Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 58769

Received: 13/12/2021

Respondent: Wates Developments Ltd

Agent: Boyer Planning

Representation Summary:

Overall, Assessment recommends growth be concentrated in new settlements or urban extensions that avoid high flood risk and have high standards for design of flood risk management, water usage and re-use, and blue-green infrastructure. Follows a Location Opportunities and Constraints Categorisation and Scoring which assesses and scores each proposed growth strategies.

Disputed why development within the Minor Rural Centres and Group Villages have been disregarded as an appropriate growth strategy if they are able to meet ambitious water usage targets and implement water recycling systems.

Full text:

Policy CC/FM states that development will be directed to the areas with the least likelihood of flooding from all sources and taking into account climate change. The Policy also states that development will be required to provide integrated water management, including SuDS. Land West of London Road, Fowlmere proposes to include SuDS and will adhere to Policy CC/FM.

Greater Cambridge Local Plan Strategic Spatial Options Assessment (November 2020)
The Greater Cambridgeshire Local Plan is supported by a Greater Cambridge Local Plan Strategic Spatial Options Assessment (November 2020).

The Assessment identifies that current over-abstraction of the Chalk aquifer is having a detrimental impact on environmental conditions. It acknowledges that none of the Councils’ growth strategies offer an opportunity to mitigate the existing detrimental impacts and there is no environmental capacity for additional development in the new Local Plan to be supplied with water by increased abstraction from the Chalk aquifer.

Major new water supply infrastructure is proposed and will be operational in mid-2030s, however, development in the interim will need to reduce abstraction through the implementation of ambitious targets for water efficiency. Such targets will be required to be addressed across all new developments.

It is understood that all development within Greater Cambridgeshire will need to adhere to such ambitious water efficiency targets and therefore there is no growth strategy that has a lesser water usage impact than another.
In so far as utilising recycling systems, the Assessment suggests that large sites are able to successfully use recycling to reduce demand for potable water. We disagree with this statement. Whilst retrofitting developments may be expensive, new development (regardless of scale) is able to adopt rainwater recycling systems. It is unclear why the statement specifically restricts water recycling usage to “large developments”. Land West of London Road, Fowlmere, is able to adopt a rainwater recycling system if this is a requirement set by Local Policy.
The Assessment also identifies the potential for introducing flood management and SuDS schemes to deliver multifunctional benefits including biodiversity enhancements. Land West of London Road, Fowlmere presents an opportunity for delivering a scheme which includes SuDS that provide multifunctional benefits including an opportunity to benefit and enhance designated wildlife sites.

Overall, however, the Assessment recommends that growth should be concentrated in new settlements or urban extensions that avoid high flood risk and have high standards for the design of flood risk management, water usage and re-use, and blue-green infrastructure.

This recommendation follows a Location Opportunities and Constraints Categorisation and Scoring which assesses and score each of the proposed growth strategies.

Minor Rural Centres (including Melbourn) and Group Villages (including Fowlmere) is assessed as having a red rating for flood risk due to potential existing fluvial flood and surface water flood risk. Wastewater and Quality are assessed as amber, subject to local WRC capacity. The red flood risk rating is despite Paragraph 4.2.1 of the Assessment stating “flood risk does not differentiate between the growth scenarios”.

Land West of London Road, Fowlmere is located within Flood Zone 1 with low risk of surface water flooding, which is a sequentially preferable location for development as supported by the NPPF (2021). In this regard the Site should be assessed as having a Green or Amber Flood Risk rating. In either instances, this Site should be given a total constraints score of -6. This score would result in the same overall scoring as the proposed recommended growth strategy of locating growth within new settlements or urban extensions. This amendment would also introduce criterion “Good opportunities”, thereby also improving the overall combined constraints and opportunities score for development within Minor Rural Centres and Group Villages.

It is therefore disputed as to why development within the Minor Rural Centres and Group Villages have been disregarded as an appropriate growth strategy if they are able to meet the ambitious water usage targets and implement water recycling systems.