BG/GI: Green infrastructure

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Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 59845

Received: 13/12/2021

Respondent: Waterbeach Parish Council

Representation Summary:

The Cambridge Green Belt abuts Waterbeach parish, green open space and river Cam corridor.
It is extremely important that areas designated as SSSI’s, RAMSAR, SAC and other recognised protected areas should be enhanced and not a means to compensate for the lack of green space in high density settlements such as the Cambridge North Eastern Fringe development. It is also important to protect the abundant biodiversity and habitat in the parish. WPC request that this matter is treated as a priority if development is accelerated in WNT and the GC area.

Full text:

RE WATERBEACH PARISH COUNCIL – RESPONSE TO LOCAL PLAN – GREATER CAMBS PLANNING

Waterbeach Parish Council would like to make the following comments to the Greater Cambridge draft plan consultation concluding on Monday 13th December 2021

The Greater Cambridge draft plan states the following proposals for the acceleration of delivery of Waterbeach New Town as detailed below:

https://maps.3csharedservices.org/portal/apps/webappviewer/index.html?id=a6742a84b6 aa418f8b1e41315c2b8845

Preferred Options Sites - August 2021

Broad location New settlements
Preferred Option reference S/NS/SS/6
Site Waterbeach New Town
Use Mixed Use
New or existing allocation Existing
Housing delivery 2020-41, counted as current pipeline (adopted allocations, existing permissions and windfall allowance) 4,580
Housing delivery 2020-41, counted as increased delivery rates/densification on existing allocations 750
Housing delivery 2020-41, counted as proposed new site allocations -
Housing delivery post-2041 5,670
Housing delivery Full Build Out (2020 onwards) 11,000
Employment use classes E(g)
Area (ha) 427.49

Although Policy SS/6 Waterbeach New Town (WNT) in the SCDC 2018 adopted local plan for approx. 8,000 – 9,000 dwellings.
Nevertheless, planning approval (S/0559/17/OL) granted to the MOD & Urban & Civic for WNT (West) for 6,500 dwellings. Planning approval (S/2075/18/OL) “currently awaiting decision” RLWE Waterbeach (East) for 4,500 dwelling making a total of 11,000 dwellings plus associated buildings and infrastructure.
Policy SS/6 South Cambs District Council (SCDC) 2018 adopted local plan Page 7 1 3.41 states: A new town will require a significant amount of new infrastructure, including schools, shops, services and facilities to meet the needs of the town. It is important that the services, facilities, landscape and infrastructure needed by this development are not only provided to a high quality, but that they are properly and effectively implemented, managed and maintained if they are to meet the needs of the community as they arise and in the long term.
3.42 A fundamental requirement for this site is that it will be highly accessible and permeable to all its residents on foot, by cycle and public transport, to support sustainable transport, recreation and health. The site offers particular opportunities to deliver public transport improvements, including the relocation of Waterbeach railway station to a location where it will also be convenient for people living in Waterbeach village making rail travel highly attractive. Segregated provision for buses both within the town and to link the new town to the public transport network in Cambridge will be required and similarly for cycle use. This will provide for quicker journeys, encourage maximum use by residents of the new town and improve safety. The existing A10 is at capacity and road improvements will be required, including measures to address capacity at the Milton junction with the A14
WPC seek to know if policy SS/6 in the SCDC adopted local plan will be carried forward into the new local plan.
South Cambridgeshire Adopted Local Plan 2018 (scambs.gov.uk)

The Waterbeach SPD adopted by SCDC in February 2019 provides strategies as to how the New Town will progress including required infrastructure and responsibilities of developers and utility providers. S106 agreements have been formalised between SCDC and MOD/Urban & Civic. S106 agreements between SCDC and RLWE now at the draft stage. But the parish council have still not had opportunity to comment.
WPC note that in the GC draft local plan states
“The Supplementary Planning Documents for Land north of Waterbeach will be carried forward.”
SCDC adopted local plan Policy SS/6 - page 70 para 17 states:
Supplementary Planning Document: The SPD to be prepared for the Strategic Site shown on the Policies Map will provide further guidance and detail on the implementation of Policy SS/6. The SPD will include: a) An overarching, high level vision for the new town. b) Consideration of relevant context including key constraints and opportunities. C) The broad location of the components of the new town which are essential to support comprehensive and seamless development. A spatial framework diagram will be included that ensures the creation of a sustainable, legible and distinctive new settlement. d) The location, nature and extent of any formal open space to be provided outside of the Major Development Site. E. Broadly how the development is to be phased, including the delivery of key infrastructure https://www.scambs.gov.uk/media/13057/waterbeach-new-town-spd-low-res-feb-2019.pdf WPC would like to highlight the following identified issues as barriers to growth in the current adopted and emerging local plans that will need overcoming in a timely and fully funded manner, at least cost and disruption to the residents of Waterbeach parish and neighbouring villages.
1. Provision of Water
Cambridge City and South Cambridgeshire already have an unsustainable supply of potable water. In August 2020, the Environment Agency, in response to a query on the viability of water supply to Northstowe Phase 3A wrote to a resident that 'current levels of abstraction are causing environmental damage.
Any increase in use within existing licenced volumes will increase the pressure on a system that is already failing environmental targets', and 'many waterbodies did not have the flow to support the ecology.' This is the situation for proposed growth for South Cambs and Cambridge City
On 1st July 2021, DEFRA announced that chalk streams would be given enhanced environmental protection,and published the Environment Agency document titled “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, page 6. According to Appendix 3, Cambridge Water needs to reduce abstraction by 22 megalitres per day from levels current as at 1st July 2021, and Anglian Water needs to reduce abstraction by 189 megalitres per day from levels current at 1st July 2021.
Water Resources East is the body responsible to produce a plan for the provision of water to enable proposed growth in the Greater Cambridge area. At present there are no plans or costings or infrastructure in place. Until there is the provision of a sustainable water supply the proposed growth in the current and future local plan development may be unsustainable.
2. Sewage
Anglian Water (AW) currently have capacity at the Milton Waste Water Treatment Works (WWTWs) for the provision of sewage until 2050. AW have proposals to relocate the WWWTs to Honey Hill on Cambridge Green Belt land. Anglian Water granted £227m HIF by the government to fund the move however it is unclear if the grant will fully fund the project or

when if approved confirmation when the new works will be operational. AW are dependent that a DCO will be issued by the Planning Inspectorate.
Although there will be a need for a pumping station and pipelines the level of detail in the “Waterbeach Zone in AW’s recent scoping report which mentions haul roads, construction plans and other material planning considerations has not yet been disclosed or taken to public consultation. The Waterbeach Zone will have a significant impact on the people of Waterbeach parish, landscape, environment, Green Belt and biodiversity and should be given due weight and consideration in the draft local plan.
The Waterbeach Zone is a huge proposition the outcome of which will be arrived at by the provider AW and developers of Waterbeach New Town and a reliance that will be brought forward in a timely manner as stated in the SPD:
Page 130-131 “Provision will be dealt with through direct agreement with service providers as development is implemented. This will be outside the scope of any planning control or S106 agreement. Service providers are obligated to meet any demand arising from the development (11,000 dwellings, associated buildings, schools, businesses, hotels) with the site promoter providing the cost.”
It is unclear if part or whole of the required infrastructure for the Waterbeach Zone will be funded by the developers of WNT or by the £227m HIF government granted to AW for the relocation of the Milton WWTWs
It should be noted that there are already issues of contamination from sewage when there is heavy rainfall and already the need for many daily tanker movements from the Waterbeach WWTP. WNT build out must be limited until a new Waterbeach pumping station is commissioned and operational.
Planning Process – Cambridge Waste Water Treatment Plant Relocation Project (cwwtpr.com)
3. Electricity
WPC are aware that currently the provision of electricity is a barrier to growth. The Greater Cambridge Partnership (GCP) has undertaken to fund electricity grid reinforcements. Will that provision be in place and funds available ensure delivery to enable the proposed accelerated growth of WNT?
GCP takes ground-breaking approach to secure future of electricity network - Greater Cambridge Partnership
4. Transport Infrastructure
Transport plans submitted by Urban & Civic and RLWE were described as “substantially underfunded” by Sharon Brown SCDC Director of Delivery at the Extraordinary Planning Meeting for Waterbeach New Town East held on 29th January 2021 as evidenced in the broadcast here: Agenda for Planning Committee on Friday, 29 January 2021, 11.00 a.m. (moderngov.co.uk)
The proposals for the required sustainable transport infrastructure for WNT are currently of a piecemeal nature. The responsibility for delivery, cost and funding is currently unknown. The Greater Cambridge Partnership (GCP) is the responsible body for the delivery of the Waterbeach segregated busway and greenway. The Combined Authority (CA) is the responsible body for the dualling of the A10 or upgrade of junctions. Developers and SCDC through S106 developer contributions and planning obligations are responsible for cycleways and park and ride sites. Developers RLWE have been granted planning permission to relocate the existing Waterbeach station to the North of the village after they promised to fund the provision of the station. It is currently unclear if funding is available for the relocation of the station by RLWE. It is also unclear when the relocated station will be operational. The delivery of WNT was claimed to be dependent on the developer funded relocated railway station as a sustainable mode of travel.

5. The delivery of infrastructure controlled by triggers as per the number of dwellings coming forward
A faster build out rate will require a faster provision of the required infrastructure as detailed in the granted planning permissions, Policy SS/6 in the adopted 2018 Local Plan and the adopted Waterbeach SPD
6. Neighbourhood Plan
WPC wish to bring to GC planning’s attention that the Waterbeach Neighbourhood Plan is at an advanced stage of completion. The plan has been through examination by the Inspector and passed inspection. WPC are working with SCDC to finalise the plan which will then go to referendum. If parishioners vote in favour the plan will be “made sound.” The plan has stand alone SEA, Heritage and Character Assessment and Design Principles documents which can be considered as material planning considerations that support the plan. WPC request that the Neighbourhood plan and supporting documents are a consideration as development comes forward in the parish.
7. Cambridge Green Belt and green spaces
The Cambridge Green Belt wraps around the parish to the South, West and East. WPC request that the Green Belt land remains protected from windfall/rural exception site development to enable a green transition from the Eastern edge of the village towards the River Cam and access to the fenland countryside and public rights of way.
WPC note the proposals for greenspace and river corridors from the City to Wicken Fen, Anglesey Abbey and beyond. WPC note the proposed high density proposed for the Cambridge North Eastern Fringe development and question if this is to compensate for the lack of open green space per capita on the development site.
WPC seek reassurance that the proposed draft plan will not increase the density of WNT and other settlements currently in the adopted 2018 SCDC local plan by using the Cambridge Green Belt, fenland, farmland, river Cam corridor and waterways as open green space to compensate for the lack of green space within high density settlements.
WPC enquire how net gain offsetting will be proven and enforced due to the proposed accelerated growth of WNT?
8. Climate change and flooding
WPC feel it is Important that future risk of flooding is not increase due to accelerated growth from WNT through fluvial or surface water flooding as shown on the Environment Agency maps Fluvial risk enlarge map to include WNT:
https://flood-map-for-planning.service.gov.uk/confirm- location?easting=550093&northing=265821&placeOrPostcode=CB25%209JT
Surface water risk enlarge map to include WNT: https://www.cambridge.gov.uk/media/2568/strategic-flood-risk-assessment-appendix-b-part- 4.pdf
Climate Change -Central predicted risk of flooding due to sea level rise caused by climate change could occur as soon as 2030. How will this be a consideration and mitigated to compensate for an accelerated build out rate of WNT? https://coastal.climatecentral.org/map/12/0.2105/52.2889/?theme=sea_level_rise&map_typ e=year&basemap=roadmap&contiguous=true&elevation_model=best_available&forecast_yea r=2030&pathway=ssp3rcp70&percentile=p50&refresh=true&return_level=return_level_1&rl_ model=gtsr&slr_model=ipcc_2021_med
WPC seek to know if the proposed accelerated growth will affect GC zero carbon targets and how will it affect the GC aspirations in the draft local plan?

In summary:
The proposed acceleration of WNT is dependent on the required essential services including health and education, transport infrastructure delivered in a strategic, timely and fully funded manner.
It is important that there is a joined up strategic transport plan to provide sustainable, affordable, accessible and a reliable transport system to replace the fragmented system presently in existence.
It is important that the Waterbeach Neighbourhood Plan and supporting documents included and given due weight and consideration within the draft local plan.
The Cambridge Green Belt abuts Waterbeach parish, green open space and river Cam corridor. It is extremely important that areas designated as SSSI’s, RAMSAR, SAC and other recognised protected areas should be enhanced and not a means to compensate for the lack of green space in high density settlements such as the Cambridge North Eastern Fringe development. It is also important to protect the abundant biodiversity and habitat in the parish. WPC request that this matter is treated as a priority if development is accelerated in WNT and the GC area.
How will GC planning ensure net gain offsetting targets in the draft local plan are met due to the accelerated growth of WNT? How will it be monitored and manage to obtain “net gain”
The settlement of WNT and Waterbeach village on the Environment Agency flood maps show them to be vulnerable and prone to flooding from fluvial, surface water and sea level rise. How will residents and important farmland be protected due to the proposed accelerated growth of WNT in the draft GC plan?

Attachments:

Representation Document (216.15 KB)

Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 59921

Received: 13/12/2021

Respondent: Fen Ditton Parish Council

Representation Summary:

Broadly supportive but again concern that this is too general a concept that requires further precision.

Full text:

Vision and development strategy
Vision and aims
THE VISION
The vision is contradictory, misconceived and undemocratic, unquestioning, unachievable, and based on inadequate evidence. The draft Plan and this whole consultation are premature.

It is contradictory in that the vision of a big decrease in climate impacts is totally undermined by blindness to fundamental incompatibilities between growth and carbon reduction. Its claims of sustainability and Net Zero are not credible given that the carbon costs of construction are not included in the Plan’s definition of a Net Zero Carbon building.

It is misconceived and undemocratic in that it claims to want “the variety of homes and jobs we need” when all the proposed options involve levels of growth dictated by a combination of Government fiat (through both imposed housing targets and four growth corridors led by the Ox Cam Arc) and the ambitions of a local oligarchy (exemplified by Cambridge Ahead) which is unrepresentative of the people of Greater Cambridge. The Arc proposals are in direct conflict with the “levelling up” agenda, will not deliver “levelling up” in terms of Cambridge’s inequalities (notably affordable housing) and should not be taken as justification for the level of growth being proposed (https://smartgrowthuk.org/wp-content/uploads/2021/09/The_Overheated_Arc_Part_3_September_2021.pdf).

The Plan’s “predict and provide” approach fails to even question the desirability or deliverability of this imposed growth. Nor does it begin to tackle the severe challenges arising from past and present growth, notably in terms of affordability (in the most unequal city in England), and transport capacity issues (first identified by Holford 70 years ago), both of which have been exacerbated by growth, and will be further exacerbated, not diminished, by the growth now proposed.

It is unachievable in that
a) it ignores environmental capacity limits, most immediately in relation to water issues, but also in relation to the physical character of Greater Cambridge, and the capacity challenges of accommodating the intense activity of a 21st century city within the built fabric and spaces of a historic University town and its hinterland.
b) its claims to increase nature, wildlife and green spaces rely on a quantum of development that, considered holistically, will have an opposite effect.
c) the Plan’s growth proposals will compound the damaging impacts of current growth on our unique heritage and landscapes.

Its evidence base is incomplete and inadequate. Inexcusably, it has no assessment whatever of environmental capacity (a fundamental issue for the Plan) other than in relation to water supply. The Climate change evidence is inadequate and misleading, notably because it uses a definition of Net Zero Building which omits the embodied carbon of construction. There is no review or assessment of the success or failure of current local plan or other policies. This is compounded by the woefully inadequate historic environment evidence base, which has no strategic consideration of Cambridge as a world famous historic city, and is so incomplete that it only mentions one Conservation Area Appraisal (the Historic Core) when all the city’s Conservation Areas are covered by Appraisals, and fails to use the readily available evidence contained within them.
The draft Plan and the whole consultation are premature pending
1) A thorough understanding and appreciation of the current character of Greater Cambridge and its environmental capacity
2) The forthcoming Water Resources East consultation on the Regional Water Plan, on which these proposals depend
3) Transport solutions which can be accommodated in the space available, including those currently and imminently out for consultation on transport capacity and links within and outside the city.

THE AIMS
The Plan’s aims do not include what is arguably the most vital: how to maintain, enhance, and provide more equitable access to what makes Cambridge special, in the face of the combined challenges of growth and Climate Change. This should be a key priority of the Historic Environment Strategy which is required by the NPPF, but absent from the First Proposals.

As someone from the Tech industry said in a meeting last year with Stephen Kelly, Director of Planning: “Malta has concrete high rises, no one goes there. The Tech sector comes here because it’s a nice place to be. If Cambridge takes a predict and provide approach, it will accelerate into catastrophe.”

How much development, and where – general comments
No more development allocations until issues arising from existing approved growth have been identified and tackled. This means waiting for the Regional Water Plan and coherent publicly-endorsed proposals for tackling existing congestion and capacity issues, challenging the assumptions underlying the Ox Cam Arc, and carrying out a holistic assessment of environmental capacity and the limits to growth. All in line with the principles of Doughnut Economics which the City Council says that it has adopted.

The evidence base is seriously inadequate in relation to environmental capacity. There is no evaluation of the success or failure of existing policies in maintaining the special character of Cambridge, an aim which the new Plan seeks to maintain. Such consideration needs to include not only impacts of the form, scale and location of new development, but also of the transport and other infrastructure required by it. Current growth is putting massive, and unresolved pressures on the capacity of existing transport links, and the physical capacity of Cambridge’s roads system and public realm.

The GCP’s Making Connections proposals, currently under consultation, attempt to resolve some of the challenges, but have no detailed assessment of the capacity of Cambridge’s streets to take the extra volumes of bus and cycle traffic being proposed. Given that Cambridge’s congestion problems are historic, and compounded by growth, this consultation on Local Plan proposals for additional growth is premature in the absence of credible and detailed proposals to tackle current capacity issues.
S/DS: Development strategy
How can the proposals aim for net zero with this sheer volume of proposed development (while whole-life costing of large new proposals is welcome, what about the carbon cost of developments in the pipeline? - see above and comments on CC/NZ below).
No mention of impacts of transport links required for these proposals. Need to ensure that these are brought forward in concurrently with the Local Plan proposals.
Cambridge urban area
Cambridge urban area - general comments

Massive environmental capacity issues, with inadequate space in City streets and public realm to cater for existing traffic, let alone approved growth already in the pipeline – even before considering these First Proposals. The capacity issues have to be tackled, with additional growth allowed only if they can be resolved.

No mention of Covid and opportunities for city centre residential / other uses resulting from potential radical changes in retail.
No new cultural or provision for other “city-scale” needs, so putting the city centre under even greater pressure.

S/NEC: North East Cambridge
Vividly illustrates the issues. Gross over development.
Edge of Cambridge
Edge of Cambridge - general comments
The Green Belt assessment is not fit for purpose, because it ignores historic environment designations and landscape character constraints.

This highlights a vital flaw of the Plan, its failure to take a holistic view of the combination of different elements (including historic and natural environment) which make up the character of Greater Cambridge. The Government may have tried to artificially separate the natural and built environment with its Environment Act, but that doesn’t mean this approach should be followed in Cambridge!

Climate change
Climate change - general comments

The definition of a Net Zero Carbon building set out in the Evidence Base does not include its embodied carbon: this is a very serious omission which undermines all claims made about the sustainability of new development, and raises questions about the claimed sustainability credentials of all the Growth options being proposed.

Already out of date in terms of Government targets (e.g. the Heat and Buildings Strategy, not mentioned in the draft Plan), and rapidly developing guidance and best practice.
Support regular reviews to keep pace with developing technology, standards, Government targets (e.g. the Heat and Buildings Strategy, not mentioned in the draft Plan), and rapidly developing guidance and best practice. There are also serious quality control challenges in relation to whether aspirational aims are actually delivered. How will this be done? Outline planning permissions must be subject to the aspirations articulated in draft local plan. How will this be done?
Projects proposed to help achieve net zero need to be both delivered and SAFEGUARDED, throughout the Plan period, to ensure that the aims are delivered (e,g, need to ensure that biodiversity / natural capital / “doubling nature” (sic) and any other such schemes are protected from subsequent inappropriate changes of use or management)
Agree that development should be located so that low carbon transport links can be accessed. However, such locations should not be chosen based on proposed busways – the delivery of these is uncertain and their construction generates carbon emissions through the embodied carbon in the building materials, tree felling reducing carbon capture, maintenance and serving works, and lighting, contrary to the Council’s net zero carbon agenda.

CC/NZ: Net zero carbon new buildings
The definition of a Net Zero Carbon building set out in the Evidence Base does not include its embodied carbon: this is a very serious omission which undermines all claims made about the sustainability of new development, and raises questions about the claimed sustainability credentials of all the Growth options being proposed.

Support recognition of embodied carbon, also whole life carbon (see CC/CE). build for future re-use, including requiring use of lime mortar not cement to enable re-use of fired and quarried materials.

Where possible, existing buildings should be re-used (“The greenest building is the one that already exists”– Carl Elefante https://www.architectsjournal.co.uk/news/opinion/the-greenest-building-is-the-one-that-already-exists quoted in the Architect’s Journal Retrofirst campaign https://www.architectsjournal.co.uk/news/opinion/join-our-retrofirst-campaign-to-make-retrofit-the-default-choice)

Require whole-life assessments whenever demolition of an existing building is proposed. (e.g. false net zero claims made for new Kings College development on Barton Rd – no mention of the embodied carbon of the buildings demolished to make way; same applies to the Flying Pig replacement) .

CC/CE: Reducing waste and supporting the circular economy
Support recognition of embodied carbon, also whole life carbon (see CC/CE). build for future re-use, including requiring use of lime mortar not cement to enable re-use of fired and quarried materials.

Where possible, existing buildings should be re-used (“The greenest building is the one that already exists”– Carl Elefante https://www.architectsjournal.co.uk/news/opinion/the-greenest-building-is-the-one-that-already-exists quoted in the Architect’s Journal Retrofirst campaign https://www.architectsjournal.co.uk/news/opinion/join-our-retrofirst-campaign-to-make-retrofit-the-default-choice)

Require whole-life assessments whenever demolition of an existing building is proposed. (e.g. false net zero claims made for new Kings College development on Barton Rd – no mention of the embodied carbon of the buildings demolished to make way; same applies to the Flying Pig replacement) .

Incredibly, no mention of retrofit in the Climate Change topic paper! The Council’s apparent view that retrofit is not within the scope of the Plan is mistaken. The only place in which retrofit is mentioned, and far too narrowly, is in policy GP/CC in the Great Places paper. This is one of several instances where a holistic approach should require read-across between Policies in different sections (e.g. also between historic environment and natural environment).

Retrofit will be within the direct scope of the Plan (guiding planning decisions) whenever it involves works which could potentially require planning permission or listed building consent.
[Case in point is the new Institute for Sustainability Leadership building (conversion of former telephone exchange) on Regent St. Major impact on appearance of building which makes (or made) a positive contribution to the Conservation Area, not a heritage asset but requiring planning permission. The submitted justification included every possible assessment criterion apart from townscape / heritage impact (shockingly not even considered by the applicants!). What has been approved and is now being built involved losing the window detailing which was a key part of the building’s character. Since that scheme was approved, PAS 2038 (non-domestic retrofit guidance) has come into force: it would have required a more comprehensive approach by the applicants, and might have led to a different decision. ]

Retrofit is also within the scope of the Sustainable Design and Construction SPD, which needs to be updated to include embodied carbon, over the whole life cycle of construction (including retrofit and refurbishment), as set out in British Standard BS EN 15978:2011:
SEE ATTACHED
(slide by Alice Moncaster)

This Climate Change section should include specific policies covering retrofit, which will feature ever more strongly as Govt targets for Band C etc bite. These targets present serious challenges now, and will get ever more serious during the Plan period, with high risks of carbon (and money) being wasted on inappropriate works. Yet Net Zero Carbon for existing buildings is mentioned only cursorily, on a single page (35) of the Local Plan’s Net Zero Carbon Evidence Base.

There is no mention whatsoever of the need for a different approach to buildings of traditional solid wall construction. These form at least a quarter of the existing stock; this proportion should have been considered and assessed as part of the Evidence Base. It could even be as high as 35%, the proportion quoted in the BRE study “Solid wall heat losses and the potential for energy saving” published by DECC in 2015.

The specific challenges of traditional buildings , and the risks of unforeseen consequences (and of consequent waste, rather than saving, of carbon and money) are highlighted in PAS2035, the Government’s guidance on domestic retrofit, which is referenced in Policy GP/CC. However the reference to PAS 2035 in the Policy is futile in its draft form because the PAS (although Government guidance) is not freely available, but published by the British Standards Institute, costing £190, and so is inaccessible to home owners and others who need the guidance.

The Climate Change section of the Plan should quote key principles and guidance* from PAS 2035 and its non-domestic counterpart PAS 2038 (and reference other freely available advice including from the STBA and IHBC as well as the Government’s own guidance to Private Sector Landlords) in sufficient detail to ensure that people dealing with ALL traditional buildings (not only heritage assets) have access to the appropriate advice and skills to ensure that their buildings are put in good repair, and then suitable retrofit measures are applied as appropriate. See https://stbauk.org/whole-house-approach/. This is essential to achieve the aims of the PASs and to minimise unintended consequences.
*including (e.g.) section 0.1.1 of PAS 2035:
SEE ATTACHED

Biodiversity and green spaces
Biodiversity and green spaces - general comments
Serious environmental capacity issues (see above), particularly in relation to intensification of pressures on green spaces..

BG/BG: Biodiversity and geodiversity
Projects proposed to help achieve net zero need to be both delivered and SAFEGUARDED, throughout the Plan period, to ensure that the aims are delivered (e,g, need to ensure that biodiversity / natural capital / “doubling nature” and any other such schemes are protected from subsequent inappropriate changes of use or management)

BG/GI: Green infrastructure
Flawed in that green infrastructure and historic environment re considered separately (see comments on Edge of Cambridge, River corridors, and Protecting open spaces). A holistic approach is essential – see NPPF definition of the historic environment..

BG/RC: River corridors
The River Cam Corridor initiative does not mention the historic environment, historic environment designations, or conservation area appraisals. High risks of more intensive use. no mention of environmental capacity issues or recognition that there may be capacity limits to growth or access by either/both local people and visitors (impacts of punt operators on Cam, etc). No mention of historic environment designations. No consideration of areas under particular threat. No consideration of historic / characteristic uses and land management. The whole river corridor from Byron’s Pool to Baits Bite, and its historic uses are vital parts of the historic and cultural as well as landscape character of Cambridge and should be safeguarded. Grantchester Meadows, one of the key river corridor historic and cultural spaces, is the only vital section of the corridor currently without Conservation Area designation; it is currently threatened by visitor pressures and by possible removal of the grazing cattle which play a vital part in traditional water meadow management.

BG/PO: Protecting open spaces
No mention that many open spaces are historic, and form part of the historic environment (see NPPF definition of the historic environment) need to consider their significance as a whole, not just in terms of green infrastructure. Historic environment and local identity are vital elements of the wellbeing identified here

BG/EO: Providing and enhancing open spaces
Open space is not just green space - what about the market square, Quayside etc etc? Need to manage existing pressures, and avoid harmful intensification of use, on all open spaces, and ensure that new development does not increase these pressures. The river corridor is particularly vulnerable.

Wellbeing and inclusion
Wellbeing and inclusion - general comments
There are no documents in the Document Library to support this theme. Why not?

The Topic Paper highlights the importance of place and space, but its text is focused on new developments, and does not mention the contribution made to wellbeing by the beauty and special character of existing places, including the city of Cambridge, the towns and villages, and valued countryside. The historic environment is a vital part of wellbeing.

Nor is Covid mentioned, even though the pandemic has highlighted the vital importance of access to local green space, and to local fresh food. Small local producers have continued to provide when the supermarkets supply chains fail. Cambridge market, and the local producers who sell from it, continues to provide a lifeline of health and wellbeing for many people, as well as providing vital opportunities for business start-ups including makers as well as food sellers.

There is no assessment of existing cultural activities, of current demands for space, or of demands for new space arising from either existing approved growth or that now proposed. Nor is there any assessment of related opportunities in terms of under-used retail space post-Covid. This is a totally inadequate baseline for a credible Plan.

The forthcoming Cultural Infrastructure Strategy for Greater Cambridge will need to recognise Cambridge’s international cultural significance in terms of both its historic environment (which meets UNESCO’s Outstanding Universal Value criteria for World Heritage sites), and its past and present cultural activities. The Local Plan should include policies to protect this significance, and specifically to support cultural activities, and to provide for, and safeguard, public and private spaces for arts and other activities.

Great places policies
Great places – general comments

The Great Places paper refers to Heritage Assets, but completely fails to recognise that the city of Cambridge is a heritage asset of worldwide significance which meets UNESCO’s Outstanding Universal Value criteria for World Heritage status. This significance derives from the combination of its built and natural heritage. The draft Plan fails to recognise the vital role which this special character plays in making Cambridge a great place to live in, work, study, and visit.

The draft Plan also fails to recognise the historic relationships between Cambridge as a market town, its market, and its productive hinterland.

The draft Plan’s approach involves a false separation between Landscape and Townscape (Objective 6) and Historic Environment (Objective 7), which for Cambridge has resulted in inadequate consideration and valuation of the historic city in its historic landscape setting, with historic landscape and open spaces considered as green infrastructure but not as historic environment.

Cambridge’s special character has been, and continues to be, under severe threats from the quantum of already approved growth (built developments and pressures on both streets and green spaces). There are severe environmental capacity issues in trying to accommodate the demands of a 21st century city within what remains the built fabric and spaces of a medieval market town. These fundamental conflicts between growth on the one hand and environmental capacity and special character on the other should have been recognised as a key challenge for the draft Local Plan. so why wasn’t the Historic Environment Baseline Study prioritised, and published as part of the Nov 2020 tranche?

But the draft Plan documents include no assessment of current pressures, let alone the impacts of the draft First Proposals.

Instead, para 3.2.4 of the Strategic Heritage Impact Assessment: baseline makes a totally unevidenced statement that:
“3.2.4 Future growth in Cambridge has the potential to strengthen and reinforce these characteristics, enabling the City to meet contemporary environmental, economic and social drivers without undermining its economic identity".

Overall, the Evidence base for Great Places is inadequate, and the proposals are premature pending a thorough review of the success or failure of existing policies.

GP/LC: Protection and enhancement of landscape character
Over-intensification of use is a major threat to landscape character.

GP/GB: Protection and enhancement of the Cambridge Green Belt
I strongly support protection of the Green Belt, but the Green Belt assessment is not fit for purpose, because it ignores historic environment designations and landscape character constraints.

The Council appears to have forgotten that the Green Belt was set up to protect the setting of the historic University city.

GP/QP: Establishing high quality landscape and public realm
Serious issues of street capacity.

GP/HA: Conservation and enhancement of heritage assets
A vital issue given totally inadequate consideration and priority. The historic environment (not just heritage assets) is a vital part of Cambridge, not just in terms of Great Places, but also for Wellbeing, and for the city’s prosperity.

The historic environment, and its capacity (or not) to withstand existing growth (let alone new growth proposed) should have been considered at the start of the Great Places chapter. Understand what you have, then consider its capacity for change
Fails to consider anything other than designated heritage assets. No consideration of heritage significance of Cambridge as a whole, or of the heritage significance of undesignated buildings, spaces, and intangible heritage –notably Cambridge’s market, which pre-dates the University, and Grantchester meadows.
The Heritage Impact Assessment is not fit for purpose, and clearly written by consultants who have limited knowledge of Cambridge, and of issues, policies, and initiatives relating to its historic environment. There is no mention of any Conservation Area appraisal apart from the Historic Core, and no cumulative assessment of significance and issues identified in these Appraisals.
.
The “Strategic Heritage Impact Assessment: baseline” is woefully inadequate in both its scope and its approach:
a) In its scope, because it confines itself to stages 1 (identify the historic assets” and 2 (“define and analyse the settings”) of Historic England’s ”Settings of Heritage Assets: Good Practice Guide”, without considering the dynamic of the city as a whole, what has been happening in its recent years, or the potential impacts of currently approved growth. It is almost as if the Council asked for an updated version of the 1971 publication “Cambridge Townscape”, whilst completely disregarding the award-winning conservation plan approach of the 2006 Historic Core Appraisal which sought to understand not just the physical character of Cambridge but its dynamic, and threats and opportunities, as part of shaping policies.

b) while the document references the Historic Core Conservation Area Appraisal, it does not even mention other Conservation Area Appraisals (ignoring the complete Appraisal coverage of the City's Conservation Areas) or issues and opportunities identified therein. Nor does it mention the Suburbs and Approaches Studies. It is all too clear that the consultants have taken only a superficial look at the baseline information.

c) I would have expected consultants preparing this “high level” document to consider the historic environment, and the extent of designations, strategically (a great opportunity for this combined Plan) - but the document does not even consider the extent to which Cambridge’s historic and cultural landscape (including the river corridor from Byron’s pool to Baits Bite Lock) is or is not protected.

d) The study completely fails to assess the significance of Cambridge as a whole. Dennis Rodwell’s “Conservation and Sustainability in Historic Cities” puts Cambridge on a similar level of international significance to Venice.

e) For the options involving development in and adjacent to Cambridge, it seems to assume that most problems can be resolved by Design, completely ignoring environmental capacity issues. At a most immediate level, what if any detailed assessment has been made of the wider visual impacts of tall buildings on the North-East Cambridge site?

There are fundamental environmental capacity issues in terms of pressures on the character and spaces of the historic core and surrounding landscape, due to not only the additional volumes of development, people and traffic being generated by the proposed additional growth, but all of these arising from existing approved growth plus the transport links required to enable it.

There is no assessment whatever of the cumulative impacts on landscape, townscape and environmental capacity of all the GCP and other proposals including busways, City Access, Greenways, Active Travel schemes etc.

A third-party, holistic overview is essential to identify and try to resolve some of these key strategic issues and balances, and consider to what extent further growth is viable. In relation to heritage, growth is seriously threatening what makes Cambridge Special. I suggest that Historic England’s Historic Places Panel are invited to visit Cambridge and provide strategic recommendations which can inform the Local Plan.

The flaws in the current approach are exemplified by a claim in the Strategic Heritage Impact Assessment: baseline:
“3.2.4 Future growth in Cambridge has the potential to strengthen and reinforce these characteristics, enabling the City to meet contemporary environmental, economic and social drivers without undermining its economic identity"
This statement can only be described as unevidenced, shockingly ignorant and ludicrously complacent.
Moving from strategic issues to safeguarding individual heritage assets and their settings, there are serious questions in relation to the effectiveness of existing policies which are proposed to be carried forward.

A case in point is the former Mill Road Library a grade II listed building of high public significance, which was recognised to be “at risk” but ignored by both the City and County Councils during the development and approval of the City’s Depot site redevelopment. This was a massive opportunity which would not have been missed had the City complied with its own Local Plan policy regarding heritage assets. While the County has belatedly refurbished the former Library, it has not been integrated as a public building within the new development. It appears that the County may now be offering this public building, built for the public, for private sale!

GP/CC: Adapting heritage assets to climate change
This policy is basically very good -but should relate to all buildings of traditional construction, and needs some updating. Needs direct read-across to CC/NZ. See my comments on CC/NZ.
Supporting documents on which we are consulting
Sustainability Appraisal (incorporating the requirements of the Strategic Environmental Assessment)

The Sustainability Appraisal fails to tackle the key environmental capacity issues arising from existing growth, let alone that now proposed.

The whole definition of “Sustainable Development” is too narrow given that since 2010 the UN has included Culture as the 4th pillar of Sustainable Development - and Cambridge's historic environment is a cultural asset of worldwide significance.

Within the current UK sustainability assessment process (dating from 2004 and excluding culture), there is a separation between Landscape and Townscape (Objective 6) and Historic Environment (Objective 7), which for Cambridge has resulted in inadequate consideration and valuation of the historic city in its historic landscape setting, with historic landscape and open spaces considered as green infrastructure but not as historic environment.

Attachments:

Diagrams referenced in Representation (68.26 KB)
Covering email (124.05 KB)

Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 60280

Received: 13/12/2021

Respondent: Commercial Estates Group

Agent: Lichfields

Representation Summary:

One of the key policies proposed in the GCLP is ‘Policy BG/GI: Green infrastructure’ which identifies the existing green infrastructure network and the strategic initiatives intended to enhance it and addresses how development proposals should relate to green infrastructure. CEG fully support the Councils’ aims and ambitions in this regard.

Full text:

Context
The NPPF sets out that local plans should take a strategic approach to maintaining and enhancing networks of habitats and green infrastructure (paragraph 175). The Local Nature Partnership ‘Natural Cambridgeshire’ have set an ambition to double the area of rich wildlife habitats and natural greenspace in the area by 2050 – known as the ‘doubling nature’ initiative. Further to this and at a more local level, the Cambridge Nature Network, devised by two charities (Cambridge Past Present and Future and the Wildlife Trust BCN) and endorsed by the Greater Cambridge Councils, have been established.
These initiatives have emerged alongside a growing awareness that Cambridgeshire is one of the most nature depleted counties in the country and that, as an area of rapid economic and population growth, the provision and accessibility of natural greenspace has not kept pace with this. Further, the report identifies the importance of the need to enhance and create green spaces for public recreation and refreshment, the Covid-19 crisis highlighting the need for publicly accessible green space. As a result, natural assets in Cambridgeshire are coming under increasing pressure from growing visitor numbers. The emerging GCLP is therefore a key element in supporting such initiatives and ensuring that the best opportunities to increase or improve new habitats and natural greenspaces are realised. The Reg 18 consultation recognises the importance of this by setting out an aim to: ‘Increase and improve our network of habitats for wildlife, and green spaces for people, ensuring that development leaves the natural environment better than it was before’.
In order to achieve this aim, one of the key policies proposed in the GCLP is ‘Policy BG/GI: Green infrastructure’ which identifies the existing green infrastructure network and the strategic initiatives intended to enhance it and addresses how development proposals should relate to green infrastructure. CEG fully support the Councils’ aims and ambitions in this regard and consider that development of the site could promote the successful delivery of green infrastructure in a positive and collaborative way. As the Cambridge Nature Network’s report alludes, the reconnection of people to nature, particularly resulting from the pandemic, has led to an increased appreciation of the value of nature for recreation and health. A survey conducted by Cambridge Ahead during the pandemic found that access to nature was the top ranked concern of young employees (aged 21-35) and therefore it is felt that there should be an acknowledgement within policy that increasing access to green spaces through a joined up green infrastructure approach should be encouraged.

Attachments:

Representations to the GCLP First Proposals - CEG (7.88 MB)

Representation ID: 60373

Received: 10/12/2021

Respondent: The Critchley Family

Number of people: 3

Agent: Cheffins

Representation Summary:

The adoption of a green infrastructure standard should be a recommendation, not a requirement. Developments should not be opposed where all reasonable steps have been taken to protect and incorporate green infrastructure.
Regardless of the chosen approach, it would be useful to include further guidance/information in a supplementary planning document (SPD).

Full text:

The adoption of a green infrastructure standard should be a recommendation, not a requirement. Developments should not be opposed where all reasonable steps have been taken to protect and incorporate green infrastructure.
Regardless of the chosen approach, it would be useful to include further guidance/information in a supplementary planning document (SPD).

Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 60378

Received: 13/12/2021

Respondent: Stephen & Jane Graves

Number of people: 2

Agent: Cheffins

Representation Summary:

The adoption of a green infrastructure standard should be a recommendation, not a requirement. Developments should not be opposed where all reasonable steps have been taken to protect and incorporate green infrastructure.
Regardless of the chosen approach, it would be useful to include further guidance/information in an SPD.

Full text:

The adoption of a green infrastructure standard should be a recommendation, not a requirement. Developments should not be opposed where all reasonable steps have been taken to protect and incorporate green infrastructure.
Regardless of the chosen approach, it would be useful to include further guidance/information in an SPD.

Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 60388

Received: 13/12/2021

Respondent: David Wright

Agent: Cheffins

Representation Summary:

The adoption of a green infrastructure standard should be a recommendation, not a requirement. Developments should not be opposed where all reasonable steps have been taken to protect and incorporate green infrastructure.
Regardless of the chosen approach, it would be useful to include further guidance/information in an SPD.

Full text:

The adoption of a green infrastructure standard should be a recommendation, not a requirement. Developments should not be opposed where all reasonable steps have been taken to protect and incorporate green infrastructure.
Regardless of the chosen approach, it would be useful to include further guidance/information in an SPD.

Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 60404

Received: 12/12/2021

Respondent: Great and Little Chishill Parish Council

Representation Summary:

This is a priority.

Full text:

Please see attached summary.

Attachments:

Biodiversity and green spaces.docx (13.04 KB)

Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 60470

Received: 13/12/2021

Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 60515

Received: 13/12/2021

Respondent: Taylor Wimpey UK Ltd

Agent: Turley

Representation Summary:

Full text:

Attachments:

Representations to the GCLP First Proposals - Taylor Wimpey (955.55 KB)
Map (539.43 KB)

Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 60572

Received: 13/12/2021

Respondent: Countryside Properties - Fen Ditton site

Agent: Turley

Representation Summary:

Full text:

This policy wording sets out that ‘all development proposals – appropriate to its type, scale and location - to include green infrastructure, providing the following varied benefits for people, wildlife and planet’. It is suggested that further clarification should be provided within the wording of this policy as to what type, scale and location of development will be required to provide green infrastructure. This will avoid any ambiguity.
Countryside specialise in designing sensitive and innovative masterplans which maximise the potential of the natural landscape. Finding ways to protect and enhance the best aspects so that they can enrich the proposals and deliver a strong character with an instant sense of maturity. Countryside believe in landscape led masterplanning with the aim of creating a living landscape. These principles will be applied to the Fen Ditton proposals to create spaces which allow wildlife, nature and people to thrive together. The proposals are will provide a range of key green infrastructure features to include:
• Pockets of green and expansion of recreation ground to connect new and old;
• Green corridor from river to railway; and
• Creation of a landscaped interface with the A14.

Attachments:

Representations to the GCLP First Proposals (1.43 MB)

Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 60587

Received: 13/12/2021

Respondent: Martin Grant Homes

Agent: Barton Willmore

Representation Summary:

Policy BG/GI highlights areas within Greater Cambridge that are considered appropriate for green infrastructure initiatives. With regards to the promotion of land in Coton, area 7 (West Cambridge green infrastructure buffer – Coton Corridor) is relevant to land at Silverdale Close given it washes over the site.

Full text:

Policy BG/GI: Green Infrastructure

9.0 POLICY BG/B1 GREEN INFRASTRUCTURE
9.1 Policy BG/GI highlights areas within Greater Cambridge that are considered appropriate for green infrastructure initiatives. With regards to the promotion of land in Coton, area 7 (West Cambridge green infrastructure buffer – Coton Corridor) is relevant to land at Silverdale Close given it washes over the site.

9.2 The policy as proposed seeks to ensure development can benefit ‘people, wildlife and the planet’ and provides a list of criteria as to how that can be achieved, including the need to ensure ’proposed green infrastructure is appropriate to its local context’.

9.3 At Silverdale Close, open space is indicatively location to the south of the site, where it can benefit from views of the countryside and Bin Brook along the southern boundary. The development allows the opportunity to enhance Bin Brook by providing long term maintenance along the waters edge and providing suitable habitat features to encourage use of the brook by identified species. On site planting can also respect and supplement the tree planting beyond the western boundary.

9.4 The finalised wording of the policy should be drafted so as not to inhibit development within these areas. As noted, the Site brings forward significant benefits and is a logical extension to the village. The green infrastructure policy must be clear that appropriate development is suitable in this location and the policy should not be an opportunity to deny appropriate development in principle. The policy should then set out the potential requirements to be included within such development.

9.5 At this stage, it is unclear as to how the policy will be worded and therefore further representations will be made in further consultations as necessary.

Attachments:

Representation Document (6.51 MB)

Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 60759

Received: 13/12/2021

Respondent: Cambridge and South Cambridgeshire Green Parties

Representation Summary:

The policy is good but direction is ambiguous in explanation.
Policy should clearly relate to Great Place/Climate
Change, also unclear interaction with open space standards referred to in BG/EO.
Would like to see that provision of green space should respect the Natural England Accessible Natural Greenspace Standards.
We support the policy direction that development should meet the GI Standard given in Building with Nature.
We support list of strategic GI initiatives, Expanding Greater Cambridge’s ‘urban forest’ but statements unclear.
We are pleased to see Allotments and Community Gardening listed in this section.

Full text:

This policy direction is very ambiguously explained and, although the policy itself is generally good, it will need much greater clarification to avoid misinterpretation by developers and those assessing planning applications. The thrust of the policy should be very clearly related to the policies on Great Place/Climate Change. We are not clear how this policy interacts with the open space standards referred to in BG/EO but would strongly advocate for specific targets to be set for the provision of the different types of Green Infrastructure wherever possible (see also our comments under BG/EO).
1st bullet: GI to be “appropriate to its local context” – we agree with this general direction but this phrase should be clarified.
2nd bullet (Supporting delivery of biodiversity net gain, including by providing links between habitats within and beyond the site boundary, and connecting where appropriate to the wider ecological network ) – we agree with this in general but again it should be worded more clearly. We welcome the recognition of the need for a ‘bigger, better, more joined up’ approach which is now an accepted biodiversity principle, but we are concerned by the phrase ‘carefully balancing the needs of wildlife and people’ which would be very difficult to define in practice.
5th bullet (Enhancing access and connectivity) – we think this has the same meaning/intention as 2 and 3 and so could be deleted to reduce complexity.
6th and 7th bullets (Providing environmental enhancement; and Supporting climate mitigation and
adaptation) need further explanation with perhaps an example, so that these general statements are comprehensible in the context of the Local Plan.
Within this GI policy, we would like to see a clear statement that provision of green space (one of the forms
of GI) should respect the Natural England Accessible Natural Greenspace Standards (which have been used in Suffolk and Shropshire). These standards are that green space should:-
● Be at least 2 ha in size, and no more than 300 metres (5 minutes walk) from home; and
● Include at least:
○ one accessible 20 ha site within two km of each home;
○ one accessible 100 ha site within five km of each home; and
○ one accessible 500 ha site within ten km of each home;
In addition, the Standards call for a minimum of one ha of statutory Local Nature Reserves per thousand population.
We support the policy direction that development should meet the GI Standard given in Building with Nature.
We support most of the final components of this policy, including the list of strategic GI initiatives, but are unclear what is meant by the five “dispersed initiatives” and how development can contribute to these in practice.
We support the policy of Expanding Greater Cambridge’s ‘urban forest’. The tree and hedge cover in the Greater Cambridge area is too low and thus we are pleased to see projects to increase this. See also our response to BG/TC.
We are pleased to see Allotments and Community Gardening listed in this section. Allotments can contribute to a number of policy targets, including under climate change, biodiversity and green space, wellbeing and great places. There is a large unmet demand for allotments in Cambridge, as evidenced by long waiting lists. The current standard for allotment provision in new settlements in both the Cambridge and South Cambridgeshire local plans is 0.4 hectares per 1000 residents. To ensure the demand for allotments is met across Greater Cambridge, we need an assessment of current levels of provision, and a plan (encompassing both existing and planned settlements) to achieve this level of provision everywhere.
Adequate quality of provision must also be included in the standard, for example on-site water supply (ideally using harvested rainwater or other suitable supply rather than potable water), provision of accessible plots for disabled allotment holders, and the possibility for appropriate structures such as sheds and polytunnels to be incorporated into allotment sites.

Attachments:

PO - Local Plan 1st Proposals Green Party response_Redacted.pdf (308.69 KB)