Draft Greater Cambridge Local Plan for consultation

Support the Supporting Information which encourages the continuation of agricultural uses. Suggest that the wording is amended to make clear that uses such as grazing can take place onsite, around the equipment, and is not referring to adjacent land.
“Proposals that affect agricultural land are more likely to be supported where applicants demonstrate that agricultural uses, SUCH AS GRAZING, can still operate around the proposed renewable energy EQUIPMENT, ….”

Paragraph 3. Conclude with: ‘Strategy priority areas and as close to the point of damage as possible.’

Paragraph 5. We welcome the reference to ongoing management and monitoring, which are key to the success of habitat mitigation and any necessary compensation. It might help developers if the detail of this was spelt out, or referenced if contained in other documentation (eg submission and approval Habitat Management and Monitoring Plans, establishing a site baseline, setting habitat condition targets, detailing management prescriptions, including any necessary funding arrangements, and monitoring schedules, incorporating an adaptive management framework with triggers for corrective action, and assigning roles for maintenance and reporting to the Local Planning Authority).

Paragraph 6. Section needs clarification as to whether this applies if the application is subject to EIA.

Paragraph 7. Need to make clear the circumstances when benefits will outweigh adverse impacts, such as no (less harmful) alternative, wider public interest and safety.

7e and 8. The policy needs to be clear that compensation follows when there is irretrievable damage to a site that cannot be mitigated.

Supporting Information:
Paragraph 11: Text on SSSIs should refer to ‘adverse’ harm to SSSI rather than ‘significant’ harm.

Final 3 paragraphs: It would be helpful to make clearer, the circumstances when benefits will outweigh adverse impacts (eg such as there is no less harmful alternative; or public safety).

The supporting text would benefit from description of the mitigation hierarchy.

We strongly advocate for a policy framework that moves beyond mere mitigation, prioritizing a "nature-first" approach to development within Greater Cambridge.

Mitigation Hierarchy and Space for Nature
The fundamental starting point for this policy should be the strict adherence to the ecological mitigation hierarchy: first avoiding harm, then recreating and enhancing habitats.

Biodiversity Net Gain (BNG) Targets and Flexibility
CambridgePPF strongly supports the Council’s aspiration to deliver a 20% BNG target, exceeding the national mandatory minimum. However, we note that this higher threshold now runs counter to some government advice unless it is site-specific and rigorously justified. To ensure the 20% target remains deliverable and robust against appeal, we suggest a more nuanced mechanism for its application: Specifically, recognizing that meeting the BNG trading rules (delivering "like-for-like" habitats) can be practically and financially challenging, the policy could adopt a tiered approach. For example, the Council could require the first 10% BNG to follow the BNG rules, with the remaining 10% allowed a more flexible approach whereby replacement habitats don’t have to follow the strict BNG trading rules, so that replacement habitats could be of other appropriate habitat types (eg hedgerow could be replaced by scub or watercourse by a pond, etc). This would maintain a high overall gain while providing the flexibility to make it more deliverable, especially on-site, and therefore more cost effectively for developers.

BNG plus extras
In addition to Biodiversity Net Gain, biodiversity can also be enhanced by development through the provision of Green Infrastructure such as landscaping, soft edges, play areas, etc and this should also be encouraged, as an example it would not be appropriate to attribute BNG to a roadside verge on a development site, but that does not preclude the verge being planted with a nature friendly seed-mix.

Other benefits of biodiversity
It would be helpful to recognise that improving biodiversity often has other benefits, such as urban cooling, reducing run-off, capturing carbon, filtering pollution and public health and wellbeing.

Biodiversity & Water
The plan should explicitly acknowledge that the health of aquatic biodiversity in Greater Cambridge is dependent on water availability. Therefore, both the Plan and new developments must demonstrate that their water requirements—and the associated impact on local aquifers—will not detrimentally affect the very water-dependent habitats that the BNG policy seeks to protect or create.

Reconsider this policy and site allocations to increase capacity for accessible natural green space by policies identifying land in suitable locations and through enabling development.
Policy to identify clear funding mechanisms and enabling development to support the Cambridge Nature Network.

CPPF strongly supports inclusion of a GI policy and the reference to the Building with Nature standards and the incorporation of the Greater Cambridge strategic green infrastructure initiatives. We commend the extensive work undertaken by Greater Cambridge to assess green infrastructure needs. However, we are concerned about several aspects of the policy though acknowledge that it is still a work in progress.

While the policy may help to ensure that most major developments provide high quality GI on-site, there is a significant risk that it will not contribute meaningfully to the delivery of strategic GI across the Greater Cambridge area. We are very concerned that the policy by itself will not deliver strategic GI in the right locations and will fail to match needs without proactive policy and site allocation decisions elsewhere in the local plan. It is simply not clear at present how the policy aspirations will be delivered.

The Cambridge Nature Network sets out a clear vision for where strategic green infrastructure and nature recovery can take place. It identified four areas as the priorities for the provision of strategic green infrastructure and land for nature recovery:

1. To the south and east of Cambridge (Gog Magog Hills to Cherry Hinton downland zone);
2. West of Cambridge (Coton Countryside Reserve);
3. North & East of Cambridge at the southern end of the National Trust Wicken Fen Vision area around Anglesey Abbey; and
4. North of Cambridge (extension to Milton Country Park).

This local plan must facilitate delivery of the strategic GI required through both policy and appropriate site allocations. Accessible natural greenspaces are already at capacity and delivery of additional capacity in all areas north, south, east and west of Cambridge is required immediately to address this issue and remove / avoid damage to nature sites, including SSSIs.

There must be clear funding mechanisms and or enabling development in the right locations to ensure that the Cambridge Nature Network and other strategic green infrastructure is provided to support the proposed population growth. Without a proactive approach, the local plan will not meet the strategic GI needs and will therefore not deliver sustainable development. The best locations to provide strategic GI for Cambridge are on the fringes of the city, and in some cases the landowners are unlikely to make land available for strategic GI unless it is related to their own development proposals. This raises the question whether there may be a case for enabling development to unlock the land in the right locations to meet the strategic GI needs of the growing city and deliver a sustainable local plan.

Some of the proposed locations for major new development are not well located to deliver the strategic green infrastructure Cambridge needs in the right locations. The proposed development at Grange Farm, Abington is a case in point. The development is too small to deliver significant strategic GI but large enough to add to the unsustainable pressures on nature sites and county parks already occurring.

At this stage we believe that the local plan has failed to address the strategic GI requirements of the Greater Cambridge area and will not do so unless land can be secured in the right locations, through a mixture of policy and enabling development. We acknowledge that the Councils are aware of this. However, addressing this missing aspect of the local plan will be critical in determining whether the local plan is sustainable or not.

We need to understand more about how all development will contribute proportionally to the strategic green infrastructure required to support sustainable development within Greater Cambridge area. Unlike other parts of the UK, Greater Cambridge does not benefit from having large areas of publicly accessible downland, forest, coasts, moorlands, etc. Provision of GI across the Greater Cambridge area has fallen well behind that required to support population growth over the past 20 years. This draft local plan needs to make up for these deficits as well as provide sufficient GI for the proposed additional population growth. While most strategic developments have provided sufficient strategic GI to meet their own needs, these have only accounted for approximately 50% of the population growth, and the other 50% of development has not contributed to the needs of the growing population. The development proposals contained in this plan indicate that around 15,000 housing units (+30,000 people) will not contribute to the strategic greenspace requirements of the city.
We strongly advocate that ALL development should contribute to strategic GI and therefore the local plan must include strategic GI within a CIL requirement for new developments. While funding for open spaces and sports pitches is often secured through local plans, the natural environment and natural greenspace has traditionally been missed or under-provided for.

We are unclear about the distinctions between Green & Blue Infrastructure and standards and the standards for Policy BG/EO Providing and enhancing open spaces. Our comments apply across both.
Greater Cambridge is perhaps unusual in that much of the open space is not in the control of the public sector (especially on the fringes of and beyond the city), instead much of it is in the hands of charities and institutions (such as the Cambridge Colleges) who often allow defacto access. These site are often managed differently, and so don’t easily fit open space typologies. This situation makes if difficult to correctly classify them for assessment purposes, which in turn has a bearing on trying to understand deficiencies and also set standards. It is also creates more of a challenge in bringing forward green infrastructure to implementation as it requires the involvement of third parties. We feel that it might be helpful to set out this context in the supporting documents/information.

Support

CPPF supports this policy but would like to see bullet point (e)i, revised to make clear that a Cam Valley trail should not follow the riverbank, or be located in the floodplain, along the whole length of the river. This is needed to protect river and floodplain wildlife from excessive disturbance. Although the policy refers to the need for balance, there is no supporting text to set out and describe the balance that must be struck between river biodiversity and public access.

The Supporting information should recognise the special historic and cultural interest of the whole of the length of the Cam from Byron’s Pool to Baitsbite Lock.

Correct the Accessible Greenspace plans to show all and only qualifying greenspaces and isodistance contours around them based on available walking routes. (See section of representation on Accuracy of Designations and Access Modelling)
Consider higher standards for Cambridge.
Explore how the Plan can better deliver off-site green space.
Include land costs in estimating contributions.
Acknowledge the shortfall in accessible greenspaces in Petersfield ward.

Policy BG/EO: Providing and enhancing open spaces

CPPF strongly supports the direction that this policy is going in, recognising that it is still a work in progress. We commend the extensive work undertaken by Greater Cambridge to assess green infrastructure needs. Below we have provided comments on this work and some of the supporting information.

Green Space Standards
We strongly suggest that a higher amount of green space per 1,000 population within developments should be pursued for higher density residential developments. Parts of Cambridge currently have a generous amount of green space, and we believe this standard should continue to be the case in our new developments, otherwise new developments will be worse than previous generations, in this regard. For example, NE’s recommended area for Doorstep greenspace is 0.5h, and Local open greenspaces is 2ha per 1,000 people. When compared with existing spaces such as Christ’s Piece (3.5 ha), which could be classified as a Local greenspace, and New Square (approximately 0.78 ha), which may fall within the Doorstep greenspace category, the Natural England standard is worse than what we have in parts of Cambridge.

Human Wellbeing, Resilience, and Functional Scale
New developments must provide access to sufficiently large areas of open green space and public realm. Larger, multi-use areas are far more functional and beneficial than a series of small incidental spaces. Small open spaces, fragmented across a site, may have biodiversity and landscaping benefits, but they often lack purpose and interest for the user and result in areas that are looked at but rarely used. Too often, such spaces lack the generosity required to support basic human comfort and wellbeing, including adequate openness, sunlight, and shade.

Critique of Green Infrastructure Strategy Mapping and Data
Volume 2 Figure D1.1 of the Green Infrastructure Strategy includes a plan showing “accessible greenspaces > 0.5ha” and the area around these that is within 200m.
This is misleading because it includes land that is not publicly accessible within the definition provided by Natural England, and access does not take into account physical barriers to access (private land, railway lines, etc).
Natural England defines “Accessible Greenspace” as “greenspace that is specifically provided FOR public access, or one to which the public would usually expect to access (such as a cemetery), or one over which there is a public RIGHT to open access, and deemed likely to be accessible to the public at any reasonable time, free to entry and available for a range of pastimes (although some sites may be closed to the public overnight and there may be fees for parking a vehicle).”(1)

Accuracy of Designations and Access Modelling
According to this definition, all private land should be omitted, including belonging to St John’s, Trinity, Clare, King’s, Queens’, Magdalene, Newnham, Girton, Botanic Garden, The Perse School, CU Rugby grounds.
School playing fields, such as Milton Road Primary should also be omitted.
Spaces that are smaller than 0.5ha should also be omitted, including at CB1, Cambridge Leisure Centre, and between Davy Road and the railway line.
Coleridge Rec and Romsey Rec should be added.
We have previously advised GCSPS of the need to handle Coton Countryside Reserve appropriately when classifying it, but it looks like our advice hasn’t been taken into account. This is a very large site, but most of it is farmed with permissive footpaths, only a relatively small area is defacto publicly accessible green space. Because of the size of this site, how it is classified has an impact on access modelling. It is CPPF’s aspiration to transform the farmland into green space but that is not the case at the current time.
The isodistance access areas should be plotted based on available rights of way.

In relation to our comments, we note the response of the Wildlife Trust, which we support. The following is an extract from the Wildlife Trust's representation.
“The reports identify that there is currently 8.7 Ha of accessible greenspace per 1,000 population across the Greater Cambridge area and set out a policy to maintain this minimum level of provision in relation to future population growth. However, from reviewing the evidence it is unclear where this figure actually comes from, and various maps appear to show some large areas of land as green infrastructure which are neither high quality nature sites nor accessible greenspace. It must include an element of accessible natural / semi-natural greenspace, but from a review of the various linked GI reports I have not been able to find the source reference for this calculation. This is critical to understand whether the figure is accurate and to understand how it was calculated. There is a good chance that the current level of provision is over-stated, which has implications for both policy and funding.

"The reports also refer to the Greater Cambridge area exceeding the Fields in Trust recommended standard of 3 Ha / 1,000 population of natural greenspace. However, this is not an appropriate standard for the Greater Cambridge area. This figure might be appropriate for many other cities and towns that have large areas of high quality, biodiverse, accessible countryside in their hinterland including areas of downland, moorland, forest or coast. These are often designated as National Parks or National Landscapes with good access provision. However, the Greater Cambridge area has none of these and therefore requires a much higher level of provision of strategic natural greenspace.

"A further consideration is that the provision of accessible natural greenspace is significantly less than required as it is not sufficient to prevent increasing impacts from recreational use of nature sites across Greater Cambridge. The levels of strategic natural greenspace provided over the past 20 years has been insufficient overall (though some individual large development allocations such as Trumpington Meadows, Clay Farm, Cambourne and Waterbeach will meet their own needs, most developments have not).

"Therefore, there is a question as to whether the 8.7 Ha per 1,000 population is either an accurate assessment of quantity or sufficient as the target for the Overall Accessible Greenspace Area-wide Standard? Does this need to be increased to address the impacts on nature sites from unsustainable recent growth and predicted future growth? Alternatively, should a set of specific and deliverable new strategic natural greenspace sites be brought forward through the Local Plan process to address and mitigate the damage from recreational impacts at existing nature sites and the capacity issues at Country Parks such as Wandlebury and Milton? Whichever approach is taken, the Local Plan must include proactive measures and deliver the strategic natural greenspaces that is required for place making and sustainable development, in addition to the local and urban green infrastructure to be delivered on-site through new developments.

"The Wildlife Trust welcome and fully supports the inclusion of the proposed Overall Nature Recovery Area-wide Standard. The standard and justification are set out in paras 3.2.24 and 3.2.25 of the Emerging GI Strategy & Standards Document. However, we do not support the current wording as it is not clear. We suggest the following revision to the proposed standard, with similar changes to wording in para 3.2.25: Delete the words 'proportion of' and replace with 'area of natural/semi natural' :-
“Target of 100% increase in the area of natural / semi-natural GI that is designed and managed for nature recovery across the Greater Cambridge area over the Local Plan period.”

"The Wildlife Trust welcomes the commitment to undertake further work on a SANGS (Suitable Accessible Natural Greenspace Standard).

"With respect to costs and implementation, it will be essential to factor in the land acquisition costs in calculating the overall figures for provision of strategic natural greenspace. At present only site creation and management costs over 30 years have been taken into account.

"Finally, within the GI Supporting Evidence Report Appendix D includes an analysis of how the Accessible Natural Greenspace Standard is met and identifies areas of deficiency. The Wildlife Trust notes the deficiency in the provision of a Sub-regional Natural Greenspace (500 ha) for the whole of the Greater Cambridge area and the deficiency in provision of District Natural Greenspace (100 ha) across most of the area. The Cambridge Nature Network report identified the opportunities to address these deficiencies in three areas to the south and east, west and north-east of Cambridge. It is essential that the Local Plan makes specific provision, if necessary allocating land, to deliver the strategic natural greenspace that will meet the identified needs.”

CPPF are unclear about the distinctions between Green & Blue Infrastructure and standards and the standards for Policy BG/BI Green & Blue Infrastructure. Our comments apply across both.
Greater Cambridge is perhaps unusual in that much of the open space is not in the control of the public sector (especially on the fringes of and beyond the city), instead much of it is in the hands of charities and institutions (such as the Cambridge Colleges) who often allow defacto access. These site are often managed differently, and so don’t easily fit open space typologies. This situation makes if difficult to correctly classify them for assessment purposes, which in turn has a bearing on trying to understand deficiencies and also set standards. It is also creates more of a challenge in bringing forward green infrastructure to implementation as it requires the involvement of third parties. We feel that it might be helpful to set out this context in the supporting documents/information.
We also note that the Appendices for the Green Infrastructure Strategy Vol 2 are not available in the document library and would ask that this be addressed.

(1) https://designatedsites.naturalengland.org.uk/GreenInfrastructure/Glossary.aspx

The policy should quantify the scale of need and recognise the need for major new cultural attractions and infrastructure to offset the pressures on city centre attractions. The policy should safeguard existing cultural and creative spaces.

The policy does not quantify the scale of local need for cultural and creative hubs. It does not recognise the need to provide major new cultural attractions and infrastructure to offset the pressures on city centre attractions. The policy does not safeguard existing cultural and creative spaces.

Support the protection of Public Houses

It is unclear how the plan will respond to and deliver Public Art. It is currently unclear whether its preservation and implementation fall under the general design quality standards of GP/QP (landscape and public realm) or the protection of Non-Designated Heritage Assets (GP/ND). Without a specific designation, significant public art installations may lack the necessary protections against removal or decay. Irrespective of how the plan will approach public art, it should emphasise the importance of early collaboration on the appropriate siting and integration of public art in the design of greenspace and/or public realm.

The governance of Street Lighting requires further definition within the plan. It is presently uncertain whether lighting standards will be dictated by shopfront guidance or broader design policies like GP/QP. Clear policy language is essential to ensure that lighting schemes are sensitive to the historic character of Cambridge and do not contribute to visual clutter or inappropriate illumination of the heritage environment.