Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 56947

Received: 09/12/2021

Respondent: Cambridgeshire County Council

Representation Summary:

There should be an emphasis on managing surface water close to the source, on the surface and within open SuDS where practicable. There is no mention of water quality in the proposed policy direction section. This should be included within the local plan as a standalone point within the flood management policy. Surface water systems should be designed with an allowance of climate change. Reference should ideally be made to the Cambridgeshire Flood and Water Supplementary Planning Document

Full text:

(Education) Policy CC/FM includes the expectation that developments will be required to provide integrated water management, including sustainable drainage systems (SuDS). The Council would be supportive of this being incorporated into the design of new schools. However, it should be acknowledged that this is likely to increase the size of the site required for a school. Currently, it is Council Policy to request the minimum site size required to enable delivery of a school which meets the standards set by the Department for Education (DfE), including suitable outdoor space to enable physical education in accordance with the school curriculum and to enable pupils to play outside. As this is a statutory requirement and delivered through the planning process via Sport England, there would be a statutory planning objection if not incorporated into the design. Including SuDS within the design would require an additional land allocation. Costs and space would also need to be incorporated into s106 agreements to ensure children’s safeguarding if, for example, SuDS ponds were to be on site rather than using attenuation tanks.
The Council therefore feels it would be most appropriate for any targets to be incorporated in policy to be the subject of a technical assessment on their achievability and cost, before being formally adopted.

(Flood Risk Team) The direction of the policy is going in a good direction, taking inspiration of the Cambridge City Local Plan 2018, as this holds good practice for the design of SuDS systems.
There should be an emphasis on managing surface water close to the source, on the surface and within open SuDS where practicable. I note it is included, but this should be the basis of all surface water schemes.
There is no mention of water quality in the proposed policy direction section. This should be included within the local plan as a standalone point within the flood management policy. This could include the use of terms such as the SuDS Management Train, focussing on providing multi stages of treatment through cascading structures. This is the way that developments should be going in managing their surface water.
While climate change is covered in Policy CC/DC, it would be worth including the surface water systems should be designed with an allowance of climate change included
The document is very much setting out the policy directions, it would be good to know the general set out of the proposed policy, as the listed versions of these policies are useful in interpreting, signposting and referring stakeholders to for information or as part of a scheme.
Reference should ideally be made to the Cambridgeshire Flood and Water Supplementary Planning Document (SPD), or any subsequent version of this, which is adopted South Cambs and Cambridge City individually.
It is noted that the policy will not need to repeat items covered by the NPPF, however, reference should be made to this within the document.