Greater Cambridge Local Plan Preferred Options

We welcome this policy. Clearly, co-ordination between this policy and the Minerals and Waste Plan will be essential to avoid policy gaps and ensure the necessary infrastructure is in place to handle this recycling stream.
We are interested to know how small-scale projects (including incremental renovation works and retrofitting)
can be brought within this policy. The regular sight of skips filled with materials which could be recycled along with offcuts of new building materials demonstrates that action is needed.

We strongly welcome this policy because protecting carbon stocks is critical to averting climate disaster. We urge that this policy does not focus solely on peatland but on all land-based carbon stocks (as set out in Natural England Research Report NERR094 which we note is one of the studies cited). Grassland (including urban green spaces), scrub, hedgerows etc all store carbon.
We would also reiterate the important distinction between a carbon sink (actively drawing down carbon from the atmosphere) and a carbon stock (carbon that is already locked away). It is vital to protect our carbon stocks even if they are not currently carbon sinks (see also our response under Climate Change - general
comments).

We support the proposal for 20% Biodiversity Net Gain (BNG, twice the national requirement of 10%), which recognises the poor starting point for biodiversity in the region, and support the policy that development should be required to achieve BNG. However:
● The outputs of the BNG calculation must always be ‘sense-checked’ by suitably qualified ecologists. Otherwise, we are concerned that over-reliance on the metric could lead to undesirable results. The metric has a number of flaws, a key one being that it favours habitats that are quick and easy to create, not necessarily those that have the greatest wildlife or climate benefit. Furthermore, it does not account for indirect impacts of development on habitats and species.
● The policy allows off-setting to take place off-site. Given that (as stated in the Council’s webinar) net gain is unlikely to be achievable “on-site” in most cases, the target itself starts to look meaningless. For example, quick gains in the Biodiversity Metric can be achieved by improving the measured condition of existing large biodiversity sites. While a desirable outcome in itself, this must not be used to compensate for the loss of a biodiversity site to development. It is important that the net result of this policy is not to ‘concentrate’ biodiversity in fewer sites. An increase in the total area of green space, with appropriate biodiversity, is necessary for improving ecological connectivity and climate resilience, and for balancing the objectives of nature recovery and improving people’s access to green space.
● New habitats created as part of the net gain approach need to be explicitly protected from development in future rounds of planning. In the government’s proposed implementation of BNG, new sites are only required to be protected for 30 years, but this time limit is inappropriate. It can take more than 30 years for a range of habitats to develop on a newly created site. For example, Trumpington’s two country parks, now almost 14 years old, are still developing to their full potential and already under threat from the Cambridge South station development. International guidance is that areas recognised as needing protection for their biodiversity should be accorded this “in perpetuity”.
● We are very concerned by the statement that “development proposals adversely affecting sites of
biodiversity or geological importance will not normally be permitted”. This policy should be much more strongly worded – it will be very difficult to assess/measure with
any certainty situations where “public benefits significantly outweigh any adverse impacts” – and we think that the proposed wording will provide a major loophole for developers to damage biodiversity. The flaws in the cost/benefit approach have been amply illustrated elsewhere in the country – for example by proposals to build a theme park on top of the Swanscombe Marshes SSSI, or to drain and build over an area of Portsmouth Harbour despite it holding every level of statutory wildlife protection. To address concern, we call for, at minimum, a strong policy statement that all existing designated sites
(with either national or local designation) remain protected and undeveloped. The development of such sites must not be considered under a cost/benefit analysis approach: it is not possible to weigh factors such as job creation against the irreversible loss of these special places. The consultation document itself makes it clear that, “National planning policy requires us to protect and enhance sites of biodiversity and geodiversity importance”, and this should be a fundamental policy within the Local Plan. The topic paper for biodiversity states “…we consider that additional clarity is required to set out how the principles [i.e. the requirement that sites of biodiversity importance are protected] set out in national policy should be applied at a local level” and this point needs to be addressed in the Local Plan.

This policy direction is very ambiguously explained and, although the policy itself is generally good, it will need much greater clarification to avoid misinterpretation by developers and those assessing planning applications. The thrust of the policy should be very clearly related to the policies on Great Place/Climate Change. We are not clear how this policy interacts with the open space standards referred to in BG/EO but would strongly advocate for specific targets to be set for the provision of the different types of Green Infrastructure wherever possible (see also our comments under BG/EO).
1st bullet: GI to be “appropriate to its local context” – we agree with this general direction but this phrase should be clarified.
2nd bullet (Supporting delivery of biodiversity net gain, including by providing links between habitats within and beyond the site boundary, and connecting where appropriate to the wider ecological network ) – we agree with this in general but again it should be worded more clearly. We welcome the recognition of the need for a ‘bigger, better, more joined up’ approach which is now an accepted biodiversity principle, but we are concerned by the phrase ‘carefully balancing the needs of wildlife and people’ which would be very difficult to define in practice.
5th bullet (Enhancing access and connectivity) – we think this has the same meaning/intention as 2 and 3 and so could be deleted to reduce complexity.
6th and 7th bullets (Providing environmental enhancement; and Supporting climate mitigation and
adaptation) need further explanation with perhaps an example, so that these general statements are comprehensible in the context of the Local Plan.
Within this GI policy, we would like to see a clear statement that provision of green space (one of the forms
of GI) should respect the Natural England Accessible Natural Greenspace Standards (which have been used in Suffolk and Shropshire). These standards are that green space should:-
● Be at least 2 ha in size, and no more than 300 metres (5 minutes walk) from home; and
● Include at least:
○ one accessible 20 ha site within two km of each home;
○ one accessible 100 ha site within five km of each home; and
○ one accessible 500 ha site within ten km of each home;
In addition, the Standards call for a minimum of one ha of statutory Local Nature Reserves per thousand population.
We support the policy direction that development should meet the GI Standard given in Building with Nature.
We support most of the final components of this policy, including the list of strategic GI initiatives, but are unclear what is meant by the five “dispersed initiatives” and how development can contribute to these in practice.
We support the policy of Expanding Greater Cambridge’s ‘urban forest’. The tree and hedge cover in the Greater Cambridge area is too low and thus we are pleased to see projects to increase this. See also our response to BG/TC.
We are pleased to see Allotments and Community Gardening listed in this section. Allotments can contribute to a number of policy targets, including under climate change, biodiversity and green space, wellbeing and great places. There is a large unmet demand for allotments in Cambridge, as evidenced by long waiting lists. The current standard for allotment provision in new settlements in both the Cambridge and South Cambridgeshire local plans is 0.4 hectares per 1000 residents. To ensure the demand for allotments is met across Greater Cambridge, we need an assessment of current levels of provision, and a plan (encompassing both existing and planned settlements) to achieve this level of provision everywhere.
Adequate quality of provision must also be included in the standard, for example on-site water supply (ideally using harvested rainwater or other suitable supply rather than potable water), provision of accessible plots for disabled allotment holders, and the possibility for appropriate structures such as sheds and polytunnels to be incorporated into allotment sites.

We support this policy and are pleased to see that it is worded in terms of outcomes (tree canopy cover) rather than inputs (e.g. number of trees planted).
We would like to see the policy require that best practices in the selection of tree species are followed, e.g. taking into account concerns such as maximising biodiversity benefits; ensuring resilience of the tree population to drought, disease, storm winds; avoiding problems such as allergen production or roots creating hazards, etc. [1]
We welcome the policy direction “provide sufficient space above and below ground for trees and other vegetation to mature”. The layout of tree planting and the amount of space given to each tree is an important determinant of tree survival - trees standing alone, and with limited space for root development or rainwater interception, are more susceptible to damage from wind or drought - as was seen at the Grafton Centre where many of the trees that were planted did not survive long.
We strongly support the fact that the first five bullet points are about “protecting” existing trees on a development site. We therefore caution that the qualification of “when felling proves necessary” will need very careful definition: felling should only be undertaken in exceptional circumstance (e.g when necessary for public safety or protecting property) and, if essential, should only be undertaken at a time of year when it does not damage wildlife such as nesting birds. A frequent cause of tree felling is shading of gardens and developers should be required to think long term about shade-casting when selecting tree species and planting locations.
[1] See for example https://www.forestresearch.gov.uk/tools-and-resources/fthr/urban-tree-manual/

We strongly support the need to protect river corridors. This policy will need precise and clear definition to
ensure that it is enforceable.
We welcome projects that aim to partially renaturalise the Cam by restoring flood plains and habitats, for
example at Logan’s Meadow, Stourbridge and Jesus Green. Such projects should be prioritised because of
their potential to benefit wildlife and water quality while helping reduce flood risk. We support the goal of
improving people’s access to high quality green spaces, but care must be taken that multiple uses of the
river and its corridor do not threaten its environmental value. The possible damage to vital habitats by high
numbers of visitors is recognised in the evidence document; Greater Cambridge Green Infrastructure
Opportunity Mapping (2020).

We understand that this policy is about protecting existing open spaces but the lack of direction and information associated with it makes it impossible to comment on. Policy to protect existing open spaces is extremely important, especially given that in recent years so many open spaces, including many of those specifically listed and supposedly protected under the two current Local Plans for the City and South Cambridge have been threatened or damaged [1]. We request a clearly worded policy so that we can assess and comment on it.
[1] See for example https://cambridge.greenparty.org.uk/news/local-greens-object-to-development-stmatthews-
piece.html

We welcome many aspects of the policy relating to the need for new, larger and enhanced open spaces, but as written it potentially could lead to more green lawns with scattered trees, lacking wildlife habitat and biodiversity, landscape appeal and other genuine amenity value found in many recent new developments.
We support the need for open space for all the activities mentioned, with an understanding that such spaces should be managed wherever possible to maximise biodiversity (reduced grass mowing, zero pesticide use, planting of trees and hedges and wildflower areas).
The policy direction under BG/GI should also apply here – development should require open space:
● “As an integral part of the development, so that it informs the overall development design. This should include identifying, retaining and enhancing existing natural features of value.
● Across all phases of development.
● To be successful for the lifetime of the development, including providing plans for management, maintenance and funding.”
We agree that multi-functionality is useful where appropriate, but this should not be used as an opportunity to reduce the overall amount of open space made available - most green spaces are not suitable for all activities (for example, allotments and sports pitches). To maximise benefits to both people and wildlife, it is
important to provide a diverse range of green spaces. Retention of any existing mature habitats and features (for example trees, hedges, ponds, pasture) within a development site should be a priority (Cambourne provides a good example). New green spaces can include community woodland, flower meadows, wetlands – not just the typical short-mown grass and flowerbeds. Where possible, communities should be involved in planning and managing the use of their green spaces, e.g. through ‘Friends of…’ groups with support from Council officers. In particular, we welcome the inclusion of community food growing opportunities in this policy and would like to see greater emphasis on this type of open space, with the recognition that allotments cannot be conflated with other open spaces as these are not publically accessible to all.
Given that SUDS, habitat, recreational space etc can be delivered by the same parcel of land as long as the overall green space provision is adequate, we request some reflection on whether SUDS could be treated
as open space – e.g. if a balancing pond is also part of a community park, it could be managed in a more wildlife-friendly and accessible way than if it wasn’t; in the same way ponds could be made a more frequent component of parks and grassy open spaces.
The proposed review of open space standards is welcome but must not result in their watering down. The
current standards for types of open space provision per head of population [1], [2] must be seen as a minimum that developers have to meet. We were very concerned that the original proposals for NE Cambridge failed to meet these standards, and it was only after strong public push back in the consultation that the plans were amended to meet the minimum requirements for different types of green space per resident.
[1] Cambridge Local Plan, October 2018. Appendix I, table I.1
https://www.cambridge.gov.uk/media/6890/local-plan-2018.pdf
[2] South Cambridgeshire Local Plan, October 2018. Policy SC/7.
https://www.scambs.gov.uk/media/17793/south-cambridgeshire-adopted-local-plan-2018.pdf

We firmly support the Greater Cambridge Shared Partnership in ensuring that Greater Cambridge’s
valuable open spaces are protected but recognise that the fulfillment of this promise is threatened by the planned development in the north part of the city. At the moment it is apparent that all the citizens of Cambridge do not benefit from the development of new homes and jobs given that Cambridge is becoming widely recognised as the most unequal city in the UK. Only this week a
Guardian journalist published a scathing article following his visit to Cambridge where he discovered “desperate inequality” [1], particularly when encountering our fellow citizens using the food banks in the ward of Abbey. According to the thinktank, Centre for Cities, Cambridge is the most unequal city in the UK [2].
We are concerned that the Local Plan’s slogan of ‘good growth’ will not only worsen environmental damage, but will fail to serve our Cambridge citizens who are greatly disadvantaged. Instead, the planned growth will only serve our significantly privileged citizens - widening the socio-economic gap even further. To illustrate, it was noted in a Cambridge Commons report [3] that while the top 6% of earners in Cambridge earn 19% of the total income generated in the city, the bottom 20% of earners received only 2% of the total income. In addition, it is well known that contemporary Cambridge has experienced one of the fastest growths in housing supply but the average house price exceeded half a million pounds in September this year [4] meaning that you need to earn over £49,338.00 in order to afford to buy a home in this city [5]. These ‘home-truths’ make Cambridge amongst the most unaffordable cities in the UK despite the amount of wealth that is generated here. A good standard of living, where one can afford to get onto the property ladder, is simply not accessible to many local residents who grow up here. Also the high cost of living in Cambridge is likely to deter those living in other parts of the country and the world from coming to live here.
[1] Aditya Chakrabortty, ‘The truth is now plain: in Johnson’s Britain, some lives are more equal than
others,’ https://www.theguardian.com/commentisfree/2021/dec/09/johnson-britain-equal-cambridgerich-
poor
[2] https://www.centreforcities.org/blog/value-challenges-taking-wider-view-city-economies/
[3] https://www.thecambridgecommons.org/wp-content/uploads/2019/01/Cambridge-Commons-SIPFinal-
Report-1.pdf
[4] https://landregistry.data.gov.uk/app/ukhpi/browse?from=2021-01-
01&location=http%3A%2F%2Flandregistry.data.gov.uk%2Fid%2Fregion%2Fcambridge&to=2021-
12-01&lang=en

For any development that does occur, we support the idea of “high quality people-focused spaces” being created but would like the Greater Cambridge Shared Planning team to explain in more detail what these might look like. The possibility of a policy which “restricts the development of new hot food takeaway premises close to schools or leisure centres” and “limits the concentration of hot food takeaway premises in city, town, neighbourhood and village centres” seems sound in light of the worrying rise in obesity amongst children leaving primary school. Measures should be taken to safeguard our children’s health, particularly those being raised in our more impoverished neighbourhoods. How can we encourage and enable local families to eat a balanced and sufficient diet? Sustainable food shops selling organic fruit and vegetables, such as the ones sold on
Cambridge market or via home delivery companies such as Cambridge Organic Food Company or sustainable local enterprises such as Full Circle, tend to be located in the centre of the city or via home delivery which is much more expensive than the fruit or vegetables you can pick up in the supermarket. Nourishing, organic food and the culture of making one’s own dinner with locally grown food seem to be restricted to our middle classes. We would like to see local businesses who already produce healthy food for the residents of Cambridge having a presence in local shops in Chesterton, Arbury, Abbey and Kings Hedges. We feel the Council should be approaching these local businesses and provide incentives for them to trade in areas where all local people can access them; not just those who live in Market or Petersfield or Trumpington.
We also feel it would be effective to encourage existing takeaways to offer healthier options so that children and young people might benefit from a better diet. This has already been done in Tottenham where local takeaways had the chance to take part in a competition. Taster’s Chicken Shop in Tottenham’s [1] new healthier children’s menu featured grilled chicken, salad and chunky chips in controlled portion sizes for the same price as the existing fried chicken and fries options.
Due to the declining health of our more disadvantaged families, we would like to see the Local Plan delivering interventions that help to reverse this trend like those set out in the ‘Encouraging Healthier Takeaways in Low Income Communities’ based on research by the Cities Institute, London Metropolitan University, October 2014 [2]. For example, in the East Midlands, Indian
restaurants were targeted by the Eat out Eat in Healthy project and asked if they might try altering the ingredients of their curries with dry spice mixes and less oil. When consumer tasting sessions demonstrated that most customers preferred the taste of the healthier curries, these restaurants were converted to providing a healthier menu. In another initiative, the Healthier Takeaways project in Antrim, the fat and salt content of 12 fish and chip shops were tabulated and the results were shown to the owners. The ones who were higher up on the table were shocked into making changes to their cooking techniques. Further, in the London Borough of Haringey, it was found that promoting the Healthier Catering Commitment in the same street meant that, once some
businesses on that street had signed up, the others did not want to be left out. [3] This evidence demonstrates that once the message has come from local authorities that local businesses need to step up their game in helping their customers make healthier choices and ultimately lead longer lives, then local businesses respond and take action. We all know that this issue is particularly poignant in Cambridge where the difference in life expectancy between the richest and the poorest
is an alarming 11.6 years [4]. We feel the impetus for action from our council to start tackling this startling inequality in Cambridge has never been greater.
[1] https://www.gov.uk/government/case-studies/healthy-high-streets-challenge-and-tasters-friedchicken-
shop
[2] https://www.cieh.org/media/1242/encouraging-healthier-takeaways-in-low-incomecommunities.
pdf
[3] https://www.cieh.org/media/1242/encouraging-healthier-takeaways-in-low-incomecommunities.
pdf
[4] https://consultations.greatercambridgeplanning.org/greater-cambridge-local-plan-firstproposals/
explore-theme/wellbeing-and-social-inclusion