Greater Cambridge Local Plan Preferred Options

Whilst Cambridge Past, Present & Future appreciate the international significance of the Cambridge Biomedical Campus and the benefits of a centre of medical excellence on our doorstep, we nevertheless have reservations about the continued expansion of the CBC and OBJECT to this policy because it would cause a high level of harm to the green belt, loss of biodiversity (see attached report from John Meed) and increase flood risk.

Future growth of the Campus is constrained by the Gog Magog Hills. The hills are arguably the most important landscape area on the city fringes and it is generally agreed that any development of the slopes would be unacceptable. Not only that but building right up to the slopes will also have significant detrimental visual impacts. This raises a fundamental question about the longer term.

If the campus does continue to expand then where will it expand if there is no acceptable land adjacent to the Campus? The answer is a new campus in a different location. If that is the long-term future, then why not address it now rather than encroaching on an important part of the green belt? Has that option been considered as part of the plan making process?

Given that future land for the campus in this location is likely to be highly constrained we challenge whether any residential provision should be made and we would also argue that a more rigorous set of criteria should be agreed so that new enterprises and activities have to demonstrate why co-location within the Campus is absolutely essential for their operation. Co-location would be desirable for any biomedical company, but is it crucial to the effective operation of that company?

Notwithstanding our objection in principle to this policy, we comment specifically on the proposal:
• "Significant Green Belt enhancement in adjoining areas of White Hill and Nine Wells will be required, to provide green infrastructure and biodiversity improvements supporting the objectives of the Strategic Initiative 3: Gog Magog Hills and chalkland fringe. These areas would remain within the Green Belt and are included in the Area of Major Change to highlight that future proposals for built development on the allocated areas must also include green infrastructure and biodiversity improvements within its adjoining open area."

We welcome this approach. Some of the previous attempts to mitigate the impacts of development through green infrastructure and public access improvements through Area Action Plans and similar have failed because they have been considered aspirational rather than contingent. Policy drafting must ensure that:

i). Any development is contingent on green infrastructure and biodiversity improvements in the adjoining area.

ii). The scale and type of improvements are spelt out clearly so that both the developer and community understand what is expected.

We are attaching with our submission a report by John Meed who has been studying farmland birds on this land for the past ten years. He reports that “At first sight the area I study may appear unlikely to support high levels of biodiversity. However, in practice it is home to remarkable populations of threatened farmland birds, all red-listed species of high conservation concern, as well as the equally endangered water voles, brown hare, and a good range of other birds, mammals, arable plants, butterflies, dragonflies and other invertebrates.” John’s report highlights that many of these species would be impacted not just by the development but potentially by future landscape and biodiversity plans. He proposes that in addition to the land identified at White Hill and Nine Wells that additional work would be needed on adjacent farmland to mitigate the impact on farmland wildlife.

In relation to the statement:
• No development will be permitted south of Granham’s Road. However there may be potential to realign the eastern end of Granham’s Road to a point no further south than the southern boundary of the Wort’s Causeway development to the east of Babraham Road, subject to achieving an acceptable junction arrangement, with the Green Belt boundary following the line of the road. The additional area that may be created by realigning Granham’s Road is shown as a separate area at this stage, and will be explored further, with the boundary to be defined in the draft Local Plan.
We note that the realignment of the road would result in further loss of 5-6 acres of greenbelt to development because Granham’s Road (the green belt boundary) would effectively be moved south.

In relation to the following points
• To retain a green corridor through the development to link the countryside with Coldham’s Common and the heart of Cambridge, that lies within the and has a landscaping, biodiversity and recreation function whilst also maintaining the individual identity of Teversham village.
• within the site, and green infrastructure within and adjoining the area, including providing additional wildlife habitat land surrounding the designated nature sites to the east of Cambridge, as part of the Eastern Fens green infrastructure initiative.
Whilst we strongly support this approach in general, the relationship between the Cambridge Airport site, the adjacent countryside, future green space provision and future transport provision is complex. There is significant risk of recreational disturbance (harm) to nationally important species and designated nature conservation sites and this does not appear to be recognised. There are also differing ideas on where future “country park” type provision should be made in order to divert pressure from ecologically sensitive sites and also to tie in with plans of environmental NGO’s. In our view, significant work is still required in order to resolve these challenges and we are concerned that the best solution should not be constrained by over-simple policy statements and over simple maps included in the Local Plan. We are attaching a letter that we sent to Marshall’s in 2020 which sets out some of our views in relation to the future development of this site. We would welcome continued dialogue on this matter as the draft Local Plan is prepared.

We also believe that the future of the S/AMC/Policy 16: South of Coldham’s Lane should be linked to Policy S/CE: Cambridge East. It is our view that the challenge (and costs) associated with bringing Coldham’s Lakes into public use as a park is only likely to be viable as part of the Cambridge Airport development. Indeed, one of the main user groups of a new Coldham’s Lakes Park would be the future residents of the airport. The lakes could also divert recreational pressure from other more sensitive ecological sites.

CambridgePPF support the proposed policy direction. To meet the identified role of Cambourne it is suggested that the policy include:
• Safeguarding of employment and services and facilities within the settlement and to prevent gradual loss of sites to residential.
• Supporting text/policy could set a modal shift from private cars to public transport, walking and cycling.
• The design concept of walkable neighbourhoods.

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

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

The same principles should be applied to this green belt release as for Policy S/CBC: Cambridge Biomedical Campus, namely that “National Planning policy requires that the impact of removing land from the Green Belt to be offset through compensatory improvements to the environmental quality and accessibility of remaining Green Belt land”.

The Preferred Options documents do not seem to recognise that this site is located within the Cambridge Nature Network (www.cambridgenaturenetwork.org) and that it is adjacent to two strategic green infrastructure areas making it an important site (Green Infrastructure Strategic Initiatives: Gog Magog Hills (3) and River Cam Corridor (2c)). We would expect the proposals in the policy area to reflect this with a very strong emphasis on biodiversity enhancement within or adjacent to the grounds of the campus combined with better public access/benefits. We note that google earth seems to show an area of exposed chalk in the south-west corner which could provide an opportunity for ecological restoration of priority calcareous grassland habitat.

The proposals for this policy area must recognise that the area identified for development would be on much higher ground than those buildings that have already been built on the campus (which are sunk into the hillside). This location is sensitive in landscape character terms, being visible from the higher ground of the Gog Magog Hills, including from the Roman Road Schedule Ancient Monument. There is a potential conflict between the development of this site and policies designed to protect landscape character. To be acceptable in planning terms, any new buildings would need to be below tree height as viewed from the Gog Magog Hills (including any chimneys or rooftop plant), they should also be designed to blend into the landscape when viewed at distance.

One of the newer buildings on the campus has already had a very negative impact on landscape which is contrary to planning policy and, in our view, should not have been granted permission (see attached photos taken from a public right of way on the Gog Magog Hills). We request that before any future development of the site takes place there is a requirement for retrospective action to screen this building and/or better blend it into the landscape when viewed at distance.

S/RSC/HW Land between Hinton Way and Mingle Lane, Great Shelford
Cambridge Past, Present & Future OBJECTS to this policy because it would cause a moderate high level of harm to the green belt. We see no evidence that 100 houses could not be provided outside the green belt and therefore this site does not pass the “exceptional circumstances” test. We do not believe that being close to a rail station qualifies for “exceptional circumstances” either.

It is obvious that the development of this site would lead to increased development pressure on the other fields in this location and therefore it undermines the green belt. Indeed, it seems that the longer-term intention of the Planning Department is for further green belt release in this location, this is evidenced by: “open space to be provided to the east of the built development to help provide compensatory improvements to the environmental quality and accessibility of remaining Green Belt.” There is also green belt to the north (indeed that is the longer boundary and the one viewed from higher ground) and therefore if the intention was to contain the development there would be a requirement for public space/green belt mitigation for both the northern and eastern boundaries.

The justification for this site seems to be that it is close to Great Shelford station. However, this means that the new dwellings will appeal to London commuters and therefore there is a high risk that the new housing does not support the new jobs creation set out in the Plan, but instead further exacerbates local housing shortage.

S/RRA/SAS
Support Policy requirement to ensure that strong landscaping is provided to help the site fit into the surrounding rural countryside character.

Notwithstanding our comment above, whilst this is a good location for a regional distribution centre it cannot meet the aspiration that “last mile delivery” in Cambridge can be carried out by sustainable modes of transport (smaller electric vehicles, cargo bikes, etc). This would not be possible from this location.

S/RRA/OHD
Support policy requirement to ensure enhanced landscaping on its open boundaries and avoidance of any impact on the settings of the Grade 1 listed church and conservation area.

As the plan progresses, you need to ensure that it references and is based on the latest government targets. Technology, standards and targets will continue to change rapidly during the period of the plan and so the plan will need to include mechanisms to ensure that policies and supplementary policies can keep pace.

Agree that development should be located so that low carbon transport links can be accessed. However, such locations should not be chosen based on proposed busways – the delivery of these is uncertain and their construction generates carbon emissions through the embodied carbon in the building materials, tree felling reducing carbon capture, maintenance and serving works, and lighting, contrary to the Council’s net zero carbon agenda. The majority of the busways are also in the green belt.

The policy should reference that the targets prioritise a fabric first approach which involves maximising the performance of the construction components and materials making up the building fabric before the use of mechanical and electrical building systems. This can help reduce capital and operational costs, improve energy efficiency and reduce carbon emissions. The fabric first approach minimises the need for energy consumption through air-tightness, super high insulation, solar gain, natural ventilation, the thermal mass of the building fabric, using energy from occupants, electronic devices etc. Focussing on the building fabric first, is generally considered to be more sustainable than relying on energy saving technology, or renewable energy generation, which can be expensive, can have a high embodied energy and may or may not be used efficiently by the consumer.

We support a policy which aims to achieve more than Building Regulations and Future Homes/building standards.

We support a policy direction which recognises embodied carbon. However, it is noted that embodied carbon is not included in all of the findings of the evidence base (Net zero carbon study (2021)). This undermines the claims made about the sustainability of new development and raises questions about the claimed sustainability credentials of the preferred growth option.

Cambridge Past, Present & Future strongly supports the proposals to require, by planning condition, whole-life assessment of carbon, including embodied carbon, construction, and building disposal through circular economy.

Cambridge Past, Present & Future welcomes the proposals in the LUC supporting report, to require limitations in terms of planned kWhr/m2/day; we particularly welcome the detail given for different types of development. Clearly these requirements can only be guidelines in the assessment of building design at Detailed Planning Application stage but they are valuable in themselves and as markers to sustainability requirement.

CambridgePPF support a policy which recognises the level of water stress in our area and which is achieving more than building regulations.

Our members questioned whether low water use targets can be met through design and construction methods alone, given that there are no restrictions on how much water people can use.