrastructure wherever possible. The Campaign for the Protection of Rural England (CPRE) has shown that building on brownfield sites is generally much quicker than developing greenfield ones because land clearance and leveling is not required and often reusable infrastructure is in place. Renovation/rebuilding empty homes is even less environmentally damaging as infrastructure is already in place. A much greater emphasis on using brownfield sites right across the country, before any greenfield building, would be welcomed.
The massive building and infrastructure developments in the proposed Local Plan breaches all obligations for sustainable development as embodied carbon emissions are ignored in the plan. Cement manufacture contributes 8% of global carbon emissions, over 3 times the impact of aviation fuel, iron and steel manufacture contributes a further 8%, and together they are responsible for more carbon emissions than the USA.
The recent Cambridge and Peterborough Climate Commission report stated that at the present rate this area will have used up its entire carbon budget, allocated so it can reach its legal obligation to reach zero carbon, by 2050 and due to the high level of planned growth the use of our carbon budget with accelerate. The obvious conclusion is that all unsustainable growth in this area needs to be curbed.


No plan for Integrated Public Transport
The current local government structure 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 is an impediment to any form of joined up thinking about an integrated transport system.

The Greater Cambridge Local Plan supports the CSET Babraham P and R and guided busway, which a university representative stated in a GCP Executive Meeting, `is only to serve the Bio-Medical Campus.’ It is fairly obvious that it is not designed to serve the villages it passes as bus stops are on the edges of villages thus encouraging on-street parking of anyone living any distance from busway stops who wish to use it. Environmental damage and damage to villages have not been taken into account in the planning of this project and it does not constitute part of an integrated transport system as, as stated, it was designed to only serve the Bio-Medical Campus.

We propose that this should be replaced with the opening up of the old Haverhill railway along which a light railway system could operate with less environmental damage than the CSET scheme and which could serve the local communities it passes, again unlike the CSET scheme. This could link to the mainline railway system and be extended to Haverhill thus giving them the railway station and access to mainline rail stations they are crying out for and need. This would constitute an integrated public transport system, in contrast with the CSET scheme.

The Local Plan is discriminatory in that, when proposing congestion charging, emissions charging and increasing parking charges, it does not take into account that the elderly, disabled and those in rural areas not within walking distance of a bus stop, need to use their cars and would be disproportionately disadvantaged in comparison with those fit enough to walk or cycle or within a reasonable distance of a bus stop. It does not consider that bus fares are expensive to some, as would be all the proposed charges. Visits to, for example, opticians, could become prohibitively expensive to the groups mentioned if you take all these additional charges into account so they could be put off with possible health implications. You suggest that emission charging would encourage people to buy electric or hybrid vehicles but buying another vehicle would be prohibitively expensive for most on low incomes or pensions. The effect all these charges could have is that shopping in Cambridge is replaced by out-of-town or online shopping resulting in a dire effect on Cambridge shops and the hollowing out of the City centre.

Democratic deficit in the process and evidence basis
Water Resources East have stated that their regional water plans align with the government’s plans for growth. However, whilst sewage outflows and the state of chalk streams is of major concern, Water Resources East state that sewage in not part of their remit. The consultation for the Regional Water Plan is not due until summer 2022 yet the public consultation for Greater Cambridge draft Local Plan is going ahead when we have no idea if and how water and sewerage challenges can be met and what trade-offs have been proposed. Therefore you had insufficient information on which to base your draft Local Plan and responders have insufficient information to base responses on.

The draft Local Plan has been prepared by the Greater Cambridge Shared Planning Service but it appears to be inordinately influenced by the unelected GCP which has business interests and ambitions represented on its board and no counteracting resident’s interests. Much of the text of the draft Local Plan appears to be consistent with announcements made by the self-appointed Arc Leaders Group which promotes the Ox-Cam Arc. The flawed concept of the Arc has been criticized for its lack of transparency or accountability across the five affected counties.

Even making full responses to the Local Plan in the way you requested would be a highly labour intensive process because of the requirement to respond to sections and sub-sections of the Local Plan then to cut and paste responses into a further document. As well as being labour intensive it would force responses into your template thinking. For these reasons we, like some others we know of, have chosen to respond in a format of our choosing. It could almost be suggested that you wish to make it as difficult as possible for affected groups to make meaningful responses.

Conclusion
This is the wrong Plan at the wrong time. There’s a climate, biodiversity and water emergency globally and locally. Local government should not be planning more economic and population growth in this area but prioritizing social housing and a new water infrastructure to reduce stress on our rivers and wildlife. It should seek to protect the Green Belt and our local countryside and not concentrate on economic development at any cost. It should be supporting the government `leveling up’ policy and `brownfield first’ policy. It should take into account the growing flood risk to large parts of this county and the consequences for national food security. We request that the Plan is rejected, rewritten, addressing the points made above, then re-submitted for full public consultation.

Babraham Parish Council.

We strongly object to the new draft Local Plan for the following reasons: our inadequate water supply, it fails to minimize climate change, it has a detrimental effect on national food security and on ecosystems. It will lead to high levels of carbon emissions from construction and the manufacture of construction materials. In addition, there is a lack of an integrated transport system, it undermines the Government policy of `leveling up’ and there is a lack of democracy in the process behind this plan and in its evidence base. We believe that the following factors will be exacerbated or caused by the high levels of development you propose. Locally we feel that certain provisos need to be added to Babraham Institute being released from the Green Belt which have not been adequately addressed in the plan.
Over-development The report “How Many Homes” by CPRE Devon, demonstrates how the ONS population projections are seriously flawed and that this is leading to over estimation of housing need in all areas of the country. Using the government’s methodology, the study demonstrates that the housing need is around 213,000 additional houses per year. The government’s target is 300,000 – a 40% overstatement. See CPRE Devon website.
https://www.cpredevon.org.uk/the-government-wants-to-build-more-than-3million-new-homes-than-are-needed/
We were dismayed at the GCP proposed levels of development so it is disturbing that our District and City councils are proposing to bring forward housing developments and build a further approximately 49,000 houses. MP Anthony Browne carried out a survey regarding the proposed developments related to the Ox-Cam Arc in South Cambs and found that a very high proportion of residents did not want further housing developments in this area and we can assume that they will also oppose the developments you propose.
The Cambridge Greenbelt is continually under attack and has already been nibbled away by the weakened Local Plan process which placed protection of the greenbelt into the hands of local planning authorities and not the Secretary of State. The Greenbelt of South Cambs will be further eroded by your proposed Local Plan eg. locally the Mingle Lane proposed development. Cambridge Greenbelt has two purposes, to stop urban sprawl and to protect the setting of the City. Further major developments around it will put the Greenbelt under even greater pressure because of the major damage being done to the essentially rural landscapes beyond the Greenbelt.
The Cambridge area has a very high level of employment so it’s not as if we need more businesses, and hence housing developments, coming to this area. We have a historical and beautiful City surrounded by picturesque villages and wonderful countryside which you should be protecting and not planning to blight with housing developments.

Inadequate water supply.
There is a lack of sustainable water supply in Cambridgeshire and the levels of development you propose will severely exacerbate this situation. The Stantec Integrated Water Management Study to the GCP showed that only the lowest level of housing provision around Cambridge was possible. This is even re-iterated in Objective 10 of your own Greater Cambridge Local Plan, Strategic Spatial Options Assessment Sustainability Appraisal (November 2020). Objective 10 Page 96 onwards, Section 3.333 especially.
https://www.greatercambridgeplanning.org/media/1393/gclp-strategic-spatial-options-assessment-sustainability-appraisal-nov2020.pdf
Any further development would put even more strain on what is already an unsustainable situation. Plans to route water from areas further north have been shown by the CPRE to be both expensive and unable to meet even GCP levels of growth and housing let alone the additional levels proposed by this plan. Indeed North Lincolnshire, one of the proposed areas to route water from, the Environment Agency has now classed as a `water stressed area.’
On 1st July, 2021 DEFRA in “Water stressed areas – final classification 2021” stated that chalk streams would be given enhanced environmental protection. On page 6 of this document it states that the supply areas of Cambridge Water and Anglian Water were areas of serious water stress. It stated that Cambridge Water needed to reduce levels of abstraction by 22 megalitres per day from levels on1st July, 2021 and Anglian Water needed to reduce abstraction levels by 189 megalitres from the same date.
In August 2020, the Environment Agency, in response to a query regarding the viability of the Northstowe Phase 3A development, replied to Ms. Hone that `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…many waterbodies did not have the flow to support the ecology.’
In short, the development proposed in this Local Plan would damage our rivers, chalk streams, our ecology and our farming because we simply do not have sufficient water supplies at present, a point a previous Local Plan had made. Water supplies certainly will not support the proposed level of development and piping it in from an area that is also Water Stressed makes no sense.
Inadequate sewerage infrastructure The draft Local Plan will lead to new building when the local sewerage system is currently inadequate. This is evidenced by the reported number of sewerage spills by Anglian Water into the Cam Valley; upstream of Cambridge saw 622 hours of untreated sewerage enter the rivers in 2020. There are currently no plans to improve the sewerage system to prevent these outflows, just to monitor them more adequately. To date there have been no upgrades at small sewerage work in the area. The only work in this area is to move the one major sewerage works in the area (at Waterbeach) one that has been future proofed until 2050, to land prone to flooding at huge expense to prevent it from flooding and subsequent pollution of the area, in order to make way for a housing development. If it was to make way for a larger sewerage works this would have been sensible and might have prevented the outflow of untreated sewerage into the delicate ecosystems of our rivers.
In short, our sewerage system is inadequate and further development will put additional strain on it, increasing the risk of sewerage outflows into rivers.


Threat to National Food Security
Any further development around Cambridge, will necessarily take scarce grade 2 and 3a land out of production. Developments in Fen land will deprive us of grade 1 agricultural land. Grade 1 designation is reserved almost solely for the peat-based soils of the drained fens. Your proposed developments around the Waterbeach area are therefore thought to be very unwise. This land is already needed for food production in a country which imports c. 60% of its food supply. Nationally, we do not have food security According to the NFU, the Fens produce one third of England’s fresh vegetables; 20% of our potatoes, over 20% of our flowers and bulbs, 20% of our sugar beet as well as a large percentage of our cereal crops. Agriculture employs 80,000 people and produces £3bn pa for the rural economy.
Farmers can only produce food when they have sufficient water, which we currently don’t have, when land is protected for food security and is not covered in solar panels, housing or business developments. Inward migration to Cambridgeshire will lead to the loss of high and the best quality agricultural land due to building. The increased water usage of those coming to the region is put at about a further 16 megalitres of water a day (based on the additional 49,000 houses proposed hence about 100,000 additional people). This is when we are already in dire need of additional water supplies.
Due to climate change there is an anticipated sea level rise of at least 1.1 metre by 2100 (IPCC 2019) and possibly up to 4.7 metres (Surging Seas) in the Wash and hence the Rivers Great Ouse and Cam. This is likely to lead to the permanent loss of much of the UK food supply as the Fens will become frequently and, eventually permanently flooded. Grade 2 and 3a land is therefore an increasingly valuable national asset which must be protected and whose protection is already documented in the NPPF paragraph 170. Such land exists in an arc around the Fens, much of it around Cambridge.
There is the suggestion of building reservoirs in the Fens to supply water for the proposed increase in population in this part of the county. However, there is little point in building reservoirs in the Fens when it is clear they will be flooded by saline water within decades.
In short, we have to protect this valuable agricultural land from over-development as climate change is likely to decrease its availability and pose a threat to our food security.

Damage to ecosystems The Cambridgeshire countryside, despite intensive farming, is a wildlife-rich area. The Greater Cambridge proposed Local Plan supports a high level of business and housing developments and makes statements suggesting that development will help nature to thrive when evidence shows that the increase in artificial surfaces leads to a decrease in water in the environment and in the amount of land that can absorb rainwater and recharge bodies of water. The river Cam has lost half its flow since the 70s and in 2019 the river Granta completely dried up. Partly as a consequence, freshwater biodiversity populations have declined by 84% (Friends of the Cam).
Concepts such as `doubling nature’, Biodiversity Net Gain and Natural Capital Accounting are used to support large development projects when the global experience of Biodiversity Net Gain (Zu Ermgasssen of University of Kent) is that it fails twice as often as it succeeds even though this study used the lower standard of No Net Loss rather than Biodiversity Net Gain. You don’t “Double Nature” by planting a few green spaces between the concrete, tarmac and bricks, whose construction has of course destroyed it.
The same investigation found that 95% of Biodiversity Net Gain adopters in England were carrying out on site offsetting (which is not covered in the new Environmental Law) where the developer is the only judge of the offsetting plans. On site offsetting does not encourage many forms of wildlife due to high levels of human use.
Monetarising nature can be used to trade environmental assets for economic ones but how we put a price on natural environments is subjective. 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 (Friends of the Cam). Economic growth at the expense of natural capital is unsustainable.
In short, we request that Greater Cambridge adopts the Dasgupta definition of sustainability and not undervalue natural capital and that biodiversity offsetting should be the last resort and seen as a failure. If it is carried out it should be very carefully monitored and penalties available if it does not succeed over time i.e. some kind of warranty system.
Carbon emissions as a result of development The proposed Local Plan does not follow a `brownfield first’ approach hence it goes contrary to the National Government policy expressed by the Prime Minister. Greenfield building maximizes carbon emissions. Greater Cambridge should be working with Government to encourage Cambridge businesses to move north in line with `leveling up’ the north and south frequently expressed by the Prime Minister.
In the north there are up to 1 million empty homes and room for 1 million more on brownfield sites. It is far less environmentally damaging to re-use existing buildings and infrastructure wherever possible. The Campaign for the Protection of Rural England (CPRE) has shown that building on brownfield sites is generally much quicker than developing greenfield ones because land clearance and leveling is not required and often reusable infrastructure is in place. Renovation/rebuilding empty homes is even less environmentally damaging as infrastructure is already in place. A much greater emphasis on using brownfield sites right across the country, before any greenfield building, would be welcomed.
The massive building and infrastructure developments in the proposed Local Plan breaches all obligations for sustainable development as embodied carbon emissions are ignored in the plan. Cement manufacture contributes 8% of global carbon emissions, over 3 times the impact of aviation fuel, iron and steel manufacture contributes a further 8%, and together they are responsible for more carbon emissions than the USA.
The recent Cambridge and Peterborough Climate Commission report stated that at the present rate this area will have used up its entire carbon budget, allocated so it can reach its legal obligation to reach zero carbon, by 2050 and due to the high level of planned growth the use of our carbon budget with accelerate. The obvious conclusion is that all unsustainable growth in this area needs to be curbed.


No plan for Integrated Public Transport
The current local government structure 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 is an impediment to any form of joined up thinking about an integrated transport system.

The Greater Cambridge Local Plan supports the CSET Babraham P and R and guided busway, which a university representative stated in a GCP Executive Meeting, `is only to serve the Bio-Medical Campus.’ It is fairly obvious that it is not designed to serve the villages it passes as bus stops are on the edges of villages thus encouraging on-street parking of anyone living any distance from busway stops who wish to use it. Environmental damage and damage to villages have not been taken into account in the planning of this project and it does not constitute part of an integrated transport system as, as stated, it was designed to only serve the Bio-Medical Campus.

We propose that this should be replaced with the opening up of the old Haverhill railway along which a light railway system could operate with less environmental damage than the CSET scheme and which could serve the local communities it passes, again unlike the CSET scheme. This could link to the mainline railway system and be extended to Haverhill thus giving them the railway station and access to mainline rail stations they are crying out for and need. This would constitute an integrated public transport system, in contrast with the CSET scheme.

The Local Plan is discriminatory in that, when proposing congestion charging, emissions charging and increasing parking charges, it does not take into account that the elderly, disabled and those in rural areas not within walking distance of a bus stop, need to use their cars and would be disproportionately disadvantaged in comparison with those fit enough to walk or cycle or within a reasonable distance of a bus stop. It does not consider that bus fares are expensive to some, as would be all the proposed charges. Visits to, for example, opticians, could become prohibitively expensive to the groups mentioned if you take all these additional charges into account so they could be put off with possible health implications. You suggest that emission charging would encourage people to buy electric or hybrid vehicles but buying another vehicle would be prohibitively expensive for most on low incomes or pensions. The effect all these charges could have is that shopping in Cambridge is replaced by out-of-town or online shopping resulting in a dire effect on Cambridge shops and the hollowing out of the City centre.

Democratic deficit in the process and evidence basis
Water Resources East have stated that their regional water plans align with the government’s plans for growth. However, whilst sewage outflows and the state of chalk streams is of major concern, Water Resources East state that sewage in not part of their remit. The consultation for the Regional Water Plan is not due until summer 2022 yet the public consultation for Greater Cambridge draft Local Plan is going ahead when we have no idea if and how water and sewerage challenges can be met and what trade-offs have been proposed. Therefore you had insufficient information on which to base your draft Local Plan and responders have insufficient information to base responses on.

The draft Local Plan has been prepared by the Greater Cambridge Shared Planning Service but it appears to be inordinately influenced by the unelected GCP which has business interests and ambitions represented on its board and no counteracting resident’s interests. Much of the text of the draft Local Plan appears to be consistent with announcements made by the self-appointed Arc Leaders Group which promotes the Ox-Cam Arc. The flawed concept of the Arc has been criticized for its lack of transparency or accountability across the five affected counties.

Even making full responses to the Local Plan in the way you requested would be a highly labour intensive process because of the requirement to respond to sections and sub-sections of the Local Plan then to cut and paste responses into a further document. As well as being labour intensive it would force responses into your template thinking. For these reasons we, like some others we know of, have chosen to respond in a format of our choosing. It could almost be suggested that you wish to make it as difficult as possible for affected groups to make meaningful responses.

Babraham Institute withdrawal from the Green Belt provisos.
This is a local issue so one close to our hearts. Babraham Institute wishes to withdraw from the Green Belt. A wish we are not in agreement with. In the draft Local Plan some rather vague provisos and assurances are made which we feel need tightening up to safeguard the interests of Babraham residents and those in the wider environment. We therefore request that the following provisos are incorporated into this Local Plan

1. The same principles should be applied to this green belt release as for Policy S/CBC: Cambridge Biomedical Campus, namely that “National Planning policy requires that the impact of removing land from the Green Belt to be offset through compensatory improvements to the environmental quality and accessibility of remaining Green Belt land”.

2. The Preferred Options documents do not seem to recognise that this site is located within the Cambridge Nature Network (www.cambridgenaturenetwork.org) and that it is adjacent to two strategic green infrastructure areas making it an important site (Green Infrastructure Strategic Initiatives: Gog Magog Hills (3) and River Cam Corridor (2c)). We would expect the proposals in the policy area to reflect this with a very strong emphasis on biodiversity enhancement within or adjacent to the grounds of the campus combined with better public access/benefits. We note that Google earth seems to show an area of exposed chalk in the south-west corner which could provide an opportunity for ecological restoration of priority calcareous grassland habitat.

3. The proposals for this policy area must recognise that the area identified for development would be on much higher ground than those buildings that have already been built on the campus (which are sunk into the hillside). This location is sensitive in landscape character terms, being visible from the higher ground of the Gog Magog Hills, including from the Roman Road Schedule Ancient Monument. There is a potential conflict between the development of this site and policies designed to protect landscape character. To be acceptable in planning terms, any new buildings would need to be below tree height as viewed from the Gog Magog Hills (including any chimneys or rooftop plant), they should also be designed to blend into the landscape when viewed at distance.

4. We would strongly oppose any expansion of Babraham Institute outside of their land and into the surrounding Green Belt.

5. One of the newer buildings on the campus has already had a very negative impact on landscape which is contrary to planning policy and, in our view, should not have been granted permission (photos available on request). We request that before any future development of the site takes place there is a requirement for retrospective action to screen this building and/or better blend it into the landscape when viewed at distance.

Conclusion
This is the wrong Plan at the wrong time. There’s a climate, biodiversity and water emergency globally and locally. Local government should not be planning more economic and population growth in this area but prioritizing social housing and a new water infrastructure to reduce stress on our rivers and wildlife. It should seek to protect the Green Belt and our local countryside and not concentrate on economic development at any cost. It should be supporting the government `leveling up’ policy and `brownfield first’ policy. It should take into account the growing flood risk to large parts of this county and the consequences for national food security. We request that the Plan is rejected, rewritten, addressing the points made above, then re-submitted for full public consultation.

Babraham Parish Council.