Greater Cambridge Local Plan: Proposed Submission

We have no specific comment to make on this paper.

While we do not find this policy unsound, we recommend that it clarifies that any proposals for new Gypsy and Traveller pitches must not be located within Flood Zone 3. The policy currently requires a Flood Risk Assessment to determine the necessary flood mitigation measures; however, Annex F Table 2 of the NPPF classifies caravans, mobile homes and park homes intended for permanent residential use as 'highly vulnerable' development. Annex F Table 3 indicates that highly vulnerable development should not be permitted within Flood Zones 3a or 3b. Therefore, we recommend that the policy is amended to make this clear to ensure consistency with national policy.

We note that North East Cambridge has been restructured from a site allocation to an Area of Major Change since the Draft Local Plan consultation. However, the policy does not appear to have been amended to incorporate the Environment Agency's previous recommendations. This policy should specifically refer to the need to adopt a sequential approach, prioritising the location of more vulnerable development outside areas at risk of fluvial and surface water flooding. We recommend that this policy refers to the requirement for the site-specific FRA to include hydraulic modelling of the watercourses on site to inform site layout and design levels.

The policy does not appear to have been amended in response to the Environment Agency's previous comments and therefore does not fully reflect the flood risk recommendations identified through the Level 2 SFRA. This policy should refer to the requirement for an FRA and the need to take a sequential approach to the site layout.

We support Policy WS/HS: Pollution, health and safety which includes a section on Contaminated Land. This correctly recognises that a risk assessment may be required which could require intrusive investigation and a remediation strategy with possible mitigation measures. We welcome the supporting information which defines contaminated land, with receptors including explicit reference to underlying aquifer. We support reference to national policy with Land Contamination Risk Management (LCRM) framework; Part IIA of the Environmental Protection Act 1990; and the Environment Agency groundwater protection guides.

Cemeteries

We welcome the inclusion of New burial grounds, cemeteries and crematoriums in Policy WS/NC: Meeting the needs of new and growing communities, especially 10(e) which acknowledges risk to the water environment. We support reference to Environment Agency guidance (6.41-6.42).