Greater Cambridge Local Plan Preferred Options

We welcome the publication of the Greater Cambridge Local Plan: First Proposals 2021 (GCLP) Habitats Regulations Assessment Report (The HRA Report) and the opportunity to comment on it. Cambridgeshire contains a number of sites of international importance for biodiversity that must have the highest level of protection. We also welcome and support the recognition at Para 1.10 that the HRA report is based on the precautionary principle and the statement that ‘where uncertainty or doubt remains, an adverse effect should be assumed’.

Cambridge Past, Present & Future has also commented on the Biodiversity and green spaces policies in the GCLP First Proposals consultation and our comments on the HRA report should be read in together with these. Whilst it is appreciated that the focus of the HRA report is necessarily on European sites, it also raises fundamental issues and concerns that apply to sites of national and local biodiversity importance too.

Although the publication of the HRA report is welcomed, there are however, some concerns that we discuss in further detail below. This applies especially to potential recreational impacts and the consequences of increased water supply and quality issues arising from the implementation of the future GCLP. We also note the caveat that the HRA report indicates that (on a precautionary basis) a conclusion of no adverse effect on the integrity of European sites cannot be reached without further work on issue of water quantity and quality - both key concerns.

Assessment of in combination effects

Chapter 3 of the HRA report refers to the assessment of potential in combination effects and the identification of other Local Authority plans that could contribute to these. The scope of this is welcomed. It should be noted though that broader projects such as the Oxford-Cambridge Arc still require more work and detail to enable potential in combination effects to be identified. This also applies to any other site allocations and development that have yet to be defined or that may emerge in future versions of the GCLP.

Screening Assessment

It is noted that para 4.3 indicates a list of policies that will not result in development and will contribute to ensuring the safeguarding of European sites. This intention is welcomed but much will depend on how these polices are worded and framed. For example, we would refer to our comments submitted in respect of the First Proposals for biodiversity and green spaces. Whilst the overall and intention and policy direction of these polices is welcomed, the detail will be critical. We have commented on the need to prioritise polices to ensure that the protection of all sites of biodiversity importance is the first principle - this should also provide clear guidance for future developments on the standards and process that will be required. This includes the assessment of projects, the application of the mitigation hierarchy and justification and compensation for harm to sites where an unavoidable adverse effect might happen. Similarly, water quantity/quality and recreational issues are key concerns and we comment on these further below.

Table 4.8 provides a summary of the screening assessment and whether potential likely significant effects (LSEs) will occur. We note that potential LSEs are identified regarding possible off site physical damage and loss and non physical disturbance for Eversden and Wimploe Woods SAC and for water quantity and quality in respect of European wetland sites. It is also noted that a potential significant effect from recreational impacts has been identified for Wicken Fen Ramsar site and the Fenland SAC - the latter overlapping the former. The reason for this appears to be because of specific visitor survey work carried out at Wicken Fen. As para 4.60 of the HRA report indicates:

‘No zone of potential risk was identified for Wicken Fen Ramsar. However, in line with a precautionary approach and following the completion of the visitor surveys within Wicken Fen Vision Area, a Zone of Influence has been applied. The survey data that was collected at the Wicken Fen Main Entrance and found that the majority of visitors travelled between 10km and 20km to visit these sites. Based on these findings and in line with a precautionary approach a ZOI of 20km was applied in this assessment.’

Recreational pressure arising from future development as a consequence of development planned for in the GCLP could have a serious impact on existing European sites and those of national and local importance that are, of course, not covered by the HRA Report. It is also evident that the potential effect on Wicken Fen and the related Fenland SAC has only been identified because of specific survey work. With this in mind, we are concerned with the confidence that can be placed on a finding of no LSE for other European sites based on a zone of potential risk for recreational pressure based on a 2Km and 5km distance. We comment further on the implications of the findings of the HRA Appropriate Assessment with regard to potential recreational impacts on Wicken Fen and the Fenland SAC further below.

Appropriate Assessment (AA) - overall approach

Para 5.5 summarises the LSEs indicated in Table 4.8. That table indicates no LSE from Air Pollution on any European sites. Para 5.5. however indicates to the contrary - we assume this is an error as the subsequent AA does not address this issue.

Paras 5.34 to 5.37 refer to mitigation in respect of non physical disturbance and Eversden and Wimpole Woods SAC. It is noted that paras 5.35 and 5.36 state (with reference to overall biodiversity policy) :

‘The policy will state that development proposals adversely affecting sites of biodiversity or geological importance will not normally be permitted. Exceptions will only be made where the public benefits significantly outweigh any adverse impacts. In such cases where development is permitted, we will require that the intrinsic natural features of particular interest are safeguarded or enhanced.’

and:

‘It is recommended that this wording is further strengthened to explicitly state that the level of protection provided should be appropriate to the international, national or local significance of the site. In addition, the policy should be updated to reflect the safeguard measures detailed above’.

We commented on this issue specifically with regard to the biodiversity and green spaces policies in this First Proposals consultation. The supporting text quoted at para 5.35 above indicates that exceptions will only be made where the public benefits significantly outweigh any adverse impacts. However, more clarity will be needed on how this will work in practice. Again, it is appreciated that the policy wording has still to be written. However, this is such an important issue that a clear statement of intent should be made in the GCLP now. If developments are proven to have an adverse effect or, applying the precautionary principle, a risk of an adverse effect, then they should only be normally permitted when clear tests are applied. Arguably this should also include being satisfied that applicants have demonstrated that there are no less damaging alternatives they could pursue.

Clarification will also be needed of what tests will be used to determine whether public benefits outweigh adverse impacts on important sites, because an approach solely on a case by case basis could risk a lack of consistency and consequent serious harm to biodiversity interests without sufficient justification. The level of public interest that would need to be demonstrated will also need to be commensurate with the level of interest affected - this is likely be very high if for example, an internationally or nationally important interest is at risk.

AA - Impacts of Recreation on Wicken Fen Ramsar site and Fenland SAC

We have already flagged our concern with the approach to the treatment of recreation effects in respect of the approach to screening for LSEs above. The AA identifies the potential impacts of increased recreational pressure on the Wicken Fen Ramsar site and Fenland SAC and paras 5.43 to paras 5.49 set out proposed mitigation. Para 5.46 states:

‘It is however recommended that the policy is strengthened further by providing a commitment in the plan that any development proposed within 20km of the European site to provide alternative natural greenspace that is specifically designed and managed to alleviate visitor pressure on the European sites. In addition to this, it is recommended that that (sic) the policy outlines the quantity and quality of open space provision and how delivery and management in-perpetuity will be secured’.

This overall commitment is welcomed and we are pleased to see that it concludes the need to manage alternative natural greenspace in perpetuity. However, the success of any mitigation (and ultimately any finding of no risk of any adverse effects) will all depend on alternative green space being delivered in a timely fashion to serve new development in the Cambridge Area. At this point in time that assumption is questionable.

Specifically, proposed new development at Waterbeach, North East Cambridge and Cambridge East will result in a substantial population within approximately 10 miles of these highly sensitive sites. Existing recreational green spaces such as Milton Country Park are already at capacity. Our recent understanding is that the relevant local authorities do not propose to create any new large scale greenspace for North East Cambridge. Whilst the need for such space is accepted, as yet the local authorities have no mechanism to deliver it. Failure to secure and deliver the required open space would thus place the Wicken Fen Ramsar site and Fenland SAC at considerable risk from increased recreational pressure and could not support a HRA finding of no adverse effect.

AA Water Quantity and Water Quality

We have already commented on these issues in respect of the biodiversity and green spaces policies because planning decisions in respect of the supply of water and waste disposal can have a number of profound impacts on both European sites and other important biodiversity interests.

With regard to water quantity it is noted that HRA report indicates potential issues regarding the impacts on European sites within the area and, with respect to mitigation, refers to work of Water Resources East (WRE) and the development of a long-term integrated water management plan (IWMP) for Eastern England.

It is also stated (para 5.60) that:

‘The purpose of this IWMP is to understand the future demand for water in this region, available water supplies, and the options available that will be required to balance supply and demand’.

The HRA also states with regard to the future GCLP at para 5.64 that:

Any new development as part of the GCLP will need to demonstrate water neutrality to ensure no adverse effect on the integrity of European sites susceptible to impacts from water. In part this will be achieved through reduced water demand within specific proposed development. However, this will largely be reliant on the actions of Cambridge Water with support from WRE. To address this, there should be a commitment in the GCLP that new development will need to demonstrate that there will be no adverse effect on the integrity of European sites. This will need to include demonstration that water will be supplied without increasing abstraction beyond the existing agreed rates in the most recent Water Resource Management Plan or reducing the current available headroom, which could result in further detrimental impacts.’

The AA then concludes at para 5.68 (emphasis added):

Subject to the findings of the Greater Cambridge IWMS and WRE IWMP being confirmed and delivered a conclusion of no adverse effect on integrity can be reached. However, in the absence of these studies and in line with a precautionary approach, a conclusion of no adverse effect on integrity cannot be reached in relation to the effect of water quantity on Ouse Washes SAC, SPA and Ramsar site, Wicken Fen Ramsar site, Chippenham Fen Ramsar site, Fenland SAC and Portholme SAC either alone or in-combination until further detail is provided and presented in the GCLP.

We are concerned that potential harmful effects on European sites have yet to be resolved. This also has implications for effects other sites of national and local biodiversity and must be addressed as a matter of urgency if the GCLP is to proceed.

Whilst water availability is, of course, a relevant constraint that the planning system should consider, the capacity of our watercourses to dispose of treated water waste is likely to be a more binding one. Furthermore, consideration must also be given to the climate-change-induced, greater frequency of storm events. Without increased investment by the water authorities the frequency of storm events leading to raw sewerage being discharged is likely to increase, even at current levels of development.

Again it is noted that para 5.71 of the HRA report states:

‘An increase in demand for wastewater treatment as a result of development in the GCLP in combination with neighbouring boroughs and districts in the region has the potential to adversely affect the integrity of European sites that are susceptible to impacts from water.’

The report goes on to highlight three particular areas of concern - increased volumes of treated waste water, overloading of the combined sewer network during storm events with potential for further flooding and contamination and a potential for contaminated surface run off from an increase in the area or urban surfaces and roads.

Mitigation is proposed to address potential water quality impacts through upgrades to Water Recycle Centres (WRC) and relocation of the existing Cambridge WRC. However the HRA report also states at para 5.74 (emphasis added):

At this stage, it is unclear whether there is sufficient capacity available within existing infrastructure and as part of upgrades to WRC to support the increase in wastewater treatment as part of proposed development in the GCLP. It is recommended that exact mitigation measures are informed by the findings of the Greater Cambridge IWMS, including Outline Water Cycle Study and upcoming Detailed Water Cycle Study.

The HRA report continues to note that there is currently limited mitigation in the plan policies that will provide for increased demands in wastewater treatment in the Greater Cambridge area. It is recommended that there is a specific inclusion of wording that outlines that any development will only be permitted where there is sufficient capacity within the WRC infrastructure. As advised by English Nature, the HRA report then indicates there should be specific detail in the GCLP on the mechanism and timescale of delivery for mitigation that will be implemented, also informed by other work on upcoming water plans. The HRA then again concludes at para 5.76 (emphasis added):

Subject to the findings of the Greater Cambridge IWMS being confirmed and delivered a conclusion of no adverse effect on integrity can be reached. However, in the absence of this study and in line with a precautionary approach, a conclusion of no adverse effect on integrity cannot be reached in relation to the effect of water quality on Ouse Washes SAC, SPA and Ramsar site, Wicken Fen Ramsar site, Chippenham Fen Ramsar site, Fenland SAC and Portholme SAC either alone or in-combination until further detail is provided and presented in the GCLP.

Again, as with the water quantity issue, we are concerned that potential harmful effects on European and other important biodiversity sites have yet to be resolved and that this must be addressed as a matter of urgency if the GCLP is to proceed.

Next Steps

Finally we note and appreciate the point made regarding next steps at para 6.6 that the HRA is an iterative process and is expected to be updated. We will of course comment on further information when this is available. We still remain concerned however, that fundamental issues such as the impacts of recreation and water as described above are still to be resolved.

We support the vision statement “for the well known characteristics of the historic core of Cambridge to be complemented by active, compact neighbourhoods – new and old. This means providing opportunities to regenerate areas that aren’t yet reaching their potential, and creating new city neighbourhoods which have the critical mass of homes, jobs and services to create thriving communities, making best use of brownfield and safeguarded land.”

We support the vision that the New Towns agreed in the 2018 plan must develop into great places to live and work. However this vision should also recognise the essential role that cultural and leisure activities play in creating great places (we suggest the inclusion of the word “play”). This will also be essential in order to take pressure off of Cambridge, which will not be able to cope if it is to serve the leisure needs of the additional 73,000 population created by this plan.

We appreciate that this is not a draft plan and we very much hope that the draft plan will set out an inspiring vision for what greater Cambridge will become - and that this vision recognises the importance of landscape, heritage and nature in continuing to ensure that Cambridge is a special place to live, work, study and visit.

We very much welcome and support the efforts to make this a much greener plan than those that have come before it and there is much that is to be commended. However, large scale new development is not yet zero-carbon or genuinely sustainable and therefore the more of it you have the more harm you inflict upon the environment, heritage and local communities – and the greater the challenges and costs of addressing those problems. There seems to us, to be a contradiction between the scale of development proposed and the aspirations for the environment, heritage and local communities.

If the councils are to proceed with such a significant level of development (equivalent to building two Bury St Edmunds in 20 years) it is essential that the policies in the plan are as strong as they can possibly be in order to protect and benefit the environment, heritage and local communities. The draft plan will also need to put in place the mechanisms to ensure that development results in the financial investment that will be needed to protect and benefit the environment, heritage and local communities. We are concerned that currently there are not sufficient mechanisms to achieve this. For example ensuring that all development contributes towards increasing the provision of large-scale green spaces so that the amount of this essential resource keeps pace with population growth. Significant investment is needed in environmental infrastructure such as water supply, sewage treatment and waste treatment.

We object to the scale of growth proposed due to the lack of available water supply to support human needs without damaging the River Cam and its tributaries, including chalk streams. This includes impacts on water quality. We welcome that you have recognised this as an environmental limit to growth and that if it is not resolved the plan will not be found sound. Even if the water industry plans are put in place to address this problem prior to the Local Plan going for public examination, there will remain the risk that the water industry plans are delayed or not fully delivered. Therefore, you will need to set out in the draft plan how you intend to deal with this scenario.

Following the designation of our area as “water stressed” and the new evidence that has been obtained through your work, we are very concerned that the level of growth already in the 2018 Local Plan is beyond the environmental limits of our water supply. Water industry plans include reducing household consumption, and whilst this is in theory achievable it may not be achieved in practice. We would like to see policies or mechanisms within the draft Plan that set out how development approvals will be aligned to improvements in water supply, and what will happen if those improvements are not achieved. This is to avoid development running ahead at a faster pace than water supply improvements.

Accurately predicting future jobs and employment space, and their relationship to housing at the current time is incredibly difficult:
• The impact of Brexit on the local economy is not yet known. Many scientific and research projects were part funded by the EU.
• Some large employers are leaving Cambridge (Marshalls and the County Council).
• Hybrid/home-working will change the dynamic between where people work and where they live, this is likely to have a number of consequences for planning:
- hot-desking will increase in offices meaning that individual office buildings will support larger numbers of workers/jobs, this could decrease the amount of floor space required.
- People will commute fewer days per week and therefore will tolerate longer commutes in order to take advantage of cheaper housing (eg to afford home office space and/or garden space). On one hand this may make it harder for new housing in greater Cambridge to compete with cheaper housing further away. On the other there may be additional demand close to Cambridge for London commuters. Either way, it is unlikely that the aspiration to co-locate jobs and housing in Greater Cambridge will be achieved.
• The 2021 census might have given some answers but unfortunately this was carried out during the pandemic, meaning that an important source of planning information will not help as it should have.

Given such uncertainty, it is unlikely that the objectively assessed needs will be accurate. Therefore it is essential that there is ability within the plan to review and make adjustments over time to reflect reality. One danger is that employment land allocated for new towns is unused and applications are made for residential development instead, meaning that these settlements become residential dormitories contrary to the vision set out in the plan. As an example, we are aware that employment sites in Haverhill are now being used for residential, placing greater commuting burden on our area.

In 2019 we met with senior planning officers from East Cambs District Council. They were clear that housing provision in their district was providing housing overspill for Cambridge. They also want to create liveable communities that include employment but they reported that they were struggling to bring forward employment sites for development in places like Ely because of supply and demand provision in Cambridge. There is clearly a strong relationship between greater Cambridge and East Cambs and other market towns in terms of housing and employment provision and we would like to better understand what work has taken place to co-ordinate planning for this.

Broadly we support the spatial strategy for locating new development:

The policy of development in a relatively small number of large new settlements, rather than green belt release or a scatter-gun approach across all the villages of South Cambs is supported.

The policy of seeking to keep Cambridge a compact city through support for its green belt against city fringe expansion is supported, however we object to two areas of green belt release.

The sustainability of this strategy will depend on the adequacy of the transport links between the new settlements and the main centres of employment. Northstowe is served by the guided busway (both public transport and active travel), Waterbeach New Town will be served by rail and a new greenway and ‘greater Cambourne’ will be served by East-West Rail and a new greenway. Some of the plans by the Greater Cambridge Partnership to provide busways to these settlements and employment sites would be damaging to the green belt, landscape, ecology and heritage and are not supported.

The transport modelling for the Preferred Option assumes that Cambridge would need to increase the number of Park & Ride parking spaces from just over 7,000 now to over 26,000 in 2041 (Table 41 in the Transport Evidence report: 20,687 Park & Active trips plus 32,239 Park & Ride trips). This is acknowledged nowhere in the draft Local Plan policies, despite it potentially harming the landscape and ecology of the green belt far more than the proposed new and extended settlements.

The settlement hierarchy is generally supported.

We know that a number of sewage treatment facilities upstream from Cambridge are unable to cope during periods of high rainfall (discharging raw sewage) and they are also contributing towards failing water quality by discharging pollution into water courses with low volume flows. We would like to see a policy that ensures that further development in any villages served by such sewage treatment works should be conditional upon improvements to those facilities, so that new development is not making the present situation any worse.

We support this approach in general.

In relation to “Outside settlement boundaries, we propose that no development would be permitted except for - development for agriculture, horticulture, forestry, outdoor recreation and other uses that need to be located in the countryside”. Changes to permitted development rights mean that some of these uses could subsequently be converted into residential or other employment uses, effectively circumventing the policies within the Local Plan. We would like to see a policy within the Local Plan that requires any such permissions to be conditional that they cannot be subject to a permitted change of use and that any change of use would require a planning application

CambridgePPF is concerned about the capacity of the Cambridge Urban area to accommodate the scale of proposed growth, an additional 73,000 people. We are particularly concerned about the inadequate space in the historic city streets and city centre public realm to cater for existing people movement (vehicular, cyclists, pedestrians) – and the ability of the complex local government system to deliver effective solutions (City Council, Cambs County Council, C&P Combined Authority, Greater Cambridge Partnership). The 2018 Local Plan included a requirement for an SPD to address this problem but at the start of 2022 limited progress has been achieved.

There are many things to commend in the environmental aspirations for this development but disappointingly the provision on natural greenspace is not one of them.

The amount of informal green space meets the minimum amount required by the council’s policies but two thirds of this is provided on a business park, described on p26 of the NECAAP Open Spaces Report as “these green spaces aren’t perceived as being accessible to the wider public”. Would you want to visit a business park for your leisure and recreation? It should be noted that the green space on the business park already exists, so it is not new space.

Only a third of the green space is provided in conjunction with the housing. Most of this is provided as linear green space or pocket parks, in other words small areas of green space that are loomed over by high-rise buildings. There is one larger park but the size of this is not provided in any of the documents. Extrapolating from the plans, we estimate this to be around 3.5 ha in size. Fig 20 in the AAP report includes an infographic which aims to compare the amount of open space in the AAP with other Cambridge parks, the comparison is misleading because the parks which are used for comparison are just that, parks. A better comparison would be the main park proposed for the new development. At 3.5ha this is small in comparison to the other parks, given that it is to cater for 16,000 people.

At a bare minimum the proposals for the AAP might possibly just provide for the day-day open space needs of the new residents: play space for children, somewhere to walk the dog or kick a ball about. But what it won’t do is provide the kind of green spaces that people in high density developments need access to – which is large natural greenspace: somewhere they can go for a long walk or run, experience nature, and escape the pressures of urban life.

There is of course somewhere for them to do that, it is Milton Country Park and a subway is proposed under the A14 so that residents can get to it. And that is exactly where the 16,000 people will go. That would be great if it were not for the fact that the Country Park is already at capacity and cannot cope with 16,000 more visitors.

In the hundreds of pages of text for the NECAAP there is almost no mention of Milton Country Park at all, let alone of it meeting the needs of the development. There has been no assessment of whether the country park has the capacity to cope and what mitigation might be required to enable it to do so. We could see no requirement for S106 contributions to support the park to cope only this rather vague paragraph on p54 of the NECAAP Open Spaces & Recreation Topic Paper:
"There is a need to build in community resilience and capacity into the existing open space provision for NEC. Alongside any on-site provision, opportunities to use S106 contributions outside the city on large-scale green infrastructure should be considered. This will avoid pressure building up on existing parks, open spaces and cycleways, which might otherwise lose their biodiversity and other qualities. For example, undertaking negotiations for specific S106 contributions, for growth sites straddling the Cambridge/South Cambridgeshire boundary. These could explore opportunities for improving existing or creating new parks beyond the city which are easily accessible by foot and cycle, in order to avoid over-investment in, and over-use of popular or environmentally sensitive sites."

Natural England’s Accessible Natural Greenspace Standards would require the NECAAP development to have a large 100 hectare site of accessible natural greenspace within 5km. Especially as this development is to be largely car free. But there isn’t one. To make matters worse, the north of Cambridge will also see 20,000 people at Northstowe and 22,000 at Waterbeach. Where will these 58,000 people go to meet their green space needs?

This is an area which has been highlighted in the Green Infrastructure evidence base for the Local Plan as already suffering from a deficit of green infrastructure and recreational pressure. This report highlights North East Cambridge to Waterbeach as a priority area for green infrastructure with its enhancement marked as of ‘critical importance’.

The only option for providing that critical greenspace is through the North East AAP and therefore it is essential that s106 contributions are secured towards this.

Failure to do so will result in increased recreational pressure on European Protected Sites/ Habitats Directive (ie Wicken Fen Special Area of Conservation). Please see our response to the Local Plan Habitats Regulations Assessment.

S/OA/NR Newmarket Road Retail Park
S/OA/BC Beehive Centre
Cambridge Past, Present & Future strongly supports the inclusion of these two new opportunity areas. Combined, they include some 25 acres of surface parking. If a multi-storey car park was built on a small portion of this land, some 20 acres could be released for development. Cambridge Past, Present & Future submitted an outline proposal for the re-development of the car parking area on both sides of Coldhams Lane during the public consultation for the 2018 Local Plan. This showed how the site could accommodate 1200 dwellings with only a marginal loss of car parking space through the provision of a multi-storey facility and by allowing parking beneath the residential blocks which were raised on columns.

When progressing the development opportunities for these sites, access to green space must be included in any schemes.

We also request that you include an adjacent area as part of these two New Opportunity Areas and this is marked in orange on the diagram attached.
There are two reasons for requesting for this inclusion:
1. It is a similar land use to the other two areas and in the same location and therefore the same principles apply.

2. We have seen a number of planning applications coming forward in this area. These are being dealt with on a piecemeal basis with all the associated problems of piecemeal development. This is not an area of high quality design and is negatively impacted by Newmarket Road. A strategic planning approach is required to ensure that any planning applications contribute towards improving public realm and the overall improvement of the area.

As the Local Plan is progressed, the evidence supporting it and the resulting policies must take a holistic view of the combination of different elements, including the historic and natural environment, which make up the character of Greater Cambridge. This is particularly important when considering the edge of Cambridge and the Green Belt. When identifying land for development, how highly land performs against the functions of the green belt must also be considered against the value of the land for its built and natural heritage.