Greater Cambridge Local Plan: Sustainability Appraisal of Issues and Options

Comment

Representation ID: 50268

Received: 24/02/2020

Respondent: Natural England

Natural England provided comments on the Councils’ Sustainability Appraisal (SA) Scoping Report in our letter dated 11 October 2019.
We are satisfied that the SA of Issues and Options report prepared by LUC (December 2019) has been prepared in a proper, logical and comprehensive manner and seeks to integrate the requirements of the Strategic Environmental Assessment (SEA) Directive, into the SA process. The approach to SA, as set out in the Scoping Report, including sustainability objectives, assessment methodology, consideration of relevant plans, policies and programmes and the SA framework appears to generally accord with the requirements of the Planning and Compulsory Purchase Act 2004. The report proposes to address relevant SA themes and topics relating to the natural environment including biodiversity and geodiversity, agriculture, open space provision, transport, air quality, water resources and resilience to climate change and flood risk.
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We welcome that the findings and recommendations of the HRA will inform the relevant aspects of the SA.
The SA considers the effects on key objectives of the following spatial distribution options for development:
 Option 1: Densification;
 Option 2: Edge of Cambridge – Outside the Green Belt including Cambridge Airport;
 Option 3: Edge of Cambridge – Green Belt;
 Option 4: Dispersal – new settlements.
 Option 5: Dispersal – villages.
 Option 6: Public transport corridors.
All options are assessed as having some degree of potential mixed negative and/or positive but uncertain effects on Objective 5 to conserve and enhance biodiversity, geodiversity and ecological networks. Option 2 is considered to present Biodiversity Opportunity Areas around the edge of the site, which could be used as a way to enhance the ecological networks present in the area, whilst also providing an opportunity to design in green infrastructure. Option 3 would put development in close proximity to a number of SSSIs and locally designated wildlife sites but may offer opportunities to design in green infrastructure, incorporating ecological networks, particularly at larger extensions. It is considered possible to avoid designated wildlife sites through Option 4 with opportunities to create a network of green infrastructure and biodiversity. Options 5 and 6 are predicted to have significant negative but uncertain effects with challenges to delivering integrated ecological networks.
Due to their urban nature options 1 and 2 are predicted to have a more positive effect on the protection of soils and agricultural land than the other options. Options 3, 4, 5 and 6 are considered likely to result in substantial development of greenfield land and loss of significant areas of BMV land.
At this stage of the SA process, and given the high level of the options, it is not possible to distinguish between the options with respect to water resources and waste water treatment capacity.
Natural England is unable to provide any detailed comments on the preliminary findings of the SA. We will be pleased to provide further comment as the detailed SA emerges, through preparation of the Local Plan and evidence documents including the Councils’ Green Infrastructure & Biodiversity and Integrated Water Study evidence documents. The evidence should be used to guide the most sustainable locations for development, prioritising avoidance of impacts to the natural environment including recreational pressure, air quality and water. We would also expect this to identify opportunities for development to implement significant enhancements to the ecological network. The delivery of enhancements should be secured through the relevant allocation and biodiversity policies.