Question 8
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There has been a huge loss of derelict wasteland (at the sidings and to come at the sewage works), which was brilliant for amphibians. How will they assess an increase of 10%? Hard to see how biodiversity will be increased. Which marker species will be used? Could the developer make a contribution to the development of the rowing lake? (not uniformly popular) There were historic problems with drainage and flooding in this area: recently the 1st public drain was very close to overtopping. Need more green space. Need an extension to Milton Country Park.
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Further comments: No comment
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Developments should achieve the national recognised standard of net gain, and if they can achieve this on site, there should not be a requirement to make contributions towards off-site improvements. At the time of writing the Environment Bill has not been made law.
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We are in broad agreement with the content of Section ‘4.4 Biodiversity’ and the ‘Policy 5: Biodiversity Net Gain’. However, we have strong concerns that with the inevitable focus on the metric for biodiversity net gain, which applies to green habitats only, that other important aspects for gains in biodiversity such as integral bird bricks in all dwellings (MKA Biodiversity Assessment Recommendation 21 page 38) will be lost. On page 70 of the Draft NE Cambridge AAP it is noted that existing habitats support a number of species including Common Swift and House Sparrow and on page 71 there is a brief reference to National Planning Policy Guidance, which also notes that ‘relatively small features such as swift bricks and bat boxes can achieve important benefits for specific species’ This is an important part of bringing nature closer to people together with green roofs and green infrastructure such as native hedges and shrubs close to buildings. This can provide shelter and food for birds and other creatures and a pleasant green environment adjacent to homes rather than these being surrounded with largely hard landscaping. We urge that the wording in Policy 5 should be strengthened to specifically include reference to integral swift bricks in all buildings at a ratio of at least 1:1 per dwelling with adjusted provision for blocks of flats, schools, community buildings and commercial premises, together with bat boxes, green roofs and adjacent green infrastructure. Please see more detailed comments in response to Policy 5. Submitted by a community action team including Action for Swifts (established 1995) Fulbourn Swifts Group (established 2011) and The Over and Swavesey Swift Conservation Project 2020 working for the conservation of swifts and other threatened species in the Greater Cambridge area. We are actively involved in practical swift conservation, nest brick and nest box design, planning processes, monitoring of nest brick and nest box installations in new developments, advising commercial swift nest box designers, house designers and developers both locally and nationally.
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Refer to comments under Policy 5
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• The site at present is a wonderful wildlife area with large trees and plenty of birds and small animals. There is also a small natural drain with lovely clear water full of fish. These will all go to make the new development. It is difficult to see how building will increase biodiversity.
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Further comments: By continuing to build houses you are putting yet more biodiversity and natural landscape at risk.
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• We believe the policies set out in the AAP are sound and comply with the latest thinking on biodiversity and development. • Ecological disturbance of surrounding areas caused by increased population pressure is mentioned but insufficiently examined in the AAP. • When applying a biodiversity matrix, levels of disturbance increase the amount of compensatory habitat required because existing habitat quality will be reduced by human disturbance. Natural England has developed an alternative measure for situations where there are recognised recreational pressures on designated nature conservation sites: the Suitable Alternative Natural Green Spaces (SANGS) measure suggests that natural greenspaces should be provided at a level of 8ha per 1,000 population. Here, that would entail a new natural green space of at least 10ha. The proposed new nature reserve at Chesterton Fen would be just 26ha. • SANGS includes a range of other recommendations as to the minimum size and characteristics of natural greenspaces for them to effectively act as alternatives to vulnerable nature conservation sites. While this approach was originally developed for internationally important heathland sites, it is starting to be more widely used. • The AAP recommends a S106 agreement to fund the creation of a wetland nature reserve on Chesterton Fen. Is this realistic? How much will the land acquisition and landscaping cost? How much of that could a S106 agreement be expected cover? What additional funding sources will be used? We would prefer to see this area included in the AAP and subject to a local Development Corporation which would have the ability to implement it. • The AAP acknowledges that at least some of the 10% net gain in biodiversity will have to ‘outsourced’, but no further detail is provided.
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No answer given
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It is encouraging to see the attention to biodiversity, but it would be good to see more than the minimum 10% net gain mentioned. There should be specific mention of ways of including measures everywhere possible (for example through pollinator-friendly public planting, making the most of even small opportunities.)
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Further comments: Seems to eb the bare minimum. Lack of wildlife corridors and connectivity to external areas.
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As per the previous response, whilst brownfield in nature the relocation of the WWTW does provide a somewhat blank canvas in terms of the potential masterplan for the area. However, the balance of green and blue infrastructure appears to heavily rely on that already provided within CSP, with the introduction of a linear park and triangular space which fit around the built form, rather than a landscape and biodiversity rich approach. The 2020 Biodiversity Assessment which supports the draft NECAAP sets out a number of recommendations, which TCC believes development of CSPN would help to achieve as follows: • Recommendation 4: All developments and projects should deliver a measurable biodiversity net gain with a target of 10% gain. • Recommendation 12: Develop green loops to encourage engagement and contact with nature to promote well-being and to deliver health benefits. • Recommendation 17: Encourage the provision of priority habitats within NEC including woodland, ponds, drains, grasslands, hedgerows and living roofs. Emphasis should be placed on delivering a mosaic of habitats to ensure diversity in opportunities for the species using them. One solution to the acknowledged difficulty in providing biodiverse development within the AAP area would be through Cambridge Science Park North which is being developed as a location that can provide compensatory improvements to a substantial (circa 90 hectares) area of remaining Green Belt land providing: • A network of new green infrastructure; with links to Milton Country Park, Histon & Impington, and Arbury and Kings Hedges. • Woodland planting of sufficient scale to provide meaningful woodland carbon capture; • Landscape and visual enhancements taking existing agricultural land and creating a valuable green asset for neighbouring communities and employees. • Improvements to biodiversity, habitat connectivity and the introduction of natural capital to an area of low ecological value agricultural land. • New and enhanced walking and cycle routes, linking into the planned improvements to Mere Way; and, • Improved access to new recreational and playing field provision. These proposed uses are all entirely compatible with both the purposes of the Green Belt and uses which are deemed as appropriate within the Green Belt i.e. material changes in the use of land for outdoor sport and recreation.
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Natural England supports the NECAAP commitment to deliver 10% measurable biodiversity net gain through improvements to the First Public Drain and linear park and Chesterton Fen along with green linkages to other biodiversity sites. We note that developers will be asked to contribute to improvements at key sites for nature including Milton Country Park and Chesterton Fen. As per our advice on green infrastructure above, we believe these offsite environmental opportunity enhancement areas should be secured and identified within a GI and biodiversity framework plan within the AAP. The AAP should set out how the project/s will be delivered and managed in the long-term. Robust policy requirements should secure delivery / developer contributions towards their delivery.
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• We welcome the use of the net gain metric but in line with our ‘Nature’s Arc’ vision, we would like Greater Cambridge to aim for 20% net gain from such an ambitious development boasting high credentials. • It is appreciated with a high-density development, achieving just 10% will be difficult without imaginative and achievable on-site thinking and off-site mitigation. • Where off-site habitat creation is required, we would encourage you to start evaluating where this might be best implemented now to contribute towards the Doubling Nature target which the Greater Cambridge Partnership have signed up to. • It is very important that each development phase follows the recommendations laid down in the Biodiversity Assessment in order to meet any chance of achieving at least the minimum 10% net gain on the site.²³ • We welcome the opportunity the development provides to restore Chesterton Fen. However, this is a small site which is unlikely to meet the requirement of a significant net gain. It will also need careful access measures and zoning to minimise negative impacts of recreation on wildlife. • Plans are also intimated to improve access and capacity for Milton Country Park. However, as with Chesterton Fen, this will not achieve significant net gain and is already over capacity.²⁴ • We note some existing ponds are concrete in construction with vertical sides. We would like to see measures implemented that modifies and enhances them to be of benefit to wildlife and contribute toward on-site net gain. • The Assessment references the use of SuDS to be incorporated into the green-blue infrastructure. We remain sceptical as it is all too often the case poor design fails to deliver any biodiversity or amenity benefit.²⁵, ²⁶, ²⁷ • The use of green roof mitigating measures for the loss of Open Mosaic Habitat (brownfield) is welcome. The Assessment report (Appendix 3) estimates there to be approximately 4.74ha of ‘good’ condition OMH. To deliver a minimum 20% net gain requires 5.7ha of biodiverse green roof.²⁷ • In addition to, and where this target cannot be fully met on roofs, we would also like to see extensive areas of eco-mimicry in landscaping at ground level across the site, particularly in areas of existing brownfield, such as the railway sidings and water treatment plant, will be lost.²⁸ • Green roofs should also be provided on all covered street furniture, such as bin stores, bike sheds, car parking and bus shelters. • The recommendations made by the Biodiversity Assessment, for long-term landscape and ecological management plans are welcome. All levels of work should be undertaken by competent and suitably qualified operatives. Furthermore, all short and long-term landscape maintenance contracts should not use herbicide. ________________________________________ Qualifying points to responses: ²³In addition to habitat recommendations made by the Biodiversity Assessment, if undertaken correctly to meet net gain they must also benefit the identified priority species of local, regional and national interest across all taxa. As advised by the assessment this must extend to built-in features such as integral bat and swift bricks of the right product, located in the right places and in the right quantities. ²⁴As outlined in our response to Question 7, Milton Country Park would require a substantial habitat expansion to and along the River Cam, as the Park is already at footfall capacity and it will be very difficult to balance the needs of access and recreation alongside biodiversity. ²⁵To be effective and contribute to net gain all SuDS must be designed and landscaped appropriately to provide sources of nectar for pollinators through native flower rich grasslands, to diverse mixes of native and non-native planting. In addition, to maximise biodiversity and amenity benefit all run- off must be treated at source before being allowed to enter any existing aquatic features, particularly the First Drain. Appropriate source control, including permeable road surfaces, kerbside rain gardens (bio-retention beds) and filter strips will also remove need for gully pots. Gully pots were highlighted in the Biodiversity Assessment as cause of high amphibian mortality. ²⁶https://www.rspb.org.uk/globalassets/downloads/documents/positions/planning/sustainable- drainage-systems.pdf ²⁷The benefits of green roofs and SuDS in high density urban areas are well documented and researched. One such example being Monitoring Report 3 of the Sustainability Research Institute ’Climate Proofing Housing Landscapes’: https://www.researchgate.net/publication/323749977_London_Borough_of_Hammersmith_and_Fu lham_Climate_Proofing_Housing_Landscapes_Monitoring_Report_3/download ²⁸Eco-mimicry is well researched: https://www.thenatureofcities.com/2018/01/09/blandscaping- erases-local-ecological-diversity/ and trialled, https://www.grassroofcompany.co.uk/brownfield- landscapes including at Bramblefields https://lnr.cambridge.gov.uk/projects/bramblefields-ceramic- mound/ within the development area. They are a cost-effective way to provide rich biodiverse, climate resilient habitat. They use nutrient poor substrates such as crushed concrete, brick, ceramics, glass and sands, for which there should be no shortage from any demolition undertaken on site. The es ensures all landscaping is climate resilient and will contribute to both biodiversity net gain and sustainability.
8.1 It is noted in Policy 5 development proposals will be required to deliver a minimum of 10% net gain in biodiversity value. The policy outlines the approach to delivering this. The policy has been informed by a site wide ecology study (2020). It is important developers view the 10% net gain as a minimum and take opportunities to exceed this where possible. 8.2 Policy 5 outlines the securing of appropriate habitat management and monitoring plans. These are crucial to ensure the 10% increase in biodiversity is met.
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Please see attached Letter including representations on behalf of The Crown Estate. The Crown Estate supports the AAP's strategy to improve biodiversity within and around North East Cambridge. Specifically, the initiatives of protecting Cowley Road Hedgerow and encouraging green and brown roofs on buildings are supported and align with The Crown Estate's own biodiversity goals. The Crown Estate’s commitment is to create a habitat of value to wildlife by incorporating pollinators friendly species or for foraging, with all green spaces looking to achieve two or more functions. The Crown Estate will look to achieve a minimum of 15% of development area to be valuable net gain green space.
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According to your ecological summary there is very little habitat in NEC (a drain and one hedgerow). Improving it should not be difficult but it comes at the expense of the destruction of Green Belt which will be concreted over to build the new sewage works. NEC is effectively being built on Green Belt. This is not mentioned in the AAP
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