Biodiversity and green spaces
66. The stated aim “Increase and improve our network of habitats for wildlife, and green spaces for people,
ensuring that development leaves the natural environment better than it was before.” clearly demonstrates
that this draft Local Plan is adopting a green-washing approach to bio-diversity.
67. Except in the case of some brownfield sites which can be restored, or existing sites where greenspace can
be improved, development will always damage the natural environment. Even the supply of building
materials will likely damage the natural environment elsewhere, whether obtained locally, nationally or
internationally.
68. The best possible treatment for the natural environment is to leave it undeveloped and in its natural state.
There are steps that can be taken to improve the biodiversity of unbuilt land with appropriate planting and
management. These are steps which should be encouraged.
The next few sub-paragraphs are taken from the submission of The Friends of the Cam and are statements
which CPRE fully supports and has signed up to:
a. Concepts such as Natural Cambridgeshire’s 'Doubling Nature' ambition, Biodiversity Net Gain (BNG)
and Natural Capital Accounting (NCA) are being used as bargaining chips in the developers' casino
that broadly amounts to saying 'no development means no funding for nature'. This is the antithesis
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of John Lawton's 2010 plea in 'Making Space for Nature' of significant funding for Nature
conservation without any strings attached.
b. The concept of doubling nature is ill-defined (doubling what, exactly?). The Draft Local Plan needs to
define exactly how the concept will be understood and measured.
c. The global experience of Biodiversity Net Gain, reviewed by zu Ermgassen of DICE, University of
Kent, is that it fails twice as often as it succeeds, even though it had the lower bar of No Net Loss,
NNL rather than BNG.
d. The same group more recently showed that 95% of early-adopters of BNG practices in England are
carrying out on site offsetting (something not covered at all in the new Environment Law) where the
developer is the judge, jury and executioner of any offsetting plans. In any case, on site offsetting
will not encourage many forms of wildlife and will be prone to the dog-fouling and trampling that
harms many wildlife areas, even those remote from housing. Meanwhile, off-site off-setting is
already damaging local communities in some rural areas.
e. Natural Capital Accounting is an untested concept. The monetary assessment of ecosystem services
(the 'yields') is recognised as being inadequate at present, while assessing the monetary value of
ecosystem stocks is more or less impossible (Ian Bateman, communicated to David Rogers). Yet the
resulting monetary assessments may be used to trade away environmental for economic assets with
a greater yield, for example a factory in a water meadow.
f. The natural environment is our vital life support system and it is a dangerous delusion to imagine
that it can be rendered easily into any economic framework (let alone the pre Dasgupta framework
that gives GDP/GVA primacy over all other forms of stocks and yields).
g. Dasgupta defines wealth as the sum of natural, human and economic capitals and yields, and
sustainability as the condition where this sum is either stable or increasing. Economic growth at the
expense of natural capital and yields is therefore unsustainable.
h. We request that the Cambridge Local Plan adopts the Dasgupta definition of sustainability (i.e.
definitely not the NPPF's false definition of 'sustainability'), with the caveats mentioned above,
especially the false or under-valuation of natural capital. This would provide a better starting point,
and the Plan should be reworked in this context.
69. CPRE repeats the request made in paragraph h) above.
70. CPRE are disappointed that we can find very little mention of hedgerows in this part of the plan or
elsewhere. Hedgerows are significant contributors to bio-diversity, as was demonstrated by the work of Dr
Norman Moore. In addition, hedgerows are more effective carbon sequestrators per unit area than tree
plantations, certainly in the first ten years of growth if not longer. With six to seven tree plants per metre in
a hedge, it stands to reason they will be most effective carbon sinks.