Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 59460

Received: 09/12/2021

Respondent: Susan Buckingham

Representation Summary:

Concerned about flooding. Need to retain quality farmland for food security. Rising sea levels is likely to result in the loss of the Fens. Moving the WWTC to the green belt to facilitate growth is contrary to the goals of the plan. Concerned about approach to BNG.

Full text:

BIODIVERSITY, NATURE AND FOOD SECURITY
Building on the scale proposed in South Cambridgeshire will increase winter flood risks to the Fens. As we need to reduce the miles over which food is imported, and with existing farm areas becoming less productive in a climate-challenged world (Richards, Upton and Allwood, 2020), we need to retain current food growing areas, and to farm sustainably. The Fens comprises 4% of England’s farmed area, but produces 7% of its total agricultural production, employing 80,000 people and generating £3b each year in the Fen economy ( NFU, 2019). Most of South Cambs land is Grade 2 and the balance is Grade 3.

On present trends the Fens are likely to be lost to the combination of sea level rise
and increased runoff from development somewhere between 2150 and 2200. (In 2021, the IPCC calculated a 2.4m sea level rise by 2100, while Climate Central forecast a 4.7m rise by 2100 if temperatures rise to 2oC.) It may happen sooner if the area has to cope with the kind of concentrated rainfall experienced elsewhere in Europe. Therefore, to propose new housing developments in areas of high flood risk and/or high grade agricultural land, is reckless.

The local plan makes repeated reference to ‘biodiversity net gain’ while also proposing building homes and associated infrastructure on greenfield sites. Moreover, it also proposes moving a functioning waste water treatment plant, upgraded in 2015 and currently running well within capacity, to a greenfield site, in order to build homes on the vacated land. Meanwhile, combined sewer overflows in Haslingfield, Linton, Melbourn and Waterbeach receive no upgrades and repeatedly spill untreated water into our river system. The relocation of Milton Sewage Works is designed to facilitate employment-led growth which requires taking the green belt from three medieval River Cam villages. Given that this proposal potentially contravenes the National Planning Policy Framework, having adverse impacts which outweigh any benefits, and failing to protect areas and assets of particular import
(NPPF 2,11 (d)), it is potentially the subject of a public enquiry.

Arguing that a large and unnecessary infrastructural project, with significant embodied carbon in construction and operating, will increase nature, wildlife and green space is, at best, disingenuous; at worse, deceptive. It is, at any rate ‘greenwashing’. Biodiversity requires space to move, and building over green space reduces this capacity. Moreover, the plan does not guarantee that whatever it defines as ‘biodiversity net gain’ will relate to the site being developed. It is possible, even likely, that a handful of green roofs or such like will count as replacement green space. Additionally, any building on greenfield sites will increase rainwater runoff, and increase heat retention, contributing to both global and urban heating and increased pressure on the water and sewage systems.