Question 14. How do we achieve biodiversity net gain through new developments?

Natural Cambridgeshire’s Developing with Nature Toolkit seeks to achieve a net gain in biodiversity through new development. It is agreed that development, and in particular large-scale development with sufficient land available, can deliver significant biodiversity enhancements. It is suggested that in deciding sites to allocate for development the emerging GCLP assesses not only whether the potential impacts on protected species and habitats can be mitigated but also whether development can deliver biodiversity enhancements. The proposed development of Land at Meadow Drift, Elsworth includes a number of ecological enhancements including: new woodland planting; aquatic habitat creation; enhancement of existing ditches; incorporation of native plants; and provision of new bat roosting and bird nesting opportunities.

There should be a simple, and proportionate, methodology set out in the local plan to allow demonstration of biodiversity gain associated with new development. For minor development (i.e. less than 10 dwellings for example) a standardised approach could be adopted but a more tailored approach is probably necessary for large developments. The local plan should clearly set out what the desirable biodiversity gains are in general terms. For example, is the priority tree planting, wetland creation or habitat enhancement?

With great difficulty. Make it a top priority and stop agreeing to tokenistic Greenwash.

5.14 The new Local Plan must ensure that policy in this matter is sufficiently flexible to accommodate the required biodiversity net gain in the most effective and efficient way for each development, with both on-site and off-site solutions possible. 5.15 The Council should develop a strategic offsetting mechanism. This would allow for new green infrastructure and biodiversity habitats to be strategically planned to provide greater benefit than the provision of small, uncoordinated and connected new habitats across a range of new developments.

There should be a simple and proportionate, methodology set out in the Plan to allow demonstration of biodiversity gain associated with new development. For minor development (i.e. less than 10 dwellings for example) a standardised approach could be adopted but a more tailored approach may be necessary for ‘major’ development or site allocations. The Plan should clearly set out what the desirable biodiversity gains are.

Pigeon supports the objective of achieving biodiversity net gain and is committed to achieving net gain through its schemes. In this context, our understanding of the system for calculating and achieving net gain indicates that it will be much more challenging to achieve net gain where development involves sites of initial high environmental value. A key initial strategy of allocating sites for development that are of lower ecological value should be adopted. The Preliminary Ecological Appraisal accompanying this submission shows the relatively low current ecological value of the proposed site south of St Neots Road, Hardwick. This increases the ability to deliver net gain as part of the development of the site and supports its allocation for housing development.

Natural Cambridgeshire’s Developing with Nature Toolkit seeks to achieve a net gain in biodiversity through new development. It is agreed that development can deliver significant biodiversity enhancements. It is suggested that in deciding which sites to allocate for development, the emerging GCLP assesses not only whether the potential impacts on protected species and habitats can be mitigated but also whether development can deliver biodiversity enhancements. The promoted land south of St Neots Road Eltisely is currently in agricultural use, it being arable land that is farmed and managed and as a result is, in the most part, of limited ecological value. The network of hedgerows that exist around the perimeter of the site are likely to have greater biodiversity value. These hedgerows would be retained. Any additional ecological features on site would be retained and additional planting provided to deliver ecological enhancements. It should be noted that there is sufficient space within the site to include ecological enhancement measures, in conjunction with new built development.

The land south of Old House Road in Balsham was promoted to the call for sites process in March 2019 on behalf of Endurance Estates. The representations to the Issues & Options consultation document will refer to that promoted site where relevant. Natural Cambridgeshire’s Developing with Nature Toolkit seeks to achieve a net gain in biodiversity through new development. It is agreed that development can deliver significant biodiversity enhancements. It is suggested that in deciding sites to allocate for development the emerging GCLP assesses not only whether the potential impacts on protected species and habitats can be mitigated but also whether development can deliver biodiversity enhancements. Although, in some instances, it should be acknowledged that net biodiversity gains would be more appropriately provided on alternative or existing sites rather than within a development site. It is suggested that the emerging GCLP should also include a policy mechanism that allows for net biodiversity gains to be delivered on alternative sites. For example, the emerging GCLP should identify suitable biodiversity projects across Greater Cambridge that development sites could make a biodiversity net gain contribution towards as an alternative to always providing on site. It is considered that in some circumstances a larger biodiversity net gain/ecological enhancement area would be more beneficial in preference to numerous smaller unconnected areas. A larger biodiversity/greenspace area would also be beneficial for recreation and health and wellbeing. A Preliminary Ecological Appraisal (prepared by Applied Ecology Ltd) has been undertaken for the site at land south of Old House Road in Balsham. The promoted development would include biodiversity measures and ecological enhancements. It would seek to retain, protect and enhance the existing hedgerows and trees on the site, or replace where removal is necessary. A lighting strategy will need to be prepared for the development in order to keep the hedgerows free from artificial lighting after dark. It would provide additional landscaping with native plants at peripheral areas of the site. It would incorporate bat and/or bird boxes into new buildings. Therefore, the promoted development would achieve a net gain in biodiversity.

Three sites in Bassingbourn were promoted to the call for sites process in March 2019 on behalf of Endurance Estates as follows: Land off Poplar Farm Close; Land off Elbourn Way; and, Land off The Causeway. The representations to the Issues & Options consultation document will refer to that promoted site where relevant. Natural Cambridgeshire’s Developing with Nature Toolkit seeks to achieve a net gain in biodiversity through new development. It is agreed that development, and in particular large-scale development with sufficient land available, can deliver significant biodiversity enhancements. It is suggested that in deciding sites to allocate for development the emerging GCLP assesses not only whether the potential impacts on protected species and habitats can be mitigated but also whether development can deliver biodiversity enhancements. Although, in some instances, it should be acknowledged that net biodiversity gains would be more appropriately provided on alternative or existing sites rather than within a development site. It is suggested that the emerging GCLP should also include a policy mechanism that allows for net biodiversity gains to be delivered on alternative sites. For example, the emerging GCLP should identify suitable biodiversity projects across Greater Cambridge that development sites could make a biodiversity net gain contribution towards as an alternative to always providing on site. It is considered that in some circumstances a larger biodiversity net gain/ecological enhancement area would be more beneficial in preference to numerous smaller unconnected areas. A larger biodiversity/greenspace area would also be beneficial for recreation and health and wellbeing. Initial ecological appraisals have been undertaken of the three sites in Bassingbourn promoted by Endurance Estates. It is recommended that the promoted developments will seek to retain any ecological features at the sites and include ecological enhancement measures. As set out in the call for sites submissions for all three sites the promoted developments could achieve a net gain in biodiversity. The promoted development at land off Elbourn Way in particular provides an opportunity to effectively manage the adjacent woodland areas for ecological enhancement and better public access.

The response to Question 12 refers to Natural Cambridgeshire’s ‘Developing with Nature Toolkit’, which aims to achieve the aim of a net gain in biodiversity through new development. The Toolkit acknowledges the role that development has in supporting the delivery net biodiversity gain. It is agreed that development, and in particular large-scale development with sufficient land available, can deliver significant biodiversity enhancements. It is suggested that in deciding sites to allocate for development the emerging GCLP assesses not only whether the potential impacts on protected species and habitats can be mitigated but also whether development can deliver biodiversity enhancements. The promoted development at South West Cambridge would include new accessible parkland and green infrastructure with potential connections to Coton Countryside Reserve. It would retain and enhance existing ecological features on the site and provide biodiversity enhancement including a new wetland habitat at Bin Brook which in addition would also retain floodwater. It is considered that this approach would result in significant net gain in biodiversity. Cambridge Past Present & Future (CPPF) owns and manages the Coton Countryside Reserve, which involved taking land out of agricultural use to create habitats for wildlife including trees, hedges, orchards and meadows. It is considered that the proposed new wetland habitat within the promoted development at South West Cambridge would represent a continuation of the environmental work that CPPF undertakes at Coton Countryside Reserve; subject to discussions, the consortium behind these proposals would be amenable to the possibility of CPPF taking on the management of the wildlife and countryside areas within the promoted site at South West Cambridge.

As I have said above, require each developer to set aside a certain proportion of each development to green space/trees, similar to the requirement for social housing. I don't know if it would be possible, but the developer should give a maintenance fee similar to the section 106 payments for the ongoing maintenance of these green spaces. Personally I would also like to see new houses built with bigger gardens, allowing for the planting of trees, bushes, hedges etc. This is good for wildlife, water absorption and also for the health and wellbeing of residents.

Restrict and discourage domestic use of herbicides and pesticides.

To keep as much as possible of the already existing biodiversity such as trees and hedges and green spaces. Replant along all residential streets and cycleways, create tunnels and bridges for e.g. hedgehogs and also wild flower spots, water gardens and green verges. Cr4eate the semi-rural spaces everone likes in Cambridge.

I think there are two parts to this - where developers are allowed to build and the sorts of materials they are told they need to build with. I think it would be beneficial for new buildings to include materials that support biodiversity such as green roofs. Developers should not be allowed to build on greenbelt land.

A possible inclusion in new developments to increase biodiversity is the use of green-fences: https://www.green-tech.co.uk/green-roofs-and-living-walls/green-walls-and-ivy-screens/living-ivy-green-screen-fence https://www.impactplants.co.uk/product/living-screens-ivy-goldchild-screens/ https://www.mobilane.com/en/products/living-green-screen/

Making sure those developments happen on existing footprints only and NEVER on gardens or green fields. Also incorporating green roofs, and creepers on the walls.

There should be a simple, proportionate methodology set out in the Local Plan to allow demonstration of biodiversity gain associated with new development. For minor development (i.e. less than 10 dwellings) a standardised approach could be adopted but a more tailored approach is probably necessary for large developments. The Local Plan should clearly set out what the desirable biodiversity gains are in general terms.

The Trumpington Residents’ Association can refer to our local experience as a model for future developments. There is no real compensation for the loss of agricultural land which results from large-scale development, but the housing developments in the Southern Fringe have been accompanied by the protection of open spaces through the development of Hobson's Park and Trumpington Meadows Country Park, the partial preservation of hedgerows and tree belts, and the integration of allotments, community gardens and small open spaces within the housing. We stress the value of the parks plus the smaller spaces. However, the developments have also resulted in the fragmentation of tree belts and wildlife corridors, and greater attention needs to be paid to the mitigation of this in future developments, as well as in good maintenance of the spaces that do exist. It is important that there is effective implementation and enforcement of planning conditions during the development process, or the outcome can be far less valuable to the community and the environment than had been promised.

• Unless the site is previously brown-field or intensive agriculture, true and effective biodiversity net gain is often not achieved. Also the density of development may militate against this aim. Short cut grass for recreation does not achieve biodiversity. Undisturbed, wilder land is required. • The way site density is calculated militates against achieving biodiversity enhancement. Developers should provide additional adjacent land exclusively for ‘natural’ spaces, both wild and semi-wild. If this cannot be achieved on site then the required enhancement must be achieved off-site. Such biodiverse areas must be properly managed and funded, in perpetuity, which means professional inspection and assessment, and the will of the authorities to take action if they are not properly maintained.

Natural Cambridgeshire’s Developing with Nature Toolkit seeks to achieve a net gain in biodiversity through new development. It is agreed that development, and in particular large-scale development with sufficient land available, can deliver significant biodiversity enhancements. It is suggested that in deciding sites to allocate for development the emerging GCLP assesses not only whether the potential impacts on protected species and habitats can be mitigated but also whether development can deliver biodiversity enhancements. Land to the east of the Ridgeway and Old Pinewood Way, Papworth Everard was subject to a full suite of biodiversity surveys through the course of the previous applications for the proposed development of the site. These included recommendations for proposed mitigation and ecological enhancements including: retention of existing trees; avoiding vegetation clearance during the nesting bird season; complying with pollution prevention guidance; planting wildlife enhancing plants, trees and hedges; and installing bird, bat, hedgehog and insect boxes across the site.

Net biodiversity gain sounds good in theory, but is more of a soundbite than a policy carrying any conviction. Green roofs are invariably mentioned as an apparent positive element of development, but in an area of extremely low summer rainfall they are unlikely to thrive. This feels like paying lip service to the environment, whilst supporting the development of large commercial sites employing hundreds of people, most of whom will drive to work by car.

Develop brownfield sites/convert unused student housing to normal use. Stick a diverse green roof on. Then make greenfield sites much less monoculture.

This can partly be achieved by ensuring that any new developments provide connectivity for wildlife between green areas, including rows of trees, hedgerows, ditches and other water courses to connect patches of green space. This could include more ambitious schemes where the offsetting from several developments could be used, for example, to purchase larger areas of land, which have a disproportionately larger beneficial effect on biodiversity by minimising edge effects. Ensure that planting schemes have a focus on mixes of plants that are suitable both for use by native pollinators and organisms but will also continue to grow in dryer and hotter conditions. Consider the ecological resilience of both trees and smaller shrubs both in terms of how they support biodiversity more generally but also how they can continue to fulfil this function as the climate changes. Adjust planning expectations of tidiness to produce more biodiverse space. The University of Cambridge is supportive of biodiversity net gain as a key principle for the Local Plan, and is currently developing its own metric for measuring biodiversity on the University Estate. We will publish an evidence-based target for biodiversity net gain with our Biodiversity Action Plan. This metric is based on the proposed Defra Biodiversity Metric but has a number of adaptations that make it more appropriate for ongoing management rather than simply offsetting development losses. We would welcome proposals that see ongoing biodiversity management enforcement enshrined as part of the planning process.

My first thought is how on Earth do we measure “biodiversity net gains”? Total area devoted to nature? Do we count semi-natural spaces? Recovery of locally endangered species? (Even if they are nationally common?) Population count or total count of species? Who is doing the counting? It’s a can of worms. Dense development will inevitably create some tall buildings, so we can easily provide habitat for swifts and cliff-dwelling birds. I suggest the most important contribution here will be long-term funding for expert wildlife management, covering each new development plus neighbouring areas that are impacted.

Minimise housing density, ensure green spaces are within all living areas, everyone has a right to access green space, covenants on paving over gardens/drives, removing trees, grass, shrubs etc. Ensure high rate of occupancy of the developments to minimise onward need for further develolments, i.e. tax those that use for AriBnB, have empty properties. etc. Ongoing commitment/requirement from developers to maintain and increase biodiversity on new developed sites.

Green roofs, but also green spaces that are biodiverse/wild rather than lawns. Have local allotments (rooftop allotments?).

3.25 Biodiversity net gain can be achieved through a combination of off-site and on-site measures. Open space provision should include habitat diversification and creation measures, ensuring that the landscape strategy is responsive to the specific ecological assets on site and in the locality to maximise connectivity and species dispersal potential. Initiatives like SuDS, resource efficiency, biodiversity monitoring and reporting should sit alongside any net biodiversity approach and long term management. 3.26 Should the site be allocated and come forward, Trumpington South can exceed DEFRA’s targets by providing a 25%+ net biodiversity gain through offering a landscaping under Grosvenor’s control that fosters a vibrant community alongside thriving natural environments. Trumpington South provides the opportunity to extend the Trumpington Meadows Country Park providing further valuable contiguous and connected habitats. This would build on the significant biodiversity net gain achieved in the Country Park. There are also opportunities to extend the existing green infrastructure network through the site’s proposed network of green links and interconnected green spaces. Car free zones will also help encourage increased natural habitats.

There should be a simple, and proportionate, methodology set out in the local plan to allow demonstration of biodiversity gain associated with new development. The local plan should clearly set out, in accordance with any forthcoming legislation, what the desirable biodiversity net gains are in general terms. Current open space policies require set amounts of open space to be provided as part of new developments. These can be harnessed to provide onsite biodiversity net gain. If new developments cannot meet the requirements for biodiversity net gain within the site area, a clear, formal, mechanism should be put in place by the Authorities through which financial contributions can be made to projects within the Greater Cambridge area that facilitate biodiversity net gain. Such projects could arguably provide greater benefits through the pooling of multiple contributions and improving public access, supporting wider aims for healthier communities.

The issue of achieving net bio-diversity gain is a difficult one as there is no focus or value given to one species or habitat over another. An invasive non-native species could be given as much weight as a single species native hedgerow. Policy should seek to provide opportunities for bio-diversity in the form of habitat provision but a simple requirement to deliver a net bio-diversity gain will encourage developers to simply clear a site pre-planning in order to achieve the net gain, having the opposite effect, while meeting the wording of the policy. There needs to be a pragmatic view; what species are you trying to promote and why and the baseline from which you are working? For example, it would be dangerous to encourage additional birds to occupy sites around the airport so a more focussed rather than broad brush approach is needed. Any policy should seek to encourage bio-diversity enhancements rather than a simple net increase in species otherwise you the Council is likely to find itself with any site with a baseline of zero species.

Development of green field sites does not easily allow us to “ensure habitats for wildlife are enhanced and left in a measurably better state than they were in before development”, unless a significant portion of each site is set aside, developed as a natural site, and some management plan / future protection is put in place to protect it in the future. If the plan is to generate new wild areas which are not part of the new developments, then some way of ensuring that each new development contributes to this will be required. This would allow a strategic plan, taking into account needs for specific habitats, linkage via wildlife corridors, and also considering the carbon capture benefits of wetlands in particular, to be developed. The effects of housing developments on adjacent green sites needs to be taken into account. General disturbance will have some adverse effect, but any increase in the population of cats will have a particularly adverse effect. In sensitive areas, cat ownership should be banned by covenant in the title to each property. Whereas the effects of a small (1 or 2 property) development are likely to be small in the first place, there will be opportunities for mitigation for large developments which could also ensure a small impact. Particular attention should however be paid to medium scale developments where the primary effects will be large, but opportunities for mitigation may be less. Environmental impact statements should be required to take into account the effects on adjacent sites, as well as on the site in question.