Greater Cambridge Local Plan Issues & Options 2020

The EA welcomes and supports the approach taken. The web site is clear, and we commend the 'Big Debate' event on 18 February where it was clear what is important to communities, the public and NGOs. As stakeholder the EA welcomes the approach to the Water evidence base, from early input to breadth of stakeholders. We hope to see this continuing.

Agree

We welcome mention of water, flood risk, green infra and biodiversity. We would like to be clear that with water resources in particular, Greater Cambridge is influenced beyond its immediate neighbours, and across the Anglian Water, Affinity Water and Cambridge (South Staffs) Water companies. Whilst ideally this would fall to regions (as previously with RSS14) the C&P Combined Authority is best placed to do this. In the absence of such join-up, the duty would fall to Greater Cambridge to consider the supply and demand for water across the affected water resources zones. For flooding, the whole River Cam catchment is significant as regards impact on the plan area, and further downstream for impacts from the growth. The duty to cooperate with such authorities and related stakeholders will help determine the approach to take. The Integrated Water Management Study and input from the C&P Combined Authority are necessary steps which we support. The plan and SEA should take account of growth impacts based on the effectiveness of existing legislation, and not assume all flood risk will be mitigated. For example much urban creep and small infill plots carry out no surface water attenuation, and SUDs are often not fully maintained in the long term. This may impact downstream. Water resources The water companies have recently produced water resources management plans (WRMP), which set out how the companies will maintain customer supplies over the period 2020- 2045. The assessments will show which companies have sufficient supplies to meet growth but also any strategic schemes that are needed to achieve this, along with reducing demands and leakage. We recommend that GC considers the long term feasibility and viability of supplying new developments in view of climate change. There is currently no assessment of ensuring that developments built in the plan can still be served for the 100 year minimum lifetime of the development, or beyond that. Also there needs to be consideration of how the phasing of growth links to the timings of the planned new strategic schemes, such as reservoirs, which would be at least 15 years off. Evidence to consider: The Anglian River Basin Management Plan https://www.gov.uk/government/publications/anglian-river-basin-district-river-basin-management-plan considered the status of all rivers and aquifers in the Region. This showed many waterbodies did not have the flow required to support the ecology and groundwater units not meeting good status. Given the pressure the Chalk aquifer faces, we cannot rule out future further reductions in the supplies available to water companies to prevent deterioration of the water related ecology. The council should seek the water company’s assurance that it can meet the needs of growth without causing deterioration. The Environment Agency advises that current levels of abstraction (not just in Cambridge) are causing environmental effects. Any increase in usage within existing licenced volumes will increase the pressure on a system that is already failing some environmental targets. We recommend any proposed development considers water resources as a key issue and GC recognises the damage of any long term increases in abstraction due to growth. We recommend this development takes into account the combined effect of growth in the area and the overall change (increase) in demand for water over that period. Cambridge Water company has recently (November 2019) published a new water resources management plan (WRMP), which sets out how the company will maintain customer supplies over the period 2020- 2045. The plan can be viewed here: https://www.cambridge-water.co.uk/about-us/our-strategies-and-plans/our-water-resources-plan The company is planning for housing growth of 2,500 properties in 2020-21, 2,400 in 2021-22 and then 2,000 per year between 2022/23 to 2025/26. After this point, the company forecasts new build growth to decline, ending up at 1,200 per year until 2044/45. This takes its total household property supplied from 101,400 in 2019/20 to a forecasted 158,530 in 2044/45. This appears to be in strident contrast to growth aspiration of GC, and in particular the C&PCA upper aspirations. The company’s assessment (using its own modest longer term growth assumptions) is that it will have sufficient supplies to meet this growth. The company’s plan is to increase the utilisation of its abstraction licences whilst seeking to reduce individual customer demands and reduce leakage. It should be noted that whilst the company has sufficient supplies available, this will result in an increase in overall abstraction and the pressure on groundwater aquifers, which are already over abstracted. This poses a risk to the rivers which are linked and supported by these aquifers. The Anglian River Basin Management Plan https://www.gov.uk/government/publications/anglian-river-basin-district-river-basin-management-plan considered the status of all rivers and aquifers in the Region and looked at what it would take to ensure they met good ecological status and reverse the over abstraction related to historical licensing of water. The measures required to make these improvements were subject to a cost benefit test. The assessment of the measures needed to get the entire aquifer and river system back to supporting good ecological status were deemed to be disproportionately expensive. The plan did approve some measures to improve the status of the rivers that were failing to meet their ecological flow needs where it was cost beneficial Given the pressure the Chalk aquifer faces, we cannot rule out future further reductions in the supplies available to CWC to protect water related ecology. At this point, we are not planning on further reductions before 2025, but there is a high likelihood that further reductions could be required after this period. Any resultant loss in available supplies would need to be addressed in the company’s next WRMP (2024). CWC’s next WRMP will need to reassess its ability to meet the demands of existing and planned customers should its abstraction licences require reductions. Significant new supplies are unlikely to be available locally as the groundwater aquifers are over abstracted and new consumptive abstraction will be permitted only by exception. Many of the rivers fed by groundwater are also over abstracted and exhibiting signs of environmental stress. Therefore, any significant new resource is likely to be part of a wider strategic scheme that involves bringing water in from other parts of the country either directly, or by linked transfers from neighbouring water companies. These types of schemes are highly likely to have significant lead in periods (10 plus years) before they could become operational, and are likely to be outside the GC planning area. The quantum and phasing of growth (through the duty to cooperate) will need to take this into account. The underlying condition of the rivers and groundwater aquifers is set out in our Cam and Ely Ouse Abstraction Licensing Strategy https://www.gov.uk/government/publications/cams-the-cam-and-ely-ouse-abstraction-licencing-strategy This shows the stress that the hydrological system is presently under as a result of abstraction. Given the pressures on local water resources and the potential risk of deterioration as a result of increased levels of abstraction, we advise that new development in the Cambridge area, and adjacent water resource zones aims for the highest levels of water efficiency. The council should also seek CWC’s assurance that it can meet the needs of the SEA growth scenarios without causing water body deterioration, or excessive water transportation and associated impact on the areas in Anglian Water’s or Affinity Water’s zones that would be affected. The Building Regulations allows local plans to specify optional standards with regards to water efficiency targets in new homes. Building regulations specify a target use of 125 litres per person per day. It is noted that both Cambridge City Council and South Cambs District Council have already applied the optional standard of 110 litres per person per day and we would advise that this is at least maintained in future plans. Given the water stress of the area as detailed above, we would also wish to see the Councils encouraging developers to aim for even higher levels of water efficiency (80 litres per person per day). However in the absence of legislative back up for this, it should not be relied upon in assumptions. Water efficiency measures in new development are highly unlikely to achieve the kinds of reductions in demand needed to keep high levels of growth within sustainable levels. Investment in leakage reduction and demand management by existing communities and businesses will play a big part, as will seasonal abstraction and storage. New consumptive uses such as basements that need dewatering, water reliant agriculture, food processing and some manufacturing may individually and will cumulatively have a significant impact on water availability. Suitable protective policies will be needed to manage these impacts. Water Quality and Wastewater The Greater Cambridge Local Plan appears to be a very comprehensive, environmentally centred, public focused plan. It is encouraging to see the level of consideration for climate change, biodiversity and green spaces, which the Environment Agency supports. The Greater Cambridge Local Plan, like any new development, which is inherently linked to population increase, risks a degradation of water quality. New development would undoubtedly put pressure on the river quality of the Greater Cambridge area and beyond. Any increase to wastewater discharge and water usage will need to be discussed with Anglian Water, whose role it is to accommodate the additional wastewater flows. They may need to increase capacity at the Water Recycling Centres or adjust their permits to treat wastewater to tighter permit conditions, to maintain river quality. The Water Framework Directive prohibits a deterioration in water quality and aims to achieve ‘Good’ status in each waterbody. Anglian Water need to continue to develop their Drainage and Wastewater Management Plan while collaborating with local authorities and the Environment Agency. Anglian Water’s wastewater treatment centres need to adapt and evolve to accommodate the proposed growth within Greater Cambridge. Climate change could potentially exacerbate the impact of development on river quality. Dry weather reduces river flow and increases pollution concentration in the waterbody. Conversely, more intense rainfall episodes creates additional surface run-off from rural and urban areas, which increases the potential for water pollution. Additional rainwater in the sewerage network will likely lead to the treatment sites using overflow tanks, some of which may spill – as they are designed to do – into the rivers. These abovementioned events potentially contribute to a deterioration of water quality. In conclusion: -New developments are likely to increase pressure on the environment; -Water companies need to adapt their infrastructure to accommodate the proposed Local Plan, and use demand management for existing communities and businesses. -Climate change will intensify the existing pressures, and these need evaluating. -An integrated approach to water management (IWM) is essential to managing the related factors. -We support GC’s emerging IWM study, but recognise that the duty to cooperate goes far beyond GC, and the C&P Combined Authority has a primary role in ensuring that the duty is fulfilled. -It is imperative through the River Basin Management Plan that delivery of the Local Plan does not lead to a deterioration in water quality through over-abstraction or wastewater. We defer to Natural England in respect of biodiversity, and recognise the role that healthy rivers play in providing habitat and connectivity.

EA recognises that water has carbon impacts across it cycle. Long distance transfer or desalinating water has significant impacts. Sustainable drainage that puts water into the ground retains a resource, and thus reduces the carbon impacts. Overworking and drying out of soils (and particular peat) has significant carbon impacts. Sustainable land use around agriculture is critical to manage this. Large scale restoration of wetlands and tree planting has positive impacts for biodiversity, water quality, flood risk as well and carbon sequestration. Requiring doubling of nature and making space for water would help achieve these objectives.

Yes, strongly agree

Looking at how water resources (and related water quality) will be affected for the minimum lifetime of new properties is vital, as is considering the infrastructure needed to adapt existing properties. Making space for water to flood and be stored will be critical to long term adaptation. Building on the fringes of flood zones 2 and 3 means there are less options to create future flood storage. Planning to avoid future flood risk is therefore as much about creating storage as it is avoiding flooding to new properties.

There are few designations for water bodies other than the Water Framework Directive. We suggest that if Cambridge values its rivers, it should consider local designations to supplement the protection and enhancement of water features. We support the doubling of nature and would like to see the focus on the doubling being around water, rivers and associated biodiversity. This will also bring a strong element of sense of place with the inherent links Cambs has to water, the fens and its wildlife.

See our answer to question 12. Rivers are natural and indelible features, but only serve people and biodiversity if they are maintained and improved as corridors. Focussing net gain projects on water achieves this along with protecting soils and peat from carbon /sediment loss.

The local plan should identify important and valuable ecological areas, such as designated wildlife sites, and those which can be augmented and connected. Areas identified for new development in the local plan should ideally avoid these wildlife sites to buffer and protect them, reducing potential impacts during and after development, such as disturbance and increased recreation. Loss and/or fragmentation of existing habitats should be avoided as much as possible. These areas should be part of a local nature recovery strategy (LNRS) and be connected to projects and partners who can help deliver the net gain. This can e through both sustainable land management as well as new/improved habitat. These projects could be pooled along with developer contributions to give flexibility on how and when the projects are implemented. There will need to be clear associated metrics. Existing areas of habitat and green spaces within proposed development footprints should be protected and incorporated within landscape designs where possible. As well as protecting existing areas of habitat, mitigation and environmental enhancements can be delivered through appropriate design that includes creation of new habitats and green spaces. New habitats should be representative of and complement the local landscape character, whilst being linked to existing features and the wider countryside, creating joined-up, resilient ecological networks. This is in line with the hierarchy used in biodiversity net gain of avoiding, mitigating and enhancing. Following development the implementation of ecological monitoring will be necessary to demonstrate biodiversity net gain objectives have been achieved. The creation of bigger, better and joined-up habitats will be beneficial to wildlife, contributing towards the local plan’s objective of doubling nature. The creation of large networks will also support ecological resilience to predicted future impacts from climate change. They will also support environmental objectives under section 170 of the National Planning Policy Framework, contributing to and enhance the natural and local environment by ‘minimising impacts on and providing net gains or biodiversity, including by establishing coherent ecological networks that are more resilient to current and future pressures’. The new plan could also acknowledge the significance of invasive non-native species (INNS) and their impacts on wildlife and the environment. INNS are considered one of the top five threats to the natural environment. They can impact on wildlife, flood risk, water quality and recreation. Costs to the economy are estimated at £1.8 billion per year. Prevention through adopting biosecurity measures can help to reduce the spread and impacts of INNS. With predicted local population growth, demand for water is likely to increase, potentially increasing pressure on water resources. The local plan should recognise the importance and value of local water resources and sustainable use. Appropriate management will help to protect and maintain the resource and provide clean water for people, wildlife and the environment. Less water for the environment has the potential to impact on rivers and wetland habitats reliant on water. Less water will reduce river flows and limit natural processes, impact on flow-dependent species and limit transportation of sediments increasing deposition. Low flows can also impact on water quality through reduce dilution of treated effluent and diffuse run-off. These impacts may be exacerbated by the predicted changes in rainfall patterns and average temperatures resulting from climate change. Increasing and prolonged droughts could affect water resource availability, whilst hotter summers could see a rise in demand for water. The plan area will need to be drought and flood resilient, meaning adaptation is needed as much as new habitat. Effects associated with reduced water availability may be mitigated through the local plan promoting sustainable water management such as making space for water and Natural Flood Management (NFM) schemes, which can support delivery of ecosystem services. Appropriate management of wetlands and river catchments, including floodplains, can allow rainwater infiltration supporting ecological benefits, sustainable flood water management, water storage, water resource availability and improved water quality. Managing riparian land sustainably will improve soil condition and reduce run-off, reducing the volume of sediment and associated nutrients, entering watercourses. Appropriate management of wetlands and fenland can also mitigate climate change through carbon sequestration. Appropriate protection and enhancement of rivers and streams will also support WFD objectives. New developments that may impact of watercourses should not lead to deterioration in waterbody’s status. Projects should ideally deliver mitigation measures in place and include environmental enhancements where possible. We support the integrated water management study and this will need to be closely related to the LNRS and green infrastructure/natural capital work.

No, strongly disagree

Yes, this can make a significant contribution to: -Flood risk management, by reducing run-off and water removal via evapotranspiration. This is especially effective in clay catchments. -Shading waterbodies that overheat in the summer, depleting oxygen to harmful levels for wildlife -Improving water quality, with the right kind of trees. -Biodiversity and related corridors and climate resilience. However, trees can also reduce water resources, especially in chalk catchments. There should be overlap between the Local Nature Recovery Strategies and Integrated Water Management studies to get this balance right.

Agree

"Please substitute this for our previous answer to this question, which contained typing errors: ""Yes, however there needs to be more recognition of the interconnectivity between these factors recognising that through climate change, factors such as temperature, rainfall and flooding will all have significant impacts on land use for existing and new development. Some forms of agriculture and consumptive water uses may no longer be feasible or viable. The EA supports that the Integrated Water Management Study should address these factors with at least a 100 year backdrop of climate change, and sensitivity test beyond that to ensure there are 'no regrets'."""