Policy 5: Biodiversity and Net Gain

Object

Representation ID: 51860

Received: 01/08/2020

Respondent: Mr Derek Prater

Only to target a 10% gain in biodiversity lack ambition to radically improve the environment and restore Biodiversity

Support

Representation ID: 51968

Received: 09/08/2020

Respondent: Pam & Mal Schofield

No tokenism. Cambridge has the space & the social commitment.This development has to be the exemplar. It makes good sense - proximity to the City where as intended Bourn Airfield is simply Cambourne East & a meaningless addition to the uninspiring housing development of the 1930's
Care has to be taken to allow for future changes.

Comment

Representation ID: 52961

Received: 28/09/2020

Respondent: Miss Isobel Connolly

BREEAM water credits have been targeted but not for this biodiversity section. The BREEAM land use and ecology section particularly LE04 Ecological change and enhancement could be considered too for this section

Object

Representation ID: 53243

Received: 01/10/2020

Respondent: Mr Jon Pavey

A minimum of 10% net gain in biodiversity value shows little ambition. Especially so as the Natural England biodiversity offsetting metric version 2.0 that will be used to calculate requirements can, according to some ecologists, be "gamed" to give the desired result. Moreover, as a measure of professional judgement is required, there are accounts that the biodiversity value computed by different assessors have differed by as much as 5%.
Obviously one expects the Councils will seek to ensure all assessments are robust and would withstand informed scrutiny: setting a higher net gain target would go some way to offset the risk of failing in practice to meet the national target requirement.
The Policy should specifically refer to seeking to bring biodiversity into the built environment with particular regard to connecting people with the environment to improve health, wellbeing as well as foster recovery of biodiversity - the Government's 25 Year Environment Plan (2018) should provide a cornerstone for the NECAAP.
Landscaping within the built up areas should in many areas be designed to support biodiversity and be complemented by features on buildings - for example locations that house sparrows can both nest (on buildings) and to spend their days nearby (eg in privet bushes). Similarly, the policy could be more adventurous by requiring facades to incorporate swift bricks and like provision for other species that might be drawn into the urban environment.
If Barn Swallows can nest on buildings in the middle of Hong Kong, surely they might be enticed to do similarly along a frontage facing the River Cam. Similarly, there is an excellent colony of House Martins on the Addenbrookes Hospital buildings; surely there is opportunity for provision of nesting sites for these at NECAAP. The Policy needs to include objectives which would ensure such biodiversity provision is readily and easily provided.

Comment

Representation ID: 53393

Received: 03/10/2020

Respondent: Mr Jonathan Heath

Access to nature in the north Cambridge area is already fairly limited. Both Milton Country Park and Ditton Meadows/Stourbridge Common do provide open accessible areas where locals can access nature. However both areas are experiencing increasing visitors and general footfall, reaching near capacity. Green areas at Science Park and Bramblefields are also under pressure from surrounding development. Nature in the area is increasingly under pressure.

The recent lockdown has shown that access to nature and green spaces is very important to people. The North East Cambridge plan is rightly trying to reduce car journeys for residents and this will mean more green spaces will need to be accessible by foot. I believe the plan needs to be more ambitious to include more green space and to target a greater than 10% biodiversity gain.

Developments in south Cambridge (Great Kneighton and Trumpington Meadows) have been very successful in incorporating green spaces into their developments. The latter collaborated with the Cambs Wildlife Trust to design wildlife meadows around the site, which has been very successful (this year the rare Small Blue Butterfly has been found breeding on site). Will local conservation bodies be consulted in the North East Cambridge development?

I know space is lacking at this development site and agree housing is a priority. However, the surrounding land at Milton CP and particularly Chesterton Fen could be significantly improved to benefit nature, as well as providing further access to green space for local residents. Certainly there is the potential to design ponds and include long grasses and wildflowers on this land (similar to what has been created at Great Kneighton and Trumpington Meadows), which will greatly benefit local nature and mitigate the negative effects towards biodiversity from the development.

Comment

Representation ID: 53413

Received: 03/10/2020

Respondent: Fen Ditton Village Society

Can biodiversity net gain be achieved after loss of biodiversity at the new WWTP site?
How will Cowley Road Hedgerow be protected during the WWTP decommissioning and decontamination?
The biodiversity net gain (or loss) metric will only be identified once the mitigation measure has been implemented; this will be too late.
To instigate the Biodiversity Checklist, will an Environment Impact Assessment be part of every individual Planning Application for individual parts of each “Centre”?

Object

Representation ID: 53469

Received: 03/10/2020

Respondent: Mrs Laurie Woolfenden

Can biodiversity net gain be achieved after loss of biodiversity at the new WWTP site?
How will Cowley Road Hedgerow be protected during the WWTP decommissioning and decontamination?
The biodiversity net gain (or loss) metric will only be identified once the mitigation measure has been implemented; this will be too late.
To instigate the Biodiversity Checklist, will an Environment Impact Assessment be part of every individual Planning Application for individual parts of each “Centre”?

Support

Representation ID: 53721

Received: 04/10/2020

Respondent: Ms Clara Todd

This is not part of the topic of "biodiversity and net gain" but related to access for the development of Chesterton Fen, which is I am wondering how it may affect the folk up Fen Road, either way, mainly mobile homes, who are among the most marginalised communities of Cambridge (GRT landlords, very poor tenants).

Chesterton Fen is outside of the North Cambridge development plan area. I've never been up to Chesterton Fen, and this is the only access by road up Fen Road (which is single track, mud and ford at one stage. Yet there is a cycle track from the north cambridge plan, presumably the space will be developed more as a park? How?

Object

Representation ID: 54021

Received: 04/10/2020

Respondent: Mrs Tamsin Beevor

The policy fails to provide any wildlife corridor linking the Science Park area to the north west of Milton Road with the wider area. The high cost relative to a moderate gain should not be an adequate reason for dismissing the options for developing 2 green crossings of Milton Road.
10% biodiversity gain in a brown filed site lacks ambition and at a time when we are recognising the ecological as well as climate emergency this is inadequate . If this limited target is only achievable by offsite enhancements then this indicates that the proposed development is too dense for the site.
It is unclear what the management plan for a LNR on Chesterton Fen would be. This must be adequately funded in the long term and not left to chance and the good will of the local community.

Support

Representation ID: 55668

Received: 02/10/2020

Respondent: St John's College

Agent: Savills

The proposal to require the national recognised standard of net gain as a minimum rather than a higher requirement is supported. The supporting text, which states that the policy has been prepared to ensure that an appropriate balance can be achieved between meeting national biodiversity requirements, working towards the Councils’ commitments in tackling biodiversity and ecological emergencies and the challenges of exceeding this within a higher density context is endorsed. The proposed mitigation hierarchy – on-site, then adjacent to NEC and then across the city and further afield – is also logical.

Object

Representation ID: 55710

Received: 03/10/2020

Respondent: Fulbourn Swifts Group

Currently the focus of Policy 5, ‘Biodiversity and Net Gain’ is understandably on green habitats away from new dwellings and on using the metric for measuring net gain. However, there is no specific reference to nest box provision in line with National Planning Guidance, although this could be covered within the very general statement:

‘Within North East Cambridge, development proposals shall take all practicable opportunities to enhance the area’s nature conservation value and ensure that site users have access to healthy, biodiverse green spaces.’

In the MKA Ecology NE Cambridge Biodiversity Assessment under Section 4.1 ‘Biodiversity Vision’ there is important content on page 25 that should not be lost with the focus on a few on site green corridors and offsite enhancement of habitat:

‘It is recognised that the higher density approach to the built environment at NEC will make the provision of widespread green space challenging. The built environment must therefore be made more permeable to nature with integrated bird and bat boxes on new structures and extensive areas of living roofs.’

Further, in this section it raises the concern that the offsite habitat enhancement should not mean that biodiversity provision is downgraded in the built environment ‘as greenspace is critical for softening the hard edges of urban areas’

Recommendations 16,19, 20 and 21 are relevant, e.g., ‘Recommendation 21: Integrated features for nesting birds should be installed at appropriate densities in appropriate locations’ page 38. For House Sparrow and Swift it is noted that these species have broadly similar requirements in terms of nesting location and the fact that both nest in colonies, and the proposal is made that a minimum of one swift brick in every building is installed at NEC to cater for both species, which is in line with current Royal Institute of British Architects (RIBA) guidance (reference 1).

Some of these aspects are highlighted in Government Guidance on the NPPF issued on 21 July 2019 (see below):
https://www.gov.uk/government/news/brokenshire-orders-house-builders-to-protect-wildlife

https://www.gov.uk/guidance/natural-environment

Paragraph 23 of this Guidance headed 'How can biodiversity net gain be achieved?' includes at the end of the first sub paragraph 'Relatively small features can often achieve important benefits for wildlife, such as incorporating 'swift bricks' and bat boxes in developments and providing safe routes for hedgehogs between different areas of habitat.'

While Swifts will travel far, if necessary, to find food, the enrichment of the habitat close to homes will attract a wider range of other birds into gardens of houses and the environment around apartments. For House Sparrows in particular hedges and shrubs for shelter are important close to potential nest sites.

Cavity nesting birds include Swifts (largely building dependent in the UK), House Sparrows and Starlings (urban birds). These species have nested for generations in older houses in holes and cavities under the eaves and in walls. However, they are in dramatic decline – Sparrows and Starlings are Red Listed and Swifts have declined by 60% in the last 25 years, so the Swift may well move from the Amber to the Red list at the next BoCC revision in 2021. According to IUCN criteria for the potential for extinction in Great Britain, the Swift is labelled as ‘Endangered’.

One big factor in the decline of all three is likely to be the loss of nesting sites through building renovation and insulation and more rigorous standards in new build homes. Further information is available in a recent article (Reference 2) reviewing the conservation status of the Swift, the growing public interest and the urgent action needed to prevent further loss by providing suitable nest sites in new developments.

Evidence is now emerging from studies being undertaken at various sites across the country that swift bricks are being used by a variety of small birds and could be described as a ‘universal’ brick for small building-dependent species. See link to a recent press release from a Duchy of Cornwall site that is in its second year of collecting data:

https://nansledan.com/nansledan-residents-asked-to-help-with-bird-box-survey/

Across the country, Swifts, House Sparrows, House Martins, Blue Tits, Great Tits, Starlings and Nuthatches have all been recorded nesting in swift bricks.

This is also very good news for developers as it means that one brick type will provide a very cost-effective ecological enhancement for a variety of bird species. These integral swift bricks are very easy to include in routine building practices with a range of sizes and finishes to suit all types of building resulting in an inexpensive biodiversity enhancement with the nesting site confined within the brick with no access to the roof space or cavity.

At least a 1:1 ratio of nest bricks per dwelling is generally accepted now as good practice – a level of provision outlined in the award-winning Exeter City Council Residential Design Guide SPD (2010). Representatives of the RSPB South West Regional Office have been working with Exeter Planners over a period of 10 years on the implementation of the biodiversity requirements of this guide and there is acceptance that in many cases the most suitable box type for all cavity nesting birds is the integral swift brick.

A similar standard was adopted by the Town and Country Planning Association and the Wildlife Trusts in 2012 (Reference 3) and by RIBA in 2013 (Reference 1).

Examples of recent Planning Authority Guidance on the level of provision include the Oxford City Council Technical Advice Note on Biodiversity (Reference 4), which gives an ‘expected provision’ of bird nest sites for building dependent birds (i.e. Swifts) at a rate of 1 per house and 1 per 2 flats, with separate provision for bats at a rate of 1 per 5 houses. Provision of such nest bricks in schools, student accommodation and hotels is addressed by a ratio of 1 per 250 m2 floor space.

https://www.oxford.gov.uk/info/20067/planning_policy/745/planning_policy_-_technical_advice_notes_tan

Local Case Studies:

There are a number of nest box schemes in new and existing developments in the Cambridge area, which have resulted in many pairs of successfully breeding Swifts and House Sparrows. For example, the Swifts Development, Fulbourn, where an estimated 100 pairs of Swifts (and in 2014, 9 pairs of House Sparrows were recorded) are nesting in 286 boxes (mainly in the integral ones), Edgecombe Flats, Cambridge – 34 pairs of Swifts and over 30 pairs of House Sparrows occupying 70 swift boxes – and Gunhild Way, Queen Edith’s – 20 pairs of Swifts occupying 50 swift boxes. As a result of nest box projects some villages around Cambridge have made an excellent start in re-establishing Swifts, for example Landbeach has seen an increase from 4 pairs to over 50 pairs, Dry Drayton from zero to 19 pairs and Elsworth from zero to 8 pairs. These schemes are proving very successful in enhancing the Swift population in the Greater Cambridge area at a time when there is a general marked decline across the United Kingdom.

We conclude that provision of integral swift bricks, at a ratio of at least 1:1 per dwelling with adjusted provision for blocks of flats, schools, community buildings and commercial premises is the modern standard to accommodate a range of cavity nesting birds in new developments.

We urge that Policy 5 should include specific wording on the provision of integral swift bricks in all buildings, at a ratio of at least 1:1 per dwelling, with adjusted provision of 1 per 2 flats and other premises, at a ratio of 1 per 250m2 floor space, as part of bringing nature closer to people.

References:

1. Gunnell, K., Murphy, B. and Williams, C., Designing for Biodiversity: A technical guide for new and existing buildings, RIBA Publishing & Bat Conservation Trust (2013).
2. Day, J., Mayer, E., Newell, R., (2019), ‘inpractice’ – Bulletin of the Chartered Institute of Ecology and Environmental Management, Issue 104 June, p.38
3. Planning for a Healthy Environment; Good Practice for Green Infrastructure and Biodiversity. The Town and Country Planning Association and The Wildlife Trusts (2012).
4. Oxford City Council Technical Advice Note: Biodiversity – Planning Application Guidance available at: https://www.oxford.gov.uk/info/20067/planning_policy/745/planning_policy_-_technical_advice_notes_tan
Submitted by a community action team including Action for Swifts (established 1995) Fulbourn Swifts Group (established 2011) and The Over and Swavesey Swift Conservation Project 2020 working for the conservation of swifts and other threatened species in the Greater Cambridge area. We are actively involved in practical swift conservation, nest brick and nest box design, planning processes, monitoring of nest brick and nest box installations in new developments, advising commercial swift nest box designers, house designers and developers both locally and nationally.

Further information is available at:

https://actionforswifts.com

https://www.scambs.gov.uk/swift-community-action-to-help-amazing-birds-in-south-cambs/

Comment

Representation ID: 55744

Received: 05/10/2020

Respondent: Brookgate

Agent: Bidwells

Neutral:
Policy 5 sets out how new development will achieve biodiversity net gain and
measurably improve the biodiversity network across the wider area. It states that
development proposals will be required to deliver a minimum of 10% net gain in
biodiversity value and shall follow the mitigation hierarchy.
Where on-site provision is not feasible, greenspace and biodiversity enhancement
will need to be provided in alternative ways and/or accommodated off-site. The
Councils are proposing a sequential approach to mitigating adverse impacts on
biodiversity resources. This is proposed to be achieved on-site in the first instance
and then in areas adjacent to North East Cambridge, such as Milton Country Park
and Chesterton Fen, before considering wider mitigation measures across the city
and further afield.
As referred to under question 7 in respect of Policy 8, the potential locations for offsite
provision are broadly supported but this should not preclude alternative off-site
locations coming forward.
Brookgate broadly support Policy 5. They acknowledge that the existing local policy
framework supports the 10% biodiversity net gain requirement even though the
legislative framework is not yet in place. The proposals for the next phases at
Cambridge North will be able to meet or exceed this target and follow the mitigation
hierarchy. Furthermore, green corridors will be designed into the Site to contribute
to the creation of a coherent on-site and off-site, high quality ecological network,
particularly along the rail corridor N/S axis. The existing vegetation along the
guided busway, the northern boundary of the Site and the narrow corridor along the
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railway fencing are the key features that the Cambridge North proposals will work
with.
On-site mitigation should however be reflective of the baseline ecological
conditions. For example, at Cambridge North where the railway sidings context has
created habitat that is unusual within the AAP area, mitigating for open mosaic
habitat (OMH) is required and this necessitates mainly brown roof planting mixed
with a small proportion of green roof.
Brookgate acknowledge the sequential approach to mitigation set out in Policy 5,
with off-site measures to form part of the mitigation strategy and the aspiration to
agree improvement projects with the Councils which could include enhancements
to Milton Country Park and/or Chesterton Fen. Given the habitats present within the
Cambridge North Site, full on-site mitigation is not practicable. However, it is
expected that the AAP developments as a whole may require the identification of
other additional/alternative sites both within the wider local area, and then other
sites elsewhere within Greater Cambridge.
Brookgate recognise the importance of improving the natural environment and
Land at Cambridge North has the potential to provide areas of high quality public
realm which recognises the very different character and functionality of public open
space around a major transport interchange and its hinterland.
The proposed residential and commercial quarters at Land at Cambridge North can
deliver a successful urban scheme where, despite public open space being limited
in terms of quantum can still deliver spaces of high quality, providing green spaces
to relax and socialise. Indeed, small intimate spaces often create the most
successful urban experiences. New areas of green infrastructure also provide
opportunities to mitigate against climate change, through creating resilient new
habitats. Strategic off-site opportunities also offer the opportunity to significantly
increase biodiversity other than providing site specific biodiversity improvements.

Support

Representation ID: 55901

Received: 02/10/2020

Respondent: GCR Camprop Nine Ltd

Agent: Carter Jonas

Policy 5 seta out the requirements for developments to achieve a net gain in biodiversity. The Ecology Report submitted in support of the proposed redevelopment of the site concluded that the proposals would deliver a net gain of approximately 130%.

Comment

Representation ID: 55955

Received: 05/10/2020

Respondent: Natural England

Natural England fully supports policy requirements for development to apply the ecological
mitigation hierarchy and for delivery of a minimum 10% measurable biodiversity net gain.

We welcome the proposal to deliver a coherent and high-quality ecological network as part of the
wider green infrastructure network including habitat and water quality improvements to The First
Public Drain, Chesterton Fen and Milton Country Park. Our advice is that the AAP requires a more
ambitious and strategic approach to biodiversity; the AAP should identify and map the existing GI /
ecological network along with viable opportunity areas to create a GI / Biodiversity Expansion and
Enhancement Framework Plan. Whilst this could include areas such as Chesterton Fen and Milton
CP it should draw on the GI and Biodiversity Opportunity Mapping Project being undertaken for the
Greater Cambridge Local Plan and the recommendations / opportunity areas identified in the
Biodiversity Assessment (MKA Ecology, June 2020). This will need to be sufficiently ambitious to
deliver mitigation measures identified through the revised HRA/SA. Policy requirements should be
set to secure delivery of the Framework through each phase of development.

The requirement for ecological assessment should address the HRA recommendation for this to
demonstrate no adverse impact to Eversden and Wimpole Woods SAC functional habitat for
barbastelle bats.

Object

Representation ID: 56016

Received: 05/10/2020

Respondent: Endurance Estates

Agent: Barton Willmore

Draft Policy 5 requires development proposals to deliver a minimum of 10% net gain in biodiversity value through a number of listed measures, of which 1 and 4 require:

1. Provision of measurable improvements in the size, quality, diversity and relationship of the site’s habitats, to deliver a coherent and high-quality ecological network as part of the wider green infrastructure network, landscape character and place making;

4. Delivery of coordinated habitat and water quality improvements to the First Public Drain, Milton Country Park and Chesterton Fen.

The above measures rely on betterment to the site’s existing habitats as well as green connections and an ecology network across the AAP area. The brownfield or open mosaic habitats present in the siding and WwTW are less common in Cambridge and are distinctive for their range of habitat and species. They also provide multiple opportunities for wildlife to thrive as reported in the NEC Biodiversity Assessment. There are also protected and notable species through NEC including water vole, roosting bats, reptile populations and notable plant and invertebrate species. These ecological features will present a high bar from which an additional 10% net gain is to be achieved. They will also present potentially significant constraints upon some development activities and a commitment in the spatial framework to their delivery.

This is currently not the case in the AAP boundary area, as it does not include Chesterton Fen, which is identified in the Biodiversity Assessment as key to providing compensatory habitat for the loss of the open mosaic habitats in the sidings and Cambridge Waste Water Treatment Plant. It is also not clear whether land ownership will be a barrier to delivering this area of compensatory habitat. Therefore, we would suggest for its inclusion and commitment in the AAP area. As stated in Policy SS/4(3) of the South Cambridgeshire Local Plan, “The final boundaries of land that the joint AAP will consider will be determined by the AAP”.

The existing biodiversity on the site, and the proposed quantum and density of urban development makes the 10% net gain in biodiversity value in Draft Policy 5 a very ambitious and potentially unachievable target. As can be seen below, the recommended biodiversity opportunities and green infrastructure networks set out in the Biodiversity Assessment appear to be tightly confined and reduced by the allocated development area within the AAP’s Spatial Framework.


NEC Biodiversity Assessment













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NECAAP Spatial Framework

















This leads us to question whether the quantum of 8,000 units and 202,900sqm of new employment, commercial and community space is too much for this site. Conversely, is the amount and size of planned off-site compensatory habitat large enough to deliver a 10% net gain across the APP when considering the policy drive to make best use of land? On a related note, we would also question whether the SA/SEA and HRA processes can be considered to be comprehensive and robust, if Milton Country Park and Chesterton Fen form an intrinsic part of the NECAAP and yet these locations are treated as being off-site.
(Maps see submission attachment)
This leads us to question whether the quantum of 8,000 units and 202,900sqm of new employment, commercial and community space is too much for this site. Conversely, is the amount and size of planned off-site compensatory habitat large enough to deliver a 10% net gain across the APP when considering the policy drive to make best use of land? On a related note, we would also question whether the SA/SEA and HRA processes can be considered to be comprehensive and robust, if Milton Country Park and Chesterton Fen form an intrinsic part of the NECAAP and yet these locations are treated as being off-site.

Comment

Representation ID: 56139

Received: 05/10/2020

Respondent: U+I PLC.

Agent: We are Town

Policy supported but long-term habitat management needs to be put in place.