Greater Cambridge Local Plan Preferred Options

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Comment

Greater Cambridge Local Plan Preferred Options

CC/FM: Flooding and integrated water management

Representation ID: 58773

Received: 13/12/2021

Respondent: Wates Developments Ltd

Agent: Boyer Planning

Representation Summary:

Policy CC/FM states development will be directed to areas with least likelihood of flooding from all sources and takes into account climate change. Development will be required to provide integrated water management, including SuDS. Land to the East Side of Cambridge Road, Melbourn proposes to include multifunctional SuDS and an integrated water management system.

Assessment identifies current over-abstraction of Chalk aquifer is having detrimental impact on environmental conditions. Development will need to adhere to ambitious water efficiency targets and no growth strategy that has a lesser water usage impact.

Utilising recycling systems, Assessment suggests large sites are able to successfully use recycling to reduce demand for potable water. Disagree. New development (regardless of scale) is able to adopt rainwater recycling systems. Land to the East Side of Cambridge Road, Melbourn, can adopt rainwater recycling system if required.

Assessment also identifies potential for introducing flood management and SuDS schemes to deliver multifunctional benefits including biodiversity enhancements. Land to the East Side of Cambridge Road, Melbourn can deliver.

Overall, Assessment recommends growth be concentrated in new settlements or urban extensions that avoid high flood risk and have high standards for design of flood risk management, water usage and re-use, and blue-green infrastructure. Follows a Location Opportunities and Constraints Categorisation and Scoring which assesses and scores each proposed growth strategies.

Disputed why development within the Minor Rural Centres and Group Villages have been disregarded as an appropriate growth strategy if they are able to meet ambitious water usage targets and implement water recycling systems.

Full text:

Policy CC/FM states that development will be directed to the areas with the least likelihood of flooding from all sources and taking into account climate change. The Policy also states that development will be required to provide integrated water management, including SuDS.
Land to the East Side of Cambridge Road, Melbourn is proposed to deliver a scheme that implements SuDS and an integrated water management system that takes into account climate change. Such SuDS will also be multifunctional, providing both biodiversity and amenity benefits.


The Greater Cambridgeshire Local Plan is supported by a Greater Cambridge Local Plan Strategic Spatial Options Assessment (November 2020).
The Assessment identifies that current over-abstraction of the Chalk aquifer is having a detrimental impact on environmental conditions. It acknowledges that none of the Councils’ growth strategies offer an opportunity to mitigate the existing detrimental impacts and there is no environmental capacity for additional development in the new Local Plan to be supplied with water by increased abstraction from the Chalk aquifer.
Major new water supply infrastructure is proposed and will be operational in mid-2030s, however, development in the interim will need to reduce abstraction through the implementation of ambitious targets for water efficiency. Such targets will be required to be addressed across all new developments.
It is understood that all development within Greater Cambridgeshire will need to adhere to such ambitious water efficiency targets and therefore there is no growth strategy that has a lesser water usage impact than another.
In so far as utilising recycling systems, the Assessment suggests that large sites are able to successfully use recycling to reduce demand for potable water. We disagree with this statement. Whilst retrofitting developments may be expensive, new development (regardless of scale) is able to adopt rainwater recycling systems. It is unclear why the statement specifically restricts water recycling usage to “large developments”. Land to the East Side of Cambridge Road, Melbourn, is able to adopt a rainwater recycling system if this is a requirement set by Local Policy.
The Assessment also identifies the potential for introducing flood management and SuDS schemes to deliver multifunctional benefits including biodiversity enhancements. Land to the East Side of Cambridge Road, Melbourn presents an opportunity for delivering a scheme which includes SuDS that provide multifunctional benefits including an opportunity to benefit and enhance designated wildlife sites.
Overall, however, the Assessment recommends that growth should be concentrated in new settlements or urban extensions that avoid high flood risk and have high standards for the design of flood risk management, water usage and re-use, and blue-green infrastructure.
This recommendation follows a Location Opportunities and Constraints Categorisation and Scoring which assesses and score each of the proposed growth strategies.
Minor Rural Centres (including Melbourn) are assessed as having a red rating for flood risk due to potential existing fluvial flood and surface water flood risk. Wastewater and Quality are assessed as amber, subject to local WRC capacity. The red flood risk rating is despite Paragraph 4.2.1 of the Assessment stating “flood risk does not differentiate between the growth scenarios”.
Land to the East Side of Cambridge Road, Melbourn is located within Flood Zone 1 with low risk of surface water flooding. In this regard the Site should be assessed as having a Green or Amber Flood Risk rating. In either instances, the Site should be given a total constraints score of -6. This score would result in the same overall scoring as the proposed recommended growth strategy of locating growth within new settlements or urban extensions. This amendment would also introduce the summary of “Good Opportunities” thereby also improving the overall combined constraints and opportunities score for development within Minor Rural Centres and Group Villages.
It is therefore disputed as to why development within the Minor Rural Centres and Group Villages have been disregarded as an appropriate growth strategy if they are able to meet the ambitious water usage targets and implement water recycling systems.

Comment

Greater Cambridge Local Plan Preferred Options

CC/CE: Reducing waste and supporting the circular economy

Representation ID: 58780

Received: 13/12/2021

Respondent: Wates Developments Ltd

Agent: Boyer Planning

Representation Summary:

Policy CC/CE states that developments should be supported by a Construction Environmental Management Plan, which should include an outline of the approach to site waste management and how construction waste will be addressed following a waste hierarchy.

It should be acknowledged that CEMPs are usually prepared at a detailed design stage when the site layout is secured. This will need to be recognised appropriately through the future Policy wording to ensure that the future Policy is effective.

Full text:

Policy CC/CE states that developments should be supported by a Construction Environmental Management Plan, which should include an outline of the approach to site waste management and how construction waste will be addressed following a waste hierarchy.

It should be acknowledged that CEMPs are usually prepared at a detailed design stage when the site layout is secured. This will need to be recognised appropriately through the future Policy wording to ensure that the future Policy is effective.

Comment

Greater Cambridge Local Plan Preferred Options

BG/BG: Biodiversity and geodiversity

Representation ID: 58787

Received: 13/12/2021

Respondent: Wates Developments Ltd

Agent: Boyer Planning

Representation Summary:

The proposed policy direction requires development to achieve a minimum 20% biodiversity net gain. It is considered that the baseline for this policy should be a minimum of 10% in accordance with Schedule 7A, Part 1 of the Environment Act 2021. The policy could be worded to strive for 20% biodiversity net gain, or require certain site allocations to provide this percentage subject to appropriate assessment that this is realistic, however it is not considered robust to set 20% as the plan-wide requirement.
Land to the East Side of Cambridge Road will provide extensive areas of open space, which will deliver amenity benefits together with biodiversity net gains in the form of habitat creation secured through a landscape strategy.

Full text:

The proposed policy direction requires development to achieve a minimum 20% biodiversity net gain. It is considered that the baseline for this policy should be a minimum of 10% in accordance with Schedule 7A, Part 1 of the Environment Act 2021. The policy could be worded to strive for 20% biodiversity net gain, or require certain site allocations to provide this percentage subject to appropriate assessment that this is realistic, however it is not considered robust to set 20% as the plan-wide requirement.
Land to the East Side of Cambridge Road will provide extensive areas of open space, which will deliver amenity benefits together with biodiversity net gains in the form of habitat creation secured through a landscape strategy.

Comment

Greater Cambridge Local Plan Preferred Options

Biodiversity and green spaces

Representation ID: 58788

Received: 13/12/2021

Respondent: Wates Developments Ltd

Agent: Boyer Planning

Representation Summary:

It is acknowledged that biodiversity and green spaces are important and it is welcomed that this section recognises that development can support on and off-site enhancements for biodiversity and can protect and provide new green spaces for nature.

Land West of London Road, Fowlmere proposes large swathes of public open space which will also contribute to on-site enhancements for biodiversity.

Full text:

It is acknowledged that biodiversity and green spaces are important and it is welcomed that this section recognises that development can support on and off-site enhancements for biodiversity and can protect and provide new green spaces for nature.

Land West of London Road, Fowlmere proposes large swathes of public open space which will also contribute to on-site enhancements for biodiversity.

Comment

Greater Cambridge Local Plan Preferred Options

BG/BG: Biodiversity and geodiversity

Representation ID: 58793

Received: 13/12/2021

Respondent: Wates Developments Ltd

Agent: Boyer Planning

Representation Summary:

The proposed policy direction requires development to achieve a minimum 20% biodiversity net gain. It is considered that the baseline for this policy should be a minimum of 10% in accordance with Schedule 7A, Part 1 of the Environment Bill 2021. The policy could be worded to strive for 20% biodiversity net gain, or require certain site allocations to provide this percentage subject to appropriate assessment that this is realistic, however it is not considered robust to set 20% as the plan-wide requirement.

Full text:

The proposed policy direction requires development to achieve a minimum 20% biodiversity net gain. It is considered that the baseline for this policy should be a minimum of 10% in accordance with Schedule 7A, Part 1 of the Environment Bill 2021. The policy could be worded to strive for 20% biodiversity net gain, or require certain site allocations to provide this percentage subject to appropriate assessment that this is realistic, however it is not considered robust to set 20% as the plan-wide requirement.

Comment

Greater Cambridge Local Plan Preferred Options

WS/HD: Creating healthy new developments

Representation ID: 58797

Received: 13/12/2021

Respondent: Wates Developments Ltd

Agent: Boyer Planning

Representation Summary:

We support the principle of Policy WS/HD, which states that good physical and mental health is related to good quality housing and development.
We also recognise the ten principles for creating healthy places.

Full text:

We support the principle of Policy WS/HD, which states that good physical and mental health is related to good quality housing and development.
We also recognise the ten principles for creating healthy places.

Comment

Greater Cambridge Local Plan Preferred Options

WS/HD: Creating healthy new developments

Representation ID: 58800

Received: 13/12/2021

Respondent: Wates Developments Ltd

Agent: Boyer Planning

Representation Summary:

We support the principle of Policy WS/HD, which states that good physical and mental health is related to good quality housing and development.

We also recognise the ten principles for creating healthy places developed from the Healthy New Towns initiative and referenced in this Policy.

Land West of London Road, Fowlmere will contribute to good physical and mental health, both in accordance with the ten principles for creating healthy places and the Building for a Healthy Life principles, through promoting the features of a “20 minute neighbourhood” through existing local facilities and offering social, leisure and recreational opportunities a short walk or cycle from occupiers’ homes.

Full text:

We support the principle of Policy WS/HD, which states that good physical and mental health is related to good quality housing and development.

We also recognise the ten principles for creating healthy places developed from the Healthy New Towns initiative and referenced in this Policy.

Land West of London Road, Fowlmere will contribute to good physical and mental health, both in accordance with the ten principles for creating healthy places and the Building for a Healthy Life principles, through promoting the features of a “20 minute neighbourhood” through existing local facilities and offering social, leisure and recreational opportunities a short walk or cycle from occupiers’ homes.

Comment

Greater Cambridge Local Plan Preferred Options

H/AH: Affordable housing

Representation ID: 58801

Received: 13/12/2021

Respondent: Wates Developments Ltd

Agent: Boyer Planning

Representation Summary:

It is acknowledged that the First Proposals include a requirement for 40% affordable housing on sites of 10 or more dwellings.
This is higher than the adopted Cambridge Local Plan approach of seeking 25% affordable homes on sites of 10-14 dwellings and 40% affordable homes on sites of 15 dwellings or more, however, we acknowledge there is an affordability issue within the Greater Cambridgeshire area which justifies the amended policy approach.
By proposing additional small to medium sized allocations within the Greater Cambridge area, including within the more rural Villages, this will ensure the delivery of affordable is housing dispersed across the wider area, providing a choice of affordable homes for future occupiers.

Full text:

It is acknowledged that the First Proposals include a requirement for 40% affordable housing on sites of 10 or more dwellings.
This is higher than the adopted Cambridge Local Plan approach of seeking 25% affordable homes on sites of 10-14 dwellings and 40% affordable homes on sites of 15 dwellings or more, however, we acknowledge there is an affordability issue within the Greater Cambridgeshire area which justifies the amended policy approach.
By proposing additional small to medium sized allocations within the Greater Cambridge area, including within the more rural Villages, this will ensure the delivery of affordable is housing dispersed across the wider area, providing a choice of affordable homes for future occupiers.

Comment

Greater Cambridge Local Plan Preferred Options

I/ST: Sustainable transport and connectivity

Representation ID: 58806

Received: 13/12/2021

Respondent: Wates Developments Ltd

Agent: Boyer Planning

Representation Summary:

We acknowledge and support the Councils’ commitment to delivering sustainable and inclusive communities “by minimising the need to travel and reducing travel distances, whilst ensuring there is effective and sufficient sustainable transport mode choice and improved connectivity for everyone of any ability”.
Land to the East Side of Cambridge Road offers connectivity across the pedestrian and cycle network, public transport and road network. Development of the Site fully aligns with the Councils’ commitment to delivering sustainable and inclusive communities, promoting walking and cycling and directing development to sustainable locations.

Full text:

We acknowledge and support the Councils’ commitment to delivering sustainable and inclusive communities “by minimising the need to travel and reducing travel distances, whilst ensuring there is effective and sufficient sustainable transport mode choice and improved connectivity for everyone of any ability”.
Land to the East Side of Cambridge Road offers connectivity across the pedestrian and cycle network, public transport and road network. Development of the Site fully aligns with the Councils’ commitment to delivering sustainable and inclusive communities, promoting walking and cycling and directing development to sustainable locations.

Comment

Greater Cambridge Local Plan Preferred Options

GP/PP: People and place responsive design

Representation ID: 58807

Received: 13/12/2021

Respondent: Wates Developments Ltd

Agent: Boyer Planning

Representation Summary:

The Draft Policy states that new development should positively contribute to their context, improve Greater Cambridge’s connectivity, support the climate emergency, and enhancing the character of Greater Cambridge.

Land West of London Road, Fowlmere will deliver a scheme that responds and supports the climate emergency through the introduction of sustainable construction methods, adopting renewable energy and maximising water efficiency. In so far as enhancing the character of Greater Cambridge, the Site proposes to include a Village Park, which will provide multifunctional benefits, promoting social cohesion and providing a biodiversity net gain.

Full text:

The Draft Policy states that new development should positively contribute to their context, improve Greater Cambridge’s connectivity, support the climate emergency, and enhancing the character of Greater Cambridge.

Land West of London Road, Fowlmere will deliver a scheme that responds and supports the climate emergency through the introduction of sustainable construction methods, adopting renewable energy and maximising water efficiency. In so far as enhancing the character of Greater Cambridge, the Site proposes to include a Village Park, which will provide multifunctional benefits, promoting social cohesion and providing a biodiversity net gain.

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