Chapter 3. Sustainability Appraisal Findings
Greater Cambridge Local Plan: Sustainability Appraisal of Issues and Options
Representation ID: 45936
Respondent: North Barton Road Landowners Group
Agent: Carter Jonas
It is considered that some of the commentary on each of the spatial distribution options and likely effects is not correct, and it is requested that a more detailed analysis of the options is required in the SA for the Draft Greater Cambridge Local Plan.
The representations are focussed on the SA of the spatial distribution options at Paragraphs 3.38 to 3.119 and associated tables including Table 3.1.
Representations to Sustainability Appraisal of Issues & Options (December 2019)
The Sustainability Appraisal (SA) of the Issues & Options consultation document includes an assessment of a range of spatial distribution options, which are as follows:
• Option 1: Densification;
• Option 2: Edge of Cambridge – Outside the Green Belt;
• Option 3: Edge of Cambridge – Green Belt;
• Option 4: Dispersal – new settlements;
• Option 5: Dispersal – villages; and
• Option 6: Public transport corridors.
It is acknowledged in the SA the preferred spatial distribution strategy may be based on a combination of these options, but the assessment is based on each option individually. It is considered that some of the commentary on each of the spatial distribution options and likely effects is not correct, and it is requested that a more detailed analysis of the options is required in the SA for the Draft Greater Cambridge Local Plan.
The North Barton Road Landowners Group (North BRLOG) is promoting land at South West Cambridge which is located within the Green Belt; the site would fall within Option 3: Edge of Cambridge – Green Belt. The findings of technical work undertaken to support the promoted site at South West Cambridge will be referred to in these representations where relevant.
The following representations are focussed on the SA of the spatial distribution options at Paragraphs 3.38 to 3.119 and associated tables including Table 3.1.
It is acknowledged in the SA that the scale of development, its design, and associated impacts will depend on the circumstances present at individual sites. It is considered that strategic sites will need to include appropriate services and facilities to meet local needs and capacity, and will need to be well-designed and include mitigation measures and enhancements to address impacts, but there is no reason why these matters cannot be satisfactorily addressed. For example, a Vision Document has been prepared for the promoted development at South West Cambridge, which has been designed to take into account landscape, heritage and ecological impacts. Mitigation measures are included to address any adverse impacts. Ecological and flood risk/drainage enhancements are provided, and the proposal includes a local centre and primary school and open space and recreation areas.
Therefore, the promoted development at South West Cambridge is capable of delivering positive outcomes when assessed against the sustainability objectives.
SA Objective 1: To ensure that everyone has the opportunity to live in a decent, well-designed, sustainably constructed and affordable home
It is not certain when Option 2 (Edge of Cambridge – Outside the Green Belt, which relates to development at Cambridge East) will be available for development because the existing uses need be relocated, and it is also not certain whether development at the site will provide policy compliant levels of affordable housing. The existing operations and businesses at Cambridge Airport will need to be relocated prior to the commencement of development. The Wing development at Cambridge East, for example, is required to provide 30% affordable housing against a policy requirement for 40%. It is requested that the assessment of Option 2 against the criteria for SA1 needs to take into account these factors.
It is incorrect to assume that Option 3 (Edge of Cambridge – Green Belt) do not deliver policy compliant levels of affordable housing. The Greater Cambridge Housing Market Economics Analysis (prepared by Bidwells on behalf of North BRLOG) demonstrates that there is sufficient residual value in strategic greenfield sites on the edge of Cambridge to support planning obligations and policy requirements including affordable housing. It is requested that the assessment of Option 3 against the criteria for SA1 needs to take into account the fact that such sites are capable of providing policy compliant levels of affordable housing.
It is agreed that Option 4 (Dispersal – new settlements) do take a long time to be delivered largely because such developments are complex, and it is noted that initial predictions about the lead-in timetable for the delivery of new settlements are often unrealistic. It is also relevant to SA1 that new settlements typically do not deliver policy compliant levels of affordable housing; the amount of affordable housing provided and proposed in the initial phases of Northstowe and Waterbeach are examples where this has occurred. It is requested that the assessment of Option 4 against the criteria for SA1 needs to take into account realistic assumptions about lead in times for new settlements which will affect the supply of housing and affordable housing, and the fact that such developments are not capable of providing policy compliant levels of affordable housing.
SA Objective 12: To minimise Greater Cambridge’s contribution to climate change
It is considered that the assessment of effects for Option 3 (Edge of Cambridge – Green Belt) includes negative commentary about the accessibility of edge of Cambridge sites by sustainable modes of transport, although it is acknowledged that these locations score well against this objective. The outcome of those effects will to a certain extent depend on the strategic sites selected.
It should be noted for the SA for the Draft Greater Cambridge Local Plan that the area to the west of Cambridge is the focus for a number of proposed and potential transport infrastructure projects i.e. Cambourne to Cambridge Bus Corridor, Comberton Greenway, Barton Greenway, Madingley Road Cycle Improvements, and Cambridge Autonomous Metro. It is considered that the promoted site at South West Cambridge is well related to all of these proposed and potential projects; the Cambourne to Cambridge Bus Corridor, Comberton Greenway, Barton Greenway are either within or immediately adjacent to the site.
Greater Cambridge Local Plan: Sustainability Appraisal of Issues and Options
Representation ID: 47300
Respondent: Mr . Wookey
Elevate low-emissions in new buildings above numbers of buildings and build cost. We must take a long-term view which minimises emissions as well as costs.
The housing section is all about building more houses. This is significant but the most important thing is to reduce emissions from housing. That means that all new building (domestic and commercial/industrial) _must_ be passivehouse grade so we are not adding to our already-huge problem of emissions from heating. heating uses twice the energy of the entire electricity grid and has barely been decarbonised at all. We must immediately stop making that problem worse whilst _also_ addressing the existing building stock, which is difficult and expensive. It's very easy to make all new buildings passivehouse and this _saves_ money over the buildings lifetimes.
Greater Cambridge Local Plan: Sustainability Appraisal of Issues and Options
Representation ID: 49767
Respondent: Martin Grant Homes Ltd & Harcourt Developments Ltd
This sections of the scoping report refers to some key documents, all of which support growth, not just in
relation to the needs of Cambridge and South Cambridgeshire, but the wider region.
3.2. The MHCLG document of March 2019 titled ‘Oxford-Cambridge Arc’* is a joint declaration of ambition
entered into by the Government and local partners envisages substantial growth in the Arc. It establishes
a target of building up to 1 million homes by 2050. These homes are necessary to deliver the
Governments industrial strategy, which envisages increased productivity in order to boost economic
growth and prosperity, and to deliver higher incomes (p14, ibid). To date, no local authority within the Arc
has provided for any additional growth in their local plans above the standard housing requirement that
would assist in reaching this target. The Greater Cambridge Plan should recognise and accommodate
part of this wider growth. If it does not do so, it will set a precedent for other local authorities within the Arc
(such as the highly productive city of Milton Keynes) to lower their ambitions, and the Government’s
strategy for increased growth will fail.
3.3. Housing affordability is a key issue for equality both nationally and more significantly, within Greater
Cambridge. It is also an international issue. International companies able to offer better living standards
with a smaller portion of wages needed to pay for living accommodation can tempt workers from the UK
to other destinations across the globe. The government and local authorities recognise in the Oxford-
Cambridge Arc document that median house price to median income ratio has been increasing across
the UK, and increasing more significantly across the Arc.
Savills estimates that for its economic potential to be reached, 9.6 million sqft of business floor spaces is
needed across the Arc, with 680,000 homes beyond the existing pipeline.** If the Arc is to deliver its
employment potential, housing affordability must be addressed through the building of significant
numbers of homes.
3.5. It is noted that connectivity is a key theme of the government-local authority declaration on the Arc.
Transport connections are key to the allocation of new development in sustainable locations.
3.6. Protection of the environment is a key theme running though all legislation relating to development
planning. A requirement for net-gain in biodiversity does much to ensure that delivering growth is not at
the cost of the environment.
The Cambridgeshire and Peterborough Strategic Spatial Framework (CPSF) and the Cambridgeshire
Local Transport Plan (CLTP) are referenced as a key development plan document in the Scoping Report.
This document has considerable overlap with the preparation of the Greater Cambridge Local Plan. The
Sustainability Appraisal should prefer policies and allocations that ensure links are made between the
ambitions of the CPSF and the proposed transportation projects in the CLTP. Transportation matters and
traffic generation should be key issues for the SA to consider, and to inform the Greater Cambridge Local
Population, Health and Wellbeing
3.8. The scoping report correctly notes that the delivery of services and facilities (and access to them without
recourse to a car) is an issue of health and equality. This should favour larger sites able to deliver access
to such infrastructure when the sustainability appraisal of sites is carried out.
3.9. One of the key issues for the delivery of housing in Greater Cambridge is the need to deliver large
numbers of homes as quickly as possible, as set out in the Greater Cambridge Housing Strategy 2019-
2023, which notes the key priority to ‘increase the delivery of homes, along with sustainable transport and
other infrastructure …’. Consideration should be given to the ability of existing sites to deliver additional
homes quickly, when considering options for densification, or additional delivery at locations already
committed for development.
3.10. Table 3.1 in this section provides an interesting comparison of development locations, identifying that the
majority of growth in current Local Plans is to be provided on the edge of Cambridge, with a significant
number being delivered in the Cambridge Urban Area, and the total number of completions, commitment
and new sites in the rural areas amounting to more development than that proposed for new settlements
or at Cambourne (an urban extension). The Sustainability Appraisal should consider this balance of
locations very carefully. In order to maximise sustainability and reduce carbon emissions, new
development should be located where: -
There are good public transport links;
- Where there is employment within walkable distance;
- Where leisure and retail facilities are within walking distance;
- Where existing facilities and services can be complemented with new facilities.
3.11. Guidance from the NHS and wider international research indicates that the provision of green open
spaces has a linear relationship with activity levels, and a direct correlation with health. Larger sites able
to deliver both incidental open spaces and good access to strategic formal sports and parkland will
therefore offer better outcomes for population health. This should be factored into the Sustainability
Appraisal of potential development sites.
Air and Noise Pollution
3.12. The Scoping Report correctly identifies that air and noise pollution are key health issues for many groups
in Greater Cambridge. Whilst there is a reflection that noise can to some extent be mitigated by traffic
reductions and other measures in paragraph 3.68, there is no similar mitigation recognised for air
pollution. Table 3.3 outlining the key sustainability issues for the Local Plan should strongly reflect the
impacts of traffic on health and inequality outcomes in the SA objectives.
3.13. Section 2 of the Scoping Report notes the high level policy requirements introduced by the Government
for the part that the Oxford Cambridge Arc is to play in the prosperity of the region (that is briefly
mentioned in paragraph 4.24). ‘Partnering for Prosperity’, the new deal for the Cambridge-Milton Keynes-
Oxford Arc is briefly referenced at paragraph 4.9. These documents together identify the high levels of
employment growth that the Government expects across the Arc. The SA scoping should be clear that
proposals that seek to deliver integrated employment growth at the higher levels expected from
Government in relation to the Oxford Cambridge Arc will be favoured in the assessment. This criterion
needs to be factored into SA objectives 14 or 15.
Transport and Air Quality
3.14. The national policy guidance listed generally contains policies that are aimed at reducing emissions from
vehicles, or making emissions les noxious. These documents give very little prominence to the reduction
of vehicle movements, in contrast to the reduction of vehicle emissions. The former aim is much better in
all respects: reducing vehicle movements (and encouraging active travel) are both good for the
environment and our health due to better air quality, but also improve health through activity.
The Air Quality Action Plan identifies (on page 18) that modal shift from private car to public transport and
active travel will impact positively on air quality. Table 2.3 of the Action Plan identifies monitoring targets
relating to increases in bus patronage, cycling trips, journeys to school by means other than car, and
traffic congestion. The ability to meet these measures should form a part of the SA objectives: i.e. policies
and potential site allocations are rated as higher / better the more likely they are to achieve these modal
shifts. This should be considered in answering the Appraisal questions under SA Objective 13.
3.16. Local Transport Plan 2 contains targets to restrict any increase of transport within Cambridge city centre.
The ability of policies, and sites, to reduce or limit traffic congestion should be a measure of how
sustainable they are, and included in the SA objectives. Table 5.1 notes that the existing policies in the
adopted Local Plans that promote sustainable and active transport based on sufficient population
densities. The ability of new development to support public transport and active travel should be a key
part of the Sustainability Appraisal assessment,
Climate Change Adaption and Mitigation
3.17. Page 97 and Table 7.1 of the Scoping Report identify that transport makes the largest contribution to
carbon emissions (over 34%) in South Cambridgeshire. Whilst it is correct that the peat fens create
significant mitigation, the reduction of vehicular traffic and emissions from traffic is likely to have
significant impacts on climate change adaption. This lends weight to the criteria that include the ability to
reduce vehicular traffic as key assessment elements for the Sustainability Appraisal.
3.18. Table 11 sets to the SA Framework for the Greater Cambridge Local Plan. Paragraph 1.5 of the Scoping
Report seeks views on any additional SA criteria that should be included. MGH comments below on each
of the SA Objectives, and additional objectives that should be included to ensure a robust assessment.
Commentary is also provided on the appraisal questions associated with each objective.
SA 1: Housing
3.19. The Scoping Report identifies (as set out in the sections above) a larger number of policy documents,
from government to local level, that indicate housing is needed to support economic development; and
that high levels of economic development are required. The SA objectives (including SA objectives 14
and 15) do not include this link between housing and employment. There are two alternatives: an
objective is added, or an existing objective is amended to include an objective: To deliver sufficient
housing to support employment growth, locating new jobs near to new homes, and balancing jobs with
homes. The Appraisal questions should include: Does the Plan support increased employment delivery
with sufficient homes to support employment growth? Have homes been provided where they are
accessibility to jobs, particularly by public transport, is maximised?
SA 4: Public health
3.20. Appraisal question 4.2 touches on the issue of transport choices, but neglects any specific reference to
public transport. Studies show that increased public transport has clear benefits to activity patterns19, in
addition the removal of harmful emissions from vehicles, the increase in equality provided by public
transport, and the benefits to mental health (and productivity) in reducing commuting times. This is set out
in the Scoping Report, see inter alia paragraphs 3.14 to 3.16 above. A separate Appraisal Question
should be added: Does the Plan promote increased levels of public transport use, and better public
SA 12: Minimising climate change
3.21. SA 12.4 relates to public transport provision, but simply asks whether the Plan supports access to public
transport. As set out above, public transport is a key element relevant to multiple factors affecting
sustainability. SA 12.4 should therefore be strengthened to read: Does the Plan support the growth of
public transport networks, modal shift away from private cars and onto public transport, and access to
public transport options?
SA 14: Facilitating the economy
3.22. The Appraisal questions included do not reflect the importance of economic growth that is highlighted in
the Scoping Report itself, and referenced above in paragraph 3.13. SA14.1 asks whether the Plan
provides for an adequate supply of land to meet Greater Cambridge’s economic and employment needs.
SA 14.5 asks whether the Plan supports stronger links to the wider economy of the Oxford Cambridge
Arc. The Scoping Report indicates a much greater requirement. Greater Cambridge is within the Arc, and
new infrastructure, including East West Rail has already been announced on the basis of higher levels of
economic growth. Government expects Greater Cambridge to deliver higher levels of employment to
support additional growth within the Oxford Cambridge Arc; and the economic reports accompanying the
evidence base produced to date (in addition to other independent research) show that substantial growth
can be achieved in the area.
SA14.1 should therefore be amended to read: Does the Plan provide for a supply of land and the delivery
of infrastructure that will meet the enhanced level of growth envisaged across the Oxford Cambridge Arc?
SA 14.5 is therefore no longer needed, but could be used as a separate question to relate the SA and
provision of employment to infrastructure. SA 14.5 should therefore be amended to: Does the Plan
provide adequate infrastructure in the right places to support enhanced levels of economic growth?
Assumptions regarding distances
3.24. The assumptions regarding distances are broadly appropriate, assuming that they are applied equally to
all sites. It would be helpful to also assess sites in relation to their accessibility by bicycle, journeys which
are increasing, particularly with the rise in use of micro-transport2*** including e-bikes and scooters.
SA Objective 1
3.25. MGH propose that this objective should include a requirement To deliver sufficient housing to support
employment growth, locating new jobs near to new homes, and balancing jobs with homes. The criteria
for the assessment of this objective should not be based simply on housing need, or the proposed small
10% increase in housing need, but should instead be predicated on meeting the housing need for
employment aspirations. Without such a requirement the Plan cannot provide sufficient housing for
everyone to live in a decent home, whilst also meeting the Governments aspirations for economic growth.
The criteria should therefore be: sites that fail to provide sufficient land for total housing need to support
the highest economic forecasts will have negative effects (-). Sites that deliver sufficient land to support
the full economic projections for the area will have significant positive effects (++).
SA Objective 3
3.27. The criteria and assumptions in the Scoping Report suggest that public transport implications are
considered elsewhere and therefore do not need to be considered in relation to social inclusion and the
equality act. This approach is incorrect. Public transport is a vital element of many of the sustainability
objectives, and should therefore be considered in relation to each objective, ensuring that the weight
given to support for public transport (and modal shift away from private car usage) is equal to its
3.28. MGH propose that two criteria are added to the assessment assumptions. 1. If a site is within walking
distance of regular public transport (1 journey every 15 minutes at peak hours) it will have a neutral effect.
If a site is within walking distance of two or more bus routes with regular public transport, it will have a
positive (+) effect. If a site is within walking or cycling distance of strategic transport, such as rail, guided
bus, park and ride or proposed Cambridge Autonomous Metro, it will have a significant positive effect.2. If
a site is able to support additional public transport provision it will have a minor or significant positive
effect, depending on the quality and quantum of public transport improvements that can be supported.
SA Objective 4
3.29. This objective includes a criteria that relates to the beneficial proximity of development to healthcare
facilities. A further criterion should be added to include that: Sites that are able to deliver new healthcare
facilities within walking distance of employees or residents, will have a significant positive effect.
SA Objective 5
3.30. MGH disagrees that sites within 400m of locally designated sites will have an uncertain negative effect.
This will depend on the site’s size and ability to offer mitigation, or its ability to offer biodiversity gains in
relation to the designated site. The assumption should therefore be amended so that the uncertain
negative effects apply only to sites where development is proposed within 400m of locally designated
SA Objective 6
4.15. The impact of development at North Cambourne is difficult to categorise in relation to this objective, as it
is not specifically related to a new settlement, and therefore does not have the potential negative impacts
that relate to development Option 4. MGH await the detailed SA of sites in order to comment more fully,
but would welcome the opportunity to discuss potential impacts on the distinctiveness of Greater
Cambridge’s landscapes and townscapes in more detail. There is an opportunity at North Cambourne to
add to the distinctiveness of Cambourne, building on the existing identity of the town and creating a
strong sense of place.
SA Objective 7
4.16. MGH strongly disagrees that North Cambourne would be likely to have a detrimental effect on the
qualities, fabric, setting and accessibility of Greater Cambridge’s historic environment. There are very few
heritage assets related to the site, and impacts on them through development would be limited. This
issues can be explored in more detail during the SA of specific development sites.
SA Objective 11
4.17. The SA concludes at paragraphs 3.86 and 3.87 that because development is likely to lead to a reduction
in permeable surfaces flood risk will increase. This is not accurate. All development is required to deliver
surface water drainage in a sustainable way, including measures that mitigate against climate change. In
other words, new development will normally mitigate flood risk by providing storm water attenuation that
slows water run-off to rates based on increased rainfall. This offers flood mitigation, contrary to the initial
findings of the SA. This would be the approach adopted at North Cambourne, which lies outside of any
designated flood zones. MGH therefore expects that the detailed SA for the site will conclude that it can
provide benefits to flood risk minimisation, and adaptability to climate change.
SA Objective 12
4.18. Assessment against this objective is particularly sensitive to the provision of public transport and the
ability of development proposals to limit the impacts of vehicular traffic, as recognised in paragraph 3.92.
Option 2 (the Cambridge Airport) is assessed as being of sufficient scale to be able to deliver a range of
homes, jobs, services and facilities, which could reduce the need for people to travel elsewhere. MGH
has carried out an assessment of the potential increase in self-containment that could be achieved at
Cambourne, together with a shift away from car usage and onto public transport. The evidence to support
this approach is set out in Appendix 1, together with the assumptions made about what could realistically
be achieved. Our evidence shows that there is potential to deliver a large number of homes at North
Cambourne with a net zero (or minimal) effect on car journeys to Cambridge.
4.19. It is clear that, should new settlements (or expansions of existing settlements such as North Cambourne),
also be located on public transport corridors, they will not necessarily have the balanced positive and
negative effects of new settlements as shown in the table on p39. It is more likely that they would have
the significant positive effects associated with development Option 6.
SA Objective 13
4.20. Objective 13, similar to Objective 12, is influenced strongly by patterns of commuting and car usage. The
comments made above in relation to Objective 12 are also relevant to this objective, with likely positive
effects from development at North Cambourne.
SA Objectives 14 and 15
4.21. The assessment of this objective would be similar for Cambridge Airport and North Cambourne; or for
public transport corridors and North Cambourne. The North Cambourne proposals are of sufficient size
suitable to create a strong and vibrant community, well-connected to Cambridge with public transport,
which would be attractive to global and local employers. The provision of a mixed-use community at North
Cambourne, including a variety of employment types, would be likely to generate significant positive
effects to the economy.
4.22. MGH are mindful that this is a high level initial appraisal of options. It is clear that the MGH site, unlike
Cambridge Airport, does not fit neatly into any one of the broad development options. However, it does
benefit from the positive effects of new settlements, and the positive effects of development on public
transport corridors. MGH looks forward to the conclusions of the individual site sustainability appraisals,
and would welcome the opportunity to engage with the Councils in this process.
*Oxford Cambridge Arc, MHCLG, March 2019
**The Oxford Cambridge Innovation Arc, Savills, 2019 p3
Greater Cambridge Local Plan: Sustainability Appraisal of Issues and Options
Representation ID: 50054
Respondent: John Preston
The Sustainability Appraisal and Scoping Report are inadequate in terms of both process and content.
While the Scoping Report notes (1.15 “Baseline Information”) that “It is a requirement of the Strategic Environmental Assessment process that consideration should be given to the current state of the environment”, there is little recognition of current environmental capacity issues (apart from “over-abstraction of water in this region is a key issue”) and constraints, and no evaluation of successes or failures of the current Local Plans.
The Sustainability Appraisal considers each of the required SA categories separately. It does not consider cumulative and synergistic significant effects on the environment as required by schedule 2 of the SEA Regulations. This oversight has left severe current and future environmental capacity issues affecting Greater Cambridge as a whole, and the Local Plan as a whole, out of Sustainability Appraisal consideration.
But the cumulative impacts of recent and currently approved growth, including related transport proposals, are key issues for the SA and Scoping Report. How can further additional growth be accommodated if that already in the pipeline is unresolved? These impacts are neither assessed nor taken into account in the SA. Baseline information as required by the SEA should include assessments of key existing unmet demands (including, e.g., city centre cycle parking) and of demands arising from current transport proposals (Busways and Greenways). The capacity of both the historic city centre and historic green spaces to accommodate these and other existing demands needs to be assessed.
The SA then has to assess the additional and cumulative impacts of this growth already in the system, in combination with the quantum of growth agreed under the Devolution deal , plus further external (Government, Ox-Cam Arc) and internally generated (Universities, Cambridge Ahead, etc) growth pressures. It has done none of these.
The consequence is that SA has failed to test the draft Issues and Options in relation to a fundamental issue: the environmental and physical capacity limits to the growth of Greater Cambridge. This should be a key Theme of the Issues and Options (and should have already been identified as such).
The SA has also failed to identify, or test, the draft Issues and Options in relation to a second, related key issue: how to manage the conflicting imperatives of economic growth and the preservation and enhancement of the historic city of Cambridge in its historic landscape setting?
The SA and Scoping Report note that all the Options will have negative effects on the historic environment, but without identifying or prioritising issues. There is inadequate recognition of Cambridge’s national and international significance as a historic city and “one of the loveliest cities in Western Europe” (David Attenborough). They do not mention that Cambridge meets at least 3 of the Outstanding Universal Value criteria (i, ii, iv) for World Heritage Site status, or suggest its historic environment should be valued accordingly. It is this level of international cultural and historic significance, expressed in the beauty of the historic city, which attracts students, workers, and visitors from all over the world. In this context historic Cambridge includes its whole associated landscape, including the upper Cam as far as Byron’s Pool and the lower Cam along the length of the Lents and Mays course as far as Baits Bite. The lower Cam section, although fully covered by Conservation Area designations, has been threatened by growth-related transport proposals; so have the West Fields. The arguably even more significant cultural landscape between Cambridge and Grantchester and beyond has no formal protection, with the Grantchester Conservation Area boundary narrowly drawn and no Appraisal. While Grantchester Meadows are owned by Kings’ College, this ownership neither provides direct protection from developments beyond their boundary, nor has any force in planning terms. The need for such protection is highlighted by the impacts on the Meadows of the combined height and bulk of the CB1 development.
This outstanding significance of Cambridge’s historic environment is at high risk from growth pressures.
Cambridge’s historic environment is also threatened by Climate Change challenges (including mitigation and adaptation) and Government targets for meeting them. These are also high risk factors for Cambridge’s historic environment, with difficult choices to be made. A baseline assessment of the implications for Greater Cambridge of current Government retrofit targets is urgently needed.
These issues should be identified and prioritised in both baseline information and the key Themes.
Greater Cambridge Local Plan: Sustainability Appraisal of Issues and Options
Representation ID: 50215
Respondent: Campaign to Protect Rural England (CPRE)
Responses To Consultation.
Greater Cambridge Local Plan Sustainability Appraisal of Issues and Options Report
1. CPRE finds the Sustainability Appraisal of Issues and Options (SAIO) to be comprehensive and clear. However, because of its terms of reference, it does not fully consider the regional and national sustainability issues created by development within Cambridge and South Cambridgeshire. CPRE believes that some of these issues are so significant that they should have been considered in greater depth.
2. The Cambridge Green Belt was the first Green Belt outside of London and it is the smallest. Green Belts were an invention of one of our county’s foremost citizens, Octavia Hill. It is therefore of historic value in its own right and furthermore provides the unique setting for the City, its collegiate buildings and its academic character and inheritance. This significance has not been acknowledged in the SAIO.
3. The SAIO accepts the same assumption of growth as the Issues and Options Report. However, growth in itself is not sustainable and CPRE believes this assumption should be questioned by the SAIO.
4. Furthermore, the SAIO has not considered the national or regional sustainability of undertaking further major developments around Cambridge. As we stated in our response to the Issues and Options report there has been no consideration as to how this major investment of national funds in the relatively well-off south-east will further reduce or limit investment in the North of the UK. This in turn will reduce the more sustainable options of re-using the near 1 million empty properties that exist in the North and Midlands and the documented space for another 1 million properties that exists on brownfield land in Northern and Midlands towns and cities.
5. The SAIO recognises the varying quantities of best and most versatile agricultural land that the different options could cause to be built on around Cambridge. However, it does not recognise that the county of Cambridgeshire hosts a nationally significant proportion of this country’s best and most versatile farm land. As we have indicated previously, by the end of this century it is probable that climate change will have caused significant loss of the Fens which currently grow 24% of UK food supply. Therefore it is imperative that the remaining best and most versatile land land is not built on but preserved for food supply. This is a national sustainability issue and it should not be ignored.
6. It is encouraging that the SAIO recognises the issues of water resources and quality as major issues. There is already damage to the chalk streams caused by over-abstraction and the River Cam shows high stress levels in the summer months. We agree with paragraph 3.79 but we are concerned that the local authorities, driven by the NPPF, may not be taking these issues as seriously as they should and instead may be relying on the statutory duties of the water companies to dig them out of a hole. Waste water treatment capacity must be given a higher priority. The North Cambridge development requires the existing treatment plant to be moved but there is no clear decision about that yet and, if further treatment capacity is need, where will that be sited and how will it be protected from flooding?
7. The SAIO does not address the issue of flood risk within the context of climate change or in the context of the wider region. Existing flood zones in many parts of Greater Cambridgeshire will experience higher risk of flooding in future because of sea level rise caused by climate change (Predictions range between 1.1 – 4.7 metres by 2100). In December 2019, the Environment Agency issued a flood warning for Cottenham Lode which extends up to and under the A14 north Cambridge by-pass. Such warnings will without doubt become more frequent. Furthermore, additional run-off from more development around Cambridge will increase flood risk to communities further north such as Waterbeach, Cottenham, Stretham, Ely and Littleport. There is no detailed indication as to how this runoff will be prevented.
8. We find that the SAIO takes a relatively superficial approach to addressing prevention of Climate Change and its mitigation. It is clearly restricted by taking its lead from the Issues and Options. As we have stated in our response to the Issues and Options, Climate Change is the most pressing issue of our time. The current proposals are predicated upon ‘growth’ and growth has to be halted in a in a controlled manner without unacceptable effects on the poorer and more vulnerable people in our society. We agree with most of what is said in paragraphs 3.92 to 3.97 when addressing
SA Objective 12. However, the Objective is too little, too late. The whole concept of the Cambridge-Oxford Arc must be reviewed and much of it halted and replaced with more sustainable changes in the location of housing and business and the discouragement of commuting and business travel.
9. We agree with most of paragraphs 3.98 – 3.103 but we would reiterate that if housing development is undertaken in villages and other rural communities it should be accompanied where possible by employment space, to encourage local employment and reduce commuting. We also see high speed broadband as a means of facilitating distributed employment. Both will improve the sustainability of rural communities.
10. We do not agree with the principles behind SA Objective 13 and hence much of the content of paragraphs 3.104 – 3.109. Society must recognise there is no such
thing as “sustainable development”. All development has varying degrees of unsustainability. We accept that Options 1 and 2 are less unsustainable than the other Options. Nevertheless we are concerned by the loss of skilled engineering employment close to Cambridge that the development of Cambridge Airport, Option 2, would engender. We are also concerned that moving the Marshall’s business to another location will just create sustainability issues elsewhere, not the least being the building of new facilities and the travel of existing employees.
11. We are disappointed with the discussion of SA Objective 14, paragraphs 3.110 –
3.119. Unfortunately, this is driven by the manner in which the Options have been set out so separately whereas, in reality, the likely outcome of the Plan will necessarily be a combination of these options. There are many communities across the County which are increasingly becoming
commuter dormitories. Larger communities, such as Cambourne/Bourne, Northstowe, Bar Hill, Ely, Alconbury Weald and Manea are capable of supporting significant local employment space. Many larger villages could easily support more small employment units of the type that start-ups and rural businesses require.
A survey in 2010 showed that some 70% of Ely’s working population on its new estates commuted to Cambridge or London. Other communities will have higher proportions of commuters. This is not a sustainable situation.
Our conclusion is that the Greater Cambridge Local Plan must consider the economic and residential impact on its wider hinterland as well as within Greater Cambridge itself.
12. We are concerned that better integration of public transport does not seem to be considered as a major sustainability issue.
13. We are concerned that adequate electricity supply does not seem to have been considered as a major sustainability issue.
14. We are concerned that no mention has been made of impact on the proposed Fenland Biosphere with its potential UNESCO designation. This is a major
Greater Cambridge Local Plan: Sustainability Appraisal of Issues and Options
Representation ID: 50268
Respondent: Natural England
Natural England provided comments on the Councils’ Sustainability Appraisal (SA) Scoping Report in our letter dated 11 October 2019.
We are satisfied that the SA of Issues and Options report prepared by LUC (December 2019) has been prepared in a proper, logical and comprehensive manner and seeks to integrate the requirements of the Strategic Environmental Assessment (SEA) Directive, into the SA process. The approach to SA, as set out in the Scoping Report, including sustainability objectives, assessment methodology, consideration of relevant plans, policies and programmes and the SA framework appears to generally accord with the requirements of the Planning and Compulsory Purchase Act 2004. The report proposes to address relevant SA themes and topics relating to the natural environment including biodiversity and geodiversity, agriculture, open space provision, transport, air quality, water resources and resilience to climate change and flood risk.
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We welcome that the findings and recommendations of the HRA will inform the relevant aspects of the SA.
The SA considers the effects on key objectives of the following spatial distribution options for development:
Option 1: Densification;
Option 2: Edge of Cambridge – Outside the Green Belt including Cambridge Airport;
Option 3: Edge of Cambridge – Green Belt;
Option 4: Dispersal – new settlements.
Option 5: Dispersal – villages.
Option 6: Public transport corridors.
All options are assessed as having some degree of potential mixed negative and/or positive but uncertain effects on Objective 5 to conserve and enhance biodiversity, geodiversity and ecological networks. Option 2 is considered to present Biodiversity Opportunity Areas around the edge of the site, which could be used as a way to enhance the ecological networks present in the area, whilst also providing an opportunity to design in green infrastructure. Option 3 would put development in close proximity to a number of SSSIs and locally designated wildlife sites but may offer opportunities to design in green infrastructure, incorporating ecological networks, particularly at larger extensions. It is considered possible to avoid designated wildlife sites through Option 4 with opportunities to create a network of green infrastructure and biodiversity. Options 5 and 6 are predicted to have significant negative but uncertain effects with challenges to delivering integrated ecological networks.
Due to their urban nature options 1 and 2 are predicted to have a more positive effect on the protection of soils and agricultural land than the other options. Options 3, 4, 5 and 6 are considered likely to result in substantial development of greenfield land and loss of significant areas of BMV land.
At this stage of the SA process, and given the high level of the options, it is not possible to distinguish between the options with respect to water resources and waste water treatment capacity.
Natural England is unable to provide any detailed comments on the preliminary findings of the SA. We will be pleased to provide further comment as the detailed SA emerges, through preparation of the Local Plan and evidence documents including the Councils’ Green Infrastructure & Biodiversity and Integrated Water Study evidence documents. The evidence should be used to guide the most sustainable locations for development, prioritising avoidance of impacts to the natural environment including recreational pressure, air quality and water. We would also expect this to identify opportunities for development to implement significant enhancements to the ecological network. The delivery of enhancements should be secured through the relevant allocation and biodiversity policies.