Greater Cambridge Local Plan Issues & Options 2020

PREAMBLE This is the response of the Cam Valley Forum to your invitation to comment on the issues to be considered in the plan. The forum, a voluntary organisation, works with many other organisations to protect and improve the river Cam and its riversides, including its many tributaries and its sustaining aquifers. This response focuses mainly, therefore, on our concerns for the future of the river and its environment. However, since as individuals and as a group, we are also concerned about the city and its environs, we are not confining our comments to river-related issues alone. The river Cam is an invaluable, but vulnerable, natural asset to the environment of Cambridge and South Cambridgeshire. Cambridge without its river would not be all that it is. The river and its tributary streams bring threads of wildness through an intensively farmed countryside as it flows north. Its riversides contain and connect with many important wetland habitats. Its wetlands hold still elements of the wildlife most typical of this lowland region. Importantly to the whole planning process its waters are enjoyed by rowers, punters, boaters, canoeists and swimmers, while many more people enjoy walking, picnicking or angling from its banks. Visitors from far and wide come to experience the world-famous Cambridge Backs. The river, however, is damaged and vulnerable to further damage. The Backs, in particular, suffer from being congested with too many punts. To many of our citizens the tourist pressure on the River is overly exploitative of our iconic City's environment. Throughout its catchment the river and its wildlife suffers from poor water quality. Environment Agency data indicate that only three tiny tributaries in the upper reaches have ‘good’ water quality, the rest of the river system is ‘moderate’ to ‘poor’. This reflects not just the pollutants that find their way into the river, but also the reduced level of natural flow. For a premier City in Europe aiming for truly sustainable living this is a fact that our citizenry should to be ashamed of. We must do better Flows in the river have been declining for many years, as a result of increasing abstraction from its Chalk aquifers to meet the demands of the rapid growth of employment and housing. Thus in September 2019 the River Granta ran completely dry, as did Nine Wells, our historic source of water. The river Cam is largely fed by Chalk springs. These flow as streams into its main tributaries, the Granta, the Cam and Rhee. When the springs run dry much of the flow is contributed by treated sewage effluent alone. This aquifer is now acknowledged to be over-licenced for water abstraction.. The Environment Agency currently estimates that, in 2019-20, we will need 160% of the mean winter rainfall to recharge our aquifers to normal levels. Present groundwater is thus used unsustainably. We have a groundwater crisis that we have been slow to recognise. Increasing demand for water and the real impact of hotter summers both genuinely threaten the very existence of the river Cam itself. Although the River Cam is a designated County Wildlife Site in recognition of the river's importance in linking semi-natural habitats we would urge that the whole River Cam be given the highest conservation status to safeguard all its benefits to both people and the environment.

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1. The Big Themes The forum agrees that all four key issues are vitally important, but that the threats of climate change and declining biodiversity, which are intimately related, are of overriding importance. There is a tendency to give lip service to sustainable development without recognising that we humans are part of the ecosystem. All the policies and proposals of this local plan need to be appraised rigorously, in the light of their potential to counteract or exacerbate these threats to environmental sustainability. Thus the human water supply (locally through the Cambridge Water Company) and the River’s own water supply (from the groundwater Chalk aquifer) are the same. Why do our rivers run dry before we even ask people to save more water? Where is the prudence that builds up resilient infrastructure? Many any of us deeply question the intelligence and prudence of this headlong rush to unending local growth that is overly driven by greed rather than need. With respect to climate change there is ample evidence of changes in temperature and atmospheric carbon, but there is very limited evidence to date of great changes in rainfall itself or of the rainfall changes predicted in 4.1. These are possibly national predictions but may not apply to this drier eastern region.

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2. Level of growth The forum is particularly concerned about the assumption in your explanatory document that the current fast rate of growth will continue or even accelerate. The plan should aim to guide change, not simply accept it. The pressures on the quality of life in the centre of Cambridge, and the congestion of the river, call for effective measures to restrain the growth of tourism in the city. The impending water crisis suggests the need to restrain, rather than to promote, the current rate of employment growth within the plan area as a whole. Environmental limits must be respected. More is not necessarily better.

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3. Location of growth We accept that there will be need to accommodate further housing and related service developments in a variety of locations, but the location of essential new developments should be subject to the following considerations: No development should be allowed which: • Adversely affects the river and its tributaries, its sustaining aquifers, land liable to flood, and river-side green spaces. • Adversely affects the chemical or biological condition, or the temperature of the river’s waters. • Adversely affects any nature reserve, woodland and semi-natural open space. • Erodes the areas of best landscape, from the south-east to south side of the city. In particular there should be no further development on the green space between the Biomedical Campus and Nine Wells Nature Reserve. It is vital to protect this sensitive reserve, and it is important to maintain the views of the hillsides above that give pleasure to many and, not least, help sustain the morale of patients in Addenbrooke’s Hospital. The plan also needs to identify areas for environmental gains, especially recognising the importance of the water environment. • The plan should map a ‘nature recovery network’ as a framework to guide essential development. Water and water sources are a vital part of this connectivity, as are drains, streams, rivers, lakes and ponds. A ‘nature recovery network’ must include these aquatic elements at the same time as identifying new large-scale areas for habitat creation, including new woodlands and areas of natural regeneration, and opportunities for linking them all together. • The plan should recognise that ‘flooding’, which will be increasingly likely with climate change, can be mitigated upstream by slowing river drainage. This ‘natural’ approach would require a reversion to an earlier pattern of agricultural land-use management with wet meadows and less arable land in the flood plain itself. Some river valley farmers are already making this positive change. e.g. South Cambridgeshire could develop a larger flood plain with a wet woodland basin as a buffer against Cambridge City flood events. This wet woodland would impede rapid flow, so attenuating the flood, save water, sink carbon dioxide and ease soil erosion.

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4. Quality of development • All new developments should have the highest standards of water efficiency to minimise the use of water abstracted from the chalk aquifer, including use of rainwater and greywater recycling, and permeable paving. Large new developments should incorporate sustainable urban drainage systems to help water percolate back into the soil. • Opportunities for new tree planting should be maximised within new developments and in existing developed areas, recognising that trees help to not only absorb carbon dioxide but also reduce air pollution, help to cool urban areas in summer, and improve the landscape for all to enjoy. Careful consideration needs to be given to the choice of appropriate species. • New development should maximise use of renewable energy generation, passive heating and cooling. • With respect to reducing flood risks, especially in Cambridge City itself, were a large wet woodland basin to be encouraged upstream of the City, such an area could additionally provide needed recreation space for people and would undoubtedly help to increase the biodiversity of Cambridgeshire’s wet woodland habitats. • Well-being, health and recreation are central to the planning process for our future population. The scenery - beauty, tranquility and atmosphere - of being by a stream or river is worth everything to people whose lives are oppressed. The worth of our environment for this alone merits the highest conservation status.

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5. Transport Radical changes are needed to reduce the reliance on the use of cars, especially within Cambridge to improve local air quality and contribute to reducing the use of carbon-based fuels. The plan should identify: • potential routes for a strategic joined-up network of cycle paths. • potential traffic free areas. Where any footpaths, cycle ways or roads are planned to cross or go beside rivers, steams or conservation wetlands consideration needs to be given to:- • The reality that on narrow tow-paths or footpaths by the river cyclists may be a real hazard to pedestrians and dog-walkers. • The importance of safer cycle ways, which if allowed to be used by pedestrians need to be made much wider for safety reasons. • The fact that rivers are a natural corridor for wildlife and should be neither overly disturbed nor polluted in any way. • The scenic merit of the river and its heritage importance, which should always be most carefully considered.

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