Protect Rural Peterborough 
41 Peterborough Rd
Castor, Peterborough
8th February 2017

Peterborough Local Plan Consultation
Sustainable Growth Strategy
Peterborough City Council,
Town Hall,
Bridge Street,

cc Shailesh Vara MP, John Holdich OBE, Peter Hiller

Peterborough City Council Draft Local Plan December 2016

Site AIL002Uii. Land North of Ailsworth and Castor (Great Kyne) East

Response to the Draft Local plan by: Protect Rural Peterborough (PRP) campaign

Dear Sir/ Madam,

The campaign group was formed after a village meeting in November 2016, where 300 people rejected the City Council’s Draft local plan proposal to locate 2,500 houses + commercial /Industrial usage, a cemetery and considered University facilities, on a greenfield site, comprising pristine rural landscape, and adjacent to a National nature reserve and SSSI site.

The land is in the parishes of Ailsworth & Castor and at its closest point is 100m from the Ailsworth Conservation area. It is also within 200m of the small village of Upton and a similar distance from Castor Hanglands. The site is on prominent rising land in the Nene Valley and on the limestone Nassaburgh plateau on the western “best landscape” approaches to Peterborough along the A47. The proposed large settlement would lie within the parishes of Ailsworth and Castor and would overshadow the villages and conservation areas of Castor & Ailsworth and the Nene Park Trust rural estate beyond. The site is 4 times the size of Castor & Ailsworth combined and is a staggering 100 times the size of the small Village of Upton.

In addition to the backing of residents, the campaign group also has the support of the Ailsworth Parish Council, Castor Parish Council, Sutton Parish Council, the people of Upton, our local Ward Councillors and Shailesh Vara our MP. PRP also works closely with the Castor & Ailsworth Neighbourhood Plan team and has their full support.

During the campaign, we have established relationships with local, regional and national organisations, who share our concerns with the inevitable negative impact that a large single development would have on the landscape, its wildlife and biodiversity and nearby villages. Many of whom will be responding to the consultation directly.

The PCC Sites Evidence report, one of the Local Plan’s supporting documents, states “this is the most sensitive area within Peterborough Unitary Authority in terms of both scheduled and unscheduled remains”. The site and surrounding area is rich in archaeological and historical remains, with significant evidence of major Roman, Saxon and prehistoric settlements. The site also features ancient trackways and Medieval lanes for passage and droving, both within and immediately adjacent to the proposed site. The distinctive rural character, has direct links to the fact that the Parishes were some of the last to be enclosed in the late-19th century, under the Enclosure Act. One of the nation’s finest Norman churches has been visible from the surrounding countryside for nearly 1000 years.

Indeed, PCC’s own LDP site assessments suggest that “In addition to impacts of CWS, there are several SSSI’s that may potentially be affected” and “This is the most sensitive area within the Peterborough Unitary Authority in terms of both scheduled and unscheduled remains”. PCC’s own Hierarchy Study (2007) says “substantial development would be incompatible with the character and scale of the villages and its setting in the landscape”

This response is written on behalf of the Protect Rural Peterborough campaign group, which objects to the Local plan published in December 2016, on the following basis:

The Plan’s own strategy is unclear

1) PRP challenges PCC’s OAN, originally assessed at 25,125, and increased by 2,500 to 27,625, following a memorandum of understanding from Cambridgeshire County Council. Surely this understanding is only appropriate if housing can be delivered on sustainable brownfield sites. To sacrifice a pristine piece of rural countryside rich in wildlife and heritage for the sake of houses needed elsewhere must be questioned by Peterborough City Council.

2) The Growth Strategy Evidence report, despite being referred to as the evidence base on which this and other site allocations were made, does in fact not exist. The reason given is that it had insufficient evidence to warrant publication and will be published later in the consultation process. Potentially in the Autumn of 2017.

As the evidence is deemed by PCC Planning as insufficient, it is unclear on what basis the sites were allocated, although on examination of the Sites Evidence report it shows that sites were allocated in many cases, and particularly this one, without due consideration to the facts of the assessment.

3) The Plan itself sets out policies relating to Urban areas, Village envelopes and Rural areas. The proposed large settlement is NOT within an Urban area. It is also NOT within a Village envelope. Therefore, by process of elimination, it must be in a rural area. So therefore, policy LP2 applies, which states that any building in the Rural area, should only be considered for the provision of housing for agricultural workers for required proximity to their employment.

4) The City Council and its Local Plan Vision refers to a ‘Characterful network of villages in an attractive rural landscape’. And yet, the proposal is to locate a large urban settlement, in attractive rural landscape, in the middle of the characterful villages of Sutton, Upton, Ailsworth and Castor. It directly contradicts its own vision and seems at odds with the city’s ambition to be the Environment Capital of the UK.

5) Despite the Site Evidence Report Selection Criteria showing that the Great Kyne site has many ‘red and amber WARNING lights it has still been assessed as a ‘preferred’ site when many other ‘rejected’ sites have indeed scored considerably better. Great Kyne has an understandable 9 Reds and 10 Ambers which is significantly more than most 'rejected' sites in our sample. (see Appendix Three).

How can you say in your comments on that report and site that there are only "minor constraints"? That should be applied to very many of the rejected sites, some of which are in our table as more relevant examples.

Rather than take into account the plans Visions and objectives has this proposed allocation been graded as preferred due to the landowner being HCA? Has PCC succumbed to Government pressure despite the fact that this greenfield site does not comply with many of your local planning policies as evidenced in our letter and many residents' letters and from local, regional and national organisations.

We do not consider that PCC is justified in releasing a greenfield site to meet the needs of another Local Authority (Cambridgeshire County Council). We know that Peterborough has alternative brownfield sites and other, more suitable sites that were proved more appropriate in many respects in your Sites Evidence report, let alone other neighbouring councils

6) The Objectively assessed housing need has been based on pre-Brexit population growth trends and outdated employment figures. Indeed, the latest Employment rates (January 2017) show a downward trend since the LDP was issued. Other Councils have taken the view, that with this level of uncertainty, it would be prudent to put on hold their local planning, with a view to adjusting those plans, when a clearer picture of inward migration is available. Surely this should apply to Peterborough, with its previously high levels of external migration over the past decade or so.

We also object from a site perspective

7) Wildlife and Biodiversity will be seriously impacted and destroyed

a. Castor Hanglands is a National nature reserve and SSSI site managed by Natural England and hosts ponds with the richest biodiversity anywhere in the UK (Freshwater Habitats Trust). Wildlife organisations advise that any development within 500m of these type of sensitive areas, would have a serious impact on small mammals, Amphibians and Birds, due to disruption from dog walking and domestic Cat predation. Mitigation measures at Hampton Nature reserve are reported by both City Council Officer and a Wildlife charity, as having been a ‘compete failure’

b. The site and surrounding area is home to 121 animal species, which are listed under Section 412 of the NERC Act (2006) and are UK BAP Priority Species.

8) Archaeology and the ancient and fragile landscape will be significantly impacted

a. Multiple archaeological sites with evidence from Bronze and Iron age people, Roman occupation and Saxon farmsteads through to Medieval farming

b. A detailed report by Dr Stephen Upex, a national authority on the Archaeology of the Nene Valley, highlights 28 sites on the proposed development land. Many of which would be regarded as archaeologically significant with large scale open area excavation being required should there be any change to the land use. These requirements would further question the overall viability of the site and would lead to protracted and costly survey work, which would also lead to a slower pace of development and deliverability

9) Flood risk and infrastructure – it is not enough to plan for ‘no unacceptable increase in flood risk’ it should ensure NO increased flood risk

a. The Plateau and its Limestone is highly permeable, therefore any development will significantly reduce rainfall soaking to ground and would significantly increase the amount and velocity of surface water run-off, increasing the risk of flooding downstream

b. Despite the flood alleviation scheme which has existed to protect Castor & Ailsworth, there is often flash surface water egress at the north end of Ailsworth and in parts of Peterborough Road, Castor

10) Overall rural and landscape character – the proposed site is in some of the area’s best open countryside, and is shown as “High” in your Selection Criteria for Sites Evidence report, however

a. PCC’s own policy on ‘Landscape character LP26’ states that any development should “enhance the character and qualities of the local landscape”

b. It is scarcely credible to suggest that a 2500 dwelling development with light industrial and logistics areas would be consistent with Policy LP26

c. It will therefore remove rather than “enhance important views” of the Nene Valley, including the Hanglands and St Kyneburgha Church specifically, both from within the area, the villages, Nene park Trust rural estate and the western approaches to Peterborough along the A47.

The villages of Castor and Ailsworth are not averse to growth and development as evidenced by absorbing 75 homes over the last 10 years and with Neighbourhood Plans proposing a further 50 homes. This represents a total of 125 homes a 25% growth over 30 years.

The Great Kyne site makes up an area used by residents of Peterborough for walking, cycling and other outdoor pursuits and its ecology, biodiversity and historic remains should not be overlooked. Peterborough’s immediate countryside should be enjoyed by the people of Peterborough and protected for future generations and not traded for gain to ease housing issues elsewhere in the country.

A draft local plan was published a week before Christmas with an initial closing date of the 26th of January 2017. Under challenge from the PRP team it was acknowledged by PCC planning that holding a public consultation over the festive season thereby resulting in only three weeks in review and comments was unsatisfactory for proper consultation. We welcomed the fact that PCC planning then extended the consultation period to the 9th February.

However, we subsequently identified the absence of the Growth Strategy Evidence Report and challenged both its omission, and requesting a delay to the consultation, until it has been provided, to enable proper review and comment. This request was rejected by PCC planning and it was indicated that the growth Strategy Evidence Report would be issued three days later on Friday the 13th of January. When that date arrived PCC planning advised that the report would now not be made public as it contained insufficient evidence.

In our view and to quote the views of our own MP, ‘this has made a mockery of the consultation process. More seriously he has criticised the PCC for moving the ‘’goalposts’’, and re-naming it as a less significant Growth Study. This will summarise the evidence towards the end of the plan process in Autumn 2017, rather than at the commencement of the consultation process when it would have been most useful to enable proper review and comment on the plan. We would concur with our MP’s assessment as we estimate the PRP team have collectively spent over 1000 hours reviewing the many documents as part of our response and likewise many residents have also wasted many hours trawling through the documents looking for the same evidence.

The PRP remains perplexed by the numerous inaccuracies, missing supporting evidence and contradictions that are contained, or indeed, not contained in PCC’s LDP. The absence of the critical Growth Strategy, which is referenced several times throughout the LDP, indicates that PCC embarked on the LDP in a state of disorganisation and questions the overall validity of the LDP as it stands.

We also note that the Further Draft Local Plan of December 16 shows in 7.3, that the site allocation named Great Kyne East had a Status which was live at 1 April 2016. How was it that this was not notified to the Parish Councils and communities until six months later? The cynical amongst us might think that this was a deliberate withholding of information to reduce the time available for the parties mentioned to respond! It could be argued that such a delay was in breach of the Plan Process.

The proposed Great Kyne development, which was also a late submission to the LDP, is not consistent with many of PCC’s local planning policies and objectives, and presents a serious threat to the character and natural environment to the west of the city. Our own scrutiny of the viability of

this site, would indicate that any developer intent on delivering large scale housing, would struggle to comply with PCC planning policy at every stage of delivery and would indeed face;

  • High infrastructure implementation costs
  • Significant costs for large scale open area archaeological excavations
  • Local opposition at every stage

  • We also understand that The Drift, Castor, which bisects the proposed Great Kyne is Common Land protected by the Commons Act 2006, which is a significant constraint on the delivery of the site. Such challenges, in our view make this whole site unviable, unsuitable and undesirable on every level.

    PRP’s Review of planning policy is attached to, and forms part of, our objection to the LDP.

    Peterborough's countryside gone forever, wildlife decimated and the enjoyment of people of Peterborough, not just the Villages, abandoned. Is this the right way to create the Environment Capital of the UK.

    Yours faithfully,

    Martin Chillcott
    Chair, Protect Rural Peterborough

    Appendix 1 – Review of planning policies

    Policy LP1: Sustainable Development and the Creation of the UK's Environment Capital.

    The Great Kyne site will not “improve the environmental conditions of the area”. It will be within a stone’s throw of the Castor Hanglands, a designated site of special scientific interest and built directly on habitat that according to CPERC contains or supports locally over 121 species, including a number of ‘Red List’ bird species.

    Creating a settlement of such size (2500 dwellings) would introduce around 500 or so domestic cats (Mammal Society ratio of pets / dwellings) with all of the carnivorous activity associated with those animals let loose on the unsuspecting fauna in the locale. This takes no account of some 6000 people and their other pets, particularly dogs.

    Policy LP2: The Settlement Hierarchy and the Countryside.

    Quoting directly from the plan: “A settlement hierarchy also helps to protect the character of the landscape, by maintaining and reinforcing the distinction between built-up areas and countryside, and placing a restriction on the forms of development that would be acceptable in the countryside.” In addition “It is Government policy that development in the countryside should be controlled, in order to conserve its character and natural resources. By identifying the settlement hierarchy and distinguishing between settlements and the countryside, the policy approach places a restriction on the types of development other than those where a rural location might be justified.”

    The Great Kyne site is 2500 dwellings with 12 ha of employment land (LP35 and LP40). This is not a small, medium or large village. Neither is it an Urban Extension. The site is ‘countryside’ and therefore there must be compelling evidence to justify this location, Which PCC have not provided.

    This evidence is conspicuous by its absence from the proposed draft plan. It should come from the Objectively Assessed Needs. This was meant to be updated in Dec 2016 but has not been made public. The most recent OAN, and the one presumably used to support the Draft Local Plan, is based on an update in 2015 prior to the UK’s historic decision to vote to leave the EU. The OAN is clearly predicated on high levels of net international migration by a ratio of over six to one (3010 to 530). See figure below from SHMAU (Oct 15).

    Given the Governments stated primary objective from the upcoming negotiation with the EU on our terms of exit to take control of our borders and limit immigration it would seem prudent to assume that future international migration will not be anything like historical international migration. This must call into question the underlying rationale for the level and distribution of growth described in section 5.19 et al of the Draft Local Plan.

    We are not the only body to have doubts over the strength of the projections for population and therefore household formation. In the GL Hearn report of Oct 2015, (P’boro sub-region strategic housing market assessment Oct 2015) “2.31 Therefore the finding of below trend population growth in Peterborough in the future is not an unreasonable finding.”

    Policy LP3: Spatial Strategy for the Location of Residential Development

    Quoting directly from this policy

    “…Provision will be made for the development of approximately 27,625 additional dwellings over the period from April 2011 to March 2036.

    9,393 34% Urban Area of Peterborough

    16,851 61% Urban Extensions to Peterborough and large scale growth locations close to the urban area of Peterborough

    1,381 5% Villages

    Total 27,625 100%...”

    Following on from the points made under LP2 the overall total requirement of 27,625 must be called into question and the allocation of 16,851 dwellings to the Urban Extension category similarly questioned.

    Policy LP4: Spatial Strategy for Employment, Skills and University Development

    Quoting directly from the Policy “In principle, development proposals which directly assist in creating a thriving independent, campus based university, with an undergraduate population of 12,500 students will be supported by 2035. The council will work with stakeholders, to identify appropriate sites, with current options including within the city centre, or as part of the new settlement north of Castor and Ailsworth.”

    This would appear to be incoherent within the same statement. ‘Campus based’ cannot mean both a location in the City and a location outside of the existing Urban boundaries. Students typically value locations close to the educational buildings themselves and with easy access to night time and weekend entertainment options and National transport links. These would not be possible with accommodation located at the Great Kyne site unless there are additional development objectives not specified in the Draft Local Plan for this site.

    Policy LP5: Urban Extensions and other Nearby Large Scale Allocations

    Quoting directly from the Draft Local Plan “A new settlement is proposed to the north of the villages of Castor and Ailsworth and the A47 in this Further Draft Local Plan for approximately 2,500 dwellings……. The locations of the proposed new urban extensions/settlements (ie not those already committed) are based on the findings of the Growth Strategy Evidence Report (December 2016) which examined the overall spatial strategy as well as all potential alternatives against a comprehensive range of assessment criteria.”

    The Growth Strategy Evidence Report (Dec 2016) has not been published along with the underlying data used to support any conclusion. Therefore the decision cannot have been based on the findings.

    Policy LP7: Health and Wellbeing

    The proposed Great Kyne site will not enhance the health and wellbeing of the Peterborough population that currently use the area for walking, cycling and riding.

    Policy LP11: Development in the Countryside

    Quoting directly from the Draft Local Plan “Areas outside the urban boundary and the village envelopes are considered as countryside for the purpose of policies in the Local Plan.” The Great Kyne site, which is countryside, fits this description. The development is at odds with the Councils own Objective for Land Use and Wildlife and identified issues such as “Peterborough has a high quality natural environment that needs protecting and enhancing”.

    There are numerous designated sites across the Parishes of Castor and Ailsworth, including two SSSIs (Castor Hanglands and Castor Flood Meadows) and a Local Nature Reserve (Grimeshaw Wood). There are 26 County Wildlife Sites, some containing Ancient Woodland and/or nationally rare or endangered flowering plants such as Crested Cow-wheat (Melampyrum cristatum)

    Policy LP13: Transport

    Quoting directly from the policy “all new development proposals should demonstrate that appropriate, proportionate and viable opportunities have been taken to:

    Reduce the need to travel, especially by car”

    This is a high barrier for the proposed Great Kyne site. Reasonable estimates of private car usage for that number of dwellings must add significant numbers of vehicles to well-known commuter routes into the City, to the Railway station and to major employment locations such as those along Oundle Road. Observation of the queues of traffic at bottlenecks such as the Thorpe Wood roundabout’ and

    the exit road from the A41129 to Oundle Road during rush hour should be all that is necessary to confirm that adding something like 1000 extra vehicles onto the network at rush hour will require significant investment to alleviate the delays experienced by commuters at these and other locations in the area.

    By definition adding a large-scale development well outside the existing urban network of transportation infrastructure must increase private car use and not reduce it as desired by the Council.

    Policy LP19: Heritage Assets

    Quoting directly from the Draft Plan “The Council will protect, conserve and/or enhance heritage assets throughout Peterborough, through the special protection afforded to listed buildings, conservation areas and scheduled monuments and through careful control of development that might adversely affect non-scheduled, nationally important archaeological remains; other areas of archaeological potential or importance; historic features and their settings; non-designated heritage assets; and areas of historic landscape or parkland….. the identification and protection of important archaeological sites and historic environment features and their settings; the identification and protection of non-designated heritage assets and their settings…..”

    The Great Kyne site will have significant impact on an ancient and fragile landscape. There are multiple archaeological sites on the proposed development area with evidence from, Bronze and Iron age peoples, Roman occupation, Saxon farmsteads through to medieval farming.

    A detailed report completed by Dr Stephen Upex, highlights 28 sites on the proposed development land, many of which would be regarded as archaeologically significant, with large scale, open area excavation being required should there be any change to the land use.

    The area contains a broad variety of sites, from Bronze Age ‘ring ditches’, Iron Age settlements, Roman roads, Saxon and medieval farming examples. There are also many ancient tracks and wide medieval lanes that were protected following land enclosure and consequently provide rich green protected areas.

    There are several very significant archaeological features spread across both parishes Castor & Ailsworth, many of which fall within the proposed development area. Not only are many of these sites important in their own right, but they should also be considered as part of the total landscape of the nationally important Durobrivae area.

    Policy LP26: Landscape Character

    The Great Kyne Site proposal impacts two areas designated by the Council as Landscape Character Areas (Nene Valley and Nassaburgh Limestone Plateau). Your policy LP26 on these areas states

    “For each Landscape Character Area and sub area, specific details of which are provided in the Landscape Character Assessment, planning permission will only be granted if the proposed development would:

  • recognise and, where possible, enhance the character and qualities of the local landscape through appropriate design and management;
  • reflect and enhance local distinctiveness and diversity;
  • make adequate provision as far as is reasonably practicable for the retention of features and habitats of significant landscape, historic, wildlife and geological importance;
  • safeguard and enhance important views within the development layout;
  • protect the landscape settings and separate identities of settlements; and
  • provide appropriate landscape mitigation proportionate in scale and design, and/or suitable off-site enhancements.”

  • It is scarcely credible to suggest that a 2500 dwelling development with light industrial and logistics areas within will, in anyway what so ever, “enhance the character and qualities of the local landscape”. Further, your own Selection Criteria in the Sites Evidence report state the Landscape Character Assessment as “High”. It will do nothing to “enhance important views” of the Nene Valley.

    From the Level 2 Peterborough Strategic Flood Risk Assessment 2010, similar development sites in the Castor area were specifically rejected for their likely impact on the character of the landscape:

    Policy LP27: Landscape and Biodiversity

    The proposed site comes within a few hundred yards of the Castor Hanglands Site of Special Scientific Interest (SSSI). This will have an adverse effect on a designated site, including harm to habitats or species of principle importance.

    The Castor Hanglands is a site of Ancient Woodland, of which 75% has been re-planted, and supports at least 40 woodland species, 10 of which are indicators of Ancient Woodland (e.g. Wood Melick (Melica uniflora), Yellow Archangel (Lamiastrum galeobdolon) and Ramsons (Allium ursinum)). It has a mix of Grade 1 broad-leaved and coniferous woodland, and species-rich Grade 2 calcareous, neutral and acidic grasslands.

    The ponds of the Castor Hanglands have been identified by the Freshwater Habitats Trust as the most species-rich in England, particularly in terms of aquatic plants and invertebrates. See link:

    The main pond is also a known breeding site for the Great Crested Newt (Triturus cristatus).

    Regrettably the Green Infrastructure and Biodiversity SPD is not available for review during this consultation period. It is not possible to understand how this document may have influenced (or not) the site assessment process resulting in the Great Kyne proposal. Our own research in this area suggests that the site is a significant resource rich in bio-diverse habitats supporting many species of wildlife including a substantial number identified as at risk by bodies such as the RSPB.

    121 animal species have been found in the Parishes of Castor and Ailsworth which are both listed under Section 41 of the NERC Act (2006) and are UK BAP Priority Species. This list is made up of:

  • 31 birds (24 of which are also Red Data-listed)
  • 10 mammals
  • 2 reptiles
  • 2 amphibians
  • 2 freshwater fish
  • 1 beetle
  • 12 butterflies
  • 61 moths
  • In addition, 9 other Red Data-listed birds have been recorded, including the Hen Harrier (Circus cyaneus) which is also listed under Section 41

    44 of these species have been recorded in the last 20 years:

  • 29 birds (23 of which are also Red Data-listed)
  • 5 mammals
  • 2 reptiles
  • 2 amphibians
  • 1 freshwater fish
  • 5 butterflies
  • From sightings by residents, 116 animal species have been observed in the area north of the A47 bypass where the proposed development has been designated. 15 of these species have been identified as being both under Section 41 of the NERC Act (2006) and UK BAP Priority Species. This covers:

  • 8 Bird species (all of which are also Red Data-listed)
  • o Northern Lapwing (Vanellus vanellus)
    o Common Cuckoo (Cuculus canorus)
    o Eurasian Skylark (Alauda arvensis)
    o European Starling (Sturnus vulgaris)
    o Song Thrush (Turdus philomelos)
    o House Sparrow (Passer domesticus)
    o Hawfinch (Coccothraustes coccothraustes)
    o Yellowhammer (Emberiza citrinella)

  • 2 Mammal species
  • o Brown Hare (Lepus europaeus)
    o European Hedgehog (Erinaceus europaeus)

  • 2 Reptile species
  • o Grass Snake (Natrix natrix)
    o Common Lizard (Zootoca vivipara)

  • 2 Amphibian species
  • o Great Crested Newt (Triturus cristatus)
    o Common Toad (Bufo bufo)

  • 1 Moth species
  • o Cinnabar (Tyria jacobaeae)

    CPERC maps showing designated sites in Castor and Ailsworth and their proximity to the proposed development are shown in Appendix Two.

    Policy LP32: Flood and Water Management

    Quoting directly from the Draft Local Plan “There are two particular flood risk issues relevant to Peterborough. The first relates to the location of new development and to potential development in flood risk areas. The second issue relates to increased surface runoff caused by development, particular in areas where there are drainage capacity issues, such as parts of the city centre with combined foul and surface water sewers.”

    We object to this policy as it refers to no unacceptable increased risk of flooding. This should be amended by removing the word ‘unacceptable’ to ‘no increased risk of flooding’ and comply with the wording within the National Planning Policy Framework(NPPF) Section 103. “all proposed

    development must be accompanied by a flood risk assessment to ensure that flood risk is not increased elsewhere “. Also Environment Agency comments on the ‘Preliminary Draft Local Plan Consultation January 2016’ in on this subject have not been incorporated.

    The Environment Agency’s website identifies a number of areas on the proposed site, at Castor Hanglands and within the villages of Castor and Ailsworth which are currently at High risk of surface water flooding and many more areas which are medium/low risk.

    Part of the development will be on Ailsworth Marsh, an area of nature conservation value and a high proportion of which lies wet for up to half the year (documented in the countryside Management project Site Data Report). Therefore whilst the site is in flood Zone1 the scale of the development will significantly increase risk of flooding to local residents and those downstream, particularly from surface water flooding and sewer flooding. It will also increase risk of flooding from fluvial sources further downstream. The Strategic Flood Risk Assessment Update (p34) also refers to sewers being at capacity with Castor and Ailsworth and significant upgrades to infrastructure will be required.

    The Strategic flood Risk Assessment (2010) Appendix F states that the sites at Castor passed the sequential test but were ruled out due to other constraints. No detail has been given as to why these constraints no longer apply.

    The site has not been assessed as one of the strategic sites within the Waste Cycle Study (2010).

    The policy should recognise the impact on water quality from surface water runoff as well as waste water treatment from commercial, industrial and urban development. The size and nature of the development at Castor & Ailsworth has the potential to significantly impact on the local aquatic environment and that further downstream. There have been several pollution incidents arising from Flag Fen’s waste water Recycling Centre. Anglian Water should be consulted on this plan and asked to demonstrate they have capacity to treat waste water from any new development without causing a deterioration of the current water quality and that any increase in flow to the sewerage network does not increase flood risk.

    The policy should incorporate impacts of climate change and the affect this will have on flood risk from new developments. The policy should be updated to ensure that it has fully considered new guidance published last year on “flood risk assessments: climate change allowances” and should take account of the guidance published

    Policy LP34: Urban Extensions and Other Nearby Large Scale Allocation

    As stated earlier in this response there is no credible data available to support the overall level of housing required for the Peterborough area and therefore the allocation of 10% of the original total of 25,000 to this site must be questionable.

    Policy LP35 Land to the north of Castor and Ailsworth (Great Kyne)

    We note the intent to include a special assessment of the transportation needs such a large-scale development would create. We have noted elsewhere the somewhat surprising recommendation to include student accommodation in the development that is contradicted by the stated objective of a campus based University in the City.

    We have drawn attention elsewhere in our response to the considerable number of omissions to the list of specific requirements that would appear to be appropriate – such as flood risk, wildlife habitat and preservation of landscape with special characteristics.

    Appendix Two – Maps of Designated Sites

    Appendix Three – Comparison of Sites