I/ST: Sustainable transport and connectivity

We acknowledge and support the Councils’ commitment to delivering sustainable and inclusive communities “by minimising the need to travel and reducing travel distances, whilst ensuring there is effective and sufficient sustainable transport mode choice and improved connectivity for everyone of any ability”.
Land to the East Side of Cambridge Road offers connectivity across the pedestrian and cycle network, public transport and road network. Development of the Site fully aligns with the Councils’ commitment to delivering sustainable and inclusive communities, promoting walking and cycling and directing development to sustainable locations.

We acknowledge and support the Councils’ commitment to delivering sustainable and inclusive communities “by minimising the need to travel and reducing travel distances, whilst ensuring there is effective and sufficient sustainable transport mode choice and improved connectivity for everyone of any ability”.
Land to the East Side of Cambridge Road offers connectivity across the pedestrian and cycle network, public transport and road network. Development of the Site fully aligns with the Councils’ commitment to delivering sustainable and inclusive communities, promoting walking and cycling and directing development to sustainable locations.

TMLC supports the ambition that development will seek to deliver sustainable and inclusive communities by minimising the
need to travel and reducing travel distances, whilst ensuring there is effective and sufficient
sustainable transport mode choice and improved connectivity for everyone of any ability. Development should be located and designed to reduce the need to travel, particularly by car, and promote sustainable travel appropriate to its location.


Considering the site ‘Trumpington South’, Highways England consider there to be no capacity on the Strategic Road Network for development. On the adjacent development site at ‘Trumpington Park and Ride’, Highways England indicate that development would be acceptable with a ‘trip budget’ approach. The site ‘Trumpington South’ could explore a ‘trip budget’ approach to mitigate the impacts on the local Strategic Road Network.

To ensure that the Greater Cambridge evidence base is robust and up-to-date and therefore accords with Paragraph 31 of the NPPF (2021) the Existing Transport Conditions Report (November 2020) and subsequent Transport Evidence Report (October 2021) should be amended to correctly reference all bus services across Greater Cambridge, notably the omitted bus service 915. As a result, the sustainability of Fowlmere should be reassessed, including its ability to accommodate development.

We acknowledge and support the Councils’ commitment to delivering sustainable and inclusive communities “by minimising the need to travel and reducing travel distances, whilst ensuring there is effective and sufficient sustainable transport mode choice and improved connectivity for everyone of any ability”.

Land West of London Road offers connectivity across the pedestrian and cycle network, public transport and road network. This is further discussed in the accompanying Vision Document.

As set out in the following Section and in response to the Greater Cambridge evidence base, the Site at Land West of London Road, Fowlmere aligns with the overall strategy for Greater Cambridge in so far as directing development to a location where active and public transport is a natural choice, providing an ability to deliver green infrastructure and providing facilities near to where people live.

Existing Transport Conditions Report (November 2020) and Transport Evidence Base Report (October 2021)
The Greater Cambridge emerging Local Plan is supported by a Transport Evidence Report (October 2021) and Existing Transport Conditions Report (November 2020).

The Existing Transport Conditions Report sets out the existing transport situation in the Study area for the emerging Greater Cambridge Local Plan. Table 8 of the Report, sets out the bus frequencies in Greater Cambridge.

Paragraph 3.2.1.2 relating to bus frequencies goes on to state:

“The frequency of these bus journeys is one of the major reasons that the bus mode share for journeys to work is so low in Greater Cambridge as the low frequency of services means that people’s arrival and departure times are limited. In addition the service times do not necessarily coincide with the start and end of the working day and certainly don’t allow shift workers to make use of the existing bus services.”

Associated Table 8, however, appears to have omitted Stagecoach bus service 915, which provides frequent links between Cambridge/Trumpington Park and Ride and Royston. This bus route also services Fowlmere and runs every hour. At particular points in the day, bus services 915 and 31 collectively service Fowlmere with two buses an hour.

The table below sets out the frequencies of these services within Fowlmere Monday to Friday travelling to the centre of Cambridge.

Bus Service 915 Bus Service 31
06:46 -
07:46 07:27
08:46 -
09:46 09:37
10:46 -
11:46 11:07
12:46 12:37
13:46 -
14:46 14:07
15:46 -
17:22 -
18:22 -
19:22 -

Table 8 is therefore incorrect and should be amended to correctly reference bus service 915 accordingly.
Notwithstanding the frequent bus services within Fowlmere, it should also be noted that Fowlmere is a 6 minute journey to Foxton, which benefits from a train station and busway, and also a 9 minute journey to Melbourn, which also benefits from a train station. Fowlmere therefore represents a sustainable location for accommodating development.

Paragraph 3.2.15 of the Transport Evidence Report (October 2021) assesses each of the Spatial Strategy Options and states “Villages is the one option to see a decrease in active mode travel compared to the 2041 baseline… Given the particularly poor performance of this option and the problems with mitigating that performance due to the dispersed nature of development within this option… [development within] Villages is unlikely to be viable.”

This Paragraph, (which should be noted has incorrectly registered the bus services across Greater Cambridge, specifically those that service Fowlmere) fails to recognise that modes of public transport should not be viewed in isolation, rather should also be viewed collectively, with future residents being able to use both bus and train links to travel across the Greater Cambridge area, rather than a single mode of transport e.g bus routes. As set out above, the bus services in Fowlmere provide connectivity with the nearby settlements of Foxton and Melbourn, both of which have additional public transport links including train stations. By viewing modes of public transport collectively this would demonstrate that there are a number of villages within the Greater Cambridge area that are in sustainable locations, including Fowlmere.

The Transport Evidence Report goes on to state that “the proposed development strategy for Greater Cambridge is to direct development to where it has the least climate impact, where active and public transport is the natural choice, where green infrastructure can be delivered alongside new development, and where jobs, services and facilities can be located near to where people live, whilst ensuring all necessary utilities can be provided in a sustainable way.”

As demonstrated in the Technical Note supporting the delivery of development on Land West of London Road, Fowlmere, the Site offers a sustainable location benefitting from being within walking distance of a number of facilities, including village hall, primary school, business park, recreation ground and churches. The two bus services through Fowlmere (bus service 31 and 951) offer regular direct services to Royston and Cambridge in addition to nearby Melbourn and Foxton, both of which benefit from train stations.

The Site at Land West of London Road, Fowlmere therefore aligns with the overall strategy for Greater Cambridge in so far as directing development to a location where active and public transport is a natural choice, providing an ability to deliver green infrastructure and providing facilities near to where people live.

To ensure that the Greater Cambridge evidence base is robust and up-to-date and therefore accords with Paragraph 31 of the NPPF (2021) the Existing Transport Conditions Report (November 2020) and subsequent Transport Evidence Report (October 2021) should be amended to correctly reference all bus services across Greater Cambridge, notably the omitted bus service 915. As a result, the sustainability of Fowlmere should be reassessed, including its ability to accommodate development.

Support for high quality cycling infrastructure must include (a) attractively designed, covered cycle parking for residents and visitors in new developments, with provision for latest form of cycle (cargo bikes etc, e-bikes, with charging facilities considered). (b) Plentiful provision of cycle stands at retail and leisure areas - with stands widely spaced allowing the cyclist with many bags to lock cycles to stand easily. (The stands outside Clifton Way's Light Cinema are too close for comfort.) (c) Where within the Authority's powers, cycle routes to be made direct with minimal cause for stopping (but with pedestrians taking priority)

We support the principles of delivering sustainable and inclusive communities by minimising the need to travel and reducing travel distances. Ensuring access to sustainable transport is critical to meet climate change goals.

The expansion of the Campus into the identified Area of Major Change offers a significant benefit in this regard – locating new development close to existing and proposed public transport connections will encourage modal shift, reduce carbon emissions and will help to reduce the pressure on the road network.

The southern side of Cambridge will benefit from exceptional transport connections, particularly through CSET, EWR and Cambridge South station, and the Campus and the area identified for expansion occupies the optimum location to take advantage of these proposals. The Campus is very unusual within a Cambridge context to have such readily-available access to existing and, particularly, planned public transport infrastructure.

The expansion of the Campus will be guided by a Mobility Strategy focused on reducing the need to travel. Active travel principles are embedded within the CBC Vision 2050 and the Spatial Vision for the expansion of the Campus, and we anticipate that these will be carried forward to the local plan policy requirements.

CambridgePPF support this, however one of the greatest challenges is that house builders still consider that providing space for two cars per household is necessary to maximise sale price/volume. This results in (large) developments being laid out to accommodate those cars through the development, leading to a development form that supports car use. Active and public transport are then fitted around that layout (eg provision of cycle or bus lanes). A sea change in the industry is required to design differently and we would like to see policies that would be strong enough to refuse applications that have not taken active travel and public transport as the starting point for the layout of their schemes.

COMMENT

Policy I/ST: Sustainable Transport and Connectivity set out how the transport impacts of development should be managed, and how new development should be connected to the transport network. An aim of the policy is to reduce transport emissions. The preferred development strategy seeks to co-locate housing close to jobs, services and facilities in order to reduce the need to travel and support travel by walking, cycling and public transport. This approach is consistent with Paragraphs 104 and 105 of the NPPF and is supported. However, it is considered of the aim of Policy I/ST will only be fully implemented if all available opportunities to direct development to sustainable locations are taken, including additional development being directed to the edge of Cambridge.

The promoted development by North BRLOG at South West Cambridge is highly accessible by walking, cycling and public transport. There are future sustainable transport projects to the west of Cambridge i.e. Cambourne to Cambridge Public Transport Corridor, Comberton Greenway and Barton Greenway that the site would be well related to and could support. The site is accessible to the wide range of services and facilities available in the City Centre. It is well-related to the current and future employment opportunities at West Cambridge and North West Cambridge, and to other employment opportunities available in the City, which will enable more residents to live closer to where they work. It is considered that the promoted development at South West Cambridge is an example of land that should be released from the Green Belt through the emerging GCLP in order to reduce travel distances and respond to climate change.

Therefore, additional allocations on the edge of Cambridge, including at the promoted development at South West Cambridge, would be consistent with the aims of Policy I/ST.

Requested Change

It is requested that the promoted development by North BRLOG at South West Cambridge is allocated for an urban extension, in order to support the aims of Policy I/ST e.g. reduce transport emissions, reduce the need to travel, and encourage the use of sustainable modes of transport.

1) Policies in the Local Plan must protect existing walking and cycle routes from being harmed by development, both during construction and after completion of the development. Where works to the highway cut through an active travel route and degrade its quality or accessibility, it must be fixed. Landowners, leaseholders or statutory undertakers must not be allowed to install barriers or obstacles into cycle routes such as fences, poles or electric charging infrastructure.
2) The cycling network is just as strategic as the public highway network and must be protected in the same way. Transport Assessments and Travel Plans should include commitments to clean, clear, de-ice and maintain the safety, usability and accessibility of walking and cycling routes.

This sentence needs expanding in more specific terms:

“Innovative and flexible solutions will be sought to internalising trips and reducing vehicle use, including through measures such as digital infrastructure and last mile deliveries.”

– “internalising trips” is about locating more amenities – for work, education, retail, leisure, sport, culture and health – within a comfortable walking or cycling distance of people’s homes. This is more commonly referred to as designing 15- or 20-minute neighbourhoods.
– “digital infrastructure” is about installing reliable high-speed broadband into all homes, businesses, schools and co-working spaces.
– “last mile deliveries” is about providing a hierarchy of break-out/consolidation depots to enable efficient movement of goods to and from homes and businesses. These will also provide collection points for private individuals, so that they do not have to be at home to accept a delivery.

The evidence base for this policy includes a Transport Evidence Report. This sets out to model the travel demand that will derive from the build-out of the Preferred Option. It also seeks to model the modal shares for trips in 2041. There appear to be some errors in the report, which we have reported separately. These need to be corrected and any modelling connected with those errors checked.

There are two areas of grave concern:
1. The modelling assumes that motor traffic will continue to grow from the 2015 baseline, contravening an objective of the Greater Cambridge Partnership and a key recommendation of the Cambridgeshire and Peterborough Independent Climate Commission.
2. The modelling also assumes a huge growth in use of Park & Ride, creating a very substantial amount of land which is not allocated in the draft Local Plan.

*Traffic growth*
The Transport Evidence Report quotes modelling that has the following changes relative to a 2015 baseline:
– 19.5% increase in trips by car in 2041 based on current Local Plan commitments.
– 23% increase when new developments in the draft Local Plan are also included.
– 27% increase if and when all land allocated in this plan is built out.

This contrasts with local authority commitments to reduce traffic:
– The Greater Cambridge Partnership aims to “reduce city traffic flows by 10–15%” on 2011 levels, which equates to a 17.7–22.2% reduction on 2015 levels
– Cambridgeshire and Peterborough Combined Authority supports “action to reduce car miles driven by 15% to 2030 relative to baseline,” as recommended by the Cambridgeshire and Peterborough Independent Climate Commission.

Furthermore, the government’s Decarbonising Transport strategy states (on p53), “By 2030, we will aim to have half of all journeys in towns and cities cycled or walked.”

This Local Plan must therefore not only restrain growth in motor vehicle trips, it must contribute to a significant reduction in trips and mileage. The modelling indicates that it will do neither.

There is no doubting the scale and difficulty of the challenge, but it is no answer to the climate crisis to pursue policies that further deepen it. Nor can it be left to the Local Transport and Connectivity Plan to do all the heavy lifting.

*Park & Ride*
The Transport Evidence Report assumes a 245% increase in usage of Park & Ride car parks for onward journeys into Cambridge by bus, cycling or walking. In fact, the 2015 base usage of Park & Ride is almost certainly lower than the modelling assumes, since the daily trip quantity implies around 8,800 parking spaces*, when only 6,743 were available in 2015.

In absolute numbers, the Transport Evidence Report assumes that there will be 60,846 car trips to and from Park & Ride sites in 2041, even if all currently planned, but not yet committed, transport measures are implemented. This equates to around 30,400 parking spaces*, compared with just over 7,000 now. The GCP plan to add another 7,000 at:
– Foxton (200)
– Hauxton (2,150)
– Babraham (2,000)
– Madingley (2,000)
– Longstanton (650)

There are no published plans for any more P&R car parks, though there is an indication on some GCP maps of a site at Barton. There is therefore a shortfall of somewhere in the region of 16,000 parking spaces. That is more than double the number of spaces currently available. Even at a compact land allocation of 3.5 hectares per 1,000 parking bays, there is an implied requirement for nearly 60 hectares of greenfield land for car parks and access roads.

Where will these new Park & Rides be located? How many sites will be in the Green Belt? What will be the trip generation characteristics of more Park & Rides for congestion and air quality in South Cambridgeshire villages?
Park & Ride bus services abstract passengers from rural bus services, which leads to a reduction in rural service quality. This has public funding implications and equality impacts for those who do not have access to a car – for instance under-17s, many disabled people, and a large proportion of the poorest households.

*Travel hubs*
Travel hubs are mentioned in the draft policy. Their function and conceptual design need to be explained, especially as the term is now being used inaccurately by the Greater Cambridge Partnership to refer to 2,000-space Park & Rides.

In essence, travel hubs are small railway or bus stations, served by trains and/or express bus services to major local destinations (e.g. Cambridge city centre, Cambridge Biomedical Campus, and railway stations). Those services would normally run frequently from early morning (before 6am) to late evening (at least 11pm).

Travel hubs are connected to the surrounding settlements, workplaces and other amenities by safe and convenient non-motorised user paths. They also include space for feeder and demand-responsive bus services to call in, enabling passengers to transfer to/from rail and express bus services; and a pick-up/drop-off zone for taxis and private vehicles. They would normally have an enclosed waiting area and toilets. They may also have some car parking, but this should be determined at a local level (e.g. by the parish council).

Travel hub car parks, where provided, may also be used for other purposes, including farmers’ and craft markets, and mobile services (e.g. public library and health screening). A travel hub may be co-located with a school (more usually secondary or further education college), health centre, co-working offices, shops, a delivery collection point, and/or other amenities.

*Rail*
Because of the geometric constraints applying to railway infrastructure, it is important that the Local Plan provides some protection for land that could plausibly be used for a railway line or station.
Potential sites for stations include:
– Fulbourn Hospital
– Six Mile Bottom
– Cambridge airport site (Cambridge East station)
– Little Shelford
– Due west of Sawston
– Between Comberton and Toft (East West Rail line)
– Little Thetford

Potential alignments for railways (heavy or light) include:
– Chord linking the western part of the Newmarket line to the Soham line
– Coldhams Lane to east of Fulbourn, via airport site and between Cherry Hinton and Teversham
– Southern Guided Busway to Girton Interchange via Cambridge station square, city centre and West Cambridge (potentially with some central sections and stations underground)
– Haverhill to Stapleford
– Haverhill to Saffron Walden, continuing to West Anglia line

*Road*
The Local Plan should provide some protection for land that could plausibly be used for new or re-routed roads, including:
– Link slips between A14 west and A11
– Link slips between M11 north and A11
– Link slips between A428 and M11
– Link slips between A428 and A1307
– Link between Airport Way and new A14 west-only junction at Lower Fen Drove Way, replacing Junction 34 (Horningsea Rd)
– Harston southern bypass (A10) between Foxton and London Rd, Harston, to the south of the railway line

*Non-motorised user tracks*
Creating a dense network of safe non-motorised user routes is key to creating 15/20-minute neighbourhoods (where most amenities people need to access regularly are within a 15/20-minute walk or cycle ride). The Local Plan should provide some protection for land that could plausibly be used for new non-motorised user tracks, especially where route choices are most limited, including:
– cut-throughs in built-up areas, especially when linking residential areas to local amenities;
– grade-separated crossings of railways and major roads (bridge or underpass);
– bridges over rivers;
– causeways over flood zones;

*Sequencing*
Absolutely critical to promoting sustainable travel behaviours is having safe and attractive options available to people at the time that they move house, start a new job or start at a new school. If the only safe and convenient option is to drive, driving will be the default choice for all trips even when alternatives become available later.
Therefore, no development should be occupied until the full range of active and public transport options planned are available to use. Delayed opening or temporary closures of walking and cycling routes should not be accepted during the build-out after first-occupation. Public transport provision may start as a demand-responsive service to local travel hubs, connecting with rail and/or express bus services, provided it offers the same level of availability as a scheduled service at peak times.

If it is determined that, for instance, Net Zero targets for transport can only be met with large mode-shares for rail-based transport from new settlements or to new employment centres, then the infrastructure and services must be in place and operating before homes and offices or labs are occupied. This would apply to East West Rail or to any light rail (or other mass transit) network planned for Greater Cambridge.

*Levelling up*
Most of Greater Cambridge lacks the quality of transport infrastructure and services that local plans aim to provide for new developments. The new Local Plan needs to include a ‘levelling up’ policy to draw planning gain from new developments, match-funded where possible, to retrofit infrastructure that is missing from areas where planning gain would not normally reach. Interventions required for existing communities include:
– pavements that adhere to modern design standards;
– protected cycle lanes;
– renewal of degraded infrastructure, including footways, cycle tracks and lighting (for which cyclical maintenance funding is no long adequate);
– secure on-street cycle parking;
– new cut-throughs to open up safer and more direct walking and cycling routes.

*The assumed ratio of usage to capacity is two trips to one parking space. Usage can exceed the static capacity of a car park as there will be some turnover during the course of a day (i.e. one parking space may be occupied by two cars at different times, generating four trips to and from the site). However, that is likely to be more than offset by underuse on some or all days. Usage tends to self-regulate at around 85% because that is when people perceive the car park to be full.

We support the general approach to Policy I/ST. There is a need to ensure new development is integrated into the existing facilities and services as well as seemless connectivity to the existing transport and community networks. Public Transport contributions need to be used effectively and have a long term impact on the connectivity of place. Sustainable deliveries (cargo bikes) should be included in policy and associated design and space requirements, particularly for cycle infrastructure and capacity.

Existing and new communities need to be integrated with public and active transport routes across Local Plan area and beyond, in order to build a strong economy and ensure access to jobs, education, training, and deliver wellbeing, through access to the natural and historic environment, including green space. Provision for low carbon, electric vehicles is also important.

The Combined Authority is currently revising its Local Transport and Connectivity Plan. That includes consultation on the same themes of sustainable transport and connectivity as set out in this section of the Local Plan. Subject to the outcome of consultation on the LTCP there is likely to be alignment on those between the two Plans, and the Combined Authority will continue to engage with the Councils (and vice versa) to ensure alignment of policies.

Shepreth Parish Council (SPC) would prefer to see EWR approaching Cambridge from the north.

Infrastructure policies
86. CPRE are very concerned about current infrastructure proposals for the Cambridge region and the damage and cost they are likely to cause.
87. CPRE strongly opposes the proposed move of the existing Cambridge Waste Water Treatment plant from
its current location into the Green Belt. Anglian Water claim in their submission to the Planning
Inspectorate requesting a Scoping Opinion that it is local planning authority pressure for the developments
in North East Cambridge which is forcing the move. However, in the Scoping Opinion for the proposed
relocation prepared by the Planning Inspectorate, on page 6 of Appendix 2, the Shared Planning Service
response states: “We would like to clarify that the relocation of the Cambridge WWTP is not a
“requirement” of the North-East Cambridge Area Action Plan and must not be referred to as such. This is
because we are not requiring the relocation, but the NEC AAP7 and the emerging joint Local Plan have
identified the opportunity that the relocation creates for homes and jobs in the North-East Cambridge
area.” So, we can only assume that the North East Area Action Plan can be progressed without the
financially and environmentally costly move of the WWTP. This is very welcome news.
88. CPRE believes that the current local government structure in Cambridge and South Cambridgeshire with
four different authorities claiming responsibility for some aspects of transport planning and delivery,
coupled with the divided responsibility for rail infrastructure between Network Rail and East West Rail
Company Ltd, prevents any form of joined-up thinking about transport.
89. CPRE believes that all public transport planning in the county should be practically and actually brought
under the control of the Combined Authority with delivery by the County Council, National Highways and
Network Rail as appropriate.
90. CPRE are particularly concerned by the activities of the unelected Greater Cambridge Partnership (GCP). Its
proposed busways will be a disaster for the countryside and communities and an expensive duplication of
facilities that could be provided by road and rail using mostly existing infrastructure. The responsibilities of
this body should be re-allocated to those identified in paragraph 89 above in order that the GCP can be
disbanded.
91. CPRE are concerned that East-West Rail has failed to consider local transport needs in its planning and as a
consequence is currently following a route in Cambridgeshire and Bedfordshire which will maximise
damage to the countryside, deliver the least useful local transport facility and not integrate well with the
main rail network. Local MPs have taken up this case with government but so far to no avail. The danger is
that the Treasury will halt the project because of lack of return on investment and Cambridge will be left
without the core of what could have been a climate-friendly metro service.
92. There is a desperate need for an integrated transport plan for the whole county and the current approach
will not realise one.
93. CPRE supports Policy I/DI: Digital infrastructure.

Thank you for consulting Historic England on the First Proposals Public Consultation for the Greater Cambridge Local Plan. As the Government’s adviser on the historic environment Historic England is keen to ensure that the protection of the historic environment is fully considered at all stages and levels of the local planning process.

Cambridge is a beautiful, compact and historic city. It is also an historic seat of learning with a very high concentration of highly graded heritage assets. Much of the city is covered by Conservation Area status. The river corridor, green fingers and open spaces, with cows grazing in meadows even at the heart of the city, shape the character of the townscape and landscape.

Although a relatively flat landscape, the elevated positions to the west and south of the Cambridge afford important views across the city skyline, which is one of extensive tree cover and emerging spires. The flatter Fens landscape to the north and east provides very long-distance views of the City and the big east Anglian skies.

The surrounding rural hinterland of South Cambridgeshire comprises over 100 villages, each with their own unique character and heritage. New settlements are an important feature of the district, with their own special identity and are growing rapidly.

We recognise the area faces intense pressure for growth, driven by both the economic success and the attractiveness of the area, in large part a consequence of

its rich architectural and cultural heritage. This growth must be carefully managed to ensure that the very things that contribute to its success are not harmed in the process.

It is for this reason that Historic England is keen to ensure that the emerging plan gives full consideration to the historic environment, both in the choice of site allocations and policy criteria for sites, as well as through a robust and clear suite of historic environment and other policies that seek to both protect but also enhance the historic environment.

We have reviewed the Draft Plan and consultation material with a view to providing advice on heritage matters.

As a general comment, Historic England welcomes emerging plan and work undertaken to date. We have however identified below some of the key issues to be addressed in progressing the next iteration of the Plan: This should be read in conjunction with Appendix A which provides more detailed comments on these and other more minor issues.

a) Site Assessment and the need for Heritage Impact Assessments

We are pleased to note that a degree of site assessment has already been undertaken in relation to the historic environment. These are set out in the HELAA Report, especially Appendix 4.

To date, the assessment of sites is fairly high level and brief but provides a useful starting point, in particular helping to identify immediate showstoppers. We note that many of the sites are shown as amber.

As we have discussed previously, the need for further assessment of heritage in terms of significance, impact on that significance, potential mitigation and enhancements etc will be needed for the site allocations. There is currently an insufficient evidence base in this regard. We therefore welcome your commitment to undertake Heritage Impact Assessments for site allocations. These should be prepared prior to the next draft of the Local Plan.

This further assessment, known as Heritage Impact Assessment (HIA) should follow the 5 step methodology set out in out in our advice note, HEAN 3 on Site Allocations in Local Plans https://historicengland.org.uk/images- books/publications/historic-environment-and-site-allocations-in-local-plans/.

HIAs should be proportionate (both to the scale of the site and the assets affected). All potential sites will need to be appraised against potential historic environment

impacts. It is imperative to have this robust evidence base in place to ensure the soundness of the Plan. We recommend that the appraisal approach should avoid merely limiting assessment of impact on a heritage asset to its distance from, or inter-visibility with, a potential site.

Site allocations which include a heritage asset (for example a site within a Conservation Area) may offer opportunities for enhancement and tackling heritage at risk, while conversely, an allocation at a considerable distance away from a heritage asset may cause harm to its significance, rendering the site unsuitable.

Impacts on significance are not just based on distance or visual impacts, and assessment requires a careful judgment based on site visits and the available evidence base. Cumulative effects of site options on the historic environment should be considered too.

The following broad steps might be of assistance in terms of assessing sites:

• Identify the heritage assets on or within the vicinity of the potential site allocation at an appropriate scale
• Assess the contribution of the site to the significance of heritage assets on or within its vicinity
• Identify the potential impacts of development upon the significance of heritage asset
• Consider how any harm might be removed or reduced, including reasonable alternatives sites
• Consider how any enhancements could be achieved and maximised
• Consider and set out the public benefits where harm cannot be removed or reduced

The HIAs should assess the suitability of each area for development and the impact on the historic environment. Should the HIA conclude that development in the area could be acceptable and the site be allocated, the findings of the HIA should inform the Local Plan policy including development criteria and a strategy diagram which expresses the development criteria in diagrammatic form.

Which sites require HIA?

Ideally all sites should have an HIA, albeit proportionate to the site and heritage sensitivities.

For existing allocations being carried forward into this Local Plan, the HIA is less about the principle of development (that has already been established through previous plan allocation) and more about exploring capacity, height, density and any heritage mitigation and enhancement opportunities so that these can then be

included in the updated policy wording.

For new allocations, the HIA will be a more holistic view and consider both the principle of development as well as the other matters identified above.

b) Policy Wording for sites

If, having completed the heritage impact assessments, it is concluded that a site is suitable for allocation, we would remind you to include appropriate policy criteria for the historic environment in the policy. Please refer to the advice we give on policy wording in the attached table.

It can be helpful to refer to an HIA in the policy wording. Concept diagrams can also be useful to include in the plan to illustrate key site considerations/ recommendations.

c) Edge of Cambridge sites

The Plan proposes carrying forward a number of partially built out allocations on the edge of the City as well as some minor extensions to these. The Plan also proposes revisiting the dwelling capacity/density for some of these sites e.g. Eddington.

Proposals for North East Cambridge are very high density and also quite tall.

The Plan also includes a very large new allocation at East Cambridge (previously released from the Green Belt and allocated in the 2006 Plan, although not in the 2018 Plan). The number of dwellings now being proposed represents a significant increase in density from the 2006 Plan.

We have some concerns regarding these densities and heights on edge of Cambridge sites. Development at very high densities/heights and the potential impact on the overall setting of this historic city. HIAs should give careful consideration to the issue of development and site capacity and height – we will be looking for evidence in this regard.

d) Historic Environment Policy

We welcome your intention to include a policy for the Historic Environment. This should cover both designated and non-designated heritage assets. Policy wording should be in line with the NPPF but we are also looking for a local flavour.

Policies should be spatially specific, unique to the area, describing the local characteristics of the area and responding accordingly with policies that address the local situation.

You should also include a policy for Heritage at Risk and a policy for historic shopfronts. For further detail see Appendix A.

e) Design Policy

We welcome the proposals for a design policy on the plan. We note that this policy is also intended to address tall buildings. We are concerned that the policy might become overly long and detailed, given it is covering such a wide and important range of issues and wonder whether separating out tall buildings into a separate policy might be helpful?

f) Tall Buildings Study and Policy

Related to the above, given the growth pressures that we would anticipate Cambridge is likely to experience over the coming years, we are pleased to see that the matter of Tall buildings and the skyline will be addressed in policy.

We had understood that you were commissioning a study in relation to tall buildings and the skyline policy. Is this still proposed to inform the policy in the next draft of the Local Plan?

See our advice note HEAN 4 and the consultation draft of HEAN 4. Any policy should indicate what considerations are needed for taller buildings, where buildings may or may not be appropriate etc. and in particular consider in the impact on the historic environment.

We broadly welcome policy 60 and Appendix F of the 2018 Cambridge City Local Plan. However, we consider that this could be further supplemented to indicate which areas may or may not be suited to taller buildings. Our advice note in relation to tall buildings provides further guidance in this respect

We have been having discussions with the team preparing The North East Area Action Plan in relation to tall buildings studies and have provided a detailed advice letter in that regard. Please refer to our advice letters in relation to NEA Action Plan and tall buildings for further information on our position.

g) Other Supporting Evidence

We welcome the preparation of the HELAA although consider that further, more detailed evidence is needed in relation to heritage impact and so welcome your intention to prepare HIAs for site allocations.

We broadly welcome the Strategic Heritage Impact Assessment including the baseline study of the setting of Cambridge. However, we have expressed some concerns regarding some aspects of this baseline, in particular the weighting given to some of the key characteristics and aspects of setting of Cambridge including views. Further detail is given in Appendix A.

We welcome the evidence in relation to landscape character assessment. We do however continue to suggest that it would also be helpful to commission Historic Landscape Characterisation work for inform this Plan and future growth in the area.

We welcome the production of the Sustainability Appraisal. We would comment however that since many of the site allocations are grouping together under particular policies, the different impacts for individual sites are not always drawn out in the assessment tables – this sometimes has the effect of neutralising the scoring.

Historic England – Ox Cam research work

Historic England has commissioned consultants to undertake some work looking at development in the OxCam Arc. ‘Measuring Impact: Managing Change’ looks at the question, ‘How should the form of growth in the Oxford-Cambridge arc positively respond to the Historic Environment’. This research is due to report in the next few months and we hope to be able to share this with you at that time as it may provide useful evidence to inform your Local Plan work.

Other comments

In preparation of the forthcoming Greater Cambridge Local Plan, we encourage you to draw on the knowledge of local conservation officers, archaeologists and local heritage groups.

Please note that absence of a comment on an allocation or document in this letter does not mean that Historic England is content that the allocation or document forms part of a positive strategy for the conservation and enjoyment of the historic environment or is devoid of historic environment issues. Where there are various options proposed for a settlement, identification of heritage issues for a particular

allocation does not automatically correspond to the support for inclusion of the alternative sites, given we have not been able to assess all of the sites.

Finally, we should like to stress that this opinion is based on the information provided by the Council in its consultation. To avoid any doubt, this does not affect our obligation to provide further advice and, potentially, object to specific proposals, which may subsequently arise where we consider that these would have an adverse effect upon the historic environment.

We trust that these comments are helpful to you in developing the Local Plan. Should you have any queries, please do not hesitate to contact us.

We suggest it might be helpful to set up a meeting to discuss our comments and, in particular, heritage impact assessments and policy wording for site allocations.
Please feel free to suggest some dates.

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

This is a summary of comments received.

Policy I/ST: Sustainable transport and connectivity proposes that “New developments should be designed around the principles of walkable neighbourhoods and healthy towns to encourage active sustainable travel; the policy will ensure priority is given to people over vehicular traffic (with low speeds), to make journeys by walking and cycling more direct and convenient than by car.”
Whilst I support this imaginative policy, it will be important to avoid unintended consequences by including local residents in discussion of specific proposals, particularly the ways in which vehicles and people can interact at low speeds. Currently there is no mention of the elderly and disabled in relation to design of transport routes. Will disability scooters and blue badge holders be automatically consulted on each development?
“Additional guidance for developers on the quality of provision is being prepared in an Active Travel Toolkit. Improvements will include enhancements to existing routes to break down barriers to use and improve safety and capacity as well as providing high quality new routes to improve connections to nearby communities, services and facilities.”
Please could the “Active Travel Toolkit” be available for consultation prior to publication? “Breaking down barriers to use” can create major safety issues in relation to sharing e.g. cycles/ pedestrians and cycles/cars on the Fendon Road roundabout. If car users had been consulted at the design stage, they would have been able to point to the multiple blind spots and prevented tall plants being planted obscuring driver’s vision of the cycle paths.

Need to add electrification - non diesel - zero carbon policy to this.

Comments from Cottenham Parish Council:

Policy S/DC - Welcome the Councils’ strategy for development.

Policy S/DC - Support the allocation of 10% more housing than required by the standard test to avoid unplanned development as happened in Cottenham (an extra 500 houses now being built in unplanned locations as a result of speculative development) while waiting for the adoption of the 2018 South Cambridge District Plan.

Policy S/RRA - Support the allocation of the Old Highways Depot site for economic development, subject to protection of view of the church.

Policy I/ST - Look forward to an integrated approach between SCDC and CCC Highways for the development and delivery of integrated sustainable transportation for pedestrian, cyclists and vehicle users.

Policy I/ST and Policy S/RRA - Look forward to more consideration of the sustainable transport in the rest of the rural area, including bus and cycle links to rail hubs such as Waterbeach and Cambridge North, improved direct bus access to Cambridge from existing centres and generally better cycling connectivity. Including reinstatement of the Citi8 bus continuing to the northern end (Church) of the village and incorporating a bus turning area in the Voland Ind Est development area. Resolution That the proposed comments are submitted to the Greater Cambridge Partnership as Cottenham Parish Council’s response to the First Proposals. Passed at CPC Full Council meeting on 7th December 2021.

Policy CC/FM - Look forward to co-operation between SCDC and CCC on sustainable drainage solutions so that developments along the East West Rail arc do not impact on the Independent Drainage Board areas and Cottenham Lode in particular and consideration to take varying infiltration rates to accommodate the impact of climate change.

Critically important.

Thank you for consulting Suffolk County Council (SCC) on the First Proposals Local Plan.

As a neighbouring authority SCC’s response will focus subjects and issues relevant across administrative boundaries. To date SCC have been included in discussions relating to the plan as part of the duty-to-cooperate. This is welcome and SCC will continue to participate in discussions with Greater Cambridgeshire as required alongside other Suffolk authorities.

Spatial Options and Chosen Distribution

It is clear that a wide range of spatial options have been tested. The chosen option is to aid in achieving both South Cambridgeshire District and Cambridge City Councils net zero carbon ambitions, particularly relating to transport, by locating homes, employment and services near to one another. Suffolk local authorities have similar net zero ambitions and support this approach. The chosen distribution, focusing additional areas of development largely in close proximity to Cambridge City, is also the least likely to impact on infrastructure within Suffolk.

Transport Links

Enabling transport across administrative boundaries should be an aim of local plans and a significant number of trips to into Cambridgeshire originate in Suffolk. It is noted that figure11 in the plan identifies some of the key transport links within the plan area and beyond. The inclusion of future improved rail links from Ipswich, via Bury St Edmunds and Newmarket is welcome. In the emerging strategy from Transport East1 the corridor between Ipswich and Cambridge, which of course consists the railway line and A14, is identified as strategically important regionally and nationally. It is also recommended that the dualling of the rail link to Newmarket is included in the infrastructure delivery plan.

Reference to improved bus services between Haverhill and Cambridge in the Infrastructure Delivery Plan is welcome. SCC are currently developing a bus improvement strategy as part of Bus Back Better and aspire to improve bus between Newmarket, Bury St Edmunds and Cambridge, as well as connecting villages outside of Suffolk, but where residents use services in Suffolk towns, such as Newmarket or Haverhill. SCC will need to work with operators and the Cambridgeshire and Peterborough Combined Authority to achieve this. However, the local plan can assist by ensuring that transport policies explicitly support the provision of public transport measures which cross administrative boundaries.

Planning Obligations and Mitigating Impacts




1 https://www.transporteast.org.uk/public-consultation/

As mentioned previously, it is not expected that the chosen distribution will create significant impacts on infrastructure in Suffolk. Regardless, policies in the plan relating to use of planning obligations to mitigate impacts of development should ensure that planning obligations can be used to mitigate impacts in neighbouring authorities, where the evidence identifies this is taking place. Related to this, policies which require site assessments should express that assessments of impacts (e.g. transport assessments) should also account for the impacts across boundaries where this is relevant.

For example, rural communities in Suffolk around Haverhill, particularly along the A1307, are reporting increased volumes and speed of traffic and reporting rat running. Some of which was associated with the development of housing in South Cambridgeshire, which illustrates the need for the plan to address cross boundary impacts.

In relation to the specific issue of A1207 communities, SCC officers recently met with a Villages Working Group, formed to address these issues, and understand the group and the Greater Cambridgeshire Partnership have corresponded with one another. SCC would encourage the Greater Cambridgeshire Partnership to continue engaging with this group, SCC and other relevant community groups where cross boundary impacts result from growth in Cambridge and South Cambridgeshire.

Green Infrastructure

Green infrastructure appears to be extensively mapped in the plan and broad areas for projects identified. Green infrastructure is also a relevant cross boundary matter as ecosystems do not stop at administrative boundaries. Development management policies of the plan should enable the development of green infrastructure across boundaries where relevant.

It is also recommended that the plan takes a positive stance towards contributing to the aims of statutory Nature Recovery Strategies established by the Environment Act 2021. While we are still awaiting secondary legislation to specify the details of the contents of these strategies, planning policies could still take a positive stance towards them pre-emptively.

Other Comments

SCC is currently in the process of reviewing its Lorry Route Plan2. This includes the A14 as a Strategic Route, but also includes routes through and around Haverhill and into South Cambridgeshire.

The SCC Green Access Strategy (Rights of Way Improvement Plan) sets out the Council’s approach to improving the rights of way network within Suffolk. We would welcome joint working to improve cross boundary rights of way connections.

I hope that these comments are helpful. SCC is always willing to discuss issues or queries you may have and you may contact us using the information at the top of this letter.

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

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

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

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

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

mitigated.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

FORM RESPONSE

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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.

NORTH-EAST CAMBRIDGE ‘CORE SITE’, COWLEY ROAD,
CAMBRIDGE


GREATER CAMBRIDGE LOCAL PLAN 'FIRST PROPOSALS' (REG 18)

Written Response on behalf of U&I PLC / TOWN

Monday, 13 December 2021


Classification L2 - Business Data



CONTENTS




0.0 INTRODUCTION 1
1.0 POLICY RESPONSE 2


0.0 INTRODUCTION

0.1 This document sets out written representations on behalf of U+I / TOWN, to a formal consultation by Greater Cambridge Shared Planning Services (‘GCSP’) on the Greater Cambridge Local Plan ‘First Proposals’ (Preferred Options, Regulation 18, 2021) (‘First Proposals’).
0.2 U+I and TOWN have been selected by Anglian Water and Cambridge City Council (as landowners) to act as Master Developer for the comprehensive redevelopment of the existing Waste Water Treatment Works (‘WWTW’), council depot and golf driving range (to be referred collectively as ‘the Core Site’), for the delivery of approximately 5,500 homes, 23,500m2 of new business space, 13,600m2 of new shops, community, leisure and recreation space (as currently set out in the North East Cambridge Area Action Plan (‘NEC AAP’) Proposed Submission Regulation 19 document). For the avoidance of doubt, these representations are submitted on behalf of U+I and TOWN as master developers rather than the landowners themselves.

0.3 Regeneration of the Core Site will be facilitated by the relocation of the WWTW, which will be funded from the Homes England’s Housing Infrastructure Fund, and which is currently going through a Development Consent Order approval process. Anglian Water will be submitting separate representations to the First Proposals, on this specific element.

0.4 U+I/TOWN have been actively involved in the policy formation process of the NEC AAP and are therefore looking to ensure there is policy consistency between the NEC AAP Proposed Submission and First Proposals documents.

0.5 Consideration will need to be given to the prospect of policy inconsistencies between the Greater Cambridge Local Plan (‘GCLP’) and NEC AAP.

0.6 As a point of broad principle, we would request that relevant GCLP policy (particularly where performance standards are stated) provides appropriate wording that defers to more area/site-specific policy, where it is being formed in other Development Plan Documents, such as NEC AAP. In the event of any inconsistency, this will ensure that there is a clear understanding over which policy takes preference. For instance, if a 20% biodiversity net gain (‘BNG’) target is ultimately adopted in GCLP policy, and a minimum 10% BNG is sought in NEC AAP, then there would be a clear signal in the GCLP policy that the NEC AAP policy is the correct standard to apply.



1.0 POLICY RESPONSE

Policy S/JH: Level of Jobs and Housing
OBJECT
1.1 The Cambridgeshire and Peterborough Devolution Deal committed to delivering substantial economic growth and to double economic output during the next 25 years. The Cambridge and Peterborough Combined Authority and the Greater Cambridge Greater Peterborough Enterprise Partnership acknowledge and support the economic growth potential of the Greater Cambridge area and consider that there is a need to substantially increase housing delivery in order to support economic growth (that is needed to meet the objective of doubling GVA by 2040) and address the significant housing affordability issues that exist (Cambridgeshire and Peterborough Independent Economic Review). At present there is an imbalance between rates of economic growth and housing delivery in Greater Cambridge.
1.2 These factors support a significantly higher number of homes than are proposed in the preferred ‘medium plus’ growth option of Policy S/JH. It is considered that the ‘medium plus’ growth option makes insufficient upward adjustments to the housing requirement (from Section Id.2a of the Planning Practice Guidance) to take into account growth strategies, strategic infrastructure improvements and housing affordability in Greater Cambridge.
1.3 It is suggested that the emerging GCLP should have selected the higher growth level option to support economic growth, address housing affordability, and reduce in-commuting. A higher growth level option would be consistent with the Government’s aspirations for the Oxford to Cambridge Arc.
1.4 It is requested that housing and jobs requirements in Policy S/JH are based on delivering the higher growth level option.


Policy S/DS: Development Strategy

SUPPORT

1.5 We broadly support this approach, given that it identifies North-East Cambridge for the creation of new compact city district on brownfield land, noting that it has already been identified for homes and jobs growth.
1.6 However, we are extremely concerned by the ‘Homes’ target for NEC that is stated in the table on page 32, which refers to 3,900 homes between 2020 and 2041. Fundamentally, this is at odds to the trajectory that has been agreed with Homes England as a pre-requisite for the substantial public funding that has been agreed in principle to relocate the WWTW.
1.7 We would therefore instead support a policy that recognises 5,600 homes will be provided on the Core Site by 2041. Consideration will also then need to be given to other housing that is expected to come forward within the NEC AAP.



Policy S/NEC: North-East Cambridge

SUPPORT

1.8 We support this approach but would request that GCLP policy for S/NEC is entirely consistent with NEC AAP. A simple policy that specifies reference to NEC AAP will enable GCLP policy to remain up to date, as and when changes are made through the examination and adoption process.
1.9 We would note that Policy 1 of the NEC AAP Proposed Submission states ‘approximately 8,350 new homes, 15,000 new jobs’, as opposed to ‘up to’ as set out in S/NEC.
1.10 S/NEC policy should therefore be amended to refer to ‘approximately’ and provide a clearer link to NEC AAP.


Policy BG/BG: Biodiversity and Geodiversity

OBJECT

1.11 The policy wording suggests that there will be a requirement for development to achieve a minimum 20% biodiversity net gain, which has been based on the South Cambridgeshire District Council Doubling Nature Strategy (2021), the draft Cambridge City Council Biodiversity Strategy 2021 – 2030, and the Oxford-Cambridge Arc Environment Principles (2021).
The Environment Act 2021, however, states that a minimum of 10% Biodiversity Net Gain should be achieved, and specifies the three forms for doing so:

- Post-development biodiversity value of the onsite habitat;

- the biodiversity value, in relation to the development, of any registered offsite biodiversity gain allocated to the development;

- the biodiversity value of any biodiversity credits purchased for the development;

1.12 Whilst U+I/TOWN recognise the importance in providing significant biodiversity improvements through development, it is considered that the mandatory minimum limit should reflect the legislative target. However, policy could still actively encourage schemes to exceed the minimum, recognising that those that do will be considered as a planning ‘benefit’ of development in sustainability terms (the greater the increase, the greater the weight attached to the assessment of benefit in any planning balance).
1.13 In terms of implications for the Core Site in North-East Cambridge, the NEC Ecology Study (2020) recommended that a target for a net gain of 10% is applied for all developments within NEC. Where this is not achievable within the site boundary then offsite measures should be provisioned.
1.14 By way illustration, a 20% gain to the 36.76 biodiversity units that have been identified in the Ecology Study would result in the need to achieve 44.112 biodiversity credits, in order to satisfy policy requirements. This seems highly ambitious, given the level of density that will need to be achieved across the Core Site to meet NEC strategy objectives. We will continue to make representations on this point as the NEC AAP progresses. GCSP must also consider alternatives to on-site provision where the necessary biodiversity net gain cannot be achieved on site. This could include a range of options including biodiversity net gain ‘credits’ being able to be purchased from other sites.



1.15 Ultimately, the aim of BNG is to leave the natural environment in a measurably better condition than beforehand. Therefore, if it can be robustly demonstrated that on-site provision is not achievable, the opportunity to measurably improve the natural environment of other appropriate receptor sites through off-site provision should still have a significant value attached to it.

Policy WS/HD: Creating Healthy New Developments

SUPPORT

1.16 We broadly support the 10 principles for creating healthy places. The vision for North-East Cambridge is of a healthy, inclusive, walkable, low-carbon new city district with a vibrant mix of high quality homes, workplaces, services and social spaces, fully integrated with surrounding neighbourhoods.
1.17 One of the five strategic objectives of the NEC AAP is for a healthy and safe neighbourhood and notes the principles of the Health New Towns programme.

Policy WS/MU: Meanwhile Uses During Long Term redevelopments

SUPPORT

1.18 We support the inclusion of a Meanwhile Use policy and agree that it can play an important role on strategic development sites. Phases of development can occur over a significant period of time, and therefore utilisation of vacant/redundant land/buildings for social and/or economic purposes can help activate an area and provide short/medium term benefits that might not otherwise be realised.

Policy GP/LC: Protection and Enhancement of Landscape Character

COMMENT

1.19 The policy notes that ‘the edges of Cambridge and the villages are an important area of transition which require sensitive landscaping to protect the setting of the settlements and to provide a well- defined edge which respects townscape and the countryside beyond’.
1.20 The Core Site at North-East Cambridge will need to be planned to a high density in order to fully achieve the the strategic objectives of the NEC AAP, as well as to hit the quantum of development required under Homes England’s Housing & Infrastructure Fund. This will require a number of buildings that are taller than may otherwise be commonly found in the north of Cambridge (including surrounding villages, such as Milton). The masterplan for the Core Site will take great care in how its development edges interface with the landscape and setting of nearby settlements, as well as adjoining ‘bad neighbour’ uses currently in existence. The policy will need to recognise the strategic objectives of NEC AAP and avoid imposing conditions that could unreasonably restrict development.

Policy GP/QD: Achieving High Quality Development

SUPPORT



Policy GP/QP: Establishing High Quality Landscape and Public Realm

SUPPORT


Policy J/NE: New Employment Development Proposals

SUPPORT

1.21 We broadly support the intent of the policy but consider it essential that GCSP takes a more ambitious approach in seeking to capture and accommodate the substantial demand in office, R&D, lab and associated manufacturing space in the Greater Cambridge area. There is a need to provide sufficient supply in order to meet the balanced homes/jobs requirements and to reflect the high employment density and employment skills these uses engender.
1.22 The Greater Cambridge Local Plan Strategic Spatial Options Assessment (Housing and Employment Relationships Nov 2021), upon which the homes and jobs growth of the First Proposals has been based (‘Central Growth’), considered a Higher Growth option of 78,742 jobs in the Plan Period. It
noted that ‘this is a plausible but more aspirational growth outcome’. We believe that the Higher Growth option should be pursued to reflect the Combined Authority’s commitment to doubling GVA by 2040 and capitalise on the significant appetite for research/knowledge-based, commercial development in the City.

Policy J/AW: Affordable Workspace and Creative Industries

SUPPORT

Policy H/HD: Housing Density

SUPPORT

Policy H/CB: Self and Custom-build Homes

OBJECT

1.23 The concern we have with this policy is the ability for the Core Site scheme to comply with the amount of Self-build/custom build being sought, given the high-density development that is envisaged. We would seek reference in the policy to wording that reflects the relevant policy in the NEC AAP i.e. to support ‘custom-finish’ as well.


Policy I/ST: Sustainable Transport and Connectivity
SUPPORT

Water supply for the plan consultation on idea of 48,000 new households during building and completion after estimated 20 years:
a)Water to supply such a project is unsustainable. We are already in a place of deficit - the flow of the river Cam is substantially reduced due to increase in the area’s population.
. Anglia Water is driven to plan new sewage works on green belt land which was promised to not be touched - ie Green Belt.
. Any plans to “create green spaces and nature reserves in the area” would need water for plant/tree life, currently this is hard to sustain and we know drought in summer will only increase.
. Any idea that we take water from other areas of the UK is magical thinking - they will also be suffering water shortages.
. Building reservoirs in the Fens is way out as with climate crisis it is envisaged they will be flooded with salt water.

b)Ecological issues regarding development around the Biomedical Site/Addenbrookes/SCBC/A Nine wells etc - will have a negative impact on bio-diversity that will be difficult to mitigate. More loss on insect, plant & wild life bring a further loss to falling farm bird populations. It’ll be hard to irrigate the plantations.
. We need every bit of land to grow our food in order to be secure when markets for our food importation might change. We import more than 50 per cent of our needs. The area around nine-wells Trumpington etc was historically excellent for agriculture. I have knowledge of south Cambridgeshire villages and the land is a major farming area for grain.

c) We already have a need for housing for key workers and we are not organised enough to achieve this. Developers and planning is not on top of this problem. Hopefully residential development opportunity at Marshals Airport will help but that brings up the transport problem.

d) Travel south up Babraham Rd and up on the Gogs, look back on Cambridge and often one sees a grey fog - Cambridge is in a dip which one reason for pollution being so high here. We are top in the nation for traffic jams, these are pollution machines, even electric cars produce toxic emissions. We need some of the measures proposed to dissuade car use in the area. Yes, I would agree to road charges that bring a noticeable reduction in car use. There could be a badge scheme for vans that have to carry tools and equipment.

To sum up: Such growth for the sake of the economy is not what we should be looking at in this way at this time. The climate crisis, covid and other pandemics that will follow is changing our work and travel pattern. It is changing our needs regarding water and land use and "levelling up”. Also consider AI as a big factor , many of the implications are unknown.

The area is too complicatedly organised by local government divisions with no satisfactory overview. We need to work on the many existing problems (some mentioned above) first before we totally fall for the Government’s hopeful plans for the south East and the Arc that are not regarding the complications realistically.

We support the Greater Cambridge Partnership's aims to deliver 'sustainable and inclusive communities' by connecting new developments to existing transport networks. The Partnership's commitment to the improvement of Whittlesford Parkway Station will ensure that there is enhanced capacity for the projected increase in commuters both to and from Whittlesford Bridge. As such, commercial development at Whittlesford Bridge is ideally placed if the goal is to maximise public use of the improved Whittlesford Parkway Station, and there is some guarantee that the enhanced facility will be able to accommodate additional footfall generated by such developments.
We would emphasise that rail services are the most sustainable form of public transport and development should be situated in conurbations with rail connections (e.g. Whittlesford Bridge) to ensure that incoming residents can travel sustainably.

Taylor Wimpey are supportive of the approach to manage the impacts of new development on the transport network. In particular, sustainable travel should be encouraged through development, which the development of Land north of Cambridge Road, Linton would achieve.
It is also noted that the policy refers to ‘planned infrastructure schemes (such as East West Rail, improvements to the A428, and schemes planned by the Greater Cambridge Partnership and Cambridgeshire and Peterborough Combined Authority) will provide significant and wide ranging improvements for active travel modes’. As identified earlier in this report, through the Greater Cambridge Partnership the Linton Greenway is being progressed which will enhance the sustainable travel options for the village and would be of direct benefit to Land north of Cambridge Road, Linton.
A concern is however raised on part of the wording of this policy. The policy states that ‘developers will be required to contribute to improvements to public and community transport and to deliver new and improved sustainable active travel connections for non-motorised users including for equestrians appropriate to the scale and nature of the proposal.’ This policy wording suggests that all developments will be required to deliver improvements, and clarity should therefore be provided on the types and thresholds of development that would trigger this requirement.

Countryside support the proposed policy aspiration. A concern is however raised on part of the wording of this policy. The policy states that ‘developers will be required to contribute to improvements to public and community transport and to deliver new and improved sustainable active travel connections for non-motorised users including for equestrians appropriate to the scale and nature of the proposal.’ This policy wording suggests that all developments will be required to deliver improvements, and clarity should therefore be provided on the types and thresholds of development that would trigger this requirement.