Greater Cambridge Local Plan: Proposed Submission

The Wildlife Trust strongly supports this policy and particularly the 20% BNG for major developments. Cambridgeshire is one of the most nature depleted counties in England, once of the most nature depleted countries in the world. Further the Cambridge area has experienced significant growth over the past 25 years with even more proposed for the next 25 years. We are in a biodiversity as well as climate crisis and sustainable development requires development make a significant contribution to reversing the declines in nature and helping us on a path to nature recovery. Further, it is widely accepted in professional circles that BNG at 10% measured by the Biodiversity Metric is probably not much better than no net loss. A figure of 20% is needed to achieve real gains through new development and make a meaningful contribution to nature recovery and delivery of the Local Nature Recovery Strategy.

The Wildlife Trust supports this policy with the changes made since the draft local plan an improvement.

The Wildlife Trust supports this policy including the changes made since the draft local plan.

The Wildlife Trust strongly supports this policy.

Changes to the development strategy and site allocations to support delivery of strategic GI beyond that delivered as part of individual developments.

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 now. Accessible natural greenspaces are 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, but the landowners are unlikely to make land available for strategic GI unless it is related to their own development proposals. The unfortunate reality is that there may be a need 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. While this development may be required to provide funding for strategic GI, the reality is that potential providers will not be able to acquire the land required south and east of Cambridge, due to current ownership and the development aspirations of those owners.

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. Addressing this missing aspect of the local plan will be critical in determining whether the local plan is sustainable or not. This may even require further carefully targeted release of green belt land to deliver nature recovery and strategic natural greenspace in the best locations, and this is allowed for in national green belt policy objectives where it delivers “improvements to local infrastructure…and the provision of new or improvements to existing green spaces that are accessible to the public.”

The Wildlife Trust supports the inclusion of this policy within the Local Plan and most of the principles. We do however have concerns regarding some of the proposed standards and deliverability which will will address in a further response.

The standard should be increase to greater than 7 Ha per 1000 population.

3. All major developments that are predominantly residentially led must demonstrate total provision of accessible greenspace equivalent to 8.0 hectares per 1,000 population, and within this total, deliver a minimum on-site accessible greenspace provision that:...

There should be better alignment between the site allocations and delivery of other policies such as GI and Biodiversity policies. The current site allocations including those around Cambridge Biomedical Campus (Cambridge south-eastern fringe) and Grange Farm either compromise or do not support the GI needs. This need not be the case as other site allocations, e.g. Cambridge East, Cambourne North do fully integrate GI and biodiversity needs into the allocation and policy.

Although the Wildlife Trust strongly supports the inclusion of this policy and the principles contained within, we do have some concerns as to the accessible greenspace standard and the overall deliverability of the policy.

The policy includes a standard of 7 Ha accessible greenspace per 1000 population seeking to maintain current standards. However, it is also accepted within the various council GI documents that there is a shortfall particularly in strategic natural greenspace. To be sustainable, the Local Plan should include a policy standard to address the identified deficiencies, which should require a standard of more than 7 Ha per 1000 population. The policy should be seeking to increase the amount of accessible greenspace and in particular large-scale, strategic, accessible natural greenspace, particularly in the four priority locations identified in the Cambridge Nature Network. This should be addressed through the development strategy and site allocations.

While the policy includes a mechanism for collecting off-site contributions, this will only work if land is available to delivery partners for strategic GI provision. In many cases around Cambridge, including some of the priority locations for provision of strategic GI (e.g. Peterhouse / Guys & St Thomas land on the Gog Magog Hills), this won’t happen without enabling development. However, the site allocations on the Cambridge south-eastern fringe, including Cambridge Biomedical Campus, currently fail to support the delivery of the land required for the strategic GI in the right place.

There also remains a significant risk that the policy will result in a net loss in per capita provision of accessible natural greenspace. While larger developments will meet their GI requirements under this policy, the large number of smaller allocations will continue to increase pressure for new strategic GI provision. At present CIL is not currently available for accessible greenspace therefore requiring S106 to secure contributions. Does this create a bottleneck with Greater Cambridge Planning not having sufficient staff or legal resources to negotiate and manage S106 agreements and increasing risk of the policy intentions not being met?

The Wildlife Trust strongly supports this policy and particularly the 20% BNG for major developments. Cambridgeshire is one of the most nature depleted counties in England, one of the most nature depleted countries in the world. Further the Cambridge area has experienced significant growth over the past 25 years with even more proposed for the next 25 years. We are in a biodiversity as well as climate crisis and sustainable development requires development to make a significant contribution to reversing the declines in nature and helping us on a path to nature recovery. Further, it is widely accepted in professional circles that BNG at 10% measured by the Biodiversity Metric is probably not much better than no net loss. A figure of 20% is needed to achieve real gains through new development and make a meaningful contribution to nature recovery and delivery of the Local Nature Recovery Strategy.