Comment

Representation ID: 55957

Received: 05/10/2020

Respondent: Natural England

Whilst we support the intention of this policy to protect exiting open space and provide new and
enhanced high quality, multi-functional open space, the delivery of 10ha of open space, the
equivalent size of Parker’s Piece or twice the area of Nun’s Way Recreational Ground, is unlikely
to meet the recreational demands of this sale of development and mitigate the impacts of
recreational pressure offsite. This level of provision falls significantly short of Local Plan open space requirements and is substantially less than the 8ha /1000 population standard advocated
through Natural England’s Suitable Alternative Natural Green Space (SANGS) guidance to meet
people’s needs and protect more sensitive designated sites such as Stow-cum-Quy Fen Site of
Special Scientific Interest (SSSI) and Wicken Fen SSSI, Ramsar site.

We are aware that the HRA / SA are in the process of assessing the recreational pressure impacts
of NECAAP development on designated sites and that these will identify specific mitigation
requirements to address adverse impacts. The HRA recommends discussion with the National
Trust to determine how increased impacts to Wicken Fen will be mitigated. A further
recommendation is for this policy to include a commitment to the provision of alternative natural
greenspace that is specifically designed and managed to alleviate visitor pressure on Wicken Fen
Ramsar and Fenland SAC.

Natural England agrees that further consideration of recreational pressure through the AAP/HRA
should include detailed discussion with the National Trust regarding impacts to Wicken Fen and
the Vision Area. We will be pleased to engage in any discussion. To address this and the wider GI
needs of the development we advise that the AAP should develop a strategic approach to GI and
biodiversity by identifying and mapping the existing network and viable opportunity areas i.e. a GI /
Biodiversity Expansion and Enhancement Framework Plan for expanding and enhancing the
green infrastructure network, including Bramblefields, Chesterton Fen, Milton CP and elsewhere.
This should draw on the GI and Biodiversity Opportunity Mapping Project being undertaken for the
Greater Cambridge Local Plan and the recommendations / opportunity areas identified in the
Biodiversity Assessment (MKA Ecology, June 2020). In particular this should identify viable
opportunity areas for the delivery of GI/biodiversity mitigation measures identified through the
revised HRA/SA, informed through discussion with the National Trust. Policy requirements should
be set to ensure delivery of the Framework through each phase of development.

The scale of development and the level of greenspace currently proposed is likely to result in local
sites such as Bramblefields and Milton CP being overwhelmed by additional visitor pressure. This
is likely to have an adverse impact on biodiversity and people’s enjoyment of these sites. Whilst
we welcome further proposals to enhance linkages to existing open spaces, adverse impacts
associated with the additional pressure, should be addressed through delivery of proportionate
expansion and enhancement measures at these sites.

Natural England will be pleased to offer advice on a draft GI / Biodiversity Framework for the
NECAAP. Our advice is that a strategic level of high-quality greenspace provision will be key to
creating a healthy community and enhancing people’s physical and mental wellbeing. The extent
of accessible natural greenspace provision (i.e. excluding formal sports areas) should be
proportionate to the scale of development, for example whilst quantity of provision should be
broadly aligned with SANGS guidance, green infrastructure design should seek to achieve the
Natural England Accessible Natural Greenspace Standards, detailed in Nature Nearby, including
the minimum standard of 2ha informal open space within 300m of everyone’s home. We advise
that green infrastructure provision should also seek to contribute towards the delivery of the
objectives of the Cambridgeshire Green Infrastructure Strategy for habitat enhancement and
improved connectivity.