Draft Greater Cambridge Local Plan for consultation

Stapleford Parish Council is broadly supportive of this policy with the following caveats:

P461, para 5.31-5.32 – the title of this section is green and blue infrastructure, yet there is nothing in these paragraphs about the aims of the policy which mentions blue infrastructure. This should be addressed. With respect to the policy itself, green infrastructure seems to be an all-encompassing term and this is confusing; look at, for example, the so-called ‘green infrastructure’ initiatives listed in clause 5, the majority of which are actually water-related and so, surely, would be more accurately described as ‘blue infrastructure’.

P461, Policy BG/GI cause 2b – we strongly support the use of green infrastructure to improve links within the landscape for the benefit of nature and people. With respect to benefits to people, our parish is surrounded by greenbelt, but we have very little access to it. And when we do, access is often limited to ‘out and back’ routes. Better links between open/green spaces would also reduce use of private cars to travel to sites. Policy S&GS 19 in the Stapleford & Gt Shelford Neighbourhood Plan highlights aspirational routes into and through our countryside that residents of these parishes, and elsewhere, would like to enjoy.

P462, Policy BG/GI clause 4 – where it is not possible to meet the greening factor onsite but a neighbourhood plan is in place for that location which identifies suitable opportunities to enhance green or blue infrastructure within the neighbourhood area, then those opportunities should take priority over resorting to off-site opportunities, otherwise the net effect of development on green infrastructure within that neighbourhood area is negative.

P462, Policy BG/GI clause 5(3) – we note the rightful inclusion of the Gog Magog Hills and chalkland fringe in the list of identified priorities for enhancing strategic green infrastructure across Greater Cambridge. However, (1) data underpinning this policy is flawed in its inaccurate portrayal of the extent of the Gog Magog Hills (2) the Gog Magog Hills are, unfathomably, not included in the Local Nature Recovery Strategy, and (3) the Gog Magog Hills will be negatively impacted by CSET. We expand upon these points below.

1. We are very concerned that the mapped extent of the Gog Magog Hills in supporting documents for the LPA is arbitrarily shrinking over time. This will undermine the aims of the Policy BG/GI. With respect to our immediate area, the northwestern extent of the Gog Magog Hills for the purposes of the draft Greater Cambridge Local Plan is established in Landscape Character Area 7B: Gog Magog Chalk Hills. This is incorrect: (a) it is at odds with the underlying local geology (b) it excludes the prominent slope and bulk of the open chalk hill in Stapleford which puts the ‘character’ into the ‘character area’ (c) it excludes the aptly named Chalk Hill Down, a new countryside park on rare open chalk soil managed by The Magog Trust as calcareous grassland, and (d) it is at odds with the pattern of early development which occurred below the spring line (which occurs at the junction between chalk and clay) at the 20m contour to avoid contamination of valuable fresh water supplies and the need to dig deep wells.

The consequences of inaccurately mapping the extent of the Gog Magog Hills have already been felt in Stapleford. In fact, it critically influenced the Appeal Inspector’s decision in Dec 2021 (appeal ref. APP/W0530/W/21/3280395) to approve major development of a retirement care village on greenbelt outside Stapleford’s development framework. As the Inspector noted in his decision report (paras 15-19): “Two recent landscape character assessments place the boundary between the two local character areas in different places, either side of the site. The Cambridge Inner Green Belt Study produced in 2015 as part of the evidence base for the extant South Cambridgeshire Local Plan adopted in 2018 places the boundary between what it calls Landscape Character Area 4B Granta Valley and Landscape Character Area 3B Gog Magog Hills along the edge of the built extent of Stapleford village, hugging the 20m contour line but rising to the 30m contour line further to the east of the site. The Greater Cambridge Landscape Assessment, produced in 2021 as part of the evidence base for the emerging Greater Cambridge Local Plan places the boundary between what it calls Landscape Character Area 3D Cam and Granta Tributaries Lowland Farmlands and Landscape Character Area 7B, Gog Magog Chalk Hills along the track which hugs the northern boundary of the site. In effect, one landscape character assessment places the site within the valley; the other places it on the hills.” Against this discrepancy, the Inspector effectively created a third location for the boundary, at the 25m contour line, and was then able to approve major development below this height because it placed it in the ‘valley area’ rather than on the higher chalk hills, which rightly have greater protection from development.

2. There is a glaring inconsistency between the draft Local Plan, which prioritises the Gog Magog Hills for enhancing strategic green infrastructure, and the Local Nature Recovery Strategy, which inexplicably fails to recognise them appropriately. There is no recognition of Wandlebury Country Park or Magog Downs (both are County Wildlife Sites), or of Stapleford Pit (a Local Nature Reserve) in the LNRS, all designated in Policy NH/5: Sites of biodiversity or geological importance. Ironically, the LNRS hails S. Cambs for its growing network of chalk grassland yet singularly fails to map them accurately; we are alarmed about the impact this will have on opportunities to enhance calcareous grassland sites, buffer and enlarge them, and to create habitat stepping stones and corridors.

3. Inaccurate mapping of the Gog Magog Hills and their exclusion from the LNRS means that, despite being a priority for enhancing strategic green infrastructure across Greater Cambridge, they are not being accorded sufficient value and hence protection when evaluating the environmental and landscape impacts of the proposed route of the CSET busway. As proposed by the Greater Cambridge Partnership, the lengthy section of the busway from where it crosses the track to the east of Stapleford Granary and continues in a north-westerly direction to where it passes Nine Wells Local Nature Reserve near Cambridge South Station will use the lower slopes of the Gog Magog Hills. There is, therefore, a glaring inconsistency between the green infrastructure aims of the draft Local Plan and its transport strategy. This inconsistency could be at least partly mitigated if an alternative, on-road route along the A1307 corridor from the A11 to the Cambridge Biomedical Campus was pursued instead. If requested, we can provide more evidence of the benefits of this on-road route.

P462, Policy BG/GI clause 5(13) – we fully support the inclusion of allotments and community gardens as an identified priority for enhancing strategic green infrastructure across Greater Cambridge.

Stapleford Parish Council is broadly supportive of this policy with the following caveats:

P461, para 5.31-5.32 – the title of this section is green and blue infrastructure, yet there is nothing in these paragraphs about the aims of the policy which mentions blue infrastructure. This should be addressed. With respect to the policy itself, green infrastructure seems to be an all-encompassing term and this is confusing; look at, for example, the so-called ‘green infrastructure’ initiatives listed in clause 5, the majority of which are actually water-related and so, surely, would be more accurately described as ‘blue infrastructure’.

P461, Policy BG/GI cause 2b – we strongly support the use of green infrastructure to improve links within the landscape for the benefit of nature and people. With respect to benefits to people, our parish is surrounded by greenbelt, but we have very little access to it. And when we do, access is often limited to ‘out and back’ routes. Better links between open/green spaces would also reduce use of private cars to travel to sites. Policy S&GS 19 in the Stapleford & Gt Shelford Neighbourhood Plan highlights aspirational routes into and through our countryside that residents of these parishes, and elsewhere, would like to enjoy.

P462, Policy BG/GI clause 4 – where it is not possible to meet the greening factor onsite but a neighbourhood plan is in place for that location which identifies suitable opportunities to enhance green or blue infrastructure within the neighbourhood area, then those opportunities should take priority over resorting to off-site opportunities, otherwise the net effect of development on green infrastructure within that neighbourhood area is negative.

P462, Policy BG/GI clause 5(3) – we note the rightful inclusion of the Gog Magog Hills and chalkland fringe in the list of identified priorities for enhancing strategic green infrastructure across Greater Cambridge. However, (1) data underpinning this policy is flawed in its inaccurate portrayal of the extent of the Gog Magog Hills (2) the Gog Magog Hills are, unfathomably, not included in the Local Nature Recovery Strategy, and (3) the Gog Magog Hills will be negatively impacted by CSET. We expand upon these points below.

1. We are very concerned that the mapped extent of the Gog Magog Hills in supporting documents for the LPA is arbitrarily shrinking over time. This will undermine the aims of the Policy BG/GI. With respect to our immediate area, the northwestern extent of the Gog Magog Hills for the purposes of the draft Greater Cambridge Local Plan is established in Landscape Character Area 7B: Gog Magog Chalk Hills. This is incorrect: (a) it is at odds with the underlying local geology (b) it excludes the prominent slope and bulk of the open chalk hill in Stapleford which puts the ‘character’ into the ‘character area’ (c) it excludes the aptly named Chalk Hill Down, a new countryside park on rare open chalk soil managed by The Magog Trust as calcareous grassland, and (d) it is at odds with the pattern of early development which occurred below the spring line (which occurs at the junction between chalk and clay) at the 20m contour to avoid contamination of valuable fresh water supplies and the need to dig deep wells.

The consequences of inaccurately mapping the extent of the Gog Magog Hills have already been felt in Stapleford. In fact, it critically influenced the Appeal Inspector’s decision in Dec 2021 (appeal ref. APP/W0530/W/21/3280395) to approve major development of a retirement care village on greenbelt outside Stapleford’s development framework. As the Inspector noted in his decision report (paras 15-19): “Two recent landscape character assessments place the boundary between the two local character areas in different places, either side of the site. The Cambridge Inner Green Belt Study produced in 2015 as part of the evidence base for the extant South Cambridgeshire Local Plan adopted in 2018 places the boundary between what it calls Landscape Character Area 4B Granta Valley and Landscape Character Area 3B Gog Magog Hills along the edge of the built extent of Stapleford village, hugging the 20m contour line but rising to the 30m contour line further to the east of the site. The Greater Cambridge Landscape Assessment, produced in 2021 as part of the evidence base for the emerging Greater Cambridge Local Plan places the boundary between what it calls Landscape Character Area 3D Cam and Granta Tributaries Lowland Farmlands and Landscape Character Area 7B, Gog Magog Chalk Hills along the track which hugs the northern boundary of the site. In effect, one landscape character assessment places the site within the valley; the other places it on the hills.” Against this discrepancy, the Inspector effectively created a third location for the boundary, at the 25m contour line, and was then able to approve major development below this height because it placed it in the ‘valley area’ rather than on the higher chalk hills, which rightly have greater protection from development.

2. There is a glaring inconsistency between the draft Local Plan, which prioritises the Gog Magog Hills for enhancing strategic green infrastructure, and the Local Nature Recovery Strategy, which inexplicably fails to recognise them appropriately. There is no recognition of Wandlebury Country Park or Magog Downs (both are County Wildlife Sites), or of Stapleford Pit (a Local Nature Reserve) in the LNRS, all designated in Policy NH/5: Sites of biodiversity or geological importance. Ironically, the LNRS hails S. Cambs for its growing network of chalk grassland yet singularly fails to map them accurately; we are alarmed about the impact this will have on opportunities to enhance calcareous grassland sites, buffer and enlarge them, and to create habitat stepping stones and corridors.

3. Inaccurate mapping of the Gog Magog Hills and their exclusion from the LNRS means that, despite being a priority for enhancing strategic green infrastructure across Greater Cambridge, they are not being accorded sufficient value and hence protection when evaluating the environmental and landscape impacts of the proposed route of the CSET busway. As proposed by the Greater Cambridge Partnership, the lengthy section of the busway from where it crosses the track to the east of Stapleford Granary and continues in a north-westerly direction to where it passes Nine Wells Local Nature Reserve near Cambridge South Station will use the lower slopes of the Gog Magog Hills. There is, therefore, a glaring inconsistency between the green infrastructure aims of the draft Local Plan and its transport strategy. This inconsistency could be at least partly mitigated if an alternative, on-road route along the A1307 corridor from the A11 to the Cambridge Biomedical Campus was pursued instead. If requested, we can provide more evidence of the benefits of this on-road route.

P462, Policy BG/GI clause 5(13) – we fully support the inclusion of allotments and community gardens as an identified priority for enhancing strategic green infrastructure across Greater Cambridge.

Stapleford Parish Council is broadly supportive of this policy with the following caveats:

P461, para 5.31-5.32 – the title of this section is green and blue infrastructure, yet there is nothing in these paragraphs about the aims of the policy which mentions blue infrastructure. This should be addressed. With respect to the policy itself, green infrastructure seems to be an all-encompassing term and this is confusing; look at, for example, the so-called ‘green infrastructure’ initiatives listed in clause 5, the majority of which are actually water-related and so, surely, would be more accurately described as ‘blue infrastructure’.

P461, Policy BG/GI cause 2b – we strongly support the use of green infrastructure to improve links within the landscape for the benefit of nature and people. With respect to benefits to people, our parish is surrounded by greenbelt, but we have very little access to it. And when we do, access is often limited to ‘out and back’ routes. Better links between open/green spaces would also reduce use of private cars to travel to sites. Policy S&GS 19 in the Stapleford & Gt Shelford Neighbourhood Plan highlights aspirational routes into and through our countryside that residents of these parishes, and elsewhere, would like to enjoy.

P462, Policy BG/GI clause 4 – where it is not possible to meet the greening factor onsite but a neighbourhood plan is in place for that location which identifies suitable opportunities to enhance green or blue infrastructure within the neighbourhood area, then those opportunities should take priority over resorting to off-site opportunities, otherwise the net effect of development on green infrastructure within that neighbourhood area is negative.

P462, Policy BG/GI clause 5(3) – we note the rightful inclusion of the Gog Magog Hills and chalkland fringe in the list of identified priorities for enhancing strategic green infrastructure across Greater Cambridge. However, (1) data underpinning this policy is flawed in its inaccurate portrayal of the extent of the Gog Magog Hills (2) the Gog Magog Hills are, unfathomably, not included in the Local Nature Recovery Strategy, and (3) the Gog Magog Hills will be negatively impacted by CSET. We expand upon these points below.

1. We are very concerned that the mapped extent of the Gog Magog Hills in supporting documents for the LPA is arbitrarily shrinking over time. This will undermine the aims of the Policy BG/GI. With respect to our immediate area, the northwestern extent of the Gog Magog Hills for the purposes of the draft Greater Cambridge Local Plan is established in Landscape Character Area 7B: Gog Magog Chalk Hills. This is incorrect: (a) it is at odds with the underlying local geology (b) it excludes the prominent slope and bulk of the open chalk hill in Stapleford which puts the ‘character’ into the ‘character area’ (c) it excludes the aptly named Chalk Hill Down, a new countryside park on rare open chalk soil managed by The Magog Trust as calcareous grassland, and (d) it is at odds with the pattern of early development which occurred below the spring line (which occurs at the junction between chalk and clay) at the 20m contour to avoid contamination of valuable fresh water supplies and the need to dig deep wells.

The consequences of inaccurately mapping the extent of the Gog Magog Hills have already been felt in Stapleford. In fact, it critically influenced the Appeal Inspector’s decision in Dec 2021 (appeal ref. APP/W0530/W/21/3280395) to approve major development of a retirement care village on greenbelt outside Stapleford’s development framework. As the Inspector noted in his decision report (paras 15-19): “Two recent landscape character assessments place the boundary between the two local character areas in different places, either side of the site. The Cambridge Inner Green Belt Study produced in 2015 as part of the evidence base for the extant South Cambridgeshire Local Plan adopted in 2018 places the boundary between what it calls Landscape Character Area 4B Granta Valley and Landscape Character Area 3B Gog Magog Hills along the edge of the built extent of Stapleford village, hugging the 20m contour line but rising to the 30m contour line further to the east of the site. The Greater Cambridge Landscape Assessment, produced in 2021 as part of the evidence base for the emerging Greater Cambridge Local Plan places the boundary between what it calls Landscape Character Area 3D Cam and Granta Tributaries Lowland Farmlands and Landscape Character Area 7B, Gog Magog Chalk Hills along the track which hugs the northern boundary of the site. In effect, one landscape character assessment places the site within the valley; the other places it on the hills.” Against this discrepancy, the Inspector effectively created a third location for the boundary, at the 25m contour line, and was then able to approve major development below this height because it placed it in the ‘valley area’ rather than on the higher chalk hills, which rightly have greater protection from development.

2. There is a glaring inconsistency between the draft Local Plan, which prioritises the Gog Magog Hills for enhancing strategic green infrastructure, and the Local Nature Recovery Strategy, which inexplicably fails to recognise them appropriately. There is no recognition of Wandlebury Country Park or Magog Downs (both are County Wildlife Sites), or of Stapleford Pit (a Local Nature Reserve) in the LNRS, all designated in Policy NH/5: Sites of biodiversity or geological importance. Ironically, the LNRS hails S. Cambs for its growing network of chalk grassland yet singularly fails to map them accurately; we are alarmed about the impact this will have on opportunities to enhance calcareous grassland sites, buffer and enlarge them, and to create habitat stepping stones and corridors.

3. Inaccurate mapping of the Gog Magog Hills and their exclusion from the LNRS means that, despite being a priority for enhancing strategic green infrastructure across Greater Cambridge, they are not being accorded sufficient value and hence protection when evaluating the environmental and landscape impacts of the proposed route of the CSET busway. As proposed by the Greater Cambridge Partnership, the lengthy section of the busway from where it crosses the track to the east of Stapleford Granary and continues in a north-westerly direction to where it passes Nine Wells Local Nature Reserve near Cambridge South Station will use the lower slopes of the Gog Magog Hills. There is, therefore, a glaring inconsistency between the green infrastructure aims of the draft Local Plan and its transport strategy. This inconsistency could be at least partly mitigated if an alternative, on-road route along the A1307 corridor from the A11 to the Cambridge Biomedical Campus was pursued instead. If requested, we can provide more evidence of the benefits of this on-road route.

P462, Policy BG/GI clause 5(13) – we fully support the inclusion of allotments and community gardens as an identified priority for enhancing strategic green infrastructure across Greater Cambridge.