A significant amount of development will come forward through windfall (or outside the development plan) and the potential impacts of this on biodiversity will need to be dealt with on a case-case basis, therefore it is essential that policies for biodiversity and green spaces are as strong as they can be and that the plan policies protect existing nature rich areas by strongly emphasising the mitigation hierarchy: avoid, minimize, restore and offset.

The overall policy direction is supported and welcomed. However, Cambridge Past, Present & Future consider that future plan policies should be prioritised with the protection of existing interests as the first principle. As the Biodiversity and Green spaces Topic paper 3 indicates at para 3.2:

"The National Planning Policy Framework (2019) paragraphs 174-188 relate to Conserving and enhancing the natural environment. Particularly relevant to biodiversity and geodiversity is paragraph 179b, which sets out that local plans should promote the conservation, restoration and enhancement of priority habitats, ecological networks and the protection and recovery of priority species; and identify and pursue opportunities for securing measurable net gains for biodiversity. "

Thus, the starting point for future policies should be the protection of existing sites of both biodiversity and geodiversity importance. This will give a clear statement of intent from the outset for any future developments. Future policies should also give some detail of what is expected with regard to development affecting these interests; we comment further on this below.

Linkage to wider GCLP Policies

Future GCLP policies for development must not put the protection and enhancement of biodiversity at risk. This means that all of the consequences of any new development or infrastructure for these interests must be assessed fully before being incorporated in the new plan. This is also likely to require action by other statutory bodies to ensure the delivery of new development without causing further harm to existing interests.

Water supply is a good example. Planning decisions that provide for future development can influence the quantity and quality of water with further potential effects on biodiversity in a number of ways. For example, the use of streams and rivers to carry the outfall from sewerage treatment could have critical effects on wildlife. In addition, whilst water availability is, of course, a relevant constraint that the planning system should consider, the capacity of our watercourses to dispose of treated water waste is likely to be a more binding one. Furthermore, consideration must also be given to the climate-change-induced, greater frequency of storm events. Without increased investment by the water authorities the frequency of storm events leading to raw sewerage being discharged is likely to increase, even at current levels of development. It should not be assumed therefore that water authorities will simply be able to accommodate the extra demands of new development. Another potential consequence of planning decisions is the demand for increased abstraction of better quality water from aquifers leading to more pressure on vulnerable wildlife dependent on it. Impacts on wider catchment areas beyond the GCLP area is another issue that will require cooperative working between statutory bodies and adjoining Local Authorities.