Draft Greater Cambridge Local Plan for consultation

We welcome the inclusion of a dedicated biodiversity theme. However, the plan will only deliver in practice if it has clear requirements, strong mechanisms for long-term management and monitoring, and robust enforcement. Our priorities include: resisting further losses of urban green space and Green Belt; prioritising brownfield land (subject to appropriate environmental assessment) where a genuine need for development is identified; insisting that biodiversity net gain is delivered on-site wherever possible; opposing garden grabbing and the loss of small natural features such as hedges and grass verges without good cause; expanding and fully protecting the network of City Wildlife Sites, Country Parks, and Local Nature Reserves; ensuring recreational green spaces and play areas are safe, clean, and accessible to all; and supporting tree planting and opposing unnecessary tree removal.

This policy should make clear that biodiversity net gain must be secured through robust management and monitoring arrangements with clear responsibilities and funding. The policy should also ensure that the local planning authority receives regular reporting and can require remedial action where outcomes are not being achieved.
We note that there is no basis in the National Planning Policy Framework establishing the acceptability of off-site biodiversity net gain, and we remain opposed to the use of off-site biodiversity net gain in principle.
Notwithstanding our opposition to the use of off-site biodiversity net gain, we recommend substituting the draft policy’s paragraphs 4 and 5 with the text set out below.
“4. All applications for major development, and any other development subject to mandatory biodiversity net gain, must be accompanied by a Biodiversity Gain Plan (or equivalent) and a Biodiversity Net Gain Management Plan, approved in writing by the local planning authority prior to commencement. The Management Plan must include an Annual Work Programme and annual progress reports to the local planning authority for years 1-5 after completion (or by phase).
5. Where there is significant on-site biodiversity net gain or any off-site biodiversity net gain, habitats delivering biodiversity net gain must be managed and monitored for a minimum of 30 years after completion. Monitoring must be undertaken by a suitably qualified ecologist in years 1, 3, 5, 10, 20 and 30, with reports to the local planning authority. The Management Plan must set out responsibilities and secured funding for management and monitoring and remedial actions where targets are not met. Delivery must be secured by planning conditions for on-site units and a section 106 agreement for off-site units.”
We are concerned that city and county wildlife sites are not adequately protected from the adverse consequences of development under the provisions of this policy and recommend that the language of policy be improved to address this issue.

We recommend strengthening the policy to require a green and blue infrastructure strategy for major development to submitted at an early stage and aligned with the Local Nature Recovery Strategy. Applicants should be required to demonstrate how proposals will connect to the wider ecological network and rights of way, and how they will deliver multiple benefits including habitat creation, urban cooling, and water management. Long-term maintenance and funding should be secured through planning conditions or planning obligations. The policy should emphasise that biodiversity-rich habitats and water sensitive design (including naturalised sustainable drainage) are preferred to amenity-only landscaping and that lighting should be designed to avoid harming wildlife along green and blue corridors.

We note that retaining mature trees greatly enhances the quality of the built environment of new development, and we recommend that the policy should be strengthened to make clear that the protection of existing mature trees is a priority. And that the built environment should be planned around existing mature trees. Felling of mature trees at development sites should only be permitted where there are clear, justifiable, and compelling reasons for doing so, supported by evidence and independent arboricultural advice.
We recommend that plantings should prioritise species with high biodiversity value and climate resilience and should include a requirement to provide adequate soil volume, irrigation, and rooting space so that trees can reach maturity. Long-term management and replacement of failed trees should be secured through planning conditions or planning obligations. We also recommend that new streets are designed to be tree-lined where practicable, with early coordination to avoid conflicts with utilities and to support healthy growth, and we have proposed a policy to that effect in the Great Places section of the plan (GP/TS).

River corridors are essential for biodiversity connectivity, water quality, and climate resilience. The policy should prioritise natural river function and habitat quality. We share residents’ concerns about the impact of tourism on the natural environment and the quality of life for local residents. We do not accept the principle that all development along river corridors should be required to support tourism, and we therefore recommend that sub-paragraph 1f is removed from the policy.

To avoid the incremental loss of existing green space through piecemeal development, the tests for any loss of open space must be sufficiently strong that it is only permitted in wholly exceptional circumstances and only where there is no reasonable alternative. We have strong doubts the proposed wording of this policy meets this requirement.
Point 1. Where loss is permitted, we agree that replacement should be like-for-like or better in terms of accessibility (including for disabled users), size (quantity), quality (which must include biodiversity value). However, we propose the addition of the following sentence “Biodiversity, including that relating to semi-natural areas and informal green space, should be a key consideration in assessing the quality of open spaces.
Point 2. We do not support Point 2a on the grounds that the ‘Accessible Green Space Accessibility Standards’ are very general and are an inappropriate benchmark for relocation. They take no account of the inherent environmental qualities of an open space. Given that the open spaces referred in this policy are protected, they have already been subject to official evaluation. There needs to be a much more compelling argument defined by the policy to allow this evaluation to be overridden, and then only in highly exceptional circumstances.
We support (2b), that any replacement site should be “fully available for use before the area of open space to be lost can be redeveloped.”
Point 3. This should be deleted as it undermines the general purpose of the policy, since it essentially creates a privileged class of development for educational institutions.
A major weakness of this policy is that, compared to Policy 67 in the 2018 Local Plan, it is not accompanied by an equivalent to the original clear Appendix I ‘Table of Standards’. Furthermore, in the draft plan as a whole there is a lack of visibility of the most POS-deficient wards, which will mean that the needs of such wards (such as Petersfield) may go unnoticed. It appears that, for ward-level data, the plan is relying on the 2011 Open Space and Recreation Strategy document, now almost 25 years old. This needs addressing, with updated data – there are several examples of protected open space being lost to developments (e.g. the Area of Major Change South of Coldham’s Lane, where the outline planning application, if it goes to full approval will result in the loss of protected open space).

The policy should require that new and enhanced open spaces are designed to support nature recovery and climate resilience with a focus on trees, hedgerows, species-rich grassland, and water and wetlands. Provision should be guided by clear quantity, quality, and proximity standards. Long-term maintenance of biodiversity values and nature, and funding must be secured, including replacement of failed planting and ongoing habitat management. This policy should also be amended to specifically reference and require physical accessibility of open spaces for disabled users.

Under “How has community engagement helped shape the wellbeing and social inclusion policies,” the final sentence should be amended to read: “We should make places inclusive, providing employment and training opportunities, as well as community spaces and facilities. We should also provide space for cultural activities, for community gatherings and for social enterprise.” This wording is less individualistic and more consistent with the stated aim of supporting delivery of healthy and inclusive communities.
We recommend adding a sentence immediately after the strategic priority to state “This includes supporting higher-density mixed-use development where appropriate in order to locally integrate homes, jobs and services, reducing distances and supporting healthier, more resilient communities.” This clarifies the importance of higher-density mixed-use development for achieving the strategic priority and includes more of a focus on communities.
To continue this community focus, the list of policy aims for this theme should be amended to include the following: “Foster community, by providing spaces and facilities for communities to come together, in particular across a range of ages and backgrounds.”
The list of policy aims should also be amended to include “Support the provision of opportunities with no barrier to entry for leisure, socialising, sport and arts,” as expanding these opportunities is essential for delivering the overall aim of healthy and inclusive communities.
Finally, the fourth item in the list of policy aims should be amended to read “Ensure proposals for new facilities are properly located, with priority given to locations that support mixed-use development and enable needs to be met locally.” Such developments reduce travel demand and support healthier, more sustainable communities.

We recommend amending the second and third sentences of the policy aim to state “The ability of individuals to lead healthy lifestyles and form vibrant communities is deeply influenced by the environment in which they live. This policy sets out how new development can support healthy lifestyles and community cohesion and promote the health and wellbeing of residents.” The current focus only on healthy lifestyles is too individualistic.
We recommend amending the beginning of point 1 to state “Development will be supported where it can be demonstrated that it provides opportunities for residents and workers to adopt healthy lifestyles, contributes to the creation of healthier communities and the reduction of health inequalities. Developments should create compact, well-connected neighbourhoods which support sustainability, reduce travel demand and enhance opportunities for social interaction and community cohesion. Developments will promote health and wellbeing by…” This gives explicit policy support to the principle of compactness, which is already mentioned in the supporting information.
We recommend adding a new clause 1.j to state “Ensuring new developments integrate accessible local employment opportunities alongside homes, services, and amenities where appropriate, to support healthy, mixed-use communities and reduce the need for travel.” This reflects the fact that access to work is part of creating healthy places.
In point 2, “to take into account how they can contribute” should be amended to “and, where possible, contribute.” Placing the onus explicitly on the developers to attempt to contribute will provide stronger support for public health strategies.
In point 7, we recommend adding a final sentence to state “Applications for hot food takeaways and fast food outlets which replace one of three or fewer such community assets or convenience shops must demonstrate that the provision to local residents will not be negatively affected by this replacement.” Otherwise, this point simply means that all but one shop or community asset can be replaced.

In point 1, “or contribute to” should be amended to “to the greatest extent possible,” and “mitigate the impact” should be amended to “mitigate as far as possible the impact.” Placing the onus on the development to avoid small gaps in provision ensures that the cumulative effects of multiple developments will not overburden or degrade facilities provision.
Point 2.a should be amended to read “the capacity, quality, and accessibility of existing facilities in the locality, and the impact on those factors of other planned developments.” This means that multiple concurrent developments must take one another into account when assessing impact on facilities.
Point 4 has an extraneous comma: “community, facilities” should read “community facilities.”
In point 5, the phrasing should be brought into line with the other points: “All housing developments will be required to contribute.”
The enumeration of specific categories of facilities provision in the supporting information would benefit greatly from an overview of each category being included in the local plan itself, where in several cases (e.g., cultural infrastructure and sports and leisure facilities) outside plans are referenced but not described.