Greater Cambridge Local Plan Preferred Options

The importance the plan places on climate change and the achievement of net zero status by 2050 is supported, recognising NPPF (2021) Paragraph 153, which requires plans to take a proactive approach to mitigating and adapting to climate change.

The First Proposals document states that the spatial strategy has been informed by carbon assessment that highlights the impact that transport emissions can have, and promotes patterns of development that enable low carbon transport modes, shifting away from a reliance on the private car. Many of the rural settlements, despite being a lower order in the settlement hierarchy, are sustainably located on public transport networks, as well as having good access to local services, facilities and employment opportunities. Land West of London Road, Fowlmere benefits from local employment, primary school, village hall, recreation ground and places of worship and is also serviced by two bus services, providing frequent links to Cambridge as well as other sustainable settlements that benefit from train stations.

In adapting to climate change, it should be noted that well-designed new residential development can contribute to carbon offsetting through tree planting, and the delivery of sustainable technologies such as water reduction, solar panels, ground source heat pumps, high levels of installation, improved lighting and other measures, whilst encouraging existing and new communities to adopt more sustainable methods of travel, including the provision of attractive open spaces and green linkages to encourage walking and cycling.

The provision of Sustainable Drainage Systems within new development can also alleviate existing fluvial and pluvial flood issues.

Land West of London Road, Fowlmere is proposed to contribute to carbon offsetting through the provision of a landscape strategy, including additional tree planting, provision of sustainable drainage systems that are multi-functional, and delivering an attractive open space in the form of a village park. The proposed development would also deliver low carbon housing, electric vehicle charging at every dwelling and promote low water consumption, therefore proactively mitigating the effects of climate change through reducing overall carbon emissions.

Climate change policy should not be overly prescriptive such that it provides a barrier to sustainable development. It should also be acknowledged that technologies are constantly changing. For example, the shift to electric vehicles significantly reduces the carbon footprint of the private car and the introduction of new sustainable technologies such as water reduction, solar panels, ground source heat pumps, high levels of installation and improved lighting, all of which contribute to sustainability and reducing carbon footprint. Therefore, policies should enable flexibility to accommodate evolution in technology and way of life.

The importance of climate change and the achievement of net zero status by 2050 is supported, recognising NPPF Paragraph 153, which requires plans to take a proactive approach to mitigating and adapting to climate change.
The First Proposals document states that the spatial strategy has been informed by carbon assessment that highlights the impact that transport emissions can have, and promotes patterns of development that enable low carbon transport modes, shifting away from a reliance on the private car. Many of the rural settlements, despite being a lower order in the settlement hierarchy, are sustainably located on public transport networks, as well as having good access to local services, facilities and employment opportunities.
Land East side of Cambridge Road, Melbourn offers an opportunity to deliver much needed growth to the settlement, to support local housing need and enhance social cohesion. The site is in a sustainable location, in proximity to services and facilities and is available for development. It is considered that development within this location will encourage future occupiers to adopt sustainable modes of transport, including walking, thereby contributing to supporting healthy lifestyles and seeking to mitigate the impacts of climate change.
In adapting to climate change, it should be noted that well-designed new residential development can contribute to carbon offsetting through tree planting and the delivery of sustainable technologies such as water reduction, solar panels, ground source heat pumps, high levels of installation, improved lighting and other measures, whilst encouraging existing and new communities to adopt more sustainable methods of travel, including the provision of attractive open spaces and green linkages to encourage walking and cycling.
The provision of Sustainable Drainage Systems within new development can also alleviate existing fluvial and pluvial flood issues.
Climate change policy should not be overly prescriptive such that it provides a barrier to sustainable development. It should also be acknowledged that technologies are constantly changing. For example, the shift to electric vehicles significantly reduces the carbon footprint of the private car. Therefore, policies should enable flexibility to accommodate evolution in technology and way of life.

This policy will require residential developments of 150 homes or more to calculate whole life carbon emissions through a nationally recognised Whole Life Carbon Assessment and demonstrate actions to reduce life-cycle emissions.
The principle of this Policy is not necessarily disputed, and it is supported that the First Proposals include reference to climate change.
We note in the accompanying Aspinell Verdi Viability Assessment (2021) that a “net zero carbon cost has been explicitly included in the appraisals” and this is welcomed. It is understood that the additional costs included allow for installation of a heat pump, mechanical ventilation with heat recovery (MVHR) and photovoltaics, with the costs allowed for as follows:
• Semi-detached house: £12,880 (10% increase on cost);
• Mid-terrace: £13,985 (13% increase on cost);
• Flats: £7,568 – based on 40 flats (5% increase on cost).
It is unclear whether in all instances installation of a heat pump, mechanical ventilation with heat recovery (MVHR) and photovoltaics will be sufficient to demonstrate a net zero carbon cost as this will vary from development to development, and therefore whether sufficient cost.

This policy will require residential developments of 150 homes or more to calculate whole life carbon emissions through a nationally recognised Whole Life Carbon Assessment and demonstrate actions to reduce life-cycle emissions.

The principle of this Policy is not necessarily disputed, and it is supported that the First Proposals include reference to climate change.

We note that a net zero carbon cost has been explicitly included in the appraisals and this is welcomed. It is understood that the additional costs included allow for installation of a heat pump, mechanical ventilation with heat recovery (MVHR) and photovoltaics, with the costs allowed for as follows:

• Semi-detached house: £12,880 (10% increase on cost);
• Mid-terrace: £13,985 (13% increase on cost);
• Flats: £7,568 – based on 40 flats (5% increase on cost).

It is unclear whether in all instances installation of a heat pump, mechanical ventilation with heat recovery (MVHR) and photovoltaics will be sufficient to demonstrate a net zero carbon cost as this will vary from development to development, and therefore whether sufficient cost has been allowed for through the viability study to accommodate for this Policy requirement.

Policy CC/WE requires developments to meet high standards of water efficiency, with residential development designed to achieve a standard of 80 litres/person/day unless demonstrate impracticable.
It is acknowledged that there are issues with current over-abstraction of the Chalk aquifer and this is having a detrimental impact on environmental conditions. It is also understood that, to address this, Greater Cambridge are seeking to adhere to ambitious water efficiency targets.
The Aspinall Verdi Viability Study (2021) states that an “extra over cost has been included for additional water standards costs with reference to Code for Sustainable Homes levels 5 and 6 (Housing Standards Review Cost Impacts report, DCLG 2014). Baseline allowance of £9 per unit to Code levels 3 & 4, and £2,697 to achieve Code levels 5 & 6 based on Department of Communities and Local Government Housing Standards Review Cost Impact, September 2014 by EC Harris.”
It is noted that these cost figures are greater than 7 years out of date, and whilst it is welcomed that these figures have been subsequently index linked, resulting in a combined figure of £3,109 per dwelling, the industry as a whole has noted that build cost and the cost of materials has significantly increased in recent years. We recommend that these figures are updated (rather than being index linked) to ensure that the evidence is robust and therefore meets the tests of soundness.
We remain concerned, therefore, whether a 2% uplift represents a sufficient increase in build costs to allow for the delivery of CC/WE.
Notwithstanding this, whilst it is clearly desirable for new development to achieve the highest possible water efficiency, the mandatory national standard set out in the Building Regulations is 125 litres/person/day. NPPG Paragraph 56-014-20150327 states that where there is a clear local need, Local Plan policies can require a tighter optional requirement of 110 litres/person/day.
The Councils’ acknowledge that the 80 litres/person/day goes beyond what Local Authorities are currently able to require but considers there is a strong case for greater water efficiency in Greater Cambridge based upon strong evidence provided by the Integrated Water Management Study. This would make full use of water efficient fixtures and fittings, water reuse measures on site including surface water and rainwater harvesting, and grey water recycling. It acknowledges that the cost effectiveness improves with the scale of the project.
The Councils’ 80 litres/person/day target is not considered realistic. Instead, it is considered that the tighter optional requirement of 110 litres/person/day should be encouraged. It may be appropriate to set tighter standards for certain site allocations but a blanket requirement of 80 litres/person/day is not realistic.

The Greater Cambridgeshire Local Plan is supported by a Greater Cambridge Local Plan Strategic Spatial Options Assessment (November 2020).
The Assessment identifies that current over-abstraction of the Chalk aquifer is having a detrimental impact on environmental conditions. It acknowledges that none of the Councils’ growth strategies offer an opportunity to mitigate the existing detrimental impacts and there is no environmental capacity for additional development in the new Local Plan to be supplied with water by increased abstraction from the Chalk aquifer.
Major new water supply infrastructure is proposed and will be operational in mid-2030s, however, development in the interim will need to reduce abstraction through the implementation of ambitious targets for water efficiency. Such targets will be required to be addressed across all new developments.
It is understood that all development within Greater Cambridgeshire will need to adhere to such ambitious water efficiency targets and therefore there is no growth strategy that has a lesser water usage impact than another.
In so far as utilising recycling systems, the Assessment suggests that large sites are able to successfully use recycling to reduce demand for potable water. We disagree with this statement. Whilst retrofitting developments may be expensive, new development (regardless of scale) is able to adopt rainwater recycling systems. It is unclear why the statement specifically restricts water recycling usage to “large developments”. Land to the East Side of Cambridge Road, Melbourn, is able to adopt a rainwater recycling system if this is a requirement set by Local Policy.
The Assessment also identifies the potential for introducing flood management and SuDS schemes to deliver multifunctional benefits including biodiversity enhancements. Land to the East Side of Cambridge Road, Melbourn presents an opportunity for delivering a scheme which includes SuDS that provide multifunctional benefits including an opportunity to benefit and enhance designated wildlife sites.
Overall, however, the Assessment recommends that growth should be concentrated in new settlements or urban extensions that avoid high flood risk and have high standards for the design of flood risk management, water usage and re-use, and blue-green infrastructure.
This recommendation follows a Location Opportunities and Constraints Categorisation and Scoring which assesses and score each of the proposed growth strategies.
Minor Rural Centres (including Melbourn) are assessed as having a red rating for flood risk due to potential existing fluvial flood and surface water flood risk. Wastewater and Quality are assessed as amber, subject to local WRC capacity. The red flood risk rating is despite Paragraph 4.2.1 of the Assessment stating “flood risk does not differentiate between the growth scenarios”.
Land to the East Side of Cambridge Road, Melbourn is located within Flood Zone 1 with low risk of surface water flooding. In this regard the Site should be assessed as having a Green or Amber Flood Risk rating. In either instances, the Site should be given a total constraints score of -6. This score would result in the same overall scoring as the proposed recommended growth strategy of locating growth within new settlements or urban extensions. This amendment would also introduce the summary of “Good Opportunities”, thereby also improving the overall combined constraints and opportunities score for development within Minor Rural Centres and Group Villages.
It is therefore disputed as to why development within the Minor Rural Centres and Group Villages have been disregarded as an appropriate growth strategy if they are able to meet the ambitious water usage targets and implement water recycling systems.

Policy CC/WE requires developments to meet high standards of water efficiency, with residential development designed to achieve a standard of 80 litres/person/day unless demonstrated to be impracticable.

It is acknowledged that there are issues with current over-abstraction of the Chalk aquifer and this is having a detrimental impact on environmental conditions. It is also understood that, to address this, Greater Cambridge are seeking to adhere to ambitious water efficiency targets.

The Aspinal Verdi Viability Study (2021) states that an “extra over cost has been included for additional water standards costs with reference to Code for Sustainable Homes levels 5 and 6 (Housing Standards Review Cost Impacts report, DCLG 2014). Baseline allowance of £9 per unit to Code levels 3 & 4, and £2,697 to achieve Code levels 5 & 6 based on Department of Communities and Local Government Housing Standards Review Cost Impact, September 2014 by EC Harris.”

It is noted that these cost figures are greater than 7 years out of date, and whilst it is welcomed that these figures have been subsequently index linked, resulting in a combined figure of £3,109 per dwelling, the industry as a whole has noted that build cost and the cost of materials has significantly increased in recent years. We recommend that these figures are updated (rather than being index linked) to ensure that the evidence is robust and therefore meets the tests of soundness.

We remain concerned, therefore, whether a 2% uplift represents a sufficient increase in build costs to allow for the delivery of CC/WE.

Notwithstanding this, whilst it is clearly desirable for new development to achieve the highest possible water efficiency, the mandatory national standard set out in the Building Regulations is 125 litres/person/day. NPPG Paragraph 56-014-20150327 states that where there is a clear local need, Local Plan policies can require a tighter optional requirement of 110 litres/person/day.

The Councils’ acknowledge that the 80 litres/person/day goes beyond what Local Authorities are currently able to require but considers there is a strong case for greater water efficiency in Greater Cambridge based upon strong evidence provided by the Integrated Water Management Study. This would make full use of water efficient fixtures and fittings, water reuse measures on site including surface water and rainwater harvesting, and grey water recycling. It acknowledges that the cost effectiveness improves with the scale of the project.

The Councils’ 80 litres/person/day target is not considered realistic. Instead, it is considered that the tighter optional requirement of 110 litres/person/day should be encouraged. It may be appropriate to set tighter standards for certain site allocations but a blanket requirement of 80 litres/person/day is not realistic.

Greater Cambridge Local Plan Strategic Spatial Options Assessment (November 2020)
The Greater Cambridgeshire Local Plan is supported by a Greater Cambridge Local Plan Strategic Spatial Options Assessment (November 2020).

The Assessment identifies that current over-abstraction of the Chalk aquifer is having a detrimental impact on environmental conditions. It acknowledges that none of the Councils’ growth strategies offer an opportunity to mitigate the existing detrimental impacts and there is no environmental capacity for additional development in the new Local Plan to be supplied with water by increased abstraction from the Chalk aquifer.

Major new water supply infrastructure is proposed and will be operational in mid-2030s, however, development in the interim will need to reduce abstraction through the implementation of ambitious targets for water efficiency. Such targets will be required to be addressed across all new developments.

It is understood that all development within Greater Cambridgeshire will need to adhere to such ambitious water efficiency targets and therefore there is no growth strategy that has a lesser water usage impact than another.
In so far as utilising recycling systems, the Assessment suggests that large sites are able to successfully use recycling to reduce demand for potable water. We disagree with this statement. Whilst retrofitting developments may be expensive, new development (regardless of scale) is able to adopt rainwater recycling systems. It is unclear why the statement specifically restricts water recycling usage to “large developments”. Land West of London Road, Fowlmere, is able to adopt a rainwater recycling system if this is a requirement set by Local Policy.
The Assessment also identifies the potential for introducing flood management and SuDS schemes to deliver multifunctional benefits including biodiversity enhancements. Land West of London Road, Fowlmere presents an opportunity for delivering a scheme which includes SuDS that provide multifunctional benefits including an opportunity to benefit and enhance designated wildlife sites.

Overall, however, the Assessment recommends that growth should be concentrated in new settlements or urban extensions that avoid high flood risk and have high standards for the design of flood risk management, water usage and re-use, and blue-green infrastructure.

This recommendation follows a Location Opportunities and Constraints Categorisation and Scoring which assesses and score each of the proposed growth strategies.

Minor Rural Centres (including Melbourn) and Group Villages (including Fowlmere) is assessed as having a red rating for flood risk due to potential existing fluvial flood and surface water flood risk. Wastewater and Quality are assessed as amber, subject to local WRC capacity. The red flood risk rating is despite Paragraph 4.2.1 of the Assessment stating “flood risk does not differentiate between the growth scenarios”.

Land West of London Road, Fowlmere is located within Flood Zone 1 with low risk of surface water flooding, which is a sequentially preferable location for development as supported by the NPPF (2021). In this regard the Site should be assessed as having a Green or Amber Flood Risk rating. In either instances, this Site should be given a total constraints score of -6. This score would result in the same overall scoring as the proposed recommended growth strategy of locating growth within new settlements or urban extensions. This amendment would also introduce criterion “Good opportunities”, thereby also improving the overall combined constraints and opportunities score for development within Minor Rural Centres and Group Villages.

It is therefore disputed as to why development within the Minor Rural Centres and Group Villages have been disregarded as an appropriate growth strategy if they are able to meet the ambitious water usage targets and implement water recycling systems.

Draft Policy CC/DC requires all development to adopt a design led approach to climate change adaptation with approaches integrated into architectural design. The draft Policy includes a hierarchy, which commences at Passive design as a preference, with full building mechanical ventilation/cooling system with lowest preference.
We support this Policy and acknowledge the importance of recognising how development and construction methods can positively contribute to reduce the impacts of climate change.

It is noted that the Aspinall Verdi Viability Study which accompanies the Draft Local Plan states that to meet Policy CC/DC no additional build cost has been included for in the viability assessment, with Aspinall Verdi stating that they “assume that the heat mitigation can be built into the design at no additional cost”.

Whilst there may be scope to introduce some passive design through materials, the hierarchy also includes mechanical ventilation. Mechanical Ventilation is not included within typical build cost, and we therefore raise concerns whether the Plan viability has accounted for sufficient costs to fully deliver this Policy across all developments within Greater Cambridge.

Policy CC/WE requires developments to meet high standards of water efficiency, with residential development designed to achieve a standard of 80 litres/person/day unless demonstrate impracticable.
It is acknowledged that there are issues with current over-abstraction of the Chalk aquifer and this is having a detrimental impact on environmental conditions. It is also understood that, to address this, Greater Cambridge are seeking to adhere to ambitious water efficiency targets.
The Aspinall Verdi Viability Study (2021) states that an “extra over cost has been included for additional water standards costs with reference to Code for Sustainable Homes levels 5 and 6 (Housing Standards Review Cost Impacts report, DCLG 2014). Baseline allowance of £9 per unit to Code levels 3 & 4, and £2,697 to achieve Code levels 5 & 6 based on Department of Communities and Local Government Housing Standards Review Cost Impact, September 2014 by EC Harris.”
It is noted that these cost figures are greater than 7 years out of date, and whilst it is welcomed that these figures have been subsequently index linked, resulting in a combined figure of £3,109 per dwelling, the industry as a whole has noted that build cost and the cost of materials has significantly increased in recent years. We recommend that these figures are updated (rather than being index linked) to ensure that the evidence is robust and therefore meets the tests of soundness.
We remain concerned, therefore, whether a 2% uplift represents a sufficient increase in build costs to allow for the delivery of CC/WE.
Notwithstanding this, whilst it is clearly desirable for new development to achieve the highest possible water efficiency, the mandatory national standard set out in the Building Regulations is 125 litres/person/day. NPPG Paragraph 56-014-20150327 states that where there is a clear local need, Local Plan policies can require a tighter optional requirement of 110 litres/person/day.
The Councils’ acknowledge that the 80 litres/person/day goes beyond what Local Authorities are currently able to require but considers there is a strong case for greater water efficiency in Greater Cambridge based upon strong evidence provided by the Integrated Water Management Study. This would make full use of water efficient fixtures and fittings, water reuse measures on site including surface water and rainwater harvesting, and grey water recycling. It acknowledges that the cost effectiveness improves with the scale of the project.
The Councils’ 80 litres/person/day target is not considered realistic. Instead, it is considered that the tighter optional requirement of 110 litres/person/day should be encouraged. It may be appropriate to set tighter standards for certain site allocations but a blanket requirement of 80 litres/person/day is not realistic.

The Greater Cambridgeshire Local Plan is supported by a Greater Cambridge Local Plan Strategic Spatial Options Assessment (November 2020).
The Assessment identifies that current over-abstraction of the Chalk aquifer is having a detrimental impact on environmental conditions. It acknowledges that none of the Councils’ growth strategies offer an opportunity to mitigate the existing detrimental impacts and there is no environmental capacity for additional development in the new Local Plan to be supplied with water by increased abstraction from the Chalk aquifer.
Major new water supply infrastructure is proposed and will be operational in mid-2030s, however, development in the interim will need to reduce abstraction through the implementation of ambitious targets for water efficiency. Such targets will be required to be addressed across all new developments.
It is understood that all development within Greater Cambridgeshire will need to adhere to such ambitious water efficiency targets and therefore there is no growth strategy that has a lesser water usage impact than another.
In so far as utilising recycling systems, the Assessment suggests that large sites are able to successfully use recycling to reduce demand for potable water. We disagree with this statement. Whilst retrofitting developments may be expensive, new development (regardless of scale) is able to adopt rainwater recycling systems. It is unclear why the statement specifically restricts water recycling usage to “large developments”. Land to the East Side of Cambridge Road, Melbourn, is able to adopt a rainwater recycling system if this is a requirement set by Local Policy.
The Assessment also identifies the potential for introducing flood management and SuDS schemes to deliver multifunctional benefits including biodiversity enhancements. Land to the East Side of Cambridge Road, Melbourn presents an opportunity for delivering a scheme which includes SuDS that provide multifunctional benefits including an opportunity to benefit and enhance designated wildlife sites.
Overall, however, the Assessment recommends that growth should be concentrated in new settlements or urban extensions that avoid high flood risk and have high standards for the design of flood risk management, water usage and re-use, and blue-green infrastructure.
This recommendation follows a Location Opportunities and Constraints Categorisation and Scoring which assesses and score each of the proposed growth strategies.
Minor Rural Centres (including Melbourn) are assessed as having a red rating for flood risk due to potential existing fluvial flood and surface water flood risk. Wastewater and Quality are assessed as amber, subject to local WRC capacity. The red flood risk rating is despite Paragraph 4.2.1 of the Assessment stating “flood risk does not differentiate between the growth scenarios”.
Land to the East Side of Cambridge Road, Melbourn is located within Flood Zone 1 with low risk of surface water flooding. In this regard the Site should be assessed as having a Green or Amber Flood Risk rating. In either instances, the Site should be given a total constraints score of -6. This score would result in the same overall scoring as the proposed recommended growth strategy of locating growth within new settlements or urban extensions. This amendment would also introduce the summary of “Good Opportunities”, thereby also improving the overall combined constraints and opportunities score for development within Minor Rural Centres and Group Villages.
It is therefore disputed as to why development within the Minor Rural Centres and Group Villages have been disregarded as an appropriate growth strategy if they are able to meet the ambitious water usage targets and implement water recycling systems.

Draft Policy CC/DC requires all development to adopt a design led approach to climate change adaptation with approaches integrated into architectural design. The draft Policy includes a hierarchy, which commences at Passive design as a preference, with full building mechanical ventilation/cooling system with lowest preference.
We support this Policy and acknowledge the importance of recognising how development and construction methods can positively contribute to reduce the impacts of climate change.
We question, however, whether a sufficient costs has been attributed within the Plan’s Viability Study to enable comprehensive delivery of this Policy. It is noted that the Aspinall Verdi Viability Study which accompanies the Draft Local Plan states that to meet Policy CC/DC no additional build cost has been included for in the viability assessment, with Aspinall Verdi stating that they “assume that the heat mitigation can be built into the design at no additional cost”.
Whilst there may be scope to introduce some passive design through materials, the hierarchy also includes mechanical ventilation. Mechanical Ventilation is not included within typical build cost, and we therefore raise concerns whether the Plan viability has accounted for sufficient costs to fully deliver this Policy across all developments within Greater Cambridge.
Notwithstanding this, Land to the East Side of Cambridge Road, Melbourn offers the opportunity to deliver a scheme that is located in proximity to sustainable modes of transport thereby promoting the use of more sustainable modes of transport and mitigating the impact of climate change. A future scheme will also be designed in a way to ensure that climate change adaption is integrated into the scheme’s design.
The residential elements of the scheme will deliver low carbon housing and benefit from electric charging points, promoting the use of electric vehicles. In accordance with the aspirations of the Greater Cambridge emerging Local Plan, low water consumption will also be promoted to reduce water usage and positively contribute to water recycling where possible.

Policy CC/FM states that development will be directed to the areas with the least likelihood of flooding from all sources and taking into account climate change. The Policy also states that development will be required to provide integrated water management, including SuDS. Land West of London Road, Fowlmere proposes to include SuDS and will adhere to Policy CC/FM.

Greater Cambridge Local Plan Strategic Spatial Options Assessment (November 2020)
The Greater Cambridgeshire Local Plan is supported by a Greater Cambridge Local Plan Strategic Spatial Options Assessment (November 2020).

The Assessment identifies that current over-abstraction of the Chalk aquifer is having a detrimental impact on environmental conditions. It acknowledges that none of the Councils’ growth strategies offer an opportunity to mitigate the existing detrimental impacts and there is no environmental capacity for additional development in the new Local Plan to be supplied with water by increased abstraction from the Chalk aquifer.

Major new water supply infrastructure is proposed and will be operational in mid-2030s, however, development in the interim will need to reduce abstraction through the implementation of ambitious targets for water efficiency. Such targets will be required to be addressed across all new developments.

It is understood that all development within Greater Cambridgeshire will need to adhere to such ambitious water efficiency targets and therefore there is no growth strategy that has a lesser water usage impact than another.
In so far as utilising recycling systems, the Assessment suggests that large sites are able to successfully use recycling to reduce demand for potable water. We disagree with this statement. Whilst retrofitting developments may be expensive, new development (regardless of scale) is able to adopt rainwater recycling systems. It is unclear why the statement specifically restricts water recycling usage to “large developments”. Land West of London Road, Fowlmere, is able to adopt a rainwater recycling system if this is a requirement set by Local Policy.
The Assessment also identifies the potential for introducing flood management and SuDS schemes to deliver multifunctional benefits including biodiversity enhancements. Land West of London Road, Fowlmere presents an opportunity for delivering a scheme which includes SuDS that provide multifunctional benefits including an opportunity to benefit and enhance designated wildlife sites.

Overall, however, the Assessment recommends that growth should be concentrated in new settlements or urban extensions that avoid high flood risk and have high standards for the design of flood risk management, water usage and re-use, and blue-green infrastructure.

This recommendation follows a Location Opportunities and Constraints Categorisation and Scoring which assesses and score each of the proposed growth strategies.

Minor Rural Centres (including Melbourn) and Group Villages (including Fowlmere) is assessed as having a red rating for flood risk due to potential existing fluvial flood and surface water flood risk. Wastewater and Quality are assessed as amber, subject to local WRC capacity. The red flood risk rating is despite Paragraph 4.2.1 of the Assessment stating “flood risk does not differentiate between the growth scenarios”.

Land West of London Road, Fowlmere is located within Flood Zone 1 with low risk of surface water flooding, which is a sequentially preferable location for development as supported by the NPPF (2021). In this regard the Site should be assessed as having a Green or Amber Flood Risk rating. In either instances, this Site should be given a total constraints score of -6. This score would result in the same overall scoring as the proposed recommended growth strategy of locating growth within new settlements or urban extensions. This amendment would also introduce criterion “Good opportunities”, thereby also improving the overall combined constraints and opportunities score for development within Minor Rural Centres and Group Villages.

It is therefore disputed as to why development within the Minor Rural Centres and Group Villages have been disregarded as an appropriate growth strategy if they are able to meet the ambitious water usage targets and implement water recycling systems.