Response to the Draft Local Plan

Thank you for the opportunity to comment on the emerging Local Plan. Our response  draws on concerns expressed by residents and community groups in St Ives and the surrounding villages about the impact of cumulative housing and commercial developments on the town.

Primarily, it focuses on the need for a cumulative strategic approach to be instated which creates the policies and processes necessary to ensure the security of the cultural and heritage assets of St Ives and its surrounding villages, the upgrading of the infrastructure necessary to support future development, the environmental protection, climate resilience, food security planning necessary to support its residents.

There is much to welcome in the Local Plan Preferred Options Report. We support its ambition to align with the Huntingdonshire Futures Strategy, and we recognise that it sets out a credible framework for safeguarding biodiversity, requiring ecological assessments, securing biodiversity net gain, embedding sustainable design and responding to climate change. These elements are necessary and welcome.

However, this is undermined by the Planning authorities’ failure to recognise the cumulative effect of developments on the market towns and small rural areas, where coalescence will significantly alter the natural habitat, sense of place and belonging and regional identities. We therefore have major concerns that proposed developments will be approved/delivered without the necessary infrastructure and environmental issues being addressed.

Approximately 70% of new housing allocations are clustered into single spatial zones, creating large, unplanned conurbations.  This results in cumulative impacts far beyond those assessed at site level.

The Draft Local Plan’s concentration of growth along the Great Ouse Valley will put severe pressure on the Priority Landscape through its cumulative development, coalescence, landscape intrusion, river-system stress and loss of settlement identity

Significantly, it does not provide any strategic gaps, green wedges or settlement separation policies to prevent coalescence.  The SA has also failed to assess cumulative landscape, transport, biodiversity, flood-risk and water quality impacts on multiple, adjacent allocations.

The pattern of growth therefore substantially risks the loss of settlement identity, erosion of market-town character, and long-term landscape harm – contrary to the Futures Place Strategy and the National Planning Policy Framework (NPPF) requirements for maintaining district communities.

Without a Cumulative Impact Assessment supported by strategic separation policies, the spatial strategy cannot be not justified.
Huntingdon Futures places strong emphasis on the Great Ouse Valley’s heritage, cultural richness and landscape’s character.   Its significance depends on its historical rural character, its open river meadows, its distinct settlement pattern, its in-tact riverside setting, continuity of agricultural land use, its views and visual relationships and its tranquillity. In order to deliver Huntingdon’s Place-Making strategy, an integrated approach is needed to protect the landscape.

Clustering of sites around Huntingdon / St Ives / A141 corridor — as is the case in the Preferred Options Plan — amplifies infrastructure risk in ways that a per-site viability model will miss. Key risks:

• Transport network overload: Many housing developments concentrated in a narrow corridor will generate overlapping peak-hour traffic demand, increasing congestion, accelerating wear, need for junction upgrades, new access roads, bypasses, or strategic interventions (which are expensive, slow, and funding-dependent).
• Utilities and water/wastewater network pressure: Close-by developments may all draw on the same WRC catchments, sewer mains, water supply zones — leading to cumulative capacity deficits, treatment overload, spill-over risk, requirement for major upgrades (or temporary pumping / treatment).
• Drainage / surface water / flood risk / SuDS delivery complexity: Multiple adjacent developments increase impermeable area, change surface-water drainage patterns and require coordinated SuDS / green-infrastructure — much harder to manage if each site deals separately rather than through a master-planned, area-wide drainage strategy.
• Infrastructure funding gap & viability squeeze: The more sites, the bigger the combined infrastructure demand. If strategic upgrades cost tens or hundreds of millions, then relying solely on per-site developer contributions (s106 / CIL) will likely leave a funding gap. Without explicit modelling, viability is over-optimistic.
• Phasing risk & “all-or-nothing” bottleneck: If strategic upgrades are needed before more than one or two developments proceed, and if upgrades are delayed (funding, approvals, environmental assessments), then multiple allocated sites may become undeliverable — undermining the Plan’s housing supply trajectory.
• Competition between sites and protection of profit margins: In an already fragile housing market the potential of too many houses being delivered in the same market area, in close proximity to each other, can radically change planned completion phasing, and therefore potentially undermine delivery of the allocated housing supply trajectory, potentially pushing the council into tilted balance.

Traffic Management

St Ives is a town of 17,000+ residents and a popular visitor destination. Current volumes of traffic into and around the town have increased significantly as a result of recent housing developments, leading to bottlenecks at numerous points.  This is significantly increased again during flood events at Earith when the morning traffic is delayed by queues on the A1123 Needingworth Road, Harrison Way & London Road. Evening queues commence on the A1307 which is an unlit 70mph dual carriageway and continues on London Road and Harrison Way back to Needingworth Road. Some road users avoid part of this bottleneck by rat-running via Fenstanton and the Low Road.

The proposed housing and commercial development outlined in the DLP potentially totals 16,000+ new properties and more than 32,000 more road users, exacerbating the situation and making extra road capacity essential and a third river crossing a practical solution.

National policy / guidance and why cumulative testing is justified

• The national viability guidance (under PPG) expects that plan-makers ensure “the total cumulative costs of development” (including planning obligations, infrastructure, contributions) will not undermine deliverability of the plan.
• The assessment of sites for local plans (Stage 2 site assessment) requires considering achievability — which includes availability of infrastructure and the capacity of infrastructure to serve development.

For a cluster of allocations, “infrastructure capacity and cost” must therefore be tested at the collective level — not just per-site. A typology-based model alone is insufficient to satisfy “achievability” when multiple sites depend on a single infrastructure network.

 

We therefore request a policy change which adds a “Cumulative Impact Zone” requirement for Huntingdon, St Ives & A141 Cluster being the primary area of concern in the Preferred Options, as follows:

 

“The Council will apply a cumulative assessment to all major development within the Huntingdon–St Ives–A141 Growth Area. Applicants must demonstrate that the total combined impact on highways, utilities, water, sewer and social infrastructure are recognised and can be fully mitigated, funded and delivered. Proposals failing to demonstrate this will be refused.”

 

This directly addresses the flaw in the Whole Plan Viability Assessment WPVA (individual site testing only) and the Infrastructure Deliverability Study Baseline IDSB (limited cumulative modelling).

 

Preventing Coalescence of Settlements

The emerging spatial distribution of sites, particularly between Huntingdon and St Ives, risks undermining settlement identity, landscape character, and the physical separation that currently prevents an urban corridor along the A1123.

Requested policy changes

1. a. Introduce “Strategic Separation Gaps” with mapped boundaries between:

• Huntingdon and St Ives
• St Ives and Houghton/Wyton
• St Ives and Needingworth
• Huntingdon/Hartford and Houghton & Wyton
• Huntingdon and RAF Wyton
• St Ives and RAF Wyton/Wyton-on-the-Hill
• Villages and their neighbouring settlements

1. b. Within these gaps, housing should not be approved, developments should be restricted to uses that maintain openness e.g. nature recovery, agriculture, outdoor recreation;
2. Policy wording should require that proposals “maintain the visual and physical separation of settlements and prevent coalescence.”
3. Introduce a requirement for permanent landscaped buffers to prevent future coalescence.

This approach mirrors established policies in South Cambridgeshire, Central Bedfordshire, and West Northamptonshire.

Based on the Preferred Options, the most at-risk areas locally are:

• Giffords Farm (St Ives/Needingworth gap)
• Land North of Houghton Road (Houghton/Wyton on the Hill –St Ives gap and ribboning risk)
• RAF Wyton / Lodge Farm cluster (Huntingdon – St.Ives gap plus risk of creating continuous sprawl along the A141)

Protecting the District’s Best and Most Versatile Agricultural Land

The principle that, if high-quality land is lost, land nearby must be restored or upgraded to avoid net loss of agricultural productivity is consistent with Natural England soils guidance, minerals restoration precedent, and S106 practice in several authorities such as South Cambridgeshire, East Cambridgeshire, West Northamptonshire and Lincolnshire.

The district’s agricultural land is a nationally significant resource. With food security rising up the policy agenda, the Local Plan must adopt stronger protections for Grades 1, 2 and 3a land. The current lack of differentiation between 3a and 3b is concerning.

Such measures are vital at sites such as Lodge Farm, Giffords Park, Needingworth, Fenstanton, Houghton, the A1123/A141 corridor and Godmanchester which would otherwise cause permanent and unmitigated loss of high-quality farmland.

We request 3 policy changes:

1. That the Council map and publish Best & Most Versatile BMV agricultural land, including distinction between Grades 3a and 3b, before site allocations are finalised.
2. To include a policy that development on BMV land will be refused unless:

• essential public need is identified, and

• no reasonable alternative exists on lower-grade land.

1. Where BMV loss is unavoidable, require a compensatory soil improvement scheme on nearby lower-grade land (e.g. Grade 3b) to maintain or increase agricultural productivity.

Flood Risk and the Great Ouse Corridor

The Draft Local Plan acknowledges the increased fluvial flood risk from climate change but does not publish details of how these will be mitigated, either for the population via a 3^rd river crossing  or environmentally by expansion of water meadows. The Preferred Options draft currently flags the appropriate issues but lacks current delivery evidence for waste-water capacity mitigation, catchment water-quality modelling, secured flood mitigation, and highway draining commitments.

Additionally, the Local Plan has not identified any new wet grassland habitats or support for nature-based flood alleviation through pond creation or other water storage facilities.

This corridor is highly sensitive, with floodplain, groundwater interaction, culverts, hydraulic pinch-points and tributaries.

The Stage 2 water study and proposed clustering of sites north and south of the River Great Ouse significantly increase cumulative flood risk. The river already operates close to capacity, and functional floodplain provides essential storage and attenuation across the valley.

To mitigate flood risk in the Huntingdon–St Ives Great Ouse corridor, the Local Plan policies must address:

✔ Cumulative flood modelling for all clustered sites

✔ A Great Ouse Flood Corridor policy

✔ Mandatory reduction in runoff & strict SuDS design

✔ Strong protections for floodplain and flood storage areas

✔ EA-approved model BEFORE permission

✔ No net increase in impermeable area

✔ Strategic drainage and flood plans BEFORE Regulation 19

✔ Phasing: no occupation until flood mitigation is delivered

 

We believe these are all reasonable, deliverable and well-supported by national guidance as well as being supported by the Water Cycle Study (WCS) Stage 2 findings.

Requested policy changes:

1. Introduce a requirement for compensatory flood storage where any site reduces floodplain, water storage capacity, or natural soil infiltration.

• This is standard Environment Agency practice and should be embedded in Local Plan policy.

1. Require that compensatory storage is equal or greater in volume and functionality and delivered before development begins.
2. Ensure compensatory storage occurs within the same hydraulic unit of the Great Ouse, preventing displacement of flood risk to St Ives, Holywell, Needingworth, Houghton and Wyton.
3. Require cumulative flood modelling, not site-by-site modelling

The major flaw of the current evidence base is individual assessment, not combined hydraulic modelling for clustered allocations.

We request a new policy requirement:

“Major development within the Great Ouse Flood Corridor (as mapped) will only be permitted where it demonstrates no increase in flood risk on-site or elsewhere, accounting for cumulative impacts of multiple allocations. Development must deliver betterment to existing flood risk conditions.”

 

This is especially crucial for sites:

North of Houghton Road

Giffords Farm (St Ives / Needingworth)

Wyton / RAF Wyton

Sites south of the river near the A1123 corridor

Given the sensitivity of the Great Ouse corridor, any expansion of abstraction associated with regional water transfers (such as the Grafham–Cambridge pipeline) must also be considered within the Local Plan’s cumulative risk assessment.

Inclusion of Regional Water Transfer Impacts

The Chatteris reservoir and Grafham–Cambridge water transfer infrastructure may increase abstraction and change flow regimes in the Great Ouse. Although these are strategic Anglian Water projects, the Local Plan must recognise and respond to their local consequences such as maintaining navigation throughout the year on The River Great Ouse – an important aspect of economic tourism and recreation in our area and not just the environmental effects.

If the Plan allocates thousands of new homes in Huntingdon, St Ives, RAF Wyton, Wyton-on-the-Hill, Needingworth etc, then it must assess the impacts on Great Ouse water supply and flows.

Requested policy wording:

“Development proposals must demonstrate that they do not rely on water supply enhancements that would result in increased abstraction from the River Great Ouse to the detriment of water levels, navigation, biodiversity, or flood management capacity.”

This ensures local planning decisions reflect regional water infrastructure pressures.

Strengthen Transport & Highways Policies

The available evidence shows the Council has strategic transport work in progress (A141 / St Ives corridor work and a Strategic Transport Study), and the Infrastructure Delivery Study (IDS)/Whole Plan Viability Assessment (WPVA) nominally recognise transport as an infrastructure   — but they do not transparently or fully reflect the scale, cost and phasing risk of the major highway schemes that are necessary to serve the four sites of Giffords Park, Norh of Houghton Road A1123, RAF Wyton and Lodge Farm  (notably the A141 corridor improvements, junction upgrades, potential new river crossing / link roads, Park & Ride and public-transport measures).

That creates a material risk the WPVA under-estimates developer costs and delivery timing (and therefore overstates viability and deliverability).

For climate mitigation to be credible, the Local Plan must require developers to show that new road planning will include measures to compensate water run-off pollution, habitat protection and other relevant environmental targets.

 

Requested policy changes:

1. Require evidence that the road network can support the total cluster allocations

Proposed wording:

“No major development will be approved where modelling shows that transport networks or junctions operate over capacity unless fully funded and deliverable mitigation is secured prior to development commencing.”

1. Require strategic transport upgrades before occupation

Examples: A141 corridor upgrades, key junctions, bus priority, pedestrian/cycle links.

“Strategic road or sustainable transport improvements necessary to support cumulative growth must be operational prior to occupation of new dwellings.”

Landscape, heritage-setting & Great Ouse Heritage Landscape protection

The Local Plan mentions The Great Ouse Valley as Priority Landscape but lacks supporting legally weighty protection, or producing mapped strategic gaps, heritage-setting protection, or a delivery/stewardship mechanism.

It also lacks any cumulative overview of the potential urban impact of the proposed developments identified within the Draft Local Plan on the infrastructure, natural landscape, heritage assets, market town character and economy of St Ives and its surrounding villages.

 

An additional Policy is required: to support the creation of a designated Heritage Landscape protection for The Great Ouse Valley.

1. Heritage-setting assessments: require setting-sensitive Landscape Visual Impact Assessments and heritage setting statements for all major allocations that could affect views, heritage assets or the valley character.
2. Create a Great Ouse Stewardship & Delivery Body: require a formal mechanism (Council + Great Ouse Trust + landowners + developers) to manage landscape stewardship funded through developer contributions / CIL / stewardship endowments.

This gives the Valley designation real planning weight, prevents future infill in gaps and secures long-term stewardship funding.

 

New policy suggested wording:

The Local Plan supports working towards The Great Ouse Valley being designated as the Great Ouse Heritage Landscape. As such development proposals within or adjoining the Landscape must conserve and enhance its historic rural character, open meadows, views, tranquillity and settlement pattern. Harmful development which undermines this aim will be refused.

Biodiversity, Nature Recovery, BNG & long-term management

The Local Plan requires Biodiversity Net Gain (BNG) but in sensitive landscapes the national 10% minimum is insufficient and the Plan currently lacks mapped strategic habitat creation areas and long-term delivery guarantees.

What we request:

1. Greater than 10% BNG in Sensitive Areas
   Wording:

The area identified as a Great Ouse Heritage Landscape and other priority biodiversity areas, developments must deliver a minimum of 20% Biodiversity Net Gain unless exceptional circumstances are demonstrated. On-site habitat creation is prioritised; off-site credits only where on-site delivery is impossible.”

2. Identify and map strategic Nature Recovery Zones
   Wording:

“The Council will identify and safeguard Strategic Nature Recovery Zones (wetlands, floodplain meadows, river corridor woodlands). Major allocations must provide explicit habitat connectivity and contribute to these zones.”

3. Long-term management & monitoring
   Wording:

“All major developments must provide a 30-year Biodiversity Management & Monitoring Plan, secured by a legal agreement, with funding and annual reporting to the Council and a district BNG register maintained publicly.”

This ensures more meaningful nature recovery, not token BNG and secures long-term stewardship.

The Local Plan must ensure that growth does not undermine the environmental integrity, traffic flow, waste-water and sewage management , food security, water resilience or settlement character of Huntingdonshire. The policy changes proposed within this document are reasonable, evidence-based and fully aligned with national guidance, Environment Agency practice, and good planning precedent.

We urge the Council to adopt these proposed policies to ensure that the future development of St Ives and its surrounds are environmentally responsible, infrastructure-led, climate-resilient, and compatible with the long-term wellbeing of our communities.

Reasons for Opposing the Draft Local Plan

The housing target premise of the Local Plan Preferred Options for the Huntingdon / St Ives area is disproportionate and has not been justified.

The Civic Society’s concerns expressed in the consultation in the summer of 2025 and earlier in this response have not been alleviated by this DLP.

Specifically, the Draft Local Plan fails to provide pathways to achieve its goals by –

• considering potential development sites individually rather than cumulatively
• not recognising the economic impact on St Ives of road and highways proposals: specifically the recent A141 Development proposal which proposed re-routing of traffic from the town centre to relieve bottle-necking which would have been a major deterrent to visitors to the town, to Waitrose customers and to local residents travelling to the local surgery, pre-school or builders merchants.  This has the potential to devastate the town’s economy if Waitrose’s customer base dwindles as a result and they relocate. There would also be a knock-on effect to other commercial businesses whose customer bases are similarly high-end, who would shop elsewhere.
• not establishing a consistent heritage status to protect the Ouse Valley  landscape
• failing to mitigate strategically for Strategic Gaps, BGI Network, floodplain management.

Thus, the DLP fails in its primary purpose, which is to consider how future development will affect and contribute to an area as a whole.  In doing so, it also fails to meet NPPF requirements for protection of valued landscapes, maintenance of settlement identity, and cumulative impact assessment.

We remain concerned that outline planning proposals will be approved/delivered without the necessary infrastructure and environmental issues being addressed.

We also consider the Preferred Options report to have been published prematurely, before the full evidence base required to justify and soundly underpin the proposed strategy has completed.  Significant gaps and inconsistencies remain in the information needed to assess whether the identified options can genuinely be considered “preferred.”

Crucially:

• The evidence streams do not appear to be fully integrated, meaning that environmental, infrastructure, transport, and viability assessments may not be informing one another in the way required by national policy.
• Some studies have been mistimed or have not yet been completed, raising questions about whether the Preferred Options are based on the best and most up-to-date information.
• Assessment has been undertaken largely on a site-by-site basis, without adequately testing the impacts of concentrated clusters of development—particularly in the area between and around Huntingdon and St Ives.
• The cumulative effects of multiple adjacent developments have not been properly modelled, especially for infrastructure demand, environmental impact, flood risk, water quality, transport capacity, or viability.
• As a result, the Preferred Options do not yet demonstrate that development in the most heavily targeted areas can be planned, serviced, or delivered in a way that is sound, justified, and compliant with national policy.

In summary, we believe further evidence, integration of datasets, and cumulative testing are required before the Preferred Options can reasonably be considered robust or ready for consultation on a preferred strategy.

For these reasons, the Trustees of the Civic Society of St Ives cannot support the DLP as it stands, and proposes it its approval is paused until the appropriate data gathering, testing, modelling and policy development is available to consultees for consideration.

At this point, we recommend that the policies requested within this document are considered favourably as steps towards a quality development programme for the town and its environs.

 

Christine Phillpotts

Chair, Civic Society of St Ives

16.12.25