Planning response C/5007/16/CC cycleway from Coldhams Lane to River Cam

The following is our response as made on 7/10/16.

 

© Google 2016

Above : Present view of Leper Chapel and Coldhams Brook floodplain – landscape impacts from extensive tree clearance and mound construction for contaminated spoil not assessed in application

tree-loss-on-ditton-meadows-southern-edge

Above : Note ridge line of Maltings and that oil depot and industrial estate is just visible at present. Tree loss on south side of Ditton Meadows will extend along blue cut line. [ and along railway line out of shot to right ]  Wood on far right shown by arrow likely to be lost as well

Table of Contents

Section 1. Overview.. 6

Section 2.  Planning overview.. 8

2.1. Deficiencies in application. 8

2.2. Deficiencies in consultation. 8

2.3. Objections as contrary to planning policy. 9

Section 3.  Details of deficiencies in application. 10

Section 4.. Heritage. 16

4.1.  Overview.. 16

4.2.  Appraisal of application. 16

4.3.  Objection. 18

Section 5. Biodiversity. 19

5.1.  Overview.. 19

Policy context. 19

5.2. Study area, suitability and standard of the studies undertaken. 21

5.3. Habitats and designated sites. 27

5.3.1. River Cam.. 27

5.3.2. Fen Ditton Meadows. 27

5.3.3. Coldhams Brook. 28

5.3.4. Old Mildenhall Railway Line. 28

5.4. Species. 28

5.4.1. Reptiles. 28

5.4.2. Bats. 29

5.4.3. Otters. 30

5.4.4. Water voles. 30

5.4.5. Invasive species. 31

5.4.6. Species and habitats of principal importance. 31

Objections for biodiversity. 32

Section 6. Landscape. 35

6.1. Overview.. 35

6.2. Deficiencies in application. 35

6.3. Deficiencies in assessment. 36

Interaction with Chesterton Bridge application. 36

Elements not assessed. 36

Omission of key view points. 36

Mitigation. 36

Visualisations as submitted. 37

Night time assessments. 37

6.4. Our assessment. 37

Effects on Ditton Meadows. 37

Effect on Barnwell Meadows, including Leper Chapel 38

Effects on Coldhams Common. 40

6.4.1. Discussion of other viewpoints. 42

6.5. Our overall assessment. 42

6.6.  Objections for landscape. 42

Section 7. Greenbelt. 47

7.1. Overview.. 47

Objection. 47

Section 8. Rights of way and common land. 48

8.1. Policy context. 48

8.2. Deficiencies in application. 48

8.3. Impacts of works. 49

8.4. Objection. 50

Section 9. Transport. 52

9.1.  Overview.. 52

9.2. Objection on transport grounds. 54

Section 10.  Traffic. 55

10.1. Overview.. 55

10.2. Objection on traffic. 55

Section 11. Contamination. 56

11.1. Overview.. 56

11.2. Objection on Contamination. 56

Section 12. Flood risk. 58

12.1. Overview.. 58

Sequential test. 58

Exception test. 58

Essential infrastructure test. 58

Local hydrology and flood conditions. 58

Modelling on Ditton Meadow.. 59

Increased flood risk from culvert removal on Coldhams Common. 59

Flooding of cycleway. 60

Alteration to functionality of floodplain. 60

Drainage discharge from underpass and bridge. 61

12.2. Objection on Flood risk. 62

Appendix 1 : 4/2 Protection of Open Space. 64

Appendix 2 : Cheap as Chips alternative to planning application details. 65

Appendix : References to mound within planning application. 66

Design and Access Statement. 66

Earth mound from FRA.. 66

Appendix : Funding sources Foot/cycle bridge between Abbey and Chesterton. 68

Planning Application. 68

Bridge design. 68

Consultation. 68

Bridge links to existing cycleways. 69

The Chisholm Trail 69

How much will it cost?. 70

 

 

 

Section 1. Overview

1.1. Following on from the Abbey-Chesterton Bridge application, a second application has been made by Cambridgeshire County Council to itself for the construction of northern sections of the Chisholm Trail.  The two applications are interlinked, but not considered in combination, despite being part of the same Chisholm Trail  and major overlap in their footprints. It has serious impacts on landscape, ecology and heritage.

1.2. The route has a total landtake of close to 5 hectares and will cut through some of the most sensitive areas within the city, including 7 Local Wildlife Sites, completely destroying one of them, Barnwell Junction Disused Railway. The route runs through the floodplain of Coldhams Brook, which includes important populations of water voles and otters and dark commuting corridors for bats. Secondary development of a cafe and retail units on Barnwell Lakes LWS is also proposed.  The locations for haul roads and compounds are not yet detailed and may involve additional impacts.

1.3. The ecological report is accompanied by no survey information other than walkovers. To quote a typo in the ecology report “Ecological features of nature conservation value in the context of the Application Site have been scoped out of the EcIA”.

1.4. We can find no record for screening for EIA as having been undertaken, and believe that this would be appropriate in this case in combination with the bridge as another element of the Chisholm Trail, of which it is an integral part[1].

1.5. The application only considers the effects of the operational cycleway and not the effects of construction, of the haul roads, of the compound area, of changes in hydrology, of light pollution and of excavations for flood defences and handling of contaminated soil.  This is an issue for biodiversity, heritage, landscape, rights of way and flood defence.

1.6. The cycle route will also have very significant landscape effects on two Conservation Areas and on the setting of Listed Buildings, including the Grade 1 Leper Chapel and the Grade II Round House on Newmarket Road.  Ditton Meadows, the iconic setting for Fen Ditton village and described as the Granchester of East Cambridge, will be significantly impacted by this major application.

1.7. This route choice appears especially gratuitous when it is realised that there is an existing cycle route along the entire length, and that sections of the path are designed to routinely flood and will be impassable. The £2m underpass proposed on Newmarket Road is directly next to a functioning crossing point.  We propose an alternative route the Cheap as Chips Trail [2]

1.8. The present application is neither coherent nor does it supply sufficient information for an informed judgement to be made. Whilst councillors may attach differing weights to the value of a new cycle bridge versus the impacts from its construction,  the effects on this highly sensitive floodplain environment should be subject to proper scrutiny and due process.

1.9. We believe that the present application should be withdrawn and resubmitted with proper information and consideration of simpler cheaper less environmentally damaging alternatives .

Section 2.  Planning overview

2.1. This is a weak application, which coupled with the significant impacts of the scheme and the complex interaction with C/5005/2016/CC we find to be of particular concern.  We have therefore divided our response into :

  • Deficiencies in application as made
  • Deficiencies in consultation
  • Objections as contrary to planning policy

2.1. Deficiencies in application

2.1.1. No adequate screening for EIA appears to have been undertaken for this project, either alone or in-combination with the Chesterton-Abbey Bridge.

2.1.2. We believe the application as submitted to be deficient for the purposes of determination in that :

  1. the application form as submitted contains factual errors and an unclear description of the project[3];
  2. it is supported by insufficient information e.g. no heritage assessment; no traffic assessment; effects on Fen Ditton Conservation Area
  • that the design and consultation process failed to consider alternatives;
  1. that the consultation process has not been transparent or inclusive and is misrepresented in the application;
  2. that no cost-benefit analysis has been made;
  3. that the usage figures as presented are misleading;
  • that no in-combination or cumulative effects with the Chisholm Trail have been considered

2.2.Deficiencies in consultation

2.2.1. Serious concerns have been expressed as to why £4.5m use of tax payers’ money  plus £8m for Chisholm Trail has been prioritised over other city projects, and about the transparency of the previous consultation process.  This is the subject of a petition to Cambridge City Council.

2.2.2. The portrayal of the consultation in the application selectively omits key details.

2.2.3. Over 600 objections were raised by concerned residents at the consultation stage, as a result of poor consultation.  This fact is not mentioned within the consultation.

2.2.4. The results of consultation meetings with Fen Ditton Parish Council are not mentioned within the application.

2.2.5. At the recent July 11 meeting of the Local Liaison Forum, residents and community organisations were conspicuously absent, and the meeting is a subject of a complaint to Cambridgeshire County Council.

2.2.6. Despite being verified on 18 August and the Cambridge Cycling Campaign being notified on 23-Aug-2016, and there being a LLF on 5 September 2016 [ where the application reference was not mentioned ], the general public were only officially notified of the planning application details on 8 September, 16 days later.  No press release announcements were made.

2.2.7. The consultation period also involved a parallel new consultation with Abbey-Chesterton Bridge, due to the original application omitting to state that the bridge did not accord with planning policy. The consultation period was then extended to 7 October, due to extensive confusion over the difference between the two applications.

2.2.8. Pre-application meeting notes with County Council planners were not made available to the public.  Responses by the public to the planning application were not published on the council website.

2.2.9.We do not believe that the consultation for this project has been carried out in a suitable or transparent fashion, either prior to or during the application.

2.3. Objections as contrary to planning policy

2.3.1. We wish to object to the planning application as submitted as submitted is contrary to Cambridge City Council plan policies and the National Planning Policy Frameworks, in particular but not exclusively that :

  1. it has an adverse effect on protected and priority species e.g. otters, bats, water voles, reptiles ;
  2. it has an adverse effect on protected sites and priority habitats i.e. County Wildlife Sites, City Wildlife Sites, floodplain grazing marsh;
  • it constitutes inappropriate development in a Green Belt;
  1. it has an adverse effect on the landscape, including the setting of the Riverside and Stourbridge Common Conservation Area;
  2. it constitutes inappropriate development in a floodplain and ;
  3. the design quality of the scheme is poor and ignores alternative better solutions;
  • it involves the development on contaminated land near Ditton Walk and disposal of contaminated waste on Barnwell Meadows ;
  • it will have adverse impacts on heritage and common land

2.3.2. The planning application has demonstrable significant adverse impacts and is contrary to NPPF or local plan policies with respect to the following issues  :

  1. Heritage;
  2. Biodiversity;
  • Landscape and Green Belt;
  1. Rights of ways and open space;
  2. Transport;
  3. Traffic ;
  • Contamination;
  • Flood risk;

for none of which an adequate solution has been demonstrated.

2.3.3. The benefits of the planning application would therefore need to outweigh these impacts, but the Transport benefits appear marginal.

2.3.4. The justification for planning approval appears to be largely based on convenience for users, e.g. reducing congestion on Green Dragon Bridge.  The Demand Assessment, based upon its own figures, primarily consists of a switch from other routes, and the modal shift is small ( <200 users[4]).

2.3.5. The Sequential Test for Flood Risk appears to have been incorrectly applied, in that no alternatives to the alignment were examined. There is no cost-benefit or other economic figures presented to demonstrate any overwhelming economic benefit.  The social impacts and equality issues of the scheme are not considered.

2.3.6. As noted above the route is also not sufficiently elevated to meet the criteria for Essential Infrastructure as to flooding and will be unusable during flood events.  As such another alternative route would be required as a “bypass” during these events.

2.3.7. As such the planning application does not demonstrate overwhelming public benefit, does not accord with being sustainable development and the planning application should be rejected in its’ present form.

2.3.8.  We will now deal with deficiencies in application and specific issues in greater detail.

Section 3.  Details of deficiencies in application

3.1.  The following tables summarises deficiencies in the application and deficiencies in information that should have been supplied but either hasn’t or supplied information that is only partial.

3.2.  We have a significant issue with the description of the planning application i.e. what is being applied for. The planning description should be comprehensive in this respect, but we note that a number of elements are unclear.

3.3.  We note that there is mention of creation of bunds and earthworks near to the Mildenhall Railway line. This element is included with D&A statement, but not described within application. Details such as we have found are included in Appendix : References to mound within planning application. It would appear to be a disposal point for contaminated waste.

Table 1 : Issues with planning application

PLANNING APPLICATION ELEMENT ISSUE Action required
FORM OF APPLICATION
Environmental Impact Assessment Project not accompanied by Environmental Assessment, despite extending to over 4-5 ha in a highly sensitive locality. Project should be accompanied by Environmental Assessment.
SCOPE OF APPLICATION
Environmental Master Plan Purpose is unclear, but majority of land is not within redline.  Affects appear not to be included in assessment and include potential extensive planting on Coldhams Common Clarify purpose

Assess effects

Development of parking at Barnwell Pits Detailed within Design and Access plan as “Restoration of 4 parking places for fishermen and restoration of 4 disabled spaces for Leper Chapel visitors”

Requires planning permission as intensification of use and Potentially facilitating development.

Details of specifications for these not included within application.

Details of parking to be included in application form.

Details of access and design to be included in application.

 

Development of café and retail at Barnwell Pits Not included within application form.

May constitute benefit to third party or as facilitating development.

Inclusion within application form.

Detailing of specifications.

Consideration of cumulative and in-combination impacts

Creation of bunds and earthworks This element is included with D&A statement, but not described within application.  Inaccurate description Clarification on inclusion
Excavation of minerals There appears to be mineral winnings for constructing the ramps, which is not included in the application. Inaccurate description Clarification on inclusion
LACK OF DETAILED INFORMATION
Lighting No lighting plan submitted with planning application.

Apparent different understandings of lighting between Demand forecasting report and Landscape assessment

No mechanism is given to prevent future installation of additional lighting

Lighting requirements for scheme need to be assessed as per ILE standards, and the impacts addressed on this basis.

This should include a full assessment of the ecological and nocturnal impacts

Drainage This element does not appear to be sufficiently detailed.

Objection noted from

Southern side of railway near Coldhams Lane noted to have significant risk from groundwater flooding during winter and spring months.

Redesign of drainage
Restoration post construction No details of this are given in application.  This prevents due consideration of impacts Application should be accompanied by a detailed restoration plan prior to planning being determined
CONSTRUCTION
Construction methods No details of these are given Details required.
Interference with site grazing No details of these are given. This will include interference with commoners rights. Details required.
Interference with public access No details of these are given Details required.
Interference with commoners rights of access and grazing No details of these are given Details required.
Traffic issues from Newmarket Road underpass This is likely to require road closures, which would create significant disruption to transport in the city, especially in context of City Deal proposed road closures. Details of proposed duration and timing should be submitted prior to planning application being determined.  Impact assessment should be made.
Pedestrian issues with railway underpass on Coldhams Common This is likely to require closure of the underpass, which would prevent access to Abbey from Coldham’s Lane.  There is no alternative for many residents to this route other than a lengthy detour via Barnwell Road. Details of proposed duration and timing should be submitted prior to planning application being determined. Impact assessment should be made. Construction should not take place during term time.
Impacts from construction traffic on residents The extent of HGV movements to and from the construction site is unclear, but is likely to be significant.  Construction movements will be through residential areas e.g. Wadloes Road Planning application should be accompanied by Traffic assessment.  Full details of movements and access routes should be detailed prior to planning.
Impacts from construction compounds The location of these does not appear to be fixed or access routes to them detailed.  This may be significant ecologically  e.g. Barnwell Pits or on residents e.g. Coldhams Lane. Construction compounds should be detailed and fixed within planning application and not conditioned.

 

 

 

Table 2 : Critique of evidence as presented, effects, suitability and planning policy

 

Issue Supporting evidence in application Appraisal of application and effects Suitability and standard of the studies undertaken Meets planning policy ?
Heritage Heritage Assessment : only considers effects on Leper Chapel only and not other buildings

No approach to Historic Landscape

Little or no consideration of setting of other listed buildings, including Round House and Papermills

Scheme has potentially significant and extensive effects on setting of Leper Chapel,

Effects on Round House likely to be severe due to proximity

Partial assessment only.

Links with landscape assessment and with Design and Access Statement are inconsistent

 

Conservation Areas Conservation Areas not included in Planning Statement

Fen Ditton Conservation area not mentioned.  Stourbridge Common and Ditton Meadows not fully considered in Landscape.

 

Significant deficiencies in application.

Landscape impacts identified within geographical area

Significant potential impacts on setting of Fen Ditton and of Ditton Meadows Conservation Areas.

Our assessment – Objections for landscape
Listed buildings Focused only on Leper Chapel.

Fails at Stage 1  of GPA3 as neither Heritage Assets nor their setting identified

Deficiencies in application.

Directly adjacent to Grade II The Round House, Cambridge

 

Heritage assessment required for all Listed Buildings

Our assessment – Objections for landscape

Biodiversity See Ecology subsection – limited to Phase 1 walkover report Extensive impacts and lack of information for assessment Additional information required; full consideration of alternatives.

Our assessment – Objections for landscape

Landscape Landscape assessment largely based on desktop assessment Visualisations as submitted not suitable and key view points missing

Fen Ditton Conservation area not considered. Conservation Areas not included in Planning Statement

Listed buildings not considered

Significant deficiencies in application

Our assessment – Objections for landscape based on significant impacts on Conservation Areas and Listed Buildings as well as Coldhams Common
Greenbelt Not considered in planning statement

No information on impacts found

Absence of information Objection : Application contrary to planning policy and will lead to urbanising influence on green belt
 Rights of way and commons No consideration in planning statement or D&A statement of effects on rights of way.

Proposals to divert or extinguish existing rights of way underclear

Definitive rights of way map as presented in application incorrect

Requires assessment

Impacts of works potentially severe

Application contrary to planning policy; application contrary to Rights of Way Policy

Objection

Common land : Not mentioned within planning application

No quantification of loss; no consideration of interference with usage

Loss of common land; interference with use Application contrary to planning policy; application contrary to Rights of Way Policy

Objection

Transport Assesses entire trail including existing usage across Coldhams Common Figures overestimate actual likely use and predicated on several unsound assumptions Objection on transport grounds of insufficient information
Traffic Traffic assessment does not assess construction traffic or effects from closures Potentially significant impacts Objection on traffic
10. Contamination Assesment of excavation of contaminated land not fully assessed; also stock piling and remediation of materials Potentially significant impacts Objection on Contamination
11. Flood risk Cycleway assessed as vulnerable to flooding; no assessment of drainage effects from underpass, etc direct into water courses Potential alternative route required; route not suitable as “Essential infrastructure” route Objection on Flood risk as not having suitable levels to prevent closures; objection on discharges

 

 

 

 

Section 4.. Heritage

4.1.  Overview

4.1.1.  The Government has set out its planning policies for the historic environment and our heritage assets in the NPPF. It was published in March 2012 and replaced PPS5.  The government published its Planning Practice Guidance in March 2014 and keeps it updated as appropriate.

4.1.2.  Both the NPPF and Planning Practice Guidance and the Practice Guide are material considerations in relevant planning applications and in relation to all listed building consents and planning permission for relevant demolition in a conservation area.

4.1.3.  Paragraphs 126 to 141 contain the heritage specific policies in the NPPF, but other policies expressly apply to the historic environment also.

4.1.4.  The objective of the policies is to maintain and manage change to heritage assets in a way that sustains and, where appropriate, enhances its significance. That significance is the value of a heritage asset to this and future generation because of its heritage interest, which may be archaeological, architectural, artistic or historic. This significance may derive not only from its physical presence but also from its setting.

4.1.5.  Harm to conservation areas and listed buildings can be caused in any number of ways including through development within their boundary or within their setting, with or without demolition being involved. Their conservation should always be given ‘great weight’ and any harm can only be justified if the application clearly and convincingly shows that the harm will be outweighed by public benefits.

4.1.6.  In order to make a sound decision a planning authority needs to understand from the applicant the significance of any heritage asset affected (paragraph 128). This may require some investigative work, but the information to be supplied with the application should be proportionate to the asset’s importance and the potential impact.

4.2.  Appraisal of application

4.2.1.  The Heritage Assessment  as submitted is primarily an Archaeological report and only considers effects on Leper Chapel only and not other buildings or wider heritage assets. There is no approach to Historic Landscape and little or no consideration of setting of other listed buildings.

4.2.2.  The application is :

  • Within the Stourbridge Common and Ditton Meadows Conservation Area;
  • Within the setting of the Fen Ditton Conservation Area;
  • Within the setting of a number of listed buildings, e.g. St Mary Church at Fen Ditton ( Grade II*) , the Leper Chapel ( Grade I ), the Round House ( Grade II) and Paper Mills ( Grade II);
  • Within the setting of city heritage assets e.g. pillbox , Coldhams Common Gatehouse and the Maltings
  • Has significant effects on industrial heritage assets of the Mildenhall Railway line, which is also a significant landscape feature
  • Within an area of previously undeveloped floodplain where undiscovered archaeology is likely.

4.2.3.  There is no overall assessment of either the significance of the heritage assets or the impact of the proposals in order to assist in determining the decision, which immediately contravenes paragraph 128 of NPPF.

4.2.4.  The scheme has potentially significant and extensive effects on setting of Leper Chapel, which we discuss under our Landscape section.

4.2.5.  The effects on Round House likely to be severe, but there is partial assessment only within the assesment.

4.2.6.  The links between historic environment, landscape assessment and with Design and Access Statement are inconsistent.

4.2.7.  No Conservation Areas are included in Planning Statement i.e. Fen Ditton Conservation area not mentioned.  Stourbridge Common and Ditton Meadows not fully considered in Landscape and only incidentally.

4.2.8.  Landscape assessment impacts are identified only within geographical area. There are significant potential impacts on setting of Fen Ditton and of Ditton Meadows Conservation Areas.  The scheme is directly adjacent to Grade II The Round House, Cambridge

4.2.9.  Listed buildings is focused only on Leper Chapel and would fail on Stage 1  of GPA3 as neither Heritage Assets nor their setting identified. A heritage assessment is required for all Listed Buildings and the Conservation areas.

4.2.10.  The comments received from the county archaeologist for C/5005/16/CC conflict with those made Historic Environment Team for Cambridge City application 16/0617/FUL, talking about the areas included in redline :

4.2.11.  “Our records indicate that the site lies in an area of high archaeological potential. It is considered likely that important archaeological remains survive on the site and that these would be severely damaged or destroyed by the proposed development. The site rests within a landscape of known prehistoric and Roman remains (for example, Historic Environment Record reference MCB6757, MCB6756, MCB6353). In addition located to the west of the application area, is the civil war fort ‘Mount Ararat’ (MCB11733).”

4.2.12.  Furthermore we note that p15 of Taylor (1999) “Cambridge the Hidden History” states that there have been significant finds of mesolithic remains on Ditton Meadows ” now in the floodplain of the Cam, on land ideal for temporary settlements when sea levels were lower than they are today.” Similarly on p16 a similar point is raised on the Neolithic archaeology and digs at Ditton Meadows.   This would seem to indicate a similar pattern to the south of the river and not of random finds as indicated within the planning statement.

4.2.13. In May 2010 Archaeological Solutions Ltd carried out an archaeological evaluation at 66-74 Ditton Walk, Cambridge, Cambridgeshire (NGR TL 474 596) stating : “The site lies within an area of high archaeological potential. Roman and Saxon occupation has been identified c.200m to the south-west of the site at Coldham’s Brook (MCB17486). The Grade I listed medieval Stourbridge Chapel is c.250m to the south-west. Three other Grade II listed buildings are located within c.250m. The site is adjacent to Wadloes Footpath, linking Newmarket Road with FenDitton, which derives its name from ‘wheat-hills’ indicating an agricultural past predating the 19th century. Early maps indicate a rural setting up to c.1890/1900 although there are some changes in field.”

4.2.14.  We believe there is the prime facia potential to cause significant damage to heritage assets present.

4.3.  Objection

 4.3.1.  We request that the applicant submits a proper heritage assessment for consideration

4.3.2.  We object on the lack of heritage information supplied and consequent deficiency of the application, which contravenes paragraph 128 of NPPF.

4.3.3.  We believe that there are obvious significant impacts on Heritage, including the setting of Conservation Areas and Listed Buildings, and the application is contrary to NPPF and local planning policies, and should be rejected as made.

Section 5. Biodiversity

5.1.  Overview

5.1.1. The 4 to 5 hectare application area includes :

  • 7 County or City Wildlife Sites : Ditton Meadows County Wildlife Site; Old Mildenhall Railway Line City Wildlife Site; Stourbridge Common City Wildlife Site; River Cam; Barnwell Meadows, Coldhams Common, Barnwell Pits.
  • Stourbridge Common Local Nature Reserve
  • Floodplain of Coldhams Brook (aka Cherry Hinton Brook or River Stour )
  • populations of protected species, such as reptiles, bats, water voles and otters;
  • priority habitats, such as floodplain grassland and chalk streams;
  • brownfield areas, scrub and many mature trees.

5.1.2. The application is in a highly-sensitive functional floodplain environment.  It directly connects to Abbey Meadows County Wildlife Site to the south. The site is part of an important network of wildlife habitat, identified within the city’s biodiversity strategy, that links :

  • East-west along the Cam valley, reaching westwards to Stourbridge Common and eastwards to meadows around Fen Ditton
  • North-south along the course of the Coldham’s Brook, which becomes the Cherry Hinton Brook higher and includes much of Abbey, Romsey and Cherry Hinton in its catchment. This tributary links the undeveloped areas of Abbey Lakes, Coldham’s Common, Barnwell LNRs and Coldhams Lane Lakes to the Cam valley.

5.1.3. The proposed route choice runs directly north south through this network of Local Wildlife Sites.  It is hard to imagine a scheme with higher environmental impacts.

Policy context

5.1.4. Para 109 of the NPPF states that : “ The planning system should contribute to and enhance the natural and local environment by:

  • protecting and enhancing valued landscapes, geological conservation interests and soils;
  • recognising the wider benefits of ecosystem services;
  • minimising impacts on biodiversity and providing net gains in biodiversity where possible, contributing to the Government’s commitment to halt the overall decline in biodiversity, including by establishing coherent ecological networks that are more resilient to current and future pressures;
  • preventing both new and existing development from contributing to or being put at unacceptable risk from, or being adversely affected by unacceptable levels of soil, air, water or noise pollution or land instability; and
  • remediating and mitigating despoiled, degraded, derelict, contaminated and unstable land, where appropriate.”

5.1.5. Para 109 of the NPPF states that : “To minimise impacts on biodiversity and geodiversity, planning policies should:

  • plan for biodiversity at a landscape-scale across local authority boundaries;
  • identify and map components of the local ecological networks, including the hierarchy of international, national and locally designated sites of importance for biodiversity, wildlife corridors and stepping stones that connect them and areas identified by local partnerships for habitat restoration or creation;
  • promote the preservation, restoration and re-creation of priority habitats, ecological networks and the protection and recovery of priority species populations, linked to national and local targets, and identify suitable indicators for monitoring biodiversity in the plan;…..”

5.1.6. Para 118 states that : “When determining planning applications, local planning authorities should aim to conserve and enhance biodiversity by applying the following principles:

  • if significant harm resulting from a development cannot be avoided (through locating on an alternative site with less harmful impacts), adequately mitigated, or, as a last resort, compensated for, then planning permission should be refused;
  • opportunities to incorporate biodiversity in and around developments should be encouraged;
  • planning permission should be refused for development resulting in the loss or deterioration of irreplaceable habitats, including ancient woodland and the loss of aged or veteran trees found outside ancient woodland, unless the need for, and benefits of, the development in that location clearly outweigh the loss

5.1.7. City Policy states under Policy 4/6 Protection of Sites of Local Nature Conservation Importance that development will not be permitted if “it will have an adverse impact on a Local Nature Reserve (LNR), a County Wildlife Site (CWS), or a City Wildlife Site (CiWS) unless it can be clearly demonstrated that there are reasons for the proposal which outweigh the need to safeguard the substantive nature conservation value of the site.”  Where development is permitted, proposals should include measures to minimise harm, to secure suitable mitigation and/or compensatory measures, and where possible enhance the nature conservation value of the site affected through habitat creation and management.”

5.1.8. City Policy 4/7 Species Protection states that “Sites, including buildings, which support species protected by English  or European Law, will be safeguarded from development proposals which would destroy or adversely  affect them. Planning permission for the development of such sites will not normally be granted unless  there is an overriding need for the development. If development is allowed, planning conditions and/or  obligations will be imposed to:

  1. facilitate the survival of individual members of the species;
  2. reduce disturbance to a minimum; and
  3. provide adequate alternative habitats to sustain at least the current levels of population of the species.”

5.1.9. City Policy 4/8 Local Biodiversity Action Plans states” rare or vulnerable habitats identified in Cambridgeshire’s  Local Biodiversity Action Plans, and habitats which support species identified in those Plans, will be  protected from harmful development. Such development will not be permitted unless the need for it outweighs the harmful effects. Where such development is permitted, proposals should include  measures to minimise harm and mitigate the harmful impacts”.

5.2. Study area, suitability and standard of the studies undertaken

5.2.1. Only the direct operational footprint seems to be studied and assessed, but the actual extent of the study areas is wholly unclear, and there are no quantification for habitats and areas lost.  Furthermore even the total extent of the application site assessed is unclear e.g. does this include mitigation land.

5.2.2. A summary of the studies is given in the following table.  The evidence issue is severe and minimal information had been supplied [ a Phase 1 survey ] by the end of the public consultation.

5.2.3. Even fundamental assessments, such as for great crested newts were lacking.

CIIEM Code of Conduct

5.2.4. Claim of compliance with “Best Practice” when unfounded are in contravention of the CIIEM Code of Conduct[5] and BS40202.

Compliance with Guidelines for Ecological Impact Assessment in the United Kingdom

5.2.5. We note that the report claims compliance with current good practice i.e. CIIEM ( 2006)[6]

5.2.6. However insufficient supporting information is supplied on surveys for birds, bats, reptiles, water voles, otters, vegetation and habitats to allow proper assessment, contrary to both CIIEM ( 2006 ) and BS4020.  Furthermore the report does not consider cumulative or in-combination effects of the site development as per CIIEM ( 2006) e.g. with the Chisholm Trail, which is significant with respect to such matters as ecological connectivity and catchment level effects.

5.2.7.We also note that the effects on designated sites ( see Section 3.4 ) are excluded from further assessment and that no assessment is made for the aquatic environment.

Bat Surveys for Professional Ecologists: Good Practice Guidelines

5.2.8.The report also claims compliance with BCT ( 2016 ) guidance[7], when survey effort is only compliant partially with BCT ( 2012).  In the more recent guidance, recommendations for survey effort in areas of high suitability for bats have increased significantly.  The majority of the survey area is in a wooded floodplain and the survey does not comply with these.

Confusion over Coldhams Brook

5.2.9. There appears to be some confusion within the text about where Coldhams Brook is. The water body described in the text as “Coldhams Brook” appears to be the boundary ditch between Ditton Meadows and the railway line.  Table 3-2 describes it as standing water.

5.2.10. This confusion is of concern as it is unclear whether the surveyors have also surveyed Coldham’s Brook itself and also whether the hydrological assessment can be correct if this is identified as a stream.

NVC survey and Phase 1 survey

5.2.11.  We are unclear of which areas were covered by this survey, since the habitat types within the NVC survey for the bridge do not correspond to the Phase 1 map e.g. no ruderal or ditch vegetation is described.  Furthermore areas identified as “Marshy grassland” by the NVC are identified as “Semi-improved grassland” by the Phase 1.

5.2.12. The conclusions on habitats which are Local Wildlife Sites as being of no significance appears to be based on a Phase 1 habitat survey at an unsuitable time of year.

Conclusion

5.2.13. The conclusion would be that the report as presented is internally inconsistent but also claims compliance with Good Practice which are demonstrably not correct.

 

 

Table 3 : Summary of evidence issues for biodiversity

Issue Supporting evidence in application Appraisal of application and effects Suitability and standard of the studies undertaken
Habitats Phase 1 survey, based on single site visits, one in October.  No detailed botanical surveys, except in bridge footprint. Extensive ecological impact on sensitive semi-natural habitats, both temporary and permanent, including secondary risks Insufficient detail and effort.  Obvious omission of rare and scarce species from data e.g. spiny restharrow, meadow barley
Designated sites
River Cam See habitats. Terrestrial only. No aquatic or river corridor survey undertaken Potential for significant changes in river frontage and river morphology from construction e.g. piling. Insufficient detail and effort of aquatic habitats and river morphology.
Coldhams Brook See habitats. No aquatic or river corridor survey undertaken Potential for significant changes in vegetation of river corridor and river morphology from construction e.g. piling. Insufficient detail and effort of aquatic habitats and river morphology.
Ditton Meadows See habitats Partial destruction; long term habitat management changes; increased disturbance Insufficient detail to assess site significance. Effects or mitigation needs
Old Mildenhall Railway Line See habitats Complete destruction likely Insufficient detail to assess site significance. Effects or mitigation needs
Barnwell Meadows See habitats Partial destruction; long term habitat management changes; increased disturbance Insufficient detail to assess site significance. Effects or mitigation needs
Coldhams Common See habitats Partial destruction; long term habitat management changes; increased disturbance Insufficient detail to assess site significance. Effects or mitigation needs
Barnwell Lakes See habitats Partial destruction; long term habitat management changes; increased disturbance Insufficient detail to assess site significance. Effects or mitigation needs
Species
Great crested newts No surveys undertaken.

Existing desktop records within 1.5km not noted in text.

Unclear. Former brick workings appears potentially suitable and does not appear to have been fully inspected Insufficient details to demonstrate absence from survey area
Reptiles No surveys undertaken Extensive habitat loss; extensive degradation of habitat network; localised extinctions and population isolation Insufficient detail to assess site significance. effects or mitigation needs
Birds No general surveys undertaken.

No surveys undertaken for Schedule 1 species e.g. Cetti’s warbler

Extensive habitat loss; extensive degradation of habitat network; increased disturbance, especially on Barnwell Pits.

Severance or destruction of habitat for Cettis warbler; impacts on nesting Schedule 1 species

No assessment of priority species or localised populations present

Significance of breeding birds within floodplain of Coldhams Brook and wintering birds on Barnwell Pits

Obvious omission of Schedule 1 species such as kingfisher, barn owl and Cetti’s warbler.

Bats Only initial day time surveys undertaken of potential roosts.  Nocturnal surveys only in bridge footprint.

Impacts on roosts considered to be conditionable.

No survey of existing light levels

Extensive habitat loss; unquantified loss of roosts; extensive degradation of habitat network; increased disturbance; interference with commuting routes; secondary lighting effects ( now or in future) from lighting of structures and footpaths. Day time surveys : Omission of pill box, of buildings as roosts; omission of some trees as roosts.

Report does not comply with Good Practice guidelines

No consideration of effects on commuting or foraging corridors; severance of roosts from commuting routes; lighting effects; disturbance effects

Otters Survey undertaken at low levels of effort Otter population known to be present on floodplains of Cam and Coldhams Brook.  Excellent network of habitat on Ditton Meadows, Stourbridge Common, Barnwell Lakes and Coldham’s Common, Mildenhall Railway Line and Barnwell Meadows.

Extensive habitat loss; unquantified loss of resting places; extensive degradation of habitat network; increased disturbance; interference with commuting corridors; secondary lighting effects ( now or in future) from lighting of structures and footpaths.

No accurate baseline data for appraisal of application. Key signs missed.

 

Water voles No survey undertaken, except in bridge footprint. Additional surveys promised, but not available for public scrutiny by 7/10/16. Water vole population present on floodplains of Cam and Coldhams Brook.  Important population corridor and excellent  but localised habitat on Barnwell Lakes and Coldham’s Common via Barnwell Meadows. No accurate baseline data for appraisal of application.

 

Mammals No appraisal for other species Hedgehog populations present on Coldhams Common
Invasive species Survey undertaken as part of Phase 1 ? Species known to be present include Himalayan balsam, swamp stonecrop ( Crassula ), floating pennywort.

Significant risk for spreading of these species due to linear nature of construction – high risk of adverse impacts

These species not identified. No accurate baseline data for appraisal of application and construction impacts.

 

Habitats of principal importance No appraisal or consideration of NERC duties on local authority Requires assessment for habitats present Failed to identify chalk streams, lowland meadows, floodplain meadows
Species of principal importance No assessment conducted for presence or significance Requires assessment Failed to identify otter, water vole, bat species ( such as soprano pipistrelle and brown long-eared )

 

 

 

5.3. Habitats and designated sites

5.3.1. River Cam

5.3.1.1. There is no survey data given on the River Cam to indicate the structure and ecology of the river and its banks and bed or aquatic biodiversity.

5.3.1.2. Based on our own observations, the southern river fringes appear to have a shallowly sloping gravel margin with emergent, floating and aquatic vegetation. Emergent vegetation includes Glyceria maxima, Iris pseudoacorus, Sparganium erectum and the tall purple flowers of Lythrum salicaria, mixed frequently with Lycopus europeaus.  Floating vegetation includes Glyceria declinata , Nuphar lutea and submerged macrophytes. The banks are steep and actively eroding into bays and small banks, but otherwise this area of the river bank appears largely natural in character.  The northern bank is piled and trained.  Water quality is good.

5.3.1.3. It is not therefore unsurprising therefore that the River Cam is a County Wildlife Site of regional significance.

5.3.1.4. Piling is likely to destroy the river’s natural morphology and alter flow regimes with an adverse effect on the integrity of the CWS.   It is inevitable that with high levels of usage that the underpass will become lit, affecting the ecology of the Cam.

5.3.2. Fen Ditton Meadows

5.3.2.1. This is described within the text section 3.2 and in Table 3-2 as “Species poor semi-improved grassland identified as the habitat Coastal and Floodplain Grazing Marsh priority habitat”

5.3.2.2. The NVC conducted identifies the habitat present as mainly MG13 Agrostis stolonifera-Alopecurus geniculatus inundation grassland.  This habitat corresponds to B5 Marshy grassland within the JNCC categories.

5.3.2.3.We note the ditch that is listed as “Coldhams Brook” was not accessed for the NVC survey in June 2015.  The ditch itself as visible from the adjacent land has tall fen vegetation with Glyceria maxima and Carex riparia dominant. Some stretches are overgrown with bramble.  It is most likely to correspond to S6 Carex riparia swamp or S7 Glyceria maxima, but is an integral feature of the meadows and Section 41 habitat.

5.3.2.4. Ditton Meadows is a City Wildlife Site containing marshy grassland which corresponds to Coastal and Floodplain Grazing Marsh, which is a national[8] and county BAP[9] habitat.  The report claims that such habitats are widespread locally, however given the surrounding area is urban such habitats are clearly localised ( hence designation as a City Wildlife Site ).

5.3.2.5. The project directly impacts the meadows by destroying habitat, altering the hydrology and urbanising the area.  The proposed mitigation by creation of grassland elsewhere is not comparable as this is not floodplain grassland; furthermore the landscaping mitigation specifies other areas as tree planting.

5.3.2.6. The project will have a significant effect on the site’s integrity.

5.3.3. Coldhams Brook

5.3.3.1. There appears to be some confusion within the text about where Coldhams Brook is. Our understanding is that it passes under the railway line via a culvert to the south of the site, and exits into the Cam about 40m west of the railway bridge.

5.3.3.2. Within this reach the brook is relatively natural, naturally meandering and includes riffles, pools.  The stream holds species such as Potamogeton pectinatis and Scrophularia umbrosa.

5.3.3.3. It should be noted that Coldhams Brook is also the major drainage for much of East Cambridge. Coldham’s Brook is a chalk stream and therefore a priority habitat, both on a county [10]basis and nationally.  There is no data presented on whether this brook contains spined loach Cobitis taenia another UK BAP species.

5.3.3.4. The brook is the only remaining substantially natural chalk stream within the city boundary and one of the few of such high quality within Cambridgeshire, and is therefore rare and irreplaceable  within the local context.

5.3.3.5. The report contains no information on the brook where it comes into contact with construction on Barnwell Meadows and Coldhams Common . The project directly threatens the brook by separating it from the surrounding flood plain by the cycleway and haul road, altering its hydrology and urbanising its bankside vegetation.  Furthermore longer term this section is likely to become lit and heavily disturbed by the Chisholm Trail, creating additional impacts.

5.3.3.6. We would conclude that the project will have a significant effect on the site’s integrity .

5.3.4. Old Mildenhall Railway Line

5.3.4.1. This is an area of dense scrub and mature trees at the south of the site, which is proposed for complete removal to create the haul road and flood compensation.  The areas which are City Wildlife Site will be completely destroyed.

5.3.4.2. This significant impact is not dealt with adequately in the report. We would conclude that the project will have a significant effect on the site’s integrity .

5.4. Species

5.4.1. Reptiles

5.4.1.1. No reptile surveys have been carried out at the site, either north or south of the river.  This is contrary to good practice guidance such as CIIEM ( 2006).  Species such as slow worm are localised in Cambridgeshire and may be present on brownfield sites such as the former depot, the Barnwell Junction Disused Railway Line and within the extensive areas of scrub to be cleared in Barnwell Pits.

5.4.1.2. There were recent losses of reptile colonies from the nearby new Chesterton Station development, which do not appear to have received compensatory habitat.

5.4.1.3. No mitigation or compensatory habitat for reptiles is proposed.

5.4.1.4. We would conclude that the project will have a significant effect on the species if present at the site, but also on reptiles within the wider network .

Birds

5.4.1.5. There are no bird surveys conducted either general surveys or for Schedule 1 species e.g. Cetti’s warbler.  We note that the location of nesting barn owls seen during the bridge bird surveys is not identified.

5.4.1.6. There is an obvious omission of Schedule 1 species such as kingfisher, barn owl and Cetti’s warbler.  Cettis Warbler has been present singing April through end May both 2014 and 2015 in Barnwell Pits.

5.4.1.7. We note that no reference is made to wintering birds e.g. snipe on the Ditton Meadows, wildfowl on Barnwell Pits.

5.4.1.8. The significance of breeding birds within floodplain of Coldhams Brook and wintering birds on Barnwell Pits is not considered.

5.4.1.9.The site development will involve extensive habitat loss; extensive degradation of habitat network; and increased disturbance, especially on Barnwell Pits, where there will be severance of habitat for Cettis warbler.

5.4.1.10.We conclude that the effect on birds has not been fully considered.

5.4.2. Bats

5.4.2.1. Under Section 2.2.3, it is noted that “The methodology used to carry out the bat surveys was followed from the Bat Surveys for Professional Ecologists: Good Practice Guidelines ( 2nd edition ) but since then the 3rd edition has been published ( BCT 2015).  The methodology has not changed between the 2nd and 3rd edition.”

5.4.2.2. The project involves extensive clearance of scrub within a river valley.  This will impact on the old Mildenhall Railway line, but also mature trees with bat potential.  Under the BCT guidelines this would be habitat of “high potential” for foraging and commuting bats.

5.4.2.3.  Given that there is no survey data, the walkover appears to omit obvious roosting features such as buildings and willow pollards, does not comply with survey effort for either manual or static surveys, and previous data only encompasses the bridge footprint of the study area, we feel that it is highly unlikely that it is sufficient to “inform mitigation for the scheme”.

5.4.2.4. We would conclude that the development would involve significant loss of high-quality commuting and foraging habitat for bats, including linkages to roosts along Coldhams Brook and along the Cam.  We would also conclude that roost sites could be potentially lost or damaged as a result of the development, but this has not been properly assessed.

5.4.3. Otters

5.4.3.1. Table 3-4 indicates “No [otter] records within 1km. No evidence of otter was identified during the protected species survey”.  This is based on a survey conducted on 20 July 2015 there was no evidence of otter activity.

5.4.3.2. However on 6 June 2016, otter spraints were found at OS grid reference TL47275998 by the Cambridgeshire mammal recorder. This location is on the short length of Coldham’s Brook going NNW towards the Cam and about 200m from the proposed bridge crossing point. We note that there are additional records for Stourbridge Common and along the Cam available online.

5.4.3.3. We also note that there are recent records for Coldhams Brook south of Newmarket Road and suitable ways for otters to cross that road.

5.4.3.4. We also note that within Atkins repot for the Chisholm Trail ( Atkins 2009 ), it is stated that “The section of the River Cam which crosses the study area had cleared grassed banks with little shelter for otters to use as sheltering habitat. However, otters are known to use the river for feeding and commuting, so potential effects on this species should be considered when the preferred route has been selected.”  This description contradicts the conditions on site at the present, but notes the need to consider the effects.

5.4.3.5. The ecological report by Atkins ( 2016) fails to assess the effects on this species.  Given that the species is an Annex II European protected species, protected under the Habitats Regulations, this is a significant omission.

5.4.3.6. The project will destroy or degrade otter habitat, both directly and by alterations to hydrology and the tranquillity of the area, which will create additional disturbance.  The use of lighting, both now and in the future has the potential to further degrade the suitability for otters. Furthermore the construction and operation will fragment habitat both along the Cam and along Coldham’s Brook will prevent access upstream in to the catchment.

5.4.3.7. We would conclude that there is a significant effect on this BAP, UK protected and European Annex II species.

5.4.4. Water voles

5.4.4.1. On 6 June 2016 mink scat were found at several places on the same length of Coldham’s Brook and where it crosses Ditton Meadows. This indicates that the local water vole population is already under threat from predation, and clearly it will be impacted further by building the trail.

5.4.4.2. The report does not assess the size of the population or its significance nor its connectivity or the vulnerability of the population.

5.4.4.3. Water voles have  localised populations within Cambridge and significant populations are present along Coldhams Brook and within Ditton Meadows.  The project will destroy or degrade habitat and construction effects may potentially completely destroy the colony by increased mortality.  Furthermore the cycleway will fragment habitat both along the Cam and along Coldham’s Brook, and planting plans for landscaping will degrade any replacement ditches.

5.4.4.4. Although the documents indicate that a 5m stand-off from suitable habitat would avoid effects, much of the trail is within 5m, there will be significant construction activity closer and there are secondary effects from landscaping and changes in site management.  Furthermore normal stand off for heavy machinery is 10m.

5.4.4.5. We would conclude there is the potential for localised extinction and for wider impacts on populations within the catchment from fragmentation.

5.4.5. Invasive species

5.4.5.1. We note that there are well known locations for species such as Crassula helmsii within the study area.  We find it peculiar that these have been missed.

5.4.5.2.We conclude that the application as presented is deficient.

5.4.6. Species and habitats of principal importance

5.4.6.1. There is no list within the report of Section 41 : Species and habitats of principal importance, but the following are noted :

  1. Chalk rivers and stream
  2. Floodplain and coastal grazing marsh

5.4.6.2. Species present known to be or potentially present :

  1. Water vole,
  2. Otter,
  3. Common Lizard,
  4. Slow worm,
  5. Grass snake,
  6. Soprano pipistrelle,
  7. Brown long-eared bat
  8. Spined loach Cobitis taenia

5.4.6.3. Para 109 of the NPPF states that ( as per the NERC Duty ):  “The planning system should contribute to and enhance the natural and local environment by:

  • minimising impacts on biodiversity and providing net gains in biodiversity where possible, contributing to the Government’s commitment to halt the overall decline in biodiversity, including by establishing coherent ecological networks that are more resilient to current and future pressures;”

5.4.6.4. Similarly it would be contrary to 4/8 Local Biodiversity Action Plans.

5.4.6.5. The impact on these biodiversity features and any net losses need to be taken into account, but at present the development is likely to have an adverse impact on protection and enhancement of these biodiversity features.

5.4.6.6. We conclude that the application is deficient in not considering them or demonstrating “no net loss”.

5.4.6.7.Exact effects are unclear due to insufficient information. The major effects include :

  • Extensive damage and fragmentation to the Cam and Coldhams Brook floodplains and physical loss of wildlife sites;
  • The removal of significant areas of scrub and trees;
  • The proposed planting of scrub and trees on grassland Local Wildlife Sites;
  • Loss of commuting routes and roosts for bats and wildlife along the river valleys, either from direct habitat loss or light pollution;
  • Loss of connectivity to the Cherry Hinton catchment via Coldham’s Brook floodplain for water voles, fish and otters and degradation of the floodplain corridor;
  • The potential for pollution events during construction, including from contaminated soil;
  • The degradation or loss from culverting of water vole habitat;
  • A net loss of floodplain grassland and wetland habitats and other Section 41 habitats;
  • Alterations to hydrology of floodplain grassland and functionality of the floodplains.

5.4.6.8.These example impacts are significant and are all contrary to both the NPPF and local plan policy.

Objections for biodiversity

5.4.6.9.  We object on the lack of information supplied and consequent deficiency of the application.

5.4.6.10.  We request that the applicant submits additional information for consideration, including:

  1. Full surveys for protected and rare/scarce species
  2. Full surveys for the habitats present;
  3. A full assessment of the impacts of the development;

5.4.6.11.  We believe there are reasonable alternatives for route choice and design.

5.4.6.12.  We believe that there are potentially significant impacts on Biodiversity and the application is contrary to NPPF and local planning policies, and that as per para 118 of the NPPF :           “if significant harm resulting from a development cannot be avoided (through locating on an alternative site with less harmful impacts), adequately mitigated, or, as a last resort, compensated for, then planning permission should be refused”

Section 6. Landscape

6.1. Overview

6.1.1. The planning application is not complete.  The actual assessments only deal with the cycle route itself and not other effects such as construction routes or the interactions with bridge elements.

6.1.2. The haul road borrow pits, spoil heaps, habitat creation and safety considerations will cause additional impacts e.g. from tree removal , that are not detailed.  In particular the removal of scrub and trees screening sections of the trail from the industrial estate on Ditton Walk will have very significant impacts, but is not identified.

6.2.Deficiencies in application

6.2.1.  Greenbelt – we note that the Landscape Assessment indicates that the Green Belt is assessed in the planning statement.  This issue however is neither assessed in the LA or the planning statement.

6.2.2.  Conservation Areas and Listed Buildings : We note that the landscape map or application does not appear to identify the boundary of the Conservation Areas or the locations or settings of listed buildings.

6.2.3.  The LA or application does not assess the Conservation Areas or Listed Buildings and their settings.  The only way to identify these therefore and the impacts on them is via cross-reading them geographically.

6.2.4.  The read-across approach to LA is not entirely suitable since they are based on too coarse a use of Landscape Character Units.  There is for instance and arbitrary division on the Barnwell Junction section where part is River Corridor – Commons and the majority is given as Residential – Post War. There are obvious discontinuities along Mildenhall Railway vegetation and changes between the adjacent industrial areas and the setting of the Leper Chapel and old Station Buildings around Barnwell Meadows, which have a pleasant open and rural feel.

6.2.5.  The division from industrial areas on Ditton Walk and  Swanns Road is important, and these areas cannot be uniformly intepreted as a single character. – “residential Post 1900 suburb”  Some of the boundaries are quite strong due to screening of existing trees, which will be lost on construction.

6.2.6.  Our interpretation is as follows :

Features Character areas
Barnwell Junction, Leper Chapel, Round House, Paper Mills –  listed as Residential – Post War
Fen Ditton Conservation Area, Ditton Meadows Conservation Area – River Corridor – Commons
Coldhams Common – Green Corridor – East Corridor

 

6.3. Deficiencies in assessment

Interaction with Chesterton Bridge application

6.3.1. No assessment is made of the interactions with the Chesterton Bridge application, either cumulatively or in-combination.

Elements not assessed

6.3.2.  We note that the mound is missing from the assessment [ see Appendix : References to mound within planning application on p66]. This element is prominent in the landscape as illustrated by the cover photograph.

6.3.3.  The effects of loss of scrub, extensively felled for construction, will be the opening up of new and undesirable views.

Omission of key view points

6.3.4.  We are unclear why several key view points are omitted :

  1. Looking north from Newmarket Road down the river valley of Coldhams Brook. The visual effects will be obvious. The following is a link to a view north from Newmarket Road across the Leper Chapel available on Google maps.

https://goo.gl/maps/9FXdNzCKP3n

Embedded map :

  1. Looking south across Ditton Meadows towards the Beadle Industrial estate

Add from Bridge objection

  1. Views from the Round House Grade II listed building towards the cycleway : As we understand from the owner the cycleway will be directly below the windows of their house and their garden will be overlooked by the ramp and adjacent road.

Mitigation

6.3.5. We are significantly concerned by a fundamental misunderstanding of the nature of Coldhams Common [within Green corridor – East ]. Within the mitiugation it is suggested that

  • the commons are “mown grassland “: they have in-fact been topped for thistle control;
  • that “vast areas of wildflower meadows” can be created – these areas are in fact already Local Wildlife Sites designated for their meadows and reseeding is wholly inappropriate

6.3.6. The landscape assessment shows a tendency to step outside the scope of scheme; fails to clearly identify key local landscape features and ignores detractors created by the scheme.

6.3.7. Much mitigation is not appropriate and does not recognise existing wildlife designations.

Visualisations as submitted

6.3.8. Presently the LA contains several inadequate photos of the site to allow assessment. There are no photomontages of the effects.  We have included some for your information.

Night time assessments

6.3.9. We are unclear why night time assessments have been omitted. South and especially north of Newmarket Road are dark areas when the flood lighting is not in use.

6.3.10. The lack of lighting in and around the Chapel creates an illusion that it is set in a more extensive area of unspoilt land, so any additional lighting will create a visual effect.

6.3.11. Whilst it is stated that the trail is unlit or has only solar lights, a proportion of cyclist using it are likely to have high powered lights.

6.3.12. There is also nothing to prevent lighting being installed at a later stage e.g. as a reaction following a crime incident. We note county officers attempted to push this agenda at the meeting of Local Liaison Forum for Abbey-Chesterton Bridge and Chisholm Trail on Monday 5th September by canvasing those present as to whether they wanted additional lighting.

6.3.13.It should therefore be presumed in the landscape assessment that the bridge and its underpasses could require much brighter lighting. It would also seem unlikely that the route is attractive to cyclists in the winter month if unlit juxtaposed against the train station. Furthermore since cyclists will not have lights but will use the ramps and access routes there is a significant point of conflict with cyclists.

6.4. Our assessment

Effects on Ditton Meadows

6.4.1.  The report notes that for “The River Corridor – Commons” – there is a moderate adverse effect on this even after 15 years.  This excludes the obvious deficiencies in consideration of the viewpoints and “the mound” not being allowed for.

6.4.2.  The project will cause significant and widespread change within the landscape character of Ditton Meadows and surrounding areas by introducing a raised cycle way, by the removal of trees along the old Mildenhall Railway line ( exposing industrial buildings to view ), as a result of construction of a haul route and borrow pits for flood defence.  These effects will be significant and long-term, reducing the quality of the landscape character by urbanising it and reducing its tranquility . We have illustrated this in Figure 1 Photo to show extent of tree loss along Mildenhall Railway Line

6.4.3. It will also cause significant impacts on the landscape character of two Conservation Areas and cause significant impacts on the settings of listed buildings, including St Mary’s Church. It will also affect the setting of Chesterton Church, whose spire is visible from the meadow.

6.4.4. Based even on the applicant’s assessment, which assess reduced extent and sensitivity of the landscape, the application would have a significant impact.

6.4.5. The mitigation by landscape planting does not appear to be deliverable without additional impacts on the biodiversity of Ditton Meadows, and is in direct conflict to that proposed for wildlife.

6.4.6. Viewpoint 9 and 10 are used to illustrate some points about Ditton Meadows.

Viewpoint 9 Viewpoint 9 (Winter): Taken from Ditton Meadows looking South towards the Beadle Industrial Estate 

6.4.7. This picture is not in the right direction. It does not look south-east, but in facts looks west towards the footbridge. The entrance sign to the footbridge is obvious on the right of the picture and the footbridge then becomes apparent in the background.  The leylandii on the industrial estate are just visible on the extreme left of the picture.

6.4.8. The viewpoint illustrates well the essentially unspoilt nature of the landscape with few or no current visual intrusions, and shows that well they exist present treebelts and vegetation are important in screening them.  However the fact that it is in the wrong direction creates significant doubts that the assessor has fully understood the impacts of the removal of trees along the edge of the Ditton Walk industrial estate, which will expose alongside very modern prefab buildings an industrial oil storage facility.

Viewpoint 10 (Winter): Taken from the corner of Ditton Meadows looking South towards the Beadle Industrial Estate. This is not an adequate picture.

6.4.9. This description is correct, but is a very distant view of the site and omits the important vistas towards the east across the meadows, taking in both the wide river corridor and distant views of Fen Ditton.  This vista is important as the discovered view as one leaves the underpass of the railway bridge, represents one of the most important entry points into the two Conservation Areas, where the viewer feels that they are standing on the edge of a largely unspoilt landscape.

6.4.10. On the right of the picture but not visible is a chainlink security fence for the railway, which is presently nearly entirely masked by scrub.

Effect on Barnwell Meadows, including Leper Chapel

6.4.11.  Looking north from Newmarket Road it is very clear that the existing scene has a very strong landscape character with an unspoilt meadow leading down from the Leper Chapel to a stream and partially screened views of adjacent listed buildings

6.4.12. View point 6 is mislabelled as “Taken from Newmarket Road (adjacent to the Round House by Coldham’s Brook) looking East.” The photograph is actually taken from Newmarket Road but is next to the Leper Chapel and facing the Round House.  The profound effect on the Roundhouse from the application cycleway from removal of trees and construction of a cycle ramp to the road at this point is obvious. The trail will cut left to right in this picture directly along the river valley.

6.4.13.This viewpoint should have been located further east, looking north from Newmarket Road down the river valley of Coldhams Brook. The visual effects will be obvious. The following is a link to a view north from Newmarket Road across the Leper Chapel

https://goo.gl/maps/9FXdNzCKP3n

Embedded map :

6.4.14.  The LA notes : “Newmarket Road is an A road and this location is already industrial in nature”. Whilst we could understand if the area was described as built-up, we cannot understand “industrial” since this is the Leper Chapel and Barnwell Meadows ?

The attractiveness is obvious to the viewer and part of the essential setting of the Chapel. The widely spaced lampposts reduce the visual incursion from the Newmarket Road and traditional Cambridge bollards and railings provide a strong sense of heritage.  As an isolated building, separated from urbanising elements, it also particularly pretty and idyllic when it catches early morning light or by twilight.

6.4.15.The effects on this view will be the introduction of a heavily used network of paths running directly towards the viewer, including an obvious connection to the underpass and a ramp to the main road. The underpass itself even if not directly visible will throw light towards the building. In the background trees will be removed punching views through to the railway line and industrial areas, but furthermore there will be the erection of a large and incongrous soil mound. On the right of the view removal of scrub along Coldhams Brook will open up presently screened views of flats along Ditton Walk.

6.4.16.The layout of the underpass involves obvious cuttings in the meadow of the Leper Chapel.  It seems peculiar that despite this being a Grade 1 listed building that no photo montages are made to show the visual effects of the development by day and night.

6.4.17.The “Green corridor” includes “large tracts of undeveloped land”. It would be incorrect therefore to argue that a subway is in character with this and it is a fundamentally built-up urban area. Furthermore the trail at this location includes wide areas of scrub clearance and tree felling ( for safety purposes ) and the introduction of mesh fencing along the trail edge. These will all create strong urbanising effects and affect the character of the setting of the Leper Chapel and Coldhams Common.

6.4.18.As we understand from the Round House owner the cycleway will be directly below the windows of their house and their garden will be overlooked by the ramp and adjacent road.  There is no assessment of this.

6.4.19. The report states that the setting of listed building “already negatively impacted by A-road” The listed buildings are either set back from the road in the context of the Leper Chapel or the proximity to the A-road is important. The Round House is a former toll booth and its setting is at the bridge crossing of the brook where tolls would have been collected : it is intimately associated with the setting of Newmarket Road. The paper mill similarly sits adjacent to a major line of communication, adjacent to an unspoit river meadow, through which its race would formerly have run.

6.4.20.Furthermore it seems peculiar for a landscape assessment to make judgements about the value of a listed building and its context.

Effects on Coldhams Common

6.4.21. We will discuss these by illustration of the viewpoints supplied, supplemented by Google maps.

Viewpoint 1 (Summer): Taken from the corner of Cromwell Road looking North towards Coldham’s Common. 

6.4.22. This picture does look north, but is not recognisable as the view from any house of the proposed planning application.  Instead it appears to show the start of the bridge to the Beehive.

6.4.23. The entrance to Coldhams Common is visible only at an oblique angle to the extreme right of the picture and there is no illustration of the alignment of the present or proposed future path.  Given that this is the proposed location for a compound, the effects are potentially profound on local residents during construction.  It is difficult to see how the visual effects have been judged on the entrance point to the common.  This is one most important access point to the common and the effects need to be assessed in full.

6.4.24. We would suggest that a more suitable viewpoint is from the crossing further east.

https://goo.gl/maps/FFQM3WhGvYN2

6.4.25. The views across the common from this point are astounding to the viewer with long vistas across the open meadows.

http://planning.cambridgeshire.gov.uk/swift/MediaTemp/41191-1950958964.pdf

Viewpoint 2 (Summer): Taken from PRoW 39/12 Coldham’s Common looking North towards the railway underpass

6.4.26. The photo demonstrates the degree of screening from the railway on the common. This section of the common is the wettest and patches of Deschampsia cespitosa are obvious on the extreme left of the picture.

6.4.27. The assessment appears to ignore the substantial widening of the path

6.4.28. Mitigation by “sowing wildflower meadows” and “bolstering peripheral” planting is no appropriate on a County Wildlife Site

Viewpoint 3 (Summer): Taken from PRoW 39/12 Coldham’s Common looking North towards the Abbey Stadium.

6.4.29. This photo is too distant to show the effects of scrub clearance along Coldhams Brook to allow construction of the new road bridge, but the screening effects of the distant tree line from the stadium are obvious.  The photo illustrates how at present the cycle path is relatively narrow and does not dominate as a landscape element, retaining the unspoilt character of the common. The doubling in width of the path and construction impacts will profoundly alter this balance, creating a width equivalent to a single track road.  The lack of any obvious effect on the grass from “overrunning” of cyclist is also obvious as is the extremely low usage – demonstrated by the complete lack of any cyclist in the picture.

6.4.30. The assessment of viewpoint 3 strays beyond the scope of works and demonstrates poor understanding of the local situation.  The lighting poles were replaced in 2015 and are not due for renewal.  Comments such as “There is a clear opportunity to make use of the vast extent through sowing of wildflowers” is not relevant to this project.

View point 4 (Summer): Taken from PRoW 39/12 adjacent to the Abbey Stadium looking North towards Newmarket Road.

6.4.31. The description is correct, but the location and direction on the Fig 2 Viewpoint locations and ZVI are not.

6.4.32. Again the heavy screening effect from Newmarket Road and the fundamentally undeveloped nature of the common at this point are obvious. Although the lamp posts form some source of urbanisation, the narrow path continues to maintain a pastoral landscape of the common. The spur path will approach from the left through the tall belt of trees along the brook.

6.4.33. The development of the spur to the underpass will punch a significant hole in the scrub belt along the brook. Additionally scrub clearance is likely along the Newmarket Road for safe access during construction to the existing entrance.  The effect of this will be to expose this section of the common to the visual detractor of the Newmarket Road bridge and traffic.  The existing spur path will double the width of the present one.  The hierachy of the paths will be incorrect since the present path will be narrower than the branch path : this will create disharmonious elements in the landscape and also confusion by removing the obvious line to the main entrance from the common.  Its acute angle of approach to the existing path will creat an areas of cut-throughs and mud during the winter, further urbanising the scene.  Lighting will be required on the spur path and will be obvious from the entrance to underpass.

6.4.1. Discussion of other viewpoints

6.4.1.1.Viewpoint 5 (Summer): Taken from a private access road (Barnwell Lake) looking North towards Newmarket Road. This picture illustrates well the present overgrown character of Barnwell Lake.  The entire view will be cleared to allow for the construction compound and then developed longer term into a cafe and retail development. The effect on the character is profound.

6.4.1.2.Viewpoint 7 (Winter): Taken from Barnwell Junction (private access road) looking East towards Ditton Walk. Again the screening effects of the very large existing trees are obvious from the house. Without public access, they can be maintained in a similar condition; with the construction of the trail many will have to be reduced or removed.  This affects not only this private view, but also the setting of the Leper Chapel and since these trees are of considerable stature extensive areas of surrounding landscape.

6.4.1.3.Viewpoint  8 (Winter): Taken from Barnwell Junction (private access road) looking South towards Newmarket Road. Some of the screening effects from trees on the left of this scene against the industrial estate are obvious.  The photo is not adequate as it has only a narrow view.

6.5. Our overall assessment

6.5.1.  The project will cause significant and widespread change within the landscape character of Ditton Meadows, Barnwell Meadows, Coldhams Common and surrounding areas by introducing an widened or new cycleway, underpass and ramps, by the removal of trees along the old Mildenhall Railway line ( exposing industrial buildings to view ), as a result of construction of a haul route and borrow pits for flood defence and by construction of mounds.  These effects will be significant and long-term, reducing the quality of the landscape character by urbanising it, introducing incongruous elements and reducing its tranquility .

6.5.2. It will also cause significant impacts on the landscape character of two Conservation Areas, a registered common, and cause significant impacts on the settings of listed buildings, including the Leper Chapel, the Round House and Papermills.

6.5.3. Based even on the applicant’s assessment, which assess reduced extent and sensitivity of the landscape, the application would have a significant impact and be contrary to planning policy.

6.5.4. The mitigation by landscape planting does not appear to be deliverable without additional impacts on the biodiversity of surrounding areas, and is in direct conflict to that proposed for wildlife.  Vice versa much of the planned biodiversity mitigation appears to impact on the landscape mitigation.

6.6.  Objections for landscape

6.6.1.  We object on the lack of information supplied and consequent deficiency of the application.

6.6.2.  We request that the applicant submits a proper landscape assessment for consideration detailing all impacts and taking into account the designations of the surrounding area and presence of listed buildings.

6.6.3.  We request proper photo montages for effects are supplied, especially in the context of the Leper Chapel and Round House.

6.6.4. We request that apparent conflicts with mitigation for wildlife are resolved.

6.6.5.  We believe that ( as identified within the applicants report and above ) there are significant impacts on Landscape, including Conservation Areas, Listed Buildings and Registered Commons  and the application is contrary to NPPF and local planning policies.

 


 

Figure 1 Photo to show extent of tree loss along Mildenhall Railway Line


 

Section 7. Greenbelt

7.1.Overview

7.1.1. We note that the Landscape Assessment indicates that the Green Belt is assessed in the planning statement.  This issue however is neither assessed in the LA or the planning statement.

7.1.2. NPPF para 88 indicates that : “When considering any planning application, local planning authorities should ensure that substantial weight is given to any harm to the Green Belt. ‘Very special circumstances’ will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm, is clearly outweighed by other considerations.”

7.1.3. No consideration is made in the document of the scale of impact or whether the harm to the Green Belt is outweighed by other considerations.

7.1.4. We note that NPPF states that local transport infrastructure which can demonstrate a requirement for a Green Belt location may be approproate. Since no alternative routes have been considered this is very difficult to demonstrate.  Furthermore some elements of the scheme are not transport related e.g. development of café and retail at Barnwell Pits.

7.1.5. The project cuts north-south through a narrow area of greenbelt and as indicated under our landscape comments creates a strongly urbanising effect, has significant landscape and biodiversity impacts and is inappropriate, especially as alternatives such as the using Ditton Walk and the “Cheap as Chips” option exist.

Objection

7.1.6. We wish to object to the planning application on the basis that :

  1. No evidence is presented as to its compliance with NPPF para 88;
  2. The development is inappropriate within a Greenbelt due to its urbanising effect.

 

 

Section 8. Rights of way and common land

8.1.Policy context

8.1.1. NPPF 74 states that : “Existing open space, sports and recreational buildings and land, including playing fields, should not be built on unless:

  • an assessment has been undertaken which has clearly shown the open space, buildings or land to be surplus to requirements; or
  • the loss resulting from the proposed development would be replaced by equivalent or better provision in terms of quantity and quality in a suitable location; or
  • the development is for alternative sports and recreational provision, the needs for which clearly outweigh the loss.

8.1.2.NPPF para 75 states that : “Planning policies should protect and enhance public rights of way and access. Local authorities should seek opportunities to provide better facilities for users, for example by adding links to existing rights of way networks including National Trails.”

8.2.Deficiencies in application

Rights of way

8.2.1.There is no consideration in planning statement or D&A statement of effects on rights of way, either on a temporary ( during construction ) or long-term basis.  Although the planning application alludes to proposals to divert or extinguish existing rights of way, the basis of application is unclear.

8.2.2.We note that the definitive rights of way map as presented in application is incorrect and that the application north of the railway line on Coldhams Common are not on existing designated rights of way.  The correct map is attached below.  Within this the FP11 crosses the main drain further east and FP12 cuts directly from this to Newmarket Road rather than hugging the field edge.  The statutory widths of these paths are 4’.  The previous alignment of FP11 is visible in dry weather and divert from the obvious bend.

8.2.3.The application fails to consider the protection of public rights of access.

Common land

8.2.4. Common land of Coldhams Common and the law surrounding, it is not mentioned within planning application.  Coldham’s Common is land from the 1807 Enclosure Act for St Andrew the Lesser, also known as the Barnwell Enclosure Act, given in award to citizens of Cambridge as a benefit of this act and held in trust by Cambridge City Council. All city residents have the right to graze on the land and to exercise rights of access.

8.2.5. The planning appraisal should include a consideration of the relevant statutory protection accorded to commons and the need for legal consent to proceed  e.g. Secretary of State consent.  It is suggested that as a minimum the 2006 Commons Act is considered.

8.2.6. There is no quantification of loss of common land resulting from the development.  We estimate it to be around 4000m2 or 0.4 hectares, excluding any land fenced for landscape plantings.

8.2.7. The total area for the cycleway would be about 940m by 3.5m consisting of the main north-south route of 857m and a side route of about 80m.

8.2.8. There is also a 650m2 block of scrub to be felled by the central culvert, that if they were to replace would need replacing and fencing off for 15-20 years.  In fact this block appears planted in the 1980s, part of the landscaping for a previous bridge, and for which the council has committed to remove within 8 weeks. Other landscaping is mentioned, but doesnt seem to be detailed.

8.2.9. There is no consideration of interference with the interests of those having rights over Coldhams Common, which are available for any citizen of Cambridge, or the provisions of the award.  Separate notes have been made on the protection of nature conservation and conservation of the landscape.

8.3. Impacts of works

8.3.1. There will be impacts on common land from construction, from land on which the cycleway is created and potentially from landscape proposals, including from fencing to protect any tree planting.

8.3.2. We note that the impacts of works are contrary to planning policy, which is not indicated in the planning statement.  The Cambridge Policy  4/2  Protection  of  Open  Space  in  the  Cambridge  Local  Plan  2006 states that: “Development  will  not  be  permitted  which  would  be  harmful  to  the  character of, or lead to the loss of, open space of environmental and/or recreational   importance   unless   the   open   space   uses   can   be   satisfactorily  replaced  elsewhere  and  the  site  is  not  important  for  environmental reasons.”  The full text of this is contained within Appendix 1 : 4/2 Protection of Open Space on p64.

8.3.3. This further states that “In the exceptional circumstance that the open space uses could be replaced elsewhere, and the land is not important for environmental reasons, planning permission will only be granted if an equivalent and equally convenient area is secured.”

 

 

 

8.4. Objection

8.4.1. We wish to object to the planning application on the basis that :

  1. Details are unclear as to what rights of way and commoners rights will be affected by the application;
  2. No consideration has been made as to loss of common land, effects on common rights or effects on rights of way, either on a temporary or permanent basis;
  3. The legal obligations of Cambridge City Council in managing the land in trust have not been considered;
  4. No proposal has been made for compensatory land;
  5. The development is inappropriate due to being harmful to the  character of, or lead to the loss of, open space of environmental and/or recreational   importance
  6. The application is contrary to Cambridge Policy 4/2 Protection of Open Spaces and NPPF para 74 and 75.

 

 

 

 

 

Figure 2 : Definitive right of way map © Cambridgeshire County Council

Section 9. Transport

9.1.  Overview

9.1.1.  The application appears to be primarily justified on transport grounds i.e. congestion for cyclists at nearby Green Dragon Bridge or reduction in car traffic.

Actual usage

9.1.2.  However only about 10% use of the headline figure for the bridge would be an immediate “modal shift” i.e. instead of car, train or bus, they are cycling or walking.  Most of the people are simply switching from the three other bridges nearby or going to Chesterton train station instead of Cambridge.  The bridge therefore simply redistributes existing use.

9.1.3.  Actual present trips switched from car to walking or cycling is 381 ONE WAY TRIPS (304 cycle and 77 pedestrians)[11]  equivalent to 190 individuals based on return journey, equivalent to £11,842.11 per user.  This figure includes some switches from bus, so may be lower.

Reliability of modelling

9.1.4.  We note that the approach used via Webtag does not justify modelling for pedestrians changing routes based on their “quality”. It is therefore are unclear if the results for pedestrains are reliable.   The modelled figures were also increased from those observed as a “correction factor” for apparent low usage, which will probably lead to further overestimation of use of the facility.

9.1.5. The traffic figures were for May. We believe that during periods of bad weather and winter months usage will be lower than modelled.

9.1.6.  We note that all of the approaches to the bridge will be unlit ( from upto 1km) and without overlooking houses or boats. By contrast both Fen Ditton and the Riverside Bridge have street lit approaches and overlooking houses or boats.

9.1.7.  We believe that the locations are too isolated for many users to prefer to use with confidence.

Economics

9.1.8.  Based on 123 900 people in Cambridge, and the new Abbey-Chesterton Bridge costing at least £4.5 million, it will cost each Cambridge citizen £36.32 to fund building the bridge.

9.1.9.  The Chisholm Trail costs a further £8 million. With these together only 3150 people will use the bridge[12].

9.1.10. The cost of the bridge alone – £4.5m over 3150 users – equates to £1429 per user.   With additional costs of the Chisholm Trail, the cost per user rises to £3,867.37 or £193.37 per user per year assuming 20 years lifespan. [13] There is therefore a huge net transfer to cycle users of the bridge to the detriment of others in Cambridge.  If we were to benchmark it in monetary value,  the £12.5m for the project represents another 70-80 units of housing for Cambridge – equivalent to permanent local homes for close to 250 people avoiding the necessity for travel by car.

9.1.11.  Based on a Cost Benefit Ratio of 30:1 as indicated by council officers, the benefit of each switch from motorist to cycling or walking would be £354,330.71. We feel this is unlikely.

9.1.12. If the project is to proceed, costs should be reduced. Friends of Coldhams Common propose the Cheap as Chips option – a modification of the Chisholm Trail to use existing infrastructure as far as possible and focusing on signposting, resurfacing existing paths and fixing potholes in roads. This would increase attractiveness to cyclists, but also reduce environmental impacts ( since the “Cheap as Chips” option already exists ).

Poor transport connections

9.1.13. We also note that there remains a connection via an unsuitably narrow and unlit southern walkway, which is less than 2m wide.  The site is in a remote location and will not be used late at night by those concerned about security.  The lack of lighting is an impediment to partially sighted users of the facility, but provision of lighting would create additional environmental impacts. We note that the width of the walkway is too narrow to allow disabled users or those with prams through safetly.  The walkway is presently already unsafe at levels of use of a fraction of that predicted.

9.1.14. On the north side of the bridge, we note that no connection is made to allow residents of Fen Road east of the railway to use the bridge or the underpass.  No connection to east of the line on Fen Road means that the residents, school children and workers there cannot use the facility or safely avoid the level crossing.  Given the ethnicity of many of these residents, we find this decision to be of concern.

9.1.15.We believe that the scheme has poor transport connections, will be less attractive than existing routes, and is contrary to City policies.  We find the lack of a connection to Fen Road east of the railway line to be of significant concern.

Encouraging London commuting

9.1.16. With direct access from Abbey to Chesterton Station will become a base for London commuters, who will then price out the local community and increase travel distances for local workers.  The purpose of the station is to encourage commuters coming into Cambridge rather than cause the converse and push the working community further out.

9.1.17. There is no assessment of the social impact of the cycleway and bridge in terms of transport. We conclude that the social impact of this should be assessed in that there may be unforeseen consequences in an increase in road traffic from the development.

Flooding making cycleway inoperable or unattractive

9.1.18. Within Coldhams Common and especially Barnwell Meadows, sections of the trail lie at flood levels and will be flooded and inoperable. Our experience of flood events is that the Cam discharges faster than the Coldhams Brook and that floods stand for some time within the catchment of the Brook.

9.1.19.  A similar flood risk applies to the underpass on Newmarket Road and the underpass on Coldhams Common once levels are reduced.  A similar underpass on Barnwell Road is often full of puddles and has historically been flooded.  It must be remembered that even relatively minor flooding will reduce attractiveness and remove utilisation of underpasses.

9.1.20.  However it is clear that the route is not sufficiently flood proof to meet standards for Essential infrastructure test, and would require an alternative route as a backup.

9.2. Objection on transport grounds

9.2.1. The project has significant environmental impacts. In order to demonstrate overriding public interest would need to be demonstrated, which is not.

  • We object on the basis that no cost-benefit analysis has been carried out.
  • We object on the basis that the route, due to periodic flooding, security and lighting concerns and its poor connection to employment areas e.g. Ditton Walk , is less attractive than existing routes
  • We object that the route does not meet flood protection standards for “Essential infrastructure”
  • We object that no social impact or equality study has been conducted for it;
  • We believe there should be transparency as to why there is no connection to Fen Road east of the railway line;
  • We believe that by encouraging London commuting the scheme may increase road traffic by increasing houses prices in Abbey and excluding local key workers;
  • We object on the basis that no alternative solutions have been properly examined e.g. “do nothing”
  • We also believe that no evidence is presented as to overriding public interest, and that the application should therefore be rejected.

 

 

Section 10.  Traffic

10.1. Overview

10.1.1.  The application does not deal with traffic impacts from the development, in particular for construction e.g. import and export of materials for the haul road and flood defence excavations.

10.1.2. This includes excavation of possibly contaminated ground [ not clear as not covered by Contamination Assessment ] and the construction traffic for lorries will probably use Wadloes Road, a quiet residential road [ not clear as contains no Traffic Assessment ].

10.1.3. Construction may involve closure of Newmarket Road on a full or partial basis interference with the railway as well as footpaths across Coldhams Common, under the walkway on the Cam and elsewhere [ see p 49 8.3. Impacts of works ].

10.1.4.We conclude that the impacts of traffic are potentially severe and should be considered before the application is determined.

10.2. Objection on traffic

10.2.1. We object in that :

  1. The traffic movements to and from and within the site for construction and the impacts from full or partial road and footpath closures are potentially significant, based on the location within an urban area;
  2. We believe that a Traffic Assessment is required as part of the application and should not be conditioned.

 

 

Section 11. Contamination

11.1. Overview

11.1.1. There Is confusion in the planning application as to what materials will be excavated and whether this falls under the bridge or trail application. The following is an extract from p18 of Design and Access Statement Chisholm Trail : Floodplain Compensation Statement and Drainage details, which provides a sort of overview :

11.1.2. “The Chisholm Trail will run in the flood plain as it crosses Ditton Meadows. A complete assessment of its effect and the necessary compensation is set out in a detailed appendix.

11.1.3. The Trail and approach ramps to the Chesterton Bridge (area A) will occupy a small volume of the Zone 3 and Zone 2 Flood Plain. This is compensated by excavating and lowering the level of the ground in areas B, C and D.

11.1.4. These have been selected so as to provide the correct values level by level and volume by volume thereby ensuring that the Chisholm Trail has no adverse effects on fl ooding .

11.1.5. We anticipate that some of the material excavated from these areas will be suitable for constructing the bridge ramp, and the causeway over low sections of the Meadows.  Rather than truck any surplus then remaining away from the site, as far as possible these materials will be used to create a low bank along the boundary of the Triangular Wood on the bed of the former Railway and a southern mound, both of which lie above the fl ood plain (E). The bank will become the boundary of the replanted wood.

11.1.6. South of the Mildenhall railway the Chisholm Trail runs very close to the top of the flood plain. Any compensation which might be required will be neutralised by carefully setting the path at the appropriate levels and by ensuring that any excavated materials are landscaped to levels above the floodplain.”

11.1.7.It is very clear from the above that considerable ground disturbance is necessary.

11.1.8.In particular the applicant proposes removal of parts of the old Mildenhall Railway line for flood compensation, including an area near the oil depot on Ditton Walk and constructing a mound of excavated material in a flood plain. Local residents believe that oil deliveries would formerly been made along this railway line in the 1950s and 60s, and this would also impede any historical contamination movement from the depot.

11.1.9. This application excludes(?) excavation of possibly contaminated ground along the old MIldenhall Railway line, which is clear not covered by this planning application, but by that of the bridge, but includes dealing with spoil. This would appear to be waste transfer.

11.2. Objection on Contamination

11.2.1. We wish to raise an objection based on two points :

  1. That the contamination issues in these areas have not been fully considered, since they are not within the scope of the submitted contamination report;
  2. That the method for disposal of any excavated contaminated materials is not identified and could be within the floodplain e.g. used for haul roads or bridge embankments.
  3. That it is not clear under which planning application the request is made or whether waste will be transferred between the two projects i.e. that there is a waste transfer scheme.

 

 

Section 12. Flood risk

12.1. Overview

Sequential test

 

12.1.1. The Sequential Test for development in a flood plain requires that alternative locations and solutions are demonstrated before development is considered within a floodplain.

12.1.2. We note that the Sequential Test appears to have been incorrectly applied for development in Zone 3, and in fact only locations in very close proximity were looked at i.e. the presumption was always of a bridge in this location as being necessary.  Other alternatives such as “Do nothing” or upgrades to Green Dragon bridge were not considered, but there is no demonstration that they would not deliver the project objectives.  No evidence for alternatives being looked at have been explored.

Exception test

 

12.1.3. The Exception Test must be followed subsequent to the Sequential Test : “If following application of the Sequential Test it is not possible consistent with wider sustainability objectives for the development to be located in zones with a lower probability the Exception Test can be applied.”

12.1.4. There is however as noted previously no clear evidence as to the importance of the scheme ( se Transport ).  The Exception Test is not therefore met as the scheme is not of overriding public importance or essential as proposed.  It is noted that p2 of the accompanying Technical Note for the Flood Risk Assessment indicates that other locations were dismissed before consultation in July 2014, but also that “the alternative alignments were not considered suitable in line with the wider objectives of Cambridgeshire County Council therefore the exception test has been applied.”

Essential infrastructure test

 

12.1.5.  Within Section 5 of the FRA it states in the summary points “The proposed scheme has been classified as ‘Essential Infrastructure’ in the FRA and therefore it must be demonstrated that it will be operational and safe during times of flood. A part of the trail will not be accessible during the 1 in 1000 (0.1%) annual probability flood event with a 20% allowance for climate change. It is suggested a strategy is put in place to use appropriate temporary signage to inform pedestrians/cyclists when the trail is flooded during extreme events.”

Local hydrology and flood conditions

 

12.1.6. Furthermore we note that much of Ditton Meadows is flooded annually, so flood return periods are likely to be underestimated.

12.1.7. Ground water flow is very common along the high ground along the edge of the meadows in early spring, and has not been included within the hydrological modelling.

12.1.8. We also note that fluvial flooding only seems to have been considered for the Cam and the connectivity of Coldhams Brook has been ignored.  There have been recent flood events on Barnwell Road caused by the brook, which is also the main drain for East Cambridge.  Its flood plain includes much of Ditton Meadows, but this hydrological connection will be impeded by the haul road.  Connectivity between the Cam and the floodplain via reverse flows up the ditch along the railway line will also be compromised.

12.1.9. We note ( see Contamination ) that some of the compensation areas involve contaminated ground and may impact on the hydraulics of contamination within the old oil depot. We also note within the proposed compensation areas that there is an intermediate pressure gas main; that they include sections of PROW; that they contain BAP habitats and that they contain commuting habitat and potential roosts for bats, and that it will involve the destruction of a City Wildlife Site.  We do not believe that they can therefore be delivered.

Modelling on Ditton Meadow

 

12.1.10.The FRA seems to be split between the two applications by catchment – one assessing Coldhams Brook and the other the River Cam.  The interaction of the two water courses does not appear to be considered.

12.1.11.The following extract illustrates this : “The channel east of the existing railway that will be realigned and culverted only conveys a small proportion of Coldham’s Brook flow, therefore it’s not included in the 1D model. The proposed Chesterton foot/ cycle bridge over the River Cam has not been modelled, as the River Cam flood extents dominate the area north of Mildenhall railway. Impacts of this feature to flood risk caused by the small channel of Coldham’s Brook are expected to be insignificant. The impacts of the Chesterton Bridge to fluvial flooding risk have been examined separately in the Chesterton Bridge FRA (Atkins, 2016b).”

12.1.12.Within Ditton Meadows, we have made previous comments about the oversimplification of the relations with the floodplain.  The model cannot allow for reverse flow along the channel east of the railway line or for bypass flow and storage.

Increased flood risk from culvert removal on Coldhams Common

 

12.1.13. We note that the present culverts are attenuating downstream flow and will cause an increase of 13mm when removed. We however believe that this may be more severe due to the increasingly flashy nature of Coldhams Brook. We note that it increases flood risk on Ditton Walk by 11mm

12.1.14. We suggest that this is mitigated by installation of a riffle at the bridge location.

Flooding of cycleway

12.1.15. The following notes are taken from the FRA :

“The majority of the scheme will be at low risk of flooding from surface water, with an annual probability of between 1 in 1000 (0.1%) and 1 in 100 (1%). Small isolated areas at medium and high risk are present with an annual probability of flooding between 1 in 30 (3.3%) and 1 in 100 (1%) respectively. These sections of the Trail are confined to locations near the Barnwell Junction and the Abbey Stadium.”

“Surface water flood depths throughout the majority of the scheme are indicated to be no greater than 300-900mm, while at the proposed crossing upstream of Newmarket Road and Surface Water Management Plan (SWMP) covering the whole of Cambridgeshire which has been updated in 2014 (Hyder, 2014). “

“Specific areas were prioritised as high risk of surface water flooding for further investigation. The areas were prioritised based on a multi-criteria analysis and a detailed SWMP plan has been undertaken for Cambridge and Milton (Hyder, 2011b). This indicated South and North Chesterton (west of the scheme) and Coldham’s Common (south of the scheme) as wetspots; areas deemed to be at a significant risk of surface water flooding. The updated SWMP ranks North Chesterton and Coldham’s Common in third and fourth place respectively.”

“Hazard mapping provided in the strategic level SFRA (WSP, 2010) also identifies the area at medium to high”

12.1.16.Although on p11 it is stated that “ Given the depth to groundwater levels at the site it is unlikely groundwater flooding will pose a future risk to the scheme”, we would contest that there is significant ground water flow south of Coldhams Common, perhaps as a result of historical deep excavation here disturbing layered clay, which results in strong spring flow during the winter and spring.

12.1.17.There is therefore a significant risk of surface water flooding identified on Coldhams Common.

Barnwell Meadows

12.1.18.We also note that within Barnwell Meadows that sections of the trail lie at flood levels and will be flooded and inoperable. Our experience of flood events is that the Cam discharges faster than the Coldhams Brook and that floods stand for some time within the catchment of the Brook.

12.1.19.A similar flood risk applies to the underpass on Newmarket Road and the underpass on Coldhams Common once levels are reduced.  A similar underpass on Barnwell Road is often full of puddles and has historically been flooded.  It must be remembered that even relatively minor flooding will reduce attractiveness and remove utilisation of underpasses.

Alteration to functionality of floodplain

 

12.1.20.Furthermore the flood risk is simply that, but is conflated within the planning report with being a hydrological report to assess the effects on ecology.

12.1.21.The construction of the trail will necessarily isolate the floodplain of the Cam and more severely Coldhams Brook from their nominate rivers, and alter hydrological regimes and deposition rates. Connection by culverts at single points is not an adequate substitute for this.

Drainage discharge from underpass and bridge

 

12.1.22.The drainage from the Newmarket Road underpass appears to be directly into Coldhams Brook.  This creates issues in that the installation of the pipe is not within the redline of the development, but also that discharge consent would be required. [ Omission from application ]

12.1.23.The Newmarket Road underpass has proposed drainage into Coldhams Brook.  This has not been assessed within the Ecology assessment and may either impact directly or via pollution.

12.1.24.There is no assessment of drainage requirements for the compound on Barnwell Lake.

12.1.25.Within the designs the idea of a SUDs system of centrally draining cycleway is mentioned : this would inevitably clog with leaves and detritus and near Coldhams Lane will be vulnerable to groundwater flow and saturated soils. We believe this should be discarded and an assessment made of conventional drainage.

Impedance of drainage

12.1.26.Where the trail passes over marshy ground i.e. the majority of the site, we believe that the cycleway will impede lateral soligenous and surface water movement creating puddling on adjacent ground and preventing soakaway and drainage to ditches.  This is obvious as the cycleway is on heavy gleyed clays through much of these lengths.

12.1.27.This is also of concern where non-cycleway footpaths are close to the trail.

12.1.28.The FRA presumes that the trail will not be under a depth of water and impassable. However even relatively shallow depths on an intermittent basis will be sufficient to reduce its attrativeness considerably.  It must be remembered that even relatively minor flooding will reduce attractiveness and remove utilisation of underpasses.

12.1.29.The proposed scheme in order to be built in a floodplain would have to be essential infrastructure and “operational and safe during times of flood”. However the section north of Newmarket Road is not : it is suggested that an alternative route will need to be provided to allow for this !

12.1.30.The construction may interfere with the floodplain functionality, which is greater than simple urban flood defence

12.2. Objection on Flood risk

12.2.1. We believe that the project, both during construction and in operation may increase flood risk, especially in relation to Coldham’s Brook, which is the main drain for East Cambridge. We wish to object in that :

  • We do not believe that the Sequential Test has been correctly applied in looking at alternatives solutions and location.
  • We do not believe that the Exception Test has been correctly applied and was pre-determined, but also that there is no demonstration of overwhelming need for the project.
  • We believe that there is the potential for increased flood risk from Coldhams Brook.
  • We believe that the compensation areas are not properly assessed for their impacts, but also cannot be delivered and therefore there will be an adverse effect on flood risk.
  • The development would thus be contrary to National Planning Policy Framework and the local plan and should be rejected.

 

 

 

Appendix 1 : 4/2 Protection of Open Space

“Development will not be permitted which would be harmful to the character of, or lead to the loss of, open space of environmental and/or recreational importance unless the open space uses can be satisfactorily replaced elsewhere and the site is not important for environmental reasons.”

4.6 Open space is an essential part of our natural resource base, making a significant contribution to the setting, character, amenity and biodiversity of the City and local communities. Open space protected under this policy includes commons, recreation grounds, Historic Parks and Gardens, sites with nature conservation designation, outdoor sports facilities, provision for children and teenagers, semi-natural green spaces, allotments, urban spaces and cemeteries. Although the majority are public open spaces, private spaces that contribute to the character, environmental quality or biodiversity of the area are protected. These spaces are often contiguous and have an important linking role as conduits for wildlife and for access by foot and cycle and recreation opportunities. Many have a dual importance, both for the contribution they make to leisure provision and for their environmental importance. Some still retain evidence of significant historic land use patterns.

4.7 Open spaces protected under this policy are:

  • areas designated as Green Belt on the Proposals Map;
  • areas designated Protected Open Space on the Proposals Map; and
  • undesignated areas which fulfill at least one of the Criteria to Assess Open Space included in the Plan. This has separate criteria for Environmental and Recreational Importance.

4.8 Only proposals which respect the character of these areas, and improve amenity, enhance biodiversity, improve sports facilities or increase public access will be supported. Further guidance on this is included in the Open Space and Recreation Strategy.

4.9 The Open Space and Recreation Strategy includes an assessment of sites identified on the Proposals Map. This shows whether each site is important for environmental and/or recreational reasons.

4.10 There is currently very little recreational open space surplus to requirements, as set out in the Open Space and Recreation Strategy. The majority makes a major contribution to the recreational resources of the local area and could not be recreated elsewhere. In the exceptional circumstance that the open space uses could be replaced elsewhere, and the land is not important for environmental reasons, planning permission will only be granted if an equivalent and equally convenient area is secured.

 

 

 

Appendix 2 : Cheap as Chips alternative to planning application details

 

 

 

Appendix : References to mound within planning application

 

Design and Access Statement

“Extract from p18 of Design and Access Statement Chisholm Trail : Floodplain Compensation Statement and Drainage details

The Chisholm Trail will run in the flood plain as it crosses Ditton Meadows. A complete assessment of its effect and the necessary compensation is set out in a detailed appendix.

The Trail and approach ramps to the Chesterton Bridge (area A) will occupy a small volume of the Zone 3 and Zone 2 Flood Plain. This is compensated by excavating and lowering the level of the ground in areas B, C and D.

These have been selected so as to provide the correct values level by level and volume by volume thereby ensuring that the Chisholm Trail has no adverse effects on fl ooding .

We anticipate that some of the material excavated from these areas will be suitable for constructing the bridge ramp, and the causeway over low sections of the Meadows.  Rather than truck any surplus then remaining away from the site, as far as possible these materials will be used to create a low bank along the boundary of the Triangular Wood on the bed of the former Railway and a southern mound, both of which lie above the fl ood plain (E). The bank will become the boundary of the replanted wood.

South of the Mildenhall railway the Chisholm Trail runs very close to the top of the flood plain. Any compensation which might be required will be neutralised by carefully setting the path at the appropriate levels and by ensuring that any excavated materials are landscaped to levels above the floodplain.

Throughout almost its whole length the Trail and its hard surface will have no effect on run off or drainage. The path runs level and will be constructed with a central camber throughout so that rainwater will in effect soak away at the point it falls, just as it does at present.”

Earth mound from FRA

“4.2.4.1. The proposed Chisholm Trail will include an earth mound adjacent to the disused railway. Initial proposals have indicated this feature would be located within the floodplain of the River Cam. Due to the urban nature of Cambridge there is limited suitable land adjacent to the River Cam floodplain to use for floodplain compensation. Therefore an alternative location for this feature has been recognised in the Design and Access Statement (Cambridgeshire County Council, 2016)

The alternative location is located at the western side of the disused railway. This area is shown by the hydraulic models to be partially within the floodplain of the River Cam. A detailed topographic survey undertaken throughout this area shows some of this area to be at higher elevations than held within the hydraulic model and therefore at lower risk of flooding. The flood outlines in this area have been refined to show the reduced flood extent, these are shown in Figure 4-2.

The reduced flood extent partially overlaps the mounds footprint where ground elevations range from 5.5 to 5.7mAOD. Floodplain compensation would be required where it displaces the existing floodplain up to the River Cam flood level of 5.7mAOD.

The final design footprint and elevation of the mound will be developed during the detailed design when detailed spoil volumes will be determined. The Disused railway embankment to the south of the proposed mound is at sufficiently high elevation to provide ample floodplain compensation on a level-by-level basis.

The total amount of volume which could be gained from this area is 546m3, the full level-by-level breakdown is provided in Appendix C as the unused Compensation Area 3.”

Fig 4-2 shows location.

 

 

Appendix : Funding sources Foot/cycle bridge between Abbey and Chesterton

http://www.cambridgeshire.gov.uk/info/20051/transport_projects/469/cambridge_city_projects/3

Date consulted 2/10/16

A new foot and cycle bridge over the river Cam was approved by the County Council’s Economy & Environment Committee on the 17 November.

This bridge would link the Abbey area of the City to Chesterton on private land, known as Ditton Meadows, close to the existing railway bridge and the site for the new Cambridge North.

A bridge between Abbey and Chesterton would link communities and improve opportunities for local and outlying residents to use their bike or walk. Encouraging more people to cycle or walk reduces congestion, improves health and boosts the local economy.

Modelling suggests there would be an average of 3,000 foot or cycle journeys per day over a bridge in this location, reducing demand on the heavily used Green Dragon footbridge. It would also link to other cycle networks including the proposed route from the north to the south of the City known as the “Chisholm Trail”.

Planning Application

A planning application has been made for the new proposed foot and cycle bridge across the river Cam. The planning reference is: Ref: C/5005/16/CC. The application and more detailed information can be viewed via this link.

Bridge design

Knight Architects, are the appointed bridge designers. The architects took into account the results of the public consultation in 2014 and comments made at a public meeting which they attended in February 2015 in their designs. Many questions were raised about the bridge and other local concerns at the February meeting, after the meeting Abbey-Chesterton Bridge Q&A (pdf, 328KB) was circulated.

Councillors have authorised the Project Officers to proceed to prepare and submit a planning application.

Visuals of the bridge can be found in Knight Architect’s Presentation (pdf, 9 MB).

Consultation

On Monday 7th September 2015 Knight Architects unveiled bridge designs for the Abbey-Chesterton Bridge. This followed from a public consultation that was undertaken from 30 June to 28 July 2014 on the possibility of creating a new foot and cycle bridge in this area. The consultation involved an online survey as well as the distribution of leaflets and events across Abbey, Chesterton and Fen Ditton. As a result proposals were developed based on feedback from local stakeholder events.

There were 885 responses to the consultation held in February. 79% of respondents said they were likely (25%) or very likely (54%) to use a bridge over the Cam on Ditton Meadows.

Preferred locations were:

  • location 1 (close to the existing railway bridge) – 72% support
  • location 2 (over 30m from the existing railway bridge) – 8% support
  • neither, I see no need for a bridge – 13% support
  • other – 7%

Results are available in the Consultation Analysis (pdf, 147KB).

Bridge links to existing cycleways

Please see the Cambridge Cycle Map (2MB) for more detailed information about the locations of nearby National Cycle Network paths, Sustrans’s routes and other dedicated local on and off-road links.

The Chisholm Trail

A bridge in this location would also form part of the ‘Chisholm Trail’, a route linking St Ives to Addenbrooke’s and beyond using the Guided Busway. This mainly off-road walking and cycling route is being proposed as part of the Greater Cambridge City Deal. If planning permission for the bridge is granted, then it will from part of the Chisholm Trail route.

You can find out more about this project on the Chisholm Trail webpage. This separate project is part of the Greater Cambridge City Deal and is subject to the City Deal Executive Board decisions.

How much will it cost?

The cost a new bridge near the railway bridge is anticipated to cost at least £4.5m. This project will be funded from a variety of sources including developer contributions and Department for Transport Cycle City Ambition Grant.

 

 

 

 

[1] [ see Appendix : Funding sources Foot/cycle bridge between Abbey and Chesterton

[2] [ see Appendix 2 : Cheap as Chips alternative to planning application details or see our website

[3] We note that there are two versions of the application form on the council website.

[4] This switch includes switches from trains and buses to cycling and walking.

[5] CIIEM (   )

[6] CIIEM ( 2006) Guidelines for Ecological Impact Assessment in the United Kingdom.

[7] Bat Conservation Trust ( 2016) Bat Surveys for Professional Ecologists: Good Practice Guidelines (3rd edition)

[8] See http://jncc.defra.gov.uk/Docs/UKBAP_BAPHabitats-07-CoastFloodGrazingMarsh.doc

[9] See http://www.cpbiodiversity.org.uk/download/66/

[10] See http://www.cpbiodiversity.org.uk/download/73/

[11] Figures from Atkins ( 25 May 2016 ) Chesterton Bridge : Chesterton Bridge Demand Forecasting for Cambridgeshire County Council. On planning app website – figs on p14

[12] 6300 single trips = 3150 return trips

[13] Since there is already a well developed plan for an Addenbrokes Station and Riverside Bridge is only a few years old, 20 years seems optimistic.

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