Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 58295

Received: 13/12/2021

Respondent: Cambridge Past, Present and Future

Representation Summary:

CambridgePPF objects to the lack of provision of natural greenspace and requests S106 contributions are sought to provide it. The proposals may provide for the day-to-day open space needs of the new residents but they do not provide large natural greenspace: somewhere people can go for a long walk or run, experience nature, and escape the pressures of urban life. Natural England's ANGSt would require NEC to have a 100ha site within 5km. The Green Infrastructure evidence has highlighted a deficit of GI. Near-by Milton Country Park is at capacity and Wicken Fen is sensitive to increased recreational pressure.

Full text:

There are many things to commend in the environmental aspirations for this development but disappointingly the provision on natural greenspace is not one of them.

The amount of informal green space meets the minimum amount required by the council’s policies but two thirds of this is provided on a business park, described on p26 of the NECAAP Open Spaces Report as “these green spaces aren’t perceived as being accessible to the wider public”. Would you want to visit a business park for your leisure and recreation? It should be noted that the green space on the business park already exists, so it is not new space.

Only a third of the green space is provided in conjunction with the housing. Most of this is provided as linear green space or pocket parks, in other words small areas of green space that are loomed over by high-rise buildings. There is one larger park but the size of this is not provided in any of the documents. Extrapolating from the plans, we estimate this to be around 3.5 ha in size. Fig 20 in the AAP report includes an infographic which aims to compare the amount of open space in the AAP with other Cambridge parks, the comparison is misleading because the parks which are used for comparison are just that, parks. A better comparison would be the main park proposed for the new development. At 3.5ha this is small in comparison to the other parks, given that it is to cater for 16,000 people.

At a bare minimum the proposals for the AAP might possibly just provide for the day-day open space needs of the new residents: play space for children, somewhere to walk the dog or kick a ball about. But what it won’t do is provide the kind of green spaces that people in high density developments need access to – which is large natural greenspace: somewhere they can go for a long walk or run, experience nature, and escape the pressures of urban life.

There is of course somewhere for them to do that, it is Milton Country Park and a subway is proposed under the A14 so that residents can get to it. And that is exactly where the 16,000 people will go. That would be great if it were not for the fact that the Country Park is already at capacity and cannot cope with 16,000 more visitors.

In the hundreds of pages of text for the NECAAP there is almost no mention of Milton Country Park at all, let alone of it meeting the needs of the development. There has been no assessment of whether the country park has the capacity to cope and what mitigation might be required to enable it to do so. We could see no requirement for S106 contributions to support the park to cope only this rather vague paragraph on p54 of the NECAAP Open Spaces & Recreation Topic Paper:
"There is a need to build in community resilience and capacity into the existing open space provision for NEC. Alongside any on-site provision, opportunities to use S106 contributions outside the city on large-scale green infrastructure should be considered. This will avoid pressure building up on existing parks, open spaces and cycleways, which might otherwise lose their biodiversity and other qualities. For example, undertaking negotiations for specific S106 contributions, for growth sites straddling the Cambridge/South Cambridgeshire boundary. These could explore opportunities for improving existing or creating new parks beyond the city which are easily accessible by foot and cycle, in order to avoid over-investment in, and over-use of popular or environmentally sensitive sites."

Natural England’s Accessible Natural Greenspace Standards would require the NECAAP development to have a large 100 hectare site of accessible natural greenspace within 5km. Especially as this development is to be largely car free. But there isn’t one. To make matters worse, the north of Cambridge will also see 20,000 people at Northstowe and 22,000 at Waterbeach. Where will these 58,000 people go to meet their green space needs?

This is an area which has been highlighted in the Green Infrastructure evidence base for the Local Plan as already suffering from a deficit of green infrastructure and recreational pressure. This report highlights North East Cambridge to Waterbeach as a priority area for green infrastructure with its enhancement marked as of ‘critical importance’.

The only option for providing that critical greenspace is through the North East AAP and therefore it is essential that s106 contributions are secured towards this.

Failure to do so will result in increased recreational pressure on European Protected Sites/ Habitats Directive (ie Wicken Fen Special Area of Conservation). Please see our response to the Local Plan Habitats Regulations Assessment.