Draft North East Cambridge Area Action Plan

Comment

Representation ID: 56008

Received: 05/10/2020

Respondent: Natural England

We welcome preparation of the updated report by LUC (July 2020) and reference to our previous
advice, including acknowledgement of the potential impacts to Chippenham Fen SAC, Ramsar site
through increased abstraction from the chalk aquifer and flood risk to the Ouse Washes SAC, SPA and
Ramsar site. We also welcome confirmation that consideration will be given through the HRA to the
implications of the Dutch Nitrogen case judgement. Our advice on the HRA conclusions and
recommendations is set out below.

Eversden and Wimpole Woods SAC
The HRA concludes no adverse effect on the integrity of the SAC, through physical damage, loss or
non-physical disturbance, subject to NECAAP making provision for the requirement for development to
confirm no adverse effect on functional habitat used by SAC barbastelles.

Devil’s Dyke SAC
At this stage the HRA has been unable to conclude that the NECAPP will not have an adverse effect
on the integrity of this site alone, and in-combination, through changes in air quality. The HRA
identifies that road traffic AADT calculations are required along the A14 and A1304, which lie
adjacent to the SAC, to determine whether NECAAP will result in exceedance of thresholds in-
combination with other plans and projects as a result of the NECAAP, noting that exceedances will
require air quality modelling to assess impacts and any avoidance and mitigation measures required
to enable a conclusion of no adverse effect on integrity.

Natural England’s advice is that this additional modelling and assessment be carried out to inform
the HRA conclusions and recommendations. The relevant NECAAP policies will need to be revised to
secure delivery of mitigation recommendations.

Ouse Washes SAC, SPA and Ramsar
At this stage the HRA is unable to conclude that the NECAPP will not have an adverse effect on the
integrity of this site alone, and in-combination, through changes in air quality and water
resources/quantity.

The HRA recommends a commitment through NECAAP to the provision of a new WRC, upgrades and
improvements to waste water infrastructure and capacity and higher standards of treatment, to meet
the additional demands of new development and ensure improved water quality within the River Cam. A
further recommendation is made to provide a commitment within Policy 21 (now policies 4a – 4c) to
protect and enhance, through improved water quality, those European sites hydrologically connected
to the AAP.

Our advice is that additional traffic and air quality modelling and assessment should be carried
out to inform the HRA conclusions and recommendations with regard to air quality impacts on the
Ouse Washes.

With regard to water quantity and quality the HRA will need to await the findings of the WCS to
fully understand and determine the impacts of increased demand for abstraction and wastewater
treatment through NECAAP alone, and in-combination with other plans and policies.

The relevant NECAAP policies will need to be revised to secure delivery of mitigation
recommendations identified in the revised HRA.

Wicken Fen Ramsar / Fenland SAC
With regard to recreational pressure the HRA concludes that discussions are required with the
National Trust to determine how increased impacts to the site will be mitigated, noting the
findings of the Footprint Ecology Wicken Fen Visitor Survey¹ commissioned by the Trust. The HRA
recommends strengthening the wording of Policy 23 (now Policy 8 Open Space), to ensure no adverse
impact. The HRA recommends that this policy should include a commitment for the development of
8,500 houses in North East Cambridge, to provide alternative natural greenspace that is
specifically designed and managed to alleviate visitor pressure on Wicken Fen Ramsar and Fenland
SAC. A further recommendation is for discussion with the National Trust to determine exact measures
that will be required to mitigate for impacts from increased recreation.

We welcome acknowledgement of Natural England’s advice with regard to the provision of sufficient
quantum and quality of accessible natural greenspace provision, noting Natural England’s Suitable
Alternative Green Space (SANGS) Guidance and Accessible Natural Greenspace Standards (ANGSt) and
opportunities for new and enhance GI through the Cambridgeshire Green Infrastructure Strategy to
ensure NECAAP does not rely on existing green spaces, such as Milton Country Park and Bramblefields
LNR which would be overwhelmed by the proposed development.

In order to conclude no adverse effect on the integrity of Wicken Fen through water quantity and
quality the HRA recommends awaiting the findings of the Greater Cambridge Local Plan Water Cycle
Study. The recommendation is for policy wording, including specific detail on mitigation measures,
mechanisms and timescales for delivery, to be guided by the findings of the Study, as advocated by
Natural England. We welcome that the HRA acknowledges the requirement to await the findings of the
WCS to fully understand and determine the impacts of increased demand for abstraction and
wastewater treatment through NECAAP alone, and in-combination with other plans and policies, to
identify how growth requirements can be met and consideration of alternative options to limit and
if possible, reduce levels of abstraction, to ensure no further impact to the natural environment
and deterioration in condition of European sites.

The HRA recommends a commitment through NECAAP to the provision of a new WRC, upgrades and
improvements to wastewater infrastructure and capacity and higher standards of treatment, to meet
the additional demands of new development and ensure improved water quality within the River Cam. A
further recommendation is made to provide a commitment within Policy 21 to protect and enhance,
through improved water quality, those European sites hydrologically connected to the AAP.

Natural England’s advice is that the additional work described above should be carried out to
inform the revised HRA. Mitigation measures identified as being necessary to ensure no adverse
effect on the integrity of Wicken Fen will need to be detailed in the AAP and their delivery
secured through robust policies.

Chippenham Fen Ramsar / Fenland SAC
We note that Chapter 6 Conclusions and Next Steps excludes Chippenham Fen Ramsar site / Fenland
SAC, despite the findings and recommendations in sections 5.58 -5.63. We assume this has simply
been overlooked and that this Chapter will be amended accordingly. Consideration of Chippenham Fen
also appears to have been omitted from the Sustainability Appraisal.

In order to conclude no adverse effect on the integrity of Chippenham Fen Ramsar / Fenland SAC.
through water quantity and quality, Chapter 5 of the HRA recommends awaiting the findings of the
Greater Cambridge Local Plan Water Cycle Study. This is required to fully understand and determine
the impacts of increased demand for abstraction and wastewater treatment through NECAAP alone, and in-combination with other plans and policies, to identify how growth requirements
can be met and consideration of alternative options to limit and if possible, reduce levels of
abstraction, to ensure no further impact to the natural environment and deterioration in condition
of European sites.

The HRA will need to be updated once the WCS work has concluded; any recommendations for mitigation
to address adverse effects will need to be detailed in the AAP and their delivery secured through
robust policies.

We welcome that the HRA will be updated in light of newly available evidence and comments from
key consultees.
_________________________________________
1 Saunders P., Lake S., Lily D., Panter C., (2019) Visitor Survey of the National Trust’s Wicken Fen 100 Year Vision Area. Unpublished Report by Footprint Ecology.

Comment

Representation ID: 56009

Received: 05/10/2020

Respondent: Natural England

Natural England welcomes the Sustainability Appraisal Final Report (July 2020) prepared by LUC.
This appears to generally accord with the requirements of the Planning and Compulsory Purchase Act
2004 and the Strategic Environmental Assessment (SEA) Regulations. The SA seeks to address the
effects of the AAP on key aspects of the natural environment including designated sites,
biodiversity, landscape, green infrastructure, water and air quality and climate change. The
assessment and recommendations / mitigation will need to be updated as the AAP policies evolve and
to take into account the findings and mitigation recommendations of the outstanding environmental
assessments and further revised HRA.

We agree that the NECAAP is likely to make substantial contribution to meeting the considerable
local housing and employment needs and the Plan has a strong focus on moving towards net zero
carbon emissions. Whilst the AAP is expected to result in overall significant positive effects
against the majority of SA objectives, negative effects are identified for air quality, pollution
greenhouse gas emissions due to increased energy and vehicle use to some extent, even if this is
substantially lower per person than the surrounding area. The SA highlights the risk of significant
negative effects on air quality particularly along the A14 Corridor, in combination with other
developments to the north and east of Cambridge, if the trip budgets which the AAP seeks to achieve
are exceeded in practice.

Natural England notes the potential for significant cumulative negative effects on protected
habitats and species based on the findings of the HRA, noting that these are uncertain pending the
requirement for further work to assess potential recreational pressure, air quality and
water-related impacts. The SA will need to be updated with the findings and recommendations of
these further assessments in due course. Mitigation measures will need to be detailed in the AAP
and their delivery secured through robust policies.

Whilst we generally support the findings of the SA our advice is that negative / uncertain effects
on protected habitats and species, including Milton Road Hedgerows City Wildlife Site and
Bramblefields LNR should not be deferred to the ‘detailed proposals’ stage. Any potential risks to
these sites, including indirect effects to any statutorily designated sites, should be assessed
through the SA and any adverse impacts appropriately mitigated, through Plan policies.

We note that the SA has omitted consideration of impacts to Chippenham Fen Ramsar site and to
the National Trust’s Wicken Fen Vision Area.