Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 59945

Received: 13/12/2021

Respondent: Mr Oliver Harwood

Representation Summary:

The Draft Local Plan does not follow a 'brownfield first' approach. It is therefore not consistent with national government policy. The massive greenfield building and infrastructure programme contained in the Draft Local Plan breaches all obligations for sustainable development. Embodied carbon emissions are ignored in the Plan.
Climate change should be the single most important consideration in all aspects of transport planning and operation, and the Draft Local Plan fails to do this.
Only by intensification of housing in the City can the car borne carbon emissions be avoided.
Cambridge City and South Cambridgeshire already have an unsustainable supply of potable water.
The local sewage system is currently inadequate.

Full text:

I have three specific objections to the draft Plan

1. Carbon emissions
The Draft Local Plan does not follow a 'brownfield first' approach. It is therefore not consistent with national government policy as expressed repeatedly, recently by the Prime Minister. Greenfield building maximises carbon emissions. The Local Plan should encourage urban intensification.
There are vast swathes of second quality post war two storey developments in and around Cambridge. These could and should be replaced or augmented with additional storeys to add 50% or more to the housing stock in the City, all within easy pedestrian or cycling distance of the city centre.
Old airfields such as those being developed in Cambridgeshire are not true brownfields; only their disused run-ways and any associated buildings are and the former could be easily cleared and used as a source of recycled aggregate. Most of the former Bourn airfield is productive farmland. The massive greenfield building and infrastructure programme contained in the Draft Local Plan breaches all obligations for sustainable development. Embodied carbon emissions are ignored in the Plan. Cement manufacture contributes 8% of global carbon emissions which is more than three times the impact of aviation fuel. Iron and steel production accounts for another 8%. Between them they account for more emissions than the USA and are second only to China as greenhouse gas emitters.
According to the recent Cambridge and Peterborough Climate Commission report, at the present rate the Region will have used up all of its carbon budget, allocated to meet its legal obligation to reach zero carbon by 2050, in less than six years; due to the level of planned growth, emissions will accelerate further. The obvious conclusion is that all unsustainable growth has to be curbed.
This means that the intensification of housing in Cambridge should use sustainable building techniques based around wood and recycled materials.
The Climate Change Committee has argued in its 2018, 2019 and 2020 Annual Reports to Parliament that UK local and imported emissions arising from construction (the UK imports most of its building materials, even the bricks are made in Belgium or Holland), must be reduced if the UK is to meet its now legal emission targets.

2. Transport
Climate change should be the single most important consideration in all aspects of transport planning and operation, and the Draft Local Plan fails to do this.
Only by intensification of housing in the City can the car borne carbon emissions be avoided.
Annual Reports to Parliament by the Climate Change Committee have consistently made the point that ‘Surface Transport’ is the greatest source of greenhouse gas emissions in the UK. Therefore, all transport planning should: (a) seek to minimise all forms of travel by locating the dwellings required within walking and cycling distance of work and leisure facilities, discouraging commuting and leisure travel
(b) encourage use of digital communications,
(c) where travel is essential, encourage active travel and/or use of public transport,
(d) provide carbon efficient forms of public transport, particularly light rail and heavy rail on the most heavily used routes. The ancient proposals for a Cambridge underground railway should be revived.
Road widening and road building proposals should be abandoned with immediate effect. The only consideration for any road layout changes, other than road safety, should be the question “Will it reduce net carbon emissions from construction and use?”. Clearly, some small schemes which ease traffic flow will reduce emissions from acceleration, but those that increase road use will not.

3 Inadequate water and waste water provision
(a) Water
Cambridge City and South Cambridgeshire already have an unsustainable supply of potable water. In 2021 the Environment Agency published “Water stressed areas – final classification 2021” which included the fact that the supply areas of Cambridge Water and Anglian Water are areas of serious water stress, Appendix 3 states Cambridge Water needs to reduce abstraction by 22 megalitres per day from levels current at 1st July 2021, and Anglian Water needs to reduce abstraction by 189 megalitres per day from levels current at 1st July 2021.
(b) Wastewater
The local sewage system is currently inadequate, evidenced by the number of sewage spills by Anglian Water sewage works into the Cam Valley. Currently, there are no plans to improve failing combined sewer overflows. Cambridge saw 622 hours of untreated waste water enter the rivers in 2020, yet Anglian Water is proposing to move the one sewage works in the area which has been upgraded and has sufficient capacity until 2050, the main Cambridge works, into the Green Belt and to spend at least £227 million of public money to do so.
To date there have been no upgrades at any of the smaller works in the area while more and more taps are still being connected. The Environment Agency has already warned at least one Cambridgeshire local planning authority, East Cambs District Council, that they must stop looking at the sewage requirements of single planning applications and instead look at the cumulative effects.