BG/BG: Biodiversity and geodiversity

We are in favour of increasing biodiversity in Greater Cambridge, but we have have grave concerns about how biodiversity is to be measured in a valid manner.

"Proposed policy directions" concentrates on biodiversity net gain at the development site. It should be unambiguously stated that developments which will adversely affect biodiversity on neighbouring sites of significance (such as county or city wildlife sites) will not be permitted.
The final paragraph of "Why is this policy needed", on the impact on biodiversity of increasing numbers of visitors, is important. There should be clear provisions for the protection of vulnerable sites from damage by excessive numbers of visitors, especially at sensitive times of year (e.g. when birds are nesting).

Where BNG is to be achieved offsite, we suggest that developers are required to demonstrate the BNG measures in practice before the housing development itself is occupied. This will provide incentive to start and to finish the BNG work

Countryside support the inclusion of a policy to secure measurable biodiversity net gains as part of new developments. The policy should set a minimum net gain percentage target based on evidence, legislation and national guidance. Whilst a preference can be set for net gains to be delivered on-site, there should also be sufficient flexibility in the policy to allow for off-site solutions to delivered as well, to not unduly restrict development and to release the benefits that can be delivered through strategic and coordinated initiatives
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Land to the west of Cambridge Road, Melbourn presents an opportunity to deliver biodiversity net gains. The site is currently arable fields of low ecological value and the development proposals, through a landscape-led approach, will seek to deliver open space that is functional whilst also creating resilient habitats. The proposed scheme will seek to preserve and enhance existing boundary vegetation where practical to do so through the development of the site. In addition, the walking route to be delivered will incorporate habitat creation, in the form of field margins, meadow grassland and woodland copses which will provide important habitat for a range of wildlife and plant species.

An indicative biodiversity net gain assessment has been undertaken taking into account the proposed development highlighted within the ‘Framework Plan’ which has concluded that the development can deliver an overall gain of 10.02% for habitat units, a 11.15% gain for hedgerows/linear features and a gain of 59.10% for ‘river’ units. The development is expected to deliver more of a gain when ‘material’ enhancements are included at a more detailed design stage, such as bird and bat boxes.

The proposed walking route will also create a new recreation asset for the village and provide a walking opportunity for those that may have otherwise considered the need to travel to SSSIs for that activity, therefore protecting nearby SSSI’s from increased recreational pressure.

The Topic Paper on Biodiversity seeks to provide justification for the proposed minimum 20% biodiversity net gain requirement, above the 10% requirement in the Environment Act. The Topic Paper focusses on the benefits of a 20% requirement rather than its practical deliverability, and it acknowledges that “Given the widespread application of BNG is still emerging, there is clearly further site-specific viability testing required of alternative BNG percentage requirements”. At present, ARU cannot support a requirement in excess of the national requirement of 10%.

Support

The proposed requirement for 20% biodiversity net gain compares with the recently passed Environment Act 2021 which requires 10% BNG. Whilst we support the concept of creating BNG on development sites, it is important that viability is carefully considered. We are concerned that off-site mitigation is likely to be required to achieve 20% BNG on many sites, resulting in considerably higher costs for developers. This could negatively impact on the viability and deliverability of sites. In addition, in some cases there would be an impact on land-take, reducing the developable area of the site and potentially the quantum of development.

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 acknowledge the importance of delivering bio-diversity net gain as an integral part of future development. Notwithstanding this, no sound basis has been provided for the requirement for a 20% net gain in biodiversity proposed under this policy.

The Government considers a 10% net gain sufficient to mitigate the impact of new development and it should be recognised that the Environment Act does not set this as a minimum. No basis is presented therefore as to why Greater Cambridge should adopt a different approach to the other areas of the Country.

The result of requiring a 20% net gain will likely be to make some schemes unviable. Equally it will potentially reduce the number of units coming forward on sites requiring identification and delivery of further sites for development which is counter intuitive to the original objective.

Policy BG/BG: Biodiversity and Geodiversity (P168)

No sound basis has been provided for the requirement for a 20% net gain in biodiversity proposed under this policy.

The Government considers a 10% net gain sufficient to mitigate the impact of new development and it should be recognised that the Environment Act does not set this as a minimum. No basis is presented therefore as to why Greater Cambridge should adopt a different approach to the other areas of the Country.

Recommendation: It is strongly recommended that the policy is amended to require no greater then a 10% net gain in bio-diversity, as per the approach established through the Environment Act.

The University supports the policy intention to control the biodiversity impacts from development, including the principle of biodiversity net gain.

As far as our Biodiversity Action Plan (BAP) is concerned our Vision is to 'Deliver a significant and measurable improvement in the biodiversity of the University of Cambridge estate, and the Greater Cambridge Area more generally, in a manner that educates and inspires an appreciation of the natural environment, and that encourages interventions, research and innovation to enhance and protect biodiversity for future generations.'

The Environment Act 2021 will require a mandatory 10% minimum biodiversity net gain across the country. We note that at an Oxford-Cambridge Arc level, the local authorities have agreed a set of Arc Environmental Principles that include the aims of doubling the area of land managed primarily for nature, and to deliver a minimum 20% biodiversity net gain on development sites. These ambitions, together with the relatively low level of designated sites and priority habitats in Greater Cambridge, form the Councils’ justification for development to bring further net gains beyond the 10% proposed nationally. Any target will have financial and operational implications, however, which should also be considered as part of the evidence base. We therefore consider it would be appropriate for the local authorities to assess the impact of a 20% net gain target (or indeed any other target that would exceed the national 10%) on the viability of development to meet the objectively assessed needs for jobs and homes for the plan period.

CambridgePPF strongly support 20% Biodiversity Net Gain.
The overall intention of this policy direction is welcomed and supported. However, the detail of how the policy is worded to guide and enhance development will be critical and it is likely to require more than one policy to achieve this. It is, of course, appreciated that plan policies have to be developed further - some important issues are touched upon already and this is welcomed. As referred to in our general comments however, the first priority must be the protection and conservation of existing biodiversity and geodiversity interests. With this in mind we have a number of specific comments regarding the principles to underpin this objective. These should be reflected in future policies and/or supporting text in the GCLP:

• Assessment of impacts
All development affecting sites of biodiversity and geodiversity importance and interest should be subject to thorough assessment of impacts based on all relevant information and recent surveys.

• Mitigation and Compensation
The mitigation hierarchy should be followed for any development proposals. We are pleased to note that this has been referenced at section 3.5 of Topic Paper 3, i.e. ‘whereby harm should be preferably avoided, adequately mitigated, or compensated for as a last resort’. Acceptance of proposed mitigation as a way of making a development must be based on proof that it will work and should not be confused with compensation for irrevocable damage to an important site or interest. The distinction between mitigation and compensation is also important as the latter must require justification as an exception. Finally, all mitigation and compensation work should be properly secured in perpetuity if necessary. This is particularly important with regard to compensation. Compensation for permanent damage requires permanent recompense.

• Approach to harmful development
Any development that has an adverse effect (or risk of such effect applying the precautionary principle) should normally be refused. The supporting text with the current first proposals consultation indicates that exceptions will only be made where the public benefits significantly outweigh any adverse impacts. However, more clarity will be needed on how this will work in practice. Again, it is appreciated that the policy wording has still to be written. However, this is such an important issue that a clear statement of intent should be made now. If developments are proven to have an adverse effect or applying the precautionary principle, a risk of an adverse effect, then they should only be normally permitted when clear tests are applied. Arguably this should also include being satisfied that applicants have demonstrated that there are no less damaging alternatives they could pursue.

It is noted that the supporting text with respect of policy BG/BG states:
‘The policy will state that development proposals adversely affecting sites of biodiversity or geological importance will not normally be permitted. Exceptions will only be made where the public benefits significantly outweigh any adverse impacts.’

Clarification will be needed of what tests will be used to determine whether public benefits outweigh adverse impacts on important sites, because an approach solely on a case by case basis could risk a lack of consistency and consequent serious harm to biodiversity interests without sufficient justification. The level of public interest that would need to be demonstrated will also need to be commensurate with the level of interest affected. This level of test may be very high if for example, an internationally of nationally important interest is at risk.

The supporting text also goes on to say:
‘In such cases where development is permitted, we will require that the intrinsic natural features of particular interest are safeguarded or enhanced.’

Presumably the intention here is to safeguard or enhance any remaining features of interest after a damaging development is allowed.

• Biodiversity Net Gain
We strongly support a level of 20% Biodiversity Net Gain for the following reasons:
• Cambridgeshire is one of the most nature depleted counties in England, which is one of the most nature depleted countries in the world.
• Doubling nature in Cambridgeshire would only bring the county to the average for the UK.
• Cambridge Nature Network Report identified that existing habitats within 10km of Cambridge are too small and too fragmented to form a functioning ecological network. To achieve a functioning ecological network sustained effort and investment will be needed over the long term to make habitats better, bigger and more connected.
• Creating new habitats to replace those lost is not an exact science, meaning that some biodiversity offsetting will produce less biodiversity gain than expected. This variability is considered to be around 10%. Therefore a 10% BNG requirement does not guarantee that any individual development would actually achieve a net gain. Only a higher level of BNG, such as 20% has the prospect of achieving this.
• It should be noted that 20% BNG will not achieve the aspiration to double nature unless it were at 50%.
We have two additional comments at this stage. First, that biodiversity net gain must take account of the full value of an affected site including any interests that may have been deliberately damaged prior to a development occurring. Second, the use of planning conditions and obligations to secure the effective long-term management of any on or off site habitat creation referred to the policy supporting text is vitally important and is welcomed. Long term monitoring to ensure that any proposed biodiversity net gain delivers what it seeks to do is also critical. The Defra Biodiversity Metric focuses on the provision of habitat. This may be used to mitigate effects or secure enhancement for species directly affected by a development. However, to ensure that species affected will benefit from habitat provision requires careful monitoring - simply creating new habitat will not necessarily mean the species affected will use it.

We also look forward to seeing more detail on how the proposed policy will seek to secure wider environmental gains.

Cambridge Past, Present & Future welcome the recognition that “Designated biodiversity sites within and close to Greater Cambridge are being impacted by increasing numbers of visitors – an issue that needs to be addressed to protect these vulnerable habitats and the species they support. For nationally designated sites, Natural England have identified Impact Recreation Zones and recommend the application of Suitable Alternative Natural Greenspace standards to inform the quantity of green space provision required for people, to lessen the impacts on these nature sites. Greater Cambridge has relatively few nationally designated nature sites, but many locally designated sites. Ahead of the draft plan we will explore how we can best measure and mitigate the impact of development on these local sites.” In Cambridge Past, Present & Future’s 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. Our research also identified that generally, larger scale development (such as Cambourne) was 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 Suitable Alternative Natural 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.

The Commissioners note the ambitious target of development achieving a minimum 20% biodiversity net gain. Whilst supportive of ambitious targets for biodiversity, the Commissioners note that this is double the target that was identified in the recently consulted on Cambridge Biodiversity SPD and also the national target which is set by Government.

The Council should be confident that the justification and impact of such policy is fully evidenced, which includes ensuring it is fed into the Plan’s viability assessment.

TMLC notes the ambitious target of a minimum of 20% biodiversity net gain for development. TMLC is supportive of ambitious targets for biodiversity having already delivered a 46% BNG during its delivery of Trumpington Meadows and its wildlife rich 150 acre Country Park. The biodiversity-led approach at Trumpington Meadows has been recognised with the project winning the Landscape Institute’s 2021 National Award for Excellent in Biodiversity Conservation and Enhancement. This highly successful strategy can be adopted at Trumpington South, delivering further significant landscape, recreational and biodiversity enhancements to this portion of the Cambridge Green Belt.

The proposed policy direction requires development to achieve a minimum 20% biodiversity net gain. It is considered that the baseline for this policy should be a minimum of 10% in accordance with Schedule 7A, Part 1 of the Environment Act 2021. The policy could be worded to strive for 20% biodiversity net gain, or require certain site allocations to provide this percentage subject to appropriate assessment that this is realistic, however it is not considered robust to set 20% as the plan-wide requirement.
Land to the East Side of Cambridge Road will provide extensive areas of open space, which will deliver amenity benefits together with biodiversity net gains in the form of habitat creation secured through a landscape strategy.

The proposed policy direction requires development to achieve a minimum 20% biodiversity net gain. It is considered that the baseline for this policy should be a minimum of 10% in accordance with Schedule 7A, Part 1 of the Environment Bill 2021. The policy could be worded to strive for 20% biodiversity net gain, or require certain site allocations to provide this percentage subject to appropriate assessment that this is realistic, however it is not considered robust to set 20% as the plan-wide requirement.

We support the approach to control biodiversity impacts from development and to work towards minimum 20% biodiversity net gain. We support the recognition of a strategic Greater Cambridge Green Infrastructure Network to encourage biodiversity enhancement. New green space as part of the development can protect Nine Wells and link parkland at Trumpington through the site with the Gogs and Magog Downs and beyond. Campus expansion offers an exceptional opportunity for strategic biodiversity net gain and habitat implementation in line with the aims of Policy BG/BG, enabled through the extension of the Area of Major Change Boundary within Policy S/CBC.

The 20% net gain is an aspiration and should not be reflected in policy unless there is a clear evidence base. 10% is an appropriate target.
The Council needs to provide a delivery mechanism for off-site projects for smaller projects.

We strongly support the policy proposals for a minimum 20% biodiversity net gain. The statutory level at the moment is only a minimum 10%, however in the Greater Cambridgeshire area particulary, the biodiversity crisis is severe & one of the most affected areas in the country, largely due to pressure on land for development. Achieving a higher minimum 20% net gain is therefore appropriate to reverse the biodiversity loss.

Moving to a minimum of 20% biodiversity net gain is a step change. It is likely that in many cases off site contributions will need to be considered to deliver schemes at appropriate densities in the urban area. A system should be put in place for off-setting similar to that in place for the District Licencing for Protected Species. Such a scheme should be straightforward to use and make the best use of strategic resources.

We support the intention to require at least 20% net gain in biodiversity from new development. This is necessary to ensure that each development makes a significant contribution to reversing the decline in biodiversity which has occurred in Cambridgeshire and across the country in recent decades.

However, we believe that the proposed policy on protection of important habitats needs strengthening. When considering irreplaceable habitats such as ancient woodland and ancient or veteran trees, it is not sufficient to say that development will be allowed if the need for it significantly outweighs the biodiversity benefit of retaining it. In 2019, the wording on ancient woodland protection in the NPPF was significantly strengthened to say that loss should only be permitted in "wholly exceptional" circumstances (para 175c). So the wording in your plan needs to be at least as strong as that in the NPPF.

St John’s College has provided general support for ambitious targets in the Local Plan and made that clear in its responses to other sections of the Plan. From experience of recent proposals, biodiversity net gain is an area where it is particular important that requirements are demonstrably deliverable in Greater Cambridge. The Topic Paper on Biodiversity seeks to provide justification for the proposed minimum 20% biodiversity net gain requirement, above the 10% requirement in the Environment Act. That 10% is in itself a transformational change. The Topic Paper focusses on the benefits of a 20% requirement rather than its practical deliverability, and it acknowledges that “Given the widespread application of BNG is still emerging, there is clearly further site-specific viability testing required of alternative BNG percentage requirements”. At present, the College cannot support a requirement in excess of 10%.

Further evidence is required as to how the Councils’ have assessed the costs and impacts of their proposed approach particularly as the requirement for 20% BNG will reduce gross development value and in some cases impact on site viability and deliverability.

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.

The need for biodiversity net gain (BNG) is supported but we have concerns that the proposed 20% net gain requirement has not been fully tested in the Council’s development viability appraisal. The First Proposals Viability Report assumes separate costs for greenfield and brownfield developments that will deliver 20% BNG on site. However, there will be several sites that cannot achieve this level of net gain on site and will require higher cost assumptions for off-site delivery. It is also not clear how the report has costed off-site delivery S106 contributions.

Cambourne Town Council considers the section will achieve the aim of the plan and these should be supported. The importance of the existing green space and biodiversity in Cambourne should be stressed especially as Cambourne is a part of the Western gateway multifunctional green infrastructure corridor.

The National Trust strongly supports the requirement for development to achieve a minimum 20% biodiversity net gain. It is important that this policy is robust.

We also support the requirement for development to mitigate evidenced recreational impacts on designated sites. It must be ensured that the Local Plan evidence assesses the impacts of increased recreational pressure arising from the housing growth on designated sites, including those which fall outside of the Local Plan boundary, including Wicken Fen (Ramsar, SAC, SSSI).

The Combined Authority has an ambition to double the amount of rich wildlife areas and natural greenspace. It has endorsed a set of Environmental Principles for the OxCam Arc that has an ambition for 20% Biodiversity Net Gain. It therefore supports the local aspiration to achieve 20% Net Gain.

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
9
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.

Introduction
Thank you for consulting Central Bedfordshire Council (CBC) on the first proposals consultation for the Greater Cambridge Local Plan 2041. Please accept this letter as our formal response. We welcome the opportunity to respond to the proposals in this consultation and look forward to continuing the good working relations that CBC has already forged with the two substantive authorities. We have provided some comments below on the consultation documentation which we hope are useful. Please do not hesitate to contact us if you have any further questions.

General Comments on Strategy

Overall, the Council supports the approach you have taken in terms of undertaking a joint local plan to ensure a consistent approach to planning and building across both Cambridge City Council and South Cambridgeshire District Council up to 2041.

We support the proposed Vision for the Greater Cambridge Plan especially as it places climate impacts at the heart of key decisions. It states that Greater Cambridge will be a place where a big decrease in your climate impacts comes with a big increase in the quality of everyday life for all your communities. It also promotes new development minimising carbon emissions and reliance on the private car; creating thriving neighbourhoods with the variety of jobs and homes you need; increasing nature, wildlife and green spaces; and safeguarding your unique heritage and landscapes. CBC considers this to be a laudable, succinct overarching Vision that we hope you will be able to carry through to effective policy and decision-making on the ground.

CBC considers that the proposed strategy outlined within the First Proposals could help ensure that Greater Cambridge makes a valuable contribution to the Oxford to Cambridge Arc and to the overall delivery of the Government’s ambitious growth aspirations. However, the Council considers that it would be useful to include reference to the emerging Arc Spatial Framework, identifying that alongside the NPPF, this will set the overarching strategic framework for the area with which all local plans within the Arc must accord. CBC would be keen to understand the timescales for the delivery of the Greater Cambridge Plan and how the emerging Spatial Framework will be taken into consideration to inform future iterations of the plan.

We appreciate that the Plan is at an early stage of development, and at the current time you are considering locations that could be delivered alongside allocated sites being carried forward from the adopted 2018 Local Plans for Cambridge and South Cambridgeshire, as well as sites which already have planning permission.

We note that you are proposing to meet in full your objectively assessed needs of 44,400 new homes to 2041, which is supported by CBC and is necessary to ensure needs can be met across the area.

CBC recognises that Cambridge has seen significant economic and jobs growth in recent years and that there is an ambition to maintain this direction of growth as the impacts of the recent pandemic subside. As stated in our comments made in response to your Issues and Options Consultation in February 2020, we would not support a level of jobs growth that could detrimentally impact upon the ability of neighbouring authorities, such as Central Bedfordshire, to meet and deliver their own economic ambitions and growth aspirations. CBC therefore supports the housing numbers proposed to meet the OAN and the identified buffer and welcomes the move away from the higher job number which were put forward in your Issues and Options consultation. We agree that the higher jobs forecast previously considered would not be the most appropriate scenario to pursue. Overall, CBC considers that the proposed level of housing of 44,400 new homes and complementary economic growth of 58,500 new jobs across all sectors including business, retail, leisure, education and healthcare, is an appropriate level of growth to deliver for over the plan period.

The First Proposals have suggested 19 new possible locations that might be suitable for additional development to meet your needs across the Greater Cambridge area up to 2041. Overall, CBC supports the proposed approach taken to the geographical spread of these sites and welcomes the inclusion of sites in the most sustainable locations around the Cambridge urban area and on the outskirts of the City, where existing and future residents can take most advantage of the proximity to jobs and services using public transport and active travel options. The proposals to direct development to where it has the least climate impact, where active and public transport is the natural choice is logical and fully supported.

It is noted that the consultation material suggests that the majority of your objectively assessed need can be provided for in the core preferred strategic sites of North East Cambridge, Cambridge East and Cambourne. This approach is supported as the locations will reduce potential climate impacts through the delivery of well connected, sustainable, compact development where active and sustainable travel can be maximised.

CBC have not provided detailed comments on all of the proposed 19 sites included within the consultation material but note the proposals for new strategic scale development at Cambourne which lies in close proximity to Central Bedfordshire. It is noted that in total, there are 3 development sites proposed for Cambourne - two of these are existing allocations; Cambourne West which has capacity for 2,590 units and Bourn Airfield which has capacity for 2,460 units, alongside a new proposed broad location for growth at Camborne - expected to deliver 1,950 homes.

CBC recognises that whilst a final decision has not yet been announced, the preferred East West Rail route between Bedford and Cambridge will likely result in a new stopping station at Cambourne and that this will transform the area, maximising sustainable opportunities for growth. Whilst we support the opportunities that the proposed new station would potentially bring, CBC would suggest that any future transport impact assessments and traffic modelling associated with the proposals should consider the cumulative impacts of both existing and proposed development at Cambourne and any implications for the wider area, including potential impact upon the strategic and local road network within Central Bedfordshire. It is likely that there will be cumulative impacts from growth at Cambourne on communities within CBC related to an increase in demand on the A1, particularly if / when the A428 dualling and Black Cat works are carried out, and also the more minor roads through areas like Potton, Sandy, Biggleswade. Whilst outside of the Greater Cambridge plan area, the capacity of the A1 in this area is already a key concern that affects a much wider area and must be considered carefully and comprehensively when decisions are being made in relation to future growth.

We would, therefore, welcome further engagement to understand the scale of those impacts and their likely implications for Central Bedfordshire communities as the work on the local plan and the sites themselves, progresses. We would welcome being involved in early engagement with National Highways in relation to these impacts. We would also be keen to look at opportunities to secure sustainable links (via public transport) between CBC and the development areas to the west and south of the Greater Cambridgeshire area.

As noted above, whilst a formal decision is yet to be announced in relation to EWR between Bedford and Cambridge, or indeed the location of a new stopping station at either Tempsford or to the south of St Neots, CBC consider it essential that the Greater Cambridge Plan considers the wider context of strategic growth within the Arc, particularly in terms of future connectivity opportunities that will undoubtedly arise as proposals within neighbouring authority areas emerge. Your approach to enabling some development within smaller villages is supported as this will support rural services and the vitality and viability of villages and their shops and services contributing to overall sustainability. We appreciate that it is unsustainable to encourage high levels of growth where car travel predominates and that therefore, in smaller villages you will continue to support infill development and affordable housing on suitable sites only. This approach is supported, especially given the very rural nature of the areas close to the Central Bedfordshire border.

The 7 Themes
We welcome the approach taken in this consultation to identify 7 key themes and we have provided some high-level comments on each of them below. It is understood that each of the themes will influence how you will plan homes, jobs and infrastructure and ultimately where growth will be directed. In our previous response to the Issues and Options stage of consultation (February 2020) we suggested that “connectivity” both within and beyond the Greater Cambridge area should perhaps be considered as an additional theme. Whilst we note this suggestion has not been taken onboard, CBC considers that connectivity is the ‘golden thread’ that runs through all the key themes and could potentially be referenced as such within the Greater Cambridge Plan.

Climate Change
We support your aim to help Greater Cambridge to transition to net zero carbon by 2050 through a number of comprehensive measures including ensuring that development is sited in places that help to limit carbon emissions, is designed to the highest achievable standards for energy and water use and is resilient to current and future climate risks. It is clear that responding to climate change has influenced the shape of the plan as an important factor in determining where future development should be located and how it should be built. CBC would be keen to have future conversations to share experiences and to understand how net zero carbon can be achieved in terms of viability, and to explore how this can be monitored to ensure the approach is successful. In terms of detailed policy, Policy GP/QD could benefit by also referring to building orientation to maximise the opportunities for renewables.

Biodiversity and Green Spaces
We support your aim for biodiversity and green space policies to increase and improve your extensive network of habitats for wildlife and green spaces for people, ensuring that development leaves the natural environment better than it was before. We also welcome confirmation that the Oxford to Cambridge Arc Environmental Principles have informed your approach to this theme, in particular, we welcome and support the ambitious policy to require 20% Biodiversity Net Gain. As this will be an issue for all Local Authorities within the Arc, CBC would also be keen to discuss how this could be delivered and the impacts this might have not only on site viability, but
the delivery of other key services and facilities across the Arc .

Wellbeing and Social Inclusion
We support your aim of helping people in Greater Cambridge to lead healthier and happier lives ensuring everyone benefits from the development of new homes and jobs.

Great Places
We support your aim for the delivery of great places through policies that sustain the unique character of Cambridge and South Cambridgeshire and compliment the area with beautiful and distinctive new development, creating a place where people will want to live, work and play.
The themes from the Cambridgeshire Quality Charter for Growth covering the four “Cs” of Community, Connectivity, Climate and Character is a sensible approach consistent with the National Model Design Code.

Jobs
CBC supports the aim of your proposed jobs policies in terms of encouraging a flourishing and mixed economy which includes a wide range of jobs while maintaining the areas global reputation for innovation. The Council considers the policies are positive and forward thinking in the current climate in that they seek to reflect how the approach to working environments is changing, by supporting remote working and improving facilities on employment parks.
We support the inclusion of a remote working policy but consider that it could be strengthened to refer to the provision of home office space in new dwellings as the emphasis is currently on the delivery of external hubs or extensions of existing dwellings.

Homes
As commented above, the Council supports the proposed strategy to plan for and deliver enough housing to meet your objectively assessed needs, including significant amounts of affordable housing and a mix of tenures to suit your diverse community’s needs. The proposed policy requiring 40% affordable housing in new developments is particularly supported.

Infrastructure
We support the approach taken that the relationship between jobs and homes and sustainable transport opportunities has been a key consideration and influence of the development strategy proposed. Recognising that infrastructure is not limited to the provision of new roads, CBC also supports the recognition for the need to consider and plan for water, energy and digital networks, and health and education and cultural facilities in the right places and at the right times to ensure your growing communities are supported. Looking to the future, your policies on electric vehicle charging points and digital infrastructure will be key given the need to move away from carbon-based vehicle fuels and the shift to homeworking that has been accelerated by the pandemic. We also note that whilst there is an objective for Air Quality within the Sustainability Appraisal, there is no objective included for Transport and Access.

We welcome this opportunity to comment on this latest stage of your development plan proposals and largely offer our support to the approach you have taken. We also appreciate how you have digitally presented and structured the documentation in order to make it as accessible as possible to everyone. The use of maps and diagrams throughout the document is an effective way of setting out the context and portraying the information within the text. In addition, the ability to explore the documentation through the “themes” and “maps” is a particularly helpful way of organising the consultation.
I hope you find these comments useful and look forward to continued engagement as your plan progresses.