STRATEGY

Contents
1. Summary of submission paras 1 – 5
2. Review of present proposals paras 6 – 20
3. Some official figures giving as different view paras 21 – 27
4. Consequences of adopting the proposals paras 28 – 36
5. Risk and uncertainties of present proposals paras 37 – 41
6. Absence of usual benefits paras 43 – 47
7. The decision facing the authority paras 48 – 57
8. Images – inspiring or misleading? paras 58 – 63


Summary of submission
1. The First Proposals for the Greater Cambridge Local Plan published in November 2021. Lead Councillors of both Local Authorities have welcomed their ambitious approach to meeting environmental challenges and also felt that the proposals would protect the rural areas of South Cambridgeshire from inappropriate development, although there was some note of caution as to the availability of adequate water supplies for the proposals’ full realisation.

2. While the First Proposals go some way to describing the current planning pressures, challenges and opportunities facing the Greater Cambridge area, lack the essential balance required in order to achieve an optimal outcome over the period 2021 -2041. They leave the way open for the even the minimum goals on climate change to be compromised and for significant avoidable harm to be done to the natural and built environment.

3. It is open to question whether the proposal to use a method other than the Government’s Standard Method for calculating future housing need can be justified and refers to an alternative official calculation for comparison and discussion.

4. There is urgent need for the most rigorous measures to reduce Co2 emissions to a minimum following the Government’s undertakings at the Glasgow COP 21 conference. To help to achieve this –

(i) the number of currently unoccupied dwellings in the Greater Cambridge area should be properly taken into account within the ‘in the pipeline’ figure and

(ii) the number of new dwellings in addition to that calculated according to the Standard Method should be as far as possible secured to the sole occupation of the families of employees of scientific and technical undertakings in the fields of life sciences and health care.

5. The effect of the visual image used in the public presentation of the proposals the Smart Survey and other public documents is examined. The image shows a graphic version of a tree with various benefits embedded in its foliage. It is argued that this as a misleading image as it suggests that the proposals represent to best way of achieving the benefits, whereas the benefits in question either already exist or can be achieved by other and less damaging means. The use of the image therefore indicates a significant flaw underlying the proposals.


Review of present proposals

6. The key element in the proposals is the use of a new method to be used in calculating the number of new homes required for the Greater Cambridge area up to 2041. It is set out in the GL Hearn report ‘Greater Cambridge Local Plan: Housing and Employment Relationships dated November 2020 (‘Hearn 1’), the basic principles of the approach being set out at paras 1.1 to 1.10.

7. The report proposes that instead of using the Government’s Standard Method of calculating housing need, other economic projections from various sources as to the growth of various industries in the area are used to calculate the number of jobs which would be created by the predicted rate economic expansion. The number of homes that would then be required to support these jobs is calculated from that figure by using the Standard Method in reverse.

8. The approach by the Hearn 1 study in relation to economic projections was to consider estimates of historic employment by various organisations such as the Business Register and Employment Survey (BRES), the Centre for Business Research (CBR), a study by CBR using ‘blended’ data from CBR and BRES, an East of England Forecasting Model that relies substantially on BRES and Cambridge Economics’ own estimates, similar to those underpinning BRES. These five datasets had broadly similar views on employment levels in 2017 but their rates of change back to 2011 differed, “… making future forecasting problematic.” The EEFM is an integrated model for economic, demographic and housing trends and uses forecasts by Cambridge Economics but can fail to account for rapid change occurring in some sectors.


9. The Hearn reports do not contain any reference to use of this method to date by other planning authorities, and we do not know of any such previous use.

10. The results of each of the two methods of calculating future increases in population and job numbers are very different. The Government’s Standard Method of calculating needs for homes and jobs for the period 2021 – 2041 would indicate an additional 45,800 jobs, supported by an additional 36,600 homes (Hearn 1 para 3.72 at p 32).

11. The economic-forecast-based method however would indicate the number of jobs needing to be ‘supported’ is much greater. Table 17 of the report at p 37 shows the more conservative ‘central’ estimate is 58,441 jobs while the ‘higher’ estimate (as explained at para 4.9) is 78,742 jobs.


12. To calculate the number of new homes that would be required to support these jobs, the Standard Method has then simply been applied in reverse, ‘translating’ this figure into a labour supply and population growth by taking into account the factors of unemployment numbers, double jobbing, commuting patterns and levels of economic activity.

13. The effect of commuting for the additional jobs created can be calculated by two possible methods. One is to assume the commuting patterns shown in the 2011 census remain substantially the same. The other is to assume a 1:1 relationship between jobs growth and the number of economically active residents (ie Greater Cambridge would not draw in any additional labour above that already assumed by applying the Standard Method and existing patterns).

14. The numbers of additional economically active residents needed to ‘support’ the number of jobs predicted in Greater Cambridge, applying all factors including the ‘2011 census’ commuting assumption are shown in Table 18 as 45,552 (‘central’ figure) and 63,938 (‘higher’ figure). Table 19 shows the figures using the ‘1:1 relationship’ commuting assumption. They are somewhat greater – 49,341 (‘central’ figure) and 68,525 (‘higher’ figure).

15. The annual housing growth needed to accommodate these future employees is set out in Table 22 and Table 23 on p 40 of the report. Over the 20-year period to 2041 this annual figure would require, using the 2011 census commuting pattern, 1996 x 20 dwellings (‘central’ figure) and 76,470 dwellings (‘Higher’ figure) and using the ‘1:1 relationship commuting pattern, 42,222 dwellings (‘central’ figure) and 53,800 dwellings (‘higher’ figure).


16. The Report on the Greater Cambridge Local Plan: First Proposals (Preferred Options) prepared for consultation by the Joint Director of Planning and Economic Development concludes (at p 5 - Development Strategy) that the need for jobs and homes in the context of national planning policy and guidance is 58,500 jobs and 44,400 homes. This figure of 44.400 for the number of new homes is reasonably close to the ‘Central’ figure using the ‘1-1’ commuting ratio and based on Table 23 of Hearn 1.

17. However an earlier document, the Local Plan ‘Issues and Options 2020’ document states at the Executive Summary:


“One big question affecting all these themes (Climate Change, Biodiversity and Green Spaces, Wellbeing and Social Inclusion and Great Places) will be the number of jobs and homes to plan for. Central Government has set us the target of planning for a minimum of around 41,000 homes between 2017 and 2040. We are doing more work to understand future jobs growth and housing growth to support it. However, to give an indication, if the recent high jobs growth was to continue, there may be a case for making provision beyond the local housing need to include flexibility in the plan and provide for about 66,000 homes during this period. We already have about 36,400 homes in the pipeline for this period, but it will be for the new Plan to find sites for the rest.”

18. The same passage also appears in the ‘First Conversation’ document published in January 2020, which includes a Welcome from Cllrs Tumi Hawkings and Katie Thornburrow.

19. As the Development Strategy Options Summary Report makes clear, the Councils have not at this stage reached any view on the preferred approach for the new Local Plan, so it seems that the possibility of ‘including flexibility in the plan’ allowing for 66,000 new homes as stated in the First Conversation document remains in the background.


20. This figure of 58,500 jobs is very close to the 58,441, the ‘central’ figure for Greater Cambridge in Table 17 of the GL Hearn report, and the annual number of new dwellings required is said to be 2,111, the ‘central’ figure in Table 23 of the report. An annual 2111 new dwellings over the 20-year period would produce a total of 42,220.

21. We therefore have several actively considered figures for the required number of new dwellings up to 2041. They are:
According to the Standard Method calculation –
1743 per annum x 20 = 34,860 (Hearn 1 Table 1)
‘Reverse Standard Method’ based on projected job figures -
‘Central’ figure (2011 commuting assumptions) : 1,996 pa x 20 = 39,920 (Hearn 1 Table 22)
‘Central’ figure based on ‘1–1’ commuting ratio: 2,111 pa x 20 = 42,222 (Hearn 1 Table 23)
‘Higher’ figure (2011 commuting assumptions): 2,549 pa x 20 = 50,980 (Hearn 1 Table 22)
‘Higher’ figure based on ‘1-1’ commuting ratio: 2,690 pa x 20 = 53,800 (Hearn 1 Table 23)
In the background -
Local Plan – Issues and Options 2020 : 66,000

Some official figures giving a different view

21 The employment forecasts referred to in section 5 of the Hearn EL and EN Study certainly appear to provide strong evidence of such dynamic growth over the period to 2041. The most striking information in the Study report (para 5.8) is that the 2018 Local Plan drew on EEFM data which assumed that 44,100 jobs would be created between 2-11 and 2031, in fact 35,800 jobs had been created between 2011 and 2017, 81% of the total. This observation, which tests the accuracy of previous forecasts in the light of subsequent developments, is strong and convincing and points to a rate of growth in areas such as life sciences (Health and Care and Research and Development) which is far stronger that predicted.

22 Nevertheless there must be strong reservations about the advisability of basing the planning policy for 2021 -2041 entirely on the figures set out in Hearn 1. It should be remembered that the Standard Method was introduced by the Government in 2017 in order to set an ‘ambitious target’ of providing 300,000 new homes across the whole of the UK. Far from being an outdated formula, it is a recently set, ambitious target calculated to meet the needs of an expanding economy.

23 In the circumstances it is worth bearing in mind that other statistical exercises on this question have had a very different result.

24 In August 2020 Robert Jenrick, Secretary of State for Housing, Communities and Local Government introduced a White Paper Planning for the Future. In the Introduction Mr Jenrick said that his aim was, “ … tackling head-on the shortage of beautiful, high-quality homes and places where people want to live and work … supporting sustainable growth in all parts of the country and rebalancing the economy”. The White Paper proposed inter alia that the Standard Method of calculating housing need should be revised to help to achieve this aim.


25 On 1st October that year the House of Commons Library published an analysis by the firm Litchfields which compared the results when applying the present Standard method with the results when applying the proposed Standard Method to calculate housing need in all Local Authorities. Using the current method, the new housing need for Cambridge was 1,085 homes annually while the proposed method showed the annual need was 745 per year, an actual decrease of 312 or 29%. For South Cambridgeshire the current method showed an annual need of 658 a year while the proposed method showed an annual need of 745, an increase of 87 or 13%.

26 In other words the recently proposed method of calculating housing need, designed to achieve the aims as stated by Mr Jenrick above for all parts of the country, would show that the Greater Cambridge area should plan for an annual reduction of 225 in the number of new dwellings planned for the area.


27 It would appear from the disparity between the authorities cited above that the Councils would be well advised to take seriously the qualification expressed on employment levels and therefore housing need in the Hearn 2 report at para 5.5:
“Although the above data sets have broadly similar views on the level of employment at 2017, the count and therefore the rate of change differed substantially, making future forecasting problematic.”

Consequences of adopting the present proposals

28 If we assume, however, that the figure of 44,400 new homes is the one finally adopted as policy, what are the consequences of this decision?

29 Our first concern is for the environment. The central concern of this year’s Glasgow COP Conference was to restrain the increase in Co2 emissions to 1.5% of the pre-industrial level. At the conclusion, the most optimistic answer to the question ‘Is 1.5 alive?’ was that it was on life support.


30 The National Planning Policy Framework (NPPF) states at para 7 that the purpose of the planning system is to contribute to the achievement of sustainable development, sustainable development being defined as meeting the needs of the present without compromising the ability of future generations to meet their own needs.

31 The current continual occurrence of floods, fires, droughts and destructive storms over much of the globe already severely restricts the ability of many of even this generation to meet their own needs, and it can scarcely be doubted that any increase in Co2 emissions over 1.5% will further compromise present and future generations and must therefore inevitably be characterised as unsustainable.


32 Para 2 of the NPPF states inter alia that planning policies must reflect international obligations, which we believe includes the undertakings make by the UK at the Glasgow COP Conference. Within the UK, the carbon budget set out in the legislation of June 2021 requires that emissions are reduced by 63% by 2035. The need to achieve the true purpose of the planning system, to contribute to sustainable development, must mean that in the current situation there is a particularly urgent duty on planning authorities to take the strongest and most rigorous means of ensuring that the carbon footprint of any development, whether arising from its nature or its extent, must be kept to its absolute minimum.

33 The present proposal is that 44,400 new homes are to be constructed over the 20 years to 2041. According to an article by Sir Mike Berners-Lee in the Guardian on 14/10/2010 to build a simple two-bedroom cottage at that time, ie the production of the materials and the construction of the building, would create 80 metric tonnes of embodied Co2, and the building would then emit 2,5 metric tonnes of Co2 annually.


34 The UK Green Building Council’s 2021 ‘Construction Carbon’ report says that since that time, “efforts to improve the energy of buildings has seen an impact on operational Co2 emissions while embodied carbon (ie that created by producing the construction materials and by the building process itself) have remained stubbornly consistent at 50MtCo2e.”

35 According to Hearn 1 above, the Government Standard Method of calculating housing need would produce a figure of 34,860 new homes. The current proposal is to build 44,400 new homes, ie 9,640 additional to the Standard Method figure. If this were rounded up in practice to 10,000 additional homes, a conservative estimate of the additional Co2 created can be calculated on the assumption that since 2010 the amount of embodied carbon could be reduced by 25% and of operational carbon by 50%.

36 The above figures are included for illustration and to promote further research. On this basis, however, a conservative estimate would be that 600,000 metric tonnes of Co2 would be produced by the initial building process and 12,500 metric tonnes would be produced annually, pro rata to construction up to 2041 and in full thereafter.

37 To put this into context, the whole of the City of Cambridge produced only 489,000 metric tonnes of Co2 emissions in 2019, with South Cambridgeshire producing 1,213,000 metric tonnes – a total of 1,702,000 metric tonnes (Data Tables – UK Local and Regional Co2 Emissions published by the Department for Business and Energy June 2021). An annual addition of 12,500 metric tonnes would increase this total to 1,714,500 metric tonnes, cancelling out almost two years of carbon reductions over the Greater Cambridge area.


Risks and uncertainties underlying the present proposals

38 The Councils’ Topic Paper 2 on Climate Change published in September 2021 refers at p 9 to s 182 of the Planning Act of 2008 which places a duty to ‘secure the contribution of development and the use of land in the mitigation of climate change’. It also acknowledges at p 10 the target set under the Climate Change Act as amended in May 2019 for reductions of emissions to net zero by 2050. We believe that the earlier duty to secure the ‘contribution’ of the development to the ‘mitigation’ of climate change is now far too weak to ensure the action needed to deal with the real danger that climate change now poses, and would to that extent be incompatible with the legal duty created by the target set by the May 2019 amendments to the Climate Change Act.

39 The paper refers to the March 2021 report of the Cambridge and Peterborough commission on Climate Change. In their initial recommendations they note at p 11 that,
“…the region’s emissions are approximately 25% higher per person than the UK average, and that if the area continues on this trajectory, we will only have six years remaining before we have exhausted our ‘allowed’ share on emissions to 2050. Urgent action is therefore required, with the report noting that local government powers in transport and planning, amongst others, will be critical in driving transformation.”

40 It is incumbent on the Greater Cambridge as a planning authority to be aware that the urgency of our situation with regard to climate change has altered significantly since 2008 and now to readily acknowledge the implications of the later legislation.

41 Most of the language in the Topic Paper itself however appears to be inspirational rather than informative. The environmental principles for the Oxford-Cambridge Arc include ‘working towards’ a target of net zero by 2040. New settlements will ‘contribute towards the achievement’ of net environmental and net carbon zero. There is a ‘vision’ for Cambridge to be net carbon zero by 2030, ‘subject to’ actions by Government, the regulators and industry. On p 16 it is noted that, “ … with net zero carbon comes the need to change the metrics used to define the performance of buildings. It is clear … that buildings constructed using current metrics are not performing as they should and that a new approach is needed …”


42 Topic Paper 2 dealing with climate change appears to some extent to be a document of signposts rather than milestones. The signposts are useful and the result of good work, but are of questionable value as a basis for policy. Section 4.5 does set out many specific technical requirements for operational emissions, in particular the requirement that all new domestic and non-domestic buildings ‘should achieve’ a space heating demand of 15 – 20 kWh per meter squared a year in accordance with the CCC’s ‘Housing Fit for the Future’ report. However wording such as ‘should achieve’ indicates that the aspirational element is still present and in relation to embodied carbon the document simply states at page 14 that ‘consideration will be given’ to the carbon associated with the construction process, and acknowledges at page 17 that,

“ … there are no nationally defined targets for reducing the embodied carbon associated with new developments. A further challenge faced by the industry is a lack of consistent measurement, leading to mis-aligned benchmarks, project targets and claims.”

43 This uncertainty with regard to fundamental environmental considerations is of course also of great concern in the case of water, in relation both to the possible – even probable - inadequacy of supply and also to the inevitable damage to the County’s system of chalk streams and associated wildlife. As is highlighted in the Executive Summary to the GCLP: First Proposals (Preferred Options) (Regulation 18) consultation paper:

“The First Proposals make clear that the proposed development strategy is contingent upon there being clear evidence that water supply challenges can be addressed before the plan moves to the draft plan stage.”

Absence of usual benefits of development

44 With regard to the proposed developments, the Hearn 1 report acknowledges at para 3.68 that as far as unemployment is concerned, “for the purposes of this report it has been assumed that there are no changes in the number of people who are unemployed moving forward from 2020 to 2041”.

45 It is also argued that the housing situation in Greater Cambridge is subject to the pressures of a speculative bubble which is of no benefit to the majority of ordinary residents and that the proposed development offers little in the way of relief because of the distorting effects of speculation.

46 As the Hearne HER Report makes clear at para 3.4, the ‘affordability’ step in the Standard Method already makes provision for increase in housing to the point where dwellings become affordable by applying a formula which relates the local median price of homes to median workplace earnings.


47 Further, the Report states in relation to employment figures at para 3.68 that, “The analysis shows a clear increase in unemployment until about 2010 -11 and that since then the number of unemployed people was back close to (or below) the level observed in 2004. This would indicate that there may be limited scope for further improvements and for the purpose of analysis in this report it has been assumed that there are no changed in the number of people who are unemployed moving forward from 2020 to 2041.

48 It is therefore difficult to see that any departure from the Standard Method of assessing housing need can be justified either in relation to any improvement in housing provision for the existing or predicted population or in relation to any reduction in unemployment figures in the joint planning area.

The decision facing the planning authority

49 The Greater Cambridge as a planning authority is now in an unusual and critically important position. It has to make its decisions where we can see an unprecedented risk of harm to the environment but can also see unprecedented opportunity for nurturing scientific developments which can bring huge benefits to human society in the UK and the world.

50 There is a third factor however which complicates the situation and makes decisions and policy implementation still more difficult. This is the development, in parallel with the expansion of scientific and technical research in the area, of a speculative property bubble, as a result of which property in Cambridge can become, and in many cases has become, simply a vehicle for opportunistic speculative investment, of no benefit either to ordinary residents or to the scientific community. Construction and development of property for this purpose contributes to the damage to the environment without furthering or supporting scientific and technical research.

51 In light of this, the aim must be to influence future job creation in such a way as to achieve the best possible outcome, not only in terms of the prosperity and wellbeing of the planning area itself but also in terms of a proper contribution to the prosperity and wellbeing of the UK as a whole.


52 The challenge now facing the Greater Cambridge planning authority is, in the current critical post-COP 21 situation, to balance these three factors so as to achieve the optimum outcome in relation to the economic, social and environmental objectives as set out at para 8 of the National Planning Policy Framework (NPPF).

53 It would appear, therefore, that interests of the scientific and technological and also the environmental factors would be better promoted, and the influence of the third factor – the speculative property bubble – restrained, by a decision to take the following measures:


i. To ensure that the total of existing unoccupied dwellings (above the normal percentage to allow for turnover) was established and included in the ‘already in the pipeline’ figure in calculating the number of new dwellings required, and to explore all possible means, by incentive, penalty or otherwise, of ensuring that such unoccupied dwellings are let or sold within a reasonable time, and

ii. To set the requirement for the number of additional new dwellings above that set by the application of the Government Standard Method at the number of new dwellings directly and specifically related to identified and authentic scientific and research undertakings in the Greater Cambridge planning area, with the future sale of such dwellings restricted by covenant or otherwise to purchasers primarily employed in such undertakings.


54 The effect of the first measure would be to allow the most realistic figure to be arrived at for the number of new dwellings required, while the second measure would operate to restrain unjustified speculative building while at the same time sustaining scientific and technological research and development. The fact that new employees in scientific and technical undertakings could be properly housed outside the conventional housing market would of course to that extent reduce the number of buyers in the conventional market and so operate to increase affordability.

55 The second measure would appear to be appropriate in relation to developments such as the Addenbrooke’s Hospital and Cambridge Biomedical Campus, Brabraham Research Campus, the Wellcome Trust Genome Campus, Granta Park, Sagentia Research Park, Melbourne Science Park, St John’s Innovation Park and the Cambridge Science Park.


56 A policy of allowing certain new dwellings only if they are to be occupied by people employed in a certain industry would be similar to existing policies in relation to new dwellings for employees in the agricultural industry, and would be amply justified by the particular situation in the Greater Cambridge area relation to the need to promote local scientific industries in the critical context of current climate change.

57 Planning conditions used to achieve the purpose of the second measure set out at (ii) above would we believe be based on considerations which would satisfy the test as material considerations established in Newbury DC v SoS for the Environment [1981] HL and in R (Wright) v Forest of Dean DC and Resilient Energy Severndale Ltd [2019] UKSC.

58 It must be the case that permissibility of the developments in all proposed sites in the joint planning area is contingent upon this, as even where a particular development itself is found to meet all relevant planning criteria, its permissibility will automatically fall into question if the overall increase in number of dwellings over the period to 2041 cannot be justified in planning terms.


Images – inspiring or misleading? The underlying flaw in the proposals

59 In its public presentation of the current proposals, the Planning Authority has used a striking image which appears in the Opus consultation document ‘Greater Cambridge 2041’ above the words ‘Our Vision’, on the front of the Smart Survey document in the First Proposals and in the Summary of the GCLP Issues and Options 2020. It is of a tree with four areas of leafy vegetation, the top one being ‘Climate Change’, the second ‘Biodiversity & Green Spaces’, the third ‘Wellbeing & Social Inclusion’ and the fourth ‘Great Places’.

60 There are two messages conveyed by the tree image. The first is that the tree – which symbolises the proposals – will bring four benefits, ie an improvement of our position with regard to climate change, provision biodiversity and green spaces, the fostering of wellbeing and social inclusion and the creation great places. The second message conveyed by the tree is that the tree, ie the proposals, is/are the essential means by we can achieve these benefits.

61 The image is misleading because either we already have the benefits are promised, without the implementation of the proposals, or they can be achieved by other simpler and less destructive means. In fact the proposals will degrade, to an indeterminate extent, our position with regard to climate change. The biodiversity and green spaces already exist. The ‘great places’ already exist and the proposals will to an indeterminate extent urbanise them. Any improvement in wellbeing and social inclusion can and should be achieved by simpler and more practical measures which operate on a smaller scale and answer to the real needs of the people they are meant to serve, one example being community and mutual schemes to reduce unemployment in the Arbury ward which the Hearn 1 report says will not be changed by the proposals.

62 It is of course to be welcomed that any development will have well-constructed, well- designed buildings, and will be planned in such a way as to promote and sustain wellbeing and a thriving local community. It would however be wrong to attempt to justify the proposals in these terms, because the benefits shown on the tree either already exist, and would be inevitably diminished by the proposals, or they can be achieved by other simpler and less otherwise harmful means.

63 The only justification for the construction of more dwellings than the Standard Method requires is the need to foster and sustain the remarkable advances in life sciences and healthcare led by the particular strength of scientific and technical expertise in Cambridge and the surrounding area. The Planning authority should use all its powers to ensure that the number of additional dwellings is sufficient for this purpose but should not go beyond it, as to do so would inevitably, to a greater or lesser extent, imperil our position with regard to climate change at this critical time.

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.

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.

Introduction
Thank you for consulting Central Bedfordshire Council (CBC) on the first proposals consultation for the Greater Cambridge Local Plan 2041. Please accept this letter as our formal response. We welcome the opportunity to respond to the proposals in this consultation and look forward to continuing the good working relations that CBC has already forged with the two substantive authorities. We have provided some comments below on the consultation documentation which we hope are useful. Please do not hesitate to contact us if you have any further questions.

General Comments on Strategy

Overall, the Council supports the approach you have taken in terms of undertaking a joint local plan to ensure a consistent approach to planning and building across both Cambridge City Council and South Cambridgeshire District Council up to 2041.

We support the proposed Vision for the Greater Cambridge Plan especially as it places climate impacts at the heart of key decisions. It states that Greater Cambridge will be a place where a big decrease in your climate impacts comes with a big increase in the quality of everyday life for all your communities. It also promotes new development minimising carbon emissions and reliance on the private car; creating thriving neighbourhoods with the variety of jobs and homes you need; increasing nature, wildlife and green spaces; and safeguarding your unique heritage and landscapes. CBC considers this to be a laudable, succinct overarching Vision that we hope you will be able to carry through to effective policy and decision-making on the ground.

CBC considers that the proposed strategy outlined within the First Proposals could help ensure that Greater Cambridge makes a valuable contribution to the Oxford to Cambridge Arc and to the overall delivery of the Government’s ambitious growth aspirations. However, the Council considers that it would be useful to include reference to the emerging Arc Spatial Framework, identifying that alongside the NPPF, this will set the overarching strategic framework for the area with which all local plans within the Arc must accord. CBC would be keen to understand the timescales for the delivery of the Greater Cambridge Plan and how the emerging Spatial Framework will be taken into consideration to inform future iterations of the plan.

We appreciate that the Plan is at an early stage of development, and at the current time you are considering locations that could be delivered alongside allocated sites being carried forward from the adopted 2018 Local Plans for Cambridge and South Cambridgeshire, as well as sites which already have planning permission.

We note that you are proposing to meet in full your objectively assessed needs of 44,400 new homes to 2041, which is supported by CBC and is necessary to ensure needs can be met across the area.

CBC recognises that Cambridge has seen significant economic and jobs growth in recent years and that there is an ambition to maintain this direction of growth as the impacts of the recent pandemic subside. As stated in our comments made in response to your Issues and Options Consultation in February 2020, we would not support a level of jobs growth that could detrimentally impact upon the ability of neighbouring authorities, such as Central Bedfordshire, to meet and deliver their own economic ambitions and growth aspirations. CBC therefore supports the housing numbers proposed to meet the OAN and the identified buffer and welcomes the move away from the higher job number which were put forward in your Issues and Options consultation. We agree that the higher jobs forecast previously considered would not be the most appropriate scenario to pursue. Overall, CBC considers that the proposed level of housing of 44,400 new homes and complementary economic growth of 58,500 new jobs across all sectors including business, retail, leisure, education and healthcare, is an appropriate level of growth to deliver for over the plan period.

The First Proposals have suggested 19 new possible locations that might be suitable for additional development to meet your needs across the Greater Cambridge area up to 2041. Overall, CBC supports the proposed approach taken to the geographical spread of these sites and welcomes the inclusion of sites in the most sustainable locations around the Cambridge urban area and on the outskirts of the City, where existing and future residents can take most advantage of the proximity to jobs and services using public transport and active travel options. The proposals to direct development to where it has the least climate impact, where active and public transport is the natural choice is logical and fully supported.

It is noted that the consultation material suggests that the majority of your objectively assessed need can be provided for in the core preferred strategic sites of North East Cambridge, Cambridge East and Cambourne. This approach is supported as the locations will reduce potential climate impacts through the delivery of well connected, sustainable, compact development where active and sustainable travel can be maximised.

CBC have not provided detailed comments on all of the proposed 19 sites included within the consultation material but note the proposals for new strategic scale development at Cambourne which lies in close proximity to Central Bedfordshire. It is noted that in total, there are 3 development sites proposed for Cambourne - two of these are existing allocations; Cambourne West which has capacity for 2,590 units and Bourn Airfield which has capacity for 2,460 units, alongside a new proposed broad location for growth at Camborne - expected to deliver 1,950 homes.

CBC recognises that whilst a final decision has not yet been announced, the preferred East West Rail route between Bedford and Cambridge will likely result in a new stopping station at Cambourne and that this will transform the area, maximising sustainable opportunities for growth. Whilst we support the opportunities that the proposed new station would potentially bring, CBC would suggest that any future transport impact assessments and traffic modelling associated with the proposals should consider the cumulative impacts of both existing and proposed development at Cambourne and any implications for the wider area, including potential impact upon the strategic and local road network within Central Bedfordshire. It is likely that there will be cumulative impacts from growth at Cambourne on communities within CBC related to an increase in demand on the A1, particularly if / when the A428 dualling and Black Cat works are carried out, and also the more minor roads through areas like Potton, Sandy, Biggleswade. Whilst outside of the Greater Cambridge plan area, the capacity of the A1 in this area is already a key concern that affects a much wider area and must be considered carefully and comprehensively when decisions are being made in relation to future growth.

We would, therefore, welcome further engagement to understand the scale of those impacts and their likely implications for Central Bedfordshire communities as the work on the local plan and the sites themselves, progresses. We would welcome being involved in early engagement with National Highways in relation to these impacts. We would also be keen to look at opportunities to secure sustainable links (via public transport) between CBC and the development areas to the west and south of the Greater Cambridgeshire area.

As noted above, whilst a formal decision is yet to be announced in relation to EWR between Bedford and Cambridge, or indeed the location of a new stopping station at either Tempsford or to the south of St Neots, CBC consider it essential that the Greater Cambridge Plan considers the wider context of strategic growth within the Arc, particularly in terms of future connectivity opportunities that will undoubtedly arise as proposals within neighbouring authority areas emerge. Your approach to enabling some development within smaller villages is supported as this will support rural services and the vitality and viability of villages and their shops and services contributing to overall sustainability. We appreciate that it is unsustainable to encourage high levels of growth where car travel predominates and that therefore, in smaller villages you will continue to support infill development and affordable housing on suitable sites only. This approach is supported, especially given the very rural nature of the areas close to the Central Bedfordshire border.

The 7 Themes
We welcome the approach taken in this consultation to identify 7 key themes and we have provided some high-level comments on each of them below. It is understood that each of the themes will influence how you will plan homes, jobs and infrastructure and ultimately where growth will be directed. In our previous response to the Issues and Options stage of consultation (February 2020) we suggested that “connectivity” both within and beyond the Greater Cambridge area should perhaps be considered as an additional theme. Whilst we note this suggestion has not been taken onboard, CBC considers that connectivity is the ‘golden thread’ that runs through all the key themes and could potentially be referenced as such within the Greater Cambridge Plan.

Climate Change
We support your aim to help Greater Cambridge to transition to net zero carbon by 2050 through a number of comprehensive measures including ensuring that development is sited in places that help to limit carbon emissions, is designed to the highest achievable standards for energy and water use and is resilient to current and future climate risks. It is clear that responding to climate change has influenced the shape of the plan as an important factor in determining where future development should be located and how it should be built. CBC would be keen to have future conversations to share experiences and to understand how net zero carbon can be achieved in terms of viability, and to explore how this can be monitored to ensure the approach is successful. In terms of detailed policy, Policy GP/QD could benefit by also referring to building orientation to maximise the opportunities for renewables.

Biodiversity and Green Spaces
We support your aim for biodiversity and green space policies to increase and improve your extensive network of habitats for wildlife and green spaces for people, ensuring that development leaves the natural environment better than it was before. We also welcome confirmation that the Oxford to Cambridge Arc Environmental Principles have informed your approach to this theme, in particular, we welcome and support the ambitious policy to require 20% Biodiversity Net Gain. As this will be an issue for all Local Authorities within the Arc, CBC would also be keen to discuss how this could be delivered and the impacts this might have not only on site viability, but
the delivery of other key services and facilities across the Arc .

Wellbeing and Social Inclusion
We support your aim of helping people in Greater Cambridge to lead healthier and happier lives ensuring everyone benefits from the development of new homes and jobs.

Great Places
We support your aim for the delivery of great places through policies that sustain the unique character of Cambridge and South Cambridgeshire and compliment the area with beautiful and distinctive new development, creating a place where people will want to live, work and play.
The themes from the Cambridgeshire Quality Charter for Growth covering the four “Cs” of Community, Connectivity, Climate and Character is a sensible approach consistent with the National Model Design Code.

Jobs
CBC supports the aim of your proposed jobs policies in terms of encouraging a flourishing and mixed economy which includes a wide range of jobs while maintaining the areas global reputation for innovation. The Council considers the policies are positive and forward thinking in the current climate in that they seek to reflect how the approach to working environments is changing, by supporting remote working and improving facilities on employment parks.
We support the inclusion of a remote working policy but consider that it could be strengthened to refer to the provision of home office space in new dwellings as the emphasis is currently on the delivery of external hubs or extensions of existing dwellings.

Homes
As commented above, the Council supports the proposed strategy to plan for and deliver enough housing to meet your objectively assessed needs, including significant amounts of affordable housing and a mix of tenures to suit your diverse community’s needs. The proposed policy requiring 40% affordable housing in new developments is particularly supported.

Infrastructure
We support the approach taken that the relationship between jobs and homes and sustainable transport opportunities has been a key consideration and influence of the development strategy proposed. Recognising that infrastructure is not limited to the provision of new roads, CBC also supports the recognition for the need to consider and plan for water, energy and digital networks, and health and education and cultural facilities in the right places and at the right times to ensure your growing communities are supported. Looking to the future, your policies on electric vehicle charging points and digital infrastructure will be key given the need to move away from carbon-based vehicle fuels and the shift to homeworking that has been accelerated by the pandemic. We also note that whilst there is an objective for Air Quality within the Sustainability Appraisal, there is no objective included for Transport and Access.

We welcome this opportunity to comment on this latest stage of your development plan proposals and largely offer our support to the approach you have taken. We also appreciate how you have digitally presented and structured the documentation in order to make it as accessible as possible to everyone. The use of maps and diagrams throughout the document is an effective way of setting out the context and portraying the information within the text. In addition, the ability to explore the documentation through the “themes” and “maps” is a particularly helpful way of organising the consultation.
I hope you find these comments useful and look forward to continued engagement as your plan progresses.

Introduction
Thank you for consulting Central Bedfordshire Council (CBC) on the first proposals consultation for the Greater Cambridge Local Plan 2041. Please accept this letter as our formal response. We welcome the opportunity to respond to the proposals in this consultation and look forward to continuing the good working relations that CBC has already forged with the two substantive authorities. We have provided some comments below on the consultation documentation which we hope are useful. Please do not hesitate to contact us if you have any further questions.

General Comments on Strategy

Overall, the Council supports the approach you have taken in terms of undertaking a joint local plan to ensure a consistent approach to planning and building across both Cambridge City Council and South Cambridgeshire District Council up to 2041.

We support the proposed Vision for the Greater Cambridge Plan especially as it places climate impacts at the heart of key decisions. It states that Greater Cambridge will be a place where a big decrease in your climate impacts comes with a big increase in the quality of everyday life for all your communities. It also promotes new development minimising carbon emissions and reliance on the private car; creating thriving neighbourhoods with the variety of jobs and homes you need; increasing nature, wildlife and green spaces; and safeguarding your unique heritage and landscapes. CBC considers this to be a laudable, succinct overarching Vision that we hope you will be able to carry through to effective policy and decision-making on the ground.

CBC considers that the proposed strategy outlined within the First Proposals could help ensure that Greater Cambridge makes a valuable contribution to the Oxford to Cambridge Arc and to the overall delivery of the Government’s ambitious growth aspirations. However, the Council considers that it would be useful to include reference to the emerging Arc Spatial Framework, identifying that alongside the NPPF, this will set the overarching strategic framework for the area with which all local plans within the Arc must accord. CBC would be keen to understand the timescales for the delivery of the Greater Cambridge Plan and how the emerging Spatial Framework will be taken into consideration to inform future iterations of the plan.

We appreciate that the Plan is at an early stage of development, and at the current time you are considering locations that could be delivered alongside allocated sites being carried forward from the adopted 2018 Local Plans for Cambridge and South Cambridgeshire, as well as sites which already have planning permission.

We note that you are proposing to meet in full your objectively assessed needs of 44,400 new homes to 2041, which is supported by CBC and is necessary to ensure needs can be met across the area.

CBC recognises that Cambridge has seen significant economic and jobs growth in recent years and that there is an ambition to maintain this direction of growth as the impacts of the recent pandemic subside. As stated in our comments made in response to your Issues and Options Consultation in February 2020, we would not support a level of jobs growth that could detrimentally impact upon the ability of neighbouring authorities, such as Central Bedfordshire, to meet and deliver their own economic ambitions and growth aspirations. CBC therefore supports the housing numbers proposed to meet the OAN and the identified buffer and welcomes the move away from the higher job number which were put forward in your Issues and Options consultation. We agree that the higher jobs forecast previously considered would not be the most appropriate scenario to pursue. Overall, CBC considers that the proposed level of housing of 44,400 new homes and complementary economic growth of 58,500 new jobs across all sectors including business, retail, leisure, education and healthcare, is an appropriate level of growth to deliver for over the plan period.

The First Proposals have suggested 19 new possible locations that might be suitable for additional development to meet your needs across the Greater Cambridge area up to 2041. Overall, CBC supports the proposed approach taken to the geographical spread of these sites and welcomes the inclusion of sites in the most sustainable locations around the Cambridge urban area and on the outskirts of the City, where existing and future residents can take most advantage of the proximity to jobs and services using public transport and active travel options. The proposals to direct development to where it has the least climate impact, where active and public transport is the natural choice is logical and fully supported.

It is noted that the consultation material suggests that the majority of your objectively assessed need can be provided for in the core preferred strategic sites of North East Cambridge, Cambridge East and Cambourne. This approach is supported as the locations will reduce potential climate impacts through the delivery of well connected, sustainable, compact development where active and sustainable travel can be maximised.

CBC have not provided detailed comments on all of the proposed 19 sites included within the consultation material but note the proposals for new strategic scale development at Cambourne which lies in close proximity to Central Bedfordshire. It is noted that in total, there are 3 development sites proposed for Cambourne - two of these are existing allocations; Cambourne West which has capacity for 2,590 units and Bourn Airfield which has capacity for 2,460 units, alongside a new proposed broad location for growth at Camborne - expected to deliver 1,950 homes.

CBC recognises that whilst a final decision has not yet been announced, the preferred East West Rail route between Bedford and Cambridge will likely result in a new stopping station at Cambourne and that this will transform the area, maximising sustainable opportunities for growth. Whilst we support the opportunities that the proposed new station would potentially bring, CBC would suggest that any future transport impact assessments and traffic modelling associated with the proposals should consider the cumulative impacts of both existing and proposed development at Cambourne and any implications for the wider area, including potential impact upon the strategic and local road network within Central Bedfordshire. It is likely that there will be cumulative impacts from growth at Cambourne on communities within CBC related to an increase in demand on the A1, particularly if / when the A428 dualling and Black Cat works are carried out, and also the more minor roads through areas like Potton, Sandy, Biggleswade. Whilst outside of the Greater Cambridge plan area, the capacity of the A1 in this area is already a key concern that affects a much wider area and must be considered carefully and comprehensively when decisions are being made in relation to future growth.

We would, therefore, welcome further engagement to understand the scale of those impacts and their likely implications for Central Bedfordshire communities as the work on the local plan and the sites themselves, progresses. We would welcome being involved in early engagement with National Highways in relation to these impacts. We would also be keen to look at opportunities to secure sustainable links (via public transport) between CBC and the development areas to the west and south of the Greater Cambridgeshire area.

As noted above, whilst a formal decision is yet to be announced in relation to EWR between Bedford and Cambridge, or indeed the location of a new stopping station at either Tempsford or to the south of St Neots, CBC consider it essential that the Greater Cambridge Plan considers the wider context of strategic growth within the Arc, particularly in terms of future connectivity opportunities that will undoubtedly arise as proposals within neighbouring authority areas emerge. Your approach to enabling some development within smaller villages is supported as this will support rural services and the vitality and viability of villages and their shops and services contributing to overall sustainability. We appreciate that it is unsustainable to encourage high levels of growth where car travel predominates and that therefore, in smaller villages you will continue to support infill development and affordable housing on suitable sites only. This approach is supported, especially given the very rural nature of the areas close to the Central Bedfordshire border.

The 7 Themes
We welcome the approach taken in this consultation to identify 7 key themes and we have provided some high-level comments on each of them below. It is understood that each of the themes will influence how you will plan homes, jobs and infrastructure and ultimately where growth will be directed. In our previous response to the Issues and Options stage of consultation (February 2020) we suggested that “connectivity” both within and beyond the Greater Cambridge area should perhaps be considered as an additional theme. Whilst we note this suggestion has not been taken onboard, CBC considers that connectivity is the ‘golden thread’ that runs through all the key themes and could potentially be referenced as such within the Greater Cambridge Plan.

Climate Change
We support your aim to help Greater Cambridge to transition to net zero carbon by 2050 through a number of comprehensive measures including ensuring that development is sited in places that help to limit carbon emissions, is designed to the highest achievable standards for energy and water use and is resilient to current and future climate risks. It is clear that responding to climate change has influenced the shape of the plan as an important factor in determining where future development should be located and how it should be built. CBC would be keen to have future conversations to share experiences and to understand how net zero carbon can be achieved in terms of viability, and to explore how this can be monitored to ensure the approach is successful. In terms of detailed policy, Policy GP/QD could benefit by also referring to building orientation to maximise the opportunities for renewables.

Biodiversity and Green Spaces
We support your aim for biodiversity and green space policies to increase and improve your extensive network of habitats for wildlife and green spaces for people, ensuring that development leaves the natural environment better than it was before. We also welcome confirmation that the Oxford to Cambridge Arc Environmental Principles have informed your approach to this theme, in particular, we welcome and support the ambitious policy to require 20% Biodiversity Net Gain. As this will be an issue for all Local Authorities within the Arc, CBC would also be keen to discuss how this could be delivered and the impacts this might have not only on site viability, but
the delivery of other key services and facilities across the Arc .

Wellbeing and Social Inclusion
We support your aim of helping people in Greater Cambridge to lead healthier and happier lives ensuring everyone benefits from the development of new homes and jobs.

Great Places
We support your aim for the delivery of great places through policies that sustain the unique character of Cambridge and South Cambridgeshire and compliment the area with beautiful and distinctive new development, creating a place where people will want to live, work and play.
The themes from the Cambridgeshire Quality Charter for Growth covering the four “Cs” of Community, Connectivity, Climate and Character is a sensible approach consistent with the National Model Design Code.

Jobs
CBC supports the aim of your proposed jobs policies in terms of encouraging a flourishing and mixed economy which includes a wide range of jobs while maintaining the areas global reputation for innovation. The Council considers the policies are positive and forward thinking in the current climate in that they seek to reflect how the approach to working environments is changing, by supporting remote working and improving facilities on employment parks.
We support the inclusion of a remote working policy but consider that it could be strengthened to refer to the provision of home office space in new dwellings as the emphasis is currently on the delivery of external hubs or extensions of existing dwellings.

Homes
As commented above, the Council supports the proposed strategy to plan for and deliver enough housing to meet your objectively assessed needs, including significant amounts of affordable housing and a mix of tenures to suit your diverse community’s needs. The proposed policy requiring 40% affordable housing in new developments is particularly supported.

Infrastructure
We support the approach taken that the relationship between jobs and homes and sustainable transport opportunities has been a key consideration and influence of the development strategy proposed. Recognising that infrastructure is not limited to the provision of new roads, CBC also supports the recognition for the need to consider and plan for water, energy and digital networks, and health and education and cultural facilities in the right places and at the right times to ensure your growing communities are supported. Looking to the future, your policies on electric vehicle charging points and digital infrastructure will be key given the need to move away from carbon-based vehicle fuels and the shift to homeworking that has been accelerated by the pandemic. We also note that whilst there is an objective for Air Quality within the Sustainability Appraisal, there is no objective included for Transport and Access.

We welcome this opportunity to comment on this latest stage of your development plan proposals and largely offer our support to the approach you have taken. We also appreciate how you have digitally presented and structured the documentation in order to make it as accessible as possible to everyone. The use of maps and diagrams throughout the document is an effective way of setting out the context and portraying the information within the text. In addition, the ability to explore the documentation through the “themes” and “maps” is a particularly helpful way of organising the consultation.
I hope you find these comments useful and look forward to continued engagement as your plan progresses.

Swavesey Parish Council Greater Cambridge Local Plan First Proposals: Consultation response 14th December 2021

Swavesey Parish Councillors have examined the proposals in the draft plan and are extremely concerned about the impact of the proposed growth on flooding and whether there is adequately planned infrastructure. Parish Councillors are also very concerned over the level of housing growth proposed and how the infrastructure, particularly in South Cambs, will cope, such as roads, increase in traffic, social services and health provision. Specific concerns are detailed below.

Flooding
Flooding in Cambridgeshire is increasing. The instances of prolonged heavy downpours of rain and the inability of the existing foul and surface water infrastructure to cope with this deluge of water is extremely concerning. Especially within village communities. Within the current growth of housing development in Cambridgeshire, the foul water infrastructure is already nearing capacity and the increased pressure on this will be unsustainable. The infrastructure required to deal with increased foul and surface water resulting from current developments is not sufficient. Foul water is being pumped long distances to existing treatment works and then treated water pumped through to the river via villages and communities which are miles away from the new developments. The flood risk in doing this increases for communities which are not in the new development areas. Swavesey in particular is having to cope with huge increases in treated water flowing through its drain system to the River Gt Ouse from development in Cambourne, Northstowe and yet to come from Bourn airfield site. These developments continue to increase and all of that water puts excessive flood risk on Swavesey.

Surface water management.
The existing surface water system is failing and often unable to cope with the changes we are experiencing in weather as well as increased development pushing more water into the system (rather than soaking into greenfield sites). This is happening now in Swavesey where properties have flooded due to surface and foul water systems unable to cope within the last year. Exacerbated by new development in the village. Proposals to continue to develop greenfield sites and increase housing and business development will increase flood risk. Proposals for new business development at land south of the A14 Cambridge Services (promoted by JAYNIC) raises strong concerns by Swavesey Parish Council. This will create increased foul and surface water flows into the Swavesey system on top of those already mentioned above. This is just not sustainable.

Water supply
Councillors are concerned about the level of housing being proposed and how those houses will be supplied with fresh water. The draft Local Plan states that ‘new sources of water supply, including potential new reservoirs, are being developed but won’t be built quickly enough to supply housing when it is needed. Without speeding up that process and additional interim action, development levels may have to be capped to avoid unacceptable harm to the environment, including the region’s important chalk streams. This may lead to housing in the area becoming even more unaffordable so that those who work in Greater Cambridge may have to commute from further afield, increasing carbon emissions and congestion. We are hoping for quick and decisive action on this from central government and the water industry.’ Additional information states that development won’t go ahead without a resolution to the water supply issue. We strongly urge the authorities to maintain this commitment.

Health and social care provision
Health and care services in Cambridgeshire are under severe pressure as they try to recover from the pandemic. There is a chronic shortage of workforce, particularly GPs, which means that waiting lists for consultations, treatment and care are long and increasing. We are concerned that the proposed increases in population will put more pressure on these already fragile and underfunded services. The current system for increasing provision is fragmented and frequently does not result in any increase.

Traffic and travel
Councillors are also concerned about transport and roads to and from new development sites. In Cambridgeshire if the new East-West Rail goes ahead a new rail station will be built at Cambourne. This will increase the traffic on the roads to/from Cambourne and many of these through and around the villages to the north cannot cope with existing traffic levels let alone increased levels. The funding to Cambridgeshire County Council for general highway maintenance cannot cope with existing demands.

Proposals for business development at land south of the A14 Cambridge Services will create increased traffic, particularly of HGVs in this area and around the already busy Swavesey A14 junction. Swavesey Parish Council has raised concerns with JAYNIC the proposer of the site, however these concerns must be considered within this Local Plan proposal and by Cambridgeshire Highways as the impact the increased traffic will have, will affect villages surrounding this site. This site is in addition to the already being developed business site at Bar Hill and another proposed business site at Slate Hall Farm, off the A14 and as well as the Northstowe development close by. The Parish Council cannot see how all of this is going to be sustainable in this area.

Quality of consultation information
We note the complexity of the information contained in the Local Plan and would observe that it is not easy for local people to understand the proposals sufficiently to meaningfully comment. We would ask that future consultations use simpler language and format. Testing readability of materials with non-planning people could help with this.

Compendium of Environment Agency Comments

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Thank you for your email below regarding the Greater Cambridge Local Plan Consultation

The Coal Authority is a non-departmental public body sponsored by the Department of Business, Energy & Industrial Strategy. As a statutory consultee, the Coal Authority has a duty to respond to planning applications and development plans in order to protect the public and the environment in mining areas.

As you are aware, Cambridge City Council and South Cambridgeshire District Council lies outside the defined coalfield and therefore the Coal Authority has no specific comments to make on your Local Plans / SPDs etc.

In the spirit of ensuring efficiency of resources and proportionality, it will not be necessary for the Council to provide the Coal Authority with any future drafts or updates to the emerging Plans. This letter can be used as evidence for the legal and procedural consultation requirements at examination, if necessary.

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,

Anthony and Rosalind Jones

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.

Dear Sir/ Madam,

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.

Dear Sir/ Madam,

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 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.

Please keep my name and address confidential.

Dear Sir/ Madam,

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 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.

Please keep my name and address confidential.

Dear Sir/ Madam,

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.

Please keep my name and address confidential.

Dear Sir/ Madam,

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.

Please keep my name and address confidential.

Dear Sir/ Madam,

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 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,

Regards

Dear Sir/ Madam,

I am writing in a personal capacity to strongly object to the Draft Local Plan. Please confirm that you have received my objection, and that this individual submission is noted, recorded, counted and made available.

I object 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

I also want to add some general thoughts, that really set the scene of the problems we are facing, and frankly the proposers of the draft plan seem to be ignoring.
Antonio Gutuerres, the Secretary General of the UN has issued many warnings. At the start of his 'state of the planet' speech, 2nd December 2020, he said:
“Dear friends,
Humanity is waging war on nature.
This is suicidal.
Nature always strikes back -- and it is already doing so with growing force and fury.
Biodiversity is collapsing. One million species are at risk of extinction.
Ecosystems are disappearing before our eyes.”
The proposed draft local plan does not seem to take any notice of those words or his recent warning; that we are at ‘code red for humanity’. He’s right; science has been saying very clearly for years that catastrophic climate and ecological chaos is approaching; and its now here. On that basis alone, I cannot see how the draft local plan is at all appropriate.
We have to reduce the use of fossil fuels immediately and most of the carbon emission reduction has to happen between now and 2030. We can’t delay on this, every day matters. In February, Sir David King, the government’s former chief scientific advisor said,"what we do in the next 3-4 years will determine the future of humanity". so we’ve already wasted a quarter of that precious time – we are running out of time. the IPCC in their 2018 special report on limiting global warming to 1.5 degrees stated that ‘rapid, far-reaching and unprecedented’ action has to needed in all aspects of society. All this means that ‘business as usual’ can’t continue – otherwise we are facing disaster. The draft local plan seems to be ‘business as usual‘ to me, perhaps with a little greenwashing thrown into the mix.
On March 15 2021 the Cambridgeshire and Peterborough Independent Commission on Climate Change released its first report on addressing transport, buildings, energy and peat, highlighting the need to take “urgent action,” and outlining suggested policies to reduce emissions.
• The report said greenhouse gas emissions in the county are “high”, approximately 25 per cent higher per person than the UK average.
• It also said, at this rate “we have only about six years remaining before we will have exhausted all of our ‘allowed’ share of emissions to 2050, if we are to play an equal part in delivering the UK’s critical net-zero target”.
• The report found the area is at a “high risk from the changing climate”, and that many of the feared effects in the UK are “particularly severe” in our region.
• These include an increased risk of flooding, high summer temperatures, water shortages, and damage to the natural carbon stores in the deep peat of the Fens.
The Commission released its second report on water, waste, and a just transition this October.
• The report calls for an in integrated water management plan to account for future water restraints in the region. Without this, economic, housing, and population growth will be difficult.
There is much in both of these reports that the draft local plan fails to address.
Under Dr Nik Johnson, the Combined Authority has committed to acting on the Commission’s recommendations. Many city, district and county councils in the area have declared a climate and ecological emergency. They need to act in accordance with that emergency.
Please confirm that you have received my objection, and that this individual submission is noted, recorded, counted and made available.

Yours faithfully,

Is growth good?
I do not consider growth to be intrinsically bad – however, most of the drive for growth comes from local landowners and businesses who want to locate here. As a resident, I am watching from the sidelines and seeing family homes turned into cramped multiple occupancies, constant traffic jams, parking problems, pollution and house prices that make it hard for our children to live in the same area. If the model of 40% growth is used for the next 100 years, it becomes 440% - a total of almost 700,000 homes. It is not unreasonable to ask, “At what point will the current model be forced to change?”
I fully accept that Cambridge clearly has a major national and international role to play and the prosperity of future generations will be affected by decisions that emanate are taken now. But there are clear tensions – what will be the impact on our local neighbourhood and on the surrounding environment? The Greater Cambridge Councils are ultimately responsible to residents and must address this fundamental concern head on if they want residents to have true ownership of the future of our city. Engagement with the public through the consultation process by those responsible for creating the Plan has been thoughtful and professional, but has ignored the elephant in the room – just how much are residents prepared to tolerate? If we are to resolve the tensions, we must not proceed by formulae nor re-act purely through nimbyism. We need to talk and to find ways to “accentuate the positives and eliminate the negatives”.
What do the two key statistics of 55,500 new jobs and 48,840 homes mean?
Page 24 states “We propose that the new Local Plan will meet the following objectively assessed needs for development in the period 2020-2041:
§ 58,500 jobs
§ 44,400 homes [which, after adding 10%, becomes 48,840]
The meaning of the 58,500 figure is unclear.
There is clearly an intention to “develop” new jobs, but it is not clear what qualifies as a “development”. The issue is highlighted by the loss of Marshall’s in 2030. The Plan identifies Cambridge East as creating 9,000 jobs on the land released. However, some 4,000 jobs already existed at the airport and these will be lost to Cambridge. The actual, net number of new jobs “developed” will be 5,000 and not 9,000, so the base figure for calculating housing should surely be 54,500.
Over the period of the Plan there will be many other examples e.g. How many staff will existing hospitals agree to lose in order to staff the Cambridge Children’s Hospital?
It is unclear whether these figures are intended to be forecasts or projections.
Essentially, a forecast is an educated guess while a projection is simply based on extending a trend. From my understanding of the Evidence Study, your consultants have simply generated a projection from existing data to generate the figures.
The addition of 10% to the housing figure adds a layer of confusion, since the original figure of 44,400 is therefore a projection based on past employment data. Were this to be displayed graphically, using standard techniques, you would show the past data following a central projection line with outliers for the extreme cases (as in the projected climate change graph below). The extreme cases already exist and are described in the table in the Evidence Study Page 102.
So, how could you show the 10% on this diagram? Are you adding to the central or the higher projection? Neither makes sense!
<image002.png>

Ultimately the data is open to more than one interpretation.
This analysis arose because I asked myself the question – do you have a target number of homes to build? My understanding is that you are only planning to build 44,400 and you would be happy with that. This is consistent with your statement on page 26 that “We consider that our objectively assessed need for housing for 2020-2041 is the number associated with the most likely future level of jobs: this is a figure of 44,400 homes.”.
So where does the 10% fit into this? On page 31 you add a nominal buffer of 10% to deal with unforeseen circumstances by identifying enough sites to build more houses if the need arises. Whilst this is a perfectly sensible contingency, it does nothing to add to the number of houses you plan to build and so your target remains 44,400 homes. However, in the table on page 31, you refer to 48,800 as the number of homes to be built. So, did you intend this to be the target?
I apologise for this lengthy discussion, but the issue is significant.

Dear Sir/ Madam,

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,

Dear Sir/ Madam,

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

Dear Sir/ Madam,

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 strongly 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 in a personal capacity to object to the Draft Local Plan. I do not wish to complete your online questionnaire.

This plan is a plan of the 1980s and 90s, putting economic growth as its core and primary objective. Vast swathes of concrete, profits for a small group of landowners and developers and huge inward migration are the only things it is sure to deliver.

We are in the year 2021. The council, the country and the world have declared a climate emergency. We are on track for a catastrophic 2.4°C of warming and 2.4 metres of sea level rise, easily within my children's lifetime. Yet all this plan does is carry on with infinite growth while pushing the lie that it can also increase or double nature and increase or double food production. THIS HAS NEVER BEEN ACHIEVED. It's called greenwash. I urge councillors and the government to listen to the science, and not be conned by the increasingly desperate growth lobby in what feels very much like a last minute gold rush, with the writing very clearly on the wall.

This plan needs to be urgently scrapped, as does any post in the council related to growth and development. Stephen Kelly's job title needs to be 'Joint Director of Planning and Carbon Degrowth'. His success should be measured by annual reduction in carbon footprint of all sectors, and measurable increases in biodiversity populations. Without this radical change we are simply accelerating towards the abyss, and denying our children precious years to find ways of adapting to and reversing global heating.

The council and the government need to encourage the University of Cambridge to stop growing locally and encourage it to set up a campus in the North where there is still some environmental capacity, and where regeneration of empty homes, and good jobs would be welcomed.

The obligation on every council in England to grow relentlessly for all infinity is a madness that needs to be scrapped urgently by the government, and a new national strategy that will seek to provide housing and jobs where there is environmental capacity, while at the same time working to reduce the carbon and land footprint in areas such as Cambridgeshire, where environmental limits (in water supply) have already been breached.

Every Councillor and council employee should be assessed on how successful they have been, year on year, in reducing their carbon footprint, increasing biodiversity and well-being of the existing residents, and of the city and county as a whole.

Further, I have read and support the letters sent to you by Friends of the Cam, and Cambridge Labour Environment Forum. These letters provide evidence for the case I have made here.

Dear Sir/ Madam,

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 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 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.

Dear Sir/ Madam,

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,