Question 7
Q7 No because you have not included any provision for equestrians.
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Further comments: We feel the spaces are minimal and Cowley triangle is particularly small. Also better connections to other green spaces in surrounding areas should be made.
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• There needs to be much more open and natural space provided within the development. • Any provision that will be outsourced must be supported by a credible plan to ensure that those areas (e.g. Milton Country Park, Chesterton Fen wetland nature reserve, the River Cam towpath, Ditton Meadows) will not become overcrowded, and that the ecology will not be damaged through overuse.
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No comment
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Having reviewed Section 5.3 whilst there is provision for public open space the document should acknowledge Public Health England’s March 2020 document ‘Improving access to greenspace: A new review for 2020’.5 This document advocates that good design integrates green infrastructure into the holistic masterplan in ways that promote active travel, recreation and leisure, and support community and social engagement. Greenspace must be recognised as critical infrastructure that will help meet a range of local priorities and is not just something ‘nice to have’. Whilst brownfield in nature, the relocation of the Waste Water Treatment Works (WWTW) does provide a somewhat blank canvas in terms of the potential masterplan for the area. However, the balance of green and blue infrastructure appears to heavily rely on that already provided within CSP, with the introduction of a linear park and triangular space which fit around the built form, rather than a landscape rich approach. Figure 20 within the draft NECAAP illustrates the proposed Cowley Triangle Park providing 1.1 hectares of new open space and the Proposed Linear Park providing 8.5 hectares. The Open Space Topic Paper sets out a total Open Space Provision of 66.3 hectares, 40.4 being dedicated to informal open space and equipped children’s play areas. This poses the question as to where this additional open space provision can and will be accommodated. Cambridge Science Park currently includes circa 8 hectares of amenity landscaping, which is included within the NECAAP is short of at least 22 hectares of informal open space and play areas according to the supporting Topic Paper. Reference is made to improvements to Milton Country Park, Chesterton Fen and Bramblefields Nature Reserves in lieu of appropriate on-site provision. However, whilst in theory this could provide part of the solution, it is questionable as to how this investment will support the initiatives set out within the Anti-Poverty and Inequality Topic Paper. This points to the wards of Arbury and Kings Hedges which neighbour the NECAAP area has falling within the most deprived areas within Cambridge. That same paper sets out the importance of providing access to open space as a means to address health inequalities. Guidance for Outdoor Sport and Play6 sets out recommendations for walking distances to varying open space typologies, which are all below the distance from Kings Hedges to the off-site improvements. One solution to the lack of new open space provision would be through Cambridge Science Park North which is being developed as a location that can provide compensatory improvements to a substantial (circa 90 hectares) area of remaining Green Belt land providing: • A network of new green infrastructure; with links to Milton Country Park, Histon & Impington, and Arbury and Kings Hedges. • Woodland planting of sufficient scale to provide meaningful woodland carbon capture; • Landscape and visual enhancements taking existing agricultural land and creating a valuable green asset for neighbouring communities and employees. • Improvements to biodiversity, habitat connectivity and the introduction of natural capital to an area of low ecological value agricultural land. • New and enhanced walking and cycle routes, linking into the planned improvements to Mere Way; and • Improved access to new recreational and playing field provision. These proposed uses are all entirely compatible with both the purposes of the Green Belt and uses which are deemed as appropriate within the Green Belt i.e. material changes in the use of land for outdoor sport and recreation.
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We support proposals for new and enhanced on-site green infrastructure through the creation of a linear park and Cowley Triangle, alongside a green High Street and neighbourhood greens. However, Natural England’s view is that the AAP needs to present a green infrastructure framework, or similar, to identify viable opportunity areas for expansion and enhancement of the existing network, sufficient to meet people’s recreational and accessible greenspace needs and mitigate adverse impacts to existing open spaces, including designated sites and priority habitats. Whilst the AAP commits to improving access to nearby green spaces such as Milton Country Park and Chesterton Fen, Natural England believes that provision of 10ha of public parks and squares is wholly inadequate for a development this scale and density. This magnitude of development requires strategic expansion and enhancement of the existing green infrastructure network. The AAP should identify how this will be delivered through a GI framework and delivery plan.
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In order to achieve this, we feel more effort and imagination must be made in maximising opportunity to favour green over grey beyond the limitations of what has been proposed. There appears to be seven areas of identified green space, two being off-site. Of those on-site, three have an association with the First Drain, in effect forming one linear unit. There is reference to one central feature green space and a second reference to an unspecified number of small green spaces throughout which presumably aims to meet the LAP, LEAP and NEAP requirement. Although there is no indication to the proportion of each type being provided to meet population size. • With an increased population, we question how can the impacts on local and surrounding wildlife sites be avoided and mitigated for, when Policy 5 states ‘Development shall avoid having any adverse impact on the nature conservation value of….City Wildlife Sites and Country Parks… other areas of natural or semi-natural sites within or adjacent to North East Cambridge’ • It is of concern not enough provision has been considered to meet Accessible Natural Green Space Standard (ANGSt) recommendations. It is noted Milton Country Park and Chesterton Fen are sought to meet the needs through expanded capacity improved public access and nature enhancements. These sites, along with the very small Local Nature Reserves (LNR) and City Wildlife Sites (CiWS) to the south and south east currently do not have the ability to absorb an increase in footfall and any further pressure, already exceeding their carrying capacity. Much work will be needed to address this issue.¹¹ • The deficit of suitable green space and forecasted population increase of 18,000, risks additional pressure being placed on other strategic statutory conservation sites within easy traveling distance. Driving to access this additional green space is contrary to the aims this development has for a low carbon community.¹² • We would like to see what proposals are intended to increase the extent of green infrastructure, by linking planned areas of green space through a vegetated road and path network which as such might include street trees and SuDS features such as rain gardens.¹³ We would also like there to be at least 30% tree cover across the site. ¹⁴ • We are also concerned the ‘Green High Street’ seems to propose a considerable amount of hard landscape, seemingly contrary to its name.¹⁵ • The need in Policy 8 of early integration of open spaces into the design process is welcome. This should be in conjunction with landscape and ecological input to maximise the amenity and net gain wildlife potential of each development and its linking path and road networks. • In order to achieve the qualitative aims of Policy 8, we believe for high quality, low maintenance, water efficient and climate change resilience, part of the solution will lie in how soils are used.¹⁶ • We would also like clarity on the interpretation in this policy for ‘…multi-functionality’.¹⁷, ¹⁸, ¹⁹, ²⁰, ²¹ • We welcome protection of existing open space, ensuring any last resort loss is compensated by something equal to or of better quality. It must also include bringing retained places into appropriate conservation management.²² ____________________________________________ Qualifying points to responses: ¹¹In order to provide greater public access to green space, improved ANGSt targets and better contribute toward a 20% net gain target, Milton Country Park would require substantial expansion east toward the River Cam, to link south with Chesterton Fen and north toward Waterbeach. In addition, improved access and provision might be considered at Fen Drayton which is easily accessible via a short ride on the guided busway running through Cambridge North East. ¹²Local sites of high nature conservation value include several fens, such as Wicken which is part of the Fenland Special Area of Conservation (SAC) and several nearby woodland SSSI sites. Acute disturbance and habitat degradation at these sites are a real problem. There is a serious risk this development will exacerbate the situation and gives cause for concern. An indicative measure of the area required to reduce these pressures, Natural Englands’ Suitable Accessible Natural Green Space (SANGS) guidance recommends 8ha per 1,000 new residents, equating to 144ha of green space being required for NE Cambridge to provide residents with the variety of green space needed for exercise and dog walking without the need to travel. ¹³These will contribute to the objectives of climate resilience, with evaporative cooling provided by trees and SuDS. ¹⁴https://www.woodlandtrust.org.uk/media/47692/emergency-tree-plan.pdf ¹⁵We would like to see more greening measures incorporated to ameliorate the heat island effect and meet the otherwise shortfalls of green space provision. Furthermore, consideration needs giving to SuDS source control in order to prevent contaminated run-off entering the First Drain, throughout the whole site but in this instance with reference to the proposed hard landscaped ‘Green High Street’. ¹⁶Topsoil should be limited to areas requiring fertility such as sports pitches and other high impact grass areas and areas where growing might take place. Nutrient poor substrates for informal and formal landscape, and flower rich grass areas will reduce maintenance costs of weeding – creating inhospitable conditions for nitrogen hungry dominant plants, while choice of drought tolerant plants and seed mixes adapted to grow in poor nutrient substrates will deliver water efficiency and climate resilience. ¹⁷This should include opportunity for temporary water storage in extreme flood events using hard and soft landscape that simultaneously provides wildlife habitat and contribute to on-site net gain. ¹⁸In addition, multi-functionality can be achieved through a more fluid landscape that also facilitates food growing. We note and appreciate in Appendix 1 of the Local Plan, that 1.9 Allotments recognises high density developments such as N E Cambridge have little space for allotments. This however is restrictive, and more thought should be given to provide the opportunity for communities to grow food in appropriate areas of planned landscape adjacent to their home. This will further reduce maintenance costs providing a fall-back plan is agreed within maintenance contracts to intervene should the community member move away or stop. ¹⁹The Poppy Estate (video) 20 Social housing (webpage and video) ²¹Pride and community cohesion will increase, along with associated and well documented health benefits. This will support the recognised objective of the step changes needed for effective use of open green space beyond the broad requirements of the Cambridge City Council standards. It also diversifies the aim and potential to provide communities with the opportunity to spend time outdoors. ²²Where S106 agreements are drawn up with developers for future management and maintenance of open space, it is important to include existing planting and open space being brought into restorative conservation management where necessary. Often tree planting lacks any post establishment maintenance and matures into stands of overcrowded canopies, with no scrub or flora understory and of sub-optimal wildlife value.
7.1 Open spaces should allow for a range of ‘occasional’ events that will help support community activities and sporting events. The use of open space by all ages needs to be considered and where appropriate facilities to promote their use provided. Policy 8 captures this in part but could be more explicit to ensure this is not overlooked when designing open spaces. 7.2 It is important to reflect on the value of open space since the Covid-19 pandemic. Access to sufficient open space of a high quality, particularly for residents in apartments, for which there is a high proportion proposed for NEC, is essential.
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Please see attached Letter including representations on behalf of The Crown Estate.
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The AAP ‘borrows’ Milton Country Park and Chesterton Fen, both of which lie outside NEC. The Country Park is already very well used and there is no information as to how the capacity could be increased. Otherwise NEC itself seems deficient in Green spaces which would make Mere Way cycle path even more important to allow people to access open countryside. What legal requirements will be placed on developers to ensure that these facilities materialise? Will the public spaces be well maintained and safe?
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