STRATEGY

Shepreth Parish Council (SPC) is supportive of the vision and aims of the plan. The assumptions that underlie the supporting evidence are reasonable. It is good to see that rural identity, sustainability, infrastructure and water are all issues of significance.

I am writing to object to the Draft Local Plan on the grounds of inadequate water supply, the effect on national food security, failure to minimise climate change, likely irreparable damage to ecosystems, carbon emissions resulting from construction, lack of an integrated public transport system, undermining of the Government's policy of ‘levelling up’, and a democratic deficit in the process and evidence base .

I support the letter of objection sent to you by Friends of the Cam, available here;

https://www.friendsofthecam.org/sites/default/files/ObjectiontoNext%20LocalPlan_0.pdf

Please confirm that you have received my objection.

I am writing to object to the Draft Local Plan on the grounds of inadequate water supply, effect on national food security, failure to minimise climate change, likely irreparable damage to ecosystems, carbon emissions resulting from construction, lack of an integrated public transport system, undermining of the Government's policy of ‘levelling up’, and a democratic deficit in the process and evidence base .

I support the letter of objection sent to you by Friends of the Cam, available here;

https://www.friendsofthecam.org/sites/default/files/ObjectiontoNext%20LocalPlan_0.pdf

Please confirm that you have received my objection.

Shepreth Parish Council (SPC) supports the vision that a big decrease in climate impact can come with a big increase in the quality of everyday life.

We strongly object to the new draft Local Plan for the following reasons: our inadequate water supply, it fails to minimize climate change, it has a detrimental effect on national food security and on ecosystems. It will lead to high levels of carbon emissions from construction and the manufacture of construction materials. In addition, there is a lack of an integrated transport system, it undermines the Government policy of `leveling up’ and there is a lack of democracy in the process behind this plan and in its evidence base. We believe that the following factors will be exacerbated or caused by the high levels of development you propose. Locally we feel that certain provisos need to be added to Babraham Institute being released from the Green Belt which have not been adequately addressed in the plan.
Over-development The report “How Many Homes” by CPRE Devon, demonstrates how the ONS population projections are seriously flawed and that this is leading to over estimation of housing need in all areas of the country. Using the government’s methodology, the study demonstrates that the housing need is around 213,000 additional houses per year. The government’s target is 300,000 – a 40% overstatement. See CPRE Devon website.
https://www.cpredevon.org.uk/the-government-wants-to-build-more-than-3million-new-homes-than-are-needed/
We were dismayed at the GCP proposed levels of development so it is disturbing that our District and City councils are proposing to bring forward housing developments and build a further approximately 49,000 houses. MP Anthony Browne carried out a survey regarding the proposed developments related to the Ox-Cam Arc in South Cambs and found that a very high proportion of residents did not want further housing developments in this area and we can assume that they will also oppose the developments you propose.
The Cambridge Greenbelt is continually under attack and has already been nibbled away by the weakened Local Plan process which placed protection of the greenbelt into the hands of local planning authorities and not the Secretary of State. The Greenbelt of South Cambs will be further eroded by your proposed Local Plan eg. locally the Mingle Lane proposed development. Cambridge Greenbelt has two purposes, to stop urban sprawl and to protect the setting of the City. Further major developments around it will put the Greenbelt under even greater pressure because of the major damage being done to the essentially rural landscapes beyond the Greenbelt.
The Cambridge area has a very high level of employment so it’s not as if we need more businesses, and hence housing developments, coming to this area. We have a historical and beautiful City surrounded by picturesque villages and wonderful countryside which you should be protecting and not planning to blight with housing developments.

Inadequate water supply.
There is a lack of sustainable water supply in Cambridgeshire and the levels of development you propose will severely exacerbate this situation. The Stantec Integrated Water Management Study to the GCP showed that only the lowest level of housing provision around Cambridge was possible. This is even re-iterated in Objective 10 of your own Greater Cambridge Local Plan, Strategic Spatial Options Assessment Sustainability Appraisal (November 2020). Objective 10 Page 96 onwards, Section 3.333 especially.
https://www.greatercambridgeplanning.org/media/1393/gclp-strategic-spatial-options-assessment-sustainability-appraisal-nov2020.pdf
Any further development would put even more strain on what is already an unsustainable situation. Plans to route water from areas further north have been shown by the CPRE to be both expensive and unable to meet even GCP levels of growth and housing let alone the additional levels proposed by this plan. Indeed North Lincolnshire, one of the proposed areas to route water from, the Environment Agency has now classed as a `water stressed area.’
On 1st July, 2021 DEFRA in “Water stressed areas – final classification 2021” stated that chalk streams would be given enhanced environmental protection. On page 6 of this document it states that the supply areas of Cambridge Water and Anglian Water were areas of serious water stress. It stated that Cambridge Water needed to reduce levels of abstraction by 22 megalitres per day from levels on1st July, 2021 and Anglian Water needed to reduce abstraction levels by 189 megalitres from the same date.
In August 2020, the Environment Agency, in response to a query regarding the viability of the Northstowe Phase 3A development, replied to Ms. Hone that `current levels of abstraction are causing environmental damage. Any increase in use within existing licensed volumes will increase the pressure on a system that is already failing environmental targets…many waterbodies did not have the flow to support the ecology.’
In short, the development proposed in this Local Plan would damage our rivers, chalk streams, our ecology and our farming because we simply do not have sufficient water supplies at present, a point a previous Local Plan had made. Water supplies certainly will not support the proposed level of development and piping it in from an area that is also Water Stressed makes no sense.
Inadequate sewerage infrastructure The draft Local Plan will lead to new building when the local sewerage system is currently inadequate. This is evidenced by the reported number of sewerage spills by Anglian Water into the Cam Valley; upstream of Cambridge saw 622 hours of untreated sewerage enter the rivers in 2020. There are currently no plans to improve the sewerage system to prevent these outflows, just to monitor them more adequately. To date there have been no upgrades at small sewerage work in the area. The only work in this area is to move the one major sewerage works in the area (at Waterbeach) one that has been future proofed until 2050, to land prone to flooding at huge expense to prevent it from flooding and subsequent pollution of the area, in order to make way for a housing development. If it was to make way for a larger sewerage works this would have been sensible and might have prevented the outflow of untreated sewerage into the delicate ecosystems of our rivers.
In short, our sewerage system is inadequate and further development will put additional strain on it, increasing the risk of sewerage outflows into rivers.


Threat to National Food Security
Any further development around Cambridge, will necessarily take scarce grade 2 and 3a land out of production. Developments in Fen land will deprive us of grade 1 agricultural land. Grade 1 designation is reserved almost solely for the peat-based soils of the drained fens. Your proposed developments around the Waterbeach area are therefore thought to be very unwise. This land is already needed for food production in a country which imports c. 60% of its food supply. Nationally, we do not have food security According to the NFU, the Fens produce one third of England’s fresh vegetables; 20% of our potatoes, over 20% of our flowers and bulbs, 20% of our sugar beet as well as a large percentage of our cereal crops. Agriculture employs 80,000 people and produces £3bn pa for the rural economy.
Farmers can only produce food when they have sufficient water, which we currently don’t have, when land is protected for food security and is not covered in solar panels, housing or business developments. Inward migration to Cambridgeshire will lead to the loss of high and the best quality agricultural land due to building. The increased water usage of those coming to the region is put at about a further 16 megalitres of water a day (based on the additional 49,000 houses proposed hence about 100,000 additional people). This is when we are already in dire need of additional water supplies.
Due to climate change there is an anticipated sea level rise of at least 1.1 metre by 2100 (IPCC 2019) and possibly up to 4.7 metres (Surging Seas) in the Wash and hence the Rivers Great Ouse and Cam. This is likely to lead to the permanent loss of much of the UK food supply as the Fens will become frequently and, eventually permanently flooded. Grade 2 and 3a land is therefore an increasingly valuable national asset which must be protected and whose protection is already documented in the NPPF paragraph 170. Such land exists in an arc around the Fens, much of it around Cambridge.
There is the suggestion of building reservoirs in the Fens to supply water for the proposed increase in population in this part of the county. However, there is little point in building reservoirs in the Fens when it is clear they will be flooded by saline water within decades.
In short, we have to protect this valuable agricultural land from over-development as climate change is likely to decrease its availability and pose a threat to our food security.

Damage to ecosystems The Cambridgeshire countryside, despite intensive farming, is a wildlife-rich area. The Greater Cambridge proposed Local Plan supports a high level of business and housing developments and makes statements suggesting that development will help nature to thrive when evidence shows that the increase in artificial surfaces leads to a decrease in water in the environment and in the amount of land that can absorb rainwater and recharge bodies of water. The river Cam has lost half its flow since the 70s and in 2019 the river Granta completely dried up. Partly as a consequence, freshwater biodiversity populations have declined by 84% (Friends of the Cam).
Concepts such as `doubling nature’, Biodiversity Net Gain and Natural Capital Accounting are used to support large development projects when the global experience of Biodiversity Net Gain (Zu Ermgasssen of University of Kent) is that it fails twice as often as it succeeds even though this study used the lower standard of No Net Loss rather than Biodiversity Net Gain. You don’t “Double Nature” by planting a few green spaces between the concrete, tarmac and bricks, whose construction has of course destroyed it.
The same investigation found that 95% of Biodiversity Net Gain adopters in England were carrying out on site offsetting (which is not covered in the new Environmental Law) where the developer is the only judge of the offsetting plans. On site offsetting does not encourage many forms of wildlife due to high levels of human use.
Monetarising nature can be used to trade environmental assets for economic ones but how we put a price on natural environments is subjective. Dasgupta defines wealth as the sum of natural, human and economic capitals and yields, and sustainability as the condition where this sum is either stable or increasing (Friends of the Cam). Economic growth at the expense of natural capital is unsustainable.
In short, we request that Greater Cambridge adopts the Dasgupta definition of sustainability and not undervalue natural capital and that biodiversity offsetting should be the last resort and seen as a failure. If it is carried out it should be very carefully monitored and penalties available if it does not succeed over time i.e. some kind of warranty system.
Carbon emissions as a result of development The proposed Local Plan does not follow a `brownfield first’ approach hence it goes contrary to the National Government policy expressed by the Prime Minister. Greenfield building maximizes carbon emissions. Greater Cambridge should be working with Government to encourage Cambridge businesses to move north in line with `leveling up’ the north and south frequently expressed by the Prime Minister.
In the north there are up to 1 million empty homes and room for 1 million more on brownfield sites. It is far less environmentally damaging to re-use existing buildings and infrastructure wherever possible. The Campaign for the Protection of Rural England (CPRE) has shown that building on brownfield sites is generally much quicker than developing greenfield ones because land clearance and leveling is not required and often reusable infrastructure is in place. Renovation/rebuilding empty homes is even less environmentally damaging as infrastructure is already in place. A much greater emphasis on using brownfield sites right across the country, before any greenfield building, would be welcomed.
The massive building and infrastructure developments in the proposed Local Plan breaches all obligations for sustainable development as embodied carbon emissions are ignored in the plan. Cement manufacture contributes 8% of global carbon emissions, over 3 times the impact of aviation fuel, iron and steel manufacture contributes a further 8%, and together they are responsible for more carbon emissions than the USA.
The recent Cambridge and Peterborough Climate Commission report stated that at the present rate this area will have used up its entire carbon budget, allocated so it can reach its legal obligation to reach zero carbon, by 2050 and due to the high level of planned growth the use of our carbon budget with accelerate. The obvious conclusion is that all unsustainable growth in this area needs to be curbed.


No plan for Integrated Public Transport
The current local government structure 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 is an impediment to any form of joined up thinking about an integrated transport system.

The Greater Cambridge Local Plan supports the CSET Babraham P and R and guided busway, which a university representative stated in a GCP Executive Meeting, `is only to serve the Bio-Medical Campus.’ It is fairly obvious that it is not designed to serve the villages it passes as bus stops are on the edges of villages thus encouraging on-street parking of anyone living any distance from busway stops who wish to use it. Environmental damage and damage to villages have not been taken into account in the planning of this project and it does not constitute part of an integrated transport system as, as stated, it was designed to only serve the Bio-Medical Campus.

We propose that this should be replaced with the opening up of the old Haverhill railway along which a light railway system could operate with less environmental damage than the CSET scheme and which could serve the local communities it passes, again unlike the CSET scheme. This could link to the mainline railway system and be extended to Haverhill thus giving them the railway station and access to mainline rail stations they are crying out for and need. This would constitute an integrated public transport system, in contrast with the CSET scheme.

The Local Plan is discriminatory in that, when proposing congestion charging, emissions charging and increasing parking charges, it does not take into account that the elderly, disabled and those in rural areas not within walking distance of a bus stop, need to use their cars and would be disproportionately disadvantaged in comparison with those fit enough to walk or cycle or within a reasonable distance of a bus stop. It does not consider that bus fares are expensive to some, as would be all the proposed charges. Visits to, for example, opticians, could become prohibitively expensive to the groups mentioned if you take all these additional charges into account so they could be put off with possible health implications. You suggest that emission charging would encourage people to buy electric or hybrid vehicles but buying another vehicle would be prohibitively expensive for most on low incomes or pensions. The effect all these charges could have is that shopping in Cambridge is replaced by out-of-town or online shopping resulting in a dire effect on Cambridge shops and the hollowing out of the City centre.

Democratic deficit in the process and evidence basis
Water Resources East have stated that their regional water plans align with the government’s plans for growth. However, whilst sewage outflows and the state of chalk streams is of major concern, Water Resources East state that sewage in not part of their remit. The consultation for the Regional Water Plan is not due until summer 2022 yet the public consultation for Greater Cambridge draft Local Plan is going ahead when we have no idea if and how water and sewerage challenges can be met and what trade-offs have been proposed. Therefore you had insufficient information on which to base your draft Local Plan and responders have insufficient information to base responses on.

The draft Local Plan has been prepared by the Greater Cambridge Shared Planning Service but it appears to be inordinately influenced by the unelected GCP which has business interests and ambitions represented on its board and no counteracting resident’s interests. Much of the text of the draft Local Plan appears to be consistent with announcements made by the self-appointed Arc Leaders Group which promotes the Ox-Cam Arc. The flawed concept of the Arc has been criticized for its lack of transparency or accountability across the five affected counties.

Even making full responses to the Local Plan in the way you requested would be a highly labour intensive process because of the requirement to respond to sections and sub-sections of the Local Plan then to cut and paste responses into a further document. As well as being labour intensive it would force responses into your template thinking. For these reasons we, like some others we know of, have chosen to respond in a format of our choosing. It could almost be suggested that you wish to make it as difficult as possible for affected groups to make meaningful responses.

Conclusion
This is the wrong Plan at the wrong time. There’s a climate, biodiversity and water emergency globally and locally. Local government should not be planning more economic and population growth in this area but prioritizing social housing and a new water infrastructure to reduce stress on our rivers and wildlife. It should seek to protect the Green Belt and our local countryside and not concentrate on economic development at any cost. It should be supporting the government `leveling up’ policy and `brownfield first’ policy. It should take into account the growing flood risk to large parts of this county and the consequences for national food security. We request that the Plan is rejected, rewritten, addressing the points made above, then re-submitted for full public consultation.

Babraham Parish Council.

I am writing in a personal capacity to object to the Draft Local Plan on the grounds of inadequate water supply, effect on national food security, failure to minimise climate change, likely irreparable damage to ecosystems, carbon emissions resulting from construction, lack of an integrated public transport system, undermining of the Government's policy of ‘levelling up’, and a democratic deficit in the process and evidence base .

I support the letter of objection sent to you by Friends of the Cam, available here;

https://www.friendsofthecam.org/sites/default/files/ObjectiontoNext%20LocalPlan_0.pdf

Please confirm that you have received my objection, and that this individual submission is noted, recorded, counted and made available.

I am writing in a personal capacity to object to the Draft Local Plan on the grounds of inadequate water supply, effect on national food security, failure to minimise climate change, likely irreparable damage to ecosystems, carbon emissions resulting from construction, lack of an integrated public transport system, undermining of the Government's policy of ‘levelling up’, and a democratic deficit in the process and evidence base . Cambridge should aspire to be one of the leading cities for sustainable development in the UK and promote development that will benefit all its residents, as well as the wider environment.

I fully support the letter of objection sent to you by Friends of the Cam, available here;

https://www.friendsofthecam.org/sites/default/files/ObjectiontoNext%20LocalPlan_0.pdf

Please confirm that you have received my objection, and that this individual submission is noted, recorded, counted and made available.

I am writing in a personal capacity to object to the Draft Local Plan on the grounds of inadequate water supply, effect on national food security, failure to minimise climate change, likely irreparable damage to ecosystems, carbon emissions resulting from construction, lack of an integrated public transport system, undermining of the Government's policy of ‘levelling up’, and a democratic deficit in the process and evidence base.

I support the letter of objection sent to you by Friends of the Cam, available here;

https://www.friendsofthecam.org/sites/default/files/ObjectiontoNext%20LocalPlan_0.pdf

Please confirm that you have received my objection, and that this individual submission is noted, recorded, counted and made available.

I am writing to object to the Draft Local Plan on the grounds of inadequate water supply, effect on national food security, failure to minimise climate change, likely irreparable damage to ecosystems, carbon emissions resulting from construction, lack of an integrated public transport system, undermining of the Government's policy of ‘levelling up’, and a democratic deficit in the process and evidence base .

I support the letter of objection sent to you by Friends of the Cam, available here;

https://www.friendsofthecam.org/sites/default/files/ObjectiontoNext%20LocalPlan_0.pdf

Please confirm that you have received my objection.

I am writing in a personal capacity to object to the Draft Local Plan on the grounds of inadequate water supply, effect on national food security, failure to minimise climate change, likely irreparable damage to ecosystems, carbon emissions resulting from construction, lack of an integrated public transport system, undermining of the Government's policy of ‘levelling up’, and a democratic deficit in the process and evidence base .

I support the letter of objection sent to you by Friends of the Cam, available here;

https://www.friendsofthecam.org/sites/default/files/ObjectiontoNext%20LocalPlan_0.pdf

Please confirm that you have received my objection, and that this individual submission is noted, recorded and counted.

Kind regards,

Dear Sir/ Madam,<BR><BR>I am writing to object to the Draft Local Plan on the grounds of inadequate water supply, effect on national food security, failure to minimise climate change, likely irreparable damage to ecosystems, carbon emissions resulting from construction, lack of an integrated public transport system, undermining of the Government's policy of ‘levelling up’, and a democratic deficit in the process and evidence base . <BR><BR>I support the letter of objection sent to you by Friends of the Cam, available here;<BR><BR>https://www.friendsofthecam.org/sites/default/files/ObjectiontoNext%20LocalPlan_0.pdf<BR><BR>Please confirm that you have received my objection.<BR><BR>Kind regards,

Dear Sir/ Madam,<BR><BR>I am writing to object to the Draft Local Plan on the grounds of inadequate water supply, effect on national food security, failure to minimise climate change, likely irreparable damage to ecosystems, carbon emissions resulting from construction, lack of an integrated public transport system, undermining of the Government's policy of ‘levelling up’, and a democratic deficit in the process and evidence base . <BR><BR>I support the letter of objection sent to you by Friends of the Cam, available here;<BR><BR>https://www.friendsofthecam.org/sites/default/files/ObjectiontoNext%20LocalPlan_0.pdf<BR><BR>Please confirm that you have received my objection.<BR><BR>Kind regards,

I am writing in a personal capacity to object to the Draft Local Plan on the grounds of inadequate water supply, effect on national food security, failure to minimise climate change, likely irreparable damage to ecosystems, carbon emissions resulting from construction, lack of an integrated public transport system, undermining of the Government's policy of ‘levelling up’, and a democratic deficit in the process and evidence base .

I support the letter of objection sent to you by Friends of the Cam, available here;

https://www.friendsofthecam.org/sites/default/files/ObjectiontoNext%20LocalPlan_0.pdf

Please confirm that you have received my objection, and that this individual submission is noted, recorded, counted and made available.

Kind regards,

Dear Sir/Madam,

I am writing in a personal capacity to strongly object to the Draft Local Plan, and to any development on site S/CBC, on the following grounds:

• inadequate water supply
• effect on national food security
• failure to minimise climate change
• likely irreparable damage to ecosystems
• carbon emissions resulting from construction
• lack of an integrated public transport system
• undermining of the Government's policy of ‘levelling up’
• a democratic deficit in the process and evidence base
• flood risk to the proposed site and surrounding roads
• the site is currently Green Belt, and should stay that way
• negative impact on the Nine Wells SSSI nature reserve

I also support the letter of objection sent to you by Friends of the Cam, available here: https://www.friendsofthecam.org/sites/default/files/ObjectiontoNext%20LocalPlan_0.pdf

Please confirm that you have received my objection, and that this individual submission is noted, recorded, counted and made available.

I am writing to object to the Draft Local Plan on the grounds of inadequate water supply, effect on national food security, failure to minimise climate change, likely irreparable damage to ecosystems, carbon emissions resulting from construction, lack of an integrated public transport system, undermining of the Government's policy of ‘levelling up’, and a democratic deficit in the process and evidence base.

I support the letter of objection sent to you by Friends of the Cam, available here;

https://www.friendsofthecam.org/sites/default/files/ObjectiontoNext%20LocalPlan_0.pdf

Please confirm that you have received my objection.

I am writing in a personal capacity to object to the Draft Local Plan on the grounds of inadequate water supply, effect on national food security, failure to minimise climate change, likely irreparable damage to ecosystems, carbon emissions resulting from construction, lack of an integrated public transport system, undermining of the Government's policy of ‘levelling up’, and a democratic deficit in the process and evidence base .

I support the letter of objection sent to you by Friends of the Cam, available here;

https://www.friendsofthecam.org/sites/default/files/ObjectiontoNext%20LocalPlan_0.pdf

Please confirm that you have received my objection, and that this individual submission is noted, recorded, counted and made available.

Dear Sir/ Madam,<BR><BR>I am writing to object to the Draft Local Plan on the grounds of inadequate water supply, effect on national food security, failure to minimise climate change, likely irreparable damage to ecosystems, carbon emissions resulting from construction, lack of an integrated public transport system, undermining of the Government's policy of ‘levelling up’, and a democratic deficit in the process and evidence base . <BR><BR>I support the letter of objection sent to you by Friends of the Cam, available here;<BR><BR>https://www.friendsofthecam.org/sites/default/files/ObjectiontoNext%20LocalPlan_0.pdf<BR><BR>Please confirm that you have received my objection.<BR><BR>Kind regards,

I am writing to object to the Draft Local Plan on the grounds of inadequate water supply, effect on national food security, failure to minimise climate change, likely irreparable damage to ecosystems, carbon emissions resulting from construction, lack of an integrated public transport system, undermining of the Government's policy of ‘levelling up’, and a democratic deficit in the process and evidence base .

I support the letter of objection sent to you by Friends of the Cam, available here;

https://www.friendsofthecam.org/sites/default/files/ObjectiontoNext%20LocalPlan_0.pdf

Please confirm that you have received my objection.

I am writing to object to the Draft Local Plan on the grounds of inadequate water supply, effect on national food security, failure to minimise climate change, likely irreparable damage to ecosystems, carbon emissions resulting from construction, lack of an integrated public transport system, undermining of the Government's policy of ‘levelling up’, and a democratic deficit in the process and evidence base .

I support the letter of objection sent to you by Friends of the Cam, available here;

https://www.friendsofthecam.org/sites/default/files/ObjectiontoNext%20LocalPlan_0.pdf

Please confirm that you have received my objection.

I am writing in a personal capacity to object to the Draft Local Plan on the grounds of inadequate water supply, effect on national food security, failure to minimise climate change, likely irreparable damage to ecosystems, carbon emissions resulting from construction, lack of an integrated public transport system, undermining of the Government's policy of ‘levelling up’, and a democratic deficit in the process and evidence base .

I support the letter of objection sent to you by Friends of the Cam, available here;

https://www.friendsofthecam.org/sites/default/files/ObjectiontoNext%20LocalPlan_0.pdf

Please confirm that you have received my objection, and that this individual submission is noted, recorded, counted and made available.

I am writing in a personal capacity to object to the Draft Local Plan on the grounds of inadequate water supply, effect on national food security, failure to minimise climate change, likely irreparable damage to ecosystems, carbon emissions resulting from construction, lack of an integrated public transport system, undermining of the Government's policy of ‘levelling up’, and a democratic deficit in the process and evidence base .

I support the letter of objection sent to you by Friends of the Cam, available here;

https://www.friendsofthecam.org/sites/default/files/ObjectiontoNext%20LocalPlan_0.pdf

Please confirm that you have received my objection, and that this individual submission is noted, recorded, counted and made available.

Thank you for your email of 1st November 2021 advising CPRE that the above consultation was open. CPRE’s comments are as follows.
Consultation Process
1. CPRE has found the consultation process via Greater Cambridge Local Plan consultation website to be confusing and cumbersome. We are concerned by the apparent pressure for direct electronic response which we believe many residents who do have computers and the skills to use them will find difficult and for those that don’t, impossible. We are concerned that there is only very limited availability for public inspection of documents and that the only place we could find the locations for such inspection was in the Public Notice of the consultation received with the above email. This stated:
The consultation documents can be viewed:
• on the Greater Cambridge Shared Planning Service website www.greatercambridgeplanning.org/localplan
• by appointment at Cambridge City Council’s Customer Service Centre: Mandela House, 4 Regent Street, Cambridge, CB2 1BY (phone 01223 457000);
• by appointment at South Cambridgeshire District Council Reception: South Cambridgeshire Hall, Cambourne Business Park, Cambourne, Cambridge, CB23 6EA (phone 01954 713000);
• at Cambridge Central Library (7 Lion Yard Cambridge CB2 3QD) and Cambourne Library (Sackville House, Sackville Way, Cambourne, Cambridge CB23 6HD) during normal opening hours.
2. So, there were only two locations where copies of the consultation documents could be viewed at will, without an appointment. Why has this information not been made available for inspection in other libraries and library access points or other suitable locations across the City and the District? Are people from places like Gamlingay, Bassingbourn or Linton really expected to drive to or use a bus to one of these two locations to access the consultation documents? Furthermore, as far as we could find, the information about the locations was not clearly available on the consultation web site, only in the attached Public Notice. Why not?


1
The Cambridgeshire branch of Campaign to Protect Rural England
Registered address: Town Hall, Market Hill, St Ives, Cambridgeshire PE27 5AL Registered charity number: 242809

3. We are concerned by the sheer number and complexity of the documents provided and while there has been some attempt to simplify, summarise and abbreviate some communications, this is often not into a form which allows members of the public or even organisations like our own to obtain a clear and rounded understanding of the proposals. Instead, over-simplification which errs towards a marketing approach rather than a factual one leads to the need to search for facts elsewhere. We found that the embedded links to the Sustainability Appraisal and the Habitats Regulations Assessment documents did not work. In the Document Library, the former consists of 4 documents, with the main document consisting of 413 pages with no Executive Summary. Likewise, the HRA report was 215 pages with no Executive Summary. The Consultation Statement is 922 pages with no Summary. This pattern is repeated throughout the library of supporting documents. This appears more akin to preventing knowledge transfer than enabling it.
4. We are pleased by the number of public engagements that have taken place both by physical meeting around Cambridge and by webinar but we are concerned that the most rural areas of the district have either not received local exhibitions or presentations, or these have not been clearly listed.
Timing of the Consultation
5. There are several questionable issues of timing associated with this consultation. Firstly, it is taking place in near parallel to the “Making Connections” and “Cambridge Eastern Access” consultations being run by the Greater Cambridge Partnership, both of which have a direct bearing on aspects of this consultation.
6. Secondly, it assumes the further coordinated development of the so-called “Ox-Cam Arc”, which is now under review by the Department for Levelling Up, Housing and Communities.
7. Thirdly, it assumes the existence and influence of a “UK Innovation Corridor” and a “Cambridge-Norwich Tech Corridor”. Both of these are concepts driven by business interests about which there has been little, if any, publicity or public debate. They are not part of an accepted national planning strategy.
8. Fourthly, the Combined Authority is responsible for transport planning for the County and a consultation on the Local Transport & Connectivity Plan that will have significant implications for this Local Plan has only just been completed and the outcomes are as yet unknown.
9. Fifthly, and perhaps most importantly, any development in or around Cambridge is predicated upon the availability of sufficient potable water supply, yet Water Resources East are still in the process of developing a Regional Water Plan which will not be available for consultation until summer 2022 and several of the basic concepts of which appear fundamentally flawed.
10. CPRE considers that, although the current Local Plans for both authorities, which were only signed off in 2018, carried an Inspector’s recommendation to effect a joint Plan, this study is premature because many key facts which will inform it remain unavailable. This haste will likely lead to a considerable waste of public money at a time when both authorities are struggling for funds to meet their statutory obligations.
Vision and development strategy
11. CPRE have read the Vision statement on the web site. It sounds forward-thinking. It is a great shame the Vision is not matched by the development strategy. The entire strategy is predicated on growth of both population and employment. Cambridge and South Cambridgeshire are areas of effectively full employment. So, any growth in jobs can only be achieved by encouraging inward migration of significant numbers of people from other, often poorer, areas of the country.
12. Such population movement will deplete other regions of some of their youngest and most dynamic populations, causing damage to the social and economic fabric of those areas. It is not consistent with the government’s Levelling Up agenda.
13. The development strategy is not consistent with the stated vision of Greater Cambridge, being “a place where a big decrease in our climate impacts comes with a big increase in the quality of everyday life for all our communities”. Quite the opposite. The level of housing and business development proposed will cause significant increases in both embedded carbon due to construction and emitted carbon due to the

increased population living in the area and the additional infrastructure needed to support them. A vision which sought to spread Cambridge expertise to other areas of the country, which could benefit from refurbishment and redevelopment, would be far more forward-looking socially and climatically.
Cambridge urban area
14. CPRE considers that some of the regeneration proposed within the Cambridge urban area, for example the Travis Perkins site, is welcome. However, there are other proposals which seem badly thought out and not in the best interest of the city or its residents.
15. The level of boring, high rise, slab development around the station has already turned this into a characterless area without charm or visual interest. It could be anywhere. More, similar development will only worsen an already bad situation.
16. CPRE are most concerned about the nature and scale of the North East Cambridge proposals. They are predicated on Anglian Water moving the only modernised sewage treatment plant in the area with spare capacity, into the Green Belt. The planned developments appear too high, characterless and lacking in a practical base for a thriving community, so close to the expanded A14. Discussion with Anglian Water on how they might reduce the environmental footprint and physical area of their existing site could still yield some land for industrial and housing development. The Anglian Water site would form a convenient barrier between new developments and the A14. It is also strange that proximity to the existing Guided Busway is given as a positive factor. Are the people living here expected to commute to St Ives? Because from Milton the busway ceases and its vehicles run on the city streets.
17. We are concerned that the area around Shire Hall and in particular the Castle Mound, with its view of Ely Cathedral on a clear day, will not be damaged by the type of unsympathetic development which has occurred elsewhere in the city.
Edge of Cambridge
18. The development of Cambridge East is predicated on closure of Cambridge Airport. The airport area is one of, if not the largest employers in Cambridge. Where will these skilled engineering staff find employment? Additionally, if Cambridge is to be such a significant centre of international business, why would it not need its own airport, providing flights to national and international hub destinations?
19. Further development in North West Cambridge will cause development to completely dominate this green space between Huntingdon Road and the M11. This green space is important for the existing residents and to the character of the area. Further major development in this area polluted by the M11 and A14 and their major intersection is unwise.
20. With respect to Policy S/CBC, CPRE objects strongly to the release of further Greenbelt land, identified as the area S/CBC-A. The existing allocation of land around the Addenbrokes site has not been built out. Land that has been built on recently has been used profligately. There is indication that since BREXIT and the move of the European Medicines Agency from London to Amsterdam, there will be less interest by major pharmaceutical companies in moving to anywhere in the UK including Cambridge. The UK is now a ‘secondary’ market in the priority of new pharmaceutical product registrations. It is more likely that companies based in the UK will move at least some of their activities to the Netherlands, especially now that the EU and the USA have reached a Mutual Recognition Agreement for drug manufacturing inspections.
21. CPRE agrees with the findings of the Greater Cambridge Green Belt Study (2021) which identifies that release of the areas proposed would result in very high harm to the Green Belt and that there are concerns regarding biodiversity and landscape impacts from the scale of development proposed by the Campus.
22. CPRE also objects to the apparent attempt to turn the “Proposed Area of Major Change” into some kind of greenwashed country park as compensation. This appears to be an underhand attempt at carbon off-

setting on what is much needed, productive, farm land. Such “compensatory improvements” are a developers’ myth. Once the released land has been developed it is gone.
23. With respect to Policy S/WC: West Cambridge, this area is already well developed and further infill within the outlined boundary is sensible. However, CPRE is concerned to ensure there will be no further spread south onto the green fields between Cambridge and the M11.
24. CPRE are concerned by the retention of the two allocations between Huntingdon Road and Histon Road (Darwin Green). These are significant areas of green space on the northern edge of the city which help retain the character of the city’s integration with its rural surroundings.
25. CPRE are concerned by proposed further development along Fulbourn Road on highly productive farm land at S/EOC/E/3: Fulbourn Road East, even though this is a retained policy.
Existing New settlements
26. CPRE objects strongly to Policy S/CB: Cambourne and the proposed further expansion of Cambourne West. This is an object lesson in how urban sprawl occurs when there are no insurmountable natural barriers to stop it. Cambourne was designed as a discrete ‘village’ development to take up overflow from Cambridge in order that the City’s character could be retained. This policy will take up further productive farm land and will lead to a never-ending cycle of demand for additional development. Our concern is that in the longer term, the extension of Cambourne and proposed and current developments around St Neots towards Bedford along the A428/A421 main route will generate further pressure for development until Cambridge is joined to Bedford in one long urban sprawl.
27. CPRE understands Policy S/NS to carry forward the existing allocations for new settlements Northstowe, Waterbeach and Bourn Airfield. However, CPRE is very concerned indeed by the poor building control, lack of democratic control of detailed planning decisions, the damage to underground water bodies, increasing flood risk, lack of engagement with local communities and lack of engagement with local expert and statutory bodies such as the local Internal Drainage Boards which is occurring as development proceeds at two of these sites, Northstowe and Waterbeach. This approach to planning is going to lead to disaster for the planning authorities, for residents and for the custodians of the water resources. Before, any further permissions are given within these allocations, CPRE considers it absolutely essential that these issues are addressed and any problems resolved.
Rural Southern cluster
28. CPRE objects strongly to Policy S/GC: Genome Campus, Hinxton. The proposed policy area is many times the area of the existing campus and the majority of it is on productive farm land on the opposite side of the A1301. To hide this attempted sprawl into the countryside by badging it as a potential expansion of the Wellcome research business, when that business has room for expansion on its existing site, is less than honest.
29. This area of land may be close to a significant road junction but Hinxton is a rural community with a long history in a countryside location and this should be respected. We find this proposal doubly surprising when it was only just over two years ago that CPRE supported the District Council in its rejection of a similar proposal in the countryside near Hinxton, rejection which was upheld by the Planning Inspectorate on appeal.
30. CPRE objects most strongly to Policy S/BRC: Babraham Research Campus. The proposed policy area would approximately double the size of the existing site. It is unacceptable to withdraw this area from the Green Belt. Withdrawal is not consistent with the National Planning Policy Framework. The Babraham site is located within the Cambridge Nature Network and adjacent to two strategic green infrastructure areas (Green Infrastructure Strategic Initiatives: Gog Magog Hills (3) and River Cam Corridor (2c)).
31. Vague terms such as these used by the Shared Planning Service:
• Protect and enhance the landscaped setting of the site

• Preserve the appearance of the conservation areas, and the setting of the Grade II Listed Babraham Hall and the Grade I Listed St Peters Church.
• Protect and enhance the corridor of the River Granta (recognised as a county wildlife site)
• Take steps to include sustainable travel opportunities, including the opportunities provided by the planned Cambridge South East Transport Scheme.
• Retain the area of The Close as key worker and affordable housing to support the needs of the Campus. Any future renovation or replacement should retain the low density character, which responds to the sensitive village edge location.
provide no comfort that this Policy will not lead to further sprawl into the countryside.
32. The proposed Policy Area extension is on higher ground than the existing campus buildings and the location is sensitive in landscape character, being visible from the higher ground of the Gog Magog Hills, including from the Roman Road Scheduled Ancient Monument. The landscape has already been damaged by one of the recently constructed buildings on the campus. CPRE is very concerned by the further development of this site towards Cambridge and we will request the Secretary of State to consider very carefully any further attrition of the Green Belt at this location.
Rest of the rural area
33. CPRE does not support development S/RRA/H Land at Highfields (phase 2), Caldecote. On its own as a village development this would have made sense. However, given the proximity of the nearby major development at Bourn Airfield, CPRE considers this will eventually lead to coalescence and a continuous urban sprawl alongside the A428 from Caldecote to Cambourne.
34. CPRE is concerned by proposal S/RRA/CR Land to the west of Cambridge Road, Melbourn. At first sight, there is logic to this proposal but it could further industrialise the centre of this historic village which has already been badly visually affected by the existing Science Park.
35. CPRE would not support further development at the Cambridge Services site close to the A14 as proposed by S/RRA/SAS, Land to the south of the A14 Services. There is no natural barrier to prevent further expansion into the wide-open landscape at this location which has already been damaged by the necessary but unfortunate location of the services. Such development will lead to further, unsightly, road freight driven sprawl.
36. For similar reasons, and the potential for additional traffic through the centres of Swavesey and Over, CPRE would not support the further expansion proposed by S/RRA/BBP, Land at Buckingway Business Park, Swavesey.
37. CPRE would like to see some form of development protection given to the nearby, former private, outdoor, laboratory of the late Dr Norman Moore at Boxworth End, Swavesey. Dr Moore was one of the UK’s most significant conservation scientists of the 20th century. He founded the former Monks Wood Research Station and established the link between wildlife mortality and widely-used pesticides. The site itself has some local value as habitat and a landscape amenity. However, its overwhelming significance is as a site of scientific study, in particular of ecology and wildlife conservation. This small site was created and studied minutely by a scientist who led the world in his chosen fields - the ecology of hedges and the chemistry of certain pesticides. Boxworth End could show future generations how these issues were first confronted. CPRE’s ongoing national campaign, supported by Lord Deben, to protect and enhance hedgerows nationally attracted a lot of support at a day in Parliament recently, demonstrating just how important hedgerows are to the future health of the countryside and at what level this is recognised.
38. CPRE is not in favour of proposal S/RRA/SNR, Land to the north of St Neots Road, Dry Drayton. This small land parcel forms a green buffer between St Neots Road and the A428 and development would create further coalescence along the A428.

39. CPRE would support the redevelopment proposed by S/RRA/OHD Old Highways Depot, Twenty Pence Lane, Cottenham, providing it was limited to employment Class E(g)(i) (offices to carry out any operational or administrative functions) and/or E(g)(ii) (Research and development of products or processes). CPRE would strongly oppose development of this site for Class B8, storage and distribution use. Cottenham already endures significant disturbance from HGV traffic arising from the industrial site further north along Twenty Pence Road.
Climate change – development issues
40. CPRE largely supports Policy CC/NZ: Net zero carbon new buildings. However, to be effective it needs to be taken in conjunction with three further policies which we have not discovered in the draft Local Plan, namely:
• a ‘brownfield first’ policy for new building
• a policy to minimise the number of new buildings and developments in the Greater Cambridge region
• a policy to halt the use of scarce farm land for solar energy generation and instead ensure that solar installations are mandated on all industrial buildings, new and existing. Policy CC/RE: Renewable energy projects and infrastructure, is totally ineffective in this respect.
41. The draft Local Plan is not consistent with national government policy because it does not follow a 'brownfield first' approach. It is also concerning that the Plan is seeking to build more houses in the Cambridge area than required by current planning legislation and the ‘five-year land supply’.
42. As stated above, the Plan assumes the development of the Ox-Cam Arc, which is leading to more greenfield building which maximises carbon emissions. The Local Plan should not be accepting the Arc, instead the local planning authorities should be firmly resisting this outdated idea of ‘clustering’ of science-based businesses. These businesses operate globally, increasingly using the internet to minimise business travel and they can operate anywhere. The development of vaccines during the pandemic has proved the effectiveness of remote collaborative working on a global scale.
43. Rather than encouraging further building on precious high grade farm land around Cambridge all responsible local organisations involved in planning, including the University and businesses, should be encouraging and enabling redevelopments in other regions, where there are up to 1 million empty homes and space for 1.3 million more on registered brownfield sites.
44. Embedded carbon emissions arising from construction appear to be ignored in the Plan. Cement manufacture contributes 8% of global carbon emissions which is more than three times the impact of aviation fuel. Iron and steel production accounts for another 8%. Between them they account for more emissions than the USA and are second only to China as greenhouse gas emitters.
45. According to the recent Cambridge and Peterborough Climate Commission report, at the present rate the Region will have used up its entire carbon budget, allocated to meet its legal obligation to reach zero carbon by 2050, in less than six years; due to the level of planned growth, emissions will accelerate further.
46. The Climate Change Committee, led by Lord Deben, has argued in its 2018, 2019 and 2020 Annual Reports to Parliament that UK local and imported emissions arising from construction, must be reduced if the UK is to meet its now legal emission targets. Yet this Plan is seeking to increase construction.
47. Large areas of some ‘brownfield’ sites, such as old airfields like Oakington, Waterbeach and Bourn, are not brownfield at all. Only their disused runways, hard-standing and associated buildings are brownfield and most of their area is already turned back to use as productive farmland. It is unacceptable that local planning authorities are blindly ignoring this fact.

48. All unsustainable growth must be halted as a matter of global and national emergency, yet the level of building and infrastructure growth contained in the draft Local Plan breaches all obligations for sustainable development other than those arising from future operation.
49. Policy CC/DC: Designing for a changing climate, is closing the stable door after the horse has bolted.
Climate change – water supply issues
50. Policy CC/WE: Water efficiency in new developments, is not going to solve the potable water crisis affecting Cambridgeshire, a crisis which is only likely to deepen if the report written by Stantec for the Shared Planning Service is ignored.
51. The Environment Agency document titled “Water stressed areas – final classification 2021”, published in July 2021 by DEFRA, included the fact that the supply areas of Cambridge Water and Anglian Water are areas of serious water stress, page 6. According to Appendix 3 of this document, Cambridge Water needs to reduce abstraction by 22 megalitres per day from levels current at 1st July 2021, and Anglian Water needs to reduce abstraction by 189 megalitres per day from levels current at 1st July 2021.
52. Anglian Water’s proposed solution to this problem, pumping water from North Lincolnshire, appears completely impracticable because the Environment Agency, in the same report, has also classified North Lincolnshire as an area of serious water stress.
53. Another solution being considered by Anglian Water, according to Water Resources East, is to build two reservoirs in the Fens. However, this idea seems to completely ignore the fact of sea level rise which will likely cause much, if not all, of the Fens to be flooded by seawater within decades.
Climate change – flooding issues
54. CPRE finds Policy CC/FM: Flooding and integrated water management to be totally inadequate in the face of the increasing flood risks arising in the county, the greatest of which is the likely loss of a high percentage of the Fens to flooding within decades, as referred to above.
55. The river Great Ouse is tidal up to Brownshill Staunch between Earith and St Ives. This means that areas such as Cottenham Lode, which extends to the A14 and the edge of Cambridge, are at future high risk of tidal flooding as well as the fluvial flooding experienced in winter 2020/21 in places such as Cottenham, St Ives and St Neots. There is also increasingly high risk of flash flooding in these low-lying areas due to the increased intensity of rainfall arising from climate change. Such flooding was experienced in several areas of the county, including Peterborough, during 2021.
56. The inexorable and increased rate of sea level rise means that the Fens will initially be subject to occasional and then annual flooding. The annual flood risk will be increased by the additional volume of run-off from development coming downstream. Eventually, the tidal inflow will cause permanent flooding and large areas of the Fens will be returned to saltmarsh. However, even the first stage of annual flooding will have a significant negative effect on agriculture and national food supply. It was found after the 1947 and 1953 floods that crop yields were reduced for seven years due to the presence of a nematode in seawater.
57. To illustrate this situation numerically, the Environment Agency has been measuring sea level (AOD) in the Wash for many years. It was rising at a rate of 3 mm per year. In 2019 it was agreed that measurements by the Environment Agency and by IPCC indicated that the annual rate of sea level rise had increased to 3.3 mm per year. The IPCC2014 report predicted global sea level rise of 1 metre by 2100. The IPCC2019 report predicted sea level rise of 1.1 metres by 2100. In 2021, IPCC increased its estimate again to 2.4 metres by 2100. Climate Central estimates sea level rise of 4.7 metre by 2100 if global temperatures rise by 2°C. Worryingly, in 2021 both the IPCC and the COP26 leadership have confirmed that the world can expect a 2.4°C global temperature rise.
58. Evidence shows that any increase in artificial surfaces, such as buildings and roads, leads to a decrease in water in the environment. Development also leads to a decrease in the amount of land that can absorb rainwater and recharge water bodies. According to the Royal Horticultural Society, 70% of ponds have been

lost from the UK countryside since 1970. The River Cam has lost on average half its flow. In 2019, the River Granta dried up completely. Freshwater biodiversity populations have declined by 84%.
59. By continuing to build on the scale planned, Cambridgeshire is sowing the seeds of its own destruction. Firstly, it is creating avoidable carbon emissions which will contribute to global temperature rise. Secondly, that temperature rise will cause large parts of the county to flood permanently. Thirdly, the additional run- off from development will increase the risk of flooding and bring forward the date of permanent flooding of large parts of the county. This issue must be taken far more seriously than the token gesture of Policy CC/FM.
Climate change – reducing waste and supporting the circular economy
60. While CPRE supports and positively encourages the principle of reducing waste and supporting the circular economy, it deems Policy CC/CE far too weak. Worse, the draft Local Plan is not in accordance with the first principles quoted in this policy: “construction waste will be addressed following the waste hierarchy and the 5 r’s of waste management: Refuse, Reduce, Reuse, Repurpose, Recycle.”
61. All unnecessary construction should be Refused and all construction Reduced. This includes the excessive building across South Cambridgeshire proposed by the draft Plan.
62. Existing constructions should be Reused, Repurposed or Recycled. This applies not just within the Cambridge region but right across the country with Cambridgeshire doing whatever it can to encourage the reusing, repurposing and recycling of the nearly 1 million empty homes in the UK and the recycling of the
1.3 million brownfield sites across the UK before permitting further greenfield construction around Cambridge.
63. These principles apply to construction as a whole, not just to construction waste. Their proper application will have a major effect in reducing greenhouse gas emissions.
Climate change – Supporting land-based carbon sequestration
64. We are puzzled by Policy CC/CS: Supporting land-based carbon sequestration while supporting the principles. There is very little undrained peat in South Cambridgeshire or Cambridge City.
65. Could this be the policy that is aimed at justifying re-flooding the Fens due to the effects of greenhouse gas emissions and increased run-off which the level of increased construction will cause?
Biodiversity and green spaces
66. The stated aim “Increase and improve our network of habitats for wildlife, and green spaces for people, ensuring that development leaves the natural environment better than it was before.” clearly demonstrates that this draft Local Plan is adopting a green-washing approach to bio-diversity.
67. Except in the case of some brownfield sites which can be restored, or existing sites where greenspace can be improved, development will always damage the natural environment. Even the supply of building materials will likely damage the natural environment elsewhere, whether obtained locally, nationally or internationally.
68. The best possible treatment for the natural environment is to leave it undeveloped and in its natural state. There are steps that can be taken to improve the biodiversity of unbuilt land with appropriate planting and management. These are steps which should be encouraged.
The next few sub-paragraphs are taken from the submission of The Friends of the Cam and are statements which CPRE fully supports and has signed up to:
a. Concepts such as Natural Cambridgeshire’s 'Doubling Nature' ambition, Biodiversity Net Gain (BNG) and Natural Capital Accounting (NCA) are being used as bargaining chips in the developers' casino that broadly amounts to saying 'no development means no funding for nature'. This is the antithesis

of John Lawton's 2010 plea in 'Making Space for Nature' of significant funding for Nature conservation without any strings attached.
b. The concept of doubling nature is ill-defined (doubling what, exactly?). The Draft Local Plan needs to define exactly how the concept will be understood and measured.
c. The global experience of Biodiversity Net Gain, reviewed by zu Ermgassen of DICE, University of Kent, is that it fails twice as often as it succeeds, even though it had the lower bar of No Net Loss, NNL rather than BNG.
d. The same group more recently showed that 95% of early-adopters of BNG practices in England are carrying out on site offsetting (something not covered at all in the new Environment Law) where the developer is the judge, jury and executioner of any offsetting plans. In any case, on site offsetting will not encourage many forms of wildlife and will be prone to the dog-fouling and trampling that harms many wildlife areas, even those remote from housing. Meanwhile, off-site off-setting is already damaging local communities in some rural areas.
e. Natural Capital Accounting is an untested concept. The monetary assessment of ecosystem services (the 'yields') is recognised as being inadequate at present, while assessing the monetary value of ecosystem stocks is more or less impossible (Ian Bateman, communicated to David Rogers). Yet the resulting monetary assessments may be used to trade away environmental for economic assets with a greater yield, for example a factory in a water meadow.
f. The natural environment is our vital life support system and it is a dangerous delusion to imagine that it can be rendered easily into any economic framework (let alone the pre Dasgupta framework that gives GDP/GVA primacy over all other forms of stocks and yields).
g. Dasgupta defines wealth as the sum of natural, human and economic capitals and yields, and sustainability as the condition where this sum is either stable or increasing. Economic growth at the expense of natural capital and yields is therefore unsustainable.
h. We request that the Cambridge Local Plan adopts the Dasgupta definition of sustainability (i.e. definitely not the NPPF's false definition of 'sustainability'), with the caveats mentioned above, especially the false or under-valuation of natural capital. This would provide a better starting point, and the Plan should be reworked in this context.
69. CPRE repeats the request made in paragraph h) above.
70. CPRE are disappointed that we can find very little mention of hedgerows in this part of the plan or elsewhere. Hedgerows are significant contributors to bio-diversity, as was demonstrated by the work of Dr Norman Moore. In addition, hedgerows are more effective carbon sequestrators per unit area than tree plantations, certainly in the first ten years of growth if not longer. With six to seven tree plants per metre in a hedge, it stands to reason they will be most effective carbon sinks.
Great places policies
71. CPRE supports the principles expressed in this section and its accompanying policies. Indeed, we are pleased to see expressed the established local purposes of the Cambridge Green Belt, which are to:
• preserve the unique character of Cambridge as a compact, dynamic city with a thriving historic centre
• maintain and enhance the quality of its setting
• prevent communities in the environs of Cambridge from merging into one another and with the city.
72. However, CPRE does not believe that the draft Local Plan is adhering to these principles, particularly in the case of proposals to remove several sites from the Green Belt.

73. We are also concerned that some of the developments that have already occurred around Cambridge are visually intrusive and, in some cases, aesthetically unappealing. We would not want to see these mistakes repeated.
Jobs policies
74. It is clear that the draft Local Plan is focused on the continuation of ‘growth’ in the Cambridge area. CPRE believes this is a mis-guided approach. The Greater Cambridge area is one which DHSS would consider to have effectively full employment, with just the usual rotation of people out of work or seeking work. Therefore, any growth in jobs will require inward migration to fill them. Inward migration creates pressure on local housing availability and prices, and hence pressure for more house-building. It is an anti-climate cycle.
75. As stated above CPRE would like to see the skills and resources of Cambridge-based organisations used to encourage employment and redevelopment in other regions of the country where housing and water capacity already exist and, in doing so, greenhouse gas emissions would be minimised.
76. CPRE are concerned by policies J/RE: Supporting the rural economy and J/AL: Protecting the best agricultural land. We think both of these policies should be strengthened and properly enforced. The rural economy can be diversified but at its core are farmers and their interests must be protected. For example, the opening up of tracks and bridleways on the scale proposed by the Greater Cambridge Partnership will cause increasing levels of damage to farms and farm equipment and increased security risk to farm properties. It will make illegal activities such as hare-coursing easier and the police enforcement job harder.
77. We think it is in the national interest to stop building on South Cambridgeshire farm land, most of which is Grade 2 with some Grade 3a. http://publications.naturalengland.org.uk/publication/127056 This land is already needed to assist the minimisation of food imports and it will be even more needed when the Fens flood and national food supply is reduced by an estimated 20 – 25%.
78. According to the NFU, the Fens produce one third of England’s fresh vegetables, 20% of England’s potatoes, more than 20% of England’s flowers and bulbs, 20% of England’s sugar beet as well as a significant percentage of the country’s cereal, oilseed rape and protein crops. Agriculture in the Fens employs 80,000 people and produces £3bn pa for the rural economy.
79. The government recognises that the UK currently imports 45% of its food; however, some sources estimate this to be as much as 80%. The Environmental Audit Committee has already warned government that the UK cannot continue to rely on food imports on this scale because climate change is going to damage food- growing areas further south.
80. Building on good Cambridgeshire farm land just does not make sense. There may be short-term economic pressures to do so but it is not in the national interest.
81. CPRE supports Policy J/PB: Protecting existing business space and Policy J/RW: Enabling remote working. We also recognise that local affordable workspace can reduce commuting and increase local employment opportunities, Policy J/AW: Affordable workspace and creative industries. We are concerned to ensure that existing buildings which could be used for employment are not demolished to make way for maximum levels of housing and maximum profit for developers as we are aware has occurred in some districts.
82. With respect to Policy J/RC: Retail and centres, CPRE are aware of increasing levels of internet shopping and decreasing footfall in retail centres. This may lead to re-purposing for housing under “Permitted Development”. CPRE is believes that all such development should be brought back under local authority building control and not be the appalling low-quality free-for-all that it is now.

Homes policies
83. As already expressed above, CPRE’s concern is that this draft Plan includes house-building far in excess of necessary or statutory requirements. It appears to be based on a growth agenda which in turn is based upon encouraging unsustainable inward migration to the area.
84. CPRE believes that the greatest housing need is for affordable homes and would like to see Policy H/AH: Affordable housing, strengthened and enforced as far as possible. We would like to see increasing numbers of small sites developed with affordable housing included.
85. CPRE has some concerns about the use of Policy H/ES: Exception sites for affordable housing, because in one district we know of, the exception site rules have been used to approve major, market led, developments posing as community-led exception sites, when they contain the minimum requirement of affordable housing. We trust that South Cambridgeshire will not countenance this deceptive approach through the application of this policy.
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.
Sustainability
94. In 1987, the United Nations Brundtland Commission defined sustainability as “meeting the needs of the present without compromising the ability of future generations to meet their own needs.”
95. CPRE does not believe that the draft Local Plan meets this essential test. The use of greenfield land, the effect of water supply on the Cambridge aquifer, the increased flood risk to the Fens caused by the Plan and the lack of an integrated public transport plan are all examples of unsustainability.
Green Belt
96. We are appalled by the proposals to remove further land from the Green Belt, particularly at Babraham and Hinxton. It is also inconsistent with the re-iteration of the purpose of the Green Belt in the statement on Great Places in the Plan.
97. CPRE will strongly oppose all attempts to further erode the Cambridge Green Belt.
98. CPRE should not have to make this statement to planning authorities who should be ensuring full protection of the Green Belt
Summary:
• CPRE are concerned by some aspects of the consultation process, in particular the complexity of the documents provided and the lack of physical access to them, except by post or visits to one of only four locations.
• CPRE are surprised by the timing of the current consultation which clashes with, or is in advance of, other consultations and studies which are relevant to the subject.
• CPRE has commented on individual development proposals where it had sufficient knowledge to make a contribution.
• CPRE are concerned that insufficient attention has been paid to the negative effects on climate change and bio-diversity which will arise from this draft Plan.
• CPRE considers that effects on flooding and food supply of the draft Plan are not in the national interest.
• CPRE considers that this draft Plan is not sustainable, within the UN definition.
• CPRE will oppose all proposed removals of land from the Cambridge Green Belt which is essential to the maintenance of Cambridge as an attractive place for working and living.
Finally, please note that our submission is in respect of the proposed draft Plan. While we have taken every effort to present accurate information for your consideration in our role as a consultee, we are not a decision maker, therefore we cannot accept any responsibility for unintentional errors or omissions and you should satisfy yourselves on any facts we have presented.

Timing of the Consultation
5. There are several questionable issues of timing associated with this consultation. Firstly, it is taking place in near parallel to the “Making Connections” and “Cambridge Eastern Access” consultations being run by the Greater Cambridge Partnership, both of which have a direct bearing on aspects of this consultation.
6. Secondly, it assumes the further coordinated development of the so-called “Ox-Cam Arc”, which is now
under review by the Department for Levelling Up, Housing and Communities.
7. Thirdly, it assumes the existence and influence of a “UK Innovation Corridor” and a “Cambridge-Norwich
Tech Corridor”. Both of these are concepts driven by business interests about which there has been little, if
any, publicity or public debate. They are not part of an accepted national planning strategy.
8. Fourthly, the Combined Authority is responsible for transport planning for the County and a consultation
on the Local Transport & Connectivity Plan that will have significant implications for this Local Plan has only
just been completed and the outcomes are as yet unknown.
9. Fifthly, and perhaps most importantly, any development in or around Cambridge is predicated upon the availability of sufficient potable water supply, yet Water Resources East are still in the process of
developing a Regional Water Plan which will not be available for consultation until summer 2022 and
several of the basic concepts of which appear fundamentally flawed.
10. CPRE considers that, although the current Local Plans for both authorities, which were only signed off in
2018, carried an Inspector’s recommendation to effect a joint Plan, this study is premature because many
key facts which will inform it remain unavailable. This haste will likely lead to a considerable waste of
public money at a time when both authorities are struggling for funds to meet their statutory obligations.

I am writing in a personal capacity to object to the Draft Local Plan on the grounds of inadequate water supply, effect on national food security, failure to minimise climate change, likely irreparable damage to ecosystems, carbon emissions resulting from construction, lack of an integrated public transport system, undermining of the Government's policy of ‘levelling up’, and a democratic deficit in the process and evidence base .

I support the letter of objection sent to you by Friends of the Cam, available here;

https://www.friendsofthecam.org/sites/default/files/ObjectiontoNext%20LocalPlan_0.pdf

Please confirm that you have received my objection, and that this individual submission is noted, recorded, counted and made available.

I am writing to object to the Draft Local Plan on the grounds of inadequate water supply, effect on national food security, failure to minimise climate change, likely irreparable damage to ecosystems, carbon emissions resulting from construction, lack of an integrated public transport system, undermining of the Government's policy of ‘levelling up’, and a democratic deficit in the process and evidence base .

I support the letter of objection sent to you by Friends of the Cam, available here;

https://www.friendsofthecam.org/sites/default/files/ObjectiontoNext%20LocalPlan_0.pdf

Please confirm that you have received my objection.

I am writing to object to the Draft Local Plan on the grounds of inadequate water supply, effect on national food security, failure to minimise climate change, likely irreparable damage to ecosystems, carbon emissions resulting from construction, lack of an integrated public transport system, undermining of the Government's policy of ‘levelling up’, and a democratic deficit in the process and evidence base .

I support the letter of objection sent to you by Friends of the Cam, available here;

https://www.friendsofthecam.org/sites/default/files/ObjectiontoNext%20LocalPlan_0.pdf

Please confirm that you have received my objection.

I am writing to object to the Draft Local Plan on the grounds of inadequate water supply, effect on national food security, failure to minimise climate change, likely irreparable damage to ecosystems, carbon emissions resulting from construction, lack of an integrated public transport system, undermining of the Government's policy of ‘levelling up’, and a democratic deficit in the process and evidence base .

I support the letter of objection sent to you by Friends of the Cam, available here;

https://www.friendsofthecam.org/sites/default/files/ObjectiontoNext%20LocalPlan_0.pdf

Please confirm that you have received my objection.

I am writing to object to the Draft Local Plan on the grounds of inadequate water supply, effect on national food security, failure to minimise climate change, likely irreparable damage to ecosystems, carbon emissions resulting from construction, lack of an integrated public transport system, undermining of the Government's policy of ‘levelling up’, and a democratic deficit in the process and evidence base .
I support the letter of objection sent to you by Friends of the Cam, available here;
https://www.friendsofthecam.org/sites/default/files/ObjectiontoNext%20LocalPlan_0.pdf
Please confirm that you have received my objection.
Kind regards

I am writing to you personally to object to the Local Plan as it has no focus on the whole future of the city, the nation or the planet, just an obvious short-term growth for the GDP based economy.

There are many problems including:
* inadequate water supply
* national food security effects
* failure to minimise any impacts to climate change
* damage to ecosystems that should be rewilded not destroyed
* carbon emissions from the construction
* no plans for an integrated public transport system
* a lack of a fully democratic process and evidence base

I support the letter of objection sent to you by Friends of the Cam, available here;

https://www.friendsofthecam.org/sites/default/files/ObjectiontoNext%20LocalPlan_0.pdf

Please confirm that you have received my objection, and that this individual submission is noted, recorded, counted and made available.

Sustainability
94. In 1987, the United Nations Brundtland Commission defined sustainability as “meeting the needs of the
present without compromising the ability of future generations to meet their own needs.”
95. CPRE does not believe that the draft Local Plan meets this essential test. The use of greenfield land, the
effect of water supply on the Cambridge aquifer, the increased flood risk to the Fens caused by the Plan
and the lack of an integrated public transport plan are all examples of unsustainability.
Green Belt
96. We are appalled by the proposals to remove further land from the Green Belt, particularly at Babraham
and Hinxton. It is also inconsistent with the re-iteration of the purpose of the Green Belt in the statement
on Great Places in the Plan.
97. CPRE will strongly oppose all attempts to further erode the Cambridge Green Belt.
98. CPRE should not have to make this statement to planning authorities who should be ensuring full
protection of the Green Belt.