S/DS: Development strategy

In principle, the National Trust does not oppose the development of land around the edge of Cambridge outside the Green Belt provided adequate new greenspaces are delivered to the north east of Cambridge in order to reduce recreational pressure on sites subject to national and international designations, including our land at Wicken Fen (RAMSAR, SSSI, SAC). Although this is located beyond the Local Plan area, our evidence demonstrates that it draws a substantial number of visitors from the Greater Cambridge area. The impact of housing growth on Wicken Fen must be assessed through the Habitats Regulations Assessment.

Any changes to the Green Belt boundary must be fully evidenced and justified and formally decided through the Local Plan process, and any development must be delivered in a sustainable and strategic way.

The reliance on existing, large site allocations should be balanced with smaller sites within existing sustainable settlements, such as the land west of Station Road, Fulbourn, to maintain the smooth delivery of housing throughout the plan period.

The above issue has been made clear in the Letwin Review, which focused on the delivery of large housing sites, and recent Local Plan examinations, such as Uttlesford and St Albans, where the focus of the plans only on large sites for delivery has been heavily criticised.


In addition the Cambridge & Peterborough Independent Economic Review (CPIER), which was published in September 2018, concluded that 'Cambridgeshire and Peterborough is an area which already makes a huge contribution to the UK, and which holds great promise for the future. It also faces risks, which could bring the success to an end, and challenges relating to creating an inclusive society where economic growth works for everyone'.

The CPIER report, advocates a 'blended spatial strategy' of four possible scenarios:
- densification
- dispersal
- fringe growth
- transport corridors

It concluded that 'some densification, particularly in Cambridge, is needed, though this should happen away from the historic centre, and more on the edges, as and where new development sites come forward. There should be some scope for expanding development around the city boundary, but intelligently planned transport links will be needed to avoid worsening of congestion. In Cambridge specifically though there are limits to the growth of the city in other directions, the east side of the city (of which Fulbourn is on) offers significant scope for housing and commercial development. Such development would have the advantage of being close to the principal centres of employment and the existing rail infrastructure whilst also opening up opportunities for new transport links to connect the main centres of employment more effectively'.

The land west of Station Road, Fulbourn is a very sustainable location, which is consistent with the conclusion of the CPIER report. The site is well-related to the centre of Fulbourn, which benefits from a high quality bus service and the site is also adjacent to the Cambridge to Newmarket railway line, where land has been safeguarded to provide for a new railway station should it be required in the future. Therefore the site should be included as an allocation within this local plan to support the sustainable delivery of housing.

Please see attached planning commentary.

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

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


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

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


No plan for Integrated Public Transport
The current local government structure with four different authorities claiming responsibility for some aspects of transport planning and delivery, coupled with the divided responsibility for rail infrastructure between Network Rail and East West Rail Company Ltd is an impediment to any form of joined up thinking about an integrated transport system.

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

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

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

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

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

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

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

Babraham Parish Council.

Vision and development strategy
11. CPRE have read the Vision statement on the web site. It sounds forward-thinking. It is a great shame the
Vision is not matched by the development strategy. The entire strategy is predicated on growth of both
population and employment. Cambridge and South Cambridgeshire are areas of effectively full
employment. So, any growth in jobs can only be achieved by encouraging inward migration of significant
numbers of people from other, often poorer, areas of the country.
12. Such population movement will deplete other regions of some of their youngest and most dynamic
populations, causing damage to the social and economic fabric of those areas. It is not consistent with the
government’s Levelling Up agenda.
13. The development strategy is not consistent with the stated vision of Greater Cambridge, being “a place
where a big decrease in our climate impacts comes with a big increase in the quality of everyday life for all
our communities”. Quite the opposite. The level of housing and business development proposed will cause
significant increases in both embedded carbon due to construction and emitted carbon due to the increased population living in the area and the additional infrastructure needed to support them. A vision
which sought to spread Cambridge expertise to other areas of the country, which could benefit from
refurbishment and redevelopment, would be far more forward-looking socially and climatically.

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

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

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

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

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

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

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

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

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

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

a) Site Assessment and the need for Heritage Impact Assessments

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

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

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

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

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

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

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

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

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

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

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

Which sites require HIA?

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

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

included in the updated policy wording.

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

b) Policy Wording for sites

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

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

c) Edge of Cambridge sites

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

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

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

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

d) Historic Environment Policy

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

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

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

e) Design Policy

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

f) Tall Buildings Study and Policy

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

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

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

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

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

g) Other Supporting Evidence

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

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

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

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

Historic England – Ox Cam research work

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

Other comments

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

a) Site Assessment and the need for Heritage Impact Assessments

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

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

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

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

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

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

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

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

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

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

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

Which sites require HIA?

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

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

included in the updated policy wording.

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

b) Policy Wording for sites

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

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

c) Edge of Cambridge sites

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

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

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

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

d) Historic Environment Policy

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

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

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

e) Design Policy

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

f) Tall Buildings Study and Policy

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

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

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

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

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

g) Other Supporting Evidence

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

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

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

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

Historic England – Ox Cam research work

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

Other comments

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

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

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

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

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

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

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

General Comments on Strategy

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

This is a summary of comments received.

The consultation document outlines the ‘preferred development strategy’ for Greater Cambridge and defines the intention to direct development where it has the least climate impact, where active and public transport is the natural choice, where green infrastructure can be delivered alongside new development, and where jobs, services and facilities can be located near to where people live, whilst ensuring all necessary utilities can be provided in a sustainable way.
The strategy notes that development will therefore make use of brownfield opportunities within the Cambridge Urban Area, urban extensions and new settlements, but only proposes a very limited amount of development in rural areas.
At this early stage in the Local Plan preparation process (Regulation 18), further consideration of sites suitable for, amongst other development typologies, specialist housing for older people (including Extra Care development) in sustainable locations should be undertaken. There are opportunities, such as the submission site, to deliver Integrated Retirement Communities which provides Extra Care housing in sustainable locations which will also serve to support rural services, improve the vitality and viability of villages, and their shops and facilities whilst also enhancing local amenities including healthcare.
The proposed development strategy focuses on a number of larger, strategic developments which will not support the existing villages and will not deliver the type of housing required to meet the housing needs of different groups (including older people) and needs of local communities in these locations.
The Plan needs to support conscious efforts to ensure the delivery of housing to meet the need for specialist housing for older people, which is described in government policy guidance (PPG) as critical. (Paragraph: 001 Reference ID: 63-001-20190626)
There is a significant amount of variability within the sector (as acknowledged within the PPG), which also recognised that the location of housing is a key consideration for older people who may be considering whether to move. It is not considered that the proposed development strategy takes into consideration the needs of the sector, including the allowance of choice, and the approach currently advocated a will not support the varying models available to provide Extra Care housing and retirement communities.
The PPG identifies the different typologies of specialist housing, each designed to meet the diverse needs of older people and identifies that specialist housing needs differ dependant on the level of care needed. The PPG makes it clear that diverse housing models will need to be considered and the provision of one type of specialist housing will not meet the care requirements of older people whose range of needs will differ greatly.
The characteristics of Extra Care accommodation, including the level of services provided and support available, materially affects the requirements of operators and the conclusions on those locations that are potentially suitable for development. The characteristics of Integrated Retirement Communities which provide Extra Care housing also enable consideration of where this can contribute towards mixed and balanced communities and sustainable growth in rural areas (in accordance with NPPF 2021 paragraph 79). There may be cases, such as at Comberton, where delivery alongside general needs housing would promote social interaction and the delivery of mixed and balanced communities.
This necessitates an objective assessment of alternatives to the Council’s proposed strategy to meet general housing needs where this would ensure a reasonable prospect of meeting needs for specialist housing in full.

Representations to the Greater Cambridge Local Plan - The First Proposals Regulation 18 Consultation
West Cambourne,

On Behalf of MCA Developments Ltd November 2021

Contents
1. Introduction 3
2. Vision and Development Strategy 4
3. New Settlements – Cambourne 8

Nichola Traverse-Healy nichola.traverse-healy@turley.co.uk
Client
MCA Developments Ltd

1. Introduction

1.1 These representations are submitted by Turley on behalf of Taylor Wimpey UK Ltd and the Vistry Group (the applicants) who together comprise the consortium MCA Developments Ltd (MCA (herein referred to as MCA), in response to the Greater Cambridge Local Plan – First Proposals Regulation 18 Consultation (January 2020). MCA are the developers behind Cambourne, a maturing new settlement, located within the administrative area of South Cambridgeshire (SCDC) approximately 7 miles to the west of Cambridge. The aim of this document is to assist the Council in formulating their Local Plan.

1.2 We have set out below responses to the questions raised in the Draft Consultation Document in the order in which they appear.

1.3 The remaining part of this document is structured as follows:

• Chapter 2 – Vision and Development Strategy
• Chapter 3 – New Settlements: Cambourne
• Chapter 4 – Conclusion

1.7 MCA would be pleased to discuss any aspect of these representations in more detail if this would be of assistance to the Council and we look forward to engaging positively with the Council and other stakeholders in the ongoing preparation of the emerging Local Plan

2. Vision and Development Strategy

Vision

2.1 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.”

2.2 Whilst MCA 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.

2.3 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.

2.4 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.

2.5 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.”

Policy S/JH: New Jobs and Homes

2.6 Policy S/JH of the Draft Local Plan proposes to meet the following objectively assessed needs for development in the period 2020-2041:

• 58,500 jobs
• 44,400 homes, reflecting an annual objectively assessed need of 2,111 homes per year

2.7 For housing, Paragraph 60 of the National Planning Policy Framework (NPPF) states that Local Plans should support the Government’s objective of significantly boosting the supply of homes, providing, as a minimum, the number of homes informed by a local housing need assessment, using the standard method in national planning guidance. National guidance says that there will be circumstances where it is appropriate to consider whether actual housing need is higher than that indicated by the standard method.

2.8 For Greater Cambridge the housing need using the Standard Method would equate to 1743 homes per annum. However, rather than planning for the minimum calculation using the Standard Method, the Councils’ strategy is to propose a higher housing figure of 2,111 homes per annum. This higher figure is based on the medium growth scenario identified in the Greater Cambridge Employment Land and Economic Development Evidence Study, published in 2020. This study also set out a higher growth scenario placing greater weight on the high historic growth rate between 2001- 2017. Based on the higher growth scenario, the modelling predicted that 78,700 jobs would be required over the plan period.

2.9 Whilst MCA is supportive of the Councils’ decision to plan for higher levels of growth than the standard method, it is disappointing that the Council have decided to base their strategy on the medium rather that the higher growth scenario. The Greater Cambridge economy is dynamic and does not readily align with national or regional forecasts for jobs growth. It has a world-renowned life sciences cluster which has the potential to drive growth beyond typical regional or national rates.

2.10 We would strongly advise the Council to ensure that their objectively assessed is more aligned with the higher jobs growth aspirations. An indicative calculation based on Cambridgeshire and Peterborough Independent Economic Review suggests that if the jobs growth is achieved, around 2,900 homes a year would need to be built in Greater Cambridge, an indicative total of 66,900 homes over 2020-2041.

2.11 As set out in the Government’s most recent consultation document the Arc has the potential to be one of ‘the most prosperous, innovative and sustainable economic areas in the world’. However this transformational growth will only be achieved if local authorities truly plan positively for the housing and economic needs of the area. On this basis we would strongly urge the Council to plan for the higher growth scenario which is more aligned with past growth rates in the Greater Cambridge area.

Policy S/DS: Development Strategy

2.12 At page 29 of Draft Local Plan the Councils’ set out the proposed development strategy for Greater Cambridge. The Plan states that the top priority is to reduce carbon emissions and to that end provide jobs and homes in close proximity to one another and major public transport routes.

2.13 To provide for these new homes in the Plan period, the proposed development strategy for Greater Cambridge is to focus the majority of development on larger scale sites within and around the edge of Cambridge and at new settlements as follows:

• North East Cambridge – redevelopment of the existing waste water treatment works to deliver 8,350 new homes.

• Cambridge East – development of the Marshalls airport site to deliver approximately 7,000 new homes.

• Intensification of Development at North West Cambridge – review of the site wide masterplan to deliver between 1,000 and 1,500 additional new homes.

• Expansion of Cambourne to around 2,000 new homes; and
• Continuing development at the new settlements of Northstowe, Waterbeach and Bourn – but at faster housing delivery rates so that more homes are provided by 2041.

2.14 MCA strongly supports the proposed expansion of Cambourne for circa 2000 homes, which aligns with the Councils’ objective to provide jobs and homes in close proximity to major public transport routes. As stated page 44 of the Draft Local Plan locating growth at Cambourne takes advantage of the proposed new East West Rail station at Cambourne and the Cambourne to Cambridge Public Transport Scheme being brought forward by the Greater Cambridge Partnership.

2.15 Notwithstanding these proposed new transport links, Cambourne is an established and successful new settlement which benefits from a range of services and facilities, including three primary schools, secondary school, library, health centre, Morrison’s superstore, pub, leisure centre, numerous restaurants and takeaways together with a number of retail uses and professional services within two parades of shops.

2.16 The development of Cambourne West, a fourth linked village will further enhance the range of services and facilities at Cambourne. In 2017 South Cambridge District Council (SCDC) granted planning permission for the development of 2350 homes at Cambourne West including a new retail and community hub, two primary schools and an extension to the existing secondary school.

2.17 Cambourne is one of the largest and most sustainable settlements in Greater Cambridge, which since development commenced in 1998 has continued to make an invaluable contribution to Greater Cambridge’s housing land supply. The settlement is not only well placed in terms of access to major transport corridors and new infrastructure, including

the new rail station as part of East West Rail but benefits from an extensive range of shops, services, facilities and recreational opportunities. For the reasons set out above, Cambourne is considered a logical location to accommodate additional growth to meet the needs of South Cambridgeshire and Cambridge City. The proposed expansion of Cambourne is considered a soundly based strategy, which is justified by the Councils’ supporting evidence base and will deliver sustainable development in accordance with the policies of the NPPF.

Policy S/SH: Settlement Hierarchy

2.18 The purpose of Policy S/SH is group together similar settlements into categories that reflect their scale, characteristics and sustainability. In view of its sustainable credentials MCA strongly supports the Councils decision to reclassify Cambourne from a rural centre to a town.

2.19 As set out at page 49 of the Draft Local Plan:

“Cambourne is a growing centre, with a growing level of services, facilities and transport opportunities. This has been recognised by it now having a town council, and it is considered that this should be recognised in the local plan”

2.20 Cambourne performs far beyond the role of a rural centre and MCA agrees that this should be recognised in the new Local Plan. Given the excellent range of services and facilities in Cambourne and the wider catchment it serves, the Councils’ are considered completely justified in the new Local Plan to include Cambourne in the ‘Towns’ category of the settlement hierarchy.

3. New Settlements – Cambourne

3.1 Policy S/CB: Cambourne of the Draft Local Plan seeks ‘to identify Cambourne as a broad location for longer term strategic scale growth’ and carry forward ‘the existing allocation for a new mixed-use development at Cambourne West…. but to be expanded to include the full extent of the planning permission’.

3.2 As stated previously in our response to Policy S/DS: Development Strategy, given Cambourne’s position in the settlement hierarchy and proximity to new major public transport schemes, MCA strongly supports the Councils’ decision to identify Cambourne as a broad location for longer term strategic scale growth. Cambourne has been identified as the location for a new railway station as part of the East West Rail scheme to connect Oxford with Cambridge and potentially beyond, along with the Cambourne to Cambridge public transport scheme being brought forward by the Greater Cambridge Partnership. The Draft Local Plan recognises that these schemes ‘provides an opportunity to consider how further development could make the most of these connections, but also make the overall Cambourne area a more sustainable place’.

3.3 MCA is also supportive of the Councils’ decision to carry forward ‘the existing allocation for a new mixed-use development at Cambourne West…. but to be expanded to include the full extent of the planning permission’. Policy SS8: Cambourne West in the adopted South Cambridgeshire Local Plan (2018) currently requires at part 12 (g) ‘Vehicular access to be provided through an enhanced route through the Business Park, one or more access points from the Caxton Bypass, and via Sheepfold Lane’

3.4 The outline planning application for Cambourne West, approved in 2017, did not include an access through the Business Park, as this land was under the control of a third party. As set out in the Committee Report, relating to the West Cambourne outline planning application, dated 11th January 2017, Officers were satisfied to approve the application without the business park access but on the basis that the ‘opportunity would still exist with any future application for the development of the business park land’. To provide the Council with comfort that the business park access could be delivered in the future, the site wide masterplan submitted by MCA as part of the planning application was designed to facilitate an access. In addition plans were submitted as part of the application, demonstrating how the business park road could be brought up to adoptable standards.

3.5 In May 2021, it was announced that the South Cambridgeshire Investment Partnership (SCIP) a 50:50 partnership between South Cambridgeshire District Council and the Hill Group, would be purchasing the remaining undeveloped land at the Business Park. It is our understanding that it is the intention of SCIP to submit an application for the development of the site to provide 275 homes.

3.6 As set out at paragraph 260 of the Committee Report, relating to the West Cambourne outline planning application, Officers stated that:

“…the council would continue to encourage the delivery of an all vehicle access through the business park due to the benefits through greater connectivity that it would bring for early Cambourne West residents”

3.7 A top priority of the Draft Local Plan is to minimise vehicular movements. It has always been the Councils’ aspiration that walking and cycling links through the business park would be delivered as part of any vehicular connection. This would mean greater permeability between Cambourne and Cambourne West for pedestrians and cyclists. Given that the legal impediments to the delivery of the road no longer exist and for the benefit of Cambourne residents, it should be a requirement in Policy S/CB: Cambourne of the new Local Plan that future planning applications for the development of land at the Business Park should be required to provide an enhanced access through the Business Park to the development at Cambourne West.

3.8 As has been the approach at North West Cambridge, when drafting Policy S/CB: Cambourne for the next stage of the Local Plan, the Councils’ should be seeking to maximise the opportunities for intensifying development within the existing boundary of Cambourne West. The updated policy should enable the development of additional dwellings on the site beyond those identified in the current outline planning permission at Cambourne West, provided through changes to the dwelling mix and appropriate intensification of development areas that have yet to be built. MCA are currently undertaking a detailed review of the site wide masterplan, and will advise in due course the likely increase in dwellings that could be achieved.

3.9 Under Policy SS/8 of the adopted Local Plan any future planning application would need to provide an equivalent quantity of employment land to that lost on the Business Park (8.1ha), to be delivered in the northern part of the Cambourne West site rather than its current location. The outline planning application submitted by MCA and approved by SCDC made for provision 6.25ha of employment space for offices. At the time the outline planning application was being determined, SCDC provided limited justification with regards to the need for this level of employment land at Cambourne West. As set out at paragraphs 208 and 209 of the Officer’s Committee Report dealing with the application:

“The history of Cambourne has shown that the employment and retail units are rarely built on a speculative basis and have only come forward when an occupier has been identified…. the reality is that the majority of employment in Cambourne is outside the business park and can be found in the schools, hotel, retail units etc. There are also a large number of residents who run successful companies out of their homes.”

3.10 Current lettings data from CoStar, the commercial property database, provides a more up to date indication of the role of Cambourne in accommodating demand for office space that arises throughout South Cambridgeshire on an annual basis.

3.11 CoStar has recorded some 1,125 lettings of office space throughout South Cambridgeshire over the last ten years to November 2021, but only 34 – or little more than three lettings per annum, on average – have been in Cambourne1. It has therefore been the location for only 3% of all such lettings in South Cambridgeshire, which is

1 Lettings have been assigned to Cambourne based on postcodes

notable where the town accommodates more than twice as much (7%) of the district’s population2.

3.12 While around three lettings have been recorded annually in Cambourne over the whole decade, this had been slowing even prior to the pandemic as shown by Figure 1 below which tracks the annual average over rolling three year periods. This shows, for instance, that there were more than four transactions per annum on average in the three years to November 2016, which remained relatively stable over the subsequent two years. This was followed, however, by the recording of less than three office lettings per annum over the three years to November 2019, which has fallen even further to the point where there have been only 1.7 lettings per annum over the past three years – equivalent to one office letting every seven months.

Figure 1: Office lettings per annum in Cambourne – rolling three year average

Source: CoStar; Turley analysis

3.13 The amount of office space taken up in Cambourne has also been falling, averaging nearly 4,900sqm per annum over the three years to November 2016 before reducing by almost a fifth to a little under 4,000sqm per annum over a similar period to November 2019, predating the pandemic. This has since more than halved to the point where only 1,700sqm of office space has been taken up annually in Cambourne over the last three years, the reduction being far starker than seen across South Cambridgeshire where the rolling average has fallen by only a quarter.

2 ONS (2021) Population estimates, mid-2020. This is the number of residents living in the officially defined Built-up Area (BUA) of Cambourne, divided by the number of people living in South Cambridgeshire (10,544/160,904)


Figure 2: Office space leased per annum in Cambourne – rolling three year average

Source: CoStar; Turley analysis

3.14 The above analysis indicates that there has long been relatively limited demand for office space in Cambourne, which appears to have reduced even further during the pandemic. On this basis, we do not consider it justified and appropriate under proposed Policy S/CB to reserve the entire 6.25ha of employment space at Cambourne West for the provision of further office space.

3.15 For the reasons stated above and to be considered sound, MCA request that in drafting Policy S/CB the Council ensures the following:

• There is an requirement as set out under Policy SS/8 of the adopted Local Plan, to provide an enhanced access through Cambourne Business Park to link with the development at Cambourne West;

• The Policy is not overly prescriptive and allows for the intensification of development areas that have yet to be built at Cambourne West; and

• The Policy promotes and allows for the development of residential uses on land previously identified for employment on the Cambourne West Masterplan. This is on the basis of clear evidence demonstrating that the market for employment floorspace in this location is limited.


Turley Office 8 Quy Court Colliers Lane Stow-cum-Quy Cambridge CB25 9AU

T 01223 810990

Barrington Parish Council (BPC) is pleased to have the opportunity to respond to the Greater Cambridge (GCP) Local Plan First Proposals (FP).

1. Overall
1.1. BPC supports the FP development strategy in general terms and supports the principles of plan-led, sustainable development that underpin the FP. BP also supports the general themes of responding to climate change, biodiversity and green spaces, well-being and social inclusion, and great places.

1.2. The wording of many of the proposed policies is incomplete and as always, the devil is in the detail - especially regarding Jobs, Homes and Infrastructure which have the greatest potential impact on the quality of the local environment. BPC is of the view that while these issues are obviously central to any Development Plan, mitigating potentially detrimental effects on rural communities in South Cambridgeshire needs to be managed through effective, carefully worded policies in the Plan.

1.3. BPC particularly welcomes the recognition of and need for reinforcement of the distinctive character of South Cambridgeshire villages.

1.4. However, BPC wishes to make some general strategic and some specific comments as follows.

2. Strategic Issues
2.1. The 2018 Local Plan for South Cambridgeshire is to be succeeded by a Local Plan for a much wider constituency developed by a Partnership for “Greater Cambridge”. This inevitably creates tensions between the interests of the city and those of the surrounding, primarily rural areas. It has to be acknowledged that development pressures in and from the city of Cambridge have significant effects upon the surrounding areas and not all of these are positive and beneficial.

2.2. The First Proposals also seek to support both the Oxford Cambridge Arc Spatial Framework and the proposed East West Rail connection - both of which introduce additional development pressures and significant environmental impacts upon South Cambridgeshire.

2.3. The First Proposals are therefore in a key sense no longer for a “Local” Development Plan but in effect have been transformed into a Regional Development Plan where the local interests and concerns of villages such as Barrington lie at the bottom of the hierarchy of interest and control.

2.4. Policy S/DS. BPC has already placed on record and wishes to re-state its fundamental opposition to both the Oxford Cambridge Arc Spatial Framework and the proposed East West Rail southern route into Cambridge. BPC has concerns that these may lead to central government-imposed rather than locally-agreed development in South Cambridgeshire which will be highly detrimental to the area.

3. Specific Matters
3.1. Policy S/DS BPC agrees that brownfield development should be prioritised and in locally - agreed not nationally targeted locations. Development “around” the villages is not considered sustainable.

3.2. Policy S/SH. BPC supports the retention of the settlement hierarchy, and the definition of Group Villages should be retained as proposed from the 2018 Local Plan, possibly reinforced with stronger wording to restrict exceptional development of up to 15 dwellings only on brownfield sites.

3.3. Policy S/ JH. BPC has concerns about the notion of “Windfall Development”. Either we have a Development Plan or not – the notion of “unplanned” “windfall” or “opportunistic” development – especially if it were to be determined by officers as opposed to councillors – is not compatible with “plan-led development”. The opening the door to opportunistic applications that run counter to the direction of the Development Plan.

3.4. Policy GP/GB. Similarly, BPC opposes development intrusion into the Green Belt. Development “creep” – even for “nationally significant” development should be resisted.

3.5. Policy S/SRC. BPC is concerned about the definition and implications of the “Rural Southern Cluster” and this requires much more detailed elucidation, explanation and justification.

3.6. Policy WS/CF. BPC believes that Community Healthcare facilities should be prioritised as they have been poorly provided for under the current Plan. Much stronger policy definition is required.

3.7. Policy CC/WE. The FP recognise that availability of water resources is a major issue in Greater Cambridge and that the level of growth has significant constraints with regards to water supply. BPC shares these concerns. Policy should address this issue more comprehensively.

4. The Consultation Process
4.1. BPC is pleased to have the opportunity to engage to the extent that it is able with the FP consultation.

4.2. However, GCP’s consultation on the Local Plan is a convoluted process. The material is voluminous, there are 60 policies and the maps are often difficult to interpret electronically, and this militates against inclusion of the diverse age and socio-economic groups in a rural population. It comes across as an IT driven process designed for an urban sophisticated readership. Further thought needs to be put into reducing the complexity but increasing the inclusion, accessibility, and meaningfulness of this consultation.

On behalf of ECDC, and as an officer-level representation only, I have undertaken a high level review of your emerging Local Plan. I also had the benefit of the virtual meeting on 30 November, where you kindly outlined some of the key issues of your emerging Plan.

Overall, ECDC has no objections to raise at this stage.

In particular, ECDC notes that there are no additional (i.e. ‘new’) major development proposals close to the border with East Cambridgeshire; and where major new allocations are proposed within your plan area, there appears no immediate or obvious significant ‘cross-border’ implications of relevance to East Cambridgeshire arising from them.

Our only area of comment relates to the scale of job growth and housing requirement proposed (the latter being dependent on the former, rather than being dependent on using the national standard method minimum derived figure). As the Plan progresses, and through on-going duty to cooperate conversations (and associated Statement of Common Ground), ECDC will want to be satisfied that the evidence behind the balance between jobs and homes growth is sufficiently robust, and that (and of more importance to ECDC) appropriate mechanisms are in place in the Plan to ensure that the Plan can react positively should the growth in jobs and/or homes not occur as forecast (whether faster or slower than forecast).

To put it another way, ECDC may have concerns if, over the coming years, new homes considerably exceeded job growth, or job growth considerably exceeded new homes. Under such scenarios, there could be ‘spill over’ effects on East Cambridgeshire, hence the need for the plan to have mechanisms in place to actively ‘plan, monitor and manage’ for these potential eventualities.

Over the coming months, I would encourage continued conversations on this issue in particular, prior to your final ‘reg 19’ consultation stage.

Finally, on wider matters, ECDC is particularly interested in continuing to work closely with you on the aspects in your Plan relating to climate change and the natural environment, recognising that these matters are clearly ones that will require cooperation and shared learning across all organisations and administrative areas. In principle, the proposals you outline in your Plan on these matters are welcomed, and we would be happy to assist with your evidence base on these matters should you find that helpful.

Regards

Richard Kay
Strategic Planning Manager

Expanding Cambourne, continuing to develop Bourn Airfield. Mansel Farm, Oakington (20 homes near Beck Brook). Mention of 10% extra buffer for homebuilding. Also 1,000 more homes on the Eddington site (M11 side).

Comments from Cottenham Parish Council:

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

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

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

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

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

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

OBJECT – proposed housing development of NE Cambridge is an area next to two of the more deprived LSOAs in Cambridge and requires the sewage works to move. Current proposals are a site at one of three alternative sites, all in the Green Belt. No consideration given to upgrading the works to be suitable for an urban area with new development nearer than 500m using suitable environmental controls.

A Local Plan key assumption is that all 44, 400 new homes have to be allocated within Greater Cambridge (GC) area (Ref GCLP - PPSE – SEPTEMBER 2021 P21 Medium “Consume Own Smoke”) and the apparent justification given elsewhere is that this in order to minimise the Carbon Footprint of Travel and congestion. Although agreeing that travel footprint is a reasonable concern, the simplistic conclusion may be unsound because:

Objection 1 – In reality, people will continue to travel from out of area:
a) as should be known from data in the current baseline
b) with a decrease in car numbers crossing the Cam bridges measured in 2019 compared to 10 years earlier. Facts that contradict the Plan’s assumptions should be explored not ignored.
c) as needs to be shown in the future baseline
d) increasingly so as working from home becomes more prevalent so journeys into GC are less frequent for some of these workers (2 or 3 days/week?).
e) with lower carbon footprint for average working day due to c) above
f) increasingly but anecdotally, due to some people wishing to take advantage of lower housing costs and more tranquil, rural surroundings. Further evidence for the drivers for growth of in-commuting from out of the GCP area can be inferred from the Housing Market Bulletins which show that prices/m2 are much greater in Cambridge City than other districts and average and lower quartile prices also show a similar ranking but over a narrower spread.
g) increasingly so by sustainable travel as a consequence of CPCA’s plan to improve public transport which may include connections to rural hubs
h) increasingly so in the case of Rail as Network Rail creates improved connections in area at Cambridge South and Waterbeach new town and out of area, eg Soham, Wisbech, Ely capacity improvements and longer range potential such as East -West Rail and Newmarket line improvements to the east.
The Local Plan assumption does not appear to be compatible with or even tested against Network Rail’s forecasts or evidence for travel patterns from out of the area (see Figure 2 attached, ref Cambridge South Station). This is a step the Local Plan needs.
Recognising potential for more rail commuting from Fenland and East Cambridge and encouraging this in housing allocations might do a lot for the levelling up agenda in the County. Some evidence of what other Districts are planning or might aspire to for commuting to GC should be given. The comment on P26 about lack of “asking” in discussion with neighbouring authorities does not inspire confidence that the right questions have been asked.

Objection 2 – In reality, some people will continue to travel to employment out of the area:
a) The long term desire for NECAAP includes the siting of 8000 plus new houses near Cambridge North station is likely to attract such out-commuters. At the very least, the number could be assessed for the Local Plan by first quantifying then comparing the degree of out commuting from existing new developments near Cambridge Station both pre 2020 and more recently.
This is a separate point to that described in the approach to the Local Plan which predicts that some of the proposed housing near Cambridge North would lead to an increase in commuting by rail as a component of the sustainable travel within the GCP area.

I have three specific objections to the draft Plan

1. Carbon emissions
The Draft Local Plan does not follow a 'brownfield first' approach. It is therefore not consistent with national government policy as expressed repeatedly, recently by the Prime Minister. Greenfield building maximises carbon emissions. The Local Plan should encourage urban intensification.
There are vast swathes of second quality post war two storey developments in and around Cambridge. These could and should be replaced or augmented with additional storeys to add 50% or more to the housing stock in the City, all within easy pedestrian or cycling distance of the city centre.
Old airfields such as those being developed in Cambridgeshire are not true brownfields; only their disused run-ways and any associated buildings are and the former could be easily cleared and used as a source of recycled aggregate. Most of the former Bourn airfield is productive farmland. The massive greenfield building and infrastructure programme contained in the Draft Local Plan breaches all obligations for sustainable development. Embodied carbon emissions are ignored in the Plan. Cement manufacture contributes 8% of global carbon emissions which is more than three times the impact of aviation fuel. Iron and steel production accounts for another 8%. Between them they account for more emissions than the USA and are second only to China as greenhouse gas emitters.
According to the recent Cambridge and Peterborough Climate Commission report, at the present rate the Region will have used up all of its carbon budget, allocated to meet its legal obligation to reach zero carbon by 2050, in less than six years; due to the level of planned growth, emissions will accelerate further. The obvious conclusion is that all unsustainable growth has to be curbed.
This means that the intensification of housing in Cambridge should use sustainable building techniques based around wood and recycled materials.
The Climate Change Committee has argued in its 2018, 2019 and 2020 Annual Reports to Parliament that UK local and imported emissions arising from construction (the UK imports most of its building materials, even the bricks are made in Belgium or Holland), must be reduced if the UK is to meet its now legal emission targets.

2. Transport
Climate change should be the single most important consideration in all aspects of transport planning and operation, and the Draft Local Plan fails to do this.
Only by intensification of housing in the City can the car borne carbon emissions be avoided.
Annual Reports to Parliament by the Climate Change Committee have consistently made the point that ‘Surface Transport’ is the greatest source of greenhouse gas emissions in the UK. Therefore, all transport planning should: (a) seek to minimise all forms of travel by locating the dwellings required within walking and cycling distance of work and leisure facilities, discouraging commuting and leisure travel
(b) encourage use of digital communications,
(c) where travel is essential, encourage active travel and/or use of public transport,
(d) provide carbon efficient forms of public transport, particularly light rail and heavy rail on the most heavily used routes. The ancient proposals for a Cambridge underground railway should be revived.
Road widening and road building proposals should be abandoned with immediate effect. The only consideration for any road layout changes, other than road safety, should be the question “Will it reduce net carbon emissions from construction and use?”. Clearly, some small schemes which ease traffic flow will reduce emissions from acceleration, but those that increase road use will not.

3 Inadequate water and waste water provision
(a) Water
Cambridge City and South Cambridgeshire already have an unsustainable supply of potable water. In 2021 the Environment Agency published “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, Appendix 3 states Cambridge Water needs to reduce abstraction by 22 megalitres per day from levels current at 1st July 2021, and Anglian Water needs to reduce abstraction by 189 megalitres per day from levels current at 1st July 2021.
(b) Wastewater
The local sewage system is currently inadequate, evidenced by the number of sewage spills by Anglian Water sewage works into the Cam Valley. Currently, there are no plans to improve failing combined sewer overflows. Cambridge saw 622 hours of untreated waste water 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.
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.

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

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

Spatial Options and Chosen Distribution

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

Transport Links

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

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

Planning Obligations and Mitigating Impacts




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

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

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

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

Green Infrastructure

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

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

Other Comments

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

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

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

Little Abington Parish Council welcomes the proposed approach of limiting any new developments in villages and focussing major new development in existing and forthcoming settlements thus preserving the character of small villages in South Cambridgeshire.

However, given that job opportunities will continue to be concentrated to the south of Cambridge particularly on the Biomedical Campus and in the science parks based in the SE corner of the county ,including Great Chesterford, and new housing is mainly planned for the north of the county we need real improvements to public transport using the existing road network.

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

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

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

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

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

mitigated.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

mitigated.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

mitigated.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

FORM RESPONSE

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

The Cambridgeshire Development Forum brings together a diverse range of organisations with a shared commitment to the delivery of high-quality developments in the Cambridgeshire region. We include promoters, developers, housebuilders, housing associations, planners, advisers, law firms, design companies, transport planners and related professionals in our membership. We do not promote individual sites and are focused on achieving more effective delivery of plans in our region. We value the engagement we receive from local planning authorities, the Combined Authority and Central Government. We welcome this opportunity to respond to the consultation on the Local Plan.

These representations reflect shared views among our members but should not be interpreted as representing the views of any individual member organisation in membership of the Forum.

Responses:

Q1: the additional 550 homes a year should be regarded as a minimum figure, which should be reviewed regularly in relation to the growth in jobs within the travel-to-work areas

Q2: the spatial strategy for development should focus the larger development sites in locations which offer public transport options to reach major employment centres. Development in rural locations of an appropriate scale should not be deterred as and when more sustainable personal transport options are available, eg EVS using renewable energy.

Q3: The Cambridge East Development should be connected directly to the City centre and the inner urban ring of development at the Biomedical campus, North Cambridge and the Science Park, Eddington and West Cambridge. But it should not be a wholly residential development. It should be a mixed development including commercial, residential and leisure/ retail options. It should be envisaged as a distinct place, with its own character. It could include high-rise apartments suitable for the younger workers who comprise many Cambridge area workforces.

Q4: North-East Cambridge should offer a residential opportunity for those employed in the technology sectors around Cambridge, including a significant component of affordable housing for market sale, market rent, shared ownership, and social housing.

Q5: development in and close to the biomedical campus should be prioritised for the healthcare, research, and technology cluster; significant adjacent sites should not be developed for large-scale residential purposes.

Q6: Cambourne should provide jobs near the new homes and include more employment space potentially including a commercial hub based on any new railway station above the A428.
Outside this commercial and retail hub, Cambourne should be focused on the large-scale offering of homes for families of those working across the Cambridge area.

Q7: in the southern rural cluster, opportunities for development on brownfield sites and for rural diversification, with small business-related developments should not be excluded.
Related residential development on smaller sites should also be accommodated, taking account of the Neighbourhood Plans. A priority should be given to sites in villages on rail routes, at public transport nodes and within public transport corridors. Subject to the decisions to be made concerning the East-West Rail Link, the option for significant growth and/or new settlement in appropriate locations that maximises the use of all forms of public transport should be considered as additions to the sites proposed.

[Q8-13 omitted]


We have welcomed the engagement with the Greater Cambridge Shared Planning team, and look forward to this continuing through this process in future discussions.

Cambridgeshire Development Forum December 2021

Our group, in collaboration with Railfuture and a wide range of others, has prepared detailed proposals and commentary of high relevance to the Local Plan. We would appreciate it if our report could be considered as part of Local Plan discussions.

A lot of work has gone into it, and we have a lot of support from residents throughout Cambridge and the surrounding region. The report has been submitted to the Making Connections consultation, and also to the Combined Authority Transport strategy consultation.

I think it is worth mentioning that most residents find it very difficult to navigate the intricacies of local planning processes, and having (at least) three significant consultations running at the same time by three different bodies with overlapping jurisdictions and responsibilities makes it especially confusing. This makes it especially difficult for democratic input by those not in the system, and for fully inclusive consultations. Our planning authorities should give this close consideration and ensure there are improvements in coordination in future.

We hope you will make an exception on this occasion and accept our report into the process 4 days late.

Cambridge Connect Cambridgeshire Light Rail Strategy
Submission to Cambridgeshire & Peterborough Combined Authority

28 Nov 2021
railfuture
EAST ANGLIA
cambndge connecT

Executive summary 5
1. Introduction 11
2. Scheme influences 12
3. Population 13
4. Economy 16
5. Education 17
6. Commuter demand 18
7. Tourism demand 18
8. Non-commuter demand 19
9. Network model 20
10. Cambridgeshire Light Rail 21
11. Urban realm 24
12. Environment 25
13. Health 27
14. Heritage 27
15. Accessibility 27
16. Tunnel 29
17. Costs 30
18. Cost comparisons 31
19. Revenue 32
20. Financing 32
21. Is Cambridge too small? 34
22. Existing GCP transport measures 36
23. Light rail and busways compared 37
24. Community engagement 39
Cambourne to Cambridge – C2C 39
Addenbrookes to Granta Park – CSET 41
25. Team – Brief bios 42
26. Declarations of interest 45
27. Appendices 46

Cover images: The transport strategy needs to address the challenges of population growth and climate change and help secure the health, safety and welfare of present and future generations.
Citation: Cambridge Connect / Railfuture. 2021. Cambridgeshire Light Rail Strategy. Submission to Cambridgeshire & Peterborough Combined Authority consultation on Transport and Connectivity Plan.

and Cambridge North stations, and in future at Cambridge South and Cambourne. The lines would share a short single tunnel of ~2.6 km in Cambridge City.
26. We recognise plans for major developments on the east side of Cambridge, and anticipate extending lines there at Phase Three. We anticipate this component of the network would be elaborated as plans for the east of Cambridge are more fully developed. The network is designed so an eastern extension can be easily incorporated.
27. We recognise the tunnel increases investment needs, although we note that it would also deliver major increased benefits. In particular, it enables a fully integrated and segregated light rail route across the region, allowing integrated, fast and reliable services to the city core and to all major employment sites around Cambridge.
28. The tunnel addresses critical practical constraints of space and the river barrier in the centre of Cambridge, and while more expensive it would repay the investment.
29. The tunnel is likely to be more deliverable than a surface solution because of vital heritage and environmental constraints in Cambridge: strong public opposition to mass transit through the inner city at the surface seems likely.
30. The tunnel enables improvements to the urban realm, and in particular frees up space for improvements to support active travel - cycling lanes and pedestrianisation. It also makes the urban realm safer for pedestrians and cyclists by removing much heavy transport infrastructure. It would greatly reduce pollution at the surface, including from particulates produced by rubber tyred buses.
31. The tunnel enables rapid access to the city core, providing a practical and efficient alternative to people so they can leave cars at home. Moreover, the alternative is more likely to make demand measures such as a Congestion Charge or Workplace Parking Levy more acceptable to the public.
32. The network is designed to support all of the major employment/ residential/ educational/ and health centres across Cambridge. In particular the Darwin Line supports the northern part of the city such as Arbury and Kings Hedges, dramatically improving social inclusion and opportunities in a relatively deprived part of Cambridge.
33. The network provides and improves access for all sectors of the community to key facilities, and to wider transport links. Phase Three extensions will develop this further, including links to the east and north, including to Bar Hill (currently poorly served) and the expanding centre of Northstowe. In time, we envisage the northern busway would be converted to light rail, although this is not put forward as an immediate priority.
34. The network is designed to protect key landscapes surrounding Cambridge by following existing major transport routes such as the A428 to the Girton Interchange, and in the south following the former rail route to Haverhill. The network thus offers greater protection to the environment than plans being put forward by the GCP for the CSET and C2C schemes, while also offering greater transport and economic benefits.
35. The Girton Interchange has been identified as a key strategic node on the regional transport network. There are opportunities to locate a coach station at this site, linked to light rail, thus reducing the need for coaches and buses to enter the city centre. This would be a major benefit for the city and the tourist industry, as well as to coach companies who currently face major difficulties with congestion.


Connecting the campuses
36. The University of Cambridge and its colleges are pivotal to the success of the Cambridge Phenomenon. This is a rare and globally unique context that cannot be easily reproduced elsewhere. It should be celebrated and supported
37. The success has driven the University expansion into three distinct and separated sites: West Cambridge Campus and Eddington, the City Campus, and the Biomedical Campus.
38. Current transport links are now inadequate to support close interaction across these campuses and with the colleges. For the modern University of Cambridge, with its links to industry, there is a need to join up the campuses by effective and fast transport links, including to science and technology business clusters.
39. Joining up the campuses with good transport links is needed to maintain and strengthen cross-disciplinary interactions and research that are fundamental to Cambridge success. We believe the GCP City Access Strategy will not be adequate to meet these needs.
40. There is also the need to create good links between the University and centres of business activity, such as the Science Park, Babraham and Granta Park to name a few.
Why light rail?
41. Light rail is selected as the mode of choice for the mass transit backbone because it is proven to be more effective at driving modal shift than buses, and is more attractive as an alternative for car drivers. It is capable of delivering on the objectives of modal shift and on supporting the economy and growth coming forward in a way that buses cannot.
42. Light rail is well established and technically supported, with billions of miles of safe operation world-wide. There has been massive investment in the technology already and there is a very competitive supplier market. There are also options to support tram-train.
43. Light rail is environmentally superior with zero emissions at the street, including almost zero fine particulates (buses emit harmful fine particulates from tyre, road and brake wear) and no waste rubber tyres. Light rail eliminates these sources of pollution.
44. Light rail has a much lower overall lifetime carbon footprint than buses / busways.
45. Light rail has superior capacity, which future-proofs the system for Cambridge growth and will be able to meet the future needs for modal shift in a rapidly-changing economy.
46. Light rail is fast, reliable, frequent, comfortable, and affordable – it has all the ingredients needed to make it a genuinely attractive public transport alternative.
47. Modern light rail can operate driverless, extending hours and reducing costs.
48. Light rail has limitations in flexibility and reach, and this is why there remains a need for close integration with bus services, as well as with active travel, and cars. Beyond the backbone of mass transit and train lines, buses offer more flexibility and reach for public transport. With well-designed stops, active travel and other modes can work closely with mass transit. This approach is proven as successful in hundreds of cities world-wide.
49. The more limited flexibility of light rail may also be considered a benefit. It provides fixed and permanent infrastructure which is powerfully attractive to investment. This enables greater confidence in the local transport network, and thus locational decisions with greater value added.

Is Cambridge too small?
50. We show that many cities throughout Europe similar in size to Cambridge, and smaller, have successful light rail. It is clearly possible; the challenge is to change the UK narrative.
51. In the context of Cambridge economic activity, its role in the UK economy, pressures of growth, the need for major behavioural change because of climate change (modal shift), the need for the right capacity to meet demand, outstanding heritage and environmental values that need protection, and the range of options for investment, we believe Cambridge is not too small. We need to plan for needs in the 2030s and beyond now.
Costs and financing
52. We project a budget of £1.4 - £1.8 bn to deliver the Isaac Newton Line and the Darwin Line in Phases One and Two over a period of 4 to 8 years, which is similar to the recent A14 road upgrade.
53. The tunnel and underground station represents ~ one quarter of the proposed initial investment. It is important to deliver the tunnel early in the process so that significant benefits, and revenue, can start to be realised quickly. The tunnel could be built in less than a year based on the speed of tunneling achieved by Crossrail, so tunnel construction speeds should not be perceived as a major barrier.
54. Given the light rail schemes proposed would wholly replace the current GCP busway plans, it is reasonable to assume that City Deal funds could be redeployed, which could provide an initial base of ~£400M in finance.
55. It seems reasonable to assume a sizeable proportion of Devolution Deal funds for the Combined Authority could be allocated to the scheme.
56. Our budget includes the link from Granta Park to Haverhill, which is an expensive component outside of the current City Deal scope. This represents ~£250M, which could be funded through an alternative mechanism such as the Restore Your Railways fund.
57. This would leave ~ £1bn of additional funds to raise. While challenging, there are a range of finance mechanisms that could be deployed. These could include some or a combination of a Business Rates Supplement (as successfully employed for Crossrail), the new National Infrastructure Bank (loan or guarantee), Section 106, and bonds. Other mechanisms such as a Congestion Charge, Workplace Parking Levy, Land Value Capture could also be explored. Significant finance was raised for the Northern Line extension to Battersea using similar mechanisms.
58. While the additional investment is a challenge, it is important to recognise that unless any investment achieves the objectives of the intervention it will fail to realise the benefits to the community.
59. Under-investment runs a very real risk of failing to deliver on important priorities that are needed to transform transport in this region, specifically to address the twin challenges of growth and climate change. We believe the strategy put forward in this document would contribute substantially to improving our prospects of meeting those challenges.
60. We hope the Combined Authority for Cambridgeshire and Peterborough will find our submission helpful, and that the arguments put forward will be found compelling and given serious consideration. We are keen to cooperate to create a better future.

Summary appraisal of light rail vs busways for Cambridgeshire





Data source: Cambridgeshire County Council Research Group https://data.cambridgeshireinsight.org.uk/dataset/2018-based-population-and-dwelling-stock- forecasts-cambridgeshire-and-peterborough

Development Houses % Houses Residents1 % Residents Jobs %Jobs
Northstowe 9500 19 22800 19 3500 9
Waterbeach Barracks 8500 17 20400 17 5800 14
West Campus / Eddington 3000 6 7200 6 6800 17
Cambridge Northern Fringe 2950 6 7080 6 3600 9
Cambridge East 1700 3 4080 3 1000 2
Cambridge Southern Fringe 4400 9 10560 9 10500 26
Hinxton / Babraham / Granta Park 0 0 5200 13
Bourn Airfield 3500 7 8400 7
Cambourne West 1500 3 3600 3 2800 7
St Neots East 3700 7 8880 7
RAF Wyton 3750 7 9000 7
Alconbury Weald 5000 10 12000 10
Ely North 3000 6 7200 6
Cambridge City Centre1 0 0 1800 4
50500 100 121200 100 41000 100
Greater Cambridge City Deal website retrieved 03 Mar 2016
http://www.cambridgeshire.gov.uk/citydeal/info/2/transport/9/transport

SUMMARY

1. GCP information made no projection for city centre houses.
2. Residents based on average number of occupants per house = 2.4 (UK average, Office of National Statistics).

Development Houses Residents % of Total
Northstowe 6345 15228 13
Waterbeach Barracks 5330 12792 11
Cambridge Northeast 3900 9360 8
Marleigh 1300 3120 3
Cambridge East 2850 6840 6
Darwin Green 2478 5947 5
Eddington 3142 7541 6
Clay Farm 151 362 0.4
Bourn Airfield 2460 5904 5
Cambourne West 2590 6216 5
Cambourne 1950 4680 4
Trumpington Meadows 302 725 1
North of Cherry Hinton 1200 2880 2
Worts Causeway 430 1032 1
Great Shelford 100 240 0.3
Sawston 418 1003 1
Melbourne 140 336 0.4
Total 35086 84206

Carbone4 / Alstom 2016. Tramways or bus rapid transit: which is greener? A study of the lifecycle CO2 emissions of tramway & BRT systems.

U-ground (km) O-ground (km) Total (km) Stops2 U-ground
£M3 O-ground
£M4 Total £M
Isaac Newton Line Phase
One 2.6 17 19.7 16 392 529 921
Darwin Line Phase One - 2.2 2.2 3 - 57 57
Phase One subtotal 2.6 19.2 21.9 19 392 586 978
Isaac Newton Line Phase
Two - 11.7 11.7 4 - 295 295
Darwin Line Phase Two - 6.5 6.5 5 - 165 165
Phase Two subtotal - 18.2 18.2 9 - 460 460
Newton Line +
Darwin Line 2.6 37.4 40.1 28 392 1046 1438
1. Estimate includes lines, tunnel, 2x u-ground stations, surface stations, rolling stock, depot.
2. Existing Cambridge Central and Cambridge North Rail Stations and proposed Cambridge South Rail Station are counted as stops.
3. Underground costs based on £73.5 M/km and INCLUDES two underground stations @ £100M each. Published cost of underground Métropole Nice Côte D’Azur Line 2, Railway Gazette (Oct 2015) and estimated cost of 5 m diameter tunnel in Cambridge geology of
£73.5M/km for bi-directional tunnel.
4. Surface light rail cost of £20-30M /km B. Menzies (2015) quoted Cambridge News 03 Feb 2015. £25M/km used above.

Figure 17. Costs of light rail by network component.

£852m £1500

Year Cambridge Working
Residents Commuting
WITHIN
Cambridge /d Commuting
OUT OF
Cambridge /d Commuting
INTO
Cambridge /d Total INTO /
OUT &
WITHIN /d Commuter journeys To-
From = x2 /d
2011 60 000 44 000 16 000 51 000 111 000 222 000
2031 70 800 51 920 18 880 60 180 130 980 261 960


Journeys Per
day Journeys Per Year
(M) Journeys Per Year
(M) Revenue per year
(£M)

Year Total journeys
commuters /d
Total /y
By Light Rail 20% (20% of commuter journeys
by Light Rail, avg fare £2.00)
2011 222 000 55.5 11.1 22.2
2031 261 960 65.6 13.1 26.2


City Lines Stations Length (km) Popn Length / person (m)
Reims 1 23 11.2 182,592 0.061
Le Havre 2 23 13 172,074 0.075
Saint-Étienne 3 38 11.7 172,023 0.068
Grenoble 5 71 36 160,215 0.225
Dijon 2 35 19 153,003 0.124
Angers 1 25 12.3 150,125 0.082
Cambridge (City) 2 24 40 154,0502 0.260
Le Mans 2 35 18.9 144,244 0.131
Clermont-Ferrand 1 34 15.9 141,463 0.112
Brest 1 28 14.3 139,386 0.103
Tours 1 29 15.5 134,803 0.115
Besançon 2 31 14.5 116,952 0.124
Orléans 2 49 29.3 114,375 0.256
Mulhouse 3 29 16.2 112,063 0.145
Rouen 1 31 15.1 110,755 0.136
Caen 2 34 15.7 107,229 0.146
Nancy 1 28 11.1 104,072 0.107
Avignon 1 10 5.2 90,305 0.058
Aubagne 1 7 2.8 45,303 0.062
Valenciennes 2 48 33.8 42,851 0.789




Cambridge Lausanne
City population 125 000 (2011)
154 050 (2031) 125 759 (1991 opened)
146 372 (Nov 2015)
Regional population 350 000 (2031):
South Cambs (commuter basin) 309 000 (Mar 2015): Lausanne
commuter basin.
City area 40.7 km2 41.4 km2
Regional area 901.63 km2 ?
Modal share 8% (bus) 40% (includes metro & bus)
Number of lines Two (Isaac Newton + Darwin) Two (M1, M2). New line in devlpmt.
Number of stations 28 29
System length 40 km 13.7 km
Length underground ~2.6 km ~7.5 km
Length dedicated alignment 92% segregated. Mainly segregated.
Length on street Several street crossings at grade. Some street crossings at grade.
Service frequency Every 5-10 min. 3 min central; 6 min elsewhere.
Top / Average speed 80 / 33 km/h 60 km/h; Avg 20 km/h (M2)
Track gauge 1435 mm 1435 mm
Catenary-free? As appropriate M1 No; M2 Yes
Automatic operation Yes (eg Docklands Light Railway) M1 No; M2 Yes
Total cost Newton + Darwin ~£1.5 bn M2 £333M (2008)
Cost per km £37.5M /km M2 £56.4M /km
Passengers /year 13.1M (2031) 40M (2014)
Operating revenue (annual) £26.2M – assumed 13.1M pax
journeys @ £2.00 average fare. £100M – assumed 40M pax journeys
@ £2.50 average fare.
Typical fare ~£2 - £4 ~£4 peak 2h for two zones


22. Existing GCP transport measures

• Construct bus lanes/ busways to regional population centres - buses proceed to Cambridge city centre. GCP strategy plans a massive increase in bus traffic in the inner city narrow streets, competing with cyclists and pedestrians.
• City Access Strategy published in August 2021, but appears similar to proposals made seven years ago, which led to resistance and protest by city business and residents.
• Lack of means to link busway limbs together to form integrated network across the region. Buses therefore likely to suffer from congestion in city centre.
• Busway schemes lack capacity and are not future-proofed for the 2030s in view of the growth already coming forward.
• GCP proposed inner city road closure at peak time with a view to forcing people to take the bus. Strong concerns about this option being harmful for the city economy and business led to protests, and the proposal was scrapped several years ago.
• Strong community opposition to both CSET and C2C busways. High concern about unnecessary damage to Green Belt environment and amenity when potentially viable alternatives exist.
• Busway schemes not aligned with community aspirations or needs. Large numbers of buses in the city will degrade the quality of the environment of the city.
• Park & Ride expansions/ additions. Greenways and cycle route/ path improvements.
• Improve traffic signaling.
• Schemes constrained by funding available in the City Deal.
• Expenditure to date: ~£100M yet limited delivery after almost seven years.
• Significant difficulties experienced in delivery of larger GCP schemes and substantial community opposition. Likely to lead to costly challenges at Public Enquiries.
• The GCP strategy was developed prior to 2015, based on a model formulated for the previous busway.
• Major developments in the science and understanding of climate change have occurred since the GCP strategy was formulated. In particular there are new requirements for decarbonisation in order to meet agreed net-zero targets.
• These changes have very practical implications for how we need to change our behaviour, systems and infrastructure going forward. This is particularly the case for transport, which accounts for around one-third of emissions.
• Questions should be raised about whether the old strategy remains fit for purpose for the 2030s and beyond?
• The solutions put in place now must have capacity and resilience to meet the needs of future generations. We believe the evidence strongly suggests that busways will not be adequate to meet the twin challenges of growth and climate change in 2030s, nor be sufficient to support the continued growth of the regional economy.

Table 11. Summary appraisal of light rail vs busways for Cambridgeshire

Cambourne to Cambridge – C2C
comments made in the Independent Audit implying we should have undertaken more detailed appraisal to be fair: this is not our job as members of the public, but rather the job of the authorities responsible for bringing schemes forward. The GCP should properly investigate all reasonable alternatives before proceeding with a preferred route that will damage the Green Belt, and both i-Transport and the Independent Audit have concluded the A428 co-aligned route is a reasonable alternative for detailed consideration.
Moreover, the A428 co-alignment alternative is supported by many in the community, and by the American Cemetery, because it would protect more of the Green Belt at the same time as delivering an excellent public transport link (e.g. see Appendix Two, and as outlined below).
The route we propose via the Girton Interchange would take less than two minutes longer to get to Cambridge from Cambourne than the route preferred by the GCP. Balanced against this, the route ensures the public transport route is integrated with the Girton Interchange, which is one of the most strategically important road junctions in the region, connecting the Ml 1, A14 and A428 highways. This allows the public transport network to be connected to regional centres such as Bar Hill and (rapidly growing) Northstowe in the future, as well as enables development of an inter-regional coach/ bus station at the interchange connected by the light rail link into Cambridge and to surrounding centres.
It is important to note that routing the C2C public transport route via the Girton Interchange does NOT REQUIRE the road interchange itself to be fully enabled at this time. This could be undertaken in the future, or not at all, and this work is not necessary for the Girton Interchange route to be strategically beneficial:
• it keeps options open for the future;
• it allows for onward links to important centres like Bar Hill and Northstowe;
• it serves to protect environmental and community values which lie at the heart of the strong opposition to the GCP preferred C2C route; and
• it allows a regional coach station to be located at the Girton Interchange connected via a light rail link into the city, employment centres, health and educational facilities, and to surrounding communities.
The outline proposal for an alternative route for C2C submitted to the C2C Independent Audit by Cambridge Connect is provided in Appendix One.
In 2019 Cambridge Connect collaborated with the Coalition of Parish Councils to the west of Cambridge to agree a 'Letter of Community Consensus' on the Girton Interchange. This letter called for consideration of fully enabling an all-ways road junction at the Girton Interchange, and importantly also called for:
"the strategic importance of the Girton Interchange be fully recognised by ensuring it is integrated with any mass transit scheme taken forward to the west of Cambridge".
This 'Letter of Community Consensus' was supported by a wide range of MPs, District Councillors, Parish Councils and Community Groups across the region to the west and north of Cambridge, and was submitted to the Secretary of State for Transport and the Secretary of State for Housing, Communities and Local Government. It was copied to the Combined Authority, GCP and Highways England amongst other stakeholders. The community represented by the signatories comprises more than 30,000 residents. The letter is provided in Appendix Two.
Addenbrookes to Granta Park – CSET
Cambridge Connect and Railfuture have collaborated with the Great Shelford and Stapleford Parish Councils in development of the 'Shelford Rail Alignment (SRA)' alternative to the GCP's preferred route for CSET, including working with i-Transport in their technical assessment of the alternative. The rationale for the SRA alternative is in summary:
• Follows former railway line to Haverhill;
• Avoids further severance and damage to landscape adjacent to villages of Great Shelford and Stapleford, adjacent to the important regional ecological sites of the Gog Magog Hills, Wandlebury and Magog Downs and also the important landscape and amenity values of the River Granta in this locality;
• More directly serves the community by passing through the villages, with stops in the heart of the villages. This will offer better community access, and will be safer for users of the public transport rather than isolated in the countryside as proposed by the GCP;
• Closely connected to the mainline railway with a convenient interchange at Great Shelford.
The i-Transport report (2021) commissioned by the Parish Councils concluded that the GCP CSET route was brought forward based on a number of false assumptions suggesting the SRA was not feasible. The professional transport analysis made by i-Transport concluded that the route is feasible, although it is recognised that it might be more expensive and further work would need to be undertaken to consider properly all aspects of how it would operate and be optimised.
We support the i-Transport conclusions, and further suggest that work undertaken on the reinstatement of the railway to Haverhill would help further inform choices of the best option for public transport in this region. Moreover, this could show how a reinstated heavy rail line could work in combination with light rail. In this context, we consider the GCP has given insufficient consideration to these alternatives and has not demonstrated a necessity to cut across the Green Belt with a new alignment and major bridge on the River Granta in the way that is proposed.
Transport proposals in the vicinity of, and have the potential to impact, the villages of Great Shelford and Stapelford include CSET, East-West Rail, Cambridge South Station, Haverhill line reinstatement, and increasing frequency of trains on existing mainlines to serve the growing population. A key community concern in this context is the cumulative effect of all of these developments, and there is concern that schemes are being developed in silos. The regional transport strategy needs to consider the cumulative impacts and develop adequate mitigation. For example, the level crossings in these villages are becoming increasingly impractical because of the frequency of closures. Cambridge Connect and Railfuture have proposed grade separation of the mainline railway in Great Shelford should be brought forward, and planned and delivered as part of regional transport schemes.
Cambridge Connect and Railfuture made formal submissions to the GCP public consultation on CSET in 2019. The Cambridge Connect submission is provided in Appendix Three.

25. Team - Brief bios
Cambridge Connect is established as a small company and is currently operated on a voluntary basis. Work is undertaken in collaboration with a range of individuals, companies and organisations on an informal basis. Brief biographical sketches of individuals who have played substantive roles in the development of the Cambridge Connect concepts and proposals are provided below.
Dr Colin Harris PIEMA – Director, Cambridge Connect
Dr Colin Harris is Director of the environmental planning consultancy Environmental Research & Assessment, based in Cambridge. Colin was educated at the University of Otago (BA Hons, First), University of Western Ontario (MA), and University of Cambridge (PhD), specialising in environmental management and spatial planning. He has worked in this field for 25 years and is a Practitioner in the Institute of Environmental Management and Assessment. His principal professional focus is on environment, sustainability and strategic spatial planning. Colin established Cambridge Connect Transit Ltd in 2015 to promote an evidence-led strategy to address Cambridge transport challenges. He has collaborated with a broad group of people to develop the evidence-base for light rail in Cambridge, and design of a segregated light rail network delivery strategy. He has published and presented widely on the subject.
Peter Wakefield – Vice-Chair, Railfuture East Anglia
Peter Wakefield was chair of Railfuture East Anglia until 2017, a role he held for over 20 years. In this role he advocated for public transport improvements, recognising the crucial link between a quality railway and sustainable economic development. For example, Peter pioneered the Railfuture campaign to restore East - West links between Cambridge and Oxford, an effort which is now close to practical delivery. Peter was closely involved in the successful campaign to establish a new station at Cambridge North, and for restoring the rail link to Wisbech. Peter has detailed knowledge of the rail industry, network and operations. Peter is interested in helping decision makers to make prudent forward-looking plans for the rail network and public transport services. Peter has played an key role on the Rail Freight Committee of Railfuture, has contributed to numerous submissions to government and consultations, and has been a spokesperson on topical issues. Peter has played the lead role in the Cambridge Connect initiative for Railfuture.

John Howland-Jackson – CEO, Nikko Asset Management Europe
John joined Nikko AM in 2014 and was appointed CEO in 2018. John is responsible for all aspects of the business across Europe, Middle East and Africa (EMEA) and Nikko AM's continuing growth strategy. John has an extensive background in international capital markets in particular and has held senior executive positions with leading financial institutions over many years. Prior to joining Nikko, he spent almost 15 years with the Dutch ING Group as Head of its Wholesale Banking Operations in Japan, the Asia Pacific region and the UK & Middle East. Having started his career with the UK Merchant Bank Kleinwort Benson he has also worked for JP Morgan, Nomura Securities Group and the NatWest Group. John holds a BA in Jurisprudence from Oxford University and is a qualified Barrister­ at-Law (Inns of Court Law School and Middle Temple 1972).

Ian Brown CBE FCILT – Railfuture / UK Tram
In a career spanning over 40 years, Ian Brown has made an outstanding contribution to public transport and the rail industry in the UK and internationally. His extensive achievements include playing a leading role in establishing the Docklands Light Railway and the London Overground, the major extension of the East London Line, the integration of Croydon Tramlink into TfL and the expansion of Oyster 'pay as you go'. Ian retired as Managing Director of TfL's London Rail in 2011 after 10 years in the role, and was honoured with a CBE in 2011 for services to the railway industry. Ian is a Vice President of Railfuture, and is on National Board of Directors. As Director of Policy, Ian has been instrumental in determining Railfuture's policies at a strategic level and has written several of its submissions to the Department for Transport. Ian is also a Board Member of UK Tram and leads its Centre of Excellence programme.

Peter Cushing – UK Tram
Peter Cushing was until recently Director of Manchester Metrolink, with responsibility for the day to day operation and delivery of a £1.8bn capital programme, retiring in 2017. He has extensive operating experience at board level and working with senior local and central government bodies delivering major capital programmes in the UK and overseas. Peter provided leadership in migration/ transition planning, merger planning and organisation design in a variety of Light Rail Transit and Metro assignments in the UK and abroad. He has been a senior figure in other consultancy projects including operations and commercial analysis roles for DfT, and several major rail bids. Peter played a lead role in establishment of the UK Light Rail Safety Standards Board. He is presently advising Midland Metro, Edinburgh Trams and consulting internationally on light rail.

James Hanson – Ankura
James manages the EMEA Construction Advisory team. He is a Civil Engineer with over 20 years industry experience in managing large and complex capital projects. James specialises in advising and assisting clients in project development, risk strategy, project controls and in the selection of project team and contracting organisations. James has extensive experience in the transport sector with expert knowledge of the financial, contractual and supply chain risks involved in delivery of railway projects. He has advised on major contractual, commercial and technical risks associated with capital delivery, operation and maintenance of railway projects, and advised on time and budget management. He has undertaken risk management reviews of vendor construction contracts, pre and post signature. Prior to Ankura, James was Managing Director of Navigant's Global Construction Advisory practice which was acquired by Ankura in 2018. Previously James was a Partner at PwC and worked for both its UK and Middle East Capital Project & Infrastructure practices.

Misbah Uddin – Ankura
Misbah is a Managing Director at Ankura specialising in transport and infrastructure project and finance advisory with over 17 years of experience. He is a government advisory and PPP specialist with particular knowledge and experience of the transport sector and infrastructure finance. His global experience and expertise includes business case development and review, cost/financial modelling, benchmarking, project due diligence, and project structuring advice to procuring authorities as well as bid-side advice to investors and contractors. Notable past clients in the rail sector include the DfT, TfL, National Express, Dubai Roads & Transport Authority, RATP and various other public and private transport sector investors and operators. Prior to Ankura, Misbah worked for PwC in both its UK and


Middle East Corporate Finance and Capital Project & Infrastructure practices. Prior to that, he worked for Boaz Allen Hamilton advising clients on a wide range of UK and international transport projects.

David Moore – CMS
David Moore is a Partner in the Infrastructure & Projects Team at the law firm CMS Cameron McKenna Nabarro Olswang LLP. David read engineering at the University of Cambridge and gained professional qualifications at the Chester College of Law. David specialises in the development and operation of transport infrastructure and is a specialist in the rail sector. He has over 20 years' experience advising on the development and operation of rail infrastructure (including as a PPP), rail franchises (both bidding and during operations), rolling stock procurement (including maintenance arrangements), operational issues, rail regulation and industry arrangements. He also has extensive experience developing and operating other transport infrastructure and acts for both private sector and public sector clients in the UK and internationally. He has been recognised by the legal directories
as "a judicious and intellectually astute transport projects lawyer'.

Paul Hollinghurst – Railfuture
Paul Hollinghurst is Secretary of Railfuture East Anglia, and has played an active role in numerous transport projects, including feasibility studies and business cases relating to reinstatement of railways to Wisbech and Haverhill. Paul has written analysis reports for Railfuture on topical issues, and has been a regular contributor to Rail East. He is a resident of Cambridge with first hand local knowledge and extensive practical experience of public transport services. Paul is an engineer for a semiconductor company working on SG mobile phone chip technologies.

Dr Mark Brown – Amey
Mark is Development Director of Arney's Consulting and Rail business where he leads strategic planning. He was previously Group Development Director at Halcrow. Mark is an economist with 30 years' experience in the transport sector. He has worked on a wide variety of highway, rail and development projects in over 20 countries and is widely published in project economics, rail planning and asset management. Mark is a director of the Wales and Borders Train Operating Company that is responsible for train operations throughout Wales, on behalf ofTransport for Wales.

Angela Chadwyck-Healey
Angela is Patron of the Cambridge and District Citizens Advice Bureau and President of the Arthur Rank Hospice Charity. She was a founder committee member for Cambridge 2030, which aims to make Cambridge a more equal city by 2030. Through this work and also involvement in community
resident's associations, amongst other activities, she has developed an excellent understanding of community needs. In particular, Angela recognises the need for a rapid transport system for those that live and work in the Cambridge region to provide reliable access to work, and for meeting other needs such as health care, education and leisure. She has supported Cambridge Connect since its inception because light rail is the only proven mode of transport that has the capacity to provide the service required, especially for future generations.


26. Declarations of interest

Ankura, Amey, COLAS Rail, COWI, CMS and OTB Engineering
These companies are agnostic in terms of specific transport modes and are involved in a wide range of public transit delivery schemes, including both bus and rail. They are interested in helping to deliver a successful transport scheme in the Cambridgeshire region on a commercial basis. None have vested interests in any specific transport solution for Cambridgeshire, rail-based or otherwise, and have freely offered their knowledge and expertise in order to help deliver an evidence-led solution with the best chance of success.
Collaboration has been on an informal basis to date.

Cambridge Connect
Cambridge Connect was founded on the principle of helping to design, develop and deliver the best public transport scheme for Cambridgeshire based on evidence, and is agnostic in terms of specific transport modes provided they meet quality and deliverability criteria.
Evidence reviewed led to the conclusion that light rail offers the most promising technology for delivery of a successful mass transit backbone in Cambridgeshire, and this would need to integrate with all other modes. Conceptual design work has therefore focussed on light rail as the core of the mass transit scheme. Work has been undertaken on both a cost-recovery and/ or voluntary basis, and in future Cambridge Connect aims to continue this work on a commercial basis.
Railfuture and UK Tram
These non-commercial groups aim to promote and support the public interest in rail-based transit in the United Kingdom in general. They have no commercial interests in the outcome for Cambridgeshire. These groups formed natural partners in the project because they possess substantial expertise in the field.

Cambourne - Cambridge Bus Road (C2C)
Independent Audit

Submission prepared by Colin M. Harris
25 ApriI 2021 (v1)
cambndge connec1

1 Introduction 3
2 Summary conclusions 3
3 Long-term transport planning 5
4 Implications of the pandemic 5
5 Sustainability 5
6 Alternative to the alignment proposed by GCP 6
7 Park & Ride proposal by GCP 8
Supporting maps and figures 8




1 Introduction
Cambridge Connect was initiated to promote a strategic and sustainable approach to public transport in Cambridgeshire. Emphasis is placed on an integrated and multi-modal approach to meeting the transport needs for Cambridge and the surrounding region. We recognise the need to link local solutions into broader regional strategies. Cambridge Connect has coordinated with a range of individuals, companies and organisations in developing its proposals. In particular, Railfuture and UK Tram have played a prominent role in the overall development of a light rail network for the region.
This submission made to the Cambourne - Cambridge Bus Road (C2C) Independent Audit focuses on an alternative to the preferred scheme proposal by the Greater Cambridge Partnership.
The alternative proposal is co-aligned with the A428 over a critical part of the route, and would avoid severance of, and landtake within, the Green Belt in this area (Figure 1).
2 Summary conclusions
In summary, Cambridge Connect:
Supports development of a new public transport route to the west of Cambridge following a fully segregated alignment immediately adjacent to, and co-aligned with, the A428 highway in the section between Madingley Mulch Roundabout and the Girton Interchange.
2 Does not accept the assumption by the GCP that an alternative fully segregated public transport route aligned to avoid severance of, and impacts on, the Green Belt is not possible, in particular because this conclusion is not supported by thorough and adequate evidence.
3 Does not support the route preferred by the GCP because of unacceptably high and unnecessary impacts on the Green Belt and on the highly valued rural landscape which lies in close proximity to Coton and Cambridge in general, which have not been sufficiently taken into account.
4 Does not support the current proposals of the GCP for the large Park & Ride at Scotland Farm, the size of which is likely to encourage and support travel by private cars to that point. Rather investment should instead consider any additional P&R, if deemed necessary, with emerging plans for both East-West Rail (EWR) and the CAM 'metro' public transport network.
5 The COVID-19 pandemic has demonstrated that current approaches to public transport delivery do not have sufficient resilience to operate effectively in the face of such shocks. The current bus road proposals are based on old approaches from the last century, and do not have sufficient resilience to cope with similar potential scenarios in the future. At a minimum, the C2C scheme should be paused to allow detailed consideration to changes that are necessary to build in greater resilience to our public transport systems, especially those for access to critical services such as healthcare and research centres.
6 Supports the submission made by the Coton Parish Council, which includes the independent technical report prepared by specialist transport consultancy i-Transport which forms an integral part of the submission by Coton Parish Council.
7 A series of maps and figures illustrating the A428 co-aligned alternative to the C2C preferred alignment is provided with this submission.

3 Long-term transport planning
Cambridge Connect considers that infrastructure development needs to be fit-for-purpose for the region with a planning horizon into the 2030s and beyond. The key drivers of economy, population, demand, education, science & technology environment & heritage, and social & cultural values all need to be taken into account with a long-term view, and these need to be balanced against the cost and investment needed for future generations.
It is important that communities are tightly integrated into future public transport provision, and this is vital to ensure the best possible up-take of the services, and to provide excellent connections for residents.
Before progressing new busways or bus roads, a detailed plan for delivery of the long-term strategy for Cambridgeshire public transport needs to be set out and adopted. Local solutions should then be designed so they integrate seamlessly into the overall strategic plan, both in terms of technologies used for the 'metro' and also the routes. This strategy should be at an advanced stage of development when implementing local solutions, even if this would mean a short-term delay in delivery of some local improvements. This approach would avoid waste and bring cost-savings over the medium-term.
4 Implications of the pandemic
The implications of the current COVID-19 pandemic for public transport are major and cannot be ignored. The pandemic has demonstrated that we need to design our public transport systems to be more resilient to shocks. The science tells us that COVID-19 is unlikely to be the last pandemic we face. It is clear that current approaches and systems have been inadequately designed and prepared for such challenges.
The authorities should carefully consider the implications for bus-based solutions which are inherently based on existing models, which have been shown to lack the capacity and technologies to enable more resilience in public transport. While light rail is by no means a panacea, it does have the substantial advantage of much greater capacity than buses, and in this it has the potential to be much more flexible and resilient to future shocks.
Before rushing to deliver a bus road solution - with major damage to the local landscape - the authorities should carefully consider how improved resilience can be built into our public transport systems. This is particularly the case in C2C which should play a vital role in servicing communities and education facilities, as well as the City Centre, to which key workers need continued access during pandemics.
5 Sustainability
Around one third of energy consumption is used on transport (MacKay, 2009: Sustainability without the hot air: p.118). The evidence shows that rail remains the most energy-efficient means of public transport available, being at least twice as efficient as buses and up to 18 times more efficient than cars. Improving the energy efficiency of our transport systems must be a key consideration in our choice of transport solutions. This approach is consistent with commitments made at the 2015 Paris Summit on Climate Change, and with the more recent declarations by the UK Government of the 'Climate Emergency' and in specific carbon reduction targets, in particular with respect to the need to adopt more sustainable approaches to city planning and transport. Light rail has been demonstrated to drive higher levels of modal shift than buses. These important conclusions have been emphasised at recent Climate summits.
Light rail also performs much better than other public transport on pollutant emissions. Fine particulate pollution is released by rubber-tyred vehicles, and these pollutants enter the atmosphere, terrestrial and water systems. These emissions have been shown to account for as much particulate pollution as released by vehicle tail-pipes, so even if the proposed buses were electric a substantial air pollution problem remains. Rubber tyres are largely made from synthetic plastics, which take a very

long time to degrade. The microplastics from wear enter into aquatic and terrestrial systems, and are taken up by organisms. In addition, large numbers of waste tyres are produced, and for a high frequency metro operation this could lead to many hundreds or thousands of waste tyres per year. The C2C proposals do not address these aspects of sustainability adequately.
Light rail is more sustainable for metro operation than buses because it consumes substantially less power than rubber-tyred buses, owing to the low rolling resistance of steel wheels on rails (~ one tenth of rubber tyres on road). Light rail lines may also offer benefits through more sustainable water drainage systems than the extensive tarmac/ concrete needed for bus roads.
These considerations, in particular with respect to the selection of mode for transport delivery (ie bus or light rail) need to be reviewed and taken into more consideration in the development of the C2C scheme.
6 Alternative to the alignment proposed by GCP
6.1.1 Cambridge Connect strongly opposes the alignment proposed by the Greater Cambridge Partnership for C2C.
6.1.2 The Girton interchange is one of the most important strategic junctions in the region, being as it is at the crossroads of nationally and regionally important highways of the M11, A14, A428 and A1307 (Huntingdon Road). However, the GCP has specifically excluded this from detailed consideration for reasons which do not hold up to scrutiny. The assessments that have been made to date have been based on poor and superficial evidence.
6.1.3 Maps 1-5 and two figures presented below outline how the alternative alignment along the A428 highway (suggested by Cambridge Connect) could be configured.
6.1.4 From Madingley Mulch Roundabout the alignment could proceed on either side of the A428 to the Girton Interchange, although maps presented here illustrate only the option for the alignment on the south/ southeast side of the A428. An alignment on the north side would also seem feasible, although would need investigation of options for crossing to the south (and hence to the West Campus) at some point either at or before the Girton Interchange.
6.1.5 The alignment presented to the south/ southeast of the A428 highway would proceed immediately alongside the A428 highway (co-aligned to the side of the highway with appropriate barrier separation), follow under existing bridges over the A428, then from the Girton Interchange proceed under the M11 using an underpass (in the area where the Ml 1 is already elevated and an underpass currently exists), thence south via the general vicinity Eddington and the Madingley Park & Ride to the West Campus. This proposal is necessarily indicative at this stage, although it has been confirmed that the proposal is viable at a high level of consideration and as such warrants detailed investigation as a realistic alternative before the C2C scheme alignment should be further progressed.
6.1.6 Inadequate evaluation has been made of this alternative, and others, which seems to have occurred because the C2C scheme has been based on a number of false assumptions. Most important amongst those has been the assumption that the Girton Interchange option should not be considered as a potential route because it would take too long to deliver and is more complex and costly. This assumption fails to consider that the route could be delivered via the Girton Interchange area without necessarily altering the Girton Interchange itself.
6.1.7 Alterations to the Girton Interchange involve changes to the road network, while the alignment presented in this alternative is separate and fully segregated from the road network and is not dependent on alterations to the Girton Interchange itself.
6.1.8 Even without alterations to the interchange itself, the alternative offers substantial benefits by co-alignment with major existing transport routes and also by avoiding sensitive Green Belt and heritage resources, while still serving the communities and scheme objectives. The alternative therefore represents a realistic alignment that could be brought forward irrespective of whether or not Highways England make alterations to the interchange itself.

6.1.9 Thus, a connection into, and integration with, the Girton Interchange is a not a necessary part of such an alignment. However, if adopted, that option would be available when and if this is considered desirable and affordable in the future. An alignment via the general location of the Girton Interchange, without alterations to it, enables it to be future-proofed for future developments by ensuring that the C2C route proceeds via the immediate vicinity of what is arguably the most important strategic junction in the region.
6.1.10 The assumption has also been made that the route via the Girton Interchange would represent a diversion that would compromise the attractiveness of the public transport route between Cambourne and Cambridge because of the extra distance. However, we have shown that the alternative route would add only approximately 1 ½ minutes to journey times on a segregated route compared to the preferred C2C route. When considered against the range of major benefits of the alternative alignment, this small journey time penalty is acceptable.
6.1.11 The alternative route would directly support the community of Eddington. Moreover, the route would open up opportunities for onward connections to communities such as Bar Hill and Northstowe in the future.
6.1.12 The C2C route makes an unnecessary incursion into Green Belt and development of major infrastructure for a busy transport route across relatively tranquil and unspoiled rural landscapes of high aesthetic value. It will impact local ecology and recreational uses, as well as commercial farms. It will create additional severance of the Madingley Hill and Bin Brook valley from local communities. These values have not been given sufficient consideration in the decision to pursue this route. The GCP preferred C2C route requires major new land-take from the Green Belt. There is insufficient justification for this because a feasible route via the A428 / Ml 1 exists utilising existing transport corridors.
6.1.13 The GCP route runs counter to policies that seek to minimise the impact of infrastructure and development on Green Belt land, and against policies that seek to protect landscapes of high value. The landscape affected is immediately adjacent to one of the very few elevated sites in the Cambridge region, namely Madingley Hill. This site is already compromised by the A1303 highway, and a further major public transport route across this landscape will further degrade and despoil the remaining high landscape values.
6.1.14 The focus of this submission has been on the section of alternative between Madingley Mulch Roundabout and the West Campus because this section represents a major strategic failing in the C2C scheme. There are also significant failings in Hardwick and the City Centre.
6.1.15 Cambridge Connect has wider proposals for an integrated scheme across the Cambridge region using light rail, including for a short tunnel (2.6 km) extending from near the West Campus through the city centre to the Cambridge Rail Station. Details of these proposals can be accessed on the Cambridge Connect website (www.cambridge-connect.uk).These wider proposals address deficiencies in the C2C scheme within the Cambridge city centre, where a coherent plan for practical public transport that is transformative of journeys is largely missing from the GCP C2C scheme. The existing plans for how C2C would work within the City Centre are inadequate and fail to show how the scheme would be delivered in an integrated and coherent manner without significant impacts on city residents and businesses.
6.2 Opportunities for long-term gains – developing an integrated approach to improvements in rail and public transport in Cambridge
6.2.1 Future developments of the heavy rail network need to be taken into consideration. For example, developments such as Cambridge South Station, East-West Rail (EWR), and service improvements more generally will influence activity and services on the main rail lines.
6.2.2 C2C should not be progressed without detailed planning for integration with CAM.
6.2.3 C2C should not be progressed without detailed planning for integration with EWR.

7 Park & Ride proposal by GCP
7.1.1 Cambridge Connect opposes the proposed Park & Ride at Scotland Farm, and considers it in the wrong location. Cambridge Connect supports some form of new Park & Ride in the general vicinity of Cambourne.
7.1.2 However, as a general principle, it is important that the location selected and size is appropriate and can be practically integrated with future development of the CAM and EWR.

FOLLOWING BELOW: SUPPORTING MAPS AND FIGURES

DISTANCE & JOURNEY TIMES
GCP 'C2C' vs 'A428 Co-Aligned Northern Route' COMPARISON Potential P&R A14
(Connect to stop via footbridge) Scale: 1:10 000 @ A3 Basemap: Sentinel Imagery
25 June 2020.
Prepared by: Cambridge Connect © 2021 www.cambridge-connect.uk 10 Apr 2021 Version 10.1

Girton
!!! GIRTON INTERCHANGE

Existing farm road
Northern route: MMR to 'BABBAGE' underpass of M11
via Girton Interchange Distance = 5.06 km Journey time = 5.06 mins
Madingley @ 60 kph average speed
= 1.42 km / 1.42 mins longer

Northwest Cambridge
Northern route: in A428 cutting !!! EDDINGTON
Co-aligned with A428

800-Yr Wood Eddington
To Scotland Farm M11
Park & Ride ~2 km

Madingley Wood American
SSSI Cemetary
Madingley Mulch
Roundabout (MMR) GCP C2C Route:
A1303 MMR to 'BABBAGE' via Coton
Distance = 3.64 km
Journey time = 3.64 mins @ 60 kph average speed
GCP C2C route: across Green Belt = 1.42 km / 1.42 mins shorter
High
Cross West
Map 1 - LEGEND Campus
A428 Co-Aligned Route (indicative) Coton !!! BABBAGE
100-y old orchards

C2C Bus Route (indicative)
0 0.5 1
Miles
0 1 2
Kilometres


C2C INDICATIVE ALTERNATIVE ALIGNMENT
Northern Route to Girton Interchange Co-Aligned with A428 Alignment at Madingley Mulch Roundabout
To Scotland Farm Park & Ride ~2 km
New bridge over A428 for public transport

A428
in cutting

To Madingley 1km

To Girton Interchange 2.5km

Bridge starts here (approx)


Alignment passes under Bridge

Madingley Mulch Roundabout (MMR)






Proposed Alternative Alignment (width 8 m)

ad
To Hardwick 2km

To Cambridge 5.6km
Source: Esri, DigitalGlobe, GeoEye, Earthstar Geographics, CNES/Airbus DS, USDA, USGS, AeroGRID, IGN, and the GIS User Community

C2C INDICATIVE ALTERNATIVE ALIGNMENT
Northern Route to Girton Interchange Co-Aligned with A428 A428 cutting at Madingley A428 Co-Alignment Positives
+ Follows existing major transport alignment
+ In A428 cutting to reduce noise
+ Car traffic reduced = noise reduced on A428
+ Protects important landscapes
+ Avoids American Cemetary
+ Avoids Madingley Wood SSSI
+ Avoids Eight Hundred Wood
+ Avoids Green Belt fragmentation Scale: 1:1000 @ A3 Basemap: ArcGIS Imagery
Prepared by: Cambridge Connect © 2021 www.cambridge-connect.uk 01 Mar 2021 Version 10.0

Madingley

Potential Madingley stop if alignment on
N side of A428 (optional) Indicative upper
level of cutting slope (~8 m (25 ft) vertically above A428)
Potential Madingley stop (optional)



Bridge buttress here (approx)

Co-aligned with A428
Width = 8 m Alignment passes
under Bridge


Trinity
Alignment in cutting Cottages
with retaining wall
No landtake from Eight Hundred Wood

Map 3 - LEGEND Eight Hundred Wood
Proposed Alternative Alignment (width 8 m)
0 50 100
Metres Source: Esri, DigitalGlobe, GeoEye, Earthstar Geographics, CNES/Airbus DS, USDA, USGS, AeroGRID, IGN, and the GIS User Community


C2C INDICATIVE ALTERNATIVE ALIGNMENT
Northern Route to Girton Interchange Co-Aligned with A428 Option - Co-Aligned Southeast side of A428

To Dry Drayton 3km Bar Hill 4 km

A428 Co-Alignment Positives
+ Strategic location future-proofed for onward links
+ Follows existing major transport alignments
+ Avoids fragmentation of Green Belt
+ Minimises environmental impacts - reduces road traffic
+ Avoids American Cemetary (Grade I Listed)
+ Supports Eddington / West Campus
++ Fully segregated, practical & deliverable

Scale: 1:5000 @ A3 Basemap: ArcGIS Imagery
Prepared by: Cambridge Connect © 2021 www.cambridge-connect.uk 01 Mar 2021 Version 10.0

Girton

Potential P&R & Coach Station


To Science Park 4km


Pedestrian overbridge from P&R / Coach Stn to Metro stop



Potential Offramp from A428 eastbound to P&R / Coach Station via underpass of A14 westbound causeway

GIRTON INTERCHANGE


Proposed Alternative Alignment (width 8 m)

C2C Northern route via Girton Interchange (1 min 45 sec longer)

Expand existing
M11 Underpass Parallels M11

To Eddington 0.75km West Campus 2km Cambridge 4km




Source: Esri, DigitalGlobe, GeoEye, Earthstar Geographics, CNES/Airbus DS, USDA, USGS, AeroGRID, IGN, and the GIS User Community

C2C INDICATIVE ALTERNATIVE ALIGNMENT
Route Co-Aligned with A428 via Eddington West Campus layout - key constraints Scale: 1:5000 @ A3 Basemap: ArcGIS Imagery
Prepared by: Cambridge Connect © 2021 www.cambridge-connect.uk
01 Mar 2021 Version 10.0
Eddington

Madingley Park & Ride



A1303 J13 Public Transport
Route Junction Public Transport Option B Route Junction
Option A

C

M11


Ancient orchards


West Campus
Public Transport Route GCP Option w M11 bridge










Map 5 - LEGEND
Proposed Alternative Alignment (width 8 m)
To City
0 50 100 200 300 400 500
Metres Source: Esri, Maxar, GeoEye, Earthstar Geographics, CNES/Airbus DS, USDA, USGS, AeroGRID, IGN, and the GIS User Community


Indicative schematic of cutting on A428 at Madingley - view west. Typical cross section. Dimensions in metres (approx).


PRESENT SITUATION
Trinity Cottages


~60 m to bridge


Ground level


Bridge rail level


Bridge ~60 m




Bridge base clearance level



Buttress



Embankment

1.0


6.0


15.0


8.0



6.25

A428
2 lanes 2 lanes
A428 Road level






WITH PUBLIC TRANSPORT LANES CO-ALIGNED WITH A428
Trinity Cottages


~60 m to bridge









Ground level


Bridge rail level



Bridge ~60 m


Buttress



Retaining Wall

2 lanes 6.25



Embankment





1.0







6.0

3.25







15.0





3.65



Two lanes
7.3 3.65
8.0



A428 Road level



APPROX SCALE

0 15 30 45 60


METRES

Schematic of bridges on A428 - south side, view west. Typical cross section. Dimensions in metres (approx).

Bridge rail level
1.0

6.0


15.0

8.0



Madingley dimensions - 15.0 m from pier to buttress edge, 6.25 m height from A428 road level to clearance under bridge. Church Road dimensions - 16.0 m from pier to buttress edge, 8.0 m height from A428 road level to clearance under bridge.
A428 MMR Offramp dimensions - 15.0 m from pier to buttress edge, 5.0 m height from A428 road level to clearance under bridge.

LETTER OF COMMUNITY CONSENSUS
FROM CAMBRIDGE PARISH COUNCILS, DISTRICT COUNCILLORS AND COMMUNITY GROUPS

01 May 2019

The Rt. Hon. Chris Grayling MP Secretary of State for Transport

cc: The Rt. Hon. James Brokenshire MP, Secretary of State for Housing, Communities and Local Government

Heidi Allen MP for South Cambridgeshire Daniel Zeichner MP for Cambridge
Lucy Fraser MP for East Cambridgeshire
James Palmer, Mayor, Cambridgeshire & Peterborough Combined Authority Councillor Bridget Smith, Leader of South Cambridgeshire District Council Councillor Lewis Herbert, Leader of Cambridge City Council
Rachel Stopard, CEO Greater Cambridge Partnership Jim O’Sullivan, CEO Highways England


Dear Secretary of State,

Open Letter of Community Consensus on the need for all-ways connectivity at the Girton Interchange serving the M11, A428, A14 and A1307 at Cambridge.
The Girton Interchange is a key strategic junction on the Cambridge regional road network, connecting the M11, A14, A428 and A1307. The junction is severely hampered by a lack of all-ways connectivity. Enabling full connectivity will provide faster and more efficient connections on the road network, help to alleviate some of the long-standing congestion problems in the region and facilitate regional transport links to support economic growth. Moreover, it will improve connections between new housing developments west of Cambridge, the M11 motorway and the rapidly growing biotechnology cluster south of Cambridge city. Longer-term, the junction is vital to proposed improvements to east- west links.
Purpose of this letter
We are a group of Parish Councils and South Cambridgeshire District Councillors, representing over 30,000 people living in communities in and near Cambridge, and selected community interest groups. We note the letter from the Greater Cambridge Partnership (GCP) to Highways England (19 Oct 2017) regarding the urgent need for all-ways connectivity at the Girton Interchange; we welcome the consensus among local governments, the Combined Authority for Cambridgeshire and Peterborough, the GCP, MPs and business groups to progress this scheme; and we warmly welcome the positive indications from Highways England for delivery in due course.
We are concerned, however, that Highways England has not yet committed to include the Girton Interchange in the Road Investment Strategy (RIS-2) work period between 2020 and 2030, and that no clear plan has yet been articulated.


We write to express, in the strongest terms possible, our support for this development, which is long overdue, and to request that it be given urgent priority.


Requests for urgent action

1. We request that work on improvements to the Girton Interchange to enable all-ways connectivity be accelerated and given urgent priority as part of the strategic transport improvements needed in this region.
2. We request that the strategic importance of the Girton Interchange be fully recognised by ensuring it is integrated with any mass transit scheme taken forward to the west of Cambridge.
3. We request that improvements help to reduce, and not exacerbate, the already detrimental impacts of traffic on the local road network and on the immediately surrounding communities.
4. We request that present proposals to constrict the capacity of the A428 eastbound where it joins the A14 at the Girton Interchange, from the present two lanes down to one lane, be reconsidered in anticipation of future needs.
5. We request that, where practicable, this work be integrated with on-going work on the A14 to make the most cost-effective use of resources and supporting works already mobilised.
6. We request that funding be made available and that all stakeholders work together to give their full commitment, with the aim of delivering these improvements by 2023 at the latest.

The letter from the GCP and MPs and the response from Highways England are encouraging, and we are pleased that support is broad and analysis is underway. However, we note that these improvements have been called for by the community for more than twenty years, with little action to date. Much as we welcome the ongoing work of Highways England, there is currently no commitment to a timetable for completion of the improvements at the Girton Interchange. We believe the time for clear, unambiguous action has arrived, and a plan and timetable for delivery of this essential infrastructure is urgently needed.
In summary, all-ways interconnections at this critical junction are in the local, regional and wider national strategic interest and are in need of urgent action by all relevant parties.

If it would be helpful, we would be pleased to meet you or your officials to provide more information on the views of the community on the scheme.

We look forward to hearing from you.




Coalition of Parish Councils


Steve Jones Chair Cambridge Connect





Dr Colin Harris Director


Parish Councils, District Councillors and Community groups expressing support for this letter
The Coalition of Parish Councils comprising Arrington, Barton, Bourn, Boxworth, Caldecote, Caxton, Comberton, Connington, Coton, Croxton, Dry Drayton, Elsworth, Eltisley, Eversden, Grantchester, Hardwick, Knapwell, Longstowe, Madingley, and Toft parish councils.

Girton Parish Council and South Trumpington Parish Council, which are not members of the Coalition, also have endorsed the letter. Cambourne Town Council has also long-expressed support for all-ways connectivity at the Girton Interchange.

South Cambridgeshire District Councillors:

• Cllr Ian Sollom (Harston & Comberton) (the Parishes of Barton, Comberton, Coton, Grantchester, Harlton, Harston, Haslingfield, Hauxton and South Trumpington)
• Cllr Philip Allen (Harston & Comberton)
• Cllr Tony Mason (Harston & Comberton)
• Cllr Grenville Chamberlain (Hardwick) (the Parishes of Hardwick and Toft)
• Cllr Tumi Hawkins (Caldecote) (the Parishes of Bourn, Caldecote, Childerley, Kingston, Little Gransden and Longstowe)
• Cllr Tom Bygott (Girton) (the Parishes of Dry Drayton, Girton and Madingley)
• Cllr Dr Shrobona Bhattacharya – Cambourne
• Cllr Ruth Betson – Cambourne

Selected Community interest groups:

• Cambridge Ahead
• Cambridge Connect
• Cambridge Past, Present & Future
• Federation of Cambridge Residents Associations (FeCRA)
• Smarter Cambridge Transport

Background
On 19 October 2017 an open letter was written from the Greater Cambridge Partnership to Jim
O’Sullivan, Chief Executive of Highways England regarding the Roads Investment Strategy 2 (RIS2) – M11 in Cambridgeshire. This letter noted a clear consensus within our region for the improvements to the Girton Interchange, as indicated by the broad representation in the letter of local government, the academic and business communities, and Members of Parliament for Cambridge City and South Cambridgeshire.
Martin Fellows, Regional Director of Operations (East) Highways England, responded on 17 Nov 2017 that the agency is assessing the strategic road network (SRN), including pressures on the M11 and the case for improvements at Girton Interchange, which will feed into RIS2. Following consultation, the Investment Plan for RIS2 will continue to be developed over 2018. In due course the Secretary of State for Transport will decide on priorities for RIS2, to be published in 2019.
The Girton Interchange is a key strategic junction on the regional road network, which is severely hampered by a lack of all-ways connectivity. Enabling connectivity will provide faster and more efficient connections on the road network, help to alleviate some of the long-standing congestion problems in


the region, facilitate regional transport links and support economic growth. Moreover, it will improve connections between areas west of Cambridge, such as Cambourne, and the M11 motorway, and support the increasing population. Longer-term, the junction is vital to proposed improvements in East- West links between Cambridge, Milton Keynes and Oxford, as recommended by the National Infrastructure Commission.
We recognise that some villages lying in close proximity to the Girton Interchange are already significantly affected by noise and air pollution from the current road system. It is important therefore that improvements should help to reduce, and do not exacerbate, any impacts on local communities.


Coalition of Parish Councils
The Coalition of Parish Councils to the West of Cambridge was formed to provide a coordinated voice on planning issues.


Cambridge Connect
Cambridge Connect was formed in 2016 to promote enduring and sustainable transport for Cambridge, in particular a light rail metro with an underground in the historic city core. The Girton Interchange is considered a key node on the network, where the metro would link with important strategic highways. Cambridge Connect works closely with Railfuture, UK Tram and Rail Haverhill, amongst others.

More information on Cambridge Connect is available at www.cambridge-connect.uk


Address for Correspondence
Dr Colin Harris Director
Cambridge Connect 12 Silverdale Avenue
Coton, Cambridge CB23 7PP

Email: colin.harris@cambridge-connect.uk Tel: 01954 212 847

Cambridge Southeast Transport (CSET) Greater Cambridge Partnership
Public Consultation

Prepared by Colin M. Harris 14 December 2020 (v1)









1 Introduction 3
2 Summary conclusions 4
3 Long-term transport planning 7
4 Implications of the pandemic 7
5 Sustainability 7
6 Light rail: general benefits for Cambridge Southeast 8
7 Specific comments on route proposed by GCP 9
8 Park & Ride proposals by GCP 15
9 References 15


1 Introduction
Cambridge Connect was initiated to promote a strategic and sustainable approach to public transport in Cambridgeshire. Emphasis is placed on an integrated and multi-modal approach to meeting the transport needs for Cambridge and the surrounding region. We recognise the need to link local solutions into broader regional strategies.
Within the immediate Cambridge region, we have proposed a light rail line from the Girton Interchange in the northwest to Granta Park in the southeast, via the University West Campus, city centre, Cambridge Central Rail Station, Addenbrookes, Great Shelford, Stapleford and Sawston. The line would extend ~22 km (~14 mi) and we call this route the 'Isaac Newton Line' (Figure 1) (Harris et al. 2019). The light rail line would follow existing and former rail alignments, run underground within the historic city core, and follow the busway alignment between Cambridge Central Rail Station and Addenbrookes. Extensions to the 'Isaac Newton Line' light rail backbone are possible in due course, for example to Haverhill and Cambourne.
This approach would provide a transformational long-term solution for Cambridge that is both scalable in terms of capacity and extendible to key destinations as demand and finances allow. Cambridge Connect is coordinating with Railfuture and UK Tram in developing these proposals and engaging with local organisations (e.g. CPPF, local parishes and Rail Haverhill) and residents.
Cambridge Connect understands that the Greater Cambridge Partnership has presently excluded light rail from consideration. However, we believe this decision should be reconsidered and light rail should form part of the strategic long-term approach to meeting transport needs in Cambridgeshire.
Reconsideration of light rail is needed because it is clear from Steer (2019) that the costs for the Cambridgeshire Autonomous Metro (CAM) will be comparable to Cambridge Light Rail. The original conclusion that CAM could be delivered for one-third of the cost of light rail has been shown to be wrong (Steer 2019). The business case for CAM was 'compelling' and would be stronger with light rail, which is able to deliver greater modal shift than buses. It is therefore essential that the strategy for metro delivery in Cambridgeshire is thoroughly reviewed to include light rail.
Notwithstanding the above views regarding light rail, we recognise the Greater Cambridge Partnership (GCP) has presently committed itself to bus-based solutions. In the context of this response to the public consultation therefore, our focus is on the selection of route rather than the mode of vehicle that would travel on that route. We have therefore made our evaluation of proposals for a fully segregated bus road following the Shelford Rail Alignment (Figure 2), not light rail.
Our evaluation is informed in part by detailed evidence developed by an independent evaluation of the option of a public transport route from Granta Park to Addenbrookes that broadly follows the Shelford Rail Alignment (Figure 2). This evaluation was commissioned by the Parish Councils of Great Shelford and Stapleford in 2020 and undertaken by the professional transport specialist consultants i­ Transport, London. Specifically, this professional review critically examined evidence underpinning the report to the GCP prepared by Mott MacDonald published in May 2020.


2 Summary conclusions
In summary, Cambridge Connect:
Supports development of a new public transport route in the Southeast following the alignment of the existing and former rail lines via Great Shelford / Stapleford. A fully segregated public transport route along the entire Shelford Railway Alignment, including through the villages adjacent to the existing rail line, has been shown to be feasible by independent specialist transport consultants.
2 Does not accept the conclusion by the GCP (as advised by Mott MacDonald in May 2020) that a new public transport route (whether light rail or busway) aligned with the existing and former rail line through Great Shelford/ Stapleford is not feasible because the conclusion is not supported by thorough and adequate evidence.
3 Does not support the route proposed by the GCP because of unacceptably high and unnecessary impacts on the Green Belt and on the highly valued rural landscape which lies in close proximity to Gog Magog Hills and Magog Down, which have not been sufficiently taken into account.
4 Does not support the current proposals of the GCP for the large Park & Ride on the A11, the size of which is likely to encourage and support travel by private vehicles. The old approach of large Park & Rides is out-moded, and the focus and investment should instead be made in delivering a first class public transport network with a more distributed model of access nodes.
5 Supports some form of Park & Ride at Granta Park, although of more modest scale and the location should support delivery of a new public transport route to Haverhill, which will strongly influence demand for Park & Ride at this location. The location selected does not appear best suited to supporting a practical segregated public transport route to Haverhill. Delivery of the link to Haverhill should be accelerated, and should be planned in an integrated way with any Park & Ride proposals. We propose the route to Haverhill should follow the broad alignment of the former railway and be implemented using light rail.
6 The COVID-19 pandemic has demonstrated that current approaches to public transport delivery do not have sufficient resilience to operate effectively in the face of such shocks. The current bus road proposals are based on old approaches from the last century, and do not have sufficient resilience to cope with similar potential scenarios in the future. At a minimum, the CSET scheme should be paused to allow detailed consideration to changes that are necessary to build in greater resilience to our public transport systems, especially those for access to critical services such as healthcare and research centres. For example, light rail has the potential to offer greater resilience through its superior passenger capacity, potentially allowing services to operate with higher social distancing in place and better margins of safety. While we do not see light rail as a panacea, it is concerning that the GCP seems to be pressing ahead as though nothing has changed.
7 Supports submissions made by Cambridge Past Present & Future, the Parishes of Great Shelford and Stapleford, Magog Down Trust, Railfuture, and Smarter Cambridge Transport related to CSET.


3 Long-term transport planning
Cambridge Connect considers that infrastructure development needs to be fit-for-purpose for the region with a planning horizon into the 2030s and beyond. The key drivers of economy, population, demand, education, science & technology environment & heritage, and social & cultural values all need to be taken into account with a long-term view, and these need to be balanced against the cost and investment needed for future generations.
It is important that communities are tightly integrated into future public transport provision, and this is vital to ensure the best possible up-take of the services, and to provide excellent connections for residents. Where practicable, and when balanced against the environmental impacts of other options, public transport should seek to achieve well-connected communities.
Before progressing new busways, a detailed plan for delivery of the long-term strategy for Cambridgeshire public transport needs to be adopted. Local solutions should then be designed so they integrate seamlessly into the overall strategic plan, both in terms of technologies used for the metro and also the routes. This strategy should be at an advanced stage of development when implementing local solutions, even if this would mean a short-term delay in delivery of some local improvements. This approach would avoid waste and bring cost-savings over the medium-term.
4 Implications of the pandemic
The implications of the current COVID-19 pandemic for public transport are major and cannot be ignored. The pandemic has demonstrated that we need to design our public transport systems to be more resilient to shocks. The science tells us that COVID-19 is unlikely to be the last pandemic we face. It is clear that current approaches and systems have been inadequately designed and prepared for such challenges.
The GCP should carefully consider the implications for bus-based solutions which are inherently based on existing models, which have been shown to lack the capacity and technologies to enable more resilience in public transport. While light rail is by no means a panacea, it does have the substantial advantage of much greater capacity than buses, and in this it has the potential to be much more flexible and resilient to future shocks.
Before rushing to deliver a bus road solution - with major damage to the local landscape - the GCP should carefully consider how improved resilience can be built into our public transport systems. This is particularly the case in CSET which will play a vital role in servicing essential healthcare facilities, to which key workers need continued access and especially in pandemics.
5 Sustainability
Around one third of energy consumption is used on transport (MacKay, 2009: 118). The evidence shows that rail remains the most energy-efficient means of public transport available, being at least twice as efficient as buses and up to 18 times more efficient than cars. Improving the energy efficiency of our transport systems must be a key consideration in our choice of transport solutions. This approach is consistent with commitments made at the 2015 Paris Summit on Climate Change, and with the more recent declaration by the UK Government of the 'Climate Emergency', in particular with respect to the need to adopt more sustainable approaches to city planning and transport. These important conclusions have been underscored at recent Climate summits.
Light rail also performs much better than other public transport on pollutant emissions. Fine particulate pollution is released by rubber-tyred vehicles, and these pollutants enter the atmosphere, terrestrial and water systems. These emissions have been shown to account for as much particulate


pollution as released by vehicle tail-pipes, so even if buses were electric a substantial air pollution problem would remain. Rubber tyres are largely made from synthetic plastics, which take a very long time to degrade. The microplastics from wear enter into aquatic and terrestrial systems, and are taken up by organisms. In addition, large numbers of waste tyres are produced, and for a high frequency metro operation this could lead to many hundreds or thousands of waste tyres per year.
Light rail is more sustainable for metro operation than buses because it consumes substantially less power than rubber-tyred buses, owing to the low rolling resistance of steel wheels on rails (~ one tenth of rubber tyres on road). Light rail lines may also offer benefits through more sustainable water drainage systems than the extensive tarmac/ concrete needed for bus roads.
6 Light rail: general benefits for Cambridge Southeast
The 'Isaac Newton Line' would substantially address transport needs to the south of Cambridge in the general area of the A1307 highway by linking the bioscience campuses at Granta Park/ Babraham to the biomedical campus at Addenbrookes and to the central rail station and city centre. In the southeast Cambridge region, the 'Isaac Newton Line' would:
• Provide a light rail 'backbone' extending from Granta Park in the southeast to Girton Interchange in the northwest, linked to the heart of Cambridge city;
• Integrate with the heavy rail network at Cambridge Central Rail Station, at Great Shelford, and at the proposed new Cambridge South Station at Addenbrookes;
• Provide multimodal links to bus/ coach and Park & Ride services at key interchanges - for example the A11 / AS0S. Similar multimodal links would be provided at Junction 11 on the Ml 1 / A10 and atthe Girton Interchange on the A428 / A14 / M11;
• Provide a new Park & Ride near the A11 / AS0S junction, close to the A1307 and Granta Park which would serve the surrounding region (although smaller than proposed by GCP);
• Provide reliable, fast and frequent public transport into the heart of Cambridge from the south, meeting public transport objectives in this region;
• Provide a reliable, fast and frequent link between the three University campuses;
• Connect the Babraham Campus and Granta Park employment centres and other research institutes and businesses in the south of Cambridge directly with the Biomedical Campus, the city centre, and University West Campus;
• Provide an excellent public transport service that could be linked to Hinxton / Wellcome Trust and Babraham Campus developments by short and cost-effective shuttle services, which could in the future be fully automated;
• Relieve vehicle traffic pressure on the A1307 / Hills Road by attracting people onto the alternative light rail route, which would provide rapid travel into the centre of Cambridge without congestion;
• Directly serve the villages of Sawston, Stapleford, the Shelfords, Abingdon and Babraham (the latter by shuttle) with a high-quality, reliable public transport system;
• Enable improvements in the links to Haverhill and Linton, which could be served directly by a light rail extension from Granta Park to Haverhill;
• Serve potential growth in housing and development to the south of Cambridge, including in the long-term to lower cost housing areas such as Haverhill;


• Serve and strengthen business connections at the South Cambridge Business Park;
• Serve the Football Club grounds in Sawston by excellent public transport, which would reduce potential congestion associated with game fixtures;
• Directly serve Sixth Form Colleges and the University Technical College at Long Road and Hills Road, better linking these to the villages of the Shelfords, Stapleford and Sawston;
• Encourage walking / cycling from nearby residential areas and employment centres to strategically located stops on the public transport network;
• Foster a more sustainable city and region, protecting its rich heritage and environmental values, with light rail being the best technology for air and water quality.
7 Specific comments on route proposed by GCP
Cambridge Connect strongly opposes the route proposed by the Greater Cambridge Partnership to link Addenbrookes to Granta Park on the following grounds.

7.1 Practical feasibility, constraints and costs
7.1.1 Cambridge Connect notes that WSP (2018: 2) highlighted "Stakeholders and members of the public ... indicated a preference for new infrastructure to follow, where possible, the route of the dismantled railway on the grounds this is an established and accepted transport corridor".
7.1.2 Cambridge Connect also notes WSP (2018: 2) pointed out that "Transport modelling ... identified a significant benefit from routing Strategy 1 close to the settlements of Sawston, Stapleford and Great Shelford, where the introduction of intermediate passenger stops would offer the most significant step change in user behaviour, with access to approximately 2800 dwellings within 800 metres of the route that would result in a pronounced mode shift away from private car travel, more than other options tested".
7.1.3 WSP (2018: 4) noted the "unguided nature of the design requires a more traditional carriageway width of 7.3m, based upon DMRB TD 27/95 fig4.4a), that is greater than that required for a kerb or track guided busway".
7.1.4 WSP (2018: 7-8) concluded: "A route following the dismantled railway through to Great Shelford was considered; unfortunately this is not viable for a road based Public Transport system given the lack of available space alongside the existing ... railway, particularly at Great Shelford station ... encompassed by residential and commercial development that precludes taking a new route that by-passes the station and platforms that abut the railway...". However, no factual evidence (such as measurements and identification of potentially affected structures) in support of this conclusion was presented in WSP (2018).
7.1.5 Mott MacDonald (2019) referred to the work by WSP (2018) that considered the old rail route and concluded "Given that using the former railway alignment through Shelford has previously been considered unfeasible, this was not considered further at this stage". While this seems to suggest that the WSP conclusion was taken 'as read', despite the lack of evidence, Mott MacDonald did carry out some further site technical evaluation of the specific section through Great Shelford, since part of their report identifies potential constraints along this section and includes cost estimates to address those constraints.
7.1.6 The Mott MacDonald (2019) Technical Note also concluded that a public transport route through Great Shelford parallel to the existing and former rail alignment is not feasible. However, the Technical Note did not conclude that the physical constraints could not be


overcome (listed in Section 6 of the Technical Note), but rather drew the conclusion that it would be more costly.
7.1.7 The work to overcome the practical constraints, while perhaps more difficult and expensive in certain places, nevertheless could be delivered through an additional investment to address the physical constraints.
7.1.8 Mott MacDonald (May 2020) concluded clearly that a route through the villages was technically feasible. This report demonstrates a feasible route could be implemented, provides detailed diagrams, and shows a short section of Chaston Road being adopted for "shared use". However, Mott MacDonald (2020) concluded that the route was not feasible on other grounds, but did not undertaken a proper like-for-like comparison with the route through the villages, and nor did it undertake an evaluation of the impacts on the environment by proceeding through the Green Belt landscape as proposed by GCP. The Mott MacDonald conclusions therefore cannot be relied upon because the report fails to consider important evidence that has a material bearing on the outcome.
7.1.9 The report by independent transport professionals i-Transport, commissioned by Great Shelford and Stapleford Parish Councils in 2020, demonstrated that - contrary to Mott MacDonald (2020) conclusions -a fully segregated public transport route along the entire Shelford Railway Alignment, including through the villages adjacent to the existing rail line, is feasible. Small amendments to the assumed layout design would enable this full segregation.
7.1.10 i-Transport further showed that deliverability with a revised approach following the Shelford Rail Alignment would only directly affect up to four residential properties. While we agree that property demolitions should be avoided wherever possible, they should not take over-riding precedence against other factors such as protection of the Green Belt. If this were to be the case, this would give undue weight to the interests of several properties/ residents against wider benefits for the entire community over the long term. We do not believe such an approach - as appears to be taken by the GCP - to be justified in the CSET context.
7.1.11 i-Transport have examined issues such as Passenger Demand, Cost and Environment at a high level at this stage, and while further appraisal will be required, they noted that the Mott MacDonald (2020) conclusions appear subjective and poorly evidenced, and are therefore unreliable.
7.1.12 In our view there is strong evidence that the route option through Great Shelford/ Stapleford has been dismissed prematurely by the GCP on the basis of insufficient evidence.
7.1.13 A clear distinction needs to be made between practical physical constraints (physical possibility) and budget constraints (need to consider costs versus benefits, or availability of funds). Mott MacDonald (2019, 2020) shows the practical physical constraints can be solved. Therefore, should the route through the villages be preferred, the question of feasibility becomes more a matter of cost, rather than one of pure physical constraints per se.
7.1.14 This is important, because while the cost of addressing the physical constraints of the route through Great Shelford has been estimated, the value of the Green Belt and its associated landscape, ecology, farm production (i.e. potential losses owing to 'orphaned' fields), and recreational benefits have not been assessed.
7.1.15 Neither have the additional costs of an alignment through Great Shelford been considered against the substantial additional economic benefits that would accrue by locating the public transport route at the heart of the community, as confirmed byWSP (2018) (see Section 7.1.2). These economic benefits would accrue both by fostering ridership on public transport, and also by improving the accessibility of businesses located within the villages of Great Shelford and Stapleford to people coming from outside of these communities. This would contribute to


improved economic activity and vibrancy in the villages. Additional economic benefits would accrue by reductions in the number of car journeys that would be made to access the stops.

Figure 3: Much of the former rail alignment remains as an elevated embankment suitable for reinstatement (Photo: C. Ross 2019).

7.1.16 Both the WSP (2018) and the Mott MacDonald (2019, 2020) Technical Notes are based on a non-guided road-based public transport alignment. This option would require greater land­ take than a light rail option, which has physical guidance by rails. As such, their conclusions on feasibility, both in terms of physical space and cost, do not apply to light rail. An assessment of the feasibility of light rail following the former rail line route remains needed.
7.1.17 A preliminary examination of Croydon Tramlink shows that it is possible to align a light rail line alongside a heavy rail line with minimal separation (Figure 4). While we have not carried out detailed investigations, this suggests that a light rail line along the Great Shelford route may be significantly more feasible, and perhaps less costly in some respects, than the proposed busway. For example, it is likely to have narrower width requirements, and require fewer physical barriers to separate the railway from the public transport route.
7.1.18 In addition, the GCP has made no assessment of the feasibility of small sections of single-track alignment where there are particular constraints on space at 'pinch-points'. This type of approach is currently successfully implemented at pinch-points on the southern Cambridge Guided Busway. We understand that modern signaling systems are capable of managing short single-track sections such as might be needed without significant delays. A proper assessment of this option should be undertaken, not only for light rail but also for the bus-based solution.
7.1.19 The GCP route has three at-grade crossings, each of which increase costs. The alternative light rail line as proposed below in Section 6.4 has one at-grade crossing, reducing costs. While the proposed grade separation would cost more at Granham's Road, this could be shared with other stakeholders, lowering costs to be paid for through this specific scheme.



Figure 4: Croydon Tramlink alignment immediately west of Beckenham Junction station. The light rail line is at far left, while the remaining three lines are heavy rail. (Image: Google Maps 2019).

7.2 Improved connectivity and integration
7.2.1 The route proposed by the GCP is isolated and approximately one km and uphill from centres of the villages of Great Shelford and Stapleford. It is thus not well-integrated with the community along the route. This distance is a barrier to residents and makes public transport use less likely, suppressing potential modal shift, which runs counter to the scheme purpose.
7.2.2 The distance to the new line will dissuade many from walking to the stops. This may encourage people to drive to the nearest stop, with knock-on implications for parking and congestion. While this may be mitigated to some degree by provision of a connecting bus service from the village to the new public transport line, and perhaps imposition of parking restrictions, this introduces additional and unnecessary barriers to use of public transport.
7.2.3 A public transport route going through the heart of the villages would be more accessible to the community, and as noted in WSP (2018) is also the clear preference of the local communities. This would promote use of the service, and lead to an outcome that is more environmentally, socially and economically sustainable. This approach would help to drive the much-needed modal shift, one of the scheme's overall objectives. Evidence shows that this effect is even greater where the public transport provided is light rail (Harris et al. 2019).
7.2.4 Close alignment with the heavy rail line within Great Shelford enables co-location of the Rail Station and light rail stop. This would facilitate easy interchange between light rail and heavy rail, improving public transport options for the community, and improving its attractiveness. The GCP route is isolated and fails to achieve this close connectivity.
7.2.5 Co-location of the Rail Station with a light rail stop would be an opportunity for improvements to the urban realm in this location, e.g. offering commercial opportunities for cafes etc.
7.2.6 The scheme should be planned in an integrated way with cycling, pedestrian and vehicle provisions. Public transport and cycleway/ pedestrian paths do not always need to be running

7.3 Environmental benefits, landscape values and sustainability

7.4 Opportunities for long-term gains – developing an integrated approach to improvements in rail and public transport at Cambridge Southeast
public transport route. It would also be a major benefit to the local community. It is important to consider these issues now so that schemes can be optimised to meet all objectives and are fit-for-purpose well into the future.
7.4.4 Cambridge Connect supports detailed investigation into options for grade-separated crossings of the main rail line on Granham's Road and Station Road/ Hinton Way in Great Shelford, and suggests that this should form an integral part of the overall scheme for public transport delivery because it should have a material influence on which options are selected.
7.4.5 An approach to address the grade separation problem in a way that integrates with public transport improvements in Cambridge Southeast has been outlined by Peter Wakefield, Vice­ Chair of Railfuture East Anglia. In this submission, we will refer to this proposal as the 'Grade Separation Proposal'. Cambridge Connect supports the general approach in the Grade Separation Proposal, and believes it should be given detailed consideration for delivery of any public transport solution in Cambridge Southeast. We recognise Grade Separation would be complex and that detailed studies and plans will need to be developed.
7.4.6 In summary, the outline Grade Separation Proposal proposes a new road bridge on Granham's Road to provide grade separation over the existing heavy rail line, and this would also span the parallel light rail line that we propose from Great Shelford to Addenbrookes. The Grade Separation Proposal includes closure of the current at-grade crossing on Station Road/ Hinton Way, with provision of an alternative vehicle route over to the newly-bridged Grantham Road. Pedestrian/ cycle access along Station Road/ Hinton Way would be continued via a modern, wide ramped, fully accessible and well-lit subway under the railway.
7.4.7 The Grade Separation Proposal would result in vehicles using Granham's Road for access to the A1307, and the Station Road/ Hinton Way would become for local traffic only, with no through-route. The proposal assumes that a bridge or subway for vehicles would be impractical on Station Road/ Hinton Way. The proposal supports a light rail line parallel to the existing and former rail line between Addenbrookes and Granta Park, as originally proposed by Cambridge Connect, Railfuture and UK Tram.
7.4.8 The new public transport route proposed by the GCP requires three at-grade crossing points with existing roads (Babraham Road, Haverhill Road, Hinton Way). These crossings will require full control by traffic lights, and will both slow public transport along the route as well as create additional constraints on vehicular traffic flow. Moreover, every crossing point contributes to additional safety risks.
7.4.9 The Grade Separation Proposal would result in only one at-grade crossing point along the light rail route instead of three, and this would be in the same location as shown by the GCP on Babraham Road. Reducing the number of crossings would significantly improve the speed and safety of the public transport route, and also improve flows for traffic needing to travel to/from the A1307 and Great Shelford.
7.4.10 Cambridge Connect urges the GCP and Combined Authority to give full consideration to the Grade Separation Proposal with a view to examining its delivery in combination with the light rail options presented in our submission following the alignment along the existing and former rail lines through the village of Great Shelford.
7.4.11 Greater consideration needs to be given to the integration of the proposed Cambridge South Station with CSET. The new station needs to be planned taking into consideration the needs for grade separation nearby and potential implications for the Great Shelford Station.


8 Park & Ride proposals by GCP
8.1.1 Cambridge Connect supports some form of new Park & Ride in the general vicinity of Granta Park. It has not been possible for us to make site-specific assessments and therefore cannot recommend one location over another based on site characteristics.
8.1.2 However, as a general principle, it is important that the location selected can be practically integrated with future development of the proposed segregated public transport route to Haverhill, which should be implemented using light rail.
8.1.3 The size and scale of the Park & Ride should be planned in conjunction with delivery of the Granta Park- Haverhill public transport route, because a high proportion of demand for the Park & Ride is likely to arise from residents along this route and from Haverhill. The proposed size of the Park & Ride appears considerably larger than needed, shouId these other considerations be given detailed attention.
8.1.4 In this respect consideration should be given to opportunities for a metro model with more 'distributed Park & Ride' sites, where stops on the metro network accommodate much smaller areas of parking where practical. This approach would reduce demand for very large Park & Ride sites that concentrate high levels of local impacts with large areas of land-take/ usage. Distributed parking at metro stops could result in less intrusive developments for parking, with more pedestrian and cycle access, although it is acknowledged that this could mean more, but smaller, sites.


9 References
Harris, C.M, Brown, I., Cushing, P., Wakefield, P. & Hollinghurst, P. 2019. Greenprint for a sustainable future: Cambridge Light Rail. Report by Cambridge Connect, Railfuture & UK Tram. Available from:
http://www.cambridge-connect.uk/wp-content/up1oads/2019/04/Cambridge-Connect-Greenprint- 30Mar2019-v8-LR.pdf
MacKay, David J.C. 2009. Sustainable energy- without the hot air. UIT Cambridge Ltd, Cambridge. Mott MacDonald. 2019. Technical Note: 'Feasibility of Old Railway Alternative Route' (16 Aug 2019). Mott MacDonald. 2020. CSET Phase 2: Shelford Railway Alignment - Design Development and
Feasibility Assessment (18 May 2020). Report prepared for GCP.
Steer 2019. Cambridgeshire Autonomous Metro Strategic Outline Business Case. Report prepared for the Greater Cambridge Partnership and Cambridgeshire and Peterborough Combined Authority.
WSP 2018. 'Technical Note: Strategy 1 Route Study'. REF: 70012014-TN-010 Strategy 1 Route Assessment. (13 July 2018).


GCP Busways Light Rail

20 November 2021
SUMMARY     
CONSIDERATION GCP Busways Cambridgeshire Light Rail (CLR)

Network • Where fully segregated, flexibility similar to light rail.
• Where not segregated, buses in congestion, impacting speed / reliability / reputation
• Busway to Waterbeach not needed – use heavy rail connected to light rail within city.
• Slow and congested within city. 
  • Fully segregated – reliable, fast, minimal collision risk.
• Network to Cambourne / Granta Park / Science Park similar.
• Higher ability to generate modal shift (proven).
• 40 km core network covers high demand areas.
• Interchange with buses: integrated ticketing / timetabling.
• Fast, frequent service connects with buses & heavy rail network.

Rubber vs Rails • Standard diesel / hybrid bus; in time battery electric
• Rubber- tyres produced from oil.
• Buses = tyre / road pollution. Not suited to tunnel.
• Buses at metro frequency = potholes.   • Standard technology, proven, highly sophisticated.
• Billions invested in Light Rail Vehicle development.
• Rails address road pothole problems. Excellent in tunnel.
• Rails inflexible, but permanent, encourages investment.

Tunnels • No tunnel currently proposed. Cheaper.
• Surface running – potential congestion.
• City access more difficult if roads closed without a good
alternative.   • Short, simple tunnel (2 portals) to meet essential needs.
• Automatic light rail proven deliverable for tunnel operations.
• Tunnel improves access speed, frequency, reliability, capacity.

Safety • Busway / articulated bus safety lower than light rail.
• Heavy buses at high frequencies impose on cyclists and pedestrians, reducing their safety, especially in city.   • Very safe. Proven over billions of miles.
• Best safety record possible. Segregated way safer in city tunnel.
• Rails add to safety by providing physical guidance.

Environment & Health • Lower energy efficiency = less sustainable.
• Higher particulate pollution from tyres = health risks.
• High volume of waste rubber tyres.
• Higher greenhouse gas emissions over scheme lifetime   • Most energy efficient, less power needed, highly sustainable.
• Lowest possible particulate pollution.
• Superior technical solution for environment / health.
• Lower greenhouse gas emissions over scheme lifetime.

Costs • Lower capex to install segregated roadway.
• Electric buses cheaper.
• Bus lifetimes short – higher materials / carbon / energy.
• Higher opex & high road maintenance costs.   • Higher capex for permanent rails.
• Light Rail Vehicles (LRVs) more expensive.
• LRVs last longer – lower embodied materials / carbon / energy.
• Lower whole-life costs.


Financeability / Economic benefits
• City Deal finance (£500 m) sufficient for several busways.
• Lower investor confidence profile for bus scheme.
• Bus schemes less attractive to investors.
• Gross Value Added lower from bus schemes.
• Lower gains in economic productivity.   • Higher investment needed up front for light rail.
• High investor confidence profile for light rail scheme.
• Proven solution provides investors with confidence.
• Permanent infrastructure provides investor confidence.
• Gross Value Added higher from light rail scheme – more attractive, generates greater associated investment.
• Higher gains in economic productivity.

Delivery of benefits • Modal shift poor compared to light rail.
• Bus mode share ~8% - need to shift to 25-30%.
• Insufficient capacity to meet scale of growth / demands of climate change. Not future-proofed.
• Buses unable to deliver change on scale required.   • Strong modal shift, as evidenced in other cities with light rail.
• Proven, dependable, reliable: deliverable today.
• Attractive and able to deliver change at scale required.
• Future-proofed capacity for growth / Climate Change.

    

GCP Busways

Light rail

• Scheme Profiles
• Comparative Analysis

Scheme profiles – key characteristics
Characteristic GCP Busways Cost (£m) Cambridgeshire Light Rail (CLR) Cost (£m)
Mode Bus with rubber tyres on tarmac or concrete road Light rail vehicle with steel wheels on rails

Power Electric batteries. Recharging at termini / supercapacitors at stops. Charging infrastructure. OLE / ground power supply options not currently
available. Hydrogen potential. Electric Overhead Line Equipment (OLE), with options for Electric ground supply, or batteries charging at termini / supercapacitors at stops. Hydrogen potential.
Guidance Driver steering on roads. Driverless automatic mode possible. Physical steel rails.
Network length1 ~45 km (incl. busway to Waterbeach). (~£11 m/km) 500 ~40 km (including tunnel) (~£25 m/km excl tunnel) ~1432
Tunnel length None ~2.6 km (Phases 1 & 2) (one fifth of CAM) with 2 portals ~273
Segregation Busways fully segregated. City not segregated. Fully segregated >95% of network
Service frequency Assumed ~5-10 mins at peak within city, beyond city
~15 mins ~5 mins within city, ~15 mins beyond city.
Max speed 100 kph (60 mph) 100 kph (60 mph)
Autonomy Driver required. Autonomous operation unknown. Automatic operation available today. Driver optional.
Number of vehicles 200 (@ ~£400K ea) 80 40 (@ ~£2 m ea). 80
Vehicle capacity 50 – 100 100 – 300. Capacity future-proofed.
Vehicle longevity 10 – 12 years (estimated bus life) 25 years (proven) (e.g. DLR vehicle life up to ~30 yrs)
Vehicle length / width 9 – 12 m / 2.2 – 2.7 m 18 – 37 m / 2.4 – 2.7 m
Vehicle weight 7.5 – 13 tonnes dependent on length 16 – 20 tonnes dependent on length
City stops Unknown 22
Underground stations None x1 (City Centre) ~100
Depots x2 (owing to number of buses required) ? x1 40
Operating costs ~£4.00 per vehicle kilometre (estimate)2 30 pa ~£5.00 per vehicle kilometre3 40 pa

1. Based on average UK scheme costs (excluding DLR; Ref 18) scaled to 2019 prices , multiplied by an optimism bias of 1.4. Half of this cost (£15 m per km) has been estimated for busway conversion since many costs will not be required (eg alignment, moving services, land purchases, etc.).
2. Operating costs uncertain. Eg, road maintenance. is excluded for buses, while for light rail it is included. A true comparison is needed, taking into account road maintenance, which is significant.
3. Based on Metrolink & others analysed by P. Cushing 2019. NB: DLR & Metrolink operate at profit, Nottingham NET breaks even. Revenue-earning capacity needs to be taken into account.

Scheme profiles – network maps

GCP Busways Cambridgeshire Light Rail (CLR)
Existing busway Proposed busway Heavy railway

CITY


REGION


GCP Busways

Light rail

• Scheme Profiles
• Comparative Analysis

NETWORK

    

RUBBER vs RAILS

Poor Weak Average

Good Excellent


CONSIDERATION GCP Busways Cambridgeshire Light Rail (CLR) Ref.


Maintenance • Road wear: proportional to the fourth power of axle weight. Wear exacerbated by high frequency.
• Repetitive tracking on single path (e.g. optical guideway) exacerbates wear, with constant potholing (e.g. Caen rubber-tyred ‘guided buses’ beset by road maintenance problems – unreliability & high costs led to replacement by light rail).
• Road maintenance costs; not clear whether road maintenance included in busway costings.
• Cambridge Guided Busway: major maintenance needed after 8 y, despite theoretical 40 y lifetime.
• Maintenance costs need to be accounted for in the whole-life cost appraisal of buses.


• Rail / trackbed transfers vehicle loads using well-understood engineering.
• Rail engineering proven to be durable and effective over
hundreds of years of experience.
• Rails address the road wear problem.
• Rail maintenance required but comparatively less.
• Rail maintenance costs are accounted for in budgets and paid out of operational revenues.
• Light rail is replacing busways where whole-life costs are taken into account.

1

Autonomous operation
• Autonomous operation delivery unknown.  
• Automatic operation deliverable today. Autonomous rail vehicles likely deliverable before road because of physical guidance.

Friction / efficiency
• High tyre friction; low energy efficiency.   • Very low friction; most energy efficient.
• Steel wheels on rails have ~15% of the rolling resistance of rubber tyred vehicles.
2

Power requirement • Significantly more power required to deliver an equivalent service level owing to substantially lower energy efficiency of rubber-tyred vehicles.
• Higher power requirements inflates operational costs.   • Light rail requires the lowest possible power to deliver the required service level because of its high efficiency.
• Less energy required to run light rail vehicles than buses to deliver the same service level.
2

Resuspension of Particulates • Approx 27% of non-exhaust particulates are derived from resuspension of particles along route.
• Large tyre > road contact surface increases particulate resuspension and recycles harmful pollutants into air.  
• Lowest possible contact area of wheel to rail (size of 5p piece) – particulate resuspension lower.
13

Passenger experience • High ride quality claimed but road subject to wear / potholes over time, leading to deterioration in quality; impacts on passenger satisfaction with ride.  
• High ride quality proven and consistent over lifetime of rail light rail vehicle with appropriate maintenance. 1, 15,
16, 17,
18

Flexibility • Flexibility to operate on normal roads using a standard bus.
• More flexible in theory but unsuited to mass transit.   • Less flexible as light rail operates only on permanent track
• Specialised system that delivers mass transit very well

TUNNELS

Poor Weak Average

Good Excellent


CONSIDERATION GCP Busways Cambridgeshire Light Rail (CLR) Ref.


Tunnel Configuration

• None, surface only.  • One simple linear tunnel with two portals.
• Tunnel length ~2.6 km (Phases 1 & 2).
• Tunnels size to meet legal and safety requirements. Diameter twin-bore ~4 -5 m OR single bore ~8 m.
• Includes 800 mm side access way
• Standard twin or single bore tunnel.

8, 9

Capacity • Operating at surface impacts other users such as pedestrians, cyclists, deliveries, etc.
• Surface operation has capacity constraints for future.  
• Tunnel capacity future-proofed.



Safety
• Elevated safety risks of large vehicles at surface for pedestrians / cyclists.
• Cyclists, pedestrians and car drivers are regularly injured and some have been killed by buses on the Cambridge busways  

• Safety proven worldwide and UK (e.g. DLR).
• Very low risk – rails provide physical guidance, proven safe.
• In-tunnel 800 mm wide along-track accessway assumed.



Tunnel operations


• N/A  • Low particulate emissions and zero engine emissions make
light rail better suited to use inside confined tunnel space.
• Lower heat venting needed without rubber tyres.
• Twin bore tunnel would have cross passage linkages and comply with legal, safety and practical requirements.
• Need for escape routes, but short tunnel length and simple configuration.

Heritage / urban realm • Heavy transport infrastructure at surface negatively impacts on city heritage /urban realm by bus congestion.
• Surface pollution increases with bus emissions from tailpipes, tyre and brake wear, degrading urban realm.  
• Protects heritage / urban realm by placing heavy transport infrastructure underground.


Tunnel cost

• Zero  

• Expensive, but benefits very high.

ENVIRONMENT, SAFETY & HUMAN HEALTH

    


CONSIDERATION GCP Busways Cambridgeshire Light Rail (CLR) Ref.

Energy Efficiency • ~ Double the energy requirements.
• Regenerative braking transfers energy back to power plant.
• Battery will wear out / lose capacity over time.   • Rail is most energy efficient form of mass transit.
• Low energy requirement is significant cost saving: energy consumption accounts for large proportion of operational costs.
• Regenerative braking transfers energy back to power plant.
2


Emissions & Particulate Pollution • Zero emissions from electric motor at point of operation.
• Particulate pollution from tyre, road & brake wear.
• Particulates elevated by heavy vehicles and tyre footprint.
• Fine particulates harmful to human health –as important as tail pipe emissions.
• Microplastics from tyres discharged into water / ecosystems.  
• Zero emissions from electric motor at point of operation.
• Low levels of particulate pollution from rail / wheel / brake wear.
• Lower levels of fine particulates.
• Best option for human health.

3, 4, 5, 6,
7, 13


Waste & sustainability • Thousands of waste tyres, which may be recycled into other uses, including burning for fuel, though energy inefficient.
• Battery waste disposal may be significant issue.
• Raw materials for batteries are non-renewable.   • Low waste. Durable. Steel recyclable.
• If OLE used, no waste batteries, and power can be sourced from sustainable, renewable sources.
• Longer vehicle life = more sustainable use of materials / embodied energy.

Noise • Electric vehicles low noise – rubber tyre roar at speed.
• Improvement on diesel buses.   • Electric vehicles low noise – rail screech if not well-maintained.
• Improvement on diesel buses and on rubber-tyred vehicles.

Carbon Footprint
• If segregated, road & guideways may result in more construction carbon.   • Rails may elevate construction carbon cf roadway structures.
• Carbon-free steel is being manufactured today.
• Low-carbon cement could be considered for tunnel.



12
• Modal shift offsets construction carbon and carbon from energy consumed. Modal shift lower than light rail.
• Higher operational carbon emissions owing to lower energy
efficiency, depending on power sources.   • Modal shift offsets construction carbon and carbon from energy consumed. Modal shift more certain.
• Lower operational carbon owing to higher energy efficiency, depending on power sources.
• Carbon footprint lower than BRT over scheme lifetime.



Collision Risk
• Busway safety lower than light rail. No physical guides.   • Segregated operation minimises collision risk / lowers costs.
• Accidents risks very low – one of safest modes that exists.
• Light rail one of the safest forms of public transport. 15x safer than buses, and 24x safer than cars.
• Operational speed, reliability, revenue and reputation all maintained at high levels.



10
• Collision risk elevated on shared roads. “Collisions in shared road space are a significant operational cost.”
• Elevated risks of injury / death on shared road spaces
• Speed, reliability, revenue & reputation suffer from collisions. 

Visual Impact • Concrete / tarmac roadway including cuttings, and potential structures for guidance, signs etc.   • OLE catenaries, if used, and tracks including cuttings.
• Catenary not required if ground feed or battery adopted (hybrid approach could minimise visual intrusion in sensitive areas).

COSTS & ECONOMIC BENEFITS

Poor Weak Average

Good Excellent


CONSIDERATION GCP Busways Cambridgeshire Light Rail (CLR) Ref.


Overall cost & risk
• £500 m for partially segregated network.
• Lower cost but unlikely to deliver modal shift required or economic benefits at the same level as light rail.  
• ~£1.3 – 1.7 bn for Phase 1 & 2 network.
• Proven technology deliverable, low financial risk.
• More costly, but greater benefits.
9, 15, 16,
17, 18

Tunnel cost & risk • Zero cost, but risks lack of capacity, poor connectivity
and impacts on urban realm, heritage and amenity.   • ~£273 m for 2.6 km tunnel with 2 portals.
• Simple short tunnel to reduce costs.
• Tunnel size and costs predictable / low risk.
9

Underground station cost
• Zero.   • ~£100 m per station.
• 1 station proposed.
9


Segregated way
costs
• Capital investment lower for existing roads.  

• Initial capital investment in steel track higher.
• Whole life costs more favourable (see below).

• Capital investment significant for segregated bus roads. 

Vehicle costs • ~£200K-£400K per electric bus.
• Shorter quoted vehicle life.   • ~£2 m per vehicle (costs vary in competitive market)
• Proven long vehicle life (e.g. DLR).
9


Operational costs • Operational road maintenance costs will be high.
• More power needed to deliver service, escalating operational costs.
• Replacement tyres elevate operational costs.
• Autonomous operation not currently deliverable, necessitating drivers and increased staff costs.   • Lower operational costs (eg. lower power requirements, no waste tyres, longer vehicle life, high durability of permanent way).
• Automatic operation currently deliverable, which could reduce need for drivers and staff costs.


Economic benefits • Lower Gross Value Added to economy.
• Lower Benefit to Cost Ratio (BCR).
• Lower efficiency (poor ridership levels).
• Low economic productivity gains (less congestion with
modestly improved public transport links)   • Higher Gross Value Added to economy.
• Higher Benefit to Cost Ratio (BCR).
• Improved efficiency.
• High economic productivity gains (higher modal shift & less congestion with great public transport links)

FINANCEABILITY, DELIVERABILITY

Poor Weak Average

Good Excellent


CONSIDERATION GCP Busways Cambridgeshire Light Rail (CLR) Ref.

Investor confidence
• City Deal finance in place.   • Modern, standardised technologies, inter-operable
• Proven modern technology = low risk.
• Higher investor confidence.
• City Deal finance re-purposed will build investor confidence.


Operational Revenue

• Buses unlikely to attract strong operational revenue.   • Likely higher farebox revenues as light rail will generate greater modal shift than buses.
• Rail greater “trip generative effect” than guided bus.
• Link with bus services at periphery to stimulate those services, not compete with them.
15, 16,
17, 18

3rd Party Revenue Potential
• Lower potential revenue with bus-based brand  
• Higher potential revenue opportunities (vehicle advertising / station naming rights) from higher quality image.

Land Value Capture
• Appeal poor, so land value uplift poor.  
• Permanence attractive for housebuilders, investors and buyers.
11, 19


Legal Approvals
• Approvals straightforward in principle.
• In practice, strong community opposition and Public Inquiry challenges are likely.   • Light rail network deliverable via standard, well established Transport & Works Act Order procedures.
• Tunnel operation straightforward in terms of legal / safety approvals as already proven (e.g. DLR).
• Strong community support likely.



Deliverability • Proven technology.
• Practicality of non-segregated way in city not clear – bus congestion.
• Greater power needs raise questions about power supply availability and upgrades to support frequent electric bus services (assumes all buses are powered by rechargeable electric batteries).
• Deliverable within available City Deal finance.

 • Proven technology; many recent precedents; clear process for consents; proven passenger attraction; etc.
• Power supply upgrades may be needed.
• More attractive to investors because of proven record with highly positive public reputation.
• Raising finance still challenging, but City Deal could fund a significant proportion, leaving ~£1 bn to raise.

OVERALL SUMMARY     
CONSIDERATION GCP Busways Cambridgeshire Light Rail (CLR)



Network • Where fully segregated, flexibility similar to light rail.
• Where not segregated, buses in congestion, impacting speed / reliability / reputation
• Busway to Waterbeach not needed – use heavy rail connected to light rail within city.
• Slow and congested within city. 
  • Fully segregated – reliable, fast, minimal collision risk.
• Network to Cambourne / Granta Park / Science Park similar.
• Higher ability to generate modal shift (proven).
• 40 km core network covers high demand areas.
• Interchange with buses: integrated ticketing / timetabling.
• Fast, frequent service connects with buses & heavy rail network.

Rubber vs Rails • Standard diesel / hybrid bus; in time battery electric
• Rubber- tyres produced from oil.
• Buses = tyre / road pollution. Poor in tunnel.
• Buses at metro frequency = potholes.   • Standard technology, proven, highly sophisticated.
• Billions invested in Light Rail Vehicle development.
• Rails address road pothole problems. Excellent in tunnel.
• Rails inflexible, but permanent, encourages investment.

Tunnels • No tunnel currently proposed. Cheaper.
• Surface running – potential congestion.
• City access more difficult if roads closed without a good
alternative.   • Short, simple tunnel (2 portals) to meet essential needs.
• Automatic light rail proven deliverable for tunnel operations.
• Tunnel improves access speed, frequency, reliability, capacity.

Safety • Busway / articulated bus safety lower than light rail.
• Heavy buses at high frequencies impose on cyclists and pedestrians, reducing their safety, especially in city.   • Very safe. Proven over billions of miles.
• Best safety record possible. Segregated way safer in city tunnel.
• Rails add to safety by providing physical guidance.

Environment & Health • Lower energy efficiency = less sustainable.
• Higher particulate pollution from tyres = health risks.
• High volume of waste rubber tyres.
• Higher greenhouse gas emissions over scheme lifetime   • Most energy efficient, less power needed, highly sustainable.
• Lowest possible particulate pollution.
• Superior technical solution for environment / health.
• Lower greenhouse gas emissions over scheme lifetime.

Costs • Lower capex to install segregated roadway.
• Electric buses cheaper.
• Bus lifetimes short – higher materials / carbon / energy.
• Higher opex & high road maintenance costs.   • Higher capex for permanent rails.
• Light Rail Vehicles (LRVs) more expensive.
• LRVs last longer – lower embodied materials / carbon / energy.
• Lower whole-life costs.



Financeability / Economic benefits
• City Deal finance (£500 m) sufficient for several busways.
• Lower investor confidence profile for bus scheme.
• Bus schemes less attractive to investors.
• Gross Value Added lower from bus schemes.
• Lower gains in economic productivity.   • Higher investment needed up front for light rail.
• High investor confidence profile for light rail scheme.
• Proven solution provides investors with confidence.
• Permanent infrastructure provides investor confidence.
• Gross Value Added higher from light rail scheme – more attractive, generates greater associated investment.
• Higher gains in economic productivity.


Delivery Risk • Modal shift poor compared to light rail.
• Bus mode share ~8% - need to shift to 25-30%.
• Insufficient capacity to meet scale of growth / demands of climate change. Not future-proofed.
• Buses unable to deliver change on scale required.   • Strong modal shift, as evidenced in other cities with light rail.
• Proven, dependable, reliable: deliverable today.
• Attractive and able to deliver change at scale required.
• Future-proofed capacity for growth / Climate Change.

References

Ref Source / Evidence / More Info
1 Caen, France: guided bus caused excessive road wear / maintenance costs / frequent disruption – replaced by light rail.
2 MacKay, David J.C. 2009. Sustainable energy – without the hot air. UIT Cambridge Ltd, Cambridge.

3 Amato, F., Flemming R. Cassee, Hugo A.C. Denier van der Gon, Robert Gehrig, Mats Gustafsson, Wolfgang Hafner, Roy M. Harrison, Magdalena Jozwicka, Frank J. Kelly, Teresa Moreno, Andre S.H. Prevot, Martijn Schaap, Jordi Sunyer, Xavier Querol. 2014. Urban air quality: The challenge of traffic non-exhaust emissions.
Journal of Hazardous Materials 275: 31-36.
4 Grigoratos, T. & Martini, G. 2014. Non-exhaust traffic related emissions. Brake and tyre wear PM. Literature review. Joint Research Centre, Institute of Energy
and Transport, European Commission, Luxembourg.
5 Hann, S., Darrah, C., Sherrington, C., Blacklaws, K., Horton, I. & Thompson, A. 2018. Reducing Household Contributions to Marine Plastic Pollution. Report for Friends of the Earth by Eunomia Research & Consulting. FoE and ERC, Bristol.
6 Barlow, T. 2014. Briefing paper on non-exhaust particulate emissions from road transport. Transport Research Laboratory. Client Project Report CPR1976.
7 Amato, F. (Ed) 2018. Non-Exhaust Emissions. An urban air quality problem for public health impact and mitigation measures. Academic Press, Elsevier.
8 Steer 2018. Greater Cambridge Mass Transit Options Assessment Report. Report prepared for the Greater Cambridge Partnership and Cambridgeshire and Peterborough Combined Authority.
9 Steer 2019. Cambridgeshire Autonomous Metro Strategic Outline Business Case. Report prepared for the Greater Cambridge Partnership and Cambridgeshire
and Peterborough Combined Authority.
10 Scott Ith, Transport Director, Salt Lake City Tramway – pers. comm. 2017.
11 TfL 2017. Land Value Capture: https://www.london.gov.uk/sites/default/files/land_value_capture_report_annexes_transport_for_london.pdf

12 European Environment Agency 2019. Specific CO2 emissions per passenger-km and per mode of transport in Europe. https://www.eea.europa.eu/data-and- maps/daviz/specific-co2-emissions-per-passenger-3#tab-chart_1

13 Lawrence et al., 2013 Source apportionment of traffic emissions of particulate matter using tunnel measurements. Atmospheric Environment 77: 548-557.
14 CPIER (Cambridgeshire & Peterborough Independent Economic Review) 2018. Final Report
15 Knowles, R. & Ferbrache, F. 2014. An investigation into the Economic Impacts on Cities of Investment in Light Rail Systems. UKTram, June 2014.
16 APPLRG (All Party Parliamentary Light Rail Group/pteg) 2010. Light Rail & the City Regions inquiry: Final Report February 2010.
17 Steer Davies Gleave / PTEG. 2005. What light rail can do for cities: a review of the evidence. Final Report February 2005.
18 DfT (Department for Transport) 2011. Green light for light rail. Report on light rail by the UK DfT.
19 Suzuki, H., Murakami J., Hong Y-H, & Tamayose B. 2015. Financing Transit-Oriented Development with Land Values. World Bank: Urban Development Series.

Please find comments from National Highways in response to your public consultation.

National Highways (NH) have been engaged with the Greater Cambridge Local Plan (GCLP) team for over a year, collaboratively engaging regarding the effect of the emerging GCLP on the Strategic Road Network (SRN) as the plan develops; and mitigation necessary to deliver the local plan proposals. National Highways has been appointed by the Secretary of State for Transport as a strategic highway company under the provisions of the Infrastructure Act 2015 and is the highway authority, traffic authority and street authority for the Strategic Road Network (SRN). The SRN is a critical national asset and as such we work to ensure that it operates and is managed in the public interest, both in respect of current activities and needs as well as in providing effective stewardship of its long-term operation and integrity.

There are a number of comments NH would like to address as part of the current consultation period, ending 13/12/2021 as detailed at point •First Proposals (preferred options) consultation (Autumn 2021); in the timetable below:

The Local Plan sets out the future land use and planning policies for the Greater Cambridge area
until 2041, establishing the areas for growth and the impact that this growth may have on the area
during this time period. The timeline for the Local Plan is as follows:
• First Conversation Consultation (Winter 2020);
• Publication of initial evidence base findings (Autumn 2020);
• First Proposals (preferred options) consultation (Autumn 2021);
• Draft Plan Consultation (Autumn 2022);
• Proposed Submission Plan Consultation (2023);
• Submission to Secretary of State (2023/2024); and
• Examination and Adoption.


1. The impact that each strategic allocation site would have on the SRN should be established in the Local Plan so that the impacts can be suitably mitigated.
2. The locations of the ‘Cambridge urban area other small allocations and windfall sites’ and ‘South Cambridgeshire other small allocations and windfall sites’ should be established and the level of growth and any impacts on the SRN should be identified so they can be suitably mitigated.
3. The locations for employment should be identified in the Local Plan and the impact that these sites would have on the SRN should be established and mitigated where required.
4. The reason for the discrepancy between housing growth figures in different parts of the Local Plan should be clarified.
5. The development quantum for all potential development site allocations should be clearly stated in the upcoming Local Plan.
6. Modelling or assessments should be undertaken regarding the development sites and their potential effects on the SRN as part of the further development of the Local Plan.
7. The Local Plan should include recommendations for all planned developments to include Transport Assessments taking into consideration the surrounding SRN network. Where there are junctions on the SRN where a significant increase in traffic flows is predicted, full junction capacity assessments should be undertaken taking into account committed developments and relevant future assessment years as per National Highways guidance set out in DfT Circular 02/2013, so that any impacts can
be identified and mitigated as necessary.
8. The inconsistency between the employment rates set out in the Employment Land and Economic Development Evidence Study and those set out in the Greater Cambridge Local Plan: Topic paper 1: Strategy (2021) should be explained.
9. The Infrastructure Delivery Plan should be updated to include any SRN junction mitigation works that are identified as part of the Local Plan junction modelling work.
10. There are a number of inconsistencies between different Local Plan documents with regard to the level of proposed housing and employment growth in Greater Cambridge. Clarification on the correct level of growth in Greater Cambridge should be provided.
11. There is insufficient information provided on the SRN to allow any conclusions to be made. It is recommended that further information is provided for the SRN links and junctions within the vicinity of the local plan area so that the base (and, hence the impact) of the proposed Local Plan can be fully understood.
12. SATURN modelling plots or outputs should be provided to National Highways for all SRN junctions in the vicinity of the Local Plan area, demonstrating likely changes in vehicle flows, volume over capacity ratio (V/C) changes and delays so that the locations where impacts are likely to be seen can be identified (and subsequently detailed junction modelling undertaken and impacts mitigated as necessary).


The Transport Evidence Report (TER) has been reviewed separately and NH provides their summary below:

Material concerns
1. There is a lack of evidence given in the TER to demonstrate the impact of the Local Plan proposals on the SRN. It is not possible for NH to understand the impacts of the performance of the SRN or its junctions compared to a typical 2041 baseline without the Local Plan.
2. Modelling has assumed that the M11 has been subject to material capacity enhancements between J8 and J14 (Girton interchange) as part of the Local Plan modelling. The detail of the enhancements assumed is unclear, but there are no M11 improvement schemes in RIS2, nor are there any significant schemes in the RIS3 pipeline.
It is likely the modelling overstates the capacity of the M11 and its junctions, which will understate the impact of the Local Plan development proposals and show an optimistic view of the SRN performance.

Moderate concerns
3. Details of the future network do not show the A14 Cambridge to Huntingdon Improvement Scheme. This scheme would not be included in either the 2015 (CSRM2 E-series) or 2019 (CSRM2 Fseries) Base Year models and so should be included in the forecasts. It is expected that this is an omission in terms of the documentation. However, this should be clarified as failure to have included the scheme would be a major concern.
4. It is noted that the report states the CSRM2 series Base Year models are compliant with DfT’s Transport Analysis Guidance (TAG).
However, no evidence of this is supplied and there is no understanding of the level of validation of the SRN in the Base Year. Clarification on the performance of the SRN in the Base Year should be sought to understand the level of uncertainty prior to the forecasts being developed.
5. The TER is lacking in detail on the methodology for developing the forecast year demand. Whilst it is not anticipated that the Local Plan growth will be constrained, it is unclear how the 2041 Baseline aligns to NTEM and if the assumed level of growth is appropriate. Information on the housing trajectories and employment levels
assumed should be supplied alongside this. The Uncertainty Log should be provided to support the 2041 Baseline assumptions.
6. There is no detail on how the internalisation of jobs assumed within the Greater Cambridge Local Plan modelling compares to internalisation levels achieved elsewhere (either best practice, or elsewhere in the local area). On this basis it is not possible to gauge whether the levels assumed are appropriate or if an optimistic assumption has been taken. Clarification on the levels of internalisation assumed and how this applied to real-world outturn should be supplied.

Minor concerns
7. The extent to which the supply and demand assumptions were reviewed between the Options assessment and the Preferred Options testing is unclear. Guidance from the DfT (TAG) will have changed in this period, as – potentially – will scheme details/assumptions from both national and local promoters.
8. Within the Preferred Option reporting, comparisons to a 2015 base are made despite the text noting the model has been updated to a 2019 base year. Likewise, no evidence of the level of validation achieved for this updated model and how this is aligned to TAG guidance has been presented. Clarification on the comparisons should be provided as well as evidence on the level of validation achieved.

National Highways look forward to further engagement on the proposals, in relation to the comments made herein.

I have read the proposed local plan and welcome such aspects as tree planting in city centres and improved rail links. I do however wish to express reservations about other aspects of the proposed policies.

Ox Cam Arc

Creating good low carbon public transport links between important centres is good but this should be done in such a way that the natural environment and local ecology is impacted as little as possible. To upgrade this infrastructure into corridor developments for retail, commercial activity and housing will impact negatively upon the environment and will create 'soul-less dormitories' for resident workers; the only winners being developers and not local people. Natural environment cannot be 'enhanced' and it can only be replaced by an unnatural human-made environment, even if that new environment has some green credentials.

Water Pollution

My concerns are those eloquently expressed by the group 'Friends of the River Cam'.

Development in the East

The County Council's Highways Committee recently resolved that the levels of traffic on Cambridge's Mill Road are such that in the interest of health and protection from serious accident, its traffic volumes need to be controlled by creating a 'separate' albeit 'integrated' policy for Mill Road. This should be noted in the policy on development to the East of Cambridge.