CC/WE: Water efficiency in new developments

Achieving all five BREEAM WAT01 water conservation credits is an extremely challenging standard that is likely to go beyond the limits of viability for smaller projects, projects with limited roof collection area, and projects with functions that do not fit the BREEAM standardised calculation methodology. There is a risk of ‘white elephant’ grey water recycling and rainwater harvesting systems that are too small to be sustainable in terms of maintenance and operating cost and ask that guidance on the appropriate threshold of viability be provided; ideally in the form of worked examples for typical building types (office, education, industrial).

CambridgePPF support a policy which recognises the level of water stress in our area and which is achieving more than building regulations.

Our members questioned whether low water use targets can be met through design and construction methods alone, given that there are no restrictions on how much water people can use.

This policy will set the standards of water efficiency that new developments must comply with. Our preference is to implement the Building Regulations alternative standard (the current policy of 110 litres/ person/day).

Policy CC/WE requires developments to meet high standards of water efficiency, with residential development designed to achieve a standard of 80 litres/person/day unless demonstrated to be impracticable.

It is acknowledged that there are issues with current over-abstraction of the Chalk aquifer and this is having a detrimental impact on environmental conditions. It is also understood that, to address this, Greater Cambridge are seeking to adhere to ambitious water efficiency targets.

The Aspinal Verdi Viability Study (2021) states that an “extra over cost has been included for additional water standards costs with reference to Code for Sustainable Homes levels 5 and 6 (Housing Standards Review Cost Impacts report, DCLG 2014). Baseline allowance of £9 per unit to Code levels 3 & 4, and £2,697 to achieve Code levels 5 & 6 based on Department of Communities and Local Government Housing Standards Review Cost Impact, September 2014 by EC Harris.”

It is noted that these cost figures are greater than 7 years out of date, and whilst it is welcomed that these figures have been subsequently index linked, resulting in a combined figure of £3,109 per dwelling, the industry as a whole has noted that build cost and the cost of materials has significantly increased in recent years. We recommend that these figures are updated (rather than being index linked) to ensure that the evidence is robust and therefore meets the tests of soundness.

We remain concerned, therefore, whether a 2% uplift represents a sufficient increase in build costs to allow for the delivery of CC/WE.

Notwithstanding this, whilst it is clearly desirable for new development to achieve the highest possible water efficiency, the mandatory national standard set out in the Building Regulations is 125 litres/person/day. NPPG Paragraph 56-014-20150327 states that where there is a clear local need, Local Plan policies can require a tighter optional requirement of 110 litres/person/day.

The Councils’ acknowledge that the 80 litres/person/day goes beyond what Local Authorities are currently able to require but considers there is a strong case for greater water efficiency in Greater Cambridge based upon strong evidence provided by the Integrated Water Management Study. This would make full use of water efficient fixtures and fittings, water reuse measures on site including surface water and rainwater harvesting, and grey water recycling. It acknowledges that the cost effectiveness improves with the scale of the project.

The Councils’ 80 litres/person/day target is not considered realistic. Instead, it is considered that the tighter optional requirement of 110 litres/person/day should be encouraged. It may be appropriate to set tighter standards for certain site allocations but a blanket requirement of 80 litres/person/day is not realistic.

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.

TMLC notes the water management concerns in the region and supports the delivery of new infrastructure and the efficiently of existing water infrastructure.

Policy CC/WE requires developments to meet high standards of water efficiency, with residential development designed to achieve a standard of 80 litres/person/day unless demonstrate impracticable.
It is acknowledged that there are issues with current over-abstraction of the Chalk aquifer and this is having a detrimental impact on environmental conditions. It is also understood that, to address this, Greater Cambridge are seeking to adhere to ambitious water efficiency targets.
The Aspinall Verdi Viability Study (2021) states that an “extra over cost has been included for additional water standards costs with reference to Code for Sustainable Homes levels 5 and 6 (Housing Standards Review Cost Impacts report, DCLG 2014). Baseline allowance of £9 per unit to Code levels 3 & 4, and £2,697 to achieve Code levels 5 & 6 based on Department of Communities and Local Government Housing Standards Review Cost Impact, September 2014 by EC Harris.”
It is noted that these cost figures are greater than 7 years out of date, and whilst it is welcomed that these figures have been subsequently index linked, resulting in a combined figure of £3,109 per dwelling, the industry as a whole has noted that build cost and the cost of materials has significantly increased in recent years. We recommend that these figures are updated (rather than being index linked) to ensure that the evidence is robust and therefore meets the tests of soundness.
We remain concerned, therefore, whether a 2% uplift represents a sufficient increase in build costs to allow for the delivery of CC/WE.
Notwithstanding this, whilst it is clearly desirable for new development to achieve the highest possible water efficiency, the mandatory national standard set out in the Building Regulations is 125 litres/person/day. NPPG Paragraph 56-014-20150327 states that where there is a clear local need, Local Plan policies can require a tighter optional requirement of 110 litres/person/day.
The Councils’ acknowledge that the 80 litres/person/day goes beyond what Local Authorities are currently able to require but considers there is a strong case for greater water efficiency in Greater Cambridge based upon strong evidence provided by the Integrated Water Management Study. This would make full use of water efficient fixtures and fittings, water reuse measures on site including surface water and rainwater harvesting, and grey water recycling. It acknowledges that the cost effectiveness improves with the scale of the project.
The Councils’ 80 litres/person/day target is not considered realistic. Instead, it is considered that the tighter optional requirement of 110 litres/person/day should be encouraged. It may be appropriate to set tighter standards for certain site allocations but a blanket requirement of 80 litres/person/day is not realistic.

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 to the East Side of Cambridge Road, Melbourn, 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 to the East Side of Cambridge Road, Melbourn 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) are 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 to the East Side of Cambridge Road, Melbourn is located within Flood Zone 1 with low risk of surface water flooding. In this regard the Site should be assessed as having a Green or Amber Flood Risk rating. In either instances, the 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 the summary of “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.

The National Trust supports the ambitions of this policy.

The RSPB supports the principles outlined for this policy. Public water supply is a key environmental limiting factor in Greater Cambridge and it is imperative that new development enables much lower per capita consumption rates. As such we agree that ambitious requirements are justified.

According to the Stantec Report, Cambridgeshire is water stressed and already does not have enough water to support the existing community, let alone those proposed (some 40,000+ dwellings). We have a lower average rainfall than parts of Syria in the Middle East, for example. Our unique chalk streams (approximately 85% of the worlds’ 200 chalk streams are in the south of England) have crystal clear water, are a haven for otters, water voles and kingfishers, but are threatened by the ever increasing stress we are putting on them by ongoing development.
SCDC has noted that none of its proposed developments in the new Local Plan can go ahead unless more water is found. We support this position. Indeed, we would encourage all relevant authorities to go further and to ensure that water efficiency measures are introduced even for the existing developments to enable the aquifer to recover within a reasonable timescale.

What support will be available for developers in seeking to meet the high standards proposed? Will the potential impact on viability be taken into consideration? Regardless of the chosen approach, it would be useful to include further guidance/information in a supplementary planning document (SPD).

Cambourne Town Council understands the need for this policy as it addresses the aims contained in the vision.

As I said, I strongly endorse your section Ensuring a deliverable plan – water supply (pp 41 -42). Complete coordination with every organisation involved in water supply is absolutely essential.

Shepreth Parish Council (SPC) notes the Stantec report and the requirement for strategic intervention on water supply, presumably a new reservoir or pipeline.

This policy introduces requirements for water efficiency in new domestic and non-domestic development in the form of the following:
• 80 litres per person per day for domestic development; and
• Full BREEAM credits for Wat 01 for non-domestic development.
Countryside acknowledge that the Greater Cambridge area is under water stress and there is a strong encouragement for all new development to improve water efficiency however with respect to draft Policy CC/ WE we have the following comments:
• We agree with the statement on Page 26 of the Topic Paper that the highest water efficiency standard that can be requested by local authorities is 110 l per person per day (pppd).
• We also agree that achieving 80lppd will require either rainwater harvesting and/ or greywater recycling. Both systems introduce significant maintenance requirements (and therefore cost) for homeowners and introduce technology that has not been tested ‘en-masse’. Countryside’s experience of trialling grey water recycling is that it is unreliable and likely to cause maintenance issues for homeowners
• Given the unreliability of greywater recycling Countryside believe the only practical mechanism to achieve the 80lpppd would be through the use of rainwater harvesting systems which have the following constraints;
‒ Such systems are more difficult for flats given that communal harvesting tanks (which are more expensive) would be necessary; and
‒ Greater Cambridge is already one of the driest areas in the UK and climate change is predicated to reduce rainfall in Greater Cambridge by 47% it is highly likely that rainwater harvesting will not capture sufficient rain to meet the policy target and will therefore be ineffective.
• Given the above, Countryside believe that the GCLP should implement the Government’s technical standard for water efficiency for Policy CC/ WE which is 110 lpppd. This would be viable, deliverable and achievable for all new dwellings within GC. Should technology such as grey water recycling become viable during the lifetime of the plan then this could be considered as a means to improve water efficiency beyond the target of 110 lpppd.

Climate change – water supply issues
50. Policy CC/WE: Water efficiency in new developments, is not going to solve the potable water crisis
affecting Cambridgeshire, a crisis which is only likely to deepen if the report written by Stantec for the
Shared Planning Service is ignored.
51. The Environment Agency document titled “Water stressed areas – final classification 2021”, published in
July 2021 by DEFRA, included the fact that the supply areas of Cambridge Water and Anglian Water are
areas of serious water stress, page 6. According to Appendix 3 of this document, 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.
52. Anglian Water’s proposed solution to this problem, pumping water from North Lincolnshire, appears
completely impracticable because the Environment Agency, in the same report, has also classified North
Lincolnshire as an area of serious water stress.
53. Another solution being considered by Anglian Water, according to Water Resources East, is to build two
reservoirs in the Fens. However, this idea seems to completely ignore the fact of sea level rise which will
likely cause much, if not all, of the Fens to be flooded by seawater within decades.

I have asked Caldecote Parish Councillors to comment upon the emerging Local Plan.
There are no significant objections not the proposed sites.
Comments included were:
• Installation of charging points
• Bicycle lane and green walkways
• Adequate community facilities
• Access to mental health care
• Limited rural village development
• Small commercial/retail premises in rural communities
• Communication infrastructure (Fibre)
• Water consumption and the use of grey water
• Green space and more diversity
• Farming community to consulted.

This is a summary of comments received.

Compendium of Environment Agency Comments

Vision and aims
The vision on page 20 is positive bringing to the forefront decreasing climate impacts, minimising carbon emissions, increasing nature, wildlife and green spaces. Reflecting on the paragraph on page 18, you outline the aim for the Local Plan is simple: to ensure sustainable development. This means planning for homes, jobs and supporting infrastructure in the right places, alongside protecting and enhancing the environment. We recommend the vision reflects this objective of ‘sustainable development.’ For example, we suggest the following revision as follows: New development must be sustainable: minimise carbon emissions and reliance on the private car; create thriving neighbourhoods with the variety of jobs and homes we need; increase nature, wildlife and green spaces; and safeguard our unique heritage and landscapes. This will align closely to the aims of the NPPF (paragraphs 7 and 8) and also demonstrate the importance of this for Greater Cambridge given the unique challenges and opportunities the area faces.

We support the references within the aims to highest achievable standard for water use and resilient to current and future climate risks. The biodiversity and green spaces aim is also positive in its focus on improving the network of habitats and ensuring development leaves the natural environment better than it was before. All these aims will help GC achieve the stated vision and it’s important that the interrelationship and interdependencies between these aims are recognised. Recognising the interdependencies will strengthen and ultimately achieve better outcomes for GC. One example is the ecological health and water quality of rivers and water dependant habitats (e.g. wetlands) is also dependent on the availability of water in addition to the contribution developments will make in creating and enhancing habitats and green space. Healthier rivers and water dependant habitats will in turn restore nature, improve the health and wellbeing of communities and have economic benefits. Serving the environment in tandem with growing communities is mutually beneficial and secures long-term resilience. This also reflects the paragraph 153 of the NPPF: ‘plans should take a proactive approach to mitigating and adapting to climate change, taking into account the long-term implications for flood risk, coastal change, water supply, biodiversity and landscapes’ etc.

S/DS Development Strategy
We welcome the section on ‘Ensuring a deliverable plan – water supply’ on pages 41 and 42, which recognises this as a significant issue for the Local Plan. We remain genuinely concerned about whether the growth proposed (48,800 new homes inclusive of 10% buffer and 37,200 from previous plans) can be sustainable without causing further deterioration to the water environment. We understand the regional and water company water resource planning is still ongoing and the next version of the IWMS Detailed WCS will be updated as these plans come to fruition. We offer our support to work collaboratively with all the parties involved.

Current levels of abstraction (not just in Cambridge) are causing environmental effects. Increase in usage within existing licenced volumes will increase the pressure on a system that is already failing some environmental targets. The Anglian River Basin Management Plan shows many waterbodies do not have the flow required to support the ecology. Abstraction licencing reductions are likely to reduce the supplies available to water companies in our efforts to prevent deterioration of the water environment. As the plan and evidence base progresses it will need to be clearly demonstrated that the water companies plans can meet the needs of growth without causing deterioration.

As a best case scenario the strategic water infrastructure (new Fenland reservoir) would be available from the mid-2030s and its foreseeable this could be later i.e. the 2040s. It is the short to medium term period coinciding with the majority of the plan period for which rapid and viable interim solutions are needed. There is currently uncertainty about whether water supplies can be provided (both supply and demand management) in a way that is both sustainable and sufficient for the proposed growth over the plan period.

We support the idea of development limited to levels that can be supported by a sustainable water supply (phased delivery) until the time the strategic infrastructure is in place, though we are mindful this may lead to heavily back loaded delivery. If the Council approaches neighbouring local planning authorities as you already recognise it is likely they will have similar issues, though some may have more options for interim solutions. This highlights the importance of cooperating across planning boundaries and growth plans being considered in the context of the combined pressure on water supplies at a regional scale. As previously mentioned, 2050 may be a more appropriate end date for the plan period given the challenges being faced which in reality require a longer lead in time to support development, e.g. strategic water resources infrastructure, climate change resilience, etc. This would also align with paragraph 153 of the NPPF ‘plans should take a proactive approach to mitigating and adapting to climate change, taking into account the long-term implications for flood risk, coastal change, water supply, biodiversity and landscapes’ etc.

Integrated Water Management Study – Outline Water Cycle Strategy
The WCS will rely on further evidence coming forward from both regional and water company water resource plans. The WCS will need to demonstrate that feasible and deliverable mitigation measures are available for the interim period until new strategic water resources options will come online.

As noted, the WCS will need to base its assessment on the forthcoming water resource plans (WRMP24) rather than the existing, as this will have a more accurate picture of the water resources situation taking into account abstraction licence reductions. Both Cambridge Water and Anglian Water are likely to require further sustainability reductions in PR24. This could mean some or all of the current water surplus’s (available headroom) are no longer available for transfer.

The reliance on demand management options is currently high-level. These will require assessment of feasibility, effectiveness and how implementation will be monitored and measured corrected if they are not working.

In facing what is collectively a significant challenge we offer our support to work collaboratively with the interested parties ahead (and beyond) the next consultation in 2022.

S/NEC: North East Cambridge
We note the intention of the policy is to set out the place-making vision and a robust planning framework for the comprehensive development of this site. There are both environmental risks and opportunities to developing this site sustainably. Ensuring sustainable water supplies, improving water quality and the effective remediation of land contamination will be key considerations in achieving this. The proposed policy direction anticipates the site (once developed in full, which will extend beyond the Local Plan period of 2041) will deliver 8,350 new homes. The IWMS Detailed WCS will need to provide evidence the new homes (and employment) can be sustainably supplied with water in time for the development phases.

The existing site at Fen Road, Chesterton continues to be a source of ongoing local water quality and environmental health problems due to inadequate foul drainage provision. There have been a number of reports of foul sewage from the site discharging into the River Cam, causing chronic on-going pollution. The relocation of the existing Milton sewage works and extensive redevelopment of North East Cambridge presents the opportunity to incorporate mains drainage connection into the Fen Road site.

Policy S/NS: Existing new settlements
With regard to the existing allocations NS/3 and SS/5 Northstowe, we are investigating flood risk management options to reduce the risk of flooding in Oakington. This will take account of measures looking to attenuate water upstream (on the upper reaches of Oakington Brook and as part of the Northstowe development), potential channel modifications and natural flood management. We note that early phases of Northstowe are under construction. We recommend the emerging policies include this as an opportunity both in terms of delivering flood risk management measures or securing financial contributions towards this project.

CC/WE: Water efficiency in new developments
We support stringent water efficiency in water stressed areas. We recommend reviewing the document The State of the Environment: Water Resources (2018) prepared by the Environment Agency. This document outlines the challenges we now face summarised as follows. Water supply (resource) is under increasing pressure from population growth, land use change, and climate change (including hotter weather increasing evaporation, less rainfall in summer, and intense rainfall events not recharging aquifers efficiently). Without increasing our supply, reducing demand, and cutting down on wastage many areas will face significant deficits by 2050, if not sooner. If not addressed this represents an immediate and measurable blocker to future growth. We need to consider development in the context of available water resources, balancing economic growth with protecting and enhancing the water environment. We will need to ensure that there is enough water for both people and the environment, that water is used efficiently, that water is protected as a precious resource, and that wastewater is treated efficiently to cut associated carbon emissions.

We agree the evidence of the water resources situation in Greater Cambridge justifies the tighter standard of 80 litres/person/day for housing. The risk of this standard not being met is an increase in abstraction risking deterioration of associated water bodies. As page 150 recognises (with reference to the Deregulation Act 2015) GC Council will need to be satisfied that this standard can be legally and practically implemented in the context of current legislation (Water Industry and Development Industry), national policy and building regulations. This affects the practical implementation of this policy. It would need to be determined the evidence/metric applicants would be expected to submit to demonstrate this standard has been achieved. It would also need to be evidenced how the policy standards would be implemented, and how this would be monitored to ensure the policy is effective.

A positive standard is proposed for non-residential development, which we support. Water neutrality should also be explored, noting the references made to water reuse and offsetting.

The Integrated Water Management Study (IWMS) states that 80 litres/person/day is achievable by making full use of water efficient fixtures and fittings, and also water re-use measures on site including surface water and rainwater harvesting, and grey water recycling. It comments that the cost effectiveness improves with the scale of the project, and that a site-wide system is preferable to smaller installations.

Currently the policy direction has a caveat of ‘unless demonstrated impracticable.’ This should be explored further in the WCS so the Council has clear guidance on the circumstances where achieving this standard would be impracticable. This will help ensure planning applications can be fairly and reasonably assessed. This will also help ensure the overall goal of the policy is not weakened or undermined. Similarly this evidence needs to be drawn out for the non-residential standard. The WCS should also set out the backstop position should the standard of 80 litres/person/day be practicably unachievable.

Although we support water efficiency measures in new development, we consider that the plan is currently unlikely to achieve the kinds of reductions in demand needed to keep the proposed levels of growth within sustainable levels. As noted with policy S/DS, the evidence base (IWMS Detailed WCS) will need to demonstrate how the water companies’ plans can meet the needs of growth without causing unsustainable abstraction and associated deterioration. We offer our support to work on this collaboratively with the interested parties both ahead of the next consultation in 2022 and beyond.

Page 150 references the Shared regional principles for protecting, restoring and enhancing the environment in the Oxford-Cambridge Arc. We recommend this is also considered and referenced elsewhere in the plan with regards to net zero, net gain, tree cover and strategic resource infrastructure provision.

CC/DC: Designing for a changing climate
The proposed policy intends to set out how the design of developments should take account of our changing climate, for example, extreme weather events including flash flooding. We welcome the reference (p. 152/153) to site wide approaches to reduce climate risks, including sustainable drainage systems as part of landscape design, urban greening, increased tree canopy cover and integrating green spaces into new developments. In the context of flooding and climate change it would also be appropriate to reference flood resistance and resilience measures (see PPG: https://www.gov.uk/guidance/flood-risk and-coastal-change#Flood-resilience-and-flood-resistance). Site wide approaches should also include adaptive measures such as setting a development away from a river so it is easier to improve flood defences in the future. In addition, making space for water to flood and be stored will be critical to long term adaptation. Planning to avoid future flood risk is as much about creating storage or contributing to nature based flood risk reduction measures (e.g. creating wetland habitats) as it is avoiding flooding to new properties.

In shaping this policy, we recommend GC Council also consider the ADEPT local authority guidance on preparing for a changing climate (2019) and the new TCPA The Climate Crisis, A Guide for Local Authorities on Planning for Climate Change (October 2021).

The Fens Baseline Report (available at https://www.ada.org.uk/knowledge/future-fens/) indicates that rising sea levels to 2115 will mean water will not drain by gravity to the sea, requiring the pumping of vast quantities of water. The carbon and engineering implications of this are significant but not yet calculated. There is a compelling case for surface water to infiltrate into permeable ground ensuring that water resources are not depleted of water. In areas of less permeable geology, net gains in surface water attenuation and re-use of the water as ‘green water’ in homes, businesses or agriculture has been considered through this study.

CC/FM: Flooding and integrated water management
We welcome the inclusion of Policy CC/FM. We agree a policy that responds to the local water management issues is needed. As climate change will intensify the existing pressures on water availability, water quality, drainage and flood risk an integrated approach to water management will be essential. As stated this should include a robust approach to drainage and water management. The proposed policy direction is a good starting point but given the water challenges (our comments to Policy S/DS) it should strive to secure both mitigation and betterment through growth.

The local policy approach should be informed by the IWMS Water Cycle Studies, the Level 1 SFRA and other relevant strategies. We would expect to see the policy content evolve with the following considerations:

1) Though the policy direction indicates that policies will require that the risk of flooding is not increased elsewhere, it should seek to secure betterment and reduce flood risk overall, wherever possible, as part of GC’s strategy to adapt to climate change. This aligns with our previous comment that making space for water to flood and be stored will be critical to long-term adaptation. Floodplain storage, natural flood management and surface water attenuation are all measures that will contribute. Protection of potential flood storage land (including functional floodplain/Flood Zone 3b) and financial contributions towards flood risk schemes could also benefit communities at risk of flooding are also much needed options. Although many sites are located in Flood Zone 1 (low probability of flooding from rivers) there are also many sites located on the fringes of Flood Zones 2 and 3 meaning these are at risk of reducing (potentially eliminating) future flood storage options for adapting to climate change. In the background, urban creep and small infill developments which do not attenuate for surface water impact drainage systems and watercourses downstream. In planning to manage future flood risk in GC, creating extra storage to allow space for flood waters is a vital element of that plan.

2) We expect the policy to include provision for water supply and waste water infrastructure, ensuring water quality and treating and re-using waste water. We recommend that the provisions of Policy CC/7, ‘Water Quality’, of the South Cambridgeshire Local Plan 2018 are considered and brought forward into the Greater Cambridge Local Plan. Site policies may also need to include specific infrastructure requirements. These should become apparent, and be informed by, assessments carried out in the IWMS Detailed Water Cycle Study.

3) There needs to be a policy approach that recognises a clear integration encompassing water resources, water quality, flood risk and recognising the role of green infrastructure. Although the value of green infrastructure and river corridors is recognised in policy BG/GI and BG/RC, it is worthwhile including it as part of the integrated water management policy. The Greater Cambridge Green Infrastructure Opportunity Mapping Study touches upon this relationship under the Water Storage bullet as follows: Our rivers are a source of flood risk. Restoration of natural flood plains where practicable and provision of green infrastructure can help reduce flood risk along the rivers itself and beyond. Wet woodland will self set and grow where conditions are right and management allows. Providing the right conditions for trees to grow in appropriate locations in river corridors can support flood risk mitigation and biodiversity.

Integrated Water Management Study – Outline Water Cycle Strategy (WCS)
For water quality we welcome that the Outline WCS has been amended based on our previous feedback. However a number of issues raised remain unresolved which we can expand upon in a more detailed response to the Council’s consultants. Some of the information presented does not represent the proper ‘baseline’ for subsequent assessments and the extent of the challenge of delivering the quantum of growth proposed in the Local Plan. For example, 2019 WFD classification data is presented but waterbody objectives are from 2015, also the information in chapter 6 does not take account of river quality improvements delivered by AMP6 or AMP7 schemes. The identified assessment methods need to be sufficiently robust, and potential mitigation actions will need to be shown to be viable. The Detailed WCS will need to provide evidence to demonstrate the delivery of foul drainage provision can be provided whilst protecting water quality of rivers.

Climate change topic paper (IWMS Level 1 Strategic Flood Risk Assessment)
We have reviewed the Level 1 SFRA. The majority of sites are in fluvial Flood Zone 1 with a proportion of sites with partial Flood Zone 2 and 3 either within the site boundaries or close to boundaries. Surface water flood risk also affect most of the sites to a limited or greater extent. Flood risk and climate change adaptation is an important consideration of the Local Plan in view of the predicted impacts of climate change on flood risk. Page 39 of the Climate Change Topic Paper states that the Level 1 SFRA (2021) has been used to support the selection of development sites through the application of the Sequential Test. This statement within the topic paper is helpful, however, it does need to be more obviously demonstrated how the Sequential Test and sequential approach to all forms of flooding has been applied. The Planning Practice Guidance advises a number of options for this including a standalone report, Sustainability Appraisal commentary, etc. This will need to be produced in time for the next draft plan consultation so it is clear how the test has been applied and demonstrated.

Page 42 explains that where necessary a Level 2 SFRA of sites in the draft plan will be carried out to ensure that designs and capacity fully reflect management of flood issues. We think that a Level 2 SFRA is necessary particularly for those sites located on the fringes of Flood Zones 2 and 3, or partially within those zones. In predominantly flat or fenland areas, breaches in flood defences can cause flooding in Flood Zone 1 due to the concentration of floodwater in one part of the floodplain, for example, the Waterbeach New Town allocation. Some sites have unmapped ordinary watercourses running alongside or through them and often these have not been modelled as part of the indicative flood map due to their limited upstream catchment size. As such there is some uncertainty over the level of flood risk to the site, with the potential that fluvial flood risk may be greater than the Flood Map for Planning. These sites will 7 require further investigation to better refine the flood extents (including climate change) preferably by flood risk modelling or utilising the Flood Map for Surface Water (FMfSW). For some sites, fluvial climate change assessment is required as this is not modelled.

A Level 2 SFRA could also identify suitable land or techniques that could be used for flood storage to adapt to climate change and urban creep. Even if these cannot be brought forward at this stage in the plan, these could be protected for future plans or for infrastructure to bring forward at the appropriate time. The LLFA may also have areas of surface water flooding to be further investigated. The Level 2 will help determine whether the site can be developed safely, mitigation measures required, sequential approach and applying the Exceptions Test (NPPF paragraph 164). The Level 2 SFRA should inform the site specific polices within the plan that will form the planning framework for the sites. We can provide a separate list of the sites we think would require L2 SFRA assessment if helpful.

BG/BG: Biodiversity and geodiversity
This policy will control biodiversity impacts from development and set out Biodiversity Net Gain requirements (aiming for 20% BNG). We welcome and support the Council’s policy direction on this. It should be clear that BNG is in addition to the standard requirements of the mitigation hierarchy i.e. avoid harm where possible, mitigate for the effects or compensate (paragraph 180 of NPPF). We recommend that local authorities adopt a natural capital evidence approach to underpin their local plan. This is mentioned briefly in the evidence base within the green spaces topic paper. Information can be found here. Natural Cambridgeshire have done some work in this area, looking at opportunity mapping. Also, the recent Oxfordshire Plan 2050 (Reg 18) had some good natural capital and ecosystem services wording (policy option 09) that we recommend you consider. Preparation of a natural capital evidence base and policy is something we (and likely Natural England) could advise on in advance of the next consultation stage.

Wider environmental net gains is also identified as a potential policy requirement which we support, and pending further guidance from a national level. We recommend that geodiversity is also considered.

We recommend ambitious maintenance requirements to protect and ensure longevity of net gain enhancements. The Environment Bill mandates 30 years but ‘in perpetuity’ should be aimed for where possible.

The proposed policy direction includes that off-site measures must be consistent with the strategic aims of the Greater Cambridge green infrastructure network strategic initiatives. We welcome the GI initiatives so far identified within the GC Green Infrastructure Mapping which include revitalising the chalk stream network, the River Cam corridor and enhancement of the fens.

This work can also help to inform a future Local Nature Recovery Strategy in identifying valuable sites, sustainable land management and how the loss and/or fragmentation of existing habitats should be avoided as much as possible. The creation of bigger, better and joined-up habitats will be beneficial to wildlife, contributing towards the local plan’s objective of doubling nature. The creation of large networks will also support ecological resilience to predicted future impacts from climate change and are likely to overlap with net gains in flood risk management.

We recommend this policy also acknowledge the significance of invasive non-native species (INNS) and their impacts on wildlife and the environment. INNS are considered one of the top five threats to the natural environment. They can impact on wildlife, flood risk, water quality and recreation. Costs to the economy are estimated at £1.8 billion per year. Prevention through adopting biosecurity measures can help to reduce the spread and impacts of INNS.

BG/GI: Green infrastructure
We support the policy direction which will require all development to include green infrastructure, and protect/enhance water environments. We welcome the list of green infrastructure initiatives on page 8 173/174 which includes revitalising the chalk stream network and references the River Cam. It’s positive that developments will be expected to help deliver or contribute towards these to enhance the existing green infrastructure network.

In addition, we consider ‘connectivity’ as a key component of this policy. As noted in the Sustainability Appraisal (Non-Technical Summary p. 15) fragmentation and erosion of habitats can be detrimental to wildlife. Existing and new habitats and greenspaces should be retained and enhanced, in connection with existing habitats and the wider countryside, establishing a coherent ecological network, as per the NPPF. We support the references to ‘providing links’ and connecting to the wider ecological network as part of this policy, as this will be invaluable to both green infrastructure provision and nature recovery.

Existing areas of habitat and green spaces within proposed development footprints should be protected and incorporated within landscape designs where possible. As well as protecting existing areas of habitat, mitigation and environmental enhancements can be delivered through appropriate design that includes creation of new habitats and green spaces. New habitats should be representative of and complement the local landscape character, whilst being linked to existing features and the wider countryside, creating joined-up, resilient ecological networks

BG/RC: River corridors
We support the inclusion of a policy to manage development that has an impact on river corridors and proposes to protect, enhance and restore natural features, supporting re-naturalisation. This is particularly important for Cambridge due to the presence of chalk streams and the role rivers and their associated floodplains play in managing flood risk and provision of habitats. The proposed policy direction includes ‘ensure that the location, scale and design of development, protects and enhances the character’ and we recommend this includes the provision of appropriate setback of developments from rivers to provide sufficient space for flood waters as well as safeguarding the integrity of the river banks and the development itself. Rivers unless they have been artificially straightened move through their landscapes through natural processes of erosion and deposition. Although river migration occurs over long time periods, developments should be set back generously to account for this alongside climate change. Natural flood management also has the potential to deliver multiple benefits. Tall buildings can have an adverse effect if located too close to a watercourse by introducing overshadowing impacts and artificial lighting which disrupts natural diurnal rhythms of wildlife such as bats.

Wellbeing and inclusion – general comments
We recommend reviewing the document The State of the Environment: Health, People and the Environment (2020).This report, prepared by the Environment Agency, highlights the substantial body of evidence indicating the physical and mental health benefits of spending time in the natural environment. Access to the natural environment is not equally distributed, those living in deprived areas often have poorer quality environments with less accessible green and blue space. The GC Local Plan presents an opportunity to level-up communities, tackling this green inequality at scale and improving the health and wellbeing of those living and working in the GC area, by creating and contributing to healthier, greener, and more accessible environments. This must, however, be achieved in balance with the need to protect the environment, by providing appropriate wildlife refuges from human disruption and interference.

WS/HS: Pollution, health and safety
We would welcome a policy that details how land contamination should be considered, ensuring the land is suitable for the end use but also ensuring that water quality of the underlying aquifers is protected.

There are some plans and strategies that will be relevant to inform this policy. In 2018 the Government committed through the 25 Year Environment Plan to ‘achieve clean air’ and to ‘minimise waste, reuse materials as much as we can and manage materials at the end of their life to minimise the impact on the environment’. The State of the Environment: Health, People and the Environment (2020) highlights the extent of the threat that air quality poses to health in the UK, shortening tens of thousands of lives each year. Analysis also shows that areas of higher deprivation and those with high proportions of ethnic minorities are disproportionately affected by high levels of air pollution. Growth plans provide the opportunity to address these inequalities by improving the quality of the environment and strategically planning the location of land use types.

We welcome that the policy will provide protection to and from hazardous installations. However, Waste management facilities also have the potential to pollute the environment, cause nuisance or amenity issues through dust and particulate emissions to air, release to ground and surface water, and to leave a legacy of contaminated land. Studies have found that more deprived populations are more likely to be living closer to waste sites, and can therefore at times be subject to greater impacts such as noise, litter, dust, odours, or increased vehicular traffic. Strategic planning of waste and resource use provides the opportunity to address this issue.

H/RC: Residential caravans
This policy will set out the criteria to be used when considering proposals for new residential caravan sites. Annex C ‘Flood risk vulnerability classification’ of the National Planning Policy Framework (NPPF) classifies caravans, mobile homes and park homes intended for permanent residential use as highly vulnerable. Permanent caravans, mobile homes and park homes if located adjacent to rivers are at significant risk from being inundated very quickly from floodwaters, without sufficient warning or adequate means of escape. There are additional dangers from the potential for floating caravans (if they become untethered), cars and objects/debris becoming trapped beneath the caravans will increase the risk by displacing floodwater elsewhere.

Page 295 states that an accommodation needs assessment is currently being developed. The Sequential Test (paragraph 161 of the NPPF) should also be applied to the accommodation needs assessment to avoid where possible locating accommodation sites in areas at risk of flooding. This should be informed by the Level 1 and where necessary a Level 2 SFRA. We recommend given the high vulnerability of this type of accommodation that flood risk is a key consideration within the policy criteria.

H/GT: Gypsy and Traveller and Travelling Show People sites
The proposed policy direction includes ‘Sites are capable of providing an appropriate environment for residents in terms of health, safety and living conditions.’ Similar to our comments to Policy H/GT above, Annex C ‘Flood risk vulnerability classification’ of the NPPF classifies ‘caravans, mobile homes and park homes intended for permanent residential use’ as highly vulnerable. Sites used for holiday or short let caravans and camping (subject to a specific warning and evacuation plan) are classified as more vulnerable. We recommend given the higher vulnerability of this type of accommodation that flood risk is a key consideration within the policy criteria.

Page 298 states that a joint accommodation needs assessment is currently being developed. The Sequential Test (paragraph 161 of the NPPF) should also be applied to the accommodation needs assessment to avoid where possible locating accommodation sites in areas at risk of flooding. This should be informed by the Level 1 and where necessary a Level 2 SFRA.

The existing site at Fen Road continues to be a source of ongoing local water quality and environmental health problems due to inadequate foul drainage provision. There have been a number of reports of foul sewage from the site discharging into the River Cam, causing chronic on-going pollution. Water quality and ensuring appropriate drainage infrastructure is also an important consideration for these sites, both in terms of protecting the environment and safeguarding the health of the site occupiers. Policy H/23 ‘Design of Gypsy and Traveller Sites and Travelling Showpeople Sites’ in the South Cambridgeshire Local Plan 2018 provides an example of this, with the following wording: d. All necessary utilities can be provided on the site including mains water, electricity supply, drainage, sanitation and provision for the screened storage and collection of refuse, including recyclable materials;” Policy H/GT should include provision for mains foul drainage and protection of water quality as part of the policy criteria.

Infrastructure – general comments
Infrastructure and connectivity improvements, must be achieved in balance with the need to protect natural spaces, providing both accessibility and retaining restricted access refuges for wildlife. There is the opportunity to achieve both if, for example, cycle and pedestrian networks are considered strategically and systematically alongside green infrastructure and natural capital networks. A holistic approach to connectivity and infrastructure should be adopted, considering the multifunctional possibilities that provision of new transport and utilities infrastructure provide. For example, by integrating new road or rail schemes with flood resilience measures, energy generation, and green infrastructure enhancements.

I/SI: Safeguarding important infrastructure
We welcome the intention to work with infrastructure providers to consider whether planned strategic infrastructure or future land should be safeguarded. This should also include land for flood storage and flood risk infrastructure which is likely to include river corridors. Managing flood risk both now and in the future will require the plan taking a pro-active approach taking into account climate change. Your SFRA evidence base can inform this identification for safeguarding. The functional floodplain (Flood Zone 3b) is a zone comprising land where water has to flow or be stored in times of flood, identified in SFRAs and deemed to be the most at risk of flooding from rivers or sea. The SFRA should also gather information on flood risk management projects. The GOSIS (formerly Great Ouse Storage and Conveyance study) will assess how flood risk within the catchment can be managed now and into the future, giving a high-level evaluation of the costs of benefits of providing large storage volumes in the catchment. The GOSIS project will look for areas for flood risk management and draft outputs from this likely to be available towards the end of GC Local Plan process. There is also the Girton Flood Alleviation Scheme (Washpit Brook catchment) and flood risk management options at Oakington Brook (the latter referenced in our comments to Policy

As mentioned for Policy CC/FM, although a sequential approach has been considered there many sites proposed on the fringes of Flood Zones 2 and 3. This reduces and potentially eliminates future flood storage options for adapting to climate change. It’s important the L2 SFRA assesses these sites for their deliverability but also a broad perspective is taken to planning for flood risk both now and in the future. Creating extra flood storage to allow space for flood waters will be a vital component of that plan. We’d also expect safeguarding to include what is required for water infrastructure more broadly (water supply and waste) and green infrastructure/biodiversity.

I/ID: Infrastructure and delivery
We support the policy direction to propose to only permit development if there is, or will be, sufficient infrastructure capacity to support and meet all the requirements arising from the new development. The developer certainly has a role in this, beneath a robust and deliverable strategic framework led by the Council and other strategic infrastructure providers (informed by evidence).

As noted for Policy S/DS, we support the idea of development limited to levels that can be supported by a sustainable water supply (phased delivery) until the time the strategic infrastructure is in place. It is important that development is sustainable and the environment is protected throughout the process of infrastructure planning.

Uses standard measurement of 80 litres/per person/per day, unless demonstrated to be impractical. Requires high water efficiency in developments. Standard building regs are 125 litres/per person/per day - or building regs are 110 litres/per person per day. Which will be used in general?

Barrington Parish Council (BPC) is pleased to have the opportunity to respond to the Greater Cambridge (GCP) Local Plan First Proposals (FP).

1. Overall
1.1. BPC supports the FP development strategy in general terms and supports the principles of plan-led, sustainable development that underpin the FP. BP also supports the general themes of responding to climate change, biodiversity and green spaces, well-being and social inclusion, and great places.

1.2. The wording of many of the proposed policies is incomplete and as always, the devil is in the detail - especially regarding Jobs, Homes and Infrastructure which have the greatest potential impact on the quality of the local environment. BPC is of the view that while these issues are obviously central to any Development Plan, mitigating potentially detrimental effects on rural communities in South Cambridgeshire needs to be managed through effective, carefully worded policies in the Plan.

1.3. BPC particularly welcomes the recognition of and need for reinforcement of the distinctive character of South Cambridgeshire villages.

1.4. However, BPC wishes to make some general strategic and some specific comments as follows.

2. Strategic Issues
2.1. The 2018 Local Plan for South Cambridgeshire is to be succeeded by a Local Plan for a much wider constituency developed by a Partnership for “Greater Cambridge”. This inevitably creates tensions between the interests of the city and those of the surrounding, primarily rural areas. It has to be acknowledged that development pressures in and from the city of Cambridge have significant effects upon the surrounding areas and not all of these are positive and beneficial.

2.2. The First Proposals also seek to support both the Oxford Cambridge Arc Spatial Framework and the proposed East West Rail connection - both of which introduce additional development pressures and significant environmental impacts upon South Cambridgeshire.

2.3. The First Proposals are therefore in a key sense no longer for a “Local” Development Plan but in effect have been transformed into a Regional Development Plan where the local interests and concerns of villages such as Barrington lie at the bottom of the hierarchy of interest and control.

2.4. Policy S/DS. BPC has already placed on record and wishes to re-state its fundamental opposition to both the Oxford Cambridge Arc Spatial Framework and the proposed East West Rail southern route into Cambridge. BPC has concerns that these may lead to central government-imposed rather than locally-agreed development in South Cambridgeshire which will be highly detrimental to the area.

3. Specific Matters
3.1. Policy S/DS BPC agrees that brownfield development should be prioritised and in locally - agreed not nationally targeted locations. Development “around” the villages is not considered sustainable.

3.2. Policy S/SH. BPC supports the retention of the settlement hierarchy, and the definition of Group Villages should be retained as proposed from the 2018 Local Plan, possibly reinforced with stronger wording to restrict exceptional development of up to 15 dwellings only on brownfield sites.

3.3. Policy S/ JH. BPC has concerns about the notion of “Windfall Development”. Either we have a Development Plan or not – the notion of “unplanned” “windfall” or “opportunistic” development – especially if it were to be determined by officers as opposed to councillors – is not compatible with “plan-led development”. The opening the door to opportunistic applications that run counter to the direction of the Development Plan.

3.4. Policy GP/GB. Similarly, BPC opposes development intrusion into the Green Belt. Development “creep” – even for “nationally significant” development should be resisted.

3.5. Policy S/SRC. BPC is concerned about the definition and implications of the “Rural Southern Cluster” and this requires much more detailed elucidation, explanation and justification.

3.6. Policy WS/CF. BPC believes that Community Healthcare facilities should be prioritised as they have been poorly provided for under the current Plan. Much stronger policy definition is required.

3.7. Policy CC/WE. The FP recognise that availability of water resources is a major issue in Greater Cambridge and that the level of growth has significant constraints with regards to water supply. BPC shares these concerns. Policy should address this issue more comprehensively.

4. The Consultation Process
4.1. BPC is pleased to have the opportunity to engage to the extent that it is able with the FP consultation.

4.2. However, GCP’s consultation on the Local Plan is a convoluted process. The material is voluminous, there are 60 policies and the maps are often difficult to interpret electronically, and this militates against inclusion of the diverse age and socio-economic groups in a rural population. It comes across as an IT driven process designed for an urban sophisticated readership. Further thought needs to be put into reducing the complexity but increasing the inclusion, accessibility, and meaningfulness of this consultation.

OBJECT because the policy needs further investigation.
The cost and carbon content of reuse should be not be excessive given that c.90% of all water used in buildings could otherwise be treated at a WWTW and then be available to meet minimum environmental minimum flows or other demands downstream.
The reliance on reduced demand must not act as a fig leaf cover for an increase the use of drought orders and restricted supply at times of shortage.

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.

Contents
1. Introduction 1
2. Taylor Wimpey’s Corporate Commitment to creating a more sustainable business 2
3. The Greater Cambridge Local Plan Policies 4
4. Summary of Representations 12










































Colin Morrison colin.morrison@turley.co.uk
Client
Taylor Wimpey Strategic Land
Our reference
TAYS3107

December 2021

1. Introduction

1. These representations to the Greater Cambridge Local Plan (GCLP) have been produced by Turley Sustainability on behalf of Taylor Wimpey with respect to their existing and potential future land interests within the Greater Cambridge Area. These representations are focused on the Climate Change Theme of the GCLP and specifically the following policies:

1.1.1 CC/NZ: Net Zero Carbon in New Buildings

1.1.2 CC/WE: Water Efficiency in New Developments

1.1.3 CC/DC: Designing for a changing climate

1.1.4 CC/ FM: Flooding and Integrated Water Management

1.1.5 CC/ RE: Renewable Energy projects and infrastructure

1.1.6 CC/ CE: Reducing Waste and supporting the local economy

1.1.7 CC/ CS: Supporting land-based carbon sequestration

2. Taylor Wimpey fully supports the strategic commitment by the GCLP to positively address the issue of climate change mitigation and adaptation within the plan period and welcome the opportunity to comment on the draft policies to ensure they evolve to meet the tests of soundness and are both deliverable and viable whilst supporting the delivery of much needed high quality, private and affordable homes within Greater Cambridge.

2. Taylor Wimpey’s Corporate Commitment to creating a more sustainable business

3. Taylor Wimpey have a strong corporate commitment to sustainability, environmental and social governance as can be seen from the recent publications on their website of their 2020 Sustainability Report1 and their 2021 Environment Strategy2.

4. Launched in 2021 the Environment Strategy sets out the company’s long term commitment to protecting the environment for future generations by reducing their environmental impact and making it easier for their customers to live a sustainable lifestyle.

5. The strategy focuses on the environmental impacts that are deemed critical to the business which are set our below along with some of the key targets to reduce these impacts:

1.5.1 Climate Change: Protect our planet and our future by playing our part in the global fight to stop climate change:

1.5.1.1 Achieve our science-based carbon reduction target through a range of measures which include reducing operational carbon emission intensity by 36% by 2025 from a 2019 baseline and reducing carbon emissions intensity from our supply chain and customer homes by 24% by 2030, from a 2019 baseline.

1.5.2 Nature: Improve access to and enable enjoyment of nature for customers and communities by regenerating the natural environment on our developments:

1.5.2.1 Increase natural habitats by 10% on new sites from 2023 and include our priority wildlife enhancements from 2021 which includes hedgehog highways, bug hotels and creating 20,000 more nature friendly gardens by 2025

1.5.3 Resources and waste. Protect the environment and improve efficiency for our business and our customers by using fewer and more sustainable resources:

1.5.3.1 Cut our waste intensity by 15% by 2025 and use more recycled materials. By 2022 publish ‘a towards zero waste’ strategy for our sites.

6. One of the key targets within the GCLP is to transition to a net zero carbon Cambridge by 2050. As stated above Taylor Wimpey have a strong corporate commitment to reducing their carbon footprint and have adopted science based carbon reduction targets against which there has been significant progress to date in the form of:

1.6.1 30% reduction in carbon emission intensity since 2013

1 https://www.taylorwimpey.co.uk/corporate/sustainability/2020-sustainability-review
2 https://www.taylorwimpey.co.uk/corporate/sustainability/2020-sustainability-review

1.6.2 39% reduction in absolute carbon emissions since 2013; and

1.6.3 58% green electricity purchased for their sites and corporate emissions;

7. These corporate commitments are resulting in more efficient and environmental friendly construction sites where there is a continued focus to reduce energy use, waste generation and improve our nature and biodiversity impacts.

3. The Greater Cambridge Local Plan Policies

8. Taylor Wimpey have reviewed each of the draft policies within the climate change section of the GCLP and have provided representations for each policy which we hope is of assistance to the Greater Cambridge Shared Planning authorities. Our focus is to ensure that each policy is both viable and deliverable whilst facilitating a shared objective of delivering more high quality affordable and private homes in an area with current and growing demand.

9. Where necessary these representations make reference to the GCLP Climate Change Topic Paper3 which summarises the evidence to support each of the policies and is hereafter referred to as the Topic Paper.

10. For draft Policy CC/ NZ, we have also reviewed the evidence base supporting these specific policies which is the Greater Cambridge Net Zero Carbon Evidence Base Non- Technical Summary and which is hereafter referred to as the Evidence Base document. Unfortunately a more detailed review of the full evidence is not possible as only the non-technical summary has been published and therefore Taylor Wimpey reserve the right to amend our representations once this material has been reviewed.

11. Taylor Wimpey welcome the opportunity to comment on these draft policies and would be happy to discuss our comments in greater detail with the authorities. We also recognise that these are currently policy options which will be informed by consultation feedback. Taylor Wimpey look forward to reviewing the next iteration of the draft GCLP.

Policy CC/ NZ: Net Zero Carbon New Buildings

12. This policy introduces new levels of energy use that will be allowed for new development and how renewable energy should be used to meet that energy need. It also introduces requirements for the assessment of whole life carbon by new development and address the potential issue of carbon offsetting.

13. The policy introduces the following parameters for energy use for new buildings in order to achieve Net Zero for Operational emissions:

1.13.1 A space heating demand of 15-20kwh per meter square per year for residential and non-residential buildings.

1.13.2 All heating provided through low carbon sources and not fossil fuels with no new development connected to the gas grid.

1.13.3 All buildings should achieve a total Energy Use Intensity (EUI) target for both regulated and unregulated energy of no more than 35kWh per m2 per year with a range of different EUI targets for non-domestic buildings as set out in the policy.


3 https://consultations.greatercambridgeplanning.org/sites/gcp/files/2021- 08/GCLP%20Climate%20Change%20Topic%20Paper.pdf

1.13.4 New development should generate at least the same amount of renewable energy (preferably on-plot) as they demand over the course of a year and this should include all regulated and un-regulated energy. In large developments the energy generation can be averaged across the development to compensate for the inability of specific dwellings to meet the target

1.13.5 Offsetting can only be used as a last resort and the building should be future proofed to allow residents or tenants to enable the achievement of net zero dwellings.

1.13.6 To target Net Zero for Construction residential developments of greater than
150 dwellings or 1,000m2 should calculate the whole life carbon of the development and present measures to reduce these.

14. Whilst Taylor Wimpey recognise the importance of addressing climate change, we do have a number of concerns that draft Policy CC/ NZ is unsound on the basis that it is not viable or deliverable and may reduce the delivery of much needed affordable and private housing within the Greater Cambridge (GC) area. We have summarised our concerns below which we hope are helpful to the authorities in their search for sound and effective climate change policies within the GCLP.

1.14.1 It is noted that the dwelling energy efficiency targets within draft Policy CC/ NZ go significantly beyond building regulations including the proposed Future Homes Standard 2025 although the Topic Paper (page 17) states that the standards proposed are not as onerous as the passivhaus standard but do go beyond the proposed FHS. The passivhaus standard is widely recognised as the highest construction standard that is currently available in the UK for residential development as it requires complex construction techniques and therefore carries a cost premium . Analysis of this standard and others compared to the targets within Policy CC/ NZ have identified the following:

1.14.1.1 The passivhaus standard4 requires an EUI of less than 120 kWh m2 per annum compared to the policy target of 35KWh per m2-thereby suggesting that the draft policy target is in fact considerably more onerous than passivhaus.

1.14.1.2 The EUI within the draft policy CC/NZ appears to have been taken from the recommendations from the London Energy Transformation Initiative (LETI) climate emergency guide5 which was created to introduce higher standards in Greater London where new development is dominated by low/ high rise apartments that are inherently more energy efficient than typical single and family housing types.

1.14.1.3 The passivhaus standard6 requires a space heating demand of 15 kWh m2 per annum compared to a draft policy target of 15 – 20

4 https://www.passivhaustrust.org.uk/what_is_passivhaus.php#2
5 https://www.leti.london/_files/ugd/252d09_3b0f2acf2bb24c019f5ed9173fc5d9f4.pdf
6 https://www.passivhaustrust.org.uk/what_is_passivhaus.php#2

kWh m2 thereby suggesting close alignment between the two on this specific issue.

1.14.1.4 Draft Policy CC/NZ requires applicants to address both regulated and unregulated energy as opposed to the FHS which deals with regulated energy alone. The Government have made this important differentiation because the use of unregulated energy (e.g. power used by televisions and appliances) is the responsibility of the homeowner and not the housebuilder and is extremely difficult to quantify accurately at construction stage.

1.14.1.5 To hit the EUI target of 35KWh per m2 the Evidence base document estimates that the following will be required although no exact details are available:

(a) Low U-values that exceed the requirements of the proposed FHS

(b) Mechanical Ventilation with Heat Recovery (MVHR) to recover waste heat from the dwellings

(c) A high level of air-tightness to prevent cold air ingress and heat loss from the dwelling

All of the measures identified above are characteristic of implementing the passivhaus standard.

1.14.1.6 The cost of implementing Policy CC/ NZ has been estimated at between 10% and 13% above that required to build to current Building Regulations. No detailed analysis of the assumptions behind this calculation were available however. It is claimed that this cost is achievable on the basis that significant costs are required to implement the FHS and therefore the costs identified by the Evidence base are an over-estimate and are therefore acceptable. Taylor Wimpey believe it is extremely important to obtain the detailed evidence behind these costs as in our experience the cost of building to passivhaus standards (or extremely close) is likely to be significantly higher than those quoted in the Evidence base paper.

1.14.2 Given the above it would appear that the Policy CC/ NZ is implementing on- site energy efficiency standards much more closely aligned to passivhaus which presents significant challenges to the housebuilding industry for the following reasons:

1.14.2.1 Building to passivhaus requires a complete transformation of the on-site construction process and supply chain which would significantly delay housing delivery and increase costs of new dwellings particularly for the small and medium sized house builders.

1.14.2.2 The cost of constructing houses to passivhaus is likely to be significantly higher than that identified in the evidence base although a direct comparison is difficult in the absence of the detail behind the assumptions in the Evidence Base. Achieving air- tightness levels close to passivhaus and installing MVHR are extremely costly forms of construction and is likely to contribute to a significant cost increase above current Building Regulations that has not been identified by the Evidence base.

15. The GCLP states that it has considered alternatives to the draft policy and targets with one being the use of the Government’s FHS as the principal metric for sustainable housing. Taylor Wimpey fully support the introduction of the FHS in 2025 as it will deliver many of the strategic requirements of draft Policy CC/ NZ which include:

1.15.1 An all-electric energy strategy thereby allowing the carbon footprint of the dwelling to fall each year in line with grid decarbonisation

1.15.2 Dwellings will have very high levels of insulation and likely require triple glazing to ensure maximum heat retention.

1.15.2.1 Each home built to the FHS will require the extensive use of renewable energy technologies in which are likely to include Air Source Heat Pumps and Photovoltaic cells.

1.15.2.2 There would a consistent, deliverable standard for all new dwellings in Greater Cambridge thereby providing a level playing field for all housing developers.

16. Whilst the detailed energy demand / performance metrics for the FHS is unknown at this time the Government have confirmed that dwellings built to this standard will reduce carbon emissions by 75% compared to those built under the current 2013 Building Regulation.

17. Taylor Wimpey therefore believe that Policy CC/ NZ of the GCLP should utilise the FHS as the main metric for the construction of energy efficient housing. The use of this standard will also provide greater support to the small and medium (including self- build) housing sector which we believe is critical to ensure greater supply and diversity of affordable housing to the consumer.

18. In addition to the concern’s with respect to the on-site standards presented in draft Policy CC/ NZ, Taylor Wimpey also have reservations with respect to other aspects of the Policy which are:

1.18.1 It is unreasonable to prohibit all new developments to connect to the gas grid as it is possible that for buildings such as care homes and health facilities gas may still be the most suitable fuel for heating given the bespoke heating requirement of these health facilities. Given that some of Taylor Wimpey’s sites are large enough to permit the delivery of critical social infrastructure such as schools and health facilities, there may be a technical requirement for gas in some form to our large sites.

1.18.2 The requirement for new dwellings to generate at least the same amount of renewable energy as they demand over the course of the year is extremely challenging given that it must include both regulated and unregulated energy for which it is difficult to estimate the exact quantum of energy needed given it is entirely dependent on the occupiers use of appliances.

1.18.3 The offsetting policy (although lacking in detail) would appear to be based on the cost of providing additional PV cells to generate the quantum of energy that remains from the development site after all on-site measures have been deployed. At this time however there appears to be no data with respect to the cost of this offsetting policy and how any money will be spent with absolute certainty to ensure ‘additionality’. Without any costs or viability information this aspect of the policy fails the test of soundness. It is evident however that this policy will add a significant (albeit unknown at this time) cost to new housing which ultimately will feed into higher house prices and greater affordability challenges. We look forward to seeing the detail of this policy but would urge the authorities to fully explore the viability of this carbon offsetting and its impact upon the delivery of affordable housing before it is adopted.

1.18.4 The requirement to calculate Whole Life Carbon (WLF) in construction would increase the importance of reducing embodied carbon within the supply chain, particularly for small and medium sized developers. For Taylor Wimpey however, we are already committed to reducing our embodied (scope 3 emissions) within the supply chain have set ambitions targets to reduce these over time. The requirement to submit a WLC assessment for each TW application places an unnecessary burden upon our new development activities as this work is already part of our corporate commitments. To ensure this policy does not negatively affect housing delivery we would request that the acceptable evidence to demonstrate policy compliance could be details of our corporate commitment and progress to date.

Summary of Representations to Policy CC/ NZ:

19. In summary, Taylor Wimpey support the strategic objective of the GCLP to positively address climate change through progressive policies in the plan. We are concerned however that the policies as they stand are unsound as they propose to introduce some of the highest sustainability requirements in the country without a complete evidence base. In order to make this policy sound and facilitate the delivery of much needed high-quality affordance and private housing we recommend the following amendments to Policy CC/ NZ:

1.19.1 Publication of a complete and full evidence base for stakeholder comments before these draft policies are developed further.

1.19.2 Adoption of the FHS as the energy efficiency target for new housing and remove the requirement for additional renewable energy deployment.

1.19.3 Allow flexibility with respect to the use of gas in new developments where gas use is necessary for health/ occupant wellbeing

Policy CC/ WE: Water Efficiency in new developments.

20. This policy introduces requirements for water efficiency in new domestic and non- domestic development in the form of the following:

1.20.1 80 litres per person per day for domestic development; and

1.20.2 Full BREEAM credits for Wat 01 for non-domestic development

21. Taylor Wimpey acknowledge that the Greater Cambridge area is under water stress and there is a strong encouragement for all new development to improve water efficiency however with respect to draft Policy CC/ WE we have the following comments:

1.21.1 We agree with the statement on Page 26 of the Topic Paper that the highest water efficiency standard that can be requested by local authorities is 110 l per person per day (pppd).

1.21.2 We also agree that achieving 80lppd will require either rainwater harvesting and/ or greywater recycling. Both systems introduce significant maintenance requirements (and therefore cost) for homeowners and introduce technology that has not been tested ‘en-masse’. Taylor Wimpey’s experience of trialling grey water recycling is that it is unreliable and likely to cause maintenance issues for homeowners

1.21.3 Given the unreliability of greywater recycling TW believe the only practical mechanism to achieve the 80lpppd would be through the use of rainwater harvesting systems which have the following constraints;

1.21.3.1 Such systems are more difficult for flats given that communal harvesting tanks (which are more expensive) would be necessary; and

1.21.3.2 Greater Cambridge is already one of the driest areas in the UK7 and climate change is predicated to reduce rainfall in Greater Cambridge by 47% it is highly likely that rainwater harvesting will not capture sufficient rain to meet the policy target and will therefore be ineffective.

1.21.4 Given the above, TW believe that the GCLP should implement the Government’s technical standard for water efficiency for Policy CC/ WE which is 110 lpppd. This would be viable, deliverable and achievable for all new dwellings within GC. Should technology such as grey water recycling become viable during the lifetime of the plan then this could be considered as a means to improve water efficiency beyond the target of 110 lpppd.

Policy CC/ DC Designing for a Changing Climate.


7 https://consultations.greatercambridgeplanning.org/sites/gcp/files/2021-
08/GCLP%20Climate%20Change%20Topic%20Paper.pdf. Page 20, Section 5.1

22. This draft Policy introduces requirements to design buildings in accordance with the Good Homes Alliance Overheating in New Homes Tool and Guidance8. Taylor Wimpey recognise the fact that all buildings will need to be designed to adapt to a warming climate and that, depending on the building type and location, this may necessitate the use of a range of measures as recommended in the Good Homes Alliance toolkit such as shading, thermal mass and different modes of ventilation. The policy requires new development to complete the Good Homes Alliance toolkit and implement the cooling hierarchy to minimise the impact of overheating.

23. Taylor Wimpey believe that this policy may be ineffective as it requires each developer to implement the guidance in a manner that is appropriate for their site and which therefore may differ from one development to the next.

24. In January 2021, the Government confirmed the introduction of the FHS and also consulted on the introduction of a range of new building regulation requirements one of which was the introduction of an overheating testing requirement9 for residential development. This will require all new homes to undergo modelling during detailed design to identify any impact from overheating and then implement mitigation measures accordingly.

25. As this requirement is proposed to be introduced with the revised changes to the Building Regulation in 2022, Taylor Wimpey believes that the policy would be unsound on the basis that it is introducing an unnecessary additional burden on development given that it duplicates the requirement of the building regulations.

26. Taylor Wimpey believe that to reduce the planning and administrative burden upon the housebuilding sector in Greater Cambridge, Policy CC/ DC should be deleted on the grounds that its objectives will be required via Building Regulations.

Policy CC/ CE: Reducing Waste and Supporting the Circular Economy

27. This policy places requirements upon new development to manage their waste and embrace the principles of the circular economy. The policy requires the following from new development proposals:

1.27.1 The submission of a Construction Environmental Management Plan (CEMP) proportionate to the size and scale of development

1.27.2 Provision of adequate waste and material storage facilities on site in accordance with the RECAP Waste Management Design Guide (or successor)

1.27.3 Submission of a Circular Economy Statement with each application

28. Taylor Wimpey fully support the strategic objective of the policy in terms of its objectives to reduce waste and, perhaps more importantly, encourage circular economy principles in development. As explained earlier in these representations,

8 https://goodhomes.org.uk/wp-content/uploads/2019/07/GHA-Overheating-in-New-Homes-Tool-and- Guidance.pdf
9https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_d
ata/file/953752/Draft_guidance_on_heating.pdf

reducing waste intensity is one of our key objectives and one in which progress is clearly being made on our sites.

29. We fully support the requirement to submit a CEMP for our sites as this is something that we already commit to as part of our best practice approach to waste management and environmental protection.

30. With respect to the provision of waste management facilities on site, Taylor Wimpey agree that the correct storage and handling of waste and raw materials is a critical step to responsible management of materials and the prevention of pollution. All of our construction sites deploy best practice measures for the prevention of pollution and provide facilities for the separation and recycling of waste. We therefore support this objective of draft Policy CC/ CE but would ask that the policy recognises that large housebuilders such as Taylor Wimpey with large and efficient supply chains may use bespoke techniques and practices on site which are not referenced in any guidance but which fully comply with all legislation and best practice.

31. With respect to the submission of a circular economy statement, Taylor Wimpey are happy to provide such information with an application although we would request that this is proportionate to the size and scale of the development in question.

Policy CC/ CS Supporting land-based carbon sequestration.

32. This policy will protect important land based carbon sinks such as peatland and woodland projects whilst encouraging new development to promote biodiversity and carbon sequestration.

33. Protecting nature and biodiversity is one of Taylor Wimpey’s key objectives within its Environment Strategy. We recognise the importance of peatlands and woodland to carbon sequestration and agree that these should be protected where possible. It is important to note however that with respect to new development, there can often be many carbon sequestration benefits associated with the creation of multi-functional green infrastructure and on-site planting which should be recognised when considering the overall ‘carbon performance’ of new development.

34. Taylor Wimpey therefore believe that the draft policy should contain text to support new development if it can be demonstrated that the green infrastructure and woodland it provides will sequester carbon. We believe this should be recognised as one of the many environmental benefits that new development can provide.

4. Summary of Representations

35. Taylor Wimpey are pleased to provide our representations to the GCLP in order to ensure the policies are sound and deliverable and facilitate the delivery of much needed private and affordable homes within Greater Cambridge.

36. Taylor Wimpey have a strong corporate commitment to positively address the causes of climate change and reduce our environmental impact and we believe we are making positive progress towards our targets.

37. We fully support many of the strategic objectives of the policy but do feel that some of the detailed targets and requirements within each policy (and specifically Policy CC/ NZ) will bring significant additional financial and technical burden to the house building industry and particularly those in the small, medium and self-build sectors. These policies are likely to have a significant impact upon the land value as these additional costs must result in lower land prices to accommodate the additional construction costs.

38. If the recommendations contained within these representations are implemented then we believe this will create a policy framework capable of meeting the significant demand for housing within the region.

39. We would be pleased to discuss our representations in greater detail with the joint authorities.

Thank you for consulting Natural England on the above in your letter dated 1 November 2021.

Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.

Natural England’s key comments
We are pleased that many of our comments at the Issues and Options stage, in our letter dated 24 February 2020 (ref. 304246), are reflected in the First Proposals Plan, helping to strengthen the Plan’s approach to the ‘big themes’ including climate change, biodiversity and green spaces, wellbeing and social inclusion. Natural England supports the general thrust of the Plan in directing development to where it will have least environmental impact and provide opportunities for enhancements.

Natural England’s previous advice highlighted the need for the Plan to address uncertainties relating to water resources and infrastructure needed to support new growth, in light of evidence that current levels of abstraction are already damaging the natural environment. We also signalled the need for the establishment of a strategic green infrastructure network that is resilient to the scale of proposed Plan development, capable of meeting people’s needs and addressing adverse impacts to the natural environment. We therefore welcome that the First Proposals Plan recognises the challenges in identifying long-term and interim solutions to the current water resource crisis to enable sustainable development without further detriment to the natural environment. We support the Plan’s progress, through the Green Infrastructure Recommendations (LUC, September 2021), in presenting opportunities for the Plan to deliver /contribute towards delivery of strategic green infrastructure.

Notwithstanding the above, Natural England believes significant additional work is required through the next stages of Plan preparation to progress these ‘solutions’ and demonstrate that development can be delivered sustainably. We have major concerns with the scale of proposed Plan development, and the 2041 timeframe for delivery, given the damage already being inflicted on the natural environment and the lengthy lead-in time for identification and delivery of measures to address the water resource issue and to implement strategic green infrastructure. Some of this Plan development is already progressing, through the adopted strategy, prior to solutions being identified and implemented; the natural environment is already being impacted. The Plan should consider how these impacts and spiralling environmental deterioration can be retrospectively

mitigated.

The section on ‘Ensuring a Deliverable Plan – Water Supply’ recognises the challenge relating to water resources; however, the Councils need to act urgently, in collaboration with relevant stakeholders, to identify strategic and interim water resource/infrastructure solutions to ensure any level of proposed development is delivered sustainably. There are currently no measures in place to mitigate the adverse effects of current development on the natural environment i.e., more water is being abstracted from the aquifer to serve this development, depleting groundwater resources and causing further declines in the condition of designated sites and supporting habitat.

Potential solutions to address Greater Cambridge’s green infrastructure deficit, and the recreational pressure effects of development, lie within the Green Infrastructure Initiatives identified in LUC’s Opportunity Mapping Recommendations Report. Natural England fully supports the Initiatives identified; however, these aspirational areas must be progressed into real projects that are happening on the ground by the time the Plan is adopted. Robust Plan policy requirements should secure funding for the delivery and long-term management of these projects from all major development.

We have provided additional comments on the Plan’s key themes and policies below; however, reference should be made to the detailed advice provided in our response to the Issues and Options consultation.

Vision and aims
We support the Plan vision and aims for decreases in our climate impacts and increase in quality of life for communities, minimising carbon emissions and reliance on the private car, increases in nature, wildlife, greenspaces and safeguarding landscapes focusing on what is unique to Greater Cambridge embracing bold new approaches.

Natural England strongly recommends that the vision should advocate a more holistic approach to securing multi-functional benefits through the protection and enhancement of the natural environment. In accordance with paragraphs 17 and 109 of the National Planning Policy Framework (NPPF) the Plan should encourage multiple benefits from the use of land in urban and rural areas, recognising that land can deliver a wide range of ecosystem services required for sustainable development including climate change mitigation, flood management, improved water resources and water quality, biodiversity net gain, accessible high quality green infrastructure and associated health and wellbeing benefits, enhanced landscapes and soil resources.

The Plan should contribute to and enhance the natural and local environment by recognising the wider benefits of ecosystem services, considering a natural capital evidence approach and making strong links to the Nature Recovery Network and the Cambridge Nature Network. National Habitats Network mapping is available to view at www.magic.defra.gov.uk.

Development Strategy
The Plan will deliver around 44,400 new homes and provide for approximately 58,500 new jobs. We welcome that the new development strategy aims to meet our increased need for new homes in a way that minimises environmental impacts and improves the wellbeing of our communities.
The strategy proposes 19 additional sites for development, along with sites already allocated in the adopted 2018 Local Plans, along with associated infrastructure including green spaces.

We support proposals to direct development to where it has the least climate impact, where active and public transport is the natural choice, where green infrastructure can be delivered alongside new development, and where jobs, services and facilities can be located near to where people live. The vision includes creating new city neighbourhoods which have the critical mass of homes, jobs and services to create thriving communities, making best use of brownfield and safeguarded land and making the most of public transport links.

Natural England welcomes the use of evidence including the Employment Land and Economic Development Evidence Study and the Greater Cambridge Housing and Employment Relationships

Report to understand the relationship between future jobs and housing growth. We note that these studies found that planning for the standard method housing figure set by government would not support the number of jobs expected to arise between 2020 and 2041. Planning for this housing figure would risk increasing the amount of longer distance commuting into Greater Cambridge, with the resulting impacts on climate change and congestion. On this basis planning for a higher jobs figure and planning for government’s standard method local housing need figure have been rejected as reasonable alternatives.

We note that high-level consideration has been given to the potential impacts of COVID-19 on the economy of Greater Cambridge, to inform this First Proposals consultation. We support the proposal to gather evidence to consider the potential longer-term quantitative impacts of COVID- 19 prior to the Draft Plan stage to understand any implications for the objectively assessed need for jobs and homes for the plan.

Natural England has no objection in principle to the proposed Plan development strategy; however, this is subject to: 1) the identification of strategic water supply solutions and / or interim measures; and 2) development of deliverable strategic GI initiatives and developer requirements and funding mechanisms being secured through the Plan.

Policy S/DS: Development strategy
Figure 6: Map shows proposed sites to be included in the Plan including existing planning permissions alongside a limited number of new sites in the most sustainable locations. We welcome that the sustainability merits, opportunities and constraints for each of the nine potential strategy choices have been considered through the Sustainability Appraisal. Alongside considering the best locations for new homes and jobs, consideration has also been given to the best locations to restore the area’s habitat networks and provide more green spaces for people providing health and wellbeing benefits. Natural England fully supports the identification of 14 Strategic Green Infrastructure Initiatives, through the Green Infrastructure evidence, to help achieve this. We welcome the approach to preparing the preferred development strategy / draft allocations and green infrastructure initiatives in parallel.

We support the general policy direction to focus development where it will have the least climate impact, where it can be aligned with active and public transport, opportunities for delivery of green infrastructure and where jobs, services and facilities can be located nearby whilst ensuring all necessary utilities can be provided in a sustainable way. We support the approach to using less land for development to reduce carbon emissions and allow more space for nature and wildlife.
The strategy focuses on opportunities to use brownfield land and opportunities created by proposed major new infrastructure.

We note that delivery of the adopted strategy is progressing well with development permitted/underway /completed at the edge of Cambridge sites and new settlement sites including Northstowe and Waterbeach New Town. Natural England is aware that these schemes are being delivered in the absence of adequate sustainable water supply infrastructure to serve the development without adverse impact to the natural environment including statutorily designated sites. Many of these schemes are also unlikely to deliver sufficient level of accessible high quality green infrastructure to meet the needs of new residents without adverse recreational pressure impacts to the existing ecological network including statutorily designated sites. These issues need to be addressed urgently through further stages of Plan preparation as discussed in our advice above and below.

Ensuring a deliverable plan – water supply
We welcome the Councils’ recognition that water supply is a significant issue for the deliverability of the Local Plan and we fully support preparation of the Integrated Water Management Study: Outline Water Cycle (WCS) by Stantec (August 2021) to address this. The WCS has identified the need for new strategic water supply infrastructure, such as a new fens reservoir, to provide for longer term needs, and to protect the integrity of the chalk aquifer south of Cambridge, in addition to a range of interim demand management measures. The draft Sustainability Appraisal also identifies significant environmental impacts if the issue is not resolved. This is a major concern for

Natural England in light of proposed growth levels and the damaging effects that groundwater abstraction is already having on the natural environment including water-dependent designated sites and important chalk stream habitats. Natural England has provided its detailed advice on this matter, and highlighted the statutorily designated sites potentially affected, in our response to the consultation on the WCS. These ‘Designated Sites of Concern’ are listed in Appendix B of the August 2021 report.

We are aware that Water Resources East is currently preparing its Water Management Plan for the region and that this will help to identify long-term measures to address the issue. However, these strategic measures, including a new fens reservoir, are unlikely to be available until the 2030’s hence interim measures are required to enable some level of sustainable growth. We welcome the suggestion of including Plan policies to phase delivery of development that can be supported by a sustainable water supply until new strategic infrastructure is in place; however, it will need to be clearly demonstrated that interim solutions are sustainable and will not cause further environmental decline. The risk is that it may not be possible to demonstrate delivery of the full objectively assessed needs within the plan period.

Natural England appreciates that pressure on water supplies is a regional issue. We share the Councils’ aspirations that the water industry, supported by government, will set out its intentions for positively addressing this key infrastructure issue at an early point in the ongoing plan making process, to provide confidence that adequate water supply will be available to support delivery of the preferred options allocations, before the next stage of a full draft Local Plan. In our view the Councils need to act urgently, in collaboration with relevant stakeholders, to identify strategic and interim water resource/infrastructure solutions, including demand management measures, to ensure any level of proposed development is delivered sustainably.

We have serious concerns that Plan development is already being progressed, through the adopted strategy, without sustainable water supply measures in place. More water will be abstracted from the aquifer to serve this development, depleting groundwater resources and causing further declines in the condition of designated sites and supporting habitat. The Plan will need to consider the impacts of this development and identify measures to address adverse environmental impact.

Natural England fully supports the concerns raised by the Environment Agency, as lead authority on this matter, including the high degree of uncertainty as to whether sufficient sustainable water supplies can be provided for the proposed growth over the plan period without further detriment to the natural environment. Further development of the WCS, informed by evidence from regional and water company water resource plans, will need to demonstrate that appropriate deliverable mitigation measures can support sustainable growth until new strategic water supply infrastructure becomes operational. We agree with the Environment Agency that it in the face of current challenges it may be appropriate to consider an extended timeframe for delivery of Plan development to limit further environmental degradation until new strategic measures become available. This would allow further time for the identification of truly sustainable options that build in resilience to climate change and robust mitigation and monitoring measures to address impacts to the natural environment and restore habitat condition.

Duty to Cooperate
Natural England welcomes consideration of how the Plan fits with other plans and strategies including cross boundary projects such as the Ox Cam Arc. We support recognition of the Plan to be prepared within a wider regional context noting the Councils’ legal duty to cooperate with key stakeholders and surrounding areas of cross boundary issues. We agree that the development of a clear and positive vision for the future of the Greater Cambridge area can help to shape the proposals for the Ox Cam Arc, noting that the outcome of the Oxford-Cambridge framework is currently awaited.

We particularly support the Councils’ recognition that the water supply challenge discussed above is a serious issue to be resolved.

Natural England will be pleased to engage with the Councils in the preparation and development of a draft Statement of Common Ground.

Transport Strategy
Natural England welcomes that the proposed strategy is heavily informed by the location of existing and committed public transport schemes. We support the use of transport modelling to understand whether additional infrastructure and policies are required to address the transport impacts of the preferred development strategy.

Transport policies should include requirements for projects to undertake robust ecological impact assessment and application of the ecological mitigation hierarchy.

Site allocation policies
Proposed site allocation policies are described through sections 2.2 – 2.5. Natural England has no objection in principle to the existing and new allocations, areas of major change or opportunity areas being taken forward for development. However, this is subject to:
• identification of strategic water supply infrastructure and/or feasible interim solutions to demonstrate that development can be delivered sustainably and without adverse impact to the natural environment;
• establishment of a framework and robust plan policies to deliver the 14 Strategic Green Infrastructure initiatives ahead of development, to meet development needs and to address the effects of recreational pressure on sensitive sites and habitats.

The site allocation policies will need to include robust requirements to secure delivery of biodiversity net gain and on-site accessible green infrastructure to meet people’s need and to contribute towards the Plan’s 20% BNG targets and delivery of the Nature Recovery Network / Cambridge Nature Network. Our advice is that major allocation policies should set a framework for development to maximum opportunities for environmental gains.

Climate Change
We welcome the proposed policies relating to net zero carbon and water efficiency, designing for climate change, flooding and integrated water management, renewable energy projects, reducing waste and supporting land-based carbon sequestration. We particularly support the proposed requirement for residential developments to be designed to achieve a standard of 80 litres/person/ day; however, we support the Environment Agency’s concerns as to whether the Plan is likely to achieve the reductions in demand required to support sustainable growth. As indicated above the WCS will need to demonstrate how water, to meet growth needs, will be supplied sustainably without adverse impact to the natural environment.

Proposed requirements for developments to provide integrated water management, including sustainable drainage systems (SuDS) where possible and for SuDS and green /brown roofs to provide multiple benefits (including biodiversity and amenity) are welcomed.

We support requirements for renewable energy projects to consider impacts on biodiversity, geodiversity, landscape and water quality.

Natural England welcomes a proposed policy to support the creation of land and habitats that play a role as carbon sinks and protect existing carbon sinks from development, particularly peatlands such as those remaining in the north of South Cambridgeshire district. We welcome recognition of the importance of peatlands as a carbon store and the role of other habitats such as woodlands and grasslands, noting loss and degradation of natural habitats results in the direct loss of carbon stored within them.

As indicated above we recommend that the Plan takes a more holistic approach to securing multi- functional benefits for climate change, flood management, water resources and water quality through the protection and enhancement of the natural environment. Natural solutions can achieve significant additional benefits for biodiversity, green infrastructure and associated health and wellbeing benefits, enhanced landscapes and soil resources.

Biodiversity and green spaces
We strongly support the proposed biodiversity and green spaces policies and the inclusion of Figure 53 depicting the existing Greater Cambridge green infrastructure network including designated sites.

We welcome that these policies will help to deliver the aims of the Ox Cam Arc of doubling the area of land managed primarily for nature and to deliver a minimum 20% biodiversity net gain on development sites, beyond the mandatory 10% biodiversity net gain requirements of the Environment Act 2021. We agree that Greater Cambridge has a relatively low level of designated sites and priority habitats, highlighting the need for development to deliver net gains beyond the 10% proposed nationally, hence we are fully supportive of minimum 20% BNG ambitions. Our advice is that the Councils, working with key partners, should identify BNG opportunities through the next phases of Plan preparation. This should take the form of a BNG opportunities / requirements map building on the foundations of the Nature Recovery Network and the Cambridge Nature Network. National Habitats Network mapping is available to view at www.magic.defra.gov.uk.

The Councils should also set a landscape / GI framework for the Site Allocations to maximise opportunities for delivery of GI and BNG within the development sites.

BG/BG: Biodiversity and geodiversity
Natural England fully supports this policy and requirements for development to achieve a minimum 20% biodiversity net gain, delivered on site where possible and calculated using the Defra Metric
3.0 or its successor. Requirements for off-site measures to be consistent with the strategic aims of the Greater Cambridge green infrastructure network strategic initiatives are welcomed.

The policy should take a natural capital evidence approach and recognise the wider benefits of ecosystem services for climate change, flood risk management, green infrastructure and health and wellbeing, in addition to biodiversity. They main thrust of this policy should be the Plan’s contribution to the Nature Recovery Network / Cambridge Nature Network and the establishment of a framework for the development of a Local Nature Recovery Strategy.

We support proposed requirements for development to avoid adverse impact to site of biodiversity or geological importance and development to mitigate recreational pressure on statutorily designated sites, applying Natural England’s SSSI Impacts Risk Zones (IRZs). The Plan’s biodiversity policy should recognise the hierarchy of international, nationally and locally designated sites across Greater Cambridge. This should be accompanied by a map of the existing ecological network and enhancement opportunity areas to guide site allocations / development away from more sensitive areas and to identify opportunities for developers to deliver net biodiversity gain enhancements.

We welcome that the policy will seek wider environmental net gains. These should focus on measures to restore ecological networks, enhance ecological resilience and provide an overall increase in natural habitat and ecological features.

Reference should be made to the detailed advice provided in our response to the Issues and Options consultation with regard to protecting and enhancing biodiversity including designated sites, priority habitats, ecological networks and priority and/or legally protected species populations. This includes additional detailed advice on embedding biodiversity net gain into the Greater Cambridge Local Plan policies.

BG/GI: Green infrastructure
We welcome the comprehensive and thorough approach taken in developing the GI evidence base for the Greater Cambridge Local Plan, including the Opportunity Mapping and the identification of 14 Strategic GI initiatives. The multifunctional benefits of GI are fully recognised, as well as the links between GI provision and the delivery of other strategic policy areas including the wider natural environment, sustainable transport and social inclusion. These threads/links

should continue through future drafts to ensure the value of GI for people and the natural environment is fully reflected in the Local Plan.

The Strategic GI initiatives are comprehensive and capture a wide variety of GI opportunities within the 14 proposals; this range of GI elements and habitats will help to maximise benefits for people and nature through the strategic planning and delivery of GI across Greater Cambridge. We support the emphasis given to blue infrastructure in Strategic Initiatives 1 and 2 given the considerable pressures on Cambridgeshire’s chalk streams and aquifer from agriculture and development. The Chalk Stream Strategy Report1 recently published by CaBA identifies a number of recommendations to protect/restore chalk stream habitats, including those in areas of high population density such as Cambridge. This report may be a useful reference in planning and progressing strategic blue infrastructure initiatives as part of the Greater Cambridge Local Plan.

We support the proposed approach to have a distinct GI policy within the Local Plan, rather than a stand-alone SPD. As noted in the Topic Paper, we agree that the policy should require all developments to contribute towards GI and that it should be incorporated into design from an early stage and through all phases of development, with a longer-term plan in place for its management and maintenance. As well as a GI policy, Green Infrastructure should be integrated into other strategic policy areas and Local Plan themes where relevant. This will give weight to the multifunctional role of GI and demonstrate where it can contribute to policy delivery and outcomes (e.g., in climate change adaptation, supporting healthy communities etc). It will also support the role of GI in implementing other mechanisms and tools, such as Biodiversity Net Gain, and may help in targeting and prioritising opportunities for GI creation and enhancement.

In addition to securing GI within individual developments, the Local Plan should also provide a framework for proposals to contribute to / link up with the wider Strategic Initiatives, including the ‘dispersed initiatives’ 10-14 (e.g., ‘Expanding the Urban Forest’). Consideration should also be given to potential join-ups on cross-boundary projects and, in time, how the strategic GI network in Greater Cambridge may contribute to greenspace at the regional level (as one of the 5 Ox-Cam counties). There may also be overlaps with other initiatives, such as the Nature Recovery Network, where Cambridgeshire’s GI resource can make an important contribution (such as that highlighted in Strategic Initiative 3 for the Gog Magog Hills and Chalkland fringe).

We note from the Part 2 Recommendations Report that there are several points for further consideration, including the funding mechanisms required to ensure that all developments include GI and contribute towards the strategic initiatives. Funding mechanisms (e.g., developer contributions) should be embedded in policy where required and should be identified as early as possible to ensure that benefits are secured long-term. For example, the policies for major allocations will need to include specific requirements for the funding / delivery of the strategic GI ahead of the developments being occupied so that these are clear from the outset. The report presents a number of potential funding sources, including land use planning obligations (e.g., S106) agri-environment streams (such as ELMS) and any ad-hoc opportunities that may arise through partnership working. The increasing emphasis on nature-based solutions may also bring in new revenue streams to support strategic projects, given that many NBS will require a landscape scale / ‘ecosystem’ approach. The costings for the delivery of the GI and biodiversity aspects of the Local Plan could be included in the IDP so that the investment required to bring about delivery is clear and transparent from an early stage and factored into development proposals. Given the significant scale of the work required, consideration should also be given to how the land will be secured to deliver the GI initiatives, whether through direct purchase, lease or management agreements. A long-term approach to the management and maintenance of GI (ideally in perpetuity) also needs to be factored in from an early stage.

Alongside its value for natural capital and placemaking, green infrastructure provides alternative natural greenspaces that can help alleviate and buffer recreational pressures on protected sites. We welcome the recognition of the recreational pressure impacts across Greater Cambridge, and

1 1 Catchment Based Approach (October 2021) Chalk Stream Restoration Strategy: Main Report. See: New strategy launched to protect chalk streams - GOV.UK (www.gov.uk)

the Strategic Initiatives aimed at addressing these (e.g., the Coton corridor and multifunctional GI corridors, Strategic Initiatives 7-8). We support the development of clear policy requirements to address these significant pressures (as suggested in the Topic Paper).

Given the Local Plan’s strong emphasis on GI and the widespread benefits that it can achieve, we feel there is clear value in having a recognised GI standard in place. A standard would help to guide and inform GI planning and delivery and provide a consistent benchmark on quality across different scales/locations of development. It would also support the recommendation in the report for a GI-led design approach to new development. A standard could be supported by other documents, e.g., Local Design Guides, to ensure that nature is fully built into design through the provision of high-quality green infrastructure. Natural England is currently developing a Green Infrastructure Framework to set standards for green space and access to natural greenspaces, as well as a Design Guide and mapping data2 to support this work. We would encourage the use of these resources to guide and inform development of strategic Green Infrastructure and policies for Greater Cambridge. The Framework of GI Standards and products are due for launch in summer/autumn 2022, with a pre-release of the beta mapping and the principles of good green infrastructure in December 20213.

Natural England fully supports the proposed inclusion of policies to improve tree canopy cover, enhance river corridors and protect and enhance open spaces. We advise that robust policy requirements should be included to secure delivery of enhancements through development to ensure the achievement of multi-functional benefits for climate change, biodiversity, water quality, access. As indicated in our comments at the Issues and Options stage tree planting needs to be targeted in appropriate locations and considered in the context of wider plans for nature recovery. Consideration should be given to ecological impacts and the opportunities to create alternative habitats that could deliver better enhancements for people and wildlife, and store carbon effectively. Where woodland habitat creation is appropriate, consideration should be given to natural regeneration, and ‘rewilding’ for the economic and ecological benefits this can achieve.
Any tree planting should use native and local provenance tree species suitable for the location. Natural England advocates an approach which seeks to increase biodiversity and green infrastructure generally, not simply planting of trees, and protecting / enhancing soils, particularly peat soils.

For further advice and guidance on green infrastructure please refer to our comments at the Issues and Options consultation stage.

Wellbeing and inclusion
Natural England is fully supportive of the proposed policies including WS/HD: Creating healthy new developments. Our advice is that the policy should include strong links to the importance of adequate level and quality of accessible green infrastructure for people’s physical and mental health and wellbeing.

Great places
Natural England supports the proposed Great Places policies. We welcome the establishment of a Place and Design Quality Panel to conduct a site typologies study to understand, protect, utilise and enhance the valued characteristics of different areas in the plan, with the intention of using this information to raise design standards to ensure development reflects and enhances Cambridge’s distinctive landscape and townscape character.

We support Policy GP/LC Protection and enhancement of landscape character. Natural England is pleased to see that the Greater Cambridge landscape character assessments have been updated and will provide an up-to-date evidence base for the development of policy GP/LC. Existing retained policies form the South Cambridgeshire Local Plan NH/1, NH/2 and NH/13 and policy 8 of the Cambridge Local Plan should be reviewed and updated in the light of these updated landscape

2 See the GI Framework Mapping Portal: https://designatedsites.naturalengland.org.uk/GreenInfrastructure/Home.aspx 3 How Natural England’s Green Infrastructure Framework can help create better places to live - Natural England (blog.gov.uk)

character assessments to ensure they reflect the most recent baseline evidence.

Policy GP/LC seeks to identify, protect and enhance locally valued landscapes. Any locally designated landscapes, e.g., Areas of Greater Landscape Value, should be identified within the plan and given appropriate policy protection to protect and enhance them and to ensure that development reflects their distinctive character. It is not the role of Natural England to define locally valued landscapes – this is for LPAs and their communities. However, it should be noted that NE considers World Heritage Sites designated for their natural interest, local landscape designations and Inheritance Tax Exempt land to be locally valued. Therefore, these areas should be identified and included on policy maps showing locally designated landscapes along with any ‘Protected views’.

The Strategic Spatial Options Assessment appears to have considered a wide range of options based on up-to-date evidence on landscape and townscape character considerations. We support this approach which is useful in identifying and considering key landscape issues early in the Plan- making process, to feed into the Sustainability Appraisal. We note that the appraisal of the strategic spatial options is based on the interim draft findings of the emerging Landscape Character Assessment. We trust that the preliminary conclusions will be updated following completion of this work. The analysis also notes that recommendations are provided for strategic landscape mitigation and enhancement for each of the strategic spatial options. Natural England supports the proposal to identify specific mitigation as part of more detailed studies in locating and designing future development.

We are generally supportive of policies to protect and enhance the Cambridge Green Belt, achieve high quality development and establish high quality landscape and public realm.

Jobs
Natural England supports proposed policy J/AL: Protecting the best agricultural land. We welcome recognition of soil as a valuable resource and key element of the environmental ecosystem which requires protection, in accordance with paragraph 174 of the NPPF. We note that the protection of peat soils is addressed under the climate change theme discussed above.

Beyond the wider water resource / supply issue, discussed above, we have no substantive comments on the other proposed policies. However, policies will need to include appropriate requirements to ensure that all development avoids adverse impact to the natural environment and delivers net gains for biodiversity in accordance with the requirements of policy BG/BG: Biodiversity and geodiversity.

Homes
Beyond the wider water resource / supply issue we have no specific comments to make on these proposed policies subject to the inclusion of appropriate requirements to ensure that all development avoids adverse impact to the natural environment and delivers net gains for biodiversity in accordance with the requirements of policy BG/BG: Biodiversity and geodiversity. Residential development should also contribute towards delivery of the Strategic GI Initiatives.

Infrastructure
Natural England supports proposed policy I/ST: Sustainable transport and connectivity for the environmental and health benefits this could achieve including reduced emissions, air quality and climate change benefits.

We have no substantive comments on the other proposed policies subject to the inclusion of appropriate requirements to ensure that all development avoids adverse impact to the natural environment and delivers net gains for biodiversity in accordance with the requirements of policy BG/BG: Biodiversity and geodiversity.

Habitats Regulations Assessment (HRA)
Natural England supports preparation of the HRA Report by LUC (August 2021). We welcome that this incorporates a screening assessment and Appropriate Assessment. The Screening stage

identifies likely significant effects on European sites, either alone or in combination with other policies and proposals, for several plan policies. These include:
• Physical damage and loss (offsite) – in relation to Eversden and Wimpole Woods SAC.
• Non-physical disturbance (offsite) – in relation to Eversden and Wimpole Woods SAC.
• Recreation – in relation to Wicken Fen Ramsar SAC and Fenland SAC.
• Water Quantity and Quality – in relation to Ouse Washes SAC, SPA and Ramsar site, Wicken Fen Ramsar site, Chippenham Fen Ramsar site, Fenland SAC and Portholme SAC.
The Appropriate Assessment concludes no adverse effect on site integrity as follows: Eversden and Wimpole Woods SAC
Subject to the following safeguards and mitigation measures being implemented:
• Completion of bat surveys for site allocations identified with moderate or high potential to support barbastelle to determine the ecological value of these sites in relation to this bat species and to inform specific mitigation proposals.
• There is a commitment in the plan that proposed development will avoid key habitat features likely to be used by this species and to create and enhance suitable habitat for this species.
• It is also recommended that policy wording in the plan is strengthened to include specific inclusion of the safeguard measures detailed above and that Policy BG/BG Biodiversity and geodiversity is strengthened to include specific reference that mitigation provided should be suitable to the level of protection afforded to designated sites.

Wicken Fen Ramsar site and Fenland SAC
The Appropriate Assessment concludes no adverse effect on integrity as a result of increased recreational pressure provided that the following safeguards and mitigation measures are required by the plan and successfully implemented:
• A commitment in the plan to ensure that development within 20km of the Ramsar site and SAC to provide sufficient suitable alternative natural greenspace in line with advice from Natural England and that there should be specific detail on the policy on the appropriate quantity and quality of open spaces and how delivery and management in perpetuity will be secured.

The Appropriate Assessment is currently unable to conclude no adverse effect on the integrity of the Ouse Washes SAC, SPA and Ramsar, Wicken Fen Ramsar site, Chippenham Fen Ramsar site, Fenland SAC and Portholme SAC, with regard to water quantity and quality, pending the provision of further evidence through the Greater Cambridge IWMS and the WRE IWMP.

We welcome that the HRA has provided a detailed consideration of air quality impacts, associated with Plan development, for the relevant European sites. This is based on best practice Highways England Design Manual for Road and Bridges (DMRB) LA 105 Air quality guidance and considers the potential for traffic-related emissions on the affected road network based on traffic modelling data, in line with the advice provided by Natural England at the Issues and Options stage. Whilst the assessment has ruled out likely significant effects on all relevant European sites Natural England has been unable to carry out a detailed review of this information and will provide comments at the next stage of Plan consultation.

Please note that Natural England is reviewing the Impact Risk Zone (IRZ) for Eversden and Wimpole Woods SAC to take into account the findings of emerging SAC barbastelle tracking surveys being undertaken for major development schemes. It will also take into consideration the availability of suitable foraging resource which is considered to be quite scarce in the local area. In the meantime, until the IRZ is formally amended, and accompanying guidance prepared, we welcome application of a precautionary 20km buffer zone for SAC barbastelles in line with Natural England’s current local guidance.

Natural England is generally supportive of the interim findings of the HRA and will provide further

advice as the HRA is updated in line with the development of Plan policies and further evidence.

Sustainability Appraisal
Through the Sustainability Appraisal (LUC, October 2021) the preferred policy approaches for the Local Plan have been subject to appraisal against the SA objectives. A range of reasonable alternative options has also been assessed, including alternatives to the preferred policy approaches, Strategic Spatial Options and site options. We welcome that the findings of the HRA will be incorporated into the SA and will provide further insight into biodiversity impacts specifically at designated sites, presenting the opportunity to limit adverse impacts at these locations.

We support recognition of the over-abstraction of water in this region as a serious concern. We welcome acknowledgement that action is required now to ensure the availability of water for future uses without detrimental impact on the environment. Natural England agrees that water resource availability and water quality are inter-related and that these are likely to be exacerbated by the effects of climate change.

The new Local Plan presents the opportunity for new development to come forward at the most appropriate locations in order to avoid detrimental impacts on biodiversity assets. However, we support recognition of potential risks to the ecological network including statutorily designated sites, through degradation and other impacts associated with development.

We agree that the new Local Plan provides the opportunity to promote biodiversity gain and to improve the overall ecological network. Natural England also agrees that opportunities identified through the Green Infrastructure Study (2020) could support delivery of Natural England's Habitat Network nearby opportunity zones and support pollinator corridors. Robust plan policies will need to be developed to secure delivery of these enhancements through all relevant development.

The report concludes that overall, the proposed direction of the Local Plan performs well in sustainability terms with a strong focus on providing an appropriate amount of development and policies focused on minimising carbon emissions, particularly through minimising the need to travel, using land efficiently and making the most of existing and planned sustainable transport links. Natural England suggests this is a premature conclusion in the current absence of strategic water supply infrastructure and sustainable interim measures. Development through the adopted strategy is already being progress without these measures in place. Further development of the Green Infrastructure Initiatives is also required to ensure adequate GI to meet development needs and to alleviate recreational pressures on some of our most sensitive sites habitats. Robust plan policies, to secure timely delivery of this strategic green infrastructure, will be required to demonstrate the Plan’s sustainability.

We generally welcome the policy recommendations presented within Chapter 5 of the SA report including reference to the mitigation hierarchy within Policy BG/BG: Biodiversity and geodiversity and stronger commitments to protect and enhance biodiversity within this and the site allocation policies. However, in our view SA recommendations should focus on the urgent requirement for the identification of strategic and interim water resource/infrastructure solutions and further work to progress the GI Initiatives into real projects.

Natural England will provide further advice as the SA is updated in line with the development of Plan policies and further evidence.

We hope our comments are helpful. For any queries relating to the specific advice in this letter only please contact Janet Nuttall on […]. For any new consultations, or to provide further information on this consultation please send your correspondences to consultations@naturalengland.org.uk.

FORM RESPONSE

Vision and development strategy
Section / Policy Your comments
Vision and aims
How much development, and where – general comments Support the approach to contain any development to major clusters.
S/JH: New jobs and homes
S/DS: Development strategy Support to the extent that development should be very restricted in smaller rural villages with limited public transport.
S/SH: Settlement hierarchy Support Steeple Morden is a group village and should remain in this category. It is well down the sustainability hierarchy.
S/SB: Settlement boundaries Support tightly drawn development boundaries are important to reduce encroachment into the countryside and particularly for linear villages protecting their character. Also assists in delivering exception sites.

Cambridge urban area
Policy Your comments
Cambridge urban area - general comments
S/NEC: North East Cambridge
S/AMC: Areas of Major Change
S/OA: Opportunity Areas in Cambridge
S/LAC: Land allocations in Cambridge

Edge of Cambridge
Policy Your comments
Edge of Cambridge - general comments
S/CE: Cambridge East
S/NWC: North West Cambridge
S/CBC: Cambridge Biomedical Campus
S/WC: West Cambridge
S/EOC: Other existing allocations on the edge of Cambridge

New settlements
Policy Your comments
New settlements - general comments
S/CB: Cambourne
S/NS: Existing new settlements

Rural southern cluster
Policy Your comments
Rural southern cluster - general comments
S/GC: Genome Campus, Hinxton
S/BRC: Babraham Research Campus
S/RSC: Village allocations in the rural southern cluster
S/SCP: Policy areas in the rural southern cluster

Rest of the rural area
Policy Your comments
Rest of the rural area - general comments
S/RRA: Allocations in the rest of the rural area
S/RRP: Policy areas in the rest of the rural area

Climate change
Policy Your comments
Climate change - general comments Future development and trends will increase the use of electricity so do we have an obligation to consider where we might generate this locally? There should be clear comments on how and where solar PV farms and windfarms are going to be planned
CC/NZ: Net zero carbon new buildings Should not be specific about not connecting a gas pipe to new housing. This might prevent the future distribution of Hydrogen. Should keep this option open
CC/WE: Water efficiency in new developments Absolutely necessary.
CC/DC: Designing for a changing climate
CC/FM: Flooding and integrated water management Infrastructure should be operational before housing occupation. Especially managing hard surface run off.
CC/RE: Renewable energy projects and infrastructure Support for community led projects but should include access to funding.
CC/CE: Reducing waste and supporting the circular economy
CC/CS: Supporting land based carbon sequestration

Biodiversity and green spaces
Policy Your comments
Biodiversity and green spaces - general comments
BG/BG: Biodiversity and geodiversity Biodiversity Net Gain conditions should include developer funds for monitoring and remedialaction if required.
BG/GI: Green infrastructure Support for recognition of Pollinator corridors. Strategic Green Infrastructure should include protection and enhancement of chalk aquifer spring line.
BG/TC: Improving Tree canopy cover and the tree population Support particularly providing enhanced protection to existing mature trees.
BG/RC: River corridors Support Steeple Morden has an important tributary of the Cam flowing through the Parish – The Rhee. There should also be recognition enhancement and protection for the brooks which emanate from the aquifer spring line and help feed the river system.
BG/PO: Protecting open spaces Support
BG/EO: Providing and enhancing open spaces Support

Wellbeing and inclusion
Policy Your comments
Wellbeing and inclusion - general comments
WS/HD: Creating healthy new developments
WS/CF: Community, sports, and leisure facilities Support
WS/MU: Meanwhile uses during long term redevelopments
WS/IO: Creating inclusive employment and business opportunities through new developments
WS/HS: Pollution, health and safety Support

Great places policies
Policy Your comments
Great places – general comments
GP/PP: People and place responsive design Support
GP/LC: Protection and enhancement of landscape character Support. Need to ensure protection of landscape setting of villages and penetration of countryside gaps as an important element of character particularly those villages with a predominantly linear form.
GP/GB: Protection and enhancement of the Cambridge Green Belt
GP/QD: Achieving high quality development Support
GP/QP: Establishing high quality landscape and public realm Support
GP/HA: Conservation and enhancement of heritage assets Support Need to complete Conservation Area Assessments for villages
GP/CC: Adapting heritage assets to climate change
GP/PH8: Protection of Public Houses Support but condition included that if part of Pub is agreed for another use the marketing policy remains.

Jobs policies
Policy Your comments
Jobs – general comments
J/NE: New employment development proposals
J/RE: Supporting the rural Economy Support
J/AL: Protecting the best agricultural land Strongly support particularly in the light of grade I peat soil requiring remedial action and the need for increased food security.
J/PB: Protecting existing business space
J/RW: Enabling remote working Support
J/AW: Affordable workspace and creative industries
J/EP: Supporting a range of facilities in employment parks
J/RC: Retail and centres
J/VA: Visitor accommodation, attractions and facilities
J/FD: Faculty development and specialist / language schools

Homes policies
Policy Your comments
Homes – general comments
H/AH: Affordable housing
H/ES: Exception sites for affordable housing Support but all types of sites should retain local connection and permanence criteria
H/HM: Housing mix
H/HD: Housing density
H/GL: Garden land and subdivision of existing plots Support
H/SS: Residential space standards and accessible homes
H/SH: Specialist housing and homes for older people
H/CB: Self- and custom-build homes
H/BR: Build to rent homes
H/MO: Houses in multiple occupation (HMOs)
H/SA: Student accommodation
H/DC: Dwellings in the countryside Support but would stress the importance of ensuring that structures are sound.
H/RM: Residential moorings
H/RC: Residential caravans
H/GT: Gypsy and Traveller and Travelling Show People sites
H/CH: Community led housing Support and encouraged where there is no conflict with exception site policy.

Infrastructure policies
Policy Your comments
Infrastructure – general comments Agree there should be support for community led projects but should describe what form the support should take.

Infrastructure should be operational before occupation of new housing particularly the need to manage surface water runoff from hard surfaces to minimise the amount of sewage being released into the waterways
I/ST: Sustainable transport and connectivity Support but Improvements required to rural public transport and the last mile congestion into Cambridge City.
I/EV: Parking and electric vehicles Support for rural public charging points at community facilities
I/FD: Freight and delivery consolidation
I/SI: Safeguarding important infrastructure Support. Should also include disused railway lines with potential for future use.
I/AD: Aviation development Airfields are an important resource and difficult to replace. Local Plan should recognise the need for National Network of General Airfields.Government National Planning Policy Framework section 106.f, to ensure that planning decisions have regard to the importance of the national network of General Aviation airfields is clear. Environmental health concerns should be taken into account when deciding on housing location to avoid new occupants stress, disappointment and possible conflict.
I/EI: Energy infrastructure masterplanning
I/ID: Infrastructure and delivery Greater Cambridge is in a severely water stressed area and is causing environmental damage. Development should be curtailed until new water supply and sewage infrastructure is operational.
I/DI: Digital infrastructure Need for enhancement of mobile phone coverage in villages with poor reception by well sited and suitably camouflaged masts.

Supporting documents on which we are consulting
Policy Your comments
Sustainability Appraisal (incorporating the requirements of the Strategic Environmental Assessment)
Habitats Regulations Assessment

Vision and aims
I support the vision and aims of the Local Plan and the general direction of the development strategy, but am concerned about the overall scale of development and the continuing high levels of growth which are driven by technical economic growth forecasts.

How much development, and where – general comments
I recognise that Greater Cambridge has a strong and nationally important economy, but I do not support the continuing pace and scale of high levels of growth that has increasing cumulative impacts on the environment, water supply, heritage and carbon emissions.
I would argue that the growth of the Cambridge and the impacts of that level of growth on South Cambridgeshire are disproportionately high (a third higher than the government targets) compared with other Local Plans, because the scale of growth is driven by technical economic forecasts studies and the desire to continue to stoke the engine of growth yet again.
The area over the last 30 years has absorbed major levels of development which has brought many benefits and disbenefits.
But the time has come with this Plan, in a new era having to seriously address the causes and impacts of climate change and net zero carbon goals to set t Cambridge on a different course.
The development strategy should with this Plan start to reduce the scale of growth to more manageable levels, perhaps towards the Low option so as to set the direction of travel for the next planning round in the era of climate change .

S/JH: New jobs and homes
The level of new homes proposed in the Plan is driven by the need to enhance economic growth, so much so that it is 37% higher than the Government targets for the area.
This proposes larger amounts of housing growth in the surrounding South Cambridgeshire District to serve Cambridge and the surrounding area.
A large amount of new development proposed in the housing pipeline is already allocated to known sites. A moderated target would lessen the uncertainty of deliverability, ease of the identified water supply issue and give time to for water companies to decide and implement sound options, and reduce climate impacts.
Even a moderate reduction in the housing target, which goes so far beyond what the Government requires, could provide more reserve housing sites, providing flexibility to maintain a five year housing supply, reduce pressure on villages and start to slow the pace of change in an area, which has seen so much cumulative change over the recent decades.

S/DS: Development strategy
I generally support the Development Strategy that supports sustainable development and proposes compact active neighbourhoods in Cambridge, development and /or expansion of new towns connected by good public and active transport and the proposals for very limited new development in the rest of the rural area.

S/SH: Settlement hierarchy
I support the proposed Settlement hierarchy policy area as a means of planning and directing new development towards the most suitable and sustainable locations.
In my comment on the rest of rural area, I am concerned about the impact of unallocated housing windfalls being used by possible speculative planning applications contrary to the development strategy to direct development to the most sustainable locations.
I would suggest that the word indictive in the proposed policy SS/SH is omitted to strengthen and add clarity to the proposed policy in the light of the revised annual windfall target.
Support the reclassification of Cottenham and Babraham villages to provide locations for development and new jobs on good public transport routes.

S/SB: Settlement boundaries
I support the work on the development of Settlement boundaries, especially to protect the open countryside from gradual encroachment around villages and on high quality agricultural land.
The work on settlement boundaries should include the involvement of Parish Councils at an appropriate stage in the development of the Policy because of their local data and knowledge of past development.

Cambridge urban area - general comments
Support in Cambridge urban area for good designed, active compact new developments, reuse of brownfield land and continued development of larger neighbourhoods where possible.

S/NEC: North East Cambridge
Support the development of NE Cambridge as a sustainable neighbourhood with good public transport and active transport into Cambridge

Edge of Cambridge - general comments
Support edge of Cambridge planned new neighbourhoods and new sustainable developments and settlements of sufficient size to cater for daily needs and with good access to public and active transport

New settlements - general comments
Support for new settlements of substantial size to cater for more than local needs. I particularly support the growth of Cambourne which can provide good rail access into Cambridge and to the West in the mid-term from new East West rail infrastructure.

S/BRC: Babraham Research Campus
Support the release of land from the Green Belt to support nationally important R and D and life science jobs located near to public transport routes and active transport.

S/RSC: Village allocations in the rural southern cluster
NB, Policy has different name on map page.
In accordance with reducing carbon emissions, and supporting access to the existing rail network the villages of Shelford and Whittlesford could be locations for more sustainable development, despite Green Belt locations

S/SCP: Policy areas in the rural southern cluster
Support existing site allocations to be carried forward including the expansion of Babraham research campus using Green Belt land

Rest of the rural area - general comments
I support the development strategy approach which directs new development to a limited number of sites in the most sustainable development locations supporting the sustainability of villages.
There is still the matter of the unallocated housing windfall development identified in the strategy Topic Paper of 5345 homes for 2021-2041 which is not included in the additional allocated land target of the 11596.
The anticipated dwellings per year for SCDC is between 240 and 255 dwellings a year. Notwithstanding the proposed policy SS/SH, there is a risk that developers will seek speculative permission in the open countryside greenfield sites contrary to the development strategy using the windfalls allocation and I have made a comment on this on Policy SS/SH.

Climate change - general comments
All new development will have impacts relating to increasing carbon emissions and require adaptation responses. A Local Plan can only seek to mitigate these impacts and by far the most impacts are from the existing development, their use and getting around using carbon fuelled transport.
The rate of change in and around Cambridge over the past 30 years has been significantly greater than for just local needs, mainly to develop nationally important economic development. This Plan continues this approach despite the issue of climate change and water supply and large amounts on new development still to be implemented from current Local Plans.
I would argue that the time has now come to step back from this direction of travel and begin to reduce the scale of growth around Cambridge using the Low option as a first step.
I was hoping, given the aims of the Plan and the input of the Net Zero Carbon study for a more radical Plan which addressed climate change and zero carbon targets through aiming to reduce the total amount of new development to meet local needs need and move to a position which is in line with Government targets in the next planning round.

CC/NZ: Net zero carbon new buildings
Support in general
Although I have concerns about how for example heat pump technology can be installed and used at reasonable cost in new development.

CC/WE: Water efficiency in new developments
Support, important given the water supply issues coming forward up to 2041

CC/DC: Designing for a changing climate
Support especially with regards balancing insulation and overheating with increasing hot to very hot summers risk brought about through a changing climate.
Site wide approaches should include appropriate lower densities through good design which allow for beyond minimum garden space and space for Suds and open space and greening.

CC/FM: Flooding and integrated water management
Support
Especially permeable surfaces and integration of water management with enhancements to biodiversity and greening.

CC/CS: Supporting land-based carbon sequestration
Support the creation of land for use as carbon sinks through the development process. Perhaps a suitable use of land in the Green Belt or on lower grade agricultural land.

Biodiversity and green spaces - general comments
Support the identification of 14 strategic GI initiatives and enhancing the linkages between GI and open spaces to provide corridors for wildlife.

BG/BG: Biodiversity and geodiversity
Support delivery of a minimum 20% biodiversity net gain.
I would comment that funding for long term management of biodiversity assets is key for the long-term benefits from such a policy.
I could also emphasis the creation of winter wet areas, water space and Suds designed to benefit enhanced biodiversity should be planned in to developments at an early stage

BG/GI: Green infrastructure
Support the use of a GI standard, particularly on larger developments.
In particular early identification of GI and biodiversity assets and potential gains as an early part of the design process and /or planning brief

BG/TC: Improving Tree canopy cover and the tree population
Support increasing tree and woodland cover, ensuring right tree(s) in right places and species futureproofed for lifetime changing climate adaptation.
A particular opportunity is the rural field margins of agricultural land to help increase the linkages and biodiversity gains and in specific places the creation of woodland belts in the open countryside, green belt land and around villages.
In Cambridge urban areas, where there are existing trees there is a need to plan their replacement with adaptation species to gradually adapt to a changing climate.
Also, to provide sufficient future tree cover to mitigate the urban heat island effect, provide shade and mitigate microclimatic effects.

BG/RC: River corridors
Support the protection and enhancement of river corridors and restoration of natural features and use of GI to support the alleviation of flooding risk.
Support the delivery of the continuous Cam Valley Trail.

BG/PO: Protecting open spaces
Support the protection of the wide variety of open spaces and use of Local Green Space designation in appropriate locations

BG/EO: Providing and enhancing open spaces
Support the provision of open space and recreation provision, including appropriate play space.

WS/HD: Creating healthy new developments
Support the use of health impact assessments in proposals.
I would comment that with the increase in ride on electric vehicles and increasing older communities there are opportunities to coordinate with transport professional the delivery of smooth pathways with minimal dropped kerbs which gives smoother access to local centres and bus stops linked to older persons housing and also can prevent falls.

GP/PP: People and place responsive design
Support the requirement of inclusion of a comprehensive design and access statement and recognise the importance of good design tailored to the local area and involving local communities and Parish Councils particularly in villages.

GP/LC: Protection and enhancement of landscape character
Support the use of landscape character assessment to enhance the setting of Cambridge and protect and enhance the setting of villages.

GP/GB: Protection and enhancement of the Cambridge Green Belt
National guidance places great importance on Green Belt policy and sets out how planning proposals should be considered.
I support the use of GI and other opportunities to provide access and increase tree and woodlands where appropriate in the Green Belt.
But I think where there are locations where there is good public transport especially rail access or future rail access there is a good case to consider the special circumstances judgment.
I think it is time to question if this national policy is still relevant to the situation Greater Cambridge in the period up to the middle of the century. Further Green Belt assessments may be better served by considering sustainable development and the extension of the Green Belt to prevent coalescence around villages beyond the current Green Belt boundary which was made before most of the new development (over 70%) is beyond the current outside boundary or further modification of this policy to enable growth to be planned for the 21st century rather than the conditions which related to the last century.

Jobs – general comments
I am concerned about the scale of economic growth in the area and its use to drive large amounts of housing growth well about what would be required in other planning areas.
However, I support the life science sector and its national importance and the appropriate development in science parks including their expansion using Green Belt land

J/AL: Protecting the best agricultural land
Support the restriction of development on the best agricultural land as supported in the Sustainability Appraisal.

Homes – general comments
Support the objective for planning enough housing to meet our needs, including affordable housing to rent or buy.
I object to needs being directly driven by future economic assessments, the direction of travel of the plan should be as much balanced by the climate change as future economic demand.

H/HD: Housing density
Support design led approach to determine optimum capacity of sites and appropriate density to respond to local character, especially in villages.

H/GL: Garden land and subdivision of existing plots
Support for controlling the use of gardens for new development.

The Council recognise that this policy requirement is significantly lower than the minimum allowable technical standard for water efficiency as set out in PPG. The reason for placing an 80 litres per person per day is due to the unsustainable levels of abstraction from the chalk aquifer used to supply the Greater Cambridge area. However, the Council have noted that the position with regard to future supply and the necessary infrastructure to meet demands is still uncertain and that more detail will be known on publication of the net Water Resource Management Plan in 2022. Clearly should the necessary infrastructure be provided to address the demands in this area then the Council will need to review the necessity of the 80 litre per person per day requirement.

INTRODUCTION

This is the consultation response from the Cam Valley Forum to the Draft Local Plan. We highlight the issues that our group addresses namely the health and well-being of our human community’s relationship with our river and river valley, be it its nature, wildlife, amenity or heritage. The Forum, a voluntary charitable organisation, works with many other bodies to protect and improve the river Cam and its riversides, including its many tributaries and its sustaining aquifers. This response focuses mainly, therefore, on our group’s concerns for the future of the river and its environment. However, since as individuals and as a group, we are also concerned about the city and its environs, we are not confining our comments to river-related issues alone. We has contributed to the planning discussions that have already taken place but we do urge that some of the points below be taken seriously.

The River Cam is an invaluable, but vulnerable, natural asset to the environment of Cambridge and South Cambridgeshire. Cambridge without its river would not be all that it is. As your proposals recognise, the river and its tributary streams bring threads of wildness through an intensively farmed countryside as it flows north. Its riversides contain and connect with many important wetland habitats. Its wetlands still hold elements of the wildlife most typical of this ancient lowland region.

Important to the whole planning process is the fact that the River Cam’s waters are enjoyed by rowers, punters, boaters, canoeists and swimmers, while many more people enjoy walking, picnicking or angling from its banks. It therefore needs to be a river to be proud of and not ashamed of. Visitors from far and wide come to experience the world-famous Cambridge Backs.

The Chalk streams in the UK are internationally important in the conservation of biodiversity. The UK has about three-quarters of the world total. For reasons of long standing environmental abuse in the Cam Valley these streams are not among the best (on account of low flows and widespread pollution) but, despite the impacts of over-abstraction, pollution and channel modifications, they are still valued highly for their lowland scenery and for their provision of recreation and well-being for local people. We welcome that Chalk streams are now on your planning map as highly significant to our national conservation position and that means that with investment by Cambridgeshire the position is potentially reversible. Largely through our lobbying and the campaigning of many other river supporters something is at last now happening.

The local plan has at last woken up to this reality - but may not have done so entirely. We do need some development but there has been too much spin and ‘greenwash’ from the pro-development lobby. There is thus a tendency to give lip service to sustainable development without recognising that we humans are part of the ecosystem and are already overdrawing our natural capital. We call on our political leaders need to heed the authoritative voice of Sir David King (former Government Chief Scientist): he made it very clear to a recent meeting of Natural Cambridgeshire that unless you first have ecosystem well-being you cannot contemplate truly sustainable development. He is right. All the policies and proposals of this local plan need to be appraised rigorously, in the light of their potential to counteract or weigh against genuine environmental sustainability. Only if that is recognised do we welcome it.
We address our remarks in response to the plan under the Policy headings you have employed, most specifically in your designated areas of ‘Climate Change’ and ‘Biodiversity and Green Spaces’.

CLIMATE CHANGE
Policy CC/DC

The report of the Cambridgeshire and Peterborough Independent Commission on Climate drew on well- founded national research but not, as far as we are aware, on any detailed local meteorological studies.

As you recognise, the Cambridge area rainfall is low compared to any other English region and is, year on year, highly variable. Droughts and flood events are therefore to be regularly expected. Summer evapotranspiration generally exceeds rainfall. Thus, only winter rainfall adds significantly to the recharge of the chalk aquifer; the local water companies’ dependence on this source (97% for Cambridge Water) therefore lacks resilience in the face of winter droughts. We are glad that this is now being addressed by plans for a Fen Reservoir. But there is little chance of this physically helping our dire situation before 2035. The reservoir provision alone will not be sufficient for the demand unless water neutrality is assured in new development.

The Commission’s report suggests that winter rainfall may increase but the graph below shows only a tiny upward trend over the past 120 years; we cannot expect any significant increase in winter recharge. There have been much greater droughts in the past than anything experienced recently. [Graph- Winter Rainfall 1900 to 2020]


There is, however, in terms of climate change, plenty of evidence of rising summer temperatures, earlier springs and longer summers. This all means greater evapotranspiration. Our studies attribute part of the Cam’s currently falling river flows to increased soil moisture deficits. i.e. it takes more rain to wet up the soil before any rain water percolates through to recharge ground water. Our 2020 Let it Flow! report shows that in 24 (41%) of the years 1961-2019 inclusive, winter rainfall did not exceed the previous deficit, so there was in effect no recharge. When this happens in two consecutive winters, as last in 2018-19, our Chalk streams suffer greatly the following summer.
Present water sourcing from the aquifer is already unsustainably managed as historical river flows have halved. This greatly reduces the chance of reversing the losses of wetland biodiversity that the Greater Cambridge area has already experienced. We heartily agree with the national Environment Agency that only a 60-70% reduction in present abstraction will return our rivers to more normal flow. Until this is achieved there will still be serious short term consequences for meeting water demand. This must continue to be recognised and not brushed aside.

We also question the good sense of the Government’s calculation of the overall risks from climate change to future population growth in this region. Year on year, many risks appear to be increasing (from sea level change to higher temperatures); the precautionary principle needs to be to the fore in this already densely crowded and low-lying region. You cannot easily plan to mitigate a rising trend.

Our policy position on water flows, as advanced in our Manifesto in 2019, Let it Flow! report in 2020, and other submissions, and as summarised in our response to the Government’s Draft Strategic Priorities for OFWAT, is:
• We expect OFWAT and the water companies to act to protect and enhance priority habitats. In the case of Chalk streams, for which the UK has a global responsibility, we expect them to take a lead role in implementing the CaBA Chalk Stream Restoration Strategy 2021. They should take all possible steps to reduce abstraction from Chalk aquifers at source, aiming to ensure that chalk springs and headwaters run freely, as they would under natural conditions, every year, whatever the weather.
• The companies should cap abstraction at current actual (not licensed) levels, meet new demand through water transfers (from surface water sources) from other companies, and invest in reservoirs fed by high winter flows as alternative sources of supply.
• Recognising that all Chalk streams now lie within ‘areas of serious water stress’, they should establish a new baseline of annual restrictions on water use and tighten these as necessary in response to environmental as well as supply triggers.
• Companies treating wastewater should invest in spill monitoring, stormwater storage, and phosphate reduction to 0.2 mg/l total phosphorus, at all works that discharge to Chalk streams.’

In the Cam Catchment, in 2019, three water companies abstracted some 105 Megalitres/day from the Chalk aquifer (Cambridge Water 64%, Affinity Water 22% and Anglian Water 14%). The Environment Agency abstracted a further 15 Ml/day to augment flows on Cam Valley Chalk streams damaged by water company abstraction. Until the proposed Fens and South Lincolnshire reservoirs come on line in the 2030s, the companies must cap abstraction and supply all new demand in Greater Cambridgeshire by water transfers from surface water sources to the west and the north. They also need to invest in compulsory metering, leakage reduction and demand management. The local authorities should do everything in their power to support this dramatic readjustment in our water supplies.

Policy CC/WE and CC/FM

We fully support Policy CC/WE, which will require new developments to meet high standards of water efficiency, in particular the standard of 80 litres/person/ day for residential properties (unless demonstrated impracticable). We contributed to and welcomed the Integrated Water Management Study (IWMS). To achieve any ‘water neutrality’ from the current position will require substantial reductions in demand commensurate with any and every development envisaged. The track record of our resource management is so bad that we have little confidence in any major development improving things without a huge cultural change and management change to the water industry operations. This is really urgent.

In Let it Flow! we proposed that consumption might be regulated by the local authority. We do recognise that this would require Central Government legislation and action, but why not? Local authorities play a much stronger role in controlling water use in similarly water stressed regions such as Cape Town (RSA) and California (USA), why not in Cambridge too? Our local water companies currently propose little more than ‘targeted communication’ to encourage voluntary reductions in water use during prolonged dry weather.
Local authorities should join us in pressing for mandatory restrictions on consumptive uses (e.g. hosepipes, sprinklers and pressure-washers) in every summer, with such restrictions being rapidly tightened and widened if ‘dry weather’ turns into ‘drought’.

Policy CC/FM

Flooding is an ever present concern. We are pressing for a more integrated approach by the Environment Agency, Natural England, farmers and Local Authorities. The Local Plan should recognise that episodic ‘flooding’, may be increasingly likely with climate change. This can be mitigated upstream by slowing river drainage. We have had over 60 years of ill-advised river dredging in our lowlands to increase arable areas on farms. To reverse this trend would help. This more ‘natural’ approach to flood plain management would require a reversion to an earlier pattern of agricultural land-use management with wet meadows and less arable land in the flood plain itself.

Some river valley farmers are already making this positive change. e.g. South Cambridgeshire could develop a larger flood plain basin with a wet woodland as a buffer against future Cambridge City flood events. This wet woodland would impede rapid flow, so attenuating the flood, save water, sink carbon dioxide and ease soil erosion. Such wet woodland sites could also provide great benefits to biodiversity and even recreational areas. The present heavy winter flood events are losing good soil from our farmlands. Restoring riparian grazing grasslands would sequester carbon efficiently - an added bonus to our carbon depleted soils.

We fully support Policy CC/FM, which includes directing development away from floodplains, the incorporation of sustainable drainage systems into new developments (including the use of mitigation wetlands and permeable surfaces), and ensuring that new development does not increase flood risk elsewhere.

BIODIVERSITY AND GREEN SPACES

Policy BG/RC

We broadly welcome the River Corridors Policy. However, it promotes River Corridors as an amenity for recreation as if the rivers are already in good health and can take increased human pressure. The river water flows and water quality are not in good health. The summer Cam runs pretty much with only treated sewage effluent. On the tiny Mel river (tributary of the Rhee) the summer flow pulses with the periodic discharge from their local sewage treatment works. We have recently shown, through water testing, that the bulk of E coli in the river Cam comes from these treated effluent sources. Because of low river flows, our water quality status is ‘poor’ in the upper Cam corridor. This is largely on account of unacceptably high phosphate levels. The status quo is already shameful.

The plan should fully map a ‘nature recovery network’ with set targets for improvement. Water is a vital part of this connectivity, as are all drains, streams, rivers, lakes and ponds. A ‘nature recovery network’ must include these aquatic elements at the same time as identifying new large-scale areas for habitat creation, including new woodlands and areas of natural regeneration, and opportunities for linking them all together. We acknowledge that there are health benefits from rural access, but our wildlife - presently limited by pollution, habitat and biodiversity losses - are also vulnerable and need more protection.

The pressures on our present open spaces along corridors with public access are already hard to manage and are presently considerable: Grantchester Meadows is a case in point. However, sites like Trumpington Meadows are beginning to show that positive change is possible.

In our 2020 Green Infrastructure consultation response we urged the planning designation of ‘Riverscape Opportunity Areas’ (perhaps a more interesting title than ‘River Corridor’) extending at least 50 metres each side of the main rivers, streams and brooks within Greater Cambridge. In these areas, the aim should be to encourage natural processes so far as possible. For example: buffering watercourses against surface water run-off and improving habitats in built-up areas; and, in rural areas,reconnecting rivers with their flood plains, tackling the damage caused by over-deepening and straightening, buffering them against nutrient, pesticide and soil inputs, and restoring light grazing.

Opportunities that should be sought within ‘Riverscape Opportunity Areas’ include:

(a) Vary mowing regimes in urban parks to create more diverse vegetation.

(b) Actively reintroduce meadow species into rye-grass swards on the urban commons and parks (including parts of the more intensively-managed local Nature Reserves) using local seed sources (e.g. as on King’s College lawn) to strengthen populations of less common wild flowers that are vulnerable to local extinction.

(c) Recreate scrapes and ditches on riverine commons in Cambridge to restore habitats for wetland plants lost when the commons were infilled and levelled in the 19th century (for examples of the impacts and their extent in Cambridge see C. D. Preston et al (2003): The long-term impact of urbanisation on aquatic plants: Cambridge and the River Cam. The Science of the Total Environment 314-316: 67-87).

(d) Create further inlets and ponds to create new water habitats, provide refuge areas for fish during high flows and areas where young fish can flourish. The new inlet created on Logan’s Meadow in Chesterton is valuable in many ways although further work appears to be necessary to improve water quality as the stream and pond bed appears to be dominated entirely by algal growth.

(e) Replace sealed surfaces where possible with permeable paving to allow water to filter into the soil rather than running into the river, creating pollution risks (e.g. in front of boathouses in Cambridge).

(f) Install and maintain silt and pollutant traps in all surface water drains from highways or private land (e.g. Colleges) that run directly into the river, or connect these instead into the sewer network, to reduce water pollution from hydrocarbons, microplastics, and silt.

(g) Commission and implement expert advice (e.g. from the Wild Trout Trust and Wildlife Trust) to restore and enhance rivers and their tributaries in Greater Cambridge. Reports available on the Wild Trout Trust website include: Cam (Hinxton 2015), Granta (Linton 2019, Babraham 2019), and Cherry Hinton Brook (2017). These make many valuable recommendations to tackle concerns such as: low flows; pollution from sewage works, surface water drains and contaminated land; tree and vegetation management; siltation; channel over-deepening and straightening; and barriers (e.g. weirs).

(h) Establish significant buffer strips of natural vegetation alongside watercourses to protect them from spray drift and run-off of soil and nutrients from intensively-managed farmland.

(i) Remove invasive non-native species such as Floating Pennywort Hydrocotyle ranunculoides, and Himalayan Balsam Impatiens glandulifera, which threaten indigenous biodiversity.

In relation to item (g), we very much welcome the Greater Cambridgeshire Chalk Stream Project, which draws on the expert work of Rob Mungovan, Ruth Hawksley and Guy Belcher; Their inspiring report identifies opportunities to restore channels and enrich the river substrates with manageable modifications. We note that the implementation cost of the 109 projects listed for Chalk Streams within 13 of the Cam catchment’s 29 water bodies is some £800,000. We urge the City and District Councils to seek this funding in conjunction with those locally committed to Chalk Stream restoration.

Policy BG/EO
We fully recognise the benefits of open spaces as a key aspect of the environment. They are indeed fundamental to the character of an area. Attractive, accessible and well-designed open space can
certainly support and enhance the appearance of an area. Such places are not built in less than decades and too often developers are completely ill-equipped to manage or plan such areas. When questioned at ‘Darwin Green’, for example, the developers there were completely unable to say how the designated open spaces would be made ‘green’ how they would be managed and what diversity of options were being considered. This is a planning imperative. Is the GCP up to planning these things with its own staff? It is frankly disgraceful that more physical conservation management staff are not employed. Green infrastructure requires jobs to be created and committed to long term planning and support.

Riparian pasture is essential to the future of our green spaces. Paradise, Sheep’s Green and Coe Fen are exemplars of good practice. These areas have quite high biodiversity, very capable management and combine traditional wetland pasture management by cattle with provision of open recreational space. The Rush stream also provides a very valuable site for wildlife in a near urban setting. Green sites can be well-used by the public while being degraded ecologically (e.g. Jesus Green has little ecological value as a grassland habitat). If river corridors are to show wildlife gain, we need genuine Rus in urbe management. Urban wildlife (in Cambridge) is substantially more biodiverse than in the surrounding countryside, especially where there are major gardens with good tree and shrub cover. Grazing by ‘Cam Cattle’ also makes a vital and under-appreciated contribution to the biodiversity of insects and many bird species.

Tree planting and appropriate species selection is also important, but the greatest losses of habitat that Cambridgeshire has suffered have been of lowland florally rich grassland. This is a more appropriate target for river corridors than extensive tree planting. If trees are planted close to watercourses, they often bring added management problems especially when they fall or are felled. It is possible to plant traditional willow species for pollarding, where there are cattle, but such plantings do need a commitment to enduring cycles of management. Again, is that enduring commitment to care built into the planning?

SPT/AW/BH

Cam Valley Forum 13 December 2021

Appendix

Our website https://camvalleyforum.uk/provides links to further information, including:

The Government’s proposed strategic priorities for OFWAT: https://camvalleyforum.uk/wp- content/uploads/2021/10/CVF-response-to-Defra-strategic-guidance-to-OFWAT-15-10-21.pdf

Green infrastructure (July 2020): https://camvalleyforum.uk/wp-content/uploads/2021/02/Cam- Valley-Forum-Green-Infrastructure-response-25-07-20.pdf

Tentative proposals for a Bathing Water designation (January 2021): https://camvalleyforum.uk/wp- content/uploads/2021/02/cvf_swimming.pdf and the responses to that consultation: https://camvalleyforum.uk/wp-content/uploads/2021/03/Cam-Valley-Forum-Responses-to-Bathing-Water- Proposal-08-03-21.pdf.

Let it Flow! (May 2020): https://camvalleyforum.uk/wp- content/uploads/2020/05/Cam_Valley_Forum_Let_it_Flow_Full_report_26-05-20-compressed.pdf

What support will be available for developers in seeking to meet the high standards proposed? Will the potential impact on viability be taken into consideration? Regardless of the chosen approach, it would be useful to include further guidance/information in an SPD.

What support will be available for developers in seeking to meet the high standards proposed? Will the potential impact on viability be taken into consideration? Regardless of the chosen approach, it would be useful to include further guidance/information in an SPD.

What support will be available for developers in seeking to meet the high standards proposed? Will the potential impact on viability be taken into consideration? Regardless of the chosen approach, it would be useful to include further guidance/information in an SPD.