Greater Cambridge Local Plan Issues & Options 2020

I write on behalf of the National Trust in response to the publication of the draft Greater Cambridge Local Plan for comment. Context The Trust owns two nationally significant sites located close to Cambridge which in combination attract close to 1 million visitors a year: • Located in South Cambridgeshire, Wimpole Hall lies approximately 13 km to the west of Cambridge and attracts some 400,000 visitors per annum. It is a Grade I Listed Building set within a Grade II* Registered Park and Garden which includes the farmed estate and extends over an area of 1,200 ha. The property as a whole contains 30 listed buildings and structures of which three, including the Gothic Tower (Folly Castle), are Grade II*, and a Scheduled Monument comprising the remains of the Romano British settlement at Arrington. The estate is the largest of its kind in Cambridgeshire and a key attraction is its landscape setting, including the 4 km long South Avenue, with extensive views to the Royston Hills. • Located in East Cambridgeshire but abutting the boundary with South Cambridgeshire, Anglesey Abbey is the second most popular visitor attraction in Cambridgeshire, outside Cambridge itself. Since 2010 visitor numbers have grown by 37%, making Anglesey Abbey one of the fasted growing properties in the Trust. The Trust is anticipating further growth with visitor numbers likely to exceed 600,000 within the next 5-10 years. It is a Grade I Listed Building set within a Grade II* Registered Park & Garden. The estate extends over 46ha and the 12th century monastic buildings have been extensively altered by successive owners over the years. Besides the Abbey and adjacent Grade II listed barn, there are several listed features within the grounds including a sundial, statues and urns. Anglesey Abbey is located near Lode, approximately 9km north-east of Cambridge on the B1102 Cambridge to Burwell road. Acquired by the National Trust in 1966 and open all year, it is especially popular in January and February when the snowdrops are in flower. In addition, the National Trust holds restrictive covenants on some 230 ha of land at Coton, including Whitwell Hill, which at 62 metres AOD is the highest point west of Cambridge. The founders of the Cambridge Preservation Society, now Cambridge Present and Future (CPPF) purchased land in this area to protect the rural character of the area, the elevated views towards Cambridge, and to prevent the setting of the historic city being damaged by urban sprawl. CPPF is party to the principle (1958) Deed of Covenant and retains ownership of some of the land. These aims and objectives are reflected in the terms and restrictions of the Trust’s covenants. Outside the Local Plan area in East Cambridgeshire, the Trust owns and manages some 250 ha of land at Wicken Fen, a National Nature Reserve and designated SSSI, and an internationally designated SAC and Ramsar. At its closest point the Reserve is located approximately 4km to the east of the boundary between the two districts, however the Trust’s plans for the Wicken Fen Vision Area would extend the area of land managed for nature conservation southwards to within 2km of the South Cambridgeshire boundary and the planned New Town at Waterbeach. The Trust’s long term management strategy for the Vision Area extends across an area of approximately 5,300 ha and aims to alleviate the growing pressure on vulnerable habitats within the SSSI, and to better protect areas at risk from the effects of trampling and other harmful activities. In responding to this consultation we have focused on responding to questions concerning those issues that relate most directly to our the Trust’s own objectives, and that resonate with our special purposes as a conservation body; our responses are reproduced at Appendix 1 for reference. In addition, the special significance of Wicken Fen SSSI and wider reserve, and of the Trust’s long term commitment to extending access to land managed for nature conservation across the Vision area are relevant to the comments which follow. Habitats Regulations Assessment (HRA) Scoping Report The National Trust welcomes the scope of this report, including the proposed 15km buffer and consideration of a longer distance impact pathway for potential hydrological and recreation impacts. We also welcome the inclusion of Wimpole and Eversden Woods SAC and Wicken Fen Ramsar within the scope of the HRA and concur with the potential effects identified in the report. In relation to both hydrological and recreation impacts, and in relation to air quality, we concur with Natural England’s advice provided by email dated 11th October 2019. We have now published the report of the 2019 visitor survey of Wicken Fen and the Vision Area mentioned in that correspondence, and South Cambridgeshire District Council planning officers are aware. Sustainability Appraisal (SA) Scoping Report and Non-Technical Summary The Trust welcomes the inclusion of biodiversity, landscape, and the historic environment as key issues for the SA, and recognition of the historic landscape setting of Cambridge is especially welcome. The challenge this presents for new development is referenced at page 15 of the Scoping Report and we comment further on this issue in our responses to the main consultation document. We note that the Sustainability Appraisal scoping report identifies over abstraction, also referenced in HRA scoping report, as a key issue. We share this concern, particularly in relation to the potential impacts on Wicken Fen as stated above. We support the intention to plan for new green spaces through the Local Plan review process, referenced at page 6 of the Scoping Report. This provides an opportunity to raise the scale of green space ambition for the Cambridge area, and should allow for the consideration of cross boundary opportunities, as identifed in the Issues and Options consultation document. The SA should include recognition of the relationship of the Plan to the Wicken Vision Area, which is located in East Cambridgeshire but adjacent to the planned new town at Waterbeach, and to the South Cambridgeshire boundary. Biodiversity and Nature Recovery The Local Plan should set clear and ambitious targets for biodiversity and nature recovery. All new development should achieve a measurable 20% net gain in biodiversity, and consistent with our own commitment to ‘nature recovery’ at Wicken Fen, we support the intention to plan for new green spaces through the Local Plan review process, referenced at page 6 of the Scoping Report. The Local Plan provides an opportunity to raise the scale of green space ambition for the Cambridge area, and should allow for the consideration of cross boundary opportunities, as identifed in the Issues and Options consultation document. This should include recognition of the relationship of emerging proposals for a Nature Recovery Network within a 10km radius of Cambridge to the Local Plan, led by CPPF and the Wildlife Trust, and supported by member organisations of Natural Cambridgeshire, the Local Nature Partnership (LNP) for Cambridgeshire. In particular, long term development proposals for north east Cambridge provide an opportunity to embed nature recovery proposals for the River Cam corridor within the Local Plan. Other Considerations Notwithstanding our broad support for the overarching themes and objectives of the Plan we are concerned about the scale of growth outlined in the consultation document. Whilst we understand the requirement to plan for future growth in accordance with assessed housing need, we question whether that approach can be truly sustainable. In particular, it is unclear whether the proposed requirement for 40,900 additional homes in and around Cambridge suggested for the suggested plan period of 2017-2040 is achievable without compromising environmental protections and social well-being, or indeed whether it can be reconciled with a net zero carbon target. Sustainable design and innovation, drawing on exemplar development in cities such as Freiburg, will be essential. Here at the Trust we protect and care for places so people and nature can thrive, ensuring everyone benefits. Our focus is on conserving and enhancing the special places of which we are custodians for the benefit of future generations at the same time as meeting the demand for public access to those places from a rapidly expanding population. This places enormous demands on the already stretched resources and presents a very significant challenge in terms of the deliverability of these twin purposes. We would ask that these underlying concerns are given consideration alongside our responses to the consultation, and we would welcome further dialogue around the implications of further growth for the Trust’s unique portfolio of land and property in the greater Cambridge area. I enclose plans showing the Wicken Fen Vision Area and Nature Recovery Network priority areas for information and trust these comments are helpful. Pleased let me know if you have any queries.

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We welcome the inclusion of Green Infrastructure as a cross boundary issue and would expect to see the Wicken Fen Vision Area referenced in that context. In terms of the wider geography, we note that the Ox-Cam Arc is referenced elsewhere but the potential cross boundary opportunities should be clearly articulated; the Local Natural Capital Plan will be key to achieving the GI vision and will go beyond neighbouring local authorities. See also our response to Questions 12 and 13.

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Question 7: How do you think we should prioritise these big themes: The big themes are all important, but ‘Great Places’ and ‘Biodiversity and Greenspace’ are especially relevant to the Trust’s principal visitor attractions in Cambridgeshire - Wimpole Hall, Anglesey Abbey and Wicken Fen - and resonate with the aims of the National Trust. See also our comments on the HRA and SA scoping reports.

The Plan’s impact on climate change can be reduced most effectively by avoidance and we question whether reliance on mitigation measures is enough to achieve a net zero carbon target.

Landscape scale cross boundary opportunities are as important as Green Infrastructure delivery within development sites and there should be more emphasis on the relationship between development and existing GI. Current policies focus narrowly on the potential impacts on sites protected by international designations, but additional population pressure is an issue for habitats and site managers at all GI sites. The approach to GI planning and delivery set out in the consultation document should address this issue. The Local Plan should also set out a strategic ambition for GI delivery and management over the Plan period, consistent with the Natural Cambridgeshire ‘Doubling Nature’ vision for Cambridgeshire. As an LNP member, the National Trust shares this ambition and supports the work of CPPF, the Wildlife Trust and others in formulating proposals for a Nature Recovery Network. ‘Cambridge Landscapes’ identifies 5 priority areas that would form the basis of this Network. The Local Plan is key mechanism for delivering this vision and should endorse this approach. Coupled to this, the wider Natural Capital Plan for the Ox-Cam Arc, also in preparation, will be a relevant consideration

Potential cross-boundary opportunities should be fully recognised eg the Wicken Fen Vision Area. There may also be opportunities which go beyond neighbouring Local Authorities. See also our response to Q 12.

The National Trust supports the Local Nature Partnership’s (Natural Cambridgeshire) Developing with Nature Toolkit, which aims to achieve a 20% net gain in biodiversity across development sites. This will help ensure the application of consistent standards throughout the Local Plan area.

Yes, strongly agree

The National Trust supports the aims of the Cambridge Tree Strategy. Linked to the Trust’s commitment to being carbon net zero by 2030, the Trust has made a commitment to plant and establish 20 million trees across an area of 18,000 ha throughout the UK and to create 20 green corridors to link up cities and the countryside. We are currently exploring options and opportunities across Cambridgeshire and the local planning authorities should work with relevant partners to identify and support a county wide tree planting ambition for inclusion in the Local Plan.

Heritage conservation is fundamental to the National Trusts’ charitable purposes and the National Planning Policy Framework correctly establishes a very high threshold for new development to pass in historic places. Change can be acceptable in such places but requires exceptional design quality and respect for heritage and its cultural importance.

Emphasis should be on respect for settings and avoiding/ minimising harm. The National Trust understands that major infrastructure proposals lie outside the local planning authority’s consenting powers, however Local Plan policy should establish the highest possible safeguards for the protection of all heritage assets, historic places and important landscapes. The Trust has objected to the proposed Cambourne to Cambridge busway on heritage and landscape conservation grounds because we do not consider the off-road part of the scheme across land protected by Trust covenants provides enough safeguards. See also our comments on Q 39.