Greater Cambridge Local Plan Preferred Options

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

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

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

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

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

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

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

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

Inadequate Water Supply

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

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

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

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

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

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

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

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

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

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

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

Green Belt Assessment

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Inadequate Water Supply

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

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

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

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

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

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

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

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

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

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

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

Green Belt Assessment

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Inadequate Water Supply

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

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

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

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

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

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

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

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

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

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

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

Green Belt Assessment

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Inadequate Water Supply

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

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

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

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

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

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

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

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

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

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

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

Green Belt Assessment

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Inadequate Water Supply

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

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

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

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

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

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

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

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

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

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

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

Green Belt Assessment

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Inadequate Water Supply

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

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

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

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

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

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

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

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

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

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

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

Green Belt Assessment

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Inadequate Water Supply

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

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

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

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

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

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

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

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

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

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

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

Green Belt Assessment

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Inadequate Water Supply

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

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

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

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

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

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

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

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

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

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

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

Green Belt Assessment

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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