Greater Cambridge Local Plan Preferred Options

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Comment

Greater Cambridge Local Plan Preferred Options

CC/WE: Water efficiency in new developments

Representation ID: 59018

Received: 13/12/2021

Respondent: Royal Society for the Protection of Birds (RSPB)

Representation Summary:

The RSPB supports the principles outlined for this policy. Public water supply is a key environmental limiting factor in Greater Cambridge and it is imperative that new development enables much lower per capita consumption rates. As such we agree that ambitious requirements are justified.

Full text:

The RSPB supports the principles outlined for this policy. Public water supply is a key environmental limiting factor in Greater Cambridge and it is imperative that new development enables much lower per capita consumption rates. As such we agree that ambitious requirements are justified.

Comment

Greater Cambridge Local Plan Preferred Options

CC/DC: Designing for a changing climate

Representation ID: 59029

Received: 13/12/2021

Respondent: Royal Society for the Protection of Birds (RSPB)

Representation Summary:

Climate and Nature friendly design is key in all new development, and as well as policy direction, detailed guidance will be necessary.

Full text:

RSPB welcomes these policy principles. Use of green roofs, SuDS, street trees etc.. will help make new urban environments suitable for a changing climate whilst also contributing to biodiversity goals within the Greater Cambridge area. Although this also relates to CC/NZ, we would also draw your attention to the use of green walls to help regulate building temperature and provide insulation.

Although not necessarily relevant to high-level policy wording, we would expect GC to develop guidance on design – eg: use of biodiverse and/or biosolar roofs (not sedum), the need for SuDS source control, the necessity for biodiverse planting schemes and trees suitable to the climate conditions we expect etc…

Comment

Greater Cambridge Local Plan Preferred Options

CC/FM: Flooding and integrated water management

Representation ID: 59031

Received: 13/12/2021

Respondent: Royal Society for the Protection of Birds (RSPB)

Representation Summary:

The RSPB supports the principles set out for this policy, particularly with reference to source control. Our experience is that this is often an element which is not implemented well due to supposed practical constraints which are not necessarily justified. We believe that Greater Cambridge have an opportunity to push the boundaries to make this a standard practice in new development. We suggest that references to green roofs should be changed to biodiverse and/or biosolar (to preclude the use of sedum roofs which have limited utility). Where use of permeable surfaces is not practicable, source control should again be implemented.

Full text:

The RSPB supports the principles set out for this policy, particularly with reference to source control. Our experience is that this is often an element which is not implemented well due to supposed practical constraints which are not necessarily justified. We believe that Greater Cambridge have an opportunity to push the boundaries to make this a standard practice in new development. We suggest that references to green roofs should be changed to biodiverse and/or biosolar (to preclude the use of sedum roofs which have limited utility). Where use of permeable surfaces is not practicable, source control should again be implemented.

Comment

Greater Cambridge Local Plan Preferred Options

CC/RE: Renewable energy projects and infrastructure

Representation ID: 59036

Received: 13/12/2021

Respondent: Royal Society for the Protection of Birds (RSPB)

Representation Summary:

Renewable energy projects need to be located appropriately and impacts on biodiversity minimised.

Full text:

RSPB supports the principles set out. Renewable energy provision in Greater Cambridge will provide an important contribution towards net carbon neutral targets. However, as with all infrastructure development, it can, and does have negative impacts on biodiversity if located in the wrong place or implemented insensitively to the environment present (eg: presence of priority spp populations and/or priority habitats). Therefore, we also support the provision of biodiversity impact criteria specific to renewable projects. As we mentioned in our previous consultation response, RSPB’s report Energy Futures has mapped how the UK can meet very high renewable energy provision whilst safeguarding nature and we would be pleased to discuss with the Greater Cambridge Councils how our Energy Vision peer-reviewed mapping methodology could be used to help identify suitable sites for renewable and low carbon energy.

Comment

Greater Cambridge Local Plan Preferred Options

CC/CE: Reducing waste and supporting the circular economy

Representation ID: 59037

Received: 13/12/2021

Respondent: Royal Society for the Protection of Birds (RSPB)

Representation Summary:

RSPB supports the policy principles set out, which are an important element of reducing the embodied carbon of new development and the efficient usage/re-use of limited resources.

Full text:

RSPB supports the policy principles set out, which are an important element of reducing the embodied carbon of new development and the efficient usage/re-use of limited resources.

Comment

Greater Cambridge Local Plan Preferred Options

CC/CS: Supporting land-based carbon sequestration

Representation ID: 59039

Received: 13/12/2021

Respondent: Royal Society for the Protection of Birds (RSPB)

Representation Summary:

Nature-based solutions have an important role to play in reducing carbon emissions. This includes creation of wetland habitats.

Full text:

RSPB supports the policy principles set out. Peat soils where they occur in Greater Cambridge are a significant potential source of carbon emissions when managed inappropriately. Where biodiversity net gain or green infrastructure provision associated with development can bring peat soils under suitable wetland habitats, this can have very significant benefits for both carbon emissions and biodiversity.

For example, studies have shown that CO2 emissions from cultivated peatland soils can reach c39 tonnes per hectare per year. Restoring this land to lowland wet grassland could reduce emissions by between 27 to 33 tonnes per ha per year, whereas restoration to swamp fen could reduce emissions by 33 to 40 tonnes per ha per year (with the potential for land to in effect become a carbon sink).

Comment

Greater Cambridge Local Plan Preferred Options

Biodiversity and green spaces

Representation ID: 59042

Received: 13/12/2021

Respondent: Royal Society for the Protection of Birds (RSPB)

Representation Summary:

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.

Full text:

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.

Comment

Greater Cambridge Local Plan Preferred Options

BG/BG: Biodiversity and geodiversity

Representation ID: 59047

Received: 13/12/2021

Respondent: Royal Society for the Protection of Birds (RSPB)

Representation Summary:

Support 20% BNG target. Strategic provision needs to align with upcoming LNRS and not just GI strategic objectives.

Full text:

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.

Comment

Greater Cambridge Local Plan Preferred Options

BG/GI: Green infrastructure

Representation ID: 59054

Received: 13/12/2021

Respondent: Royal Society for the Protection of Birds (RSPB)

Representation Summary:

Support approach and need for clear requirements for new development to support GI infrastructure provision. Accessibility and locational relationship of development to GI strategic areas should be a key consideration.

Full text:

The RSPB support this policy direction, and we are pleased to see that our Ouse Valley reserves, where we have significant green infrastructure ambitions, are included in the ‘Great Ouse Fenland Arc’ priority area. As a potential GI provider, we have struggled to gain contributions from developments in the past, notably from the first phases of Northstowe which is in close proximity to and connected by public transport to our Fen Drayton Lakes site. We will therefore be very keen to ensure there are clear requirements and standards set out in this policy which will enable new development to make a significant contribution to the Greater Cambridge strategic GI initiatives.

We feel that there is an obvious connection between provision of strategic GI and its proximity and transport connectivity to new development, and we believe this should influence which initiatives are supported by a particular development (as an example, various development sites will be in proximity to our Fen Drayton Lakes site, or directly connected via the guided busway). We would therefore like to see policy wording which makes this connection.

We fully support that GI contributions should go towards the establishment, enhancement and on-going management costs, as this latter requirement is often overlooked.

Comment

Greater Cambridge Local Plan Preferred Options

BG/TC: Improving Tree Canopy Cover and the Tree Population

Representation ID: 59057

Received: 13/12/2021

Respondent: Royal Society for the Protection of Birds (RSPB)

Representation Summary:

Right tree in the right place.

Full text:

The RSPB support the policy direction outlined and we agree with a policy that supports additional tree planting and canopy cover in developments without setting particular targets (as appropriate provision will vary depending on the site). We believe that the policy will need to require developers to assess suitability of planting to ensure we achieve the right tree in the right place – so for example to preclude planting on inappropriate soils (ie: peat) and/or planting of species that may not be suited to the changed climate envelope when they mature. There are also obvious links and benefits here to achieving biodiversity policy gains by planting native species as a preference.

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