Draft Greater Cambridge Local Plan for consultation

Comment

Representation ID: 211156

Received: 30/01/2026

Respondent: Environment Agency

Development in the undefended floodplain – we recommend the policy clarifies that any development in the floodplain (i.e. within the 1% annual probability flood
extent, including an allowance for climate change) that is considered acceptable must not decrease flood storage capacity or impede flood water flows. See draft policy LP13 of the draft Hunts Local Plan for suggested wording.

Comment

Representation ID: 211157

Received: 30/01/2026

Respondent: Environment Agency

Residual risk – we recommend clarifying that if development is proposed within areas benefitting from flood defences, the FRA should assess the residual risk of a flood defence breach or overtopping and breach analysis or modelling may be required where ‘more vulnerable’ development is proposed.

Comment

Representation ID: 211158

Received: 30/01/2026

Respondent: Environment Agency

Change of use – we recommend that the policy clarifies the Council’s position on change of use applications in flood risk areas. The PPG recommends that Local
Plans outline where change of use applications will be acceptable. These applications are excluded from the sequential and exception test but may still involve an increase in flood risk, either due to an increase in the number of properties in flood risk areas or an increase in the flood risk vulnerability classification. We recommend that appropriate restrictions are placed on change of use applications for sites within Flood Zones 3b and 3a, and within areas of high surface water flood risk, where ‘more vulnerable’ basement or ground floor uses may not be appropriate.

Comment

Representation ID: 211159

Received: 30/01/2026

Respondent: Environment Agency

We note the inclusion for developers to consider waste management for all proposals. However, there is a lack of detail on post-development household waste management including Persistent Organic Pollutants, hazardous or problematic waste streams and the support of the circular economy. Reference should be included on how future growth will be supported by adequate infrastructure such as Household Waste Recycling Centres, recycling hubs, Waste Treatment Stations, Incinerators and treatment capacity.

Comment

Representation ID: 211160

Received: 30/01/2026

Respondent: Environment Agency

It has been noted that water scarcity is a concern for the local plan, please note that water is generally required alongside waste operations for the purpose of dust suppression and fire prevention. This would need to be considered in relation to any waste management infrastructure required as per the point above. It may also be required by constructors for dust suppression during building works.

Comment

Representation ID: 211161

Received: 30/01/2026

Respondent: Environment Agency

Please ensure that Contractors are aware of the potential requirement to obtain Waste Permits and/or apply under DoWCoP in relation to construction waste.

Comment

Representation ID: 211162

Received: 30/01/2026

Respondent: Environment Agency

We would recommend revision to reflect the following comments for waste management in the context of land contamination/remediation: Excavated materials recovered on a development site via a treatment operation can be re-used on-site under the CL:AIRE Definition of Waste Development Industry Code of Practice (DoWCoP) subject to certain conditions being met. This is sustainable approach. However, contaminated materials that are or must be disposed of are waste and must be managed in
accordance with the relevant legislation. We recommend that the following guidance be referenced: The Definition of Waste: Development Industry Code of Practice; and The Waste Management page on gov.uk.

Comment

Representation ID: 211163

Received: 30/01/2026

Respondent: Environment Agency

We recommend the inclusion of a clear requirement for biosecurity measures to prevent the spread of invasive species. Development proposals must demonstrate implementation of recognised protocols such as ‘Check, Clean, Dry’ to minimise the risk of transferring invasive non-native species. This aligns with national biosecurity best practice.

Comment

Representation ID: 211164

Received: 30/01/2026

Respondent: Environment Agency

In relation to Long-Term Management and Monitoring while the Local Plan acknowledges the need for 30-year management agreements for BNG sites in the Topic Paper section 3.40, this requirement should be broadened and made explicit for all biodiversity enhancements,
not just those linked to BNG. The Local Plan should require developers to submit a funded HMMP for every habitat creation or enhancement measure. Funding must be guaranteed upfront to cover maintenance, monitoring, and reporting for a minimum of 30 years, ensuring ecological integrity and compliance over the long term.

Comment

Representation ID: 211165

Received: 30/01/2026

Respondent: Environment Agency

We support this policy but would like to see specific reference made to the potential for green and blue infrastructure to reduce flood risk. We suggest expanding part 2.d. as follows: ‘d. Resilient – responds to the climate emergency in a positive, contributory way, reducing flood risk where possible.’