The overall intent and policy direction of this policy is welcomed and supported. The need for development plans to take a strategic approach to maintaining and enhancing networks of habitats and green infrastructure is of critical importance. This objective is a core part of the ‘Cambridge Nature Network’ which is supported by both South Cambridgeshire and Cambridge City Councils and we are pleased that this document has also been referred to. We also agree that green infrastructure initiatives must be included in the development plan rather than a supplementary planning document to provide the strongest possible support.

It is noted that views are sought on the adoption of standards for the provision of green infrastructure such as those set out in ‘Building with Nature’. Adoption of a set of key objectives and principles for the provision of green infrastructure is welcome - although the detail of theses would need careful consideration. As we commented with regard to policy BG/BG, the protection of existing sites must be the first priority. As the explanatory text for standard 11 (Delivers Wildlife Enhancement) of the Building with Nature document notes:

‘This standard emphasises the requirement to follow the Mitigation Hierarchy and create
Net Positive benefits for wildlife. The standard reiterates the need to protect any existing ecological assets as a necessary first step in the development process.’

Any application of standards should also, of course, not simply be used as a green ‘tick list’ or applied to try and make developments acceptable when these would cause permanent harm (or risk of harm) to important biodiversity sites or interests.

We strongly agree that “Opportunity Mapping has identified a number of strategic green infrastructure initiatives which have the potential to enhance the existing network. This policy will require all new development to help deliver or contribute to support delivery of the green infrastructure strategic initiative objectives. Contributions will include the establishment, enhancement and the on-going management costs.” In our research for the Cambridge Nature Network (http://cambridgenaturenetwork.org/) we identified that the creation of new accessible green space in Cambridgeshire has not kept pace with the increase in population over the past 20 years and this has been one of the main drivers of recreational impact on wildlife sites. In addition, many green space sites in Cambridgeshire are wetlands, meaning that although they might cover a large area, the amount of land that can actually be used by the public is often small or limited to paths. Unlike other counties Cambridgeshire does not have large areas of public access woodlands, downland/moorland/heathland or coastline and as a consequence there is poor access to countryside. Our research also identified that larger scale development (such as Cambourne) were providing larger areas of new greenspace but smaller developments were not and therefore it is these that are contributing most towards the problem as they have made up around 50% of the development in Cambridgeshire over the past 20 years. If the Local Plan is to be sustainable (ie not increase recreational impacts more than has already occurred) then ALL new development will need to make a contribution towards creating new strategic greenspace (if none is created through the development). The Local Plan should set out how these contributions are to be collected and the amount that would be required per person. We refer you to the submission by the s106 Officer for South Cambridgeshire District Council who has calculated that this should be £498 per dwelling.
We have noted the Greater Cambridge Green Infrastructure Opportunity Mapping Final Report (2021). We have been trying to arrange a meeting with officers to discuss this and will submit additional comments once we have been able to do so.