Greater Cambridge Statement of Community Involvement Draft Consultation 2023

Comment

Representation ID: 200056

Received: 28/11/2023

Respondent: Gladman Developments

In general, Gladman support the approach for early and meaningful consultation with key stakeholders across Greater Cambridge. However, Gladman have one significant comment regarding the content of the SCI. Within section 5.0, at paragraph 5.5 under the heading ‘Biodiversity’, it states the that ‘The Councils will seek to require developers to deliver 20% BNG and under the scheme developers who are unable to meet BNG on site in the South Cambridgeshire area will be able to secure biodiversity off site from the Lower Farm BNG scheme in Fulbourn.’

The SCI is not the place to identify BNG intentions. BNG should be established in a planning policy within a Local Plan which is tested through examination. As part of this process, the policy requirement must be shown to be deliverable, viable and justified by a supporting evidence base demonstrating that 20% BNG would be viable. Secondly, 20% BNG is not in line with the Environment
Act 2021 as this only requires 10% BNG. The text within the SCI should be amended to reflect this. A 20% BNG requirement could potentially render schemes unviable, and while off-site credits can help to deliver the required BNG, these credits are expensive. They are deliberately so to discourage their use in the first instance, therefore seeking 20% BNG with a noted reliance on off-site credits poses significant viability concerns for developments.