Object

Representation ID: 56016

Received: 05/10/2020

Respondent: Endurance Estates

Agent: Barton Willmore

Draft Policy 5 requires development proposals to deliver a minimum of 10% net gain in biodiversity value through a number of listed measures, of which 1 and 4 require:

1. Provision of measurable improvements in the size, quality, diversity and relationship of the site’s habitats, to deliver a coherent and high-quality ecological network as part of the wider green infrastructure network, landscape character and place making;

4. Delivery of coordinated habitat and water quality improvements to the First Public Drain, Milton Country Park and Chesterton Fen.

The above measures rely on betterment to the site’s existing habitats as well as green connections and an ecology network across the AAP area. The brownfield or open mosaic habitats present in the siding and WwTW are less common in Cambridge and are distinctive for their range of habitat and species. They also provide multiple opportunities for wildlife to thrive as reported in the NEC Biodiversity Assessment. There are also protected and notable species through NEC including water vole, roosting bats, reptile populations and notable plant and invertebrate species. These ecological features will present a high bar from which an additional 10% net gain is to be achieved. They will also present potentially significant constraints upon some development activities and a commitment in the spatial framework to their delivery.

This is currently not the case in the AAP boundary area, as it does not include Chesterton Fen, which is identified in the Biodiversity Assessment as key to providing compensatory habitat for the loss of the open mosaic habitats in the sidings and Cambridge Waste Water Treatment Plant. It is also not clear whether land ownership will be a barrier to delivering this area of compensatory habitat. Therefore, we would suggest for its inclusion and commitment in the AAP area. As stated in Policy SS/4(3) of the South Cambridgeshire Local Plan, “The final boundaries of land that the joint AAP will consider will be determined by the AAP”.

The existing biodiversity on the site, and the proposed quantum and density of urban development makes the 10% net gain in biodiversity value in Draft Policy 5 a very ambitious and potentially unachievable target. As can be seen below, the recommended biodiversity opportunities and green infrastructure networks set out in the Biodiversity Assessment appear to be tightly confined and reduced by the allocated development area within the AAP’s Spatial Framework.


NEC Biodiversity Assessment













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NECAAP Spatial Framework

















This leads us to question whether the quantum of 8,000 units and 202,900sqm of new employment, commercial and community space is too much for this site. Conversely, is the amount and size of planned off-site compensatory habitat large enough to deliver a 10% net gain across the APP when considering the policy drive to make best use of land? On a related note, we would also question whether the SA/SEA and HRA processes can be considered to be comprehensive and robust, if Milton Country Park and Chesterton Fen form an intrinsic part of the NECAAP and yet these locations are treated as being off-site.
(Maps see submission attachment)
This leads us to question whether the quantum of 8,000 units and 202,900sqm of new employment, commercial and community space is too much for this site. Conversely, is the amount and size of planned off-site compensatory habitat large enough to deliver a 10% net gain across the APP when considering the policy drive to make best use of land? On a related note, we would also question whether the SA/SEA and HRA processes can be considered to be comprehensive and robust, if Milton Country Park and Chesterton Fen form an intrinsic part of the NECAAP and yet these locations are treated as being off-site.