BG/RC: River Corridors

Firstly, the Form To Assist gives a comment column for Vision and Aims.
We have numerous comments to make under this heading but I have not been able to locate this on the online system.
Secondly, the online system asks "Did you raise the matter that is the subject of your representation with the LPA earlier in the process?"
Guilden Morden Parish Council have not been involved earlier in the process. I have therefore clicked "No" but the system will not allow me to proceed further.
The online system allows only 100 words for each comment and to summarise the comments to avoid exceeding 100 words. It would have been helpful if the Form To Assist had stated that.
Vision and development strategy
Section / Policy Your comments
Vision and aims 1.Guilden MordenParish Council has concerns that the increase in population resulting from the additional homes target of 44,000 will have a negative impact on an already struggling traffic, school and healthcare infrastructure.
Specifically on traffic and congestion:
Commuting into and out of Cambridge at peak times already attracts significant congestion and delay for commuters.
This not only effects commuting by car but also bus and the Park&Ride buses as these typically use the same roads as the other commuters and the bus lane network doesn’t extend to where it’s needed.
Links between the train stations and the city centre are also currently inadequate and equally effected by commuter congestion.
The guided busway is too infrequent to be a viable alternative and typically the Park& Ride parking is at capacity leaving commuters with little alternative other than to drive into the city centre.
All of the above describes the current situation which will clearly be significantly worsened by the addition of 44,000 homes by 2041.
2. Is the methodology used in arriving at the figure of 44,000 defendable?

How much development, and where – general comments Support that the proposed developments are to be in major clusters in areas with good public transport.
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. Guilden 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.

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. Where might this be generated locally by solar and/or wind?
CC/NZ: Net zero carbon new buildings Support
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
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 remedial action 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
BG/RC: River corridors Support
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

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.
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
GP/CC: Adapting heritage assets to climate change
GP/PH8: Protection of Public Houses Support

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 Support
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
H/RM: Residential moorings
H/RC: Residential caravans
H/GT: Gypsy and Traveller and Travelling Show People sites
H/CH: Community led housing Support

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 fromhard surfacesto minimise the amount of sewage being released into the waterways
I/ST: Sustainable transport and connectivity Support but improvements required rural public transport and congestion into Cambridge (see comments under Vision and Aims)
I/EV: Parking and electric vehicles Support
I/FD: Freight and delivery consolidation
I/SI: Safeguarding important infrastructure Support
I/AD: Aviation development Support
I/EI: Energy infrastructure master planning
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.

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.

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

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.

Please see attached summary.

This policy relates to the impact of development on the River Cam and its tributaries. River Granta is such a tributary, which runs along the northern edge of the Land north of Cambridge Road, Linton. Taylor Wimpey are therefore supportive of the approach to protect, enhance and restore this natural feature, which the development of the site could help to achieve.

We strongly support the need to protect river corridors. This policy will need precise and clear definition to
ensure that it is enforceable.
We welcome projects that aim to partially renaturalise the Cam by restoring flood plains and habitats, for
example at Logan’s Meadow, Stourbridge and Jesus Green. Such projects should be prioritised because of
their potential to benefit wildlife and water quality while helping reduce flood risk. We support the goal of
improving people’s access to high quality green spaces, but care must be taken that multiple uses of the
river and its corridor do not threaten its environmental value. The possible damage to vital habitats by high
numbers of visitors is recognised in the evidence document; Greater Cambridge Green Infrastructure
Opportunity Mapping (2020).