Greater Cambridge Local Plan Issues & Options 2020

Thank you for your e-mail dated 13th January in respect of the above. The opportunity to contribute to the consultation is welcomed. It is noted that a questionnaire type format has been used. As you will appreciate as a navigation, water level and flood risk management authority many of the matters or questions are not relevant to our duties and functions. Therefore, please find below our response to the applicable questions asked. Where the questions raised are not specifically relevant but may be related to issues upon which we would like to make a remark we have prefixed the text with the word "Comment". Our response is as follows: (A) Risk Management Authorities The Middle Level Commissioners (the Commissioners) are a statutory water level and flood risk management and navigation authority responsible for the maintenance of major watercourses within their catchment. In addition to their statutory role, the Commissioners provide consultancy services to the Internal Drainage Boards (the Boards) within and adjacent to their area. The Boards are autonomous water level and flood risk management authorities that obtain support from the Commissioners' staff and supervise drainage at a more local level. The Commissioners and associated Boards are Risk Management Authorities (RMA), as identified by Defra and designated under the Flood and Water Management Act 2010. Together with the County, your and other District Councils and other stakeholders, the Commissioners are members of the Cambridgeshire Flood Risk Management Partnership (CFRMP). As members of the CFRMP we would generally promote issues that improve water level management and reduce flood risk on our particular systems in accordance with the respective policy statement. Please note that the Commissioners' catchment does not extend into the Greater Cambridge area. Therefore, with the exception of general navigation related issues, this response is made on behalf of the Boards for whom we provide a planning consultancy service within your Council's area of jurisdiction which are listed above.

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Both the Over and Willingham Internal Drainage Board and Swavesey Internal Drainage Board are pleased to be involved in the emerging Water Cycle Study (WCS) and Strategic Flood Risk Assessment (SFRA) and note that reference is made to the County Council in its role as the Lead Local Flood Authority (LLFA) but given that most surface, ground and treated foul effluent water discharges through higher level watercourses that cross the lower lying fen to the north of the District they are most disappointed that little reference is made in the consultation document to "water related" issues including water level and flood risk management, water resources, treated foul effluent water disposal etc. It is appreciated that the constraints created by flooding and the extents of the floodplain are not as great as those experienced by other councils within Cambridgeshire but adequate consideration must be given to these matters particularly where flooding is an issue, for example, Swavesey, Bar Hill, Girton, Addenbrookes Hospital etc. The current South Cambridgeshire Development Control Policies are some of the best and most relevant "water related" policies within the County. It would be most disappointing if this position was lost. See also the additional relevant items discussed elsewhere in this response. The inclusion of a relevant flooding section within the recently adopted Swavesey Village Design Guide document should be taken as an example of what should be included within other similar relevant documents.

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Whilst the issues of climate change and Biodiversity and green spaces are important it is disappointing to note the absence of "water related" issues including water level and flood risk management, water resources etc. The contents of the response to Question 5, above, are reiterated. These issues must be considered if the proposed growth targets are to be achieved.

(a) Comment - It is imperative that climate change is a core consideration of the new Local Plan and as such it should require developers to incorporate renewable energy generation within its proposals. (b) Comment - On the whole it has been possible to accommodate renewable energy developments. However, it is often the export cable/main that creates problems, particularly in the absence of suitable "grid" infrastructure. Therefore, it is considered that the location of the nearest appropriate grid connection and the potential detrimental effect that connecting into it may cause must also be considered as part of the planning process. (c) Comment - The peatlands of East Anglia, of which a sizeable proportion are within the Cambridgeshire Fens, represent a significant carbon store and efforts should be made to develop a policy on the loss of peat-based soils. Guidance should be taken from the Lowland Agricultural Peat Taskforce when launched by Defra and the East Anglian Fens peat pilot managed by Natural England. (d) Comment - Given that the Greater Cambridge area is within one of the driest areas in the country and is "stressed" during periods of drought it is considered essential that water efficiency incorporating a range of water saving devices is included in the design of not just new homes but any development that utilises potable water. In terms of fixtures and fittings issues such as total water neutrality, are not going to be achieved until all 'old' fixtures and fittings are totally replaced by 'sustainable' fittings. It is also considered that a change of thinking is required to ensure that potable water is provided "at source" rather than being abstracted and pumped several miles to where it is used. It is understood that this is currently being reviewed by the providers of potable water and will presumably be discussed during the preparation of the emerging Water Cycle Strategy (WCS). See also the additional relevant items discussed elsewhere in this response. (e) Comment - Where possible footpaths, cycleways, street lighting, and/or other street furniture should be positioned outside of any protected watercourse and the associated maintenance access. The Boards' prior written consent may be required and they will wish, when appropriate, to be involved in any discussions at the earliest possible stage. The Board will only give consent for hard surfaced "pavements" where a formal hardened road exists and will require that the relevant structure is positioned away from the watercourse on the landward side of the road. See also the additional relevant items discussed elsewhere in this response.

Comment - A new Local Plan is a huge opportunity to boost the natural environment. This should include wildlife spaces being created as part of new developments (as well as recreational spaces) to allow people access to nature in their daily lives. Putting in place requirements for developers to incorporate relevant biodiversity measure into new builds — at a minimum this should include 'swift bricks' and provisions for hedgehogs. SuDS should be essential in slowing the flow of and improving the quality of water entering watercourses. See also the additional relevant items discussed elsewhere in this response.

Our comments include but are not limited to the following: • A large part of the Greater Cambridge area relies on managed artificial drainage infrastructure, therefore, flooding can occur if the capacity of such infrastructure is exceeded, whether through the discharge of surface, ground or treated foul effluent water flows. Therefore, all relevant development proposals must be discussed with the relevant RMA including the appropriate Internal Drainage Board at the earliest opportunity, preferably at the pre-application stage. • In addition to the requirements of the NPPF and associated technical guide, all applications for relevant developments must include a drainage strategy to demonstrate both during and following completion of the development stage that: (a) Suitable consideration has been given to the disposal of surface, ground and treated foul effluent water flows and should detail any mitigation required; (b) Appropriate arrangements have been made for developments adjacent to watercourses; and (c) Issues of long-term ownership, funding and maintenance of the water level and flood risk management system are addressed. • On-site open watercourses should be retained in the developments design. • Adequate maintenance strips should be provided for on-site open watercourses; protected watercourses i.e. Board's Drains and Main Rivers; Sustainable Drainage Systems (SuDS) and other parts of the water level and flood risk management systems to enable ready access in an emergency and to enable suitable spoil disposal, as required. • All proposals should have regard to the guidance and byelaws of the relevant RMA including the Internal Drainage Boards. Where appropriate the contents of hydraulic models and studies must be considered. • The retention and improvement of the waterways, their settings and associated corridors in the Greater Cambridge area for navigation, environmental, leisure and tourism through the provision of related facilities. See also the additional relevant items discussed elsewhere in this response.

Issues include, but are not limited to: • The retention and improvement of the waterways, their settings and associated corridors in the Greater Cambridge area for navigation, environmental, leisure and tourism through the provision of related facilities. • The provision of a Water Space Strategy.

Refer to the response to Question 23 above.

It is noted that the Local Plan will need to consider how our water and wastewater infrastructure is developed to meet the needs of new development, and to increase efficiency so we are resilient to our changing climate". See also the additional relevant items discussed elsewhere in this response.

5 Where to build? 5.1 Our current approach to locating development Comment - Given that the proportions of housing growth in rural areas are the highest both within the Structure Plan 1999-2016 and the Adopted Local Plans 2011-2031 it is surprising how lacking the consultation document considers the rural environment.

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