Biodiversity and green spaces

Marshall is thoroughly supportive of a Local Plan that seeks to ensure an enhanced biodiversity resource, with new and better green spaces, within the city of Cambridge and its surrounds. Marshall appreciates that cities that can provide access to a range of green spaces including those that support high levels of biodiversity are better for the people that live there and the environment more generally. The ambitions of Cambridge East align with that of the Authorities as has been set out in the Local Plan evidence submitted by Marshall. Cambridge East can help the GCSP achieve their Local Plan proposals by providing significant green infrastructure to, amongst other things, help provide an enhanced biodiversity resource, a natural water management solution and formal and informal areas for recreation.

Marshall acknowledges the GCSP’s emerging target to achieve Biodiversity Net Gain (BNG) of at least 20%. This is a challenging target but Marshall appreciates the ambition given the global biodiversity crisis and that locally there is seen to be a significant opportunity to ‘double nature’. However, it is appreciated that it comes not without its challenges, as achieving BNG of this level on a site where development is proposed, is likely in many cases to prove to be very difficult given other land-use constraints. Marshall’s view is that, as a result, there will be a need for GCSP to have clearly identified appropriate planning mechanisms for achieving off-site BNG provision likely through the ability to buy off-sets. This should be achieved in areas identified as having strategic biodiversity potential, for example the Local Nature Networks or areas identified as priorities in the Greater Cambridge Green Infrastructure Strategy. This will allow off-site BNG to be targeted in the areas where it will provide most potential value, and balanced against other needs for open and green spaces, including for recreation and wellbeing of existing and future residents.

Marshall would like to, as a part of the evolving Local Plan process, work with the GCSP to help develop these mechanisms. For Cambridge East, Marshall commits to seeking to achieve Biodiversity Net Gain of 20% or more. The ambition will be to achieve as much of this as is possible through on-site BNG provision and via a significant Green Infrastructure Strategy that will include a major green corridor that will run from west to east through the development. In addition, green infrastructure of value for biodiversity will penetrate the built environment too, creating a series of green networks that will allow wildlife to occupy the urban areas of Cambridge as well as the large areas of greenspace.

If development is confined to the airfield, Marshall will seek to achieve BNG of 20% or more within the area of the airfield itself albeit the initial view is that even with large scale green infrastructure provision there is likely to be a need for some off-site provision. For this Marshall would seek to engage with the GCSP to utilise any BNG off-set mechanism that has been developed (and as stated previously Marshall would like to engage with GCSP as soon as is possible to help support the development of such a scheme).

If the extent of the development area was to be extended to cover land to the east of Airport Way, Marshall would propose to continue the green corridor through the development. This would have the benefit of creating an accessible green link that extends from the centre of Cambridge to the countryside that lies to the east. In fact, and as shown in the Cambridge East submission Marshall made in December 2020 to support the evidence base for the Local Plan, if access could be achieved across only a small area of land just to the south and north of the A14, this connection could extend all the way into the area of the Wicken Fen Vision, creating a hugely significant new green network and active travel route. This could potentially link to green infrastructure being proposed as part of Anglian Water’s DCO for the Cambridge Waste Water Treatment Works.

Development in this area would also support the potential re-wetting of Teversham Fen which occurs in land east of Airport Way. This would have a multitude of benefits for wildlife including through the reinstatement of an important biodiversity habitat in its right, and by potentially taking visitor pressure from nearby and more sensitive fenland. Although Marshall has not yet investigated the feasibility of this in detail, it is thought most likely achievable if development was to occur to the east of Airport Way so that surface water run off could be utilised.

In summary, Marshall therefore support the ambition of BNG of 20% or more and will be seeking to achieve this at Cambridge East. The focus will be on provision on-site, but we acknowledge that it is likely that off-site provision will also be required. To achieve this Marshall would like to engage with GCSP at the earliest possible point. In addition Marshall feel that the greatest BNG opportunity would come with extending development and BNG provision to land east of Airport Way, thereby allowing a more extensive Green Infrastructure network to be created.

We support the aim to increase and improve the network of habitats for wildlife, and green spaces for people, ensuring that development leaves the natural environment better than it was before.

Section 3.2 – Biodiversity and Green Spaces

OBJECT

As highlighted in the submitted Vision Document, the promoted development at land at Caxton Gibbet includes substantial areas of green infrastructure and ecological enhancements. It is considered that this approach would be consistent with the aims of the following policies in Section 3.2: Policy BG/BG: Biodiversity and Geodiversity; and Policy BG/GI: Green Infrastructure. It is the large-scale development with sufficient land available that can deliver significant benefits for all these policy areas.

Figure 54 in the GCLP Preferred Options document identifies green infrastructure initiatives, including one at Western Gateway Multifunctional GI Corridors, which is located around Cambourne and Bourn and along the A428 corridor. One of the objectives for this green infrastructure initiative is to “Provide opportunities to improve biodiversity by expanding and joining up the existing woodland, hedgerow and grassland habitat network. This will be delivered through new woodland planting, natural regeneration, hedgerow extension and management, and habitat restoration. Ensure opportunities for biodiversity offsets from East West rail are sought”. – see pg.8 of Greater Cambridge Green Infrastructure Opportunity Mapping Part 2 Recommendations Report (LUC September 2021). The green infrastructure proposed for the promoted development at land at Caxton Gibbet would be consistent with this initiative, in terms of providing additional woodland and retaining and enhancing hedgerows.

There is a real opportunity to deliver green infrastructure improvements to the north of Cambourne in conjunction with employment development at land at Caxton Gibbet, and complement the Western Gateway green infrastructure initiative.

Requested Change

It is requested that the promoted development at land at Caxton Gibbet is allocated in emerging GCLP for employment development to deliver substantial green infrastructure benefits and complement the Western Gateway Multifunctional GI Corridors initiative.

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.

Given that the Environment Bill will set a mandatory 10% minimum biodiversity net gain across the country, the identification of 14 strategic green infrastructure initiatives will assist the delivery of these targets in instances where on-site provision cannot reach this level.

The second ‘Plan Theme’ within section 3 of the First Proposals is ‘Biodiversity and green spaces’. Overall, the Commissioners are supportive of the Councils’ aims to increase and improve habitats for wildlife and green spaces for people, ensuring that development leaves the natural environment better than it was before. The Commissioners do however wish to make specific comment in relation to emerging Policy BG/BG.

The policy should include a requirement for buffer zones around all designated (at any level) wildlife sites. The buffer zones should be similar to those desired for SSSIs, but in any case a minimum of 50m is desirable. In urban locations a buffer might just mean not permitting development of gardens, but could include protection of brownfield sites. In more rural situations there may be opportunity for considerable biodiversity net gain through ELMS, particularly for sites that currently have no buffer protection.

An example where ELMS could be used for benefit would be the Roman Road SSSI, where a 50m buffer on either side could provide opportunity for declining ruderal arable species and hence for declining farmland birds. Equally a buffer of new grassland might allow opportunity for management of the SSSI by grazing, which would help reverse biodiversity decline.

The policy needs to clearly recognise that dogs are not compatible with biodiversity. The policy for all wildlife sites should state that dogs must be on lead. Some sites need to be designated as being dog free, whilst others will need to have limited public access.

Any biodiversity net gain calculations should be done by an accredited member of CIEEM. The calculations need to factor in that a “new” site will not support the same range of biodiversity as an old established site, even it is of greater area. A functioning ecosystem takes a long time to establish and much may be hidden, eg as fungal mycelia. To cover this a multiplicative factor, proportional to the age of the site being developed, should be used in any calculations for the proposed offsetting area.

The Wilbraham River Protection Society supports the proposals to revitalise the chalk stream network and the enhancement of the Eastern Fens in which the Wilbraham River and its tributaries arising in Fulbourn fall. We are, disappointed, however, that the opportunity to encourage the enhancement of the Wilbraham River system does not seem to be taken in the First Proposals as this would clearly help in the enhancement of the Eastern Fens as well as revitalising the chalk streams. (The River is not marked up on Fig. 5.1) We believe the assessment in the Greater Cambridge Chalk Streams Project downplays the role that could be played by this river through emphasising the ' land drainage' element in the low lying fen edge situation. The final comment in that Report that 'if reliable flows were re-instated this river would have multiple opportunities' indicates possibilities that could be taken up should adequate and continuous flows become available. While the Granta/Lodes Augmentation Scheme provides a degree of sustainability, outside drought conditions, we believe water abstraction from the Fleam Dyke Pumping Station and other boreholes has a profound effect on the springs in both Wilbraham and Fulbourn parishes that historically would have run sufficiently to power water mills in both parishes. Enhancing the river flows would, we believe, have a significant effect in increasing biodiversity along the river corridor and its tributaries and play a key role in enhancing the Eastern Fens.

Any such offsetting area needs to have a management plan and funding to enable that management to be carried out.

It will be important for developers to use suitable metrics when assessing sites. Currently this is usually limited to those species that have a “protected” status, such as newts and bats. As biodiversity is in decline across the county, assessment should be made against lists of species of conservation concern in the county. For plants there is a Register of Plants of Conservation Concern https://legacy.bas.ac.uk/met/jds/cnhs/vc29%20RPCC.pdf , which includes all rare and threatened plant species in the county. Similar lists for other taxa could be compiled.

Given the pace of biodiversity loss, the policy should require that site surveys have been made within the last five years.

The policy should not only consider species that are present, but also the overall habitat. On occasion sites will support a range of individual species that are not of individual significance, but overall have high biodiversity. Brownfield sites are typical in this regard.

Amenity grassland can cover a wide variation from a monoculture of hard-wearing grass to species rich that is only apparent during periods such as “no mow May”. Often lawns of older properties retain many species that persist from when the lawn was created.

It is acknowledged that biodiversity and green spaces are important and it is welcomed that this section recognises that development can support on and off-site enhancements for biodiversity and can protect and provide new green spaces for nature.

Land West of London Road, Fowlmere proposes large swathes of public open space which will also contribute to on-site enhancements for biodiversity.

CBC Limited and the landowners share and strongly support the vision for biodiversity and green spaces. The expansion of CBC into the identified Major Area of Change enables the ultimate development of an integrated masterplan in which green infrastructure forms an essential framework for the development. CBC’s Vision 2050 shares the Councils’ determination to achieve the highest standards of development, to integrate and deliver biodiversity enhancement.

4.The policy approach to biodiversity and green spaces is supported. There is significant potential to enhance the biodiversity of the areas proposed for development in Meldreth and Melbourn. The creation of new residential areas would replace existing areas of agricultural land which currently have low levels of biodiversity. It is therefore anticipated that there is significant potential for enhancements to biodiversity and opportunities for net gain of 10% or greater to be achieved as part of development proposals.

Please see additional written representations for further details.

The National Trust supports the aim set out. One of our priorities set out in our Strategy (2020-2025) is to increase access to the outdoors, focusing on opportunities for people and nature to connect.

OBJECT

As highlighted in the submitted Vision Document, the promoted development at South West Cambridge would include new accessible parkland and green infrastructure with potential connections to Coton Countryside Reserve. It would retain and enhance existing ecological features on the site and provide biodiversity enhancement including a new wetland habitat at Bin Brook which would also retain floodwater. It is considered that this approach would be consistent with the aims of the following policies in Section 3.2: Policy BG/BG: Biodiversity and Geodiversity; Policy BG/GI: Green Infrastructure; Policy BG/RC: River Corridors; and Policy BG/EO: Providing and Enhancing Open Spaces. It is the large-scale development with sufficient land available that can deliver significant benefits for all these policy areas.

Figure 54 in the GCLP Preferred Options document identifies green infrastructure initiatives, including one at West Cambridge GI Buffer – Coton Corridor, which is located on the western side of the M11 and opposite the South West Cambridge site. The objective for this green infrastructure initiative is to “Enhance the recreational and habitat offer to ensure there is sufficient high-quality and accessible GI to keep pace with growing development (and associated recreational pressure) west of Cambridge. This includes improving accessibility to and between GI assets and surrounding settlements, providing more opportunities for recreation and nature (making sites 'work harder'), expanding GI where possible, and enhancing habitats” – see pg.8 of Greater Cambridge Green Infrastructure Opportunity Mapping Part 2 Recommendations Report (LUC September 2021). The green infrastructure proposed for the promoted development at South West Cambridge would be consistent with this initiative, in terms of providing additional opportunities for recreation and nature, improving accessibility to green infrastructure for Cambridge residents, and connecting green infrastructure areas.

Cambridge Past Present & Future (CPPF) owns and manages the Coton Countryside Reserve, which involved taking land out of agricultural use to create habitats for wildlife including trees, hedges, orchards and meadows. It is considered that the proposed new wetland habitat within the promoted development at South West Cambridge would represent a continuation of the environmental work that CPPF undertakes at the Coton Countryside Reserve.

There is a real opportunity to deliver green infrastructure improvements on the western edge of Cambridge in conjunction with development at the South West Cambridge site, and complement existing initiatives and activities.

Requested Change

It is requested that the promoted development at South West Cambridge is allocated in emerging GCLP to deliver substantial green infrastructure benefits and complement the West Cambridge GI Buffer – Coton Corridor initiative and CPPF’s work at Coton Countryside Reserve.

The policy should provide a balanced approach to ensure that the other aims of the emerging Greater Cambridge Local Plan i.e. delivery of homes and jobs are not overly restricted by the aims of biodiversity and green space protection and enhancement.

The land at Cambridge South has limited ecological value and currently provides a barrier between the city and the River Cam. The opportunity exists through development to achieve significant biodiversity gains but also to connect important links in the Greater Cambridge Green Infrastructure Network.

RSPB supports the general direction outlined here. We believe that the objective should explicitly include that the plan policies will contribute toward doubling nature in Greater Cambridge – something the councils have signed up to as part of the OxCamArc Environmental Principles. We support objectives for green space which benefit people and nature.

We believe biodiversity should be integrated into the whole landscape. From public parks, verges, gardens and farms, opportunities for biodiversity should be included in all new developments, for example
• bee-friendly plantings,
• wild flower meadows,
• tree planting and space for woodland
• fruit trees in public spaces
• Local composting facilities
• Space for wetlands – ponds, lakes and rivers

Grosvenor supports these aim of the Plan. The proposals at Whittlesford would achieve a BNG and create a striong green infrastructure network as can be seen from the vision and environmental appraisal documents.

Though the plan notes the need for biodiversity and green spaces, it contradicts this position by allowing proposals to release areas of green belt for development.

The southern approaches to the City are the last real rural areas around Cambridge following the developments to the north west, north and north east of Cambridge.

Biodiversity and green spaces - general comments We support policies which support general health and well-being, access to green space, and healthy lifestyle choices.

Cambourne Town Council supports the theme as it addresses the aims contained in the vision.

General vision is to support and protect existing nature sites. Sadly many developments will be built on and take away well-established green open areas - fields north of Cherry Hinton and airport which have been home to
vast amounts of wildlife, wild flowers, streams with frogs, tadpoles, birds,hedgehogs, bees and butterflies for years.
The proposed policy approach to Bio/Geodiversity (section 3) which centres on a 20% minimum net gain is ambitious, realistic, and welcomed. However, there is no clear policy to explain what procedures will be in place should overall progress falls short of this target. In section 3.5, 3rd bullet point, there is a typo (off/on-site) but in any case the policy should prohibit off-site where-ever possible since this can be leveraged as a loop-hole by small developments at the detriment to local parishes and neighbourhood plans.
It is disappointing to see the Councils not yet have adopted its own metrics to assess environmental net gain, particular given the importance of the local ecosystem. Such a metric would assist the Councils better assess the impact of developments encroaching on green belt, such as proposals to relocate Cambridge United football stadium, the Newmarket Rd P&R, and sewerage works. As a parish council, we oppose the re-location of the P&Ride site to the Teversham side of airport Way, as this will encroach on the Green belt and encourage further connected development, as the current P&Ride site has.
Recognition of recreational impact as a "significant issue" is welcome and future clarification of the policy must include a focus on pro-active repair and maintenance, both of which are currently lacking.

In section 4.4 "Green Infrastructure, Evidence Base" there is no mention of the pressure from the significant number of large housing developments on pressures to the chalk stream network. This is a major omission that needs to be addressed urgently. It is also disappointing not to see mention of quantitative targets throughout this section. A simpler route to obtaining planning permission for community orchards and allotments is required.
It is positive to see policy for green infrastructure explore the proposal for all significant developments to align to the Building With Nature standard. This will strengthen the framework for protecting green spaces identified in local neighbourhood plans, for example.
It is not justified to reject the alternative approach to restrict development within respective GI strategic areas on the basis that these areas are too broad. To redress the balance wherein the value of GI is greater than that of new developments, the policy should be to define the strategic areas more specifically.
The poor tree canopy cover across Cambridgeshire is well known (e.g. Woodland Trust) and the target of 19% TC by 2030 is welcome. However, it is disappointing to not see in the Evidence Base a more recent re-evaluation of the scientific and biodiversity value of all wet woodland on clay soils (e.g. Hayley Wood). While there are many welcome and well-intentioned policy proposals for woodlands, there is a greater need for specific quantitative targets that align to the BNG target as well as the TC target. A far greater emphasis on improving the quality of woodland and hedgerow is required. There are many local public woodlands and hedgerows which are low in diversity because of poor maintenance (as evidenced by overgrowth of ivy).
It is welcome to see in section 7 a recognition that wellbeing and open spaces are linked, particularly a focus on formal sports pitches. It is surprising that there is no mention of partnerships with major charities, especially the football foundation. Furthermore, while reference to strategic sporting facilities is made, there is no mention of support for grass roots clubs and this omission should be rectified.