STRATEGY

Vision and aims
I support the vision and aims of the Local Plan and the general direction of the development strategy, but am concerned about the overall scale of development and the continuing high levels of growth which are driven by technical economic growth forecasts.

How much development, and where – general comments
I recognise that Greater Cambridge has a strong and nationally important economy, but I do not support the continuing pace and scale of high levels of growth that has increasing cumulative impacts on the environment, water supply, heritage and carbon emissions.
I would argue that the growth of the Cambridge and the impacts of that level of growth on South Cambridgeshire are disproportionately high (a third higher than the government targets) compared with other Local Plans, because the scale of growth is driven by technical economic forecasts studies and the desire to continue to stoke the engine of growth yet again.
The area over the last 30 years has absorbed major levels of development which has brought many benefits and disbenefits.
But the time has come with this Plan, in a new era having to seriously address the causes and impacts of climate change and net zero carbon goals to set t Cambridge on a different course.
The development strategy should with this Plan start to reduce the scale of growth to more manageable levels, perhaps towards the Low option so as to set the direction of travel for the next planning round in the era of climate change .

S/JH: New jobs and homes
The level of new homes proposed in the Plan is driven by the need to enhance economic growth, so much so that it is 37% higher than the Government targets for the area.
This proposes larger amounts of housing growth in the surrounding South Cambridgeshire District to serve Cambridge and the surrounding area.
A large amount of new development proposed in the housing pipeline is already allocated to known sites. A moderated target would lessen the uncertainty of deliverability, ease of the identified water supply issue and give time to for water companies to decide and implement sound options, and reduce climate impacts.
Even a moderate reduction in the housing target, which goes so far beyond what the Government requires, could provide more reserve housing sites, providing flexibility to maintain a five year housing supply, reduce pressure on villages and start to slow the pace of change in an area, which has seen so much cumulative change over the recent decades.

S/DS: Development strategy
I generally support the Development Strategy that supports sustainable development and proposes compact active neighbourhoods in Cambridge, development and /or expansion of new towns connected by good public and active transport and the proposals for very limited new development in the rest of the rural area.

S/SH: Settlement hierarchy
I support the proposed Settlement hierarchy policy area as a means of planning and directing new development towards the most suitable and sustainable locations.
In my comment on the rest of rural area, I am concerned about the impact of unallocated housing windfalls being used by possible speculative planning applications contrary to the development strategy to direct development to the most sustainable locations.
I would suggest that the word indictive in the proposed policy SS/SH is omitted to strengthen and add clarity to the proposed policy in the light of the revised annual windfall target.
Support the reclassification of Cottenham and Babraham villages to provide locations for development and new jobs on good public transport routes.

S/SB: Settlement boundaries
I support the work on the development of Settlement boundaries, especially to protect the open countryside from gradual encroachment around villages and on high quality agricultural land.
The work on settlement boundaries should include the involvement of Parish Councils at an appropriate stage in the development of the Policy because of their local data and knowledge of past development.

Cambridge urban area - general comments
Support in Cambridge urban area for good designed, active compact new developments, reuse of brownfield land and continued development of larger neighbourhoods where possible.

S/NEC: North East Cambridge
Support the development of NE Cambridge as a sustainable neighbourhood with good public transport and active transport into Cambridge

Edge of Cambridge - general comments
Support edge of Cambridge planned new neighbourhoods and new sustainable developments and settlements of sufficient size to cater for daily needs and with good access to public and active transport

New settlements - general comments
Support for new settlements of substantial size to cater for more than local needs. I particularly support the growth of Cambourne which can provide good rail access into Cambridge and to the West in the mid-term from new East West rail infrastructure.

S/BRC: Babraham Research Campus
Support the release of land from the Green Belt to support nationally important R and D and life science jobs located near to public transport routes and active transport.

S/RSC: Village allocations in the rural southern cluster
NB, Policy has different name on map page.
In accordance with reducing carbon emissions, and supporting access to the existing rail network the villages of Shelford and Whittlesford could be locations for more sustainable development, despite Green Belt locations

S/SCP: Policy areas in the rural southern cluster
Support existing site allocations to be carried forward including the expansion of Babraham research campus using Green Belt land

Rest of the rural area - general comments
I support the development strategy approach which directs new development to a limited number of sites in the most sustainable development locations supporting the sustainability of villages.
There is still the matter of the unallocated housing windfall development identified in the strategy Topic Paper of 5345 homes for 2021-2041 which is not included in the additional allocated land target of the 11596.
The anticipated dwellings per year for SCDC is between 240 and 255 dwellings a year. Notwithstanding the proposed policy SS/SH, there is a risk that developers will seek speculative permission in the open countryside greenfield sites contrary to the development strategy using the windfalls allocation and I have made a comment on this on Policy SS/SH.

Climate change - general comments
All new development will have impacts relating to increasing carbon emissions and require adaptation responses. A Local Plan can only seek to mitigate these impacts and by far the most impacts are from the existing development, their use and getting around using carbon fuelled transport.
The rate of change in and around Cambridge over the past 30 years has been significantly greater than for just local needs, mainly to develop nationally important economic development. This Plan continues this approach despite the issue of climate change and water supply and large amounts on new development still to be implemented from current Local Plans.
I would argue that the time has now come to step back from this direction of travel and begin to reduce the scale of growth around Cambridge using the Low option as a first step.
I was hoping, given the aims of the Plan and the input of the Net Zero Carbon study for a more radical Plan which addressed climate change and zero carbon targets through aiming to reduce the total amount of new development to meet local needs need and move to a position which is in line with Government targets in the next planning round.

CC/NZ: Net zero carbon new buildings
Support in general
Although I have concerns about how for example heat pump technology can be installed and used at reasonable cost in new development.

CC/WE: Water efficiency in new developments
Support, important given the water supply issues coming forward up to 2041

CC/DC: Designing for a changing climate
Support especially with regards balancing insulation and overheating with increasing hot to very hot summers risk brought about through a changing climate.
Site wide approaches should include appropriate lower densities through good design which allow for beyond minimum garden space and space for Suds and open space and greening.

CC/FM: Flooding and integrated water management
Support
Especially permeable surfaces and integration of water management with enhancements to biodiversity and greening.

CC/CS: Supporting land-based carbon sequestration
Support the creation of land for use as carbon sinks through the development process. Perhaps a suitable use of land in the Green Belt or on lower grade agricultural land.

Biodiversity and green spaces - general comments
Support the identification of 14 strategic GI initiatives and enhancing the linkages between GI and open spaces to provide corridors for wildlife.

BG/BG: Biodiversity and geodiversity
Support delivery of a minimum 20% biodiversity net gain.
I would comment that funding for long term management of biodiversity assets is key for the long-term benefits from such a policy.
I could also emphasis the creation of winter wet areas, water space and Suds designed to benefit enhanced biodiversity should be planned in to developments at an early stage

BG/GI: Green infrastructure
Support the use of a GI standard, particularly on larger developments.
In particular early identification of GI and biodiversity assets and potential gains as an early part of the design process and /or planning brief

BG/TC: Improving Tree canopy cover and the tree population
Support increasing tree and woodland cover, ensuring right tree(s) in right places and species futureproofed for lifetime changing climate adaptation.
A particular opportunity is the rural field margins of agricultural land to help increase the linkages and biodiversity gains and in specific places the creation of woodland belts in the open countryside, green belt land and around villages.
In Cambridge urban areas, where there are existing trees there is a need to plan their replacement with adaptation species to gradually adapt to a changing climate.
Also, to provide sufficient future tree cover to mitigate the urban heat island effect, provide shade and mitigate microclimatic effects.

BG/RC: River corridors
Support the protection and enhancement of river corridors and restoration of natural features and use of GI to support the alleviation of flooding risk.
Support the delivery of the continuous Cam Valley Trail.

BG/PO: Protecting open spaces
Support the protection of the wide variety of open spaces and use of Local Green Space designation in appropriate locations

BG/EO: Providing and enhancing open spaces
Support the provision of open space and recreation provision, including appropriate play space.

WS/HD: Creating healthy new developments
Support the use of health impact assessments in proposals.
I would comment that with the increase in ride on electric vehicles and increasing older communities there are opportunities to coordinate with transport professional the delivery of smooth pathways with minimal dropped kerbs which gives smoother access to local centres and bus stops linked to older persons housing and also can prevent falls.

GP/PP: People and place responsive design
Support the requirement of inclusion of a comprehensive design and access statement and recognise the importance of good design tailored to the local area and involving local communities and Parish Councils particularly in villages.

GP/LC: Protection and enhancement of landscape character
Support the use of landscape character assessment to enhance the setting of Cambridge and protect and enhance the setting of villages.

GP/GB: Protection and enhancement of the Cambridge Green Belt
National guidance places great importance on Green Belt policy and sets out how planning proposals should be considered.
I support the use of GI and other opportunities to provide access and increase tree and woodlands where appropriate in the Green Belt.
But I think where there are locations where there is good public transport especially rail access or future rail access there is a good case to consider the special circumstances judgment.
I think it is time to question if this national policy is still relevant to the situation Greater Cambridge in the period up to the middle of the century. Further Green Belt assessments may be better served by considering sustainable development and the extension of the Green Belt to prevent coalescence around villages beyond the current Green Belt boundary which was made before most of the new development (over 70%) is beyond the current outside boundary or further modification of this policy to enable growth to be planned for the 21st century rather than the conditions which related to the last century.

Jobs – general comments
I am concerned about the scale of economic growth in the area and its use to drive large amounts of housing growth well about what would be required in other planning areas.
However, I support the life science sector and its national importance and the appropriate development in science parks including their expansion using Green Belt land

J/AL: Protecting the best agricultural land
Support the restriction of development on the best agricultural land as supported in the Sustainability Appraisal.

Homes – general comments
Support the objective for planning enough housing to meet our needs, including affordable housing to rent or buy.
I object to needs being directly driven by future economic assessments, the direction of travel of the plan should be as much balanced by the climate change as future economic demand.

H/HD: Housing density
Support design led approach to determine optimum capacity of sites and appropriate density to respond to local character, especially in villages.

H/GL: Garden land and subdivision of existing plots
Support for controlling the use of gardens for new development.

In order for a local plan to be considered sound paragraph 34 requires local authorities to ensure that the cumulative impact of the policies it contains does not undermine its deliverability. It is therefore essential that the viability assessment underpinning the local plan takes into account all the policy costs being imposed on development across the plan period and that benchmark land values are accurate. As such it will be necessary for the Council to consider the impact of the following costs which have been underestimated in the viability assessment.

Policy costs
The approach taken to First Homes in the viability assessment has bene to treat them as an affordable housing product with regard to costs and their risk profile. Whilst First Homes are an affordable housing product they are marketed and sold by the developer. As such the costs and risks related to the sale of such housing when considered in any viability assessment should reflect those for market housing and not affordable housing. In particular the return on such homes should be set at those for market housing and not the 6% return usually expected for affordable housing.

The Council are proposing a 20% net gain in biodiversity on all sites at a cost of £1,211 per unit for Greenfield sites and £289 per unit on brownfield sites. These costs are based on the impact assessment on biodiversity net gain produced by Defra. However, this assessment is based on scenario B and the assumption that the additional 10% net gain will be delivered wholly on site. Firstly, it cannot be assumed that the additional 20% net gain could be delivered wholly on site. An additional 10% of net gain would not necessarily follow this scenario with more offsite delivery being required. A higher degree of offsite mitigation is likely to be required in order to deliver a 20% net gain which will mean a far higher cost to the developer. If scenario C of the Government’s impact assessment is taken as a broad indication as to costs facing a developer, the proposed 20% net gain requirements could see costs rise significantly per hectare. If all of the additional 10% net gain above the proposed legislation being suggested by the Council had to be delivered offsite that could see costs rise by circa £60,000 per hectare, a considerable additional burden and one that could impact on the viability and deliverability of some sites.

Secondly, even if delivery could be achieved on site a higher net gain requirement would require more land reducing the developable area of a site, reducing the gross development value and site viability. This is an issue that does not appear to have been considered in the Government’s impact assessment nor by the Councils’ viability assessment.

The viability assessment includes a figure of £1,000 per electric vehicle charging point (EVCP) and £2,500 for a multi-charging point for every 4 flats. However, the HBF would consider this assessment as to the cost to be too low. Whilst the HBF accept that electric vehicles will form a key part of the Government’s strategy to reduce carbon emissions it is necessary for these to be properly considered with regard to their potential impact on the viability of new development. However, whilst the Viability Assessment assesses the cost of installing an electric vehicle charging point no allowance seems to have been made with regard to potential improvements to the electricity supply infrastructure that may be required to support the use these charging points.

The HBF and its Members have serious concerns about the capacity of the existing electrical network in the UK. The supply from the power grid is already constrained in many areas across the country. Major network reinforcement will be required across the power network to facilitate the introduction of EVCPs and the move from gas to electric heating as proposed in this local plan and under the Future Homes Standard. These costs can be substantial and can drastically affect the viability of developments.

If developers are funding the potential future reinforcement of the National Grid network at significant cost, this will have a significant impact on their businesses and potentially jeopardise future housing delivery. Following the Government’s announcement that all new homes with a parking space will be required to have a EVCP fitted from 2022 the details of this announcement are still to be set out in detail. However, the Government’s proposal from its consultation in EVCPs in 2019 was to automatically cap charges to developers for upgrading local electricity networks at figure of £3,600 per charge point so clearly the costs could be significant and should be included in the viability assessment.

Finally in relation to policy costs, the Councils’ viability assessment does not consider this policy can be delivered at no extra cost. However, this position fails to consider whether such measures will reduce the number of homes that can be delivered on site nor the potential need, as set out in the policy, for mechanical ventilation where passive or natural cooling mechanism cannot be delivered. It is important that these costs are factored into the viability assessment to ensure they are fully considered.

Land values
The HBF are concerned that the land values used in relation to brownfield sites appear to be low for an area with a strong economy. Evidence from the VOA published by the Government on land value estimates indicates that in 2019 industrial land was valued at £1,100,000 per hectare, edge of centre office space at £24m per hectare and out of town office space at £3.9m. All these are significantly higher than the £988,400 used in the viability assessment and will have an impact as to whether such sites are viable alongside all the costs being placed upon them by the Council. As such the land values for brownfield sites should be reconsidered and increased to reflect these higher existing use values for brownfield land in the Greater Cambridge area.

INTRODUCTION

This is the consultation response from the Cam Valley Forum to the Draft Local Plan. We highlight the issues that our group addresses namely the health and well-being of our human community’s relationship with our river and river valley, be it its nature, wildlife, amenity or heritage. The Forum, a voluntary charitable organisation, works with many other bodies to protect and improve the river Cam and its riversides, including its many tributaries and its sustaining aquifers. This response focuses mainly, therefore, on our group’s concerns for the future of the river and its environment. However, since as individuals and as a group, we are also concerned about the city and its environs, we are not confining our comments to river-related issues alone. We has contributed to the planning discussions that have already taken place but we do urge that some of the points below be taken seriously.

The River Cam is an invaluable, but vulnerable, natural asset to the environment of Cambridge and South Cambridgeshire. Cambridge without its river would not be all that it is. As your proposals recognise, the river and its tributary streams bring threads of wildness through an intensively farmed countryside as it flows north. Its riversides contain and connect with many important wetland habitats. Its wetlands still hold elements of the wildlife most typical of this ancient lowland region.

Important to the whole planning process is the fact that the River Cam’s waters are enjoyed by rowers, punters, boaters, canoeists and swimmers, while many more people enjoy walking, picnicking or angling from its banks. It therefore needs to be a river to be proud of and not ashamed of. Visitors from far and wide come to experience the world-famous Cambridge Backs.

The Chalk streams in the UK are internationally important in the conservation of biodiversity. The UK has about three-quarters of the world total. For reasons of long standing environmental abuse in the Cam Valley these streams are not among the best (on account of low flows and widespread pollution) but, despite the impacts of over-abstraction, pollution and channel modifications, they are still valued highly for their lowland scenery and for their provision of recreation and well-being for local people. We welcome that Chalk streams are now on your planning map as highly significant to our national conservation position and that means that with investment by Cambridgeshire the position is potentially reversible. Largely through our lobbying and the campaigning of many other river supporters something is at last now happening.

The local plan has at last woken up to this reality - but may not have done so entirely. We do need some development but there has been too much spin and ‘greenwash’ from the pro-development lobby. There is thus a tendency to give lip service to sustainable development without recognising that we humans are part of the ecosystem and are already overdrawing our natural capital. We call on our political leaders need to heed the authoritative voice of Sir David King (former Government Chief Scientist): he made it very clear to a recent meeting of Natural Cambridgeshire that unless you first have ecosystem well-being you cannot contemplate truly sustainable development. He is right. All the policies and proposals of this local plan need to be appraised rigorously, in the light of their potential to counteract or weigh against genuine environmental sustainability. Only if that is recognised do we welcome it.
We address our remarks in response to the plan under the Policy headings you have employed, most specifically in your designated areas of ‘Climate Change’ and ‘Biodiversity and Green Spaces’.

CLIMATE CHANGE
Policy CC/DC

The report of the Cambridgeshire and Peterborough Independent Commission on Climate drew on well- founded national research but not, as far as we are aware, on any detailed local meteorological studies.

As you recognise, the Cambridge area rainfall is low compared to any other English region and is, year on year, highly variable. Droughts and flood events are therefore to be regularly expected. Summer evapotranspiration generally exceeds rainfall. Thus, only winter rainfall adds significantly to the recharge of the chalk aquifer; the local water companies’ dependence on this source (97% for Cambridge Water) therefore lacks resilience in the face of winter droughts. We are glad that this is now being addressed by plans for a Fen Reservoir. But there is little chance of this physically helping our dire situation before 2035. The reservoir provision alone will not be sufficient for the demand unless water neutrality is assured in new development.

The Commission’s report suggests that winter rainfall may increase but the graph below shows only a tiny upward trend over the past 120 years; we cannot expect any significant increase in winter recharge. There have been much greater droughts in the past than anything experienced recently. [Graph- Winter Rainfall 1900 to 2020]


There is, however, in terms of climate change, plenty of evidence of rising summer temperatures, earlier springs and longer summers. This all means greater evapotranspiration. Our studies attribute part of the Cam’s currently falling river flows to increased soil moisture deficits. i.e. it takes more rain to wet up the soil before any rain water percolates through to recharge ground water. Our 2020 Let it Flow! report shows that in 24 (41%) of the years 1961-2019 inclusive, winter rainfall did not exceed the previous deficit, so there was in effect no recharge. When this happens in two consecutive winters, as last in 2018-19, our Chalk streams suffer greatly the following summer.
Present water sourcing from the aquifer is already unsustainably managed as historical river flows have halved. This greatly reduces the chance of reversing the losses of wetland biodiversity that the Greater Cambridge area has already experienced. We heartily agree with the national Environment Agency that only a 60-70% reduction in present abstraction will return our rivers to more normal flow. Until this is achieved there will still be serious short term consequences for meeting water demand. This must continue to be recognised and not brushed aside.

We also question the good sense of the Government’s calculation of the overall risks from climate change to future population growth in this region. Year on year, many risks appear to be increasing (from sea level change to higher temperatures); the precautionary principle needs to be to the fore in this already densely crowded and low-lying region. You cannot easily plan to mitigate a rising trend.

Our policy position on water flows, as advanced in our Manifesto in 2019, Let it Flow! report in 2020, and other submissions, and as summarised in our response to the Government’s Draft Strategic Priorities for OFWAT, is:
• We expect OFWAT and the water companies to act to protect and enhance priority habitats. In the case of Chalk streams, for which the UK has a global responsibility, we expect them to take a lead role in implementing the CaBA Chalk Stream Restoration Strategy 2021. They should take all possible steps to reduce abstraction from Chalk aquifers at source, aiming to ensure that chalk springs and headwaters run freely, as they would under natural conditions, every year, whatever the weather.
• The companies should cap abstraction at current actual (not licensed) levels, meet new demand through water transfers (from surface water sources) from other companies, and invest in reservoirs fed by high winter flows as alternative sources of supply.
• Recognising that all Chalk streams now lie within ‘areas of serious water stress’, they should establish a new baseline of annual restrictions on water use and tighten these as necessary in response to environmental as well as supply triggers.
• Companies treating wastewater should invest in spill monitoring, stormwater storage, and phosphate reduction to 0.2 mg/l total phosphorus, at all works that discharge to Chalk streams.’

In the Cam Catchment, in 2019, three water companies abstracted some 105 Megalitres/day from the Chalk aquifer (Cambridge Water 64%, Affinity Water 22% and Anglian Water 14%). The Environment Agency abstracted a further 15 Ml/day to augment flows on Cam Valley Chalk streams damaged by water company abstraction. Until the proposed Fens and South Lincolnshire reservoirs come on line in the 2030s, the companies must cap abstraction and supply all new demand in Greater Cambridgeshire by water transfers from surface water sources to the west and the north. They also need to invest in compulsory metering, leakage reduction and demand management. The local authorities should do everything in their power to support this dramatic readjustment in our water supplies.

Policy CC/WE and CC/FM

We fully support Policy CC/WE, which will require new developments to meet high standards of water efficiency, in particular the standard of 80 litres/person/ day for residential properties (unless demonstrated impracticable). We contributed to and welcomed the Integrated Water Management Study (IWMS). To achieve any ‘water neutrality’ from the current position will require substantial reductions in demand commensurate with any and every development envisaged. The track record of our resource management is so bad that we have little confidence in any major development improving things without a huge cultural change and management change to the water industry operations. This is really urgent.

In Let it Flow! we proposed that consumption might be regulated by the local authority. We do recognise that this would require Central Government legislation and action, but why not? Local authorities play a much stronger role in controlling water use in similarly water stressed regions such as Cape Town (RSA) and California (USA), why not in Cambridge too? Our local water companies currently propose little more than ‘targeted communication’ to encourage voluntary reductions in water use during prolonged dry weather.
Local authorities should join us in pressing for mandatory restrictions on consumptive uses (e.g. hosepipes, sprinklers and pressure-washers) in every summer, with such restrictions being rapidly tightened and widened if ‘dry weather’ turns into ‘drought’.

Policy CC/FM

Flooding is an ever present concern. We are pressing for a more integrated approach by the Environment Agency, Natural England, farmers and Local Authorities. The Local Plan should recognise that episodic ‘flooding’, may be increasingly likely with climate change. This can be mitigated upstream by slowing river drainage. We have had over 60 years of ill-advised river dredging in our lowlands to increase arable areas on farms. To reverse this trend would help. This more ‘natural’ approach to flood plain management would require a reversion to an earlier pattern of agricultural land-use management with wet meadows and less arable land in the flood plain itself.

Some river valley farmers are already making this positive change. e.g. South Cambridgeshire could develop a larger flood plain basin with a wet woodland as a buffer against future Cambridge City flood events. This wet woodland would impede rapid flow, so attenuating the flood, save water, sink carbon dioxide and ease soil erosion. Such wet woodland sites could also provide great benefits to biodiversity and even recreational areas. The present heavy winter flood events are losing good soil from our farmlands. Restoring riparian grazing grasslands would sequester carbon efficiently - an added bonus to our carbon depleted soils.

We fully support Policy CC/FM, which includes directing development away from floodplains, the incorporation of sustainable drainage systems into new developments (including the use of mitigation wetlands and permeable surfaces), and ensuring that new development does not increase flood risk elsewhere.

BIODIVERSITY AND GREEN SPACES

Policy BG/RC

We broadly welcome the River Corridors Policy. However, it promotes River Corridors as an amenity for recreation as if the rivers are already in good health and can take increased human pressure. The river water flows and water quality are not in good health. The summer Cam runs pretty much with only treated sewage effluent. On the tiny Mel river (tributary of the Rhee) the summer flow pulses with the periodic discharge from their local sewage treatment works. We have recently shown, through water testing, that the bulk of E coli in the river Cam comes from these treated effluent sources. Because of low river flows, our water quality status is ‘poor’ in the upper Cam corridor. This is largely on account of unacceptably high phosphate levels. The status quo is already shameful.

The plan should fully map a ‘nature recovery network’ with set targets for improvement. Water is a vital part of this connectivity, as are all drains, streams, rivers, lakes and ponds. A ‘nature recovery network’ must include these aquatic elements at the same time as identifying new large-scale areas for habitat creation, including new woodlands and areas of natural regeneration, and opportunities for linking them all together. We acknowledge that there are health benefits from rural access, but our wildlife - presently limited by pollution, habitat and biodiversity losses - are also vulnerable and need more protection.

The pressures on our present open spaces along corridors with public access are already hard to manage and are presently considerable: Grantchester Meadows is a case in point. However, sites like Trumpington Meadows are beginning to show that positive change is possible.

In our 2020 Green Infrastructure consultation response we urged the planning designation of ‘Riverscape Opportunity Areas’ (perhaps a more interesting title than ‘River Corridor’) extending at least 50 metres each side of the main rivers, streams and brooks within Greater Cambridge. In these areas, the aim should be to encourage natural processes so far as possible. For example: buffering watercourses against surface water run-off and improving habitats in built-up areas; and, in rural areas,reconnecting rivers with their flood plains, tackling the damage caused by over-deepening and straightening, buffering them against nutrient, pesticide and soil inputs, and restoring light grazing.

Opportunities that should be sought within ‘Riverscape Opportunity Areas’ include:

(a) Vary mowing regimes in urban parks to create more diverse vegetation.

(b) Actively reintroduce meadow species into rye-grass swards on the urban commons and parks (including parts of the more intensively-managed local Nature Reserves) using local seed sources (e.g. as on King’s College lawn) to strengthen populations of less common wild flowers that are vulnerable to local extinction.

(c) Recreate scrapes and ditches on riverine commons in Cambridge to restore habitats for wetland plants lost when the commons were infilled and levelled in the 19th century (for examples of the impacts and their extent in Cambridge see C. D. Preston et al (2003): The long-term impact of urbanisation on aquatic plants: Cambridge and the River Cam. The Science of the Total Environment 314-316: 67-87).

(d) Create further inlets and ponds to create new water habitats, provide refuge areas for fish during high flows and areas where young fish can flourish. The new inlet created on Logan’s Meadow in Chesterton is valuable in many ways although further work appears to be necessary to improve water quality as the stream and pond bed appears to be dominated entirely by algal growth.

(e) Replace sealed surfaces where possible with permeable paving to allow water to filter into the soil rather than running into the river, creating pollution risks (e.g. in front of boathouses in Cambridge).

(f) Install and maintain silt and pollutant traps in all surface water drains from highways or private land (e.g. Colleges) that run directly into the river, or connect these instead into the sewer network, to reduce water pollution from hydrocarbons, microplastics, and silt.

(g) Commission and implement expert advice (e.g. from the Wild Trout Trust and Wildlife Trust) to restore and enhance rivers and their tributaries in Greater Cambridge. Reports available on the Wild Trout Trust website include: Cam (Hinxton 2015), Granta (Linton 2019, Babraham 2019), and Cherry Hinton Brook (2017). These make many valuable recommendations to tackle concerns such as: low flows; pollution from sewage works, surface water drains and contaminated land; tree and vegetation management; siltation; channel over-deepening and straightening; and barriers (e.g. weirs).

(h) Establish significant buffer strips of natural vegetation alongside watercourses to protect them from spray drift and run-off of soil and nutrients from intensively-managed farmland.

(i) Remove invasive non-native species such as Floating Pennywort Hydrocotyle ranunculoides, and Himalayan Balsam Impatiens glandulifera, which threaten indigenous biodiversity.

In relation to item (g), we very much welcome the Greater Cambridgeshire Chalk Stream Project, which draws on the expert work of Rob Mungovan, Ruth Hawksley and Guy Belcher; Their inspiring report identifies opportunities to restore channels and enrich the river substrates with manageable modifications. We note that the implementation cost of the 109 projects listed for Chalk Streams within 13 of the Cam catchment’s 29 water bodies is some £800,000. We urge the City and District Councils to seek this funding in conjunction with those locally committed to Chalk Stream restoration.

Policy BG/EO
We fully recognise the benefits of open spaces as a key aspect of the environment. They are indeed fundamental to the character of an area. Attractive, accessible and well-designed open space can
certainly support and enhance the appearance of an area. Such places are not built in less than decades and too often developers are completely ill-equipped to manage or plan such areas. When questioned at ‘Darwin Green’, for example, the developers there were completely unable to say how the designated open spaces would be made ‘green’ how they would be managed and what diversity of options were being considered. This is a planning imperative. Is the GCP up to planning these things with its own staff? It is frankly disgraceful that more physical conservation management staff are not employed. Green infrastructure requires jobs to be created and committed to long term planning and support.

Riparian pasture is essential to the future of our green spaces. Paradise, Sheep’s Green and Coe Fen are exemplars of good practice. These areas have quite high biodiversity, very capable management and combine traditional wetland pasture management by cattle with provision of open recreational space. The Rush stream also provides a very valuable site for wildlife in a near urban setting. Green sites can be well-used by the public while being degraded ecologically (e.g. Jesus Green has little ecological value as a grassland habitat). If river corridors are to show wildlife gain, we need genuine Rus in urbe management. Urban wildlife (in Cambridge) is substantially more biodiverse than in the surrounding countryside, especially where there are major gardens with good tree and shrub cover. Grazing by ‘Cam Cattle’ also makes a vital and under-appreciated contribution to the biodiversity of insects and many bird species.

Tree planting and appropriate species selection is also important, but the greatest losses of habitat that Cambridgeshire has suffered have been of lowland florally rich grassland. This is a more appropriate target for river corridors than extensive tree planting. If trees are planted close to watercourses, they often bring added management problems especially when they fall or are felled. It is possible to plant traditional willow species for pollarding, where there are cattle, but such plantings do need a commitment to enduring cycles of management. Again, is that enduring commitment to care built into the planning?

SPT/AW/BH

Cam Valley Forum 13 December 2021

Appendix

Our website https://camvalleyforum.uk/provides links to further information, including:

The Government’s proposed strategic priorities for OFWAT: https://camvalleyforum.uk/wp- content/uploads/2021/10/CVF-response-to-Defra-strategic-guidance-to-OFWAT-15-10-21.pdf

Green infrastructure (July 2020): https://camvalleyforum.uk/wp-content/uploads/2021/02/Cam- Valley-Forum-Green-Infrastructure-response-25-07-20.pdf

Tentative proposals for a Bathing Water designation (January 2021): https://camvalleyforum.uk/wp- content/uploads/2021/02/cvf_swimming.pdf and the responses to that consultation: https://camvalleyforum.uk/wp-content/uploads/2021/03/Cam-Valley-Forum-Responses-to-Bathing-Water- Proposal-08-03-21.pdf.

Let it Flow! (May 2020): https://camvalleyforum.uk/wp- content/uploads/2020/05/Cam_Valley_Forum_Let_it_Flow_Full_report_26-05-20-compressed.pdf

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Climate change
Climate change - general comments

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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


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

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

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

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

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

Great places policies
Great places – general comments

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

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

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

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

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

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

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


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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

I have looked at your short tick-box ‘survey’ and your ‘detailed response’ mechanisms and find both wholly unsatisfactory. The former leads me by the nose without permitting any opportunity to express my views; the latter is too cumbersome. Options to use phones, apps etc. are of zero benefit to me; I do not own a smart phone. Per the Gunning Principles emphasised in your department’s Webinar on 4 November 2021, please confirm that the content of my following brief comments will be:
• noted;
• recorded;
• counted; and
• conscientiously taken into account with other public feedback.

On water issues, I fully endorse the Consultation Response of the Friends of the Cam on the Draft Local Plan (see https://www.friendsofthecam.org/sites/default/files/ObjectiontoNext%20LocalPlan_0.pdf)
On trees, I draw to your attention the very recent report by the Forestry Commission (see https://www.forestresearch.gov.uk/research/valuing-the-mental-health-benefits-of-woodlands/) regarding the vital importance of improving, enhancing, protecting and preserving tree cover. This must be delivered everywhere in and around Cambridge, but especially where tree canopy cover falls below the already meagre average for our area – in order to reduce entrenched disadvantage (per the well established principles of ‘Doughnut economics’; see https://doughnuteconomics.org/principles-of-practice).

Focussing on my immediate area, north Petersfield in Cambridge, as an active supporter of the Friends of St Matthew’s Piece, I stress the need to both retain and strengthen the provisions of the existing 2018 Local Plan Policies 23 and 60 (see https://tiny.cc/FoSMP23and60). Petersfield is the most densely populated ward in Cambridge, and the ward with both the poorest tree canopy cover and worst open-space provision (see https://tiny.cc/FoSMPtrees4 & https://tiny.cc/FoSMPappsIV-V).

The Friends of St Matthew’s Piece therefore seek for the provisions of existing Policy 23 in the New Local Plan to explicitly protect and preserve the northern half of St Matthew’s Piece and its invaluable trees. Although partly ‘Protected Open Space’, and not designated as a potential development site under the 2018 Local Plan, this area still lies within the boundary of the ‘Eastern Gate Opportunity Area’. Any possible ambiguity must be explicitly removed for both for the northern half of St Matthew’s Piece and also Abbey Ward's New Street Allotments (there are no allotments at all within Petersfield).

The Friends of St Matthew’s Piece also seek for the provisions of existing Policy 60 (on tall buildings) in the New Local Plan to be fully retained and also strengthened so that the wording of the Policy can be fully enforced by Planning Officers, as explained very briefly here: https://tiny.cc/FoSMP23and60.

Many local residents hold strong views on the First Proposal's inclusion of a possible development site on St Matthew’s Street – for 12 houses to be constructed in place of the existing garages. I wish here to stress the fundamental needs to both:
• protect and fully preserve the magnificent mature tree at the eastern edge of the site; and
• take full account of any increased stress to water and drainage/sewerage systems in evaluating any future proposals.

Introduction

Thakeham Homes Ltd (Thakeham) is pleased to be participating in this consultation and has outlined its position below in response to the consultation on the Greater Cambridge Local Plan – The First Proposals (1st November to 13th December 2021).

About Thakeham

Thakeham prides itself in being an infrastructure-led sustainable placemaker and is committed to creating new, extraordinary places, where the highest attention to detail makes a positive difference.

Thakeham build for the future, for communities and individuals. Our approach sets us apart from our competitors. We deliver our schemes with a focus on sustainable development, looking ahead of current housing standards. From 2025, all Thakeham Homes will be carbon neutral in production and zero carbon in lifetime use.

Each development is different and tailored to its locality with careful consideration of the area’s character, as well as the environment. As a sustainable placemaker first and foremost, Thakeham’s commitment to improving existing communities means its schemes are design and infrastructure-led; engaging with education, highways, healthcare, utilities and other local community, cultural and environmental stakeholders from the start of each project. The delivery of homes facilitates the delivery of physical, social and green/blue infrastructure which benefits the wider surrounding area, as well as the new residents, and ensures that Thakeham create sustainable places to live and work.

As one of 12 members of the NHS Healthy New Towns network, Thakeham is a committed advocate of developing healthy places in line with the Healthy New Town principles. But over time, we have realised that these principles are just the starting blocks, and at Thakeham, as a founder member of the HBF Future Homes Task Force, we are committed to delivering sustainable, zero carbon communities. Out approach sets us apart from our competitors. We deliver our schemes with a focus on infrastructure-led sustainable development.

Sustainability

There is an evident theme in Greater Cambridge in respect of environmental impact and the importance of ensuring any development, whether that be residential or infrastructure, seeks to minimise its impact. Thakeham would like to take this opportunity to outline the measures implemented on its developments to minimise environmental impacts as a direct and indirect result of development:

• From 2025, all Thakeham homes will be net-zero carbon in lifetime use.
• From 2025, all Thakeham homes will be carbon neutral in production. Our off-site panellised system will make construction more efficient, faster, enhancing quality and reducing construction traffic.
• Thakeham is committed to offsetting the embodied impact from the production of new houses, as well as development houses that are zero carbon in lifetime operation.
• Thakeham support the Wildlife Trust’s guidance on Homes for People and Wildlife. Our commitment is to at least 20% biodiversity net gain (double the government’s target within the recent Environment Act 2021) on all our developments post-2025 with attractive and functional green and blue infrastructure.
• Through placemaking and the implementation of sustainable travel plans, Thakeham prioritises walking and cycling over car travel, helping people make more sustainable choices around walking, cycling and taking public transport, as well as highlighting innovative car-sharing online platforms such as LiftShare to reduce single-occupancy car use and facilitating use of autonomous vehicle/pods.
• Thakeham provides electric car charging points at all of their homes both market and affordable alike, reducing barriers to customers purchasing emission-free vehicles.
• Thakeham is keen to champion low carbon transport in the local area, encouraging local transport services such as buses to electrify their fleet.
• Mechanical Ventilation with Heat Recovery (MHVR) is installed in our homes, which has a filter built-in to capture incoming pollution to provide fresh filtered air.
• Thakeham works with its supply chain with an aim that all mechanical plant on site is less than 18 months old, which means it is less polluting and more fuel efficient

Response to Options

Thakeham has reviewed the consultation documents and has chosen to comment on key questions and themes where relevant to our business to comment on.

Vision and development strategy
Section / Policy Your comments
Vision and aims Thakeham supports the Council’s vision for new development to come forward with sustainability and healthy place shaping at the forefront.

As we’ve touched on above, Thakeham support the focus on healthy place shaping, with a need to ensure that future development maximises opportunities for journeys to be made on foot or bicycle. This will necessitate ensuring new developments prioritise non- motorised transport and are easily accessible to full range of day-to- day services and facilities.

Thakeham has made a number of commitments in respect of its own carbon impact, ensuring that all its development will be net-zero carbon in lifetime use and carbon neutral in production by 2025.
Additionally, Thakeham has made a commitment to achieve 20% biodiversity net gain on all projects post-2025 which is double that set out in the Environment Act 2021.
How much development, and where – general comments Whilst Thakeham supports a weighted distribution of development towards the most sustainable locations and key employment hubs, we would emphasise the importance of a variety of growth locations and sizes to support housing growth. New settlements, strategic extensions and development in rural locations all form a key part in meeting varying housing needs and ensuring a consistent supply of housing delivery.
S/JH: New jobs and homes Thakeham is supportive of the Councils’ conclusions that adopting the suggested ‘standard method minimum homes and related jobs’ approach would not be appropriate for Greater Cambridge and would not support its economic growth aspirations.

It is acknowledged that the Councils’ have sought to accommodate an uplift to accommodate their economic growth aspirations, suggesting that the ‘medium level of homes’ approach is justified, resulting in a need for 44,400 homes over the plan period 2020-2041 amounting

the 2,111 homes per annum, alongside provision of 58,500 new jobs over the plan period.

Whilst the ‘maximum level of homes’ does not represent the Councils’ preferred approach; it is worth noting that this approach does acknowledge housing need arising out of fast job growth and therefore the Employment Land Review makes recommendations to provide more that the ‘medium’ scenario level of jobs to provide flexibility.

Thakeham is supportive of the Councils’ intention to accommodate their full objectively assessed needs for housing and jobs within the plan area. It is also acknowledged that a 10% buffer has also been added into their housing requirement to provide flexibility, amounting to a housing requirement of 48,840 over the plan period.

The Greater Cambridge Local Plan will need to ensure that it is planning for a sufficient number of new homes to support its economic growth aspirations. Whilst it is acknowledged that the medium option for new homes does incorporate an uplift for economic growth in the area, in addition to the application of a 10% buffer to reach the suggested housing requirement. Thakeham would suggest that the Councils undertake further work to ensure that the correct uplift has been applied to ensure that the Councils can meet their relevant aspirations in terms of job creation and growth, and as consequence provide the right level of housing to support this. This is important to ensure that existing employers in the area can continue to thrive and expand importantly retaining and attracting staff including graduates, in what is a global recruitment marketplace for many of the industries already located in Greater Cambridge. Further, in order to ensure Greater Cambridge continues to be a focus for inward investment into the UK, following on from the successes of the past, continued focus on supporting employment growth will be key and part of that will be providing housing to attract not just highly skilled staff but also for the variety of lower paid workers such as cleaners, delivery drivers and shop workers. These lower paid workers are necessary to support the wider community and economy such as in Greater Cambridge, where land and house prices are high. These people are either driven out, much has been the case in London and has been seen in parts of Greater Cambridge to more
affordable locations, but with the consequence of a longer commute,

or greater affordable housing provision is required to accommodate them.
S/DS:
Development strategy The first proposals consultation is suggesting a focus on existing commitments and expansion of existing sites to meet the suggested housing need. Where new sites are proposed these are focussed predominantly within and around the edge of Cambridge.

The background text to S/DS suggests that very limited development is proposed in rural areas due the Councils’ desire to focus growth to more readily sustainable locations. Whilst, as we have touched on above, Thakeham supports a weighted distribution of development towards the most sustainable locations and key employment hubs, we would emphasise the importance of a variety of growth locations and sizes to support housing growth. New settlements, strategic extensions and development in rural locations all form a key part in meeting varying housing needs and ensuring a consistent supply of housing delivery.
S/SH: Settlement hierarchy The settlement hierarchy seeks to group together similar settlements into categories that reflect their scale, characteristics and sustainability. It then seeks to limit development in any settlements which fall within the ‘Minor Rural Centre’ category and below.

Thakeham considers this view is overly prescriptive. The Settlement hierarchy identifies just 8 settlements which would have no limit on individual scheme size:

City: Cambridge
Town: Cambourne, Northstowe and Waterbeach New Town
Rural Centres: Bourn Airfield New Village, Histon & Impington, Great Shelford and Stapleford and Sawston

The Greater Cambridge Area covers a significant geographical area and this suggested policy approach limits development opportunities across the plan area. It is suggested that development at Minor Rural Centre’s should incorporate schemes of a maximum scheme size of 30 dwellings with lower tiers suggesting significantly less.

Policies should retain a flexible approach to ensure that promotion sites and applications can be assessed on a site by site basis on the
merits and positive contribution they could make to an existing and

future community. Development opportunities in these communities could have significant longer-term sustainability benefits by helping existing services remain, and where appropriate levels of growth are accommodated, new services could be provided as a result of development.

Climate change
Policy Your comments
Climate change - general comments Thakeham is supportive of the Councils’ objectives to enhance climate change resilience and transition Greater Cambridge to net zero carbon by 2050.

As a developer, Thakeham prides itself in the objectives it has set in respect of climate change and the impact development can have.
Thakeham has a key focus on sustainable practices both in construction and placemaking. Our approach sets us apart from our competitors. Thakeham’s schemes are delivered with a focus on sustainable development, looking ahead of current housing standards. From 2025, all Thakeham homes will be carbon neutral in production and zero carbon in lifetime use. Thakeham are a founding member of the HBF Future Homes Task Force, which examines
how the house building industry can work toward delivering net
zero carbon homes in order to support the Government’s target of the country delivering ne zero carbon emissions by 2050. Thakeham has a particular focus on first improving the fabric of buildings, constructed from sustainable timber sources, consideration of sustainable energy features and a sustainable procurement strategy which encourages the use of recycled materials. Thakeham intends to open a new MMC factory in the future, which will provide locally sourced MMC constructed homes further helping to reduce the environmental impact of construction.
CC/NZ: Net zero carbon new buildings Thakeham considers that the proposed policy direction is too prescriptive and does not provide sufficient flexibility for advances in technologies and Building Regulations. Policy wording should be less prescriptive on the measures used to achieve net zero carbon buildings, rather there should be sufficient flexibility to allow the methods for achieving such targets to be assessed on a site-by-site basis. This is critical as technology is advancing quickly and will
continue to do so during the lifetime of the emerging local plan and

consequently to set prescriptive policies will have the effect of the local plan being out of date before or at adoption.

As above, Thakeham prides itself in its own objectives for all its new homes to the zero-carbon in lifetime use and carbon neutral in production by 2025.

Biodiversity and green spaces
Policy Your comments
BG/BG: Biodiversity and geodiversity Thakeham is supportive of the policy direction of BG/BG and the Councils’ aspiration to require a minimum of 20% biodiversity net gain, whilst also acknowledging the difficulties this may bring for smaller sites with a suggested contribution mechanism to allow these sites to meet the requirements of the proposed policy. However, the current policy direction seeks to limit off-site habitat measures to align with the Greater Cambridge green infrastructure network strategic initiatives.
Whilst it is acknowledged that this may represent a preferred approach, this may cause issues in deliverability due to availability of such land. Policy BG/BG should incorporate sufficient flexibility to allow sites to achieve the required biodiversity net gain requirements by measures which are most appropriate to that site, if this requires off-site habitat creation there should be sufficient flexibility to allow consideration of all suitable options to ensure such requirements do not stifle development.

Thakeham itself has already made a commitment to achieve at least 20% biodiversity net gain as a result of our projects post- 2025.

Wellbeing and inclusion
Policy Your comments
Policy WS/HD: Creating healthy new developments Thakeham supports the objective and policy direction of Policy WS/HD, requiring health principles to be applied to new development, drawing on the ten principles developed from the Healthy New Towns Initiative.

In our view, relevant policies in respect of wellbeing and inclusion could go further to set out requirements on not only creating healthy new developments, but other measures which maximise wellbeing

benefits that developments can offer those who build them, those who live in them and the communities around them now and into the future.

Thakeham itself is passionate about having a positive impact on people’s wellbeing, constantly striving to deliver against our four key- focus areas:

• Building local communities via excellent placemaking that creates interconnected communities that challenge issues of loneliness and promoting healthy living, and via our long-term charity partnerships.
• Building future generations via our school
engagement programmes, including our industry leading holistic ecology programme ‘Eddie and Ellie’s Wild Adventures’ for primary age pupils, and providing inspiring careers support to secondary age pupils through our Cornerstone Employer status with The Careers Enterprise Company.
• Building a stronger Industry with our support of small and medium size enterprises and upskilling for local workers, supporting apprenticeships, and actively contributing to the diversification and upskilling of the construction sector.
• Building Sustainable places by tackling issues of climate change, biodiversity loss and societal disconnects via our ambitious Sustainability Strategy.
WS/IO: Creating inclusive employment and business opportunities through new
developments Thakeham is supportive of the policy direction of Policy WS/IO and as touched on above, adopts its own approach to creating inclusive employment and business opportunities through our support of small and medium size enterprises and upskilling for local workers, supporting apprenticeships, and actively contributing to the diversification and upskilling of the construction sector.

Homes policies
Policy Your comments
H/AH: Affordable housing Thakeham support the Councils’ policy direction in respect of Affordable Housing and the importance that such homes are built with inclusion, health and wellbeing at the forefront. Thakeham continues to provide policy compliant affordable housing across all of our developments whilst adopting a truly tenure blind approach to affordable housing which creates cohesive communities.

H/SS: Residential space standards and accessible homes Whilst Thakeham supports the Councils’ aspiration to see good quality homes delivered across their district, such policy requirement which seeks all dwellings to meet NDSS needs to be supported by robust evidence that there is a specific need to introduce such standards.

Any policy requirements in respect of housing accessibility requirements should be based off identified need, with sufficient flexibility incorporated to ensure that provision is directed to the right places. In particular, blanket policy requirements for M4(2) in all new developments should not be adopted as these requirements should be based off identified need, whilst requirements in relation to M4(3) can be particularly onerous and should only be directed to developments where there is an identified end user.
H/CB: Self- and custom-build homes Whilst Thakeham is supportive of self and custom build home provision in Greater Cambridge, it is not considered that a blanket policy as suggested by H/CB on developments of 20 or more is appropriate or feasible. Self and custom-build products should be directed towards key strategic allocations to ensure such homes are deliverable. Self and custom build home provision should also be based off identified need.

We trust that these representations are useful and clear, and we would be grateful for confirmation of receipt of our submission. In the meantime, please do not hesitate to contact me if you have any further queries or require any further information.

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

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

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

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

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

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

The Federation of Cambridge Residents’ Associations (FeCRA) is a grassroots civic voice for everyone in Cambridge and for its environment. Residents want a say in shaping Cambridge’s development to ensure that the city grows in a way that is sustainable and inclusive, achieves balanced communities and addresses the issues of climate change and health, social equality and quality of life. Residents know their areas well, and they want to be involved in evidence gathering and data collection.

Over the last years residents' associations have organised successful discussions on parking, local election hustings, Greater Cambridge transport schemes, neighbourhood planning, heritage and public realm and green spaces and the river and biodiversity.

FeCRA’s well attended AGM events are organised on the same basis, featuring presentations from prominent experts including leading landscape architect Kim Wilkie, George Ferguson, former Mayor of Bristol and the distinguished Oxford ecologist Professor David Rogers. More recently, the Supersize Cambridge event which attracted 230 people and involved community reps from all over Cambridge highlighted concerns about employment led growth and the global interests driving this. FeCRA’s strength is in its network of members in all city neighbourhoods and good channels of communication with villages across South Cambs, along with the five OxCam Arc counties and Norfolk, Suffolk, Hert and Essex. The Federation is entirely voluntary and self funded.

A sense of neighbourhood and wellbeing and belonging and mutual support is especially important in a city which has earned the unenviable title of the most unequal city in the UK.

Draft Local Plan
How much development and where
Many residents are shocked at the level of growth proposed in the new Draft Local Plan and what they see as the plan’s failure to consider the overall environmental capacity and climate change impact and the effect on the historic environment (built and natural) in a holistic way. There is no mention of Covid and opportunities for city centre residential and/or other uses resulting from potential radical changes in retail and office working.
There is no consideration or assessment of current growth in the pipeline or of the success or failure of current Local Plan policies, no assessment of the cumulative impact of current growth, especially in terms of delivering the claimed nature and quality of development.

There is a complete dearth of new cultural or provision for other ‘city-scale’ needs which will put the city centre under even greater pressure.

Where is the overall vision of what Cambridge will be like in the future? Who is the city for? This plan does not make clear.

The question of how much development and where is premature pending the January 2022 consultation on the Regional Water Plan and the investigation of sewage infrastructure and sewage dumping by Anglian Water.

Inadequate Water Supply

Cambridge City and South Cambridgeshire already have an unsustainable supply of potable water. In August 2020, the Environment Agency, in response to a query on the viability of water supply to Northstowe Phase 3A wrote to Monica Hone of Friends of the Cam that 'current levels of abstraction are causing environmental damage. Any increase in use within existing licenced volumes will increase the pressure on a system that is already failing environmental targets', and 'many waterbodies did not have the flow to support the ecology.'
On the 1st July 2021, DEFRA announced that chalk streams would be given enhanced environmental protection, and published the Environment Agency document titled “Water stressed areas – final classification 2021” which included the fact that the supply areas of Cambridge Water and Anglian Water are areas of serious water stress, page 6.
According to Appendix 3, Cambridge Water needs to reduce abstraction by 22 megalitres per day from levels current at 1st July 2021, and Anglian Water needs to reduce abstraction by 189 megalitres per day from levels current at 1st July 202

Yet, one of Anglian Water’s proposed ‘solutions’ to this problem is to pump water from North Lincolnshire, which is also classified by the Environment Agency in the above report as a water stressed area.

The expectation that ‘green’ growth and River Cam Corridor nature tourism can fund a system of water management without addressing over- abstraction and sewage in the rivers

The local sewage system is currently inadequate. The inadequacy of the sewage system is evidenced by the number of sewage spills by smaller Anglian Water sewage works into the Cam Valley. Currently, there are no plans to improve failing combined sewer overflows (csos), just promises to monitor them more accurately. The Cam Valley upstream of Cambridge saw 622 hours of untreated wastewater enter the rivers in 2020, yet Anglian Water is proposing to move the one sewage works in the area which has been upgraded and has sufficient capacity until 2050, the main Cambridge works, into the Green Belt and to spend at least £227 million of public money to do so. This will be the subject of only a partial public inquiry because it has been submitted as a National Infrastructure project in order to minimise public scrutiny.

To date there have been no upgrades at any of the smaller works in the area while more and more taps are still being connected. The Environment Agency has already warned at least one Cambridgeshire local planning authority, East Cambs District Council, that they must stop looking at the sewage requirements of single planning applications and instead look at the cumulative effects.

How can anyone talk about ‘green’ growth and nature tourism when the water companies are over-abstracting and filling the Cam chalk streams with sewage.
New jobs and homes – the plan proposes 58,500 jobs and 44, 400 homes

The way in which this consultation is framed and the fact that it does not address how the region’s water crisis and wastewater and emission problems will be resolved ignores both environmental constraints and the failure of current policies to provide affordable housing. It does not give a true picture of the cost of such high employment growth for the UK’s driest city with a water crisis whose world famous river is drying up and dumped full of sewage.

It undermines the Government’s policy of ‘levelling up.
It completely ignores how the plan will ensure that new developments are for local people and not dormitories for London commuters or just opportunities for foreign investors.

New communities take time to emerge, if they do at all, but the issue is that many new developments are injected into places with existing communities that may suffer as a result, an issue this plan does not assess.

Professor Dieter Helm, Chair of the National Capital Committee has stressed the importance of long-term risk assessment in ensuring net environmental gain, in perpetuity, despite development. There is no evidence that this has been done.

There are massive environmental capacity issues which the Draft Local Plan does nothing to address, with inadequate space in city streets and public realm to cater for existing traffic, let alone approved growth already in the pipeline – even before considering these First Proposals. The capacity issues have to be tackled, with additional growth allowed only if they can be resolved.

Green Belt Assessment

The Green Belt assessment is not fit for purpose, because it ignores historic environment designations and landscape character constraints.

On the edge of Cambridge the serious landscape impacts of the Cambridge BioMedical Campus expansion southwards into the Green Belt open countryside towards the Gogs will severely damage this lovely setting of the city with its beautiful chalk downland views. The expansion and likely increase in footfall will hugely impact the small nature reserve of Ninewells, the reserve’s unique character and boskiness and farmland birds.
Building NE Cambridge will indirectly destroy the Green Belt by displacing the sewage works and using a lot of concrete which has a very high carbon footprint.
There is no operational need to move the treatment works as Anglian Water has confirmed. The relocation is taking place to enable development within Cambridge in which the water company is a beneficiary as co-developer. The current site is more than adequate for at least another 30 years and could be upgraded at far less cost. The existing treatment works at Milton is effective and has spare capacity. It was upgraded only recently, at a cost of £21 million in 2015, in order to support planned development in Cambridge and the surrounding area until 2050 and is being vacated only to enable redevelopment. We understand that the Milton Plant is currently only running at approximately 50% capacity. The CO2 cost embedded in the new structure and emitted in demolition and construction is sizable.

Many residents question why the works are being moved given the impact on the Green Belt, the loss of valuable farmland, and the harm to local communities, all of which are united in their opposition. They question how this complies with the guidance outlined in the HM Treasury’s Green Book Valuation of Wellbeing Guidance for Appraisal https://www.gov.uk/government/publications/green-book-supplementary-guidance-wellbeing especially as the Stantec Report prepared as part of the review of the Local Plan and the letter from the Environment Agency https://www.fecra.org.uk/docs/Env%20Agency%20re%20Northstowe%207%20August%202020.pdf make clear that any further development beyond that already planned is unsustainable as ‘current levels of abstraction are causing environmental damage. Any increase in use within existing licensed volumes will increase the pressure on a system that is already failing environmental targets’.

There is no mention in these plans of how relocation of the wastewater plant will address any of the concerns about all the sewage being dumped in the Cam or how Anglian Water proposes to make the River Cam clean and safe for all users. If you were going to spend £200m plus, or even a fraction of it, it should be spent on improving and updating the small local sewage works based around villages etc, which release sewage in the Cam via its tributaries, not on rebuilding something that is working well. In the case of these small poorly functioning sewage systems Anglian Water is almost solely responsible and that is what residents tell us this company should be focusing on, not this grandiose money-making scheme. The chair of Water Resources East, Dr Paul Leinster, is a member of the new Office for Environmental Protection. He is on public record as stating that what to do with the wastewater is one of the biggest problems for development in the region proposed by the government for the Oxford Cambridge Arc.
There are a number of SSSI’s close to the site which could be affected by its construction and operation: Brackland Rough, Cam Washes, Cherry Hinton Pit, Chippenham Fen and Snailawell Poors Fen (a RAMSAR site), Devils Dyke, Felan Dyke, Fulbourn Fen, Gog Magog Golf course, Great Wilbraham Common, Histon Road, Roman Road, Snailwell Meadows, Stow-cum-Quy Fen, Upware South Pit and Wicken Fen, which is another RAMSAR site.

Anglian Water recognises the likelihood that the surface water originating at the works at the Honey Hill site will drain towards Quy Waters protected waterbody and could contaminate it. Yet they have ignored the fact that contaminated groundwater in the chalk aquifer beneath the site could pollute these other receptors and protected rights (local well users) as well as other parts of the surface water drainage network.

The Honey Hill site is in the National Trust Wicken Fen Vision. This is a National Nature Reserve and a Nature Conservation Review site. It is a designated RAMSAR, SAC wetland site of international importance and part of the Fenland Special Area under the Habitats Directive. How does a scheme which robs East Cambridgeshire villages of their green belt and medieval river landscape setting and which impacts the Wicken Fen Vision correlate with protecting Green Belt land which is specifically designed to preserve the historic character of Cambridge and its green belt setting and the River Cam?
Democratic deficit in the process and evidence basis for the Draft Local Plan

Water Resources East have stated that their regional water plans which include plans for natural capital align with the Government's plans for growth. Sewage in rivers and chalk streams is a matter of national concern, yet Water Resources East say that sewage is not part of their remit. They have also said that there will not be public consultation on the regional water plan.

Meanwhile, the public consultation for the Draft Local Plan is taking place now, yet the consultation for the Regional Water Plan is not due until summer 2022. The public and councillors are forced to respond to Local Plan proposals with no idea whether, and if so, how, the water and sewage challenges can be resolved or what trade-offs have been proposed.

South Cambs. MP Anthony Browne has rightly expressed concerns about the Local Plan process and about water issues and transparency.

The Draft Local Plan has been prepared by the Greater Cambridge Shared Planning Service, but it appears to be inordinately influenced by the unelected Greater Cambridge Partnership which has business interests represented on its board.

Much of the text of the Draft Local Plan appears to be consistent with announcements made by the self- appointed Arc Leaders Group promoting the so-called Ox-Cam Arc. This flawed concept has been criticised for lack of transparency or accountability right across the five affected counties and one county, Buckinghamshire, has withdrawn entirely from this completely undemocratic, self-selecting, body.

At a presentation of growth scenarios for Cambridge Futures3 given by the Vice Chair of Cambridge Ahead Matthew Bullock and Dr Ying Jin in June 16, 2018 the audience pointed out that all of the scenarios for Cambridge Future 3 led to Cambridge having a much higher level of growth.

They highlighted that the growth scenarios made no mention of environmental capacity issues, nothing on climate change, quality of life, affordable housing or why people chose to live in and around Cambridge for cultural and green spaces reasons etc. At the presentation it was made clear that Cambridge Ahead & Cambridge University planned to monetise the model they had come up with.

So the model was not in any sense charitable work, it was completely commercial.
Bullock stressed how complex the model was that Dr Ying Jin and his team had come up with and that they would need to come up with a price for running the model with different input parameters.

This meant that Cambridge Ahead and Cambridge University controlled access to the model, limiting detailed scrutiny and testing by independent third parties.
Those working on the growth scenarios included officers and consultants from SQW – the same consultancy employed along with the real estate consultants GL Hearn by the planners to assess the modelling for the Draft Local Plan as ‘they were not conflicted’.

The presenters Matthew Bullock and Dr Yin Jing said that changing elements of the model and programming scenarios was technically challenging and slow, making it difficult or impossible to test a large number of scenarios.

They also said that they intended to monetise the model, e.g. by charging planning authorities, ONS (the Office of National Statistics) and developers to use it.

The business group Cambridge Ahead had a strong commercial motive for this modelling and the modelling evidence for a much higher level of growth and lots more houses to be built, gives a strong lead on where development should take place. Attendees at the Case for Cambridge Future 3 meeting pointed out that the pre-set "no holds barred" scenarios defined by Cambridge Ahead and Cambridge University and officers and consultants working with them would thus become the only options, even though there were likely to be many other scenarios that would produce better outcomes.
Thus the modelling that has been used to inform the Cpier Strategy cited in the Greater Cambs Employment Land and Economic Development Study Draft Local Plan does not take account of social justice, regional landscape strategy or address environmental capacity issues including those of the river, the city centre and the city’s green spaces. Nor does it consider how people want to live, respecting what communities value, and the issues of climate change, the natural world, water shortage, sewage etc.

This Draft Local Plan reflects those pre-determined scenarios of building on the urban fringes and transport corridors to support the high employment growth defined by Cambridge Ahead and the interests funding the research.

At the Case for Cambridge Future 3 meeting attendees referred to "No holds barred scenarios" and a number of people noted the 'densification' scenario assumed that Trumpington Meadows would be developed alongside Cambridge South station as a location for high density development which would assume a planning approach of creating new development which you “mitigate” by reserving areas of green spaces as ‘wild belt’. They pointed out the approach was to sell housing on that basis and then take it back afterwards for infill and that this was already happening at Cambourne.
The same point about infill and wild belt was made by David Plank of the Trumpington Residents Association regarding the recent presentation by the planners of the Draft Local Plan and the BioMedical Campus Expansion plans round Ninewells to the South Area Committee.
In August 2019 the FeCRA Committee wrote to the Deputy Leader of Cambridge City Council to express concern that the Shelford Local Plan workshop for city residents, cited as the formal first stage of public engagement on the Draft Local Plan had been organised at very short notice and with very little opportunity for city residents to engage in the first formal stage of the Local Plan Process.

FeCRA filmed all f the Local Plan Presentation on the 2018 Local Plan. The film is available for everyone to see. There was very positive feedback from Residents Association members but the presentation also flagged up major concerns about the ‘growth agenda’ and the apparent lack of transparency and democratic input around it.

We were told at that meeting that there would be an opportunity for residents to contribute to early discussions about the next LP, yet this Local Plan workshop was arranged at such short notice and at a time and place that made it difficult for many city residents to attend. Consequently very few city residents attended.

Green Infrastructure Modelling Workshops
In June 2020 Deputy Director of Greater Cambridge Shared Planning, Paul Frainer, writing to the FeCRA Committee, said:
‘Ahead of and separate to the Local Plan process, the Local Nature Partnership (as a separate body albeit with some local authority input) has identified priority projects it would support if funding were to become available in the short term, but no decisions have been made through the Local Plan process about which green spaces to prioritise.

The Local Plan green space evidence base study will identify priority projects, and will advise which should be included in the Local Plan, and which should be delivered through land management as opposed to development processes. This priority list will in future also inform biodiversity net gain offsetting, and bids for funding from other sources’.

The minutes for the June 2020 Natural Cambridgeshire board meeting states that the board will:
• ‘Work with developers to enhance nature either on site or through offsets’ –Cameron Adams, the Environment Agency
• ‘Consider how best to engage with farmers and other landowners, and help them get better returns from their investments’ –Rob Wise NFU
• ‘Collaborate with Natural Capital East’ –Cameron Adams
• ‘Review progress of Doubling Nature at end 2020’ –Richard Astle - Athene Communications
On 26 July 2020 the FeCRA Committee wrote to MPs, copied to the planners and Lead Councillors to express concern about the Greater Cambridge Green Infrastructure Online Survey - 27 July which had been framed again in a way that excluded residents from having a say, particularly about the river and its historic environment. They asked why this survey was linked to funding bids, S106 development sites and future parks accelerator plans and why there had been no assessment of impacts and issues arising from current and already approved growth on green spaces at this stage?

“Why is there no engagement with strategic environmental capacity issues as a vital part of the evidence base for the new Plan?” The Committee pointed out that the government’s plan for sustaining high growth and building one million houses in the OxCamArc is underpinned by Natural Cambridgeshire’s vision for “doubling local nature”, with urban fringe parks in the green belt. Plans for ‘linear river parks’ feature in council and development plans but there had been no consultation with friends or river groups or local councillors.

The River Cam is the only river in the country that is not back to normal flows, yet exponential growth fuels huge pressure upon our natural water supplies. Concerns about the impact of over-abstraction on the River Cam have been expressed but large development keeps getting approved.

Stage 3 of this Local Plan Green infrastructure consultation featured technical workshops, themed around the benefits that green infrastructure provides, to discuss the issues and opportunities arising from the survey responses.

Community reps and residents who had not been able to engage with this survey or who didn’t have funding bids with developers and NGO’s were not able to get a say at the next stage.

This letter followed concerns expressed to Greater Cambs Planners and Cllrs Katie Thornburrow and Bridget Smith that many residents had not been able to access the on line Green Infrastructure consultation hub and the inaccuracy of the mapping and data, highlighted by experienced university conservationists.

Addressing the challenges of climate change and health, social equality and quality of life benefits from local knowledge and the involvement of residents who know about water, flooding, wildlife and nature and managing green spaces and local resources in their areas, working with their elected councillors. Residents say that decisions about land use and ecology have been made by business and interest groups without local knowledge or accountability

The inspirational town planner Jan Gehl advocates that to build communities that work well where people, not cars, occupy the pavement, the evidence needs to be shown and environmental capacity issues need to be addressed. One should count all the pedestrians, cyclists and strollers going by, just as highway planners have long tallied up road users in vehicles and the number of people using the river and its green spaces.
Where is the evidence that this has been done in the Draft Local Plan? It has not been demonstrated that there is sufficient water supply within Greater Cambridge to support future development and existing ground water abstraction is impacting water flows within chalk streams in the region anday need to be reduced, especially in the light of climate change.

The situation with groundwater around Cambridge is critical: the whole Cam river system is in crisis
Using water more efficiently is important, but efficiency will not increase the maximum volume of water that can be supplied on a sustainable basis without impacting the environment.

As such REFUSAL of developments is necessary where there is no available water to supply them and/or the environmental impacts caused from supplying that water outweigh benefits of the grant of that permission.
A similar point applies to discharge, especially where this is to groundwater. Where a European site is affected, alternative locations and OROPI ( Overriding Reasons of Public Interest ) may need to be considered prior to any planning decision.

NPPF para 7 makes this point: "The purpose of the planning system is to contribute to the achievement of sustainable development. At a very high level, the objective of sustainable development can be summarised as meeting the needs of the present without compromising the ability of future generations to meet their own needs. "

The presumption in favour of sustainable development cannot be determined without sufficient information on the water demands of a development, how these will be met and the implications for the environment and future generations.

We strongly suggest that all planning applications should at application stage confirm their total required annual water usage and have accompanying documentation to confirm that such water can be supplied and discharged where applicable in a manner.

We suggest that all developments are subject to Habitat Regulations Assessment based on their cumulative and in-combination impacts on the available water supply.

Biodiversity
Conservation is essential to sustainable development and together with enhancement of biodiversity should be considered as a key element of good planning and design. 'Doubling nature', Biodiversity Net Gain (BNG) and Natural Capital Accounting (NCA) are being used as bargaining chips by developers. That broadly amounts to saying, 'No development means no funding for nature'. This is the antithesis of John Lawton's 2010 plea in 'Making Space for Nature' of significant funding for Nature conservation without any strings attached.
The concept of doubling nature is ill-defined - doubling what, exactly? The Draft Local Plan needs to define exactly how the concept will be understood and measured.

The global experience of Biodiversity Net Gain, reviewed by zu Ermgassen of DICE, University of Kent, is that it fails twice as often as it succeeds, even though it had the lower bar of No Net Loss, NNL rather than BNG.
The same group more recently showed that 95% of early-adopters of BNG practices in England are carrying out on site offsetting (something not covered at all in the new Environment Law), where the developer is the judge, jury and executioner of any offsetting plans. In any case, on site offsetting will not encourage many forms of wildlife and will be prone to the dog-fouling and trampling that harms many wildlife areas, even those remote from housing. Meanwhile, off-site off-setting is already damaging local communities in some rural areas.
Natural Capital Accounting is an untested concept. The monetary assessment of ecosystem services (the 'yields') is recognised as being inadequate at present, while assessing the monetary value of ecosystem stocks is more or less impossible (Ian Bateman, communicated to David Rogers). Yet the resulting monetary assessments may be used to trade away environmental for economic assets with a greater yield, for example a factory in a water meadow.

The natural environment is our vital life support system, and it is a dangerous delusion to imagine that it can be rendered easily into any economic framework, let alone the pre Dasgupta framework that gives GDP/GVA primacy over all other forms of stocks and yields.
Dasgupta defines wealth as the sum of natural, human and economic capitals and yields, and sustainability as the condition where this sum is either stable or increasing. Economic growth at the expense of natural capital and yields is therefore unsustainable.
We request that the Cambridge Local Plan adopts the Dasgupta definition of sustainability, i.e. definitely not the NPPF's false definition of 'sustainability', with the caveats mentioned above, especially the false or under-valuation of natural capital. This would provide a better starting point, and the Plan should be reworked in this context.

Sea level rise
Large areas of Cambridgeshire, including parts of the City of Cambridge, are subject to continuously increasing flood risk. Indeed, not only is sea level rising, the rate of sea level rise is increasing rapidly. For many years, since measurement began, sea level in the Wash was rising at a rate of 3mm per year. In 2019 it was measured by the Environment Agency in the Wash, and confirmed by IPCC figures globally, that the annual rate was now 3.3mm per year. In 2014, the IPCC report estimated a sea level rise of 1 metre by 2100. In 2019, the IPCC increased this estimate to 1.1 metres by 2100. In 2021, the IPCC has increased its estimate again, to a terrifying 2.4 metres by 2100. Meanwhile, the meteorological partnership Climate Central estimates a 4.7 metre sea level rise by 2100 if global temperatures rise by 2°C. Both the IPCC 2021 and the COP26 leadership have confirmed that the world is currently on track for a 2.4°C global temperature rise.

The other solution to Cambridgeshire’s water shortages being proposed by Water Resources East and Anglian Water is to build two reservoirs in the Fens, one in South Lincolnshire, the other in Cambridgeshire near the River Great Ouse. However, there is little point in building reservoirs in the Fens when it is clear that there is a high risk they will be flooded by saline water within decades.
As flood risk increases, the Fens will initially be subject to occasional and then annual flooding caused by water in its tidal rivers meeting increased volume of run-off from development. Eventually, the tidal inflow will prevail and flooding will become permanent as the sea level inexorably increases. However, even the first stage will have a significant negative effect on agriculture. The Treasury Green Book assumes loss of cropping for one year if sea water inundation occurs. In fact, as was found in the 1947 and 1953 floods, reduced crop yields last up to seven years due to the presence of a nematode in sea water.

Climate Change
We support regular reviews to keep pace with developing technology, standards, Government targets (e.g. the Heat and Buildings Strategy, not mentioned in the draft Plan) and rapidly developing guidance and best practice. There are also serious quality control challenges in relation to whether aspirational aims are actually delivered. Outline planning permissions must be subject to the aspirations articulated in the Draft Local Plan.

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

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

For all of these reasons we strongly object to the level of growth proposed in the new Draft Local Plan
Local government should not be planning more economic and population growth in this area or more housing than current government targets require, but prioritising social housing and new water infrastructure to reduce stress on our rivers and wildlife. It should be supporting the national ‘levelling up’ policy. It should be consistent with the government’s ‘brownfield first’ objective which will deliver badly needed homes faster. It should take into account the growing flood risk to large parts of the county and consequences for national food supply. It also needs to take into account the as yet, unknown, long-term effects on employment and travel behaviours of the COVID pandemic.

We request that this flawed Draft LP is rejected, re-written and re-submitted for full public consultation.

Context for this consultation

The current situation nationally and internationally with respect to Covid 19 could not have been foreseen when the review of the South Cambrdgeshire and Cambridge Local Plans commenced in 2019. The economic and social consequences of the pandemic and, at some point in the future, its aftermath, could be significant in both the short term and long term, yet no assessment of any possible future changes are built into the proposals set out in this consultation.

Given that certain major housing developments , such as Northstowe and Waterbeach are well underway and planning applications regarding new employment (such as at Granta Park and the Babraham Research Campus) are coming forward, is this consultation so time critical that it could not be delayed for, say,12 to 18 months ?

The location of at least some types of jobs could be affected by more remote working than pre-2020 and this, in turn, could mean that some individuals would no longer need to live close to the company or organisation for which they work, and this would have an impact on travel to work and commuting patterns.

A delay would give time for some indications of impacts relating to local jobs and housing to emerge and to be integrated into the emerging Plan prior to consultations such as this..


Location of housing

Much of the housing development the plan period will come from sites that are already in the current planning pipeline (that is, land already allocated for housing in the approved 2018 Local Plans or when developments has already commenced as , for example, at Northstowe, at Waterbeach and on the edge of Sawston).

However, I wish to comment on two of the new allocations.

I am concerned that the move of Marshalls from the airport site as this will lead to a reduction in the range of job opportunities available in the Greater Cambridge area. However, I accept that Marshalls do seem set to move, so development of the airport site (a brownfield site) is appropriate.

I am very concerned about housing on the waste water treatment plant site. It does not seem to me to be good use of more than £100 million of public money to move the waste water treatment plant about one mile in order to build houses on the present plant site. In fact, there is no need to build houses on the plant site. If the Councils were to revise their housing numbers to bring them more into line with government figures, then this site could be removed from the sites needed for housing development.


The Rural Southern Cluster

The First Proposals consultation includes policy areas for the Babraham Research Campus and for the Genome Campus. Given further likely developments at Granta Park, it is surprising to see that there is no such specific Policy Area for Granta Park.

Planning applications submitted over time are considered on an individual basis, but this approach fails to take into account the cumulative impacts of successive developments on Granta Park. In addition, successive planning applications that each involve building hundreds of car parking spaces do not seem to align with reducing dependence on motor vehicles.

Having a Policy Area covering the Granta Park site could provide a locally agreed framework for future development

The proposed Vision for Greater Cambridge is set out at page 20 of the Draft Local Plan and states that:
“We want Greater Cambridge to be a place where a big decrease in our climate impacts comes with a big increase in the quality of everyday life for all our communities. New development must 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.”
Whilst Miller supports the Council’s objectives with regards to climate changes and protecting the environment, it is disappointing that the Vision as currently drafted makes no reference to the Oxford-Cambridge Arc.
The Oxford-Cambridge Arc is an area covering Oxford, Milton Keynes and Cambridge, identified by the Government as a unique opportunity to become an economic asset of international standing. In July the Government held a 12 week consultation which closed on 12 October 2021 seeking views on the vision for the Arc. The consultation document ‘Creating a vision for the Oxford-Cambridge Arc’ (July 2021) confirmed that it is still the Government’s intention to prepare a ‘Spatial Framework’, which will provide a national planning policy framework for the Arc.
As set out at paragraph 1.1 of the Government’s consultation document the Oxford-Cambridge Arc ‘is a national economic priority area’. Its world-class research, innovation and technology can help the UK prosper in a changing global economy. But success cannot be taken for granted. As advised by the National Infrastructure Commission, without urgent action, a chronic under-supply of homes could jeopardise growth, limit access to labour and put prosperity at risk.
If the Arc to reach its full potential local authorities will need to plan positively in their areas to deliver the transformational growth required. On this basis we would suggest that the Vision is revised as follows:
“Greater Cambridge is a leading UK and global hub of innovation, which plays a key role in the internally recognised Oxford-Cambridge Arc. We want Greater Cambridge to be a place of great prosperity and innovation where a big decrease in our climate impacts comes with a big increase in the quality of everyday life for all our communities. New development must 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.”

The proposed Vision for Greater Cambridge is set out at page 20 of the Draft Local Plan and states that:
“We want Greater Cambridge to be a place where a big decrease in our climate impacts comes with a big increase in the quality of everyday life for all our communities. New development must 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.”
Whilst Miller supports the Council’s objectives with regards to climate changes and protecting the environment, it is disappointing that the Vision as currently drafted makes no reference to the Oxford-Cambridge Arc.
The Oxford-Cambridge Arc is an area covering Oxford, Milton Keynes and Cambridge, identified by the Government as a unique opportunity to become an economic asset of international standing. In July the Government held a 12 week consultation which closed on 12 October 2021 seeking views on the vision for the Arc. The consultation document ‘Creating a vision for the Oxford-Cambridge Arc’ (July 2021) confirmed that it is still the Government’s intention to prepare a ‘Spatial Framework’, which will provide a national planning policy framework for the Arc.
As set out at paragraph 1.1 of the Government’s consultation document the Oxford- Cambridge Arc ‘is a national economic priority area’. Its world-class research, innovation and technology can help the UK prosper in a changing global economy. But success cannot be taken for granted. As advised by the National Infrastructure Commission, without urgent action, a chronic under-supply of homes could jeopardise growth, limit access to labour and put prosperity at risk.
If the Arc to reach its full potential local authorities will need to plan positively in their areas to deliver the transformational growth required. On this basis we would suggest that the Vision is revised as follows:
“Greater Cambridge is a leading UK and global hub of innovation, which plays a key role in the internally recognised Oxford-Cambridge Arc. We want Greater Cambridge to be a place of great prosperity and innovation where a big decrease in our climate impacts comes with a big increase in the quality of everyday life for all our communities. New development must 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.”

Duty to Cooperate
The Duty to Cooperate (DtC) is a legal requirement established through section 33(A) of the Planning and Compulsory Purchase Act 2004, as amended by Section 110 of the Localism Act. The DtC requires local planning authorities to engage constructively, actively and on an ongoing basis with neighbouring authorities on cross-boundary strategic issues through the process of ongoing engagement and collaboration.
The revised Framework introduced a number of significant changes to how local planning authorities are expected to cooperate including the preparation of Statement(s) of Common Ground (SoCG) which are required to demonstrate that a plan is based on effective cooperation and has been based on agreements made by neighbouring authorities where cross boundary strategic issues are likely to exist. Planning guidance sets out that local planning authorities should produce, maintain, and update one or more SoCGs, throughout the plan making process. The SoCG(s) should provide a written record of the progress made by the strategic planning authorities during the process of planning for strategic cross-boundary matters and will need to demonstrate the measures local authorities have taken to ensure cross boundary matters have been considered and what actions are required to ensure issues are proactively dealt with, such as unmet housing needs.
Gladman are supportive of the two Councils working jointly to prepare the new Local Plan for Greater Cambridge, as this both aligns with the policy commitment in the existing Local Plans and allows for strategic matters which cross between the two LPAs to be considered comprehensively in a joined-up manner. Notwithstanding this, it still remains of critical importance for Cambridge City and South Cambridgeshire to work alongside the other Cambridgeshire authorities to ensure that any wider cross boundary issues are addressed. It may be the case that these need to be addressed through SOCGs with the other LPAs.
As demonstrated through the outcome of the Coventry, Mid Sussex, Castle Point and St Albans examinations, if a Council fails to satisfactorily discharge its DtC a Planning Inspector must recommend non-adoption of the Plan. This cannot be rectified through modifications.

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

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

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

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

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

I am writing to object to the Draft Local Plan on the grounds
1) There is an insufficient water supply for the number of dwellings proposed. The Government has allocated a large sum of money to protect the rare chalk streams that are found in this area. The fact is that the only way to give proper protection to our chalk streams is to stop excessive extraction of water from the underground waters that supply the streams and us with water.

2) Do NOT move the sewerage works. These works were upgraded in 2015 and are capable of further upgrading on the present site. To move them would cost at least £227 million of taxpayers money: would take local green belt land out of food production and release vast quantities of carbon into the atmosphere in contravention of the Government’s own stated aim of reducing carbon emissions.
We need local food production to ensure food security.

IF it ain’t broke don’t fix it!!!

3) The consultation process has been undemocratic.
The promise of the discovery centre is is like offering sweets to children. It is blatant bribery.

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

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

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

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

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

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

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

Please confirm that you have received my objection

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

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

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

Please confirm that you have received my objection.

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

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.

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,<BR><BR>I am writing to object to the Draft Local Plan on the grounds of inadequate water supply, effect on national food security, failure to minimise climate change, likely irreparable damage to ecosystems, carbon emissions resulting from construction, lack of an integrated public transport system, undermining of the Government's policy of ‘levelling up’, and a democratic deficit in the process and evidence base . <BR><BR>I support the letter of objection sent to you by Friends of the Cam, available here;<BR><BR>https://www.friendsofthecam.org/sites/default/files/ObjectiontoNext%20LocalPlan_0.pdf<BR><BR>Please confirm that you have received my objection.<BR><BR>Kind regards,
Cambridge resident for 30 years during which the continuous development has resulted in precisely the bad effects that Friends of the Cam point out.

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.

We broadly support the vision and aims as set out in the First Proposals. However, as explained in later sections of our response, we do not believe this plan can achieve them.
For example, “We want Greater Cambridge to be a place where a big decrease in our climate impacts comes with a big increase in the quality of everyday life for all our communities.” This very laudable aim would only be achieved through a strategy that took as its starting point the challenges experienced in our existing built environment - for example energy inefficient buildings and congestion in Cambridge city centre. It is nonsensical to claim that “a big decrease in our climate impacts” can be achieved through building thousands of new homes.

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

The Cambridgeshire Local Access Forum (CLAF) was established through the statutory provisions of the Countryside and Rights of Way Act 2000 and its remit is to advise relevant bodies as defined in Section 94(4) of the Countryside and Rights of Way Act 2000 on matters relating to access to the countryside. Section 94(4) bodies are required by the legislation to take the views of the Local Access Forum into account.

The Cambridgeshire LAF welcomes this opportunity to provide input into the Greater Cambridge Local Plan and how it might be revised and improved to better reflect the
existing and potential future use of the non-motorised transport network across the Cambridge and South Cambridgeshire District.

We recognise that it's a very comprehensive plan, with a lot of concern for biodiversity, historical sites, and conservation. We are also pleased to see and
support policies that aim to protect, enhance, and develop the rights of way network providing a network of routes to promote walking, cycling and riding and to point out that circular routes, or routes that link with others, are particularly recommended. We have the further following points to make about the plan:

 An off road NMU off-road route from Cherry Hinton Road up to the Beechwoods and Roman Road; negotiations with landowners are required to
start ASAP. A large population of SE Cambridge has no off-road access to some of our best landscape areas.
 Links from the new Marleigh development to the ROW network in the Wilbraham’s/Teversham area as well as Fen Ditton/Lode.
 Rights of way between Great Shelford and Hauxton to link with Trumpington Meadows Park and Hobson Park; the permissive path between Great Shelford and Hauxton must be upgraded to a PROW and there needs to be
an alternative to the Genome path, possibly using existing permissive paths, augmented by off-road paths.
 PROW paths are required between Magog Down and the City, including the Nine Wells development and Biomedical campus.
 Planned development on the Marshalls Airport site must be connected by a ‘green lung’ to Teversham and Fulbourn rights of way.
There is a desperate need for at least one, probably two, major new country parks;
Nature Reserves DO NOT meet this need because of pressures which numbers of people place on their fragile ecosystems. These require visitor facilities such as car
parks and toilets. It would be even better if they can be accessed by public transport.
Milton CP and Wandlebury are already over-used, leading to both physical and ecological damge. Coton Reserve has limited access due to agricultural tenancies
taking up much of the land and a lack of facilities for visitors. Wimpole is very unclear about its role as only National Trust members can use the Estate car park in order to enter the parkland without a very high fee being payable. The Beds, Cambs & Northants Wildlife Trust is unwilling to accept open access unless there is a PROW;
the RSPB at Fowlmere is even more restrictive.
The Local Plan should identify prospective areas for the creation of such parks, requesting bids from landowners and potential managers. Funding should be through S106/CIL received through the new developments.
In summary, we think that the Local Plan needs to identify a clear list of projects for NMU routes and public access which ‘development taxes’ should fund. The current proposals are extremely vague and do not focus on specifics. They are well-meaning but toothless and we will finish up without ANY much-needed schemes being built into the Plan.

The CLAF would be happy to discuss further our concerns and how we might resolve these issues.

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