Draft Greater Cambridge Local Plan for consultation

The RSPB supports the premise of this policy. Changes in land-management and land-use can contribute significantly to flooding issues downstream, which can have implications for biodiversity and nature as well as communities. The Ouse Washes SPA/SAC has suffered increased intensity and frequency of nuisance flooding in recent decades, much of which has been driven by land use and land management change in the upstream catchment. Implementation of this policy should ensure these issues (along with those affecting sites on the Cam) are not exacerbated further.

The RSPB supports this policy. Retention and preservation of peat soils is a fundamental part of nature based solutions to climate change, and development should in the first instance aim to retain peat soils in place and maintain their integrity. If soils need to be disturbed or removed they need to be stored properly and re-used appropriately, preferably on a site where water levels will retain the carbon content in the soil, for example in created wetland habitat.

The RSPB supports the premise of this policy. In particular we support the strategic GI initiatives listed which includes the Great Ouse Fenland Arc which contains the RSPB's Fen Drayton Lakes Reserve, located on the St Ives guided busway, which has the potential to provide more GI potential north of Cambridge. We also support and are part of, the aspirations of the Cambridge Nature Network, whose areas are included in these strategic GI initiatives. However, it is unclear at present how the councils will deliver this strategic GI - and they are not allocated outside of the broad areas identified in the Green Infrastructure Opportunity Mapping, and we look forward to the Councils developing this further in the proposed submission stage. We would support the Wildlife Trust's suggestion that all new development above an appropriate threshold should contribute toward strategic GI provision, so ensuring that GI provision keeps up with development as a whole in the plan area.

The RSPB supports the premise of this policy, and in particular the requirement to preserve and protect existing trees and hedgerows where possible. Regarding buffer zones, we question whether a 15m buffer for ancient woodlands is appropriate. Although this may direct root damage, this buffer does not take any account of the potential for light and noise pollution from development, or the impacts of domestic animal disturbance and predation on the likes of ground nesting birds in our woodlands. In our view a 500m buffer would be more appropriate taking these impact pathways into account.

RSPB supports this policy. Rivers and streams and their associated riparian habitats provide important wildlife corridors within the Greater Cambridge area. In particular we are pleased to see Point 1c on the restoration of river, floodplains and riparian habitats and Point 2 on the provision of riparian buffer zones. As well as supporting the restoration and conservation of associated habitats, these measures also have an important part to play in natural flood management, reducing and slowing the flow of water into our rivers and streams with knock-on impacts downstream.

The RSPB supports point 3 regarding the consideration of impact upon Priority Spp and Habitats of development on agricultural land. Reference should also be made in the supporting text to the Local Nature Recovery Strategy and local habitat map.

The RSPB objects to this allocation as currently mapped. Although we understand this is an allocation carried over from the previous local plan, it has come to our attention that the policy as mapped includes an area of the Fen Drayton Lakes RSPB Reserve and Fen Drayton Gravel Pits County Wildlife Site. This area in and around Springhill Lagoon is an integral part of the Reserve and designated site and so is not an appropriate location for infill development, nor will the RSPB be selling it. We ask the council to amend the allocation to remove the area indicated in the attached map.

We note the adopted SPD on the allocation contains requirements to control surface runoff from any development. This is particularly important for any new development along Springhill road, so that the possibility of surface water pollution to the lagoon is avoided.

The RSPB supports the premise of this policy. In particular we support the obligation on major development to provide 20% BNG, which most likely the single biggest benefit the local plan makes for nature in Greater Cambridge, and is a key policy to help implement the Cambridgeshire Doubling Nature Vision.

We are pleased to see application of the mitigation hierarchy in the wording and the need for SANGS to reduce the potential of recreational disturbance to sites. However, we believe that the wording as current does not adequately take into account the strict tests that apply to development that might affect a European Site - which in the Greater Cambridge context means the Eversden and Wimpole Woods SAC, but also potentially other sites outside the planning authority's boundaries such as Portholme SAC and the Ouse Washes SPA/SAC.

The Habitats Regulations impose a strict negative test that permission can only be granted if it can be concluded that there will be no adverse effect on the site's conservation objectives. Derogations are only permitted where there are no alternative solutions, imperative reasons of overriding public interest and only then through provision of compensation. As such these tests are at a significantly higher level than would be applied to nationally or locally designated sites, and this needs to be made clearer in both the policy text and the supporting information.

The RSPB has significant concerns about Policy S/CBN North Cambourne.
 
We acknowledge the significant transport sustainability benefits of having a significant new town in this location. However, we are concerned that the allocation abuts our RSPB Hope Farm land-holding, which is mostly contained within the identified Strategic Enhancement Area for the allocation.
 
RSPB Hope Farm is a nationally-significant demonstration farm of 25 years standing which demonstrates nature-friendly and regenerative farming methods. Long-term monitoring has shown a 160% increase in breeding farmland birds, a 1300% increase in wintering bird populations using the farm and a 400% increase in butterfly abundance over that period. We are concerned that any allocation policy ensures that the farm continues to be a viable proposition long-term.
 
As such, through the masterplanning process the RSPB will want to ensure that:
The approach to securing the objectives of the Strategic Enhancement Area (SEA) (in terms of land ownership/ tenure and any legal management agreements) ensure the RSPB's ability to manage the farm as we see fit into the future and continue the invaluable long-term monitoring of nature on the site. 
Green Infrastructure within the allocation buffers our Hope Farm holding, so reducing impacts of disturbance and supporting the species using the farm.
Design manages recreational access from the allocation, restricting this to existing public footpaths, so minimising recreational disturbance.
Land-use and land-management in the surrounding parts of the SEA complement and buffer wildlife populations on the farm. That there is an appropriate mix of land uses and habitat creation within the SEA.
 
We would welcome additions to the supporting information to ensure these considerations are an expected part of the design process. We support the wording in the supporting information regarding the protection of turtle doves and their habitats within the SEA.
 
Regarding the ancient woodland sites subsumed by and in proximity to the proposed allocation:
We welcome restrictions on access and provision of SANGS to ensure no adverse recreational impact on these sites. However, careful consideration will need to be given within the design process to ensure that these measures work effectively.
Significant work will need to be undertaken to assess likely impact pathways affecting the special interests of these woodlands. Precautionary buffers may need to be built into the masterplan removing any built development an appropriate distance away from site boundaries.
The potential presence of Barbastelle bat roosts within these woodlands is a significant risk to the allocation as currently mapped. If present, this will mean that these sites are functionally linked to the Eversden and Wimpole Woods SAC, and a Habitats Regulation Assessment will need to be undertaken to show no adverse effect on the Conservation Objectives of this European Site. As well as suitable buffer zones, connectivity within the landscape would likely be an important consideration, that might necessitate wildlife corridors connecting through the southern part of the allocation with safe routes over the A428 and East/West Rail corridors.
As above, we would expect the masterplanning process to enhance the habitat connectivity of these ancient woodlands to the wider countryside through the Strategic Enhancement Area.
 
We believe the potential need to meet the strict requirements of a HRA should be included as a consideration in the policy wording on Nature.