Greater Cambridge Local Plan Preferred Options

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Comment

Greater Cambridge Local Plan Preferred Options

STRATEGY

Representation ID: 59964

Received: 13/12/2021

Respondent: Natural England

Representation Summary:

Natural England’s key comments
We are pleased that many of our comments at the Issues and Options stage are reflected in the First Proposals Plan, helping to strengthen the Plan’s approach to the ‘big themes’ including climate change, biodiversity and green spaces, wellbeing and social inclusion. Natural England supports the general thrust of the Plan in directing development to where it will have least environmental impact and provide opportunities for enhancements. We therefore welcome that the First Proposals Plan recognises the challenges in identifying long-term and interim solutions to the current water resource crisis to enable sustainable development without further detriment to the natural environment. We support the Plan’s progress, through the Green Infrastructure Recommendations (LUC, September 2021), in presenting opportunities for the Plan to deliver /contribute towards delivery of strategic green infrastructure. Notwithstanding the above, Natural England believes significant additional work is required through the next stages of Plan preparation to progress these ‘solutions’ and demonstrate that development can be delivered sustainably. We have major concerns with the scale of proposed Plan development, and the 2041 timeframe for delivery, given the damage already being inflicted on the natural environment and the lengthy lead-in time for identification and delivery of measures to address the water resource issue and to implement strategic green infrastructure.

Comment

Greater Cambridge Local Plan Preferred Options

STRATEGY

Representation ID: 59965

Received: 13/12/2021

Respondent: Natural England

Representation Summary:

We support the Plan vision and aims for decreases in our climate impacts and increase in quality of life for communities, minimising carbon emissions and reliance on the private car, increases in nature, wildlife, greenspaces and safeguarding landscapes focusing on what is unique to Greater Cambridge embracing bold new approaches. Natural England strongly recommends that the vision should advocate a more holistic approach to securing multi-functional benefits through the protection and enhancement of the natural environment.

Comment

Greater Cambridge Local Plan Preferred Options

S/DS: Development strategy

Representation ID: 59966

Received: 13/12/2021

Respondent: Natural England

Representation Summary:

We welcome that the new development strategy aims to meet our increased need for new homes in a way that minimises environmental impacts and improves the wellbeing of our communities. We support proposals to direct development to where it has the least climate impact, where active and public transport is the natural choice, where green infrastructure can be delivered alongside new development, and where jobs, services and facilities can be located near to where people live. The vision includes creating new city neighbourhoods which have the critical mass of homes, jobs and services to create thriving communities, making best use of brownfield and safeguarded land and making the most of public transport links. Natural England welcomes the use of evidence including the Employment Land and Economic Development Evidence Study and the Greater Cambridge Housing and Employment Relationships Report to understand the relationship between future jobs and housing growth. We support the proposal to gather evidence to consider the potential longer-term quantitative impacts of COVID19 prior to the Draft Plan stage.

Natural England has no objection in principle to the proposed Plan development strategy; however, this is subject to: 1) the identification of strategic water supply solutions and / or interim measures; and 2) development of deliverable strategic GI initiatives and developer requirements and funding mechanisms being secured through the Plan.

Transport Strategy
Natural England welcomes that the proposed strategy is heavily informed by the location of existing and committed public transport schemes. We support the use of transport modelling to understand whether additional infrastructure and policies are required to address the transport impacts of the preferred development strategy. Transport policies should include requirements for projects to undertake robust ecological impact assessment and application of the ecological mitigation hierarchy.

Comment

Greater Cambridge Local Plan Preferred Options

S/DS: Development strategy

Representation ID: 59968

Received: 13/12/2021

Respondent: Natural England

Representation Summary:

We welcome that the sustainability merits, opportunities and constraints for each of the nine potential strategy choices have been considered through the Sustainability Appraisal. Alongside considering the best locations for new homes and jobs, consideration has also been given to the best locations to restore the area’s habitat networks and provide more green spaces for people providing health and wellbeing benefits. Natural England fully supports the identification of 14 Strategic Green Infrastructure Initiatives, through the Green Infrastructure evidence, to help achieve this.

We support the general policy direction to focus development where it will have the least climate impact.

The local plan needs address delivery of sufficient level of accessible high quality green infrastructure and adequate sustainable water supply infrastructure.

Comment

Greater Cambridge Local Plan Preferred Options

STRATEGY

Representation ID: 59969

Received: 13/12/2021

Respondent: Natural England

Representation Summary:

Ensuring a deliverable plan – water supply
We welcome the Councils’ recognition that water supply is a significant issue for the deliverability of the Local Plan and we fully support preparation of the Integrated Water Management Study: Outline Water Cycle (WCS) by Stantec (August 2021) to address this.

Further development of the WCS, informed by evidence from regional and water company water resource plans, will need to demonstrate that appropriate deliverable mitigation measures can support sustainable growth until new strategic water supply infrastructure becomes operational. We agree with the Environment Agency that it in the face of current challenges it may be appropriate to consider an extended timeframe for delivery of Plan development to limit further environmental degradation until new strategic measures become available.

Comment

Greater Cambridge Local Plan Preferred Options

STRATEGY

Representation ID: 59970

Received: 13/12/2021

Respondent: Natural England

Representation Summary:

Duty to Cooperate
Natural England welcomes consideration of how the Plan fits with other plans and strategies including cross boundary projects such as the Ox Cam Arc. We support recognition of the Plan to be prepared within a wider regional context noting the Councils’ legal duty to cooperate with key stakeholders and surrounding areas of cross boundary issues. We agree that the development of a clear and positive vision for the future of the Greater Cambridge area can help to shape the proposals for the Ox Cam Arc, noting that the outcome of the Oxford-Cambridge framework is currently awaited. We particularly support the Councils’ recognition that the water supply challenge discussed above is a serious issue to be resolved.

Comment

Greater Cambridge Local Plan Preferred Options

S/DS: Development strategy

Representation ID: 59971

Received: 13/12/2021

Respondent: Natural England

Representation Summary:

Natural England has no objection in principle to the existing and new allocations, areas of major change or opportunity areas being taken forward for development. However, this is subject to:
• identification of strategic water supply infrastructure and/or feasible interim solutions to demonstrate that development can be delivered sustainably and without adverse impact to the natural environment;
• establishment of a framework and robust plan policies to deliver the 14 Strategic Green Infrastructure initiatives ahead of development, to meet development needs and to address the effects of recreational pressure on sensitive sites and habitats. The site allocation policies will need to include robust requirements to secure delivery of biodiversity net gain and on-site accessible green infrastructure to meet people’s need and to contribute towards the Plan’s 20% BNG targets and delivery of the Nature Recovery Network / Cambridge Nature Network. Our advice is that major allocation policies should set a framework for development to maximum opportunities for environmental gains.

Comment

Greater Cambridge Local Plan Preferred Options

Climate change

Representation ID: 59972

Received: 13/12/2021

Respondent: Natural England

Representation Summary:

We welcome the proposed policies relating to net zero carbon and water efficiency, designing for climate change, flooding and integrated water management, renewable energy projects, reducing waste and supporting land-based carbon sequestration.

Comment

Greater Cambridge Local Plan Preferred Options

CC/WE: Water efficiency in new developments

Representation ID: 59973

Received: 13/12/2021

Respondent: Natural England

Representation Summary:

We particularly support the proposed requirement for residential developments to be designed to achieve a standard of 80 litres/person/ day; however, we support the Environment Agency’s concerns as to whether the Plan is likely to achieve the reductions in demand required to support sustainable growth. As indicated above the WCS will need to demonstrate how water, to meet growth needs, will be supplied sustainably without adverse impact to the natural environment.

Comment

Greater Cambridge Local Plan Preferred Options

CC/FM: Flooding and integrated water management

Representation ID: 59974

Received: 13/12/2021

Respondent: Natural England

Representation Summary:

Proposed requirements for developments to provide integrated water management, including sustainable drainage systems (SuDS) where possible and for SuDS and green /brown roofs to provide multiple benefits (including biodiversity and amenity) are welcomed.

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