Habitats Regulation

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Greater Cambridge Local Plan Preferred Options

Representation ID: 58084

Received: 12/12/2021

Respondent: Ms Imogene Blackburn-Horgan

Representation Summary:

New housing beyond Ninewells must not find a rat run through Ninewells to our homes on Greenland's adding to the already extensive drug running and antisocial groups coming into a cul-de-sac of only 32 homes. Ninewells needs to be redirected to CBC and Park and Ride/cycle route needs to go around NW not through Greenlands. Ninewells needs its own cycle route out to main road and to school/work/leisure routes. Footfall of thousands on Greenlands needs to be reduced not increased.

Full text:

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You state "To properly reflect the three strands of sustainable development, we must plan for homes, jobs
and supporting infrastructure (transport, utilities, services and facilities) in the right places, alongside protecting and enhancing the environment."
I live next to CBC it is not a great place to live it does not have the infrastructure for current needs let alone an expansion of the size recommended. I know residents do not feel their wellbeing has been met by the previous 26 years expansion of the CBC/NHS/UH site with ongoing suspicious, antisocial and criminal behaviours entering RedCross Areas from opening up the link on Red Cross Lane to Addenbrooke's and opening up a pavement link to Ninewells through to the cycle route and Park and Ride completely swamping 3 cul-de-sacs of 70 homes 24/7. With no responsibility or accountability of those associated with the CBC it is left to residents to manage the behaviours emerging for the thousands on the site daily coming through 2 of our small cul-de-sacs and behaving in a way that brings their employers into disrepute.
Biodiversity and green spaces have already been cut with the previous 26 years expansion and how building so many more homes, offices, stations without the current infrastructure meeting the current level of need it leaves the lives of those surrounding CBC continuing to be blighted. There are not nurseries, schools, shops, GP's, leisure, library etc. facilities for the current population next to Addenbrooke's this is before a proposal to quadruple the population in the first stage!
Why are we removing further land from the Green Belt (at all, or in this location)?
What about the lack of spare capacity in Cambridge’s water supply?
If the proposed use of this land for employment space, won’t this intensify the imbalance between jobs (too many) and housing (too little)? Rebalancing this is supposed to be one of the big aims of this plan!
What about the flood risk? Not worked flooding on the field (S/CBC/A) and Ninewells flood mitigation is not working?
Creating ‘a new soft edge to the city’? Isn’t this the same thing was said about the Ninewells development during its planning process?
How does a trip budget ‘limited to an appropriate level for the surrounding road network’ work, unless that level is zero, as the road network is already overloaded?
Does the proposal allow for better utilisation of the existing Campus?
Is this an opportunity for better management of the ‘spillover impacts’ on the wider neighbourhood?
Cambridge Biomedical Campus Vision 2021 – 2051 - Partnership with RedCross Areas Vision for Safer Streets Now in 2021
i. CBC VISION 2021 - 2051
The RedCross Areas Residents Association (RARA) welcome the Cambridge Biomedical Campus Vision 2021 - 2051 and developments in terms of job opportunities, research and health care – welcoming the open and collaborative approach outlined in their Vision. With this in mind RARA would like to open a channel of communication to the benefit of all parties. CBC states is a globally important life sciences engine, and has come together to demonstrate its commitment to Cambridge through a new Vision for its campus, renewing its role in the city and beyond. We hope this extends to accountability for the staff and users of the site to ensure the emotional well-being and safety of their near neighbours living in residential communities on all sides surrounding their site.

From 1967 the site has developed alongside the building of homes on the three streets Red Cross Lane, Stansgate Avenue and Greenlands, making up RedCross Areas, and over the last 21 years Addenbrooke’s and the Cambridge Biomedical Campus has expanded exponentially. The history of this has appeared to the outsider as piecemeal at best and as insular at its worst – witnessing the haphazard development of Addenbrooke's site by its immediate neighbours. This approach and model has not kept pace with today's thinking particularly in context of green agendas, sustainability, air quality/pollution/noise and travel/connectivity. The insularity of approach has been particularly felt in a negative way in the local residential community that abuts the site. Until very recently thanks to my work with the NHS CE Team the needs and legitimate aspirations of local people for a safe environment has been compromised by the unchecked growth of Addenbrooke’s, Rosie, papworth Hospitals and the Cambridge Biomedical site.

For example, as attitudes and health issues particularly smoking have changed, Addenbrooke’s NHS response has been short sighted in its interpretations. Because the needs of the local community have not had sufficient consideration and weight accorded them. The unintentional consequences of the Smoking Policy has left in its wake an increase in aggressive and anti social behaviour from staff from the Cambridge Biomedical Campus in residential areas not just RedCross as you are aware from concerns raised by other near neighbours surrounding the Campus with staff and any patients being anti social who are forced off the site to smoke as provision on the campus is not adequate. It has improved since one of our younger residents identified and engaged with the NHS CE Office during 2019 and RARA connected with the NHS and 1 private Contractor in 2020. But it is now with the good weather becoming a cause of concern yet again for those neighbouring the Addenbrooke’s and Biomedical site with examples daily of smokers coming off site to smoke, sitting in private greens/communal drives/drives and sitting on and blocking pavements and road access and leaving their masks, litter and butts in their wake stating “There are not enough sites/seats on the Biomedical site”. RARA does not want to return to recruiting neighbours t put in 500 hours litter picking as they did through 2020 with additional cleans weekly by the NHS and Bell School plus community clean ups with the Council, SOS and community pay back schemes,. In 2021 an additional 500 +hours were put in and when CBC cars could not park when double yellow lines went down February 2021 RARA was able to stand down 8 litter pickers as litter, PPE, butts, fly tipping dropped by 90%. When the CBC staff were coming back onto RedCross Areas in May/June 2021 to illegal trail, idle, park and loiter major clean up operations have had to take place due to PPE, litter, butts and broken bottles affecting the young children who use our streets for their school run.

Cmbridge Biomedical Campus – Impact from your Smoking Policy on your neighbours
2006 -2009 “The first ban on smoking on site ran from 2006 to 2009, but was withdrawn when it was ignored”.
2014 “A smoking ban has been put in place across the Addenbrooke's Hospital site in Cambridge. From the start of 2014, people can no longer smoke anywhere on the site, whether they are inside or outside. It applies to all staff, visitors and patients”
“The Queen Elizabeth and James Paget hospitals in Norfolk also tried going smoke-free, but the ban was largely ignored. In the end, the hospitals built new smoking shelters”.
2015 “More than 11,000 people have been challenged by security staff at the Addenbrooke's site since the smoking ban was introduced just over a year ago. Eleven thousand!!”
2016 “Visitors caught lighting up are advised to put it out and directed to the nearest site boundary by the NHS” - blighting residents and your neighbours lives
The Trust said “about 400 people a month are caught smoking on the site but are “mostly visitors” rather than patients or staff”.
2019 In one week the count of smokers with NHS lanyards smoking in RedCross Areas (Red Cross Lane, Stansgate Avenue, Greenlands) was 400 & In RedCross Areas in 1 year all smokers spoken to have been staff, not just individuals but big groups blighting residents lives and blocking pavements, roads and access, dropping litter, butts. PPE and there have been many unpleasant outbursts to residents from smokers especially on Red Cross Lane resulting in NHS and Police Incident reports
2020 In one week the informal and not total count of smokers with NHS lanyards smoking in RedCross Areas (Red Cross Lane, Stansgate Avenue, Greenlands) was 600, in Greenland’s in one full day they counted 200 (so the weekly total is 600+) even sitting on private greens
(The Trust back in 2016 stated Professor Patrick Maxwell, Regius Professor of Physic, said at a 2016 board meeting “Putting up more signage would make it much easier to get to those people - we could signpost them to places to where they could smoke off site” - In 2016 Dr Mike Knapton, non- executive director, said: “Most of our smokers are visitors not patients, most who are from further away and not aware of the culture of this hospital. If in Year 1 2015 of the No Smoking Policy 11,000 were spoken to for smoking on site back in 2016 it was noted “Particularly a challenge will be in 18 months’ time when the site gets bigger. People will have to walk further to get off the site”)
In 2021 where does this massive number of people go - onto our streets blighting residents lives for over 7 years
2020/21 CE Team started work on issues which was commended by residents and this now needs a long term strategy embedding it in the Cambridge Biomedical Campus Vision
As from 2016 it has not been visitors or patients found to be smoking in RedCross Areas the majority coming into our streets areYOUR staff

The same issues apply to car parking in the local area over the last 11 years, in 2014-16 the Trust RARA is informed made a total of £108,421 from parking charges whilst at he same time residents say anti social behaviours of people parking in RedCross Areas hit an all time high. As pressure on Addenbrooke’s and the Biomedical site has increased, then it has overspilled on local streets bringing with it 24 hour 7 days a week. CBC was fully aware of the pressures in Red Cross Lane as Your Transport Survey (2016) found Red Cross Lane had 165% occupancy of the on street parking with 76-100% being CBC staff (not residents). Tenants past and present informed RARA that they have had groups and other car drivers intimidate and abuse them when trying to park in the street and told in no uncertain terms that the street parking is for the NHS and they need to park on their own drives (ironically many of the tenants are NHS employees themselves and are then put at a disadvantage as they feel unable to demand their colleagues stop these behaviours and do not feel confident to be whistle blowers). This has been confirmed by long term residents of 10 – 60 years and by RARA’s own experience, with Cambridge being a small interconnected community with many of the community and near neighbours working at the CBC at all levels. RARA has had first hand, both factual and anecdotal feedback of both the Residents Association, membership, groups in the community, families and even individuals having unprofessional conduct not just by individuals but also by agents and organisations connected to or part of the CBC demonising any effort by any of these locals to challenge illegal or anti social behaviours. Very disappointing from a Global Partnership with a new Vision “..bringing together its role in Cambridge life … We want to develop CBC in a way that is inclusive rather than exclusive, and contribute to making Cambridge an even better place”.

Historically for 11 years the community has experiences incidents of aggressive and anti social behaviours, culminating in August 2019 as an ACT/Cheffins tenant was so exasperated they reported a local worker parked illegally all day on their drive to the Police and put the information on social media. Damage to Greenlands communal access roads is at a high financial cost to owners 36 cars should be using the roads yet daily up to 100 NHS car idled, turned or even parked no redress scheme has been made to the owners for the financial impact it has had on the Estate. From this 80% of the community over the next 6 months came forward with examples of 10 years of incidents from damaging their garages, gate posts, fences, drives, cars, car tyres, hate crime, antisocial behaviours etc. always a day after asking someone to remove themselves from parking illegally on their drives/blocking their drives or being illegally parked on Greenland’s communal drives. The worst being individuals being driven at by these illegally parked cars when they had phoned the Police to request they move. On many occasions the individual was reported to be at or admitted themselves that they worked at the Hospitals on the Cambridge Biomedical Campus. Even now when on street parking is illegal it is increasing exponentially every week. There was a recent incident where a young woman and her young child were nearly run off their bikes by a person waiting illegally in their car on double yellow lines (not a one off this individual had been parking illegally for 4 weeks running and had previously had had the new yellow lines on other roads explained) they stated they were there to pick up a Hospital staff member and were allowed to park. On this occasion they were asked if they would consider moving which they did, but being so engaged at swearing at the residents the driver did not look where they were driving. This resulted in this young girl being doubly upset as a car was coming toward them with total disregard for their safety whilst a male driver was swearing and making rude hand gestures. The community had to think carefully and decide to cancel organising a Playing Out event for children and families as the car drivers connected with the Cambridge Biomedical Campus are behaving in a way that is not enabling RedCross Areas to have Safer Streets.

CBC 2016 Travel Survey stated “demand for car parking on-site is currently significantly over-capacity …. with over 1,106 cars parked on local streets … and residential areas are seeing increasing levels of tidal traffic during the peak hours” in 2018 CBC Report which said “People travel to CBC from locations across east and south-east England and beyond”. What can be seen in May 2021 is that the Trust is seeing an additional 500 staff park on site every day. As this is not being addressed strategically the staff who do not meet the NHS eligibility parking criteria are now being forced off site. This means more negative impact on RedCross Areas where the Council Parking Enforcement are fighting a valiant daily battle to manage the tidal wave of additional cars coming in to the area to trail and park illegally. There needs to be finance from the CBC for monitoring/enforcement via CCTV, patrols daily 24/7 and enforcement/accountability for those form the CBC blighting the lives of thise that live in RedCross Areas to keep the community and those travelling through safe with a strategic vision for Safer Streets.

In the context of this history of expansion of the CBC site bringing with it problems that were not managed or mitigated for it is imperative that the latest Vision learn the lessons e.g.
If in 2018 CBC knew parking by CBC staff resulted in “Occupancy exceeding capacity on roads south of Mill Road including Red Cross Lane” with “76% - 100% non-residential parking on streets in the immediate vicinity of CBC” and “the streets surrounding CBC are dominated by non-residential parking during the morning and afternoon periods, particularly on Red Cross Lane” with no planning put in place for the 30-40% increase predicted in cars to CBC in 2019. If CBC knew from 2016 about the impacts likely on the local communities and have not been able to mitigate these over the past 5 years how can they be entrusted with a 30 year plan of expansion.

v. What’s Needed-Safer Streets
What’s Needed - Safer Streets, good public transport, more cycling provision, safe walking routes, discourage cars to trail, illegally wait, idle and park by offering adequate parking on site, adequate taxi/Private Hire Vehicle ranks on site, adequate drop off and pick up points on site for staff, visitors and patients, more smoking shelters with seating. Please have routes of accountability for staff not upholding your core values, communication regularly to promote and move car drivers and smokers away from residential areas as Red Cross Lane (would be beneficial to see if other areas are too?) as it is experiencing anti social behaviours yet again from the Biomedical and Addenbrooke’s site encroaching on their homes and safety. Finance is needed from the CBC for signage into the site for parking/drop off/taxis &PHVs, signage on roads abutting the site saying no route through to Biomedical/Addenbrooke’s/Hospitals/no trailing, waiting, idling or parking. Funding from the Biomedical site to enable the residential roads surrounding your site to have consultations/installation of requested no loading, bollards, signage, modal filters, safe cycle routes, pavements pedestrians/disabled/wheelchairs/pushchairs can use - not blocked by staff groups to embed your Vision with an Active Travel Route that does not disadvantage your neighbours with noise, pollution, littering/fly tipping, illegal idling/waiting and parking including pavement parking nd trailing cars disadvantaging the disabled/families with buggies, antisocial and behaviours that do not comply with the Governments Safer Streets.

With plans will inevitably come pressures on the local area and environment particularly in relation to transport. Potentially many thousands of extra staff on top of the 21,000 2020 and additional 5000 2021 (envisaged by CBC in 2019 to reach 41,387 on an average weekday this year 2021 before any expansion) presently will be travelling through RedCross streets to reach the CBC site. Traditionally this has been primarily by car and in 2018 your own Biomedical Campus Transport Review Part 1 and 2 report noted a 30-40% increase in car use from the CBC expansion primarily happening in 2019 and no provision was made by the CBC for this and no assistance was allocated or given to communities such as RedCross Areas that suffered significantly due to this. The current expansions have put pressure on the Biomedical / Addenbrooke’s site and historically the solutions have been for staff to flood the local residential streets in search of free, convenient parking 24 hours a day. This has resulted in anti social behaviour and dangerous driving including trailing, waiting, idling, parking on pavements blocking disabled/school run access, parking on people’s drives, blocking residents access, driving at speed, reversing, blocking junctions and parking illegally, blocking access for emergency vehicles. A person attending Addenbrooke’s recently parked illegally for half a day and was requested by the Police to move his car, when asked why he parked illegally he cited he did not wish to pay for parking on the Biomedical / Addenbrooke’s site, then became abusive to a female. Just a few weeks ago a pavement parked car had to be asked to move on Greenland’s as an ambulance was due and would not have been able to access the property of the elderly resident.

To avoid a repeat of this your Vision must take account of historical mistakes which have caused Police Incidents, illegal actions, verbal abuse, anti social behaviours and much upset among local residents over an extended period and take account of RedCross Areas being a main thoroughfare for your staff, visitors and patients. CBC report (2018) “With new developments, the demand for parking is likely to increase. Red Cross Lane – has reached 165% occupancy. So there is likely to be a deficit in the intervening period depending on the phasing of site development until 2025”. This is a projection prior to current and future 30 year Vision for further expansion. Plus in 2018 CBC identified “Both car and cycling parking levels are currently over capacity” and what has been actioned on CBC site to address this over the past 3 years as demand has grown.

A multi agency approach is required including for example local Councillors, Community Groups, local Cycling Campaigns, local Neighbourhood Watch and Residents Associations, local residents including tenants (who traditionally have informed groups they feel insecure in their contracts and tenancies so do not feel able to raise their own issues), the Local Authority, Police, national groups with relevant expertise to name just a few as you knew in 2018 that “the likely future pinch points would continue to be Addenbrooke’s Road and Babraham Road” both of which surround RedCross Areas to take forward CBC findings of 2016 and 2018 that RedCross Areas needs “On-street parking controls”. CCTV seems the only solution as staff ignore the double yellow lines.

Poor communication that does not effectively take all parties concerns into account leads to poor planing outcomes with unintended consequences that disproportionately negatively impact on local people.

viii. RedCross Areas needs an SAE

S Safer Streets- Funding from CBC for CCTV and fund more Parking Enforcement Patrols for 24/7 monitoring/better night time lighting for nurses/night shift workers/signage to site/signage encouraging traffic away from RedCross Areas and remove loitering, littering, fly tipping and illegally waiting, idling, pavement and on street parking from RedCross Areas streets

A Accountability– Cambridge Biomedical Campus Companies taking responsibility for CCTV/ Parking Patrols/Funding - informing and managing their staff, patients, visitors, taxis, private hire vehicles with an aim to stopping illegal, anti-social, aggressive, bullying behaviours  that impact adversely on health to the communities neighbouring your site

E Enforcement– CBC leading Enforcement not the community reporting illegal & anti-social actions. Routes to report/Policies/Procedures enforce (A) achieving (S)

Funding and an SAE directly from the Cambridge Biomedical Campus organisations 


Please see our first draft RedCross Areas Vision which the neighbourhood hope the CBC will sign up to work with relevant agencies to take forward and incorporate into immediate 2021 actions and future expansion plans as Girlguiding’s CEO Angela Salt OBE, Chief Guide Amanda Medler and Chair of the Board of Trustees Catherine Irwin (2021) 'Women and girls have a right to feel and be safe at all times of the day and night”. their Survey identified that “A quarter (26%) of girls aged 7 to 10 feel unsafe when they go outdoors, increasing to two in five (41%) 17 to 21 year olds. All these measure were higher for girls and young women who identify as disabled or LBGQ+”. When an illegally parked car last week at nearly midnight by a residents home is looked at by an elderly disabled 5ft woman (as a very close by neighbours home - an elderly 91 year old disabled woman her daughter and a 5 year old grand daughter who were at home - was entered by an unknown male a few days previously so naturally the community was concerned) and the woman returned to their home to be accosted by the 6ft male car driver coming out of the Biomedical Campus with clenched fists shouting at them, this does not create a Safe Street/Space and neighbourhood surrounding the Cambridge Biomedical Campus.

x. To conclude we leave you with RedCross dream for 2021 as stated nationally by Kit Malthouse MP (2021) “As Minister for Crime and Policing, I am committed to ensuring that our citizens can live comfortably in the knowledge that their communities and streets are safer and free of crime” and locally by a vision by our new Mayor  Nik Johnson saying "He will encourage people to live healthier lifestyles .... and will be making a priority of compassion, cooperation and community to be at the source of all policy decisions”.   

Our biggest neighbour CBC with the most impact on the health and well being of RedCross Areas and other neighbourhoods could learn from Nik's words they certainly give our and the wider communities across Cambridgeshire hope.

Cambridge Draft RedCross Areas Vision 2021 – 2051 linking to Cambridge Biomedical Campus Organisations & Their 30 Year Vision 2021 - 2051
Safer Streets
• More street and key area lighting, (CCTV junction with Red Cross Lane and Greenlands), pavement bollards by dropped kerbs to stop illegal driving onto pavements, no loading at junctions (Create a signposted/road marking junction at Red Cross Lane & Greenlands), stop dangerous waiting at junctions/pavement parking) for current and future nos of staff to keep roads/pavements safe for CBC staff and those that live and travel through the RedCross area, no motorbike signs cyle path into CBC and Greenlands to Ninewells
• Adequate break/smoking areas with seating on site therefore freeing up our streets for all including pedestrians/disabled/ pushchairs/ wheelchairs/cyclists etc. – for those who live here and travel through to work, visit or have treatments on the CBC
• It is intimidating using roads and pavements when unable to pass large groups of CBC/NHS staff on roads/ sitting on pavements/parked on pavements or double yellow lines 24/7
• Extend Ninewells Cycle path around Ninewells (not through it) and connect to cycle path by Helicopter pad – linking Park & Ride/Trumpington and give a Safer Active Travel Route for the increasing numbers of staff going into the Biomedical Campus
• Please for the CBC staff nearly 75% female and our community create Safer Streets
RED CROSS AREAS WANT AN SAE - Safer Streets - Accountability & Enforcement
CBC/NHS/UC/Council/Councillors/Mayor/GCP/Police/Bell/Agents/Owners & Multi Agency Joined Up Working



CBC/NHS/UC/Council/Councillors/Mayor/GCP/Police/Bell/Agents/Owners & Multi Agency Joined Up Working
CBC/NHS/UC/Council/Councillors/Mayor/GCP/Police/Bell/Agents/Owners Multi Agency Working

NOW & CBC VISION ongoing

NOW & CBC VISION ongoing

NOW & CBC VISION ongoing


• More smoking shelters/seating/move away shelter from Red Cross Lane/alternatively close or a gate (?one with ease of access wheelchairs/pushchairs/mobility/sight)pavement entrance to denote CBC/Addenbrooke’s (with lighting/APR) from the residential street - cycle route open
• Signs on current posts (future gates) containing message from current NHS Large Sign
• CBC / NHS Induction, continually rolling programme of monthly all staff email, monthly management/team meeting agenda item/Awareness work with the Council & pocket ashtrays
• Accountability, policies in place to monitor, manage and uphold Best Practice/Values of orgs

CBC/NHS/ UC/Council


NOW & CBC VISION ongoing


• Signage on entrance to RCL NO TROUGH ROUTE TO HOSPITALS/CBC – maps to site REMOVE Red Cross lane add P&R cycle path to CBC cutting out Greenlands
• Signage by No 1 RCL/Hospital site– No STAFF DROP OFF OR PICK UP/Waiting/Parking
• Fund Council consultation and installation of any agreed e.g. double yellow kerb blips, mini bollards, modal etc. to reduce dangerous &/or illegal cars waiting/parking/pavement parking
• Enough Blue Badge disabled parking by each area of the hospital so no need to park at a distance and cause those most vulnerable additional stress attending Clinics and Treatments
• Easy access pick up/drop off on site areas for staff/patients on CBC – promoted monthly
• Publicise on offer of appointment letters to staff and appointment letters to patients-visitors
• Induction, monthly all staff email, monthly management/team meeting agenda Re: RCA
• Accountability policies in place to monitor, manage and uphold Best Practice/Values of orgs
CBC/NHS/UC /Council
CBC/NHS/ UC/Council/Councillors/Mayor/GCP



NOW & CBC VISION ongoing

NOW & CBC VISION ongoing
NOW & CBC VISION ongoing

Private Hire Vehicles
Adequate Taxi Bays on CBC/for NHS etc.– Publicised and Promoted Continually no parking in RCA
Adequate Private Hire Vehicle Bays on CBC/for NHS/Patients booking them for collection – P&PC
Lets support the small business person have breaks wait for fares most coming from the CBC
CBC/NHS/UC Council/Councillors/Mayor/GCP
CBC/NHS/UC Council/Councillors/Mayor/GCP
NOW & CBC VISION ongoing
NOW & CBC VISION ongoing

Fly tipping /Littering
By actioning the above and below this should decrease and have routes of accountability Accountability policies in place to monitor, manage and uphold Best Practice/Values of all orgs
CBC/NHS/UC Council/Councillors/GCP/Police/Bell/Agents/Owners
NOW & CBC VISION ongoing

Anti Social Behaviours
Policies in place to monitor, manage, have accountability of agencies for anyone bringing them into disrepute/not upholding their Behaviour Policies of all orgs–onus taken away from community complaints
Process to report and gain feedback on any of the issues/those involved in the above to each agency
RARA WANTS A PAM Prevention Action Monitoring
CBC/NHS/UC Police/Bell/Man & Letting Agents/ Licencing / Council / Owners & Multi Agency
NOW & CBC VISION ongoing


• CBC needs a Station – please stop cars using RedCross Areas as a pick up/drop off site now
• If the site infrastructure does not support expansion, power, water, cable – let neighbours know and your plans for addressing these shortfalls & impact on their neighbourhoods/lives
• Consult with the neighbours this will impact on – e.g. station, expansion, road closures/road works/ disruption/ noise/gas pipes/water pipes/sewage/digital cabling etc. etc. etc. etc. etc.
CBC/NHS/UC Mayor/Council/ Councillors/ Police/ GCP/Bell/Agents/ Owners & Multi Agency

NOW & CBC VISION ongoing

NOW & CBC VISION ongoing


Greater Cambridge Local Plan Preferred Options

Representation ID: 58186

Received: 13/12/2021

Respondent: Cambridge Past, Present and Future

Representation Summary:

CambridgePPF are concerned about the potential recreational impacts and the consequences of increased water supply and quality issues arising from the Plan. We also note the caveat that the HRA report indicates that (on a precautionary basis) a conclusion of no adverse effect on the integrity of European sites cannot be reached without further work on issue of water quantity and quality - both key concerns.

Full text:

We welcome the publication of the Greater Cambridge Local Plan: First Proposals 2021 (GCLP) Habitats Regulations Assessment Report (The HRA Report) and the opportunity to comment on it. Cambridgeshire contains a number of sites of international importance for biodiversity that must have the highest level of protection. We also welcome and support the recognition at Para 1.10 that the HRA report is based on the precautionary principle and the statement that ‘where uncertainty or doubt remains, an adverse effect should be assumed’.

Cambridge Past, Present & Future has also commented on the Biodiversity and green spaces policies in the GCLP First Proposals consultation and our comments on the HRA report should be read in together with these. Whilst it is appreciated that the focus of the HRA report is necessarily on European sites, it also raises fundamental issues and concerns that apply to sites of national and local biodiversity importance too.

Although the publication of the HRA report is welcomed, there are however, some concerns that we discuss in further detail below. This applies especially to potential recreational impacts and the consequences of increased water supply and quality issues arising from the implementation of the future GCLP. We also note the caveat that the HRA report indicates that (on a precautionary basis) a conclusion of no adverse effect on the integrity of European sites cannot be reached without further work on issue of water quantity and quality - both key concerns.

Assessment of in combination effects

Chapter 3 of the HRA report refers to the assessment of potential in combination effects and the identification of other Local Authority plans that could contribute to these. The scope of this is welcomed. It should be noted though that broader projects such as the Oxford-Cambridge Arc still require more work and detail to enable potential in combination effects to be identified. This also applies to any other site allocations and development that have yet to be defined or that may emerge in future versions of the GCLP.

Screening Assessment

It is noted that para 4.3 indicates a list of policies that will not result in development and will contribute to ensuring the safeguarding of European sites. This intention is welcomed but much will depend on how these polices are worded and framed. For example, we would refer to our comments submitted in respect of the First Proposals for biodiversity and green spaces. Whilst the overall and intention and policy direction of these polices is welcomed, the detail will be critical. We have commented on the need to prioritise polices to ensure that the protection of all sites of biodiversity importance is the first principle - this should also provide clear guidance for future developments on the standards and process that will be required. This includes the assessment of projects, the application of the mitigation hierarchy and justification and compensation for harm to sites where an unavoidable adverse effect might happen. Similarly, water quantity/quality and recreational issues are key concerns and we comment on these further below.

Table 4.8 provides a summary of the screening assessment and whether potential likely significant effects (LSEs) will occur. We note that potential LSEs are identified regarding possible off site physical damage and loss and non physical disturbance for Eversden and Wimploe Woods SAC and for water quantity and quality in respect of European wetland sites. It is also noted that a potential significant effect from recreational impacts has been identified for Wicken Fen Ramsar site and the Fenland SAC - the latter overlapping the former. The reason for this appears to be because of specific visitor survey work carried out at Wicken Fen. As para 4.60 of the HRA report indicates:

‘No zone of potential risk was identified for Wicken Fen Ramsar. However, in line with a precautionary approach and following the completion of the visitor surveys within Wicken Fen Vision Area, a Zone of Influence has been applied. The survey data that was collected at the Wicken Fen Main Entrance and found that the majority of visitors travelled between 10km and 20km to visit these sites. Based on these findings and in line with a precautionary approach a ZOI of 20km was applied in this assessment.’

Recreational pressure arising from future development as a consequence of development planned for in the GCLP could have a serious impact on existing European sites and those of national and local importance that are, of course, not covered by the HRA Report. It is also evident that the potential effect on Wicken Fen and the related Fenland SAC has only been identified because of specific survey work. With this in mind, we are concerned with the confidence that can be placed on a finding of no LSE for other European sites based on a zone of potential risk for recreational pressure based on a 2Km and 5km distance. We comment further on the implications of the findings of the HRA Appropriate Assessment with regard to potential recreational impacts on Wicken Fen and the Fenland SAC further below.

Appropriate Assessment (AA) - overall approach

Para 5.5 summarises the LSEs indicated in Table 4.8. That table indicates no LSE from Air Pollution on any European sites. Para 5.5. however indicates to the contrary - we assume this is an error as the subsequent AA does not address this issue.

Paras 5.34 to 5.37 refer to mitigation in respect of non physical disturbance and Eversden and Wimpole Woods SAC. It is noted that paras 5.35 and 5.36 state (with reference to overall biodiversity policy) :

‘The policy will state that development proposals adversely affecting sites of biodiversity or geological importance will not normally be permitted. Exceptions will only be made where the public benefits significantly outweigh any adverse impacts. In such cases where development is permitted, we will require that the intrinsic natural features of particular interest are safeguarded or enhanced.’


‘It is recommended that this wording is further strengthened to explicitly state that the level of protection provided should be appropriate to the international, national or local significance of the site. In addition, the policy should be updated to reflect the safeguard measures detailed above’.

We commented on this issue specifically with regard to the biodiversity and green spaces policies in this First Proposals consultation. The supporting text quoted at para 5.35 above indicates that exceptions will only be made where the public benefits significantly outweigh any adverse impacts. However, more clarity will be needed on how this will work in practice. Again, it is appreciated that the policy wording has still to be written. However, this is such an important issue that a clear statement of intent should be made in the GCLP now. If developments are proven to have an adverse effect or, applying the precautionary principle, a risk of an adverse effect, then they should only be normally permitted when clear tests are applied. Arguably this should also include being satisfied that applicants have demonstrated that there are no less damaging alternatives they could pursue.

Clarification will also be needed of what tests will be used to determine whether public benefits outweigh adverse impacts on important sites, because an approach solely on a case by case basis could risk a lack of consistency and consequent serious harm to biodiversity interests without sufficient justification. The level of public interest that would need to be demonstrated will also need to be commensurate with the level of interest affected - this is likely be very high if for example, an internationally or nationally important interest is at risk.

AA - Impacts of Recreation on Wicken Fen Ramsar site and Fenland SAC

We have already flagged our concern with the approach to the treatment of recreation effects in respect of the approach to screening for LSEs above. The AA identifies the potential impacts of increased recreational pressure on the Wicken Fen Ramsar site and Fenland SAC and paras 5.43 to paras 5.49 set out proposed mitigation. Para 5.46 states:

‘It is however recommended that the policy is strengthened further by providing a commitment in the plan that any development proposed within 20km of the European site to provide alternative natural greenspace that is specifically designed and managed to alleviate visitor pressure on the European sites. In addition to this, it is recommended that that (sic) the policy outlines the quantity and quality of open space provision and how delivery and management in-perpetuity will be secured’.

This overall commitment is welcomed and we are pleased to see that it concludes the need to manage alternative natural greenspace in perpetuity. However, the success of any mitigation (and ultimately any finding of no risk of any adverse effects) will all depend on alternative green space being delivered in a timely fashion to serve new development in the Cambridge Area. At this point in time that assumption is questionable.

Specifically, proposed new development at Waterbeach, North East Cambridge and Cambridge East will result in a substantial population within approximately 10 miles of these highly sensitive sites. Existing recreational green spaces such as Milton Country Park are already at capacity. Our recent understanding is that the relevant local authorities do not propose to create any new large scale greenspace for North East Cambridge. Whilst the need for such space is accepted, as yet the local authorities have no mechanism to deliver it. Failure to secure and deliver the required open space would thus place the Wicken Fen Ramsar site and Fenland SAC at considerable risk from increased recreational pressure and could not support a HRA finding of no adverse effect.

AA Water Quantity and Water Quality

We have already commented on these issues in respect of the biodiversity and green spaces policies because planning decisions in respect of the supply of water and waste disposal can have a number of profound impacts on both European sites and other important biodiversity interests.

With regard to water quantity it is noted that HRA report indicates potential issues regarding the impacts on European sites within the area and, with respect to mitigation, refers to work of Water Resources East (WRE) and the development of a long-term integrated water management plan (IWMP) for Eastern England.

It is also stated (para 5.60) that:

‘The purpose of this IWMP is to understand the future demand for water in this region, available water supplies, and the options available that will be required to balance supply and demand’.

The HRA also states with regard to the future GCLP at para 5.64 that:

Any new development as part of the GCLP will need to demonstrate water neutrality to ensure no adverse effect on the integrity of European sites susceptible to impacts from water. In part this will be achieved through reduced water demand within specific proposed development. However, this will largely be reliant on the actions of Cambridge Water with support from WRE. To address this, there should be a commitment in the GCLP that new development will need to demonstrate that there will be no adverse effect on the integrity of European sites. This will need to include demonstration that water will be supplied without increasing abstraction beyond the existing agreed rates in the most recent Water Resource Management Plan or reducing the current available headroom, which could result in further detrimental impacts.’

The AA then concludes at para 5.68 (emphasis added):

Subject to the findings of the Greater Cambridge IWMS and WRE IWMP being confirmed and delivered a conclusion of no adverse effect on integrity can be reached. However, in the absence of these studies and in line with a precautionary approach, a conclusion of no adverse effect on integrity cannot be reached in relation to the effect of water quantity on Ouse Washes SAC, SPA and Ramsar site, Wicken Fen Ramsar site, Chippenham Fen Ramsar site, Fenland SAC and Portholme SAC either alone or in-combination until further detail is provided and presented in the GCLP.

We are concerned that potential harmful effects on European sites have yet to be resolved. This also has implications for effects other sites of national and local biodiversity and must be addressed as a matter of urgency if the GCLP is to proceed.

Whilst water availability is, of course, a relevant constraint that the planning system should consider, the capacity of our watercourses to dispose of treated water waste is likely to be a more binding one. Furthermore, consideration must also be given to the climate-change-induced, greater frequency of storm events. Without increased investment by the water authorities the frequency of storm events leading to raw sewerage being discharged is likely to increase, even at current levels of development.

Again it is noted that para 5.71 of the HRA report states:

‘An increase in demand for wastewater treatment as a result of development in the GCLP in combination with neighbouring boroughs and districts in the region has the potential to adversely affect the integrity of European sites that are susceptible to impacts from water.’

The report goes on to highlight three particular areas of concern - increased volumes of treated waste water, overloading of the combined sewer network during storm events with potential for further flooding and contamination and a potential for contaminated surface run off from an increase in the area or urban surfaces and roads.

Mitigation is proposed to address potential water quality impacts through upgrades to Water Recycle Centres (WRC) and relocation of the existing Cambridge WRC. However the HRA report also states at para 5.74 (emphasis added):

At this stage, it is unclear whether there is sufficient capacity available within existing infrastructure and as part of upgrades to WRC to support the increase in wastewater treatment as part of proposed development in the GCLP. It is recommended that exact mitigation measures are informed by the findings of the Greater Cambridge IWMS, including Outline Water Cycle Study and upcoming Detailed Water Cycle Study.

The HRA report continues to note that there is currently limited mitigation in the plan policies that will provide for increased demands in wastewater treatment in the Greater Cambridge area. It is recommended that there is a specific inclusion of wording that outlines that any development will only be permitted where there is sufficient capacity within the WRC infrastructure. As advised by English Nature, the HRA report then indicates there should be specific detail in the GCLP on the mechanism and timescale of delivery for mitigation that will be implemented, also informed by other work on upcoming water plans. The HRA then again concludes at para 5.76 (emphasis added):

Subject to the findings of the Greater Cambridge IWMS being confirmed and delivered a conclusion of no adverse effect on integrity can be reached. However, in the absence of this study and in line with a precautionary approach, a conclusion of no adverse effect on integrity cannot be reached in relation to the effect of water quality on Ouse Washes SAC, SPA and Ramsar site, Wicken Fen Ramsar site, Chippenham Fen Ramsar site, Fenland SAC and Portholme SAC either alone or in-combination until further detail is provided and presented in the GCLP.

Again, as with the water quantity issue, we are concerned that potential harmful effects on European and other important biodiversity sites have yet to be resolved and that this must be addressed as a matter of urgency if the GCLP is to proceed.

Next Steps

Finally we note and appreciate the point made regarding next steps at para 6.6 that the HRA is an iterative process and is expected to be updated. We will of course comment on further information when this is available. We still remain concerned however, that fundamental issues such as the impacts of recreation and water as described above are still to be resolved.


Greater Cambridge Local Plan Preferred Options

Representation ID: 59010

Received: 13/12/2021

Respondent: Endurance Estates

Agent: Barton Willmore

Representation Summary:

It appears from the HRA Report that the relocation of the CWWTP is part of the mitigation measures which will be necessary to provide certainty that water quality impacts arising from the First Proposals will not adversely affect the integrity of several designated nature sites, in combination with other plans and projects. We expect the policies of the First Proposals to be revised (including to provide for the relocation of the CWWTP) in order to ensure that the emerging plan secures appropriate mitigation in connection with the development strategy - in particular North East Cambridge.

Full text:

It appears from the HRA Report that the relocation of the CWWTP is part of the mitigation measures which will be necessary to provide certainty that water quality impacts arising from the First Proposals will not adversely affect the integrity of several designated nature sites, in combination with other plans and projects. We expect the policies of the First Proposals to be revised (including to provide for the relocation of the CWWTP) in order to ensure that the emerging plan secures appropriate mitigation in connection with the development strategy - in particular North East Cambridge.



Greater Cambridge Local Plan Preferred Options

Representation ID: 59991

Received: 13/12/2021

Respondent: Natural England

Representation Summary:

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. Detailed comments are provided.

Full text:

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


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.

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.

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.

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.