Comment

Representation ID: 50215

Received: 24/02/2020

Respondent: Campaign to Protect Rural England (CPRE)

Responses To Consultation.
Greater Cambridge Local Plan Sustainability Appraisal of Issues and Options Report
1. CPRE finds the Sustainability Appraisal of Issues and Options (SAIO) to be comprehensive and clear. However, because of its terms of reference, it does not fully consider the regional and national sustainability issues created by development within Cambridge and South Cambridgeshire. CPRE believes that some of these issues are so significant that they should have been considered in greater depth.
2. The Cambridge Green Belt was the first Green Belt outside of London and it is the smallest. Green Belts were an invention of one of our county’s foremost citizens, Octavia Hill. It is therefore of historic value in its own right and furthermore provides the unique setting for the City, its collegiate buildings and its academic character and inheritance. This significance has not been acknowledged in the SAIO.
3. The SAIO accepts the same assumption of growth as the Issues and Options Report. However, growth in itself is not sustainable and CPRE believes this assumption should be questioned by the SAIO.
4. Furthermore, the SAIO has not considered the national or regional sustainability of undertaking further major developments around Cambridge. As we stated in our response to the Issues and Options report there has been no consideration as to how this major investment of national funds in the relatively well-off south-east will further reduce or limit investment in the North of the UK. This in turn will reduce the more sustainable options of re-using the near 1 million empty properties that exist in the North and Midlands and the documented space for another 1 million properties that exists on brownfield land in Northern and Midlands towns and cities.
5. The SAIO recognises the varying quantities of best and most versatile agricultural land that the different options could cause to be built on around Cambridge. However, it does not recognise that the county of Cambridgeshire hosts a nationally significant proportion of this country’s best and most versatile farm land. As we have indicated previously, by the end of this century it is probable that climate change will have caused significant loss of the Fens which currently grow 24% of UK food supply. Therefore it is imperative that the remaining best and most versatile land land is not built on but preserved for food supply. This is a national sustainability issue and it should not be ignored.
6. It is encouraging that the SAIO recognises the issues of water resources and quality as major issues. There is already damage to the chalk streams caused by over-abstraction and the River Cam shows high stress levels in the summer months. We agree with paragraph 3.79 but we are concerned that the local authorities, driven by the NPPF, may not be taking these issues as seriously as they should and instead may be relying on the statutory duties of the water companies to dig them out of a hole. Waste water treatment capacity must be given a higher priority. The North Cambridge development requires the existing treatment plant to be moved but there is no clear decision about that yet and, if further treatment capacity is need, where will that be sited and how will it be protected from flooding?
7. The SAIO does not address the issue of flood risk within the context of climate change or in the context of the wider region. Existing flood zones in many parts of Greater Cambridgeshire will experience higher risk of flooding in future because of sea level rise caused by climate change (Predictions range between 1.1 – 4.7 metres by 2100). In December 2019, the Environment Agency issued a flood warning for Cottenham Lode which extends up to and under the A14 north Cambridge by-pass. Such warnings will without doubt become more frequent. Furthermore, additional run-off from more development around Cambridge will increase flood risk to communities further north such as Waterbeach, Cottenham, Stretham, Ely and Littleport. There is no detailed indication as to how this runoff will be prevented.
8. We find that the SAIO takes a relatively superficial approach to addressing prevention of Climate Change and its mitigation. It is clearly restricted by taking its lead from the Issues and Options. As we have stated in our response to the Issues and Options, Climate Change is the most pressing issue of our time. The current proposals are predicated upon ‘growth’ and growth has to be halted in a in a controlled manner without unacceptable effects on the poorer and more vulnerable people in our society. We agree with most of what is said in paragraphs 3.92 to 3.97 when addressing
SA Objective 12. However, the Objective is too little, too late. The whole concept of the Cambridge-Oxford Arc must be reviewed and much of it halted and replaced with more sustainable changes in the location of housing and business and the discouragement of commuting and business travel.
9. We agree with most of paragraphs 3.98 – 3.103 but we would reiterate that if housing development is undertaken in villages and other rural communities it should be accompanied where possible by employment space, to encourage local employment and reduce commuting. We also see high speed broadband as a means of facilitating distributed employment. Both will improve the sustainability of rural communities.
10. We do not agree with the principles behind SA Objective 13 and hence much of the content of paragraphs 3.104 – 3.109. Society must recognise there is no such
thing as “sustainable development”. All development has varying degrees of unsustainability. We accept that Options 1 and 2 are less unsustainable than the other Options. Nevertheless we are concerned by the loss of skilled engineering employment close to Cambridge that the development of Cambridge Airport, Option 2, would engender. We are also concerned that moving the Marshall’s business to another location will just create sustainability issues elsewhere, not the least being the building of new facilities and the travel of existing employees.
11. We are disappointed with the discussion of SA Objective 14, paragraphs 3.110 –
3.119. Unfortunately, this is driven by the manner in which the Options have been set out so separately whereas, in reality, the likely outcome of the Plan will necessarily be a combination of these options. There are many communities across the County which are increasingly becoming
commuter dormitories. Larger communities, such as Cambourne/Bourne, Northstowe, Bar Hill, Ely, Alconbury Weald and Manea are capable of supporting significant local employment space. Many larger villages could easily support more small employment units of the type that start-ups and rural businesses require.
A survey in 2010 showed that some 70% of Ely’s working population on its new estates commuted to Cambridge or London. Other communities will have higher proportions of commuters. This is not a sustainable situation.
Our conclusion is that the Greater Cambridge Local Plan must consider the economic and residential impact on its wider hinterland as well as within Greater Cambridge itself.
12. We are concerned that better integration of public transport does not seem to be considered as a major sustainability issue.
13. We are concerned that adequate electricity supply does not seem to have been considered as a major sustainability issue.
14. We are concerned that no mention has been made of impact on the proposed Fenland Biosphere with its potential UNESCO designation. This is a major
sustainability issue.