Draft Greater Cambridge Local Plan for consultation

Policy BG/PO: Protecting Open Spaces (Draft Local Plan) should be redrafted to encompass the above objections as follows:

1. Proposals will not be permitted where they would harm the character of, or lead to the loss of, protected open space of environmental and/or recreational importance as identified on the policies map, or undesignated areas that fulfil the criteria used to assess protected open space, unless there are compelling reasons to override this policy.

Paragraph 2. of this policy is not required as the concept of replacement space is unrealistic.

Paragraph 3 of the policy undermines the general purpose of the policy, particularly in Cambridge, as it essentially creates a privileged class of development for educational institutions. Policies should be developer neutral. Paragraph 3 should be deleted.

Policy BG/PO does not achieve its objective of protecting open space. The qualities inherent to a space, particularly its environmental qualities, are part of that space in its particular location. The ‘Accessible Green Space Accessibility Standards’ are very general and an inappropriate benchmark for relocation. They take no account of the inherent environmental qualities of a space or the importance of locale. If spaces are protected, it is for an officially evaluated defined reason. There needs to be a much more compelling argument defined by the policy to allow this evaluation to be overridden, and then only in exceptional circumstances.

In summary, we consider that the following amendments to the policy should be made:
A. In the introductory paragraph to the policy, the words:
“It requires that development does not lead to, or is subject to, significant adverse effects as a result of noise, vibration, odour and/or light pollution and where any residual adverse impact is unavoidable then it is mitigated and minimised to an acceptable level” be changed to:
“It requires that development does not lead to adverse effects as a result of noise, vibration, odour and/or light pollution and where pollution will be increased, even after mitigation, development will not be permitted save where the development is essential to achieve more important objectives which cannot be achieved in another way.”
B. In paragraph 1.c under the heading “Light pollution”, the word “unacceptable” be deleted and replaced by “adverse”.
C. Paragraph 3 under the heading “Light pollution” be deleted and replaced by:
“Where the adverse effects of light pollution cannot be entirely mitigated, development will not be permitted save where a more important objective is achieved which cannot be achieved in another way.”

The draft policy on pollution, health and safety which is to form part of the new Local Plan requires that development does not lead to significant adverse effects as a result of noise, vibration, odour and/or light pollution and where any residual adverse impact is unavoidable then it is mitigated and minimised to an acceptable level and that, where necessary, conditions will be imposed.
The underlying intention here appears at first sight to be uncontroversial.
However, we consider that pollution is inadequately addressed by the policy, which seems to accept without question that increasing pollution is an inevitability and the best that we can hope for is to mitigate its more serious adverse effects. Light pollution is already a particularly acute problem in parts of Cambridge and we should be seeking to reduce it rather than allowing the situation inexorably to worsen.

There are two particularly troubling aspects of the proposed policy

1.Subjectivity is embedded in the policy when decisions should be evidence led. When considering the effect of development, it should be sufficient that there is a demonstrable adverse effect for mitigation and minimisation to be engaged, without the need for wholly subjective decisions as to whether that adverse impact is “significant” or “unacceptable” or “necessary”.

2.The policy seems to presuppose that permission for development should be granted, whether or not it causes pollution, on the ground that that pollution can be mitigated and minimised. Once adverse impacts occur, particularly the impacts from light pollution on wildlife (and, there is increasing evidence, on humans too), mitigation does not alleviate the irreversible detriment that may occur. The policy regarding any pollution should not be founded on the inevitability of its increasing. This is particularly so in the case of light pollution and the glare from the current proliferation of strong LED lighting. This conflicts with the overarching objective “to deliver sustainable development, to protect and enhance our natural and built environment, to support health and vibrant communities, and a successful and innovative economy.” A development that is incompatible with the achievement of one or more of these objectives should not be permitted.