The RSPB fully supports the councils’ approach to require 20% Biodiversity Net Gain from development within the Greater Cambridge Area. We believe that this is justified due to the relative paucity of land managed for nature and of priority habitats, both in Greater Cambridge and in Cambridgeshire county more widely. This approach is required if we are to Double Nature in the plan area.

We support the approach of providing BNG on site where practicable, but contributing to larger, strategic sites when needed. However, we believe that care is needed if linking this to the Green Infrastructure strategic objectives. Although GI and BNG outputs are likely to be complementary, they are separate requirements. Strategic BNG provision should be aligned to help deliver the Local Nature Recovery Strategy once this has been formalised. It is likely that this will incorporate initiatives such as the Cambridge Nature Network and other landscape scale priority areas identified by Natural Cambridgeshire, which in a Greater Cambridge context also include the Great Ouse Valley and West Cambridgeshire Hundreds.

This may be reflected in the policy wording when drafted, but the parts of this policy related to site protection and procedure will obviously need to take full account of the approach taken through the Habitats Regulations to Special Areas of Conservation and Special Protection Areas, and the much more stringent protections and tests applicable to these sites, which is not reflected in the policy direction explanatory text at the moment.