S/NS: Existing new settlements

Support the expansion of existing new settlements and provision of better public transport provision/ to deliver their role as local transport hubs.

Provided there are good public transport infrastructure, schools and Gps etc, these are better than spread out development.

We agree with the proposals.

Improve the carbon footprint for houses already in the pipeline at Northstowe (and other areas where existing planned development will be sped up by this new Local Plan)

No objection is raised to the continued development at the existing new towns. In particular it is considered that the Waterbeach new town offers excellent opportunities for linked trips to the existing settlement and further growth should be located here to ensure the long-term vitality of the settlement continues.

No objection is raised to the continued development at the existing new towns. In particular it is considered that the Waterbeach new town offers excellent opportunities for linked trips to the existing settlement and further growth should be located here to ensure the long-term vitality of the settlement continues.

Policy S/NS proposes accelerated delivery at Waterbeach and Northstowe. At Northstowe, supporting documents identify that this will be as a result of using modern methods of construction. Huntingdonshire District Council concur that off-site modular construction can assist in accelerating delivery on sites. The Council would like to ensure that faster delivery on sites does not impact on infrastructure provision and services in the surrounding areas, this would include access to GP surgeries, transport networks etc and recreational pressure on green infrastructure e.g. Fen Drayton Lakes.

Careful consideration should also be given to the impact that faster delivery could have on market absorption rates and tenure diversity to justify that this is achievable.

Waterbeach requires major enhancements to the A10.

As the Cambridge Metro no longer an option, a lot of thought on how to get from A14 A10 junction to Waterbeach and to Cambridge needs multiple plans to meet a number of scenarios as currently, we don't know what transport corridor if any will be there.

This is a sensible approach given the overarching context.

If it is anticipated that existing new settlements are built out more quickly than anticipated in the 2018 Local Plan then it will be essential to ensure that supporting infrastructure and services including transport infrastructure are also put in place at a commensurately accelerated rate. The particular issues with public and active travel transport infrastructure to/from Waterbeach New Town must be given proper consideration. Trip budgets will need to be revised.

If any changes are made to policies relating to Waterbeach NT they must properly consider the Waterbeach Neighbourhood Plan (expected to go to referendum in the next few months).

DB Group (Holdings) Ltd does not object to the existing allocation of Bourn Airfield (SS/7) being carried forward from the 2018 South Cambridgeshire Local Plan. However, as set out in previous representations, the development of Bourn Airfield needs to come forward in a way that is compatible with their existing industrial use of their site at Wellington Way, Bourn.
DB Group operate in Bourn and their site is in close proximity to the Bourn Airfield New Village. The following operations and processes are undertaken on site:
- Sand grading – filtering sand to provide different levels of fineness;
- Production of additives used in concrete mixes – blending of powders from silo storage;
-Warehousing – receipt and dispatch of goods either manufactured or purchased off site for resale.
The blending and grading processes undertaken on site generates external noise, particularly in respect of the extraction system used to capture and recycle dust particles from the manufacturing processes to maintain air quality. The site is also serviced by an average of 2 incoming and 3 outgoing HGV movements a day.
The company currently employs 21 full time staff on site with a further 40 being primarily field based and visiting the site approximately once a week.
DB Group are currently exploring a number of expansion opportunities. One of these is a volumetric truck operator to supply concrete directly to customers. Activity at their existing site at Bourn associated with this operation would be external and would entail filling the various hoppers on the vehicle. This would require at least one further silo on site and the use of a mechanical loader to take aggregates and sand from external storage bays. These operations have the potential to increase the level of noise generated at the site and would also increase HGV movements.
A further opportunity exists in the production, cutting and finishing of precast concrete products. This would require concrete mixing equipment, supplied from bagged and/ or additional bulk silo stocks, as well as the use of stone-cutting saws.
In light of the above, it is essential that the proposed Bourn Airfield New Village takes full account of DB Group’s existing operations and will not hamper future expansion plans. This will require particular consideration being given to adequate distance separation from noise sources, site and building layout / orientation, provision of acoustic barriers as deemed necessary as a result of detailed assessments, particularly with regard to noise and air quality.
This accords with the Planning Practice Guidance (PPG) which states:
“How can the risk of conflict between new development and existing businesses or facilities be addressed?
Development proposed in the vicinity of existing businesses, community facilities or other activities may need to put suitable mitigation measures in place to avoid those activities having a significant adverse effect on residents or users of the proposed scheme.
In these circumstances the applicant (or ‘agent of change’) will need to clearly identify the effects of existing businesses that may cause a nuisance (including noise, but also dust, odours, vibration and other sources of pollution) and the likelihood that they could have a significant adverse effect on new residents/users. In doing so, the agent of change will need to take into account not only the current activities that may cause a nuisance, but also those activities that businesses or other facilities are permitted to carry out, even if they are not occurring at the time of the application being made.
The agent of change will also need to define clearly the mitigation being proposed to address any potential significant adverse effects that are identified. Adopting this approach may not prevent all complaints from the new residents/users about noise or other effects, but can help to achieve a satisfactory living or working environment, and help to mitigate the risk of a statutory nuisance being found if the new development is used as designed (for example, keeping windows closed and using alternative ventilation systems when the noise or other effects are occurring).”
Paragraph: 009 Reference ID: 30-009-20190722
Revision date: 22 07 2019
DB Group have recently received pre-application advice (reference 21/50156/PREAPP) from South Cambridgeshire District Council advising that an extension in hours of operations would be unlikely to be supported as a result of a “detrimental impact on the living conditions of existing neighbouring properties and future occupiers in the New Village development”.
This is constraining DB Group’s expansion plans and calling into question how compatible their continued operation from this site can be with the surrounding uses that are coming forward.

Hallam Land Management (HLM) query whether the evidence is sufficiently robust to support an increase in the number of homes delivered at Northstowe and Waterbeach New Town to 2041. In the absence of seeing the evidence to justify completion rates averaging 300 dwellings per annum, it is not possible to comment further.

No comments

This emerging policy will confirm that the three new settlements of Northstowe, the new town north of Waterbeach, and Bourn Airfield new village, will continue to be developed during the period of the new Local Plan and beyond.
We note that the consultation document states that there is evidence which means “it is reasonable to assume that annual delivery rates at Northstowe and Waterbeach will be higher than so far relied on, meaning that more of the planned homes will be completed in the plan period, with less to follow after 2041”.
The evidence base supporting this approach is stated to lie within the Development Strategy Topic Paper. On reviewing the relevant section relating to emerging Policy S/NS: Existing new settlements, it is stated that the Authority “have not completed evidence focused on this topic”. Therefore, we are very concerned that there is no clear justification for the assumption that these new settlements will deliver more homes within the plan period.
In the ‘delivery of development’ section relating to the new settlement policy, it is states that the new settlement sites are:
• “anticipated to start delivering additional dwellings a year from 2026/2027 after adoption of the new Local Plan and current five year supply period (2021- 2026), with build out rates based on Housing Delivery Study assumptions for new settlements of maximum of 300 dwellings a year, therefore additional 50 dwellings a year to the 250 dwellings a year already including in the Greater Cambridge Housing Trajectory (April 2021)
• additional 750 dwellings anticipated in 2020-2041 for each of Northstowe and Waterbeach New Town”.
The above does not provide any reasoning for the basis behind these assumptions. For example, it is not clear if these delivery rates have been suggested by the new settlement’s promoters or if they have been assumed by the local planning authority.
Moreover, it is noted that even with the ‘higher delivery rates’ the new settlements will not be contributing to the area’s housing land supply within the first five years of the plan period.
Published evidence from Nathaniel Lichfield & Partners (Start to Finish, November 2016) outlines that the determination period of an application of 500+ dwellings (i.e. a new settlement) is circa 5.3 to 6.9 years. For the most part, this time period is due to complex planning issues. When an application is determined quicker than average, this is a result of matters being substantially addressed prior to submission which, when combined with the determination period, still adds up to the same amount of time; as the report states “there is rarely a way to short-circuit planning”. For new standing settlements, this is likely to be significantly longer given the greater difficulty in identifying and planning, then servicing and accessing such sites. This means the best way to plan for strategic sites is to do so well in advance. Whilst we do agree that the Greater Cambridge Plan should be planning for new settlements, what this evidence does demonstrate, is that in the short term, there is often a need for an Authority to place a greater reliance on small and medium sized sites, which can deliver homes in fewer than five years.
Delivering more new homes as soon as possible is especially pertinent in the Greater Cambridge area especially given the current issues with higher house prices and trends of in-commuting due to the number of jobs outstripping local housing supply.
The land east of Cambridge Road, Sawston SHLAA Ref: 531, and land east of Haverhill Road, Stapleford SHLAA Ref: 530 are both examples of sites that are capable of accommodating housing developments within the first five years of the plan. Therefore, in the absence of the clear evidence to justify why the new settlement sites should be attributed higher numbers of homes throughout the plan period, we believe the Local Plan should be allocating more homes to come forward within the initial five year period.

The consultation document proposes that the three new settlements of Northstowe, Waterbeach New Town and Bourn Airfield New Village will continue to be developed during the new Local Plan Period and beyond.

The policy approach assumes that the annual delivery rates at Northstowe and Waterbeach will be higher than so far relied on, meaning that more of the homes will be completed during the period to 2041.

We object to this assumption, as there are significant questions over the timings of the infrastructure required at both Waterbeach and Bourn Airfield. Where triggers are in place, requiring off-site highway, transport and infrastructure works before a certain threshold of development can be passed, we consider that this poses a genuine risk to delivery.

A realistic review of the timeframes for development and impacts on the trajectory is required.

Northstowe AAP is now 14 years old. Is the Local plan an opportunity to replace any out of date policies?

These settlements need to deliver the same role as identified for Cambourne
• Well-connected place through high quality public transport, cycling and walking facilities
• South Cambridgeshire town for the 21st century
• growing employment centre to provide local opportunities for its residents and nearby communities
• place that meets the day to day needs of its residents.
Therefore the policy needs to include
• Safeguarding of employment and services and facilities within the settlement and to prevent gradual loss of sites to residential.
• Supporting text/policy could set a modal shift from private cars to public transport, walking and cycling.
• The design concept of walkable and cyclable neighbourhoods.

It is unclear what evidence is being relied upon to inform the view that annual delivery rates at Northstowe and Waterbeach can accelerate over the plan period (in comparison with historic rates and lead-in times)

No evidence has been put forward to detail how delivery will be sped up on existing new settlements. What specific, reliable and deliverable mechanisms will be used to ensure that this strategy will come to fruition?
Furthermore, we question if the necessary infrastructure for these sites will be delivered at the same pace?

The new plan will set out significant requirements for Green Infrastructure, Biodiversity Net Gain and environmental design, which need to be reflected in the requirements placed on those elements of existing allocations which have yet not received planning permission. For example, the need for Northstowe to potentially support GI infrastructure in the Great Ouse Fenland Arc.

The draft policy assumes that annual delivery rates at Northstowe and Waterbeach will be higher than so far relied on; however, we question whether the required infrastructure is able to keep pace with these increased delivery rates especially as there is a trip budget at Waterbeach.

Once these thresholds are met, it is highly likely that the dualling of the A10 will be required to unlock further development. At present there is no certainty over build programme. Similar concerns exist in terms of wastewater infrastructure delivery and the relocation of Milton Sewage Works.

Cambourne Town Council understands the need for this policy, but would comment that Bourn Airfield transport links/ hub should be considered in line with Cambourne and West Cambourne.

It is unclear to what extent any technical work has been undertaken to demonstrate that intensified rates of development at Northstowe and Waterbeach New Town each for an additional 750 homes in the plan period is achievable.

Contingency sites should therefore be included at this early stage in the plan process to ensure the plan is effective (deliverable over the plan period) as required by the NPPF (2021).

It is unclear to what extent any technical work has been undertaken to demonstrate that intensified rates of development at Northstowe and Waterbeach New Town each for an additional 750 homes in the plan period is achievable.

Contingency sites should therefore be included at this early stage in the plan process to ensure the plan is effective (deliverable over the plan period) as required by the NPPF (2021).

We support the intention to carry forward the existing allocations for the new settlements allocated in the South Cambridgeshire Local Plan (2018) which will continue to form an important source of supply in the Greater Cambridge Local Plan. We note that a map of the boundaries of the allocations is provided at the end of the consultation document. For clarity we consider the proposed policy maps should include both the Strategic Site Boundary and the Major Development Site Boundary.
Of the three new settlement sites, Bourn Airfield is the only one not proposed to have amended annual delivery rates. Countryside consider that the annual rates for Bourn Airfield have the potential to be higher than previously stated due to the mix of tenures which has been agreed within the outline. Providing a broad mix of tenures across the sites will allow the delivery of a wide range of housing products which can be delivered without competing with each other.
It is considered that the Bourn Airfield new village has the potential to deliver the following housing trajectory: 2021/2022 – 0, 2022/2023 – 0, 2023/2024 – 35, 2024/2025 – 160, 2025/2026 – 190, with 190 housing completions per annum thereafter.

Existing New settlements
26. CPRE objects strongly to Policy S/CB: Cambourne and the proposed further expansion of Cambourne West.
This is an object lesson in how urban sprawl occurs when there are no insurmountable natural barriers to
stop it. Cambourne was designed as a discrete ‘village’ development to take up overflow from Cambridge
in order that the City’s character could be retained. This policy will take up further productive farm land
and will lead to a never-ending cycle of demand for additional development. Our concern is that in the
longer term, the extension of Cambourne and proposed and current developments around St Neots
towards Bedford along the A428/A421 main route will generate further pressure for development until
Cambridge is joined to Bedford in one long urban sprawl.
27. CPRE understands Policy S/NS to carry forward the existing allocations for new settlements Northstowe,
Waterbeach and Bourn Airfield. However, CPRE is very concerned indeed by the poor building control, lack
of democratic control of detailed planning decisions, the damage to underground water bodies, increasing
flood risk, lack of engagement with local communities and lack of engagement with local expert and
statutory bodies such as the local Internal Drainage Boards which is occurring as development proceeds at
two of these sites, Northstowe and Waterbeach. This approach to planning is going to lead to disaster for
the planning authorities, for residents and for the custodians of the water resources. Before, any further
permissions are given within these allocations, CPRE considers it absolutely essential that these issues are
addressed and any problems resolved.

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.

Compendium of Environment Agency Comments

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Transport links and possible increased densities in areas with access to those transport hubs - this could creep out into the Dry Drayton borders.

RE WATERBEACH PARISH COUNCIL – RESPONSE TO LOCAL PLAN – GREATER CAMBS PLANNING

Waterbeach Parish Council would like to make the following comments to the Greater Cambridge draft plan consultation concluding on Monday 13th December 2021

The Greater Cambridge draft plan states the following proposals for the acceleration of delivery of Waterbeach New Town as detailed below:


https://maps.3csharedservices.org/portal/apps/webappviewer/index.html?id=a6742a84b6 aa418f8b1e41315c2b8845

Preferred Options Sites - August 2021

Broad location New settlements
Preferred Option reference S/NS/SS/6
Site Waterbeach New Town
Use Mixed Use
New or existing allocation Existing
Housing delivery 2020-41, counted as current pipeline (adopted allocations, existing permissions and windfall allowance) 4,580
Housing delivery 2020-41, counted as increased delivery rates/densification on existing allocations 750
Housing delivery 2020-41, counted as proposed new site allocations -
Housing delivery post-2041 5,670
Housing delivery Full Build Out (2020 onwards) 11,000
Employment use classes E(g)
Area (ha) 427.49

Although Policy SS/6 Waterbeach New Town (WNT) in the SCDC 2018 adopted local plan for approx. 8,000 – 9,000 dwellings.
Nevertheless, planning approval (S/0559/17/OL) granted to the MOD & Urban & Civic for WNT (West) for 6,500 dwellings. Planning approval (S/2075/18/OL) “currently awaiting decision” RLWE Waterbeach (East) for 4,500 dwelling making a total of 11,000 dwellings plus associated buildings and infrastructure.
Policy SS/6 South Cambs District Council (SCDC) 2018 adopted local plan Page 7 1 3.41 states: A new town will require a significant amount of new infrastructure, including schools, shops, services and facilities to meet the needs of the town. It is important that the services, facilities, landscape and infrastructure needed by this development are not only provided to a high quality, but that they are properly and effectively implemented, managed and maintained if they are to meet the needs of the community as they arise and in the long term.
3.42 A fundamental requirement for this site is that it will be highly accessible and permeable to all its residents on foot, by cycle and public transport, to support sustainable transport, recreation and health. The site offers particular opportunities to deliver public transport improvements, including the relocation of Waterbeach railway station to a location where it will also be convenient for people living in Waterbeach village making rail travel highly attractive. Segregated provision for buses both within the town and to link the new town to the public transport network in Cambridge will be required and similarly for cycle use. This will provide for quicker journeys, encourage maximum use by residents of the new town and improve safety. The existing A10 is at capacity and road improvements will be required, including measures to address capacity at the Milton junction with the A14
WPC seek to know if policy SS/6 in the SCDC adopted local plan will be carried forward into the new local plan.
South Cambridgeshire Adopted Local Plan 2018 (scambs.gov.uk)

The Waterbeach SPD adopted by SCDC in February 2019 provides strategies as to how the New Town will progress including required infrastructure and responsibilities of developers and utility providers. S106 agreements have been formalised between SCDC and MOD/Urban & Civic. S106 agreements between SCDC and RLWE now at the draft stage. But the parish council have still not had opportunity to comment.
WPC note that in the GC draft local plan states
“The Supplementary Planning Documents for Land north of Waterbeach will be carried forward.”
SCDC adopted local plan Policy SS/6 - page 70 para 17 states:
Supplementary Planning Document: The SPD to be prepared for the Strategic Site shown on the Policies Map will provide further guidance and detail on the implementation of Policy SS/6. The SPD will include: a) An overarching, high level vision for the new town. b) Consideration of relevant context including key constraints and opportunities. C) The broad location of the components of the new town which are essential to support comprehensive and seamless development. A spatial framework diagram will be included that ensures the creation of a sustainable, legible and distinctive new settlement. d) The location, nature and extent of any formal open space to be provided outside of the Major Development Site. E. Broadly how the development is to be phased, including the delivery of key infrastructure https://www.scambs.gov.uk/media/13057/waterbeach-new-town-spd-low-res-feb-2019.pdf WPC would like to highlight the following identified issues as barriers to growth in the current adopted and emerging local plans that will need overcoming in a timely and fully funded manner, at least cost and disruption to the residents of Waterbeach parish and neighbouring villages.
1. Provision of Water
Cambridge City and South Cambridgeshire already have an unsustainable supply of potable water. In August 2020, the Environment Agency, in response to a query on the viability of water supply to Northstowe Phase 3A wrote to a resident that 'current levels of abstraction are causing environmental damage.
Any increase in use within existing licenced volumes will increase the pressure on a system that is already failing environmental targets', and 'many waterbodies did not have the flow to support the ecology.' This is the situation for proposed growth for South Cambs and Cambridge City
On 1st July 2021, DEFRA announced that chalk streams would be given enhanced environmental protection,and published the Environment Agency document titled “Water stressed areas – final classification 2021” which included the fact that the supply areas of Cambridge Water and Anglian Water are areas of serious water stress, page 6. According to Appendix 3, Cambridge Water needs to reduce abstraction by 22 megalitres per day from levels current as at 1st July 2021, and Anglian Water needs to reduce abstraction by 189 megalitres per day from levels current at 1st July 2021.
Water Resources East is the body responsible to produce a plan for the provision of water to enable proposed growth in the Greater Cambridge area. At present there are no plans or costings or infrastructure in place. Until there is the provision of a sustainable water supply the proposed growth in the current and future local plan development may be unsustainable.
2. Sewage
Anglian Water (AW) currently have capacity at the Milton Waste Water Treatment Works (WWTWs) for the provision of sewage until 2050. AW have proposals to relocate the WWWTs to Honey Hill on Cambridge Green Belt land. Anglian Water granted £227m HIF by the government to fund the move however it is unclear if the grant will fully fund the project or

when if approved confirmation when the new works will be operational. AW are dependent that a DCO will be issued by the Planning Inspectorate.
Although there will be a need for a pumping station and pipelines the level of detail in the “Waterbeach Zone in AW’s recent scoping report which mentions haul roads, construction plans and other material planning considerations has not yet been disclosed or taken to public consultation. The Waterbeach Zone will have a significant impact on the people of Waterbeach parish, landscape, environment, Green Belt and biodiversity and should be given due weight and consideration in the draft local plan.
The Waterbeach Zone is a huge proposition the outcome of which will be arrived at by the provider AW and developers of Waterbeach New Town and a reliance that will be brought forward in a timely manner as stated in the SPD:
Page 130-131 “Provision will be dealt with through direct agreement with service providers as development is implemented. This will be outside the scope of any planning control or S106 agreement. Service providers are obligated to meet any demand arising from the development (11,000 dwellings, associated buildings, schools, businesses, hotels) with the site promoter providing the cost.”
It is unclear if part or whole of the required infrastructure for the Waterbeach Zone will be funded by the developers of WNT or by the £227m HIF government granted to AW for the relocation of the Milton WWTWs
It should be noted that there are already issues of contamination from sewage when there is heavy rainfall and already the need for many daily tanker movements from the Waterbeach WWTP. WNT build out must be limited until a new Waterbeach pumping station is commissioned and operational.
Planning Process – Cambridge Waste Water Treatment Plant Relocation Project (cwwtpr.com)
3. Electricity
WPC are aware that currently the provision of electricity is a barrier to growth. The Greater Cambridge Partnership (GCP) has undertaken to fund electricity grid reinforcements. Will that provision be in place and funds available ensure delivery to enable the proposed accelerated growth of WNT?
GCP takes ground-breaking approach to secure future of electricity network - Greater Cambridge Partnership
4. Transport Infrastructure
Transport plans submitted by Urban & Civic and RLWE were described as “substantially underfunded” by Sharon Brown SCDC Director of Delivery at the Extraordinary Planning Meeting for Waterbeach New Town East held on 29th January 2021 as evidenced in the broadcast here: Agenda for Planning Committee on Friday, 29 January 2021, 11.00 a.m. (moderngov.co.uk)
The proposals for the required sustainable transport infrastructure for WNT are currently of a piecemeal nature. The responsibility for delivery, cost and funding is currently unknown. The Greater Cambridge Partnership (GCP) is the responsible body for the delivery of the Waterbeach segregated busway and greenway. The Combined Authority (CA) is the responsible body for the dualling of the A10 or upgrade of junctions. Developers and SCDC through S106 developer contributions and planning obligations are responsible for cycleways and park and ride sites. Developers RLWE have been granted planning permission to relocate the existing Waterbeach station to the North of the village after they promised to fund the provision of the station. It is currently unclear if funding is available for the relocation of the station by RLWE. It is also unclear when the relocated station will be operational. The delivery of WNT was claimed to be dependent on the developer funded relocated railway station as a sustainable mode of travel.

5. The delivery of infrastructure controlled by triggers as per the number of dwellings coming forward
A faster build out rate will require a faster provision of the required infrastructure as detailed in the granted planning permissions, Policy SS/6 in the adopted 2018 Local Plan and the adopted Waterbeach SPD
6. Neighbourhood Plan
WPC wish to bring to GC planning’s attention that the Waterbeach Neighbourhood Plan is at an advanced stage of completion. The plan has been through examination by the Inspector and passed inspection. WPC are working with SCDC to finalise the plan which will then go to referendum. If parishioners vote in favour the plan will be “made sound.” The plan has stand alone SEA, Heritage and Character Assessment and Design Principles documents which can be considered as material planning considerations that support the plan. WPC request that the Neighbourhood plan and supporting documents are a consideration as development comes forward in the parish.
7. Cambridge Green Belt and green spaces
The Cambridge Green Belt wraps around the parish to the South, West and East. WPC request that the Green Belt land remains protected from windfall/rural exception site development to enable a green transition from the Eastern edge of the village towards the River Cam and access to the fenland countryside and public rights of way.
WPC note the proposals for greenspace and river corridors from the City to Wicken Fen, Anglesey Abbey and beyond. WPC note the proposed high density proposed for the Cambridge North Eastern Fringe development and question if this is to compensate for the lack of open green space per capita on the development site.
WPC seek reassurance that the proposed draft plan will not increase the density of WNT and other settlements currently in the adopted 2018 SCDC local plan by using the Cambridge Green Belt, fenland, farmland, river Cam corridor and waterways as open green space to compensate for the lack of green space within high density settlements.
WPC enquire how net gain offsetting will be proven and enforced due to the proposed accelerated growth of WNT?
8. Climate change and flooding
WPC feel it is Important that future risk of flooding is not increase due to accelerated growth from WNT through fluvial or surface water flooding as shown on the Environment Agency maps Fluvial risk enlarge map to include WNT:
https://flood-map-for-planning.service.gov.uk/confirm- location?easting=550093&northing=265821&placeOrPostcode=CB25%209JT
Surface water risk enlarge map to include WNT: https://www.cambridge.gov.uk/media/2568/strategic-flood-risk-assessment-appendix-b-part- 4.pdf
Climate Change -Central predicted risk of flooding due to sea level rise caused by climate change could occur as soon as 2030. How will this be a consideration and mitigated to compensate for an accelerated build out rate of WNT? https://coastal.climatecentral.org/map/12/0.2105/52.2889/?theme=sea_level_rise&map_typ e=year&basemap=roadmap&contiguous=true&elevation_model=best_available&forecast_yea r=2030&pathway=ssp3rcp70&percentile=p50&refresh=true&return_level=return_level_1&rl_ model=gtsr&slr_model=ipcc_2021_med
WPC seek to know if the proposed accelerated growth will affect GC zero carbon targets and how will it affect the GC aspirations in the draft local plan?

In summary:
The proposed acceleration of WNT is dependent on the required essential services including health and education, transport infrastructure delivered in a strategic, timely and fully funded manner.
It is important that there is a joined up strategic transport plan to provide sustainable, affordable, accessible and a reliable transport system to replace the fragmented system presently in existence.
It is important that the Waterbeach Neighbourhood Plan and supporting documents included and given due weight and consideration within the draft local plan.
The Cambridge Green Belt abuts Waterbeach parish, green open space and river Cam corridor. It is extremely important that areas designated as SSSI’s, RAMSAR, SAC and other recognised protected areas should be enhanced and not a means to compensate for the lack of green space in high density settlements such as the Cambridge North Eastern Fringe development. It is also important to protect the abundant biodiversity and habitat in the parish. WPC request that this matter is treated as a priority if development is accelerated in WNT and the GC area.
How will GC planning ensure net gain offsetting targets in the draft local plan are met due to the accelerated growth of WNT? How will it be monitored and manage to obtain “net gain”
The settlement of WNT and Waterbeach village on the Environment Agency flood maps show them to be vulnerable and prone to flooding from fluvial, surface water and sea level rise. How will residents and important farmland be protected due to the proposed accelerated growth of WNT in the draft GC plan?

Northstowe
We share the strong concerns expressed by residents of Longstanton and others about the impacts of building to date on local water tables. A Hydrogeological Assessment commissioned by Longstanton Parish Council [1] concluded that local land use change as a result of the development of Northstowe is the most significant impact on the local groundwater elevation. Initial construction at Northstowe lowered the water table to such an extent that ponds have dried out. The development has changed the recharge of local groundwater features and it is unclear whether they will recover. We call for no further building at Northstowe until this issue is fully resolved. We also call for tighter enforcement of the environmental standards the developers are required to meet - our local members describe them as currently ‘getting away with the bare minimum’, resulting in a settlement that is far from sustainable.
[1] http://www.longstanton-pc.gov.uk/ UserFiles/Files/Reports/202105HRWallingfordReport3-
reduced.pdf