Greater Cambridge Local Plan: Proposed Submission

The policy wording needs to clearly distinguish between the differing requirements of development affecting international, national and local wildlife sites.

Although the RSPB acknowledges the extra text added to the supporting information on the requirements of the Habitats Regulations regarding proposals affecting Internationally important sites, we still do not believe that paragraph 9 adequately covers the strict requirements that development affecting a Habitats Site need to fulfil. The benefits of a development with a potential adverse effect on the Conservation Objectives of a site cannot merely 'significantly outweigh' adverse impacts, but there must be imperative reasons of overriding public interest. Likewise there needs to be no alternative solutions and compensation to maintain the integrity of the network must be provided.

The RSPB supports the amended allocation boundary that excludes land within our Fen Drayton Lakes Reserve.

The RSPB supports the requirement for 20% BNG in major development. This is particularly important in the context of Cambridgeshire which is one of the most nature depleted counties in England. We also support the prioritisation of BNG that aligns with the LNRS in priority areas.

Additional wording, potentially in the supporting information 3.3.18, should be added which explicitly reflects the need for green space provision within the allocation footprint to buffer Hope Farm, so that we do not have built development with associated domestic pets in direct proximity to our nature-abundant fields.

Viable and safe dark corridor bridges over the A428 and East/West Rail corridors should be made explicit in supporting text para.3.3.22.

Para 25(b)(i) should include the words 'a minimum of...' to reflect that many impact pathways could have significant impacts well beyond 40m.

The RSPB welcomes the changes made in the submission plan policy text and supporting information taking into account the concerns we raised at the Draft Plan stage.

With regards to our demonstration Hope Farm at Knapwell, we support the inclusion of the text at para 13(e) ensuring that the SEA supports the viability and nature friendly farming principles of Hope Farm, and that at para 37(b)(i) which seeks to limit recreational pressures on species and habitats at the farm (as well as ancient woodlands and other sensitive habitats and species). We also support the supporting text at para 3.3.23 which sets out the need to buffer Hope Farm with arable land uses, and for this land to support priority species such as Turtle Dove, and pollinators, backed up by the policy wording at para 14(b)(ii).

The allocation footprint abuts the RSPB Hope Farm landholding. As such, in addition to the above, we would like to see additional wording, potentially in the supporting information 3.3.18 which explicitly reflects the need for green space provision within the allocation footprint to buffer Hope Farm, so that we do not have built development with associated domestic pets in direct proximity to our nature-abundant fields.

The RSPB acknowledges the updated Indicative Spatial Framework (figure 66), and the provision within this, backed up in the policy and supporting text, providing green corridors between the sensitive ancient woodland sites and connecting these to the wider countryside. We support the provision of extensive dark corridors to support bat movement and connectivity, which are especially important to ensure that any subsequent planning applications comply with the strict requirements of the Habitats Regulations, particularly regarding the probable functional link between these sites and the Eversden and Wimpole Woods SAC. Viable and safe dark corridor bridges over the A428 and East/West Rail corridors will be a key element of this, and this should be made explicit in supporting text para.3.3.22.

The RSPB acknowledges the buffer areas between ancient woodland and other sensitive habitats and development set out in para.25(b). The RSPB believes that these buffer distances need to be the minimum used as many impact pathways could have significant impacts well beyond 40m. Subsequent EIA and HRA assessment will need to inform where wider distances are needed to mitigate impacts from the likes of domestic animal predation, noise and light. As such we believe that para 25(b)(i) should include the words 'a minimum of...' to reflect this.