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.