Greater Cambridge Local Plan: Proposed Submission

Measures to sustainably align new housing and employment growth with the carrying capacity of the natural environment.

The scale of growth proposed in terms of jobs and new homes is not currently sustainable due to lack of sustainable water supplies and continuing over-abstraction from the chalk aquifer negatively impacting chalk streams and wetlands, including nationally designation nature sites across the Greater Cambridge area.

The proposed Fens Reservoir will not be completed until the late 2030s and the proposed pipeline from Grafham won’t be in place until 2032. In the meantime, our chalk streams will not be able to recover in spite of proposed massive investment through Water Companies funding without sufficient supplies of good quality water. It is likely that the Cambridge Water abstraction from the chalk aquifer would have to reduce by half to recover near natural flows. However, the scale of proposed housing and jobs included in the Local Plan will only exacerbate the problem without radical and faster solutions, none of which are in place.

This Local Plan should be delivering a comprehensive plan for the south-east of Cambridge and the areas on the edge of Cherry Hinton, Queen Ediths and the Biomedical Campus. A one-off targeted review of the inner green belt boundary coupled with securing the land to provide a large, accessible area of nature rich downland from Cherry Hinton and Queen Ediths to the Gog Magog Hills would set the long-term boundary to Cambridge in the south-east, while delivering the nature-rich downland and strategic accessible natural greenspace that Cambridge is missing and also delivering the Local Nature Recovery Strategy. This would complement the similar approach taken at Trumpington Meadows and Clay Farm nearly 20 years ago and deliver a legacy in sustainable development.

Grange Farm, Abington allocation should be removed from the plan, or if retained it should be at a much smaller scale of a village rather than a small town, which will not be large enough to support all the services a town requires and with its location will result in significant out-commuting along the M11 / A11 corridor as well as out-commuting for many everyday needs including much shopping, cultural and leisure activities and access to greenspaces elsewhere, exacerbating pressures on green infrastructure and the natural environment.

The Wildlife Trust believes that the overall development strategy is inconsistent and not well enough thought out to deliver the needs of a growing population in Greater Cambridge. There are aspects such as Cambridge East, Cambourne North and Cambridge North-East which make strategic sense. However, the proposals for the green belt releases south-east of Cambridge are confused, piecemeal and fail to represent a holistic approach to sustainable development. Likewise, Grange Farm, Abington is ill thought out and will become a mainly car commuter settlement with its proximity to the A11 / M11 and ease of access south towards London and it is very unlikely that the majority of new residents would work in the southern research cluster. It will also be a place which results in out-commuting for many everyday needs including much shopping, cultural and leisure activities and access to greenspaces elsewhere, exacerbating pressures on green infrastructure and the natural environment.

This Local Plan should be delivering a comprehensive plan for the south-east of Cambridge and the areas on the edge of Cherry Hinton, Queen Ediths and the Biomedical Campus. A one-off targeted review of the inner green belt boundary coupled with securing the land to provide a large, accessible area of nature rich downland from Cherry Hinton and Queen Ediths to the Gog Magog Hills would set the long-term boundary to Cambridge in the south-east, while delivering the nature-rich downland and strategic accessible natural greenspace that Cambridge is missing and also delivering the Local Nature Recovery Strategy. This would complement the similar approach taken at Trumpington Meadows and Clay Farm nearly 20 years ago and deliver a legacy in sustainable development.

The Council's need to take a strategic approach to planning the whole of the Cambridge south-eastern fringe, including the Biomedical Campus that will last for the long-term and not just the next 5 years until the next Local Plan. A strategic approach including limited Green Belt releases would unlock a regional-scale strategic green infrastructure site across the Gog Magog Hills and be in line with the Cambridge Nature Network and Local Nature Recovery Strategy, while contributing to housing and employment needs. The delivery of the Gog Magog Hills and green infrastructure and biodiversity ambitions and policies set out elsewhere in the plan will not be deliverable without a joined up, sustainable approach to allocations in the Local Plan for the south-eastern fringe of Cambridge.

The current proposals for the green belt releases south-east of Cambridge are confused, piecemeal and fail to represent a holistic approach to sustainable development. The Councils should have used this Local Plan to undertake a one-time strategic review of the Green Belt boundary across the whole of the Cambridge south-eastern fringe from the Biomedical Campus round to Cherry Hinton, to address employment, housing green infrastructure and nature recovery holistically, in the same way that the Cambridge Southern Fringe was planned twenty years ago. This should have been planned for the next 20-25 years and not just 5-10 years and made provision to deliver the nature recovery and strategic green infrastructure provisions set out in the Cambridge Nature Network as well as the LNRS priorities on the Gog Magog Hills.

This Local Plan should be delivering a comprehensive plan for the south-east of Cambridge and the areas on the edge of Cherry Hinton, Queen Ediths and the Biomedical Campus. A one-off targeted review of the inner green belt boundary coupled with securing the land to provide a large, accessible area of nature rich downland from Cherry Hinton and Queen Ediths to the Gog Magog Hills would set the long-term boundary to Cambridge in the south-east, while delivering the nature-rich downland and strategic accessible natural greenspace that Cambridge is missing. This would complement the similar approach taken at Trumpington Meadows and Clay Farm nearly 20 years ago and deliver a legacy in sustainable development.

The reality is that the Cherry Hinton and Gog Magog downs will not be delivered unless the landowners’ development aspirations are included in the Local Plan. A small, targeted extension to the Peterhouse Business Park, coupled with additional development either side of Wort’s Causeway (20-30 Ha of inaccessible Green Belt) would deliver 150-200 Ha of new accessible nature-rich countryside ("Cherry Hinton, Shelford & Stapleford Downs") to support the growing city and make up for the historic deficits in provision of strategic natural greenspace. With Wandlebury and Magog Downs and buffering of and connections to Nine Wells LNR this would provide the sub-regional natural greenspace missing from the Greater Cambridge area, right on the doorstep of Cambridge and in keeping with the vision for an internationally renowned biomedical campus. It would also contribute to delivering one of the top priorities for nature recovery in and around Cambridge identified in the Cambridge Nature Network and fully align with the Local Nature Recovery Strategy (LNRS). This needs to be undertaken now, not at some undefined point in the future. We have attached two maps, the first showing the opportunities in the Gog Magog Hills to buffer, enlarge and connect the important nature sites and the second showing the LNRS priorities for the area.

The Wildlife Trust does not support much of the the green infrastructure proposals for the Cambridge Biomedical Campus and in particular the location of parts of the Strategic Enhancement Area and Landscape Improvement Area. Nine Wells LNR needs to be better buffered, expanded and integrated into the green infrastructure, which it isn't in the current proposals. While we do support the creation of the greenspace to the south of the proposed Biomedical Campus Expansion, more needs to be done to integrate Nine Wells LNR into this.

The Wildlife Trust does not support the proposed green infrastructure round the Park & Ride site, as it will make no strategic contribution to the Cambridge Nature Network or Local Nature Recovery Strategy, and is not even identified in the LNRS. It does not buffer, or link the designated sites on the Gog Magog Hills and is of low biodiversity potential. It may even compromise future delivery of the Gog Magog Hills strategic greenspace by sterilising land the development of which could pay for its creation. Surely land around a Park & Ride site would be a more sustainable location for new housing? Strategic planning of the whole south-eastern fringe would be likely to come up with a better solution for housing, jobs, green infrastructure and nature recovery than the current proposals and the Council seems to have missed the bigger, strategic picture with this short-sighted allocation.

The field below Beechwoods LNR is included in the Cambridge Nature Network proposals and LNRS, so we do support this being part of a future strategic natural greenspace across the Gog Magog Hills.

Some of the detail for the Landscape Improvement Area is also unrealistic and undeliverable. Many of the species prefer large open fields without public access. Conservation of existing red listed farmland bird populations will not be compatible with provision of accessible greenspace. The proposals for increased woodland and hedgerows while potentially beneficial to some farmland bird species, will not be suitable for others. It is likely that off-site compensation would be required for several red listed species of farmland birds if the current proposals are taken forward. Finally, It will not provide a high quality ecological connection from Beechwoods to Nine Wells LNRs and takes the wrong route.

Add paragraphs 16b and 16ciii from Cambridge East site allocation policy to this policy:

16b. Enhance ecological links beyond the site boundary, responding to strategic priorities for this area from the Cambridge Nature Network and Local Nature Recovery Strategy.

16ciii. Contribute towards the creation of strategic scale green infrastructure associated with the Gog Magog Hills priority area of the Cambridge Nature Network.

Further to our previous submission on this site allocation we have one further suggestion for an addition to the policy to improve it if it remains largely in its current form.

We suggest that paragraphs 16b and 16ciii from the Cambridge East site allocation policy are replicated in this policy.

The Wildlife Trust supports the biodiversity and green infrastructure aspects of the policy. We particularly welcome the inclusion of paragraphs 16b and 16ciii.

The Wildlife Trust supports the nature elements of this policy including the Strategic Enhancement Zone with specific nature objectives and the protection and enhancement of the River Granta and its wider corridor.

The Wildlife Trust supports the stronger inclusion of the Strategic Enhancement Area with policy for its explicit enhancement to include natural greenspace. We also support the nature and public space aspects of the policy.

If the allocation remains in the local plan the following changes should be made to the Nature section of the policy (21)

21 v. Ensure that appropriate measures are implemented to minimise recreational disturbance and pressures on ecology at the SSSI along the Worstead Roman Road which is a Public Right of Way and a European Long Distance Route and at other nearby SSSIs and nature sites within easy travel distance;

The following text (taken and adapted from paragraph 16 of the East Cambridge site allocation policy) should also be added to the Nature section of the policy (21):

a. Enhance ecological links beyond the site boundary, responding to strategic priorities for this area from the Cambridge Nature Network and Local Nature Recovery Strategy.
b. Contribute towards the creation of strategic scale green infrastructure associated with the Gog Magog Hills

The Wildlife Trust objects to this allocation as it is in an unsustainable location in terms of water, transport and green infrastructure.

Grange Farm, Abington proposed new town is too large and inherently unsustainable and appears to have been purely placed there to “jump” the Green Belt. This hasn’t worked with places like Bar Hill, which are almost completely car dependent. The location is ill thought out and will become a mainly car commuter settlement with its proximity to the A11 / M11 and ease of access south towards London and it is very unlikely that the majority of new residents would work in the southern research cluster.

While a new village in this location might be justified a town that is too small to deliver most of the services residents will need and will result in high levels of out-commuting and car visits for work, leisure and recreation is unsustainable. While a public transport hub is planned, and the development in nominally designed to serve the southern research cluster, the reality is it is located adjacent to the A11 and would provide an ideal location for commuting to the south towards London or east. Unless the housing is only for employees who work at Granta Park, Babraham or Hinxton it is hard to see how it won’t be an unsustainable 20th century car dominated commuter settlement.

The location is also likely to be unsustainable in terms of water resources. While the policy prevents any development starting before 2034, which may mitigate some of the threat to continued over-abstraction of the chalk aquifer with its adverse impacts on chalk streams and associated wetlands, the scale of development is likely to contribute to a continuation of this adverse impacts for longer. Other water resource concerns are the impacts on ground water from pollution as the site lies on the chalk directly over the aquifer.

The location and size of the proposed town will also likely result in adverse impacts on nature sites beyond the site. The strategic enhancement area will be too small and not varied enough to meet strategic green infrastructure needs on-site. Further any new natural greenspaces created will not be as attractive as other nearby mature sites. This will therefore result in displacement of recreational activities to well established sites elsewhere that are at capacity and will result in damage to nature sites elsewhere. Even if the development provided significant financial contributions for strategic green infrastructure, it is highly unlikely that providers would be able to acquire the land required in the right places by 2034, as land assembly for strategic green infrastructure on the edge of Cambridge will ultimately depend on the landowners getting at least part of their own development aspirations in return for providing the land for strategic green infrastructure. The reality is that this development will place unmitigated additional pressure on Wandlebury, Magog Down and various SSSIs within the catchment of this new settlement and not just the Roman Road SSSI (21a v) and these impacts are likely to extend way beyond the 2 km (21a iv).

The policy provisions for nature set out in paragraph 21 are inconsistent and unlikely to be successful. The policy seeks to prevent access to the Roman Road SSSI / SAM with good reason and requires management and enhancement of the SSSI. It also seeks to buffer the SSSI with high quality green infrastructure (GI). However, it is debateable as to whether it will be possible to prevent access to the Roman Road which is also a Public Right of Way. However in preventing access to the SSSI and Public Right of Way, the policy limits the scope for creating circular walks of the varied lengths (2km, 5 km & 10km) that people need and that mak for good GI planning. The strategic enhancement area is not large enough to cater for all of the countryside and nature recreational needs of the new population. The consequence of this is that the development will generate a significant increase in trips to other nature sites both local to the area and further afield.

Should this allocation proceed at its current scale, the policy will also need to make provision for supporting the creation and maintenance of strategic green infrastructure elsewhere, particularly on the Gog Magog Hills (Wandlebury & Magog Down). We therefore strongly suggest that the policy wording used in Cambridge East policy paragraph 16b and 16c iii) be adapted and added to this policy.

Amend policy Nature paragraph (17)

e. Providing a Sensitive Lighting Strategy and dark habitats/corridors, linking to those being delivered as part of Cambourne North (Policy S/CBN), and around the outer edge of the settlement;

The policy wording is not sufficiently strong in terms of providing mitigation such as continuous dark corridors for bats through and along the edge of the development.

Under the Nature section (17), points d and e could be in conflict with each other. For example for Barbastelle bats and to connect to Cambourne North there will need to be effective dark corridors along the eastern edge of the development (between Bourn airfield and Cambourne (Broadway) and the eastern edge of the development between Bourn Airfield, Highfields and through Bourn Quarter. The words "where possible" in paragraph e are likely to be in conflict with the Barbastelle bat activity (as confirmed by surveys from point d).

The Wildlife Trust supports many of the other measures relating to nature and GI, including the extension of the Strategic Enhancement Area from the previous allocation.

We propose the following amendments to points within the Nature paragraphs. The change to paragraph 25b i is for greater clarity. The change to paragraph 35 to to align it with the better wording in paragraph 25a.

25 b. Incorporate the following buffer zones to Ancient Woodlands and SSSIs:
i. 40m buffer to all Priority Woodland and other designated nature sites; and

35. Provide sufficient high-quality green infrastructure on site to provide publicly accessible natural and semi-natural open spaces (including within the Strategic Enhancement Area), to compensate for any additional recreation pressure created by the expansion of Cambourne on SSSIs within or close to the site.

The Wildlife Trust is pleased to see that there has been significant changes to the policy wording under the Nature section arising from workshops since the draft local plan stage. We do however remain concerned that the development and its green infrastructure proposals could still result in material harm to the nationally important local Barbastelle bat population as well as significant adverse impacts to nature sites within and adjacent to the allocation, and to some nature sites well beyond the site boundary. We have proposed some further minor amendments to the Nature policy wording for increased clarity.