Draft Greater Cambridge Local Plan for consultation

Comment

Representation ID: 211146

Received: 30/01/2026

Respondent: Environment Agency

We support the text in Policy CC/IW para 7, which outlines that foul drainage should connect to public sewers (Mains) wherever possible. It would helpful be to expand on this further within the supporting text section to clarify guidance on non-mains drainage. For example:
- A first presumption for development to discharge waste water via mains system as set out in the wastewater drainage hierarchy in the PPG
- Private sewerage treatment facilities only being used where it is not feasible to be connected to a public sewer in terms of cost and/or practicality.

Comment

Representation ID: 211147

Received: 30/01/2026

Respondent: Environment Agency

It should be noted that whilst we support infiltration drainage as a way to promote aquifer recharge and reduce flooding, there are risks associated with installing infiltration SuDS in areas of contaminated land. We would recommend amendments within the supporting text to the policy and a summary of the position within part 4 or 5 of the policy.

Comment

Representation ID: 211148

Received: 30/01/2026

Respondent: Environment Agency

We also support sections 1.a and 1.b. and 4.d for a whole development scale strategy for integrated water management from the earliest opportunity. 3, 4. and 5. Reflecting aspects of the drainage hierarchy and standards from the national SuDS standards – although we acknowledge that the LLFA will lead on advising which are the most pertinent aspects for Greater Cambridge. We advise that the water re-use and infiltration aspects are crucial to protecting groundwater resources and taking pressure off the Fens where fluvial waters will, over the coming decades, be decreasingly able to discharge by
gravity discharge into a rising sea level. We welcome the recognition of this challenge in the supporting information.

Comment

Representation ID: 211149

Received: 30/01/2026

Respondent: Environment Agency

Should be expanded to include reference to the need to consider the impacts of climate change and all sources of flood risk when applying the sequential and exception tests. We recommend rewording this to: ‘…having regard to actual and residual flood risks from all sources and taking into account the impacts of climate change’. This would be in line with the recommendations of the Level 1 SFRA. Paragraph 174 of the NPPF states that the sequential test should be used in areas known to be at risk of flooding now or in the future from any form of flooding.

Comment

Representation ID: 211150

Received: 30/01/2026

Respondent: Environment Agency

The wording in brackets should be caveated as the exception test may need to be reapplied at the planning application stage – e.g. if evidence on flood risk has changed significantly or the nature of the development differs significantly from the nature of the allocation (see paragraph 180 of the NPPF).

Comment

Representation ID: 211151

Received: 30/01/2026

Respondent: Environment Agency

We support part 1b as it requires a sequential approach to be taken to the site layout, avoiding any areas of flood risk.

Comment

Representation ID: 211152

Received: 30/01/2026

Respondent: Environment Agency

We support the reference to reducing flood risk overall where possible in 1c. However, we would like this to be expanded to include reference to the use of natural flood management techniques, as detailed below.

Comment

Representation ID: 211153

Received: 30/01/2026

Respondent: Environment Agency

In respect of 1d, the safety of access / egress routes should be defined – i.e. Is a dry route of escape required or is some depth of flood water along the route acceptable?
This point should also clarify when emergency plans need to be provided.

Comment

Representation ID: 211154

Received: 30/01/2026

Respondent: Environment Agency

Natural Flood Management (NFM) – we recommend that reference is made to the need for development proposals in flood risk areas to demonstrate that all reasonable opportunities to use natural flood management techniques or naturebased solutions to reduce flood risk overall have been considered and taken, in line with paragraph 172 of the NPPF.

Comment

Representation ID: 211155

Received: 30/01/2026

Respondent: Environment Agency

Hydraulic modelling – we recommend that the policy makes it clear that where hydraulic modelling of a watercourse within or adjacent to a site is not available or is out-of-date, modelling may be required as part of a site-specific FRA to define the extents and depths of fluvial flood risk at the site. This will help ensure FRAs include sufficient evidence to ensure a sequential approach is taken and to inform any proposed mitigation measures to ensure the development will be safe for its lifetime.