Comment

Representation ID: 50054

Received: 24/02/2020

Respondent: John Preston

The Sustainability Appraisal and Scoping Report are inadequate in terms of both process and content.
While the Scoping Report notes (1.15 “Baseline Information”) that “It is a requirement of the Strategic Environmental Assessment process that consideration should be given to the current state of the environment”, there is little recognition of current environmental capacity issues (apart from “over-abstraction of water in this region is a key issue”) and constraints, and no evaluation of successes or failures of the current Local Plans.
The Sustainability Appraisal considers each of the required SA categories separately. It does not consider cumulative and synergistic significant effects on the environment as required by schedule 2 of the SEA Regulations. This oversight has left severe current and future environmental capacity issues affecting Greater Cambridge as a whole, and the Local Plan as a whole, out of Sustainability Appraisal consideration.

But the cumulative impacts of recent and currently approved growth, including related transport proposals, are key issues for the SA and Scoping Report. How can further additional growth be accommodated if that already in the pipeline is unresolved? These impacts are neither assessed nor taken into account in the SA. Baseline information as required by the SEA should include assessments of key existing unmet demands (including, e.g., city centre cycle parking) and of demands arising from current transport proposals (Busways and Greenways). The capacity of both the historic city centre and historic green spaces to accommodate these and other existing demands needs to be assessed.

The SA then has to assess the additional and cumulative impacts of this growth already in the system, in combination with the quantum of growth agreed under the Devolution deal , plus further external (Government, Ox-Cam Arc) and internally generated (Universities, Cambridge Ahead, etc) growth pressures. It has done none of these.

The consequence is that SA has failed to test the draft Issues and Options in relation to a fundamental issue: the environmental and physical capacity limits to the growth of Greater Cambridge. This should be a key Theme of the Issues and Options (and should have already been identified as such).

The SA has also failed to identify, or test, the draft Issues and Options in relation to a second, related key issue: how to manage the conflicting imperatives of economic growth and the preservation and enhancement of the historic city of Cambridge in its historic landscape setting?

The SA and Scoping Report note that all the Options will have negative effects on the historic environment, but without identifying or prioritising issues. There is inadequate recognition of Cambridge’s national and international significance as a historic city and “one of the loveliest cities in Western Europe” (David Attenborough). They do not mention that Cambridge meets at least 3 of the Outstanding Universal Value criteria (i, ii, iv) for World Heritage Site status, or suggest its historic environment should be valued accordingly. It is this level of international cultural and historic significance, expressed in the beauty of the historic city, which attracts students, workers, and visitors from all over the world. In this context historic Cambridge includes its whole associated landscape, including the upper Cam as far as Byron’s Pool and the lower Cam along the length of the Lents and Mays course as far as Baits Bite. The lower Cam section, although fully covered by Conservation Area designations, has been threatened by growth-related transport proposals; so have the West Fields. The arguably even more significant cultural landscape between Cambridge and Grantchester and beyond has no formal protection, with the Grantchester Conservation Area boundary narrowly drawn and no Appraisal. While Grantchester Meadows are owned by Kings’ College, this ownership neither provides direct protection from developments beyond their boundary, nor has any force in planning terms. The need for such protection is highlighted by the impacts on the Meadows of the combined height and bulk of the CB1 development.

This outstanding significance of Cambridge’s historic environment is at high risk from growth pressures.

Cambridge’s historic environment is also threatened by Climate Change challenges (including mitigation and adaptation) and Government targets for meeting them. These are also high risk factors for Cambridge’s historic environment, with difficult choices to be made. A baseline assessment of the implications for Greater Cambridge of current Government retrofit targets is urgently needed.

These issues should be identified and prioritised in both baseline information and the key Themes.