Greater Cambridge Local Plan Issues & Options 2020

We strongly welcome the environmental ambition outlined in this consultation. This level of ambition will be essential to address the climate and ecological emergencies declared by the Greater Cambridge councils, and to achieve the agreed ‘doubling nature’ target. We look forward to working with the councils to deliver a revised and improved Local Plan and to unlocking the substantial benefits for nature and for residents. The RSPB manage several sites within the Greater Cambridge area, including our reserves at Fen Drayton, Fowlmere and Hope Farm at Knapwell, and are working with Hanson to create one of Europe’s largest new reedbeds at their Needingworth quarry. We would encourage the planning authorities to work proactively with nature conservation organisations operating in the plan area to identify existing green networks and infrastructure and the potential opportunities for significant habitat creation associated with development (and mineral extraction) likely to occur up to 2040. As such we would encourage the authorities to work closely through the Local Nature Partnership and directly with local NGO players when formulating policy approaches and identifying sites linked to your Biodiversity and Green Spaces theme.

Question 3:Please submit any sites for green space and wildlife habitats you wish to suggest for consideration through the Local Plan. Please use the site submission form that can be found on our website, and provide as much information and supporting evidence as possible. Q3 Response: The RSPB will be looking to work with the Greater Cambridge Authorities to ensure the continued conservation and potential enhancement of its current suite of reserves (Ouse Fen, Fen Drayton and Fowlmere), and ensuring that development through the plan protects, but also improves the management of the protected areas and reserves within the Plan boundary, which should be at the heart of a Green Infrastructure network. We are also aware of existing efforts to identify existing and potential greenspace/wildlife habitats by organisations such as BCN Wildlife Trust and Cambridge Past, Present and Future which the plan authorities should take account of. As below we also think that the Greater Cambridge authorities should work with relevant stakeholders and neighbouring authorities to formulate a Green Infrastructure supplementary planning document to identify how and where the ‘doubling nature’ target will be met. We would encourage the Greater Cambridge Local Plan to accept sites with exceptionally high nature and carbon potential in neighbouring districts as greenspace/wildlife sites under the Local Plan - we believe this will be necessary to address the climate and ecological emergency in Cambridgeshire. The CUSPE report for the County Council found the majority of the county's carbon emissions are from land in surrounding districts, and the only substantial funding available to address this will be linked to development in the Greater Cambridge area.

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Strongly agree

Strongly Agree For nature to recover it is critical that authority boundaries do not create a barrier to wildlife moving throughout the habitat network. If we are to achieve our ‘doubling nature’ target in Cambridgeshire, the Greater Cambridge Plan authorities need to work closely with neighbouring authorities to deliver ambitious and strategic habitat creation projects and a coherent green infrastructure network that is joined up across authority boundaries. RSPB believes that many of the most significant opportunities lie in districts neighbouring the Greater Cambridge area, but rely on and will benefit the development planned for the area.

Strongly agree

Strongly Agree We applaud the Greater Cambridge Authorities’ emphasis on both climate change and biodiversity as they are interlinked crises that the emerging plan needs to tackle head on.

The Local Plan will achieve net zero carbon by: • Policies that require all new development to be zero carbon. This includes: o use of low-carbon building materials, o high thermal performance of buildings, o space heating from renewable sources, o Provision of renewable electricity generation on-building and on-site. • Ensuring major new development is connected by public transport infrastructure powered from renewable sources. All existing settlements to be connected by public transport links powered by renewable sources. • Policies that require provision of electric vehicle charging points in all new housing and employment development. • Ensuring that new employment development is near and connected to residential areas by active travel infrastructure. • By ensuring that as well as on-site habitat creation and greenspace provision, development enables large scale wetland habitat creation in the Fens (through a combination of developer community contributions and the application of biodiversity net gain policy), reducing carbon emissions from peatland soils and so contributing significantly to net zero carbon in the Greater Cambridge plan area. This approach may also help Greater Cambridge with climate adaptation through improved management of water (for example improved flood storage and sustainable drainage). As set out below this will require the Greater Cambridge Councils to work co-operatively with neighbouring authorities to deliver strategic mitigation outside of the plan area. It is vital to ensure strategic spatial planning of renewable energy infrastructure in order to avoid deployment in environmentally sensitive places, thereby driving down emissions in a way which is in harmony with nature. The RSPB’s 2050 Energy Vision outlined a number of priorities for achieving very high levels of renewable energy by 2050. We would be pleased to discuss with the Greater Cambridge Councils how our Energy Vision peer-reviewed mapping methodology could be used to help identify suitable sites for renewable and low carbon energy. Conservation-managed lowland fens appear to be among the most effective carbon sinks per unit area in England and Wales, whereas lowland peats under intensive arable agriculture in England are probably the UK’s largest land-use derived source of carbon dioxide emissions. Drainage-based conventional agriculture on lowland fen and raised bog peatlands is a major (and probably the largest) source of land-use GHG emissions per unit area in the UK, and thus a high priority for future climate change mitigation activity: http://oro.open.ac.uk/50635/1/14106_Report_FINAL%20Defra%20Lowland%20Peat%20Published.pdf The RSPB would be happy to work with and support the Greater Cambridge Councils on realising these ambitions for the restoration of carbon-rich habitats in a way that will maximise their biodiversity benefit.

See response to Question 8. Tree planting can be an effective way of mitigating carbon emissions through providing an increased ‘carbon sink’, as long as it takes place in a strategic manner, in the right place (so, for example avoiding peat soils or species-rich grassland habitats). We believe that the plan will have far greater benefits if it also identifies where other options for habitat creation may be more effective and appropriate. As above, this may include re-wetting peatland soils in the wider Cambridgeshire area through wetland creation and enabling more climate-friendly land-management in the farmed landscape.

Yes, strongly agree

Yes, Strongly Agree We draw your attention to the Urban Greening Factor study for the City of London - https://www.cityoflondon.gov.uk/services/environment-and-planning/planning/planning-policy/local-plan/Documents/urban-greening-factor-study.pdf , and the Nature/Public Space sections of the National Design Guide - https://www.cityoflondon.gov.uk/services/environment-and-planning/planning/planning-policy/local-plan/Documents/urban-greening-factor-study.pdf

Using climate projections to estimate increased flood storage and water resource needs in the Ouse catchment, the plan should identify the level of need for increased flood and water storage capacity up to and beyond 2040, and opportunities for development to enable the provision of this. The early modelling that we are aware of (eg:- the 2019 ITRC Mistral report and Anglian Water’s WRMP projections) raises this as a serious concern. We believe that strategic deployment of nature-based solutions (e.g. wetland creation) both inside and outside of the plan area will be an important way of providing this, whilst also contributing to objectives on biodiversity and green space. The RSPB manage flood and water storage wetlands elsewhere in the UK and are looking to explore options in Greater Cambridge.

The Local Plan should: • Provide policies for the unambiguous protection of designated nature conservation areas within the Greater Cambridge area, to include the Natura 2000, SSSI and County Wildlife Sites. • Through a supplementary green infrastructure plan document, identify existing nature sites for enhancement, potential areas for habitat creation, and habitat corridors that together will create a joined up ecological network (see below), with the target of achieving ‘doubling nature’ in Greater Cambridge, but also across the Combined authority area. This should provide the framework for delivering biodiversity net gain, which should be a requirement for all development implemented within the new plan period and is soon to be mandated by the new Westminster Environment Bill. • This green infrastructure plan should be developed in co-ordination with neighbouring authorities and key partners (in particular the minerals, flood and water management sectors along with eNGOs), allowing for strategic delivery of large-scale habitat creation, which may be outside the boundaries of the Greater Cambridge plan area. • Provide policies to ensure all new development provides room for nature through building design (for example use of swift bricks), Sustainable Urban Drainage Systems (including source control features), ponds, and wild-flower verges. Green spaces and parks should integrate public open space with habitats and be subject to nature-friendly management (for example mowing regimes to benefit wildflowers in meadow areas, limits on use of insecticides/herbicides/fungicides). Urbanisation can act to fragment landscapes by creating barriers between habitats, thus isolating wildlife populations. In 2010 a review of England’s wildlife sites concluded that our habitat areas are currently too small, and too isolated from one another, to allow wildlife to thrive. In order for nature to recover we need to develop and protect a connected, ecological network across England, covering both rural and urban areas. The creation of such a green network throughout Greater Cambridge and neighbouring authorities would enable wildlife to move around, and species populations to expand and grow, while also improving the health and wellbeing of local communities. By maintaining and restoring existing priority habitats and protected sites - including brownfield land of high environmental value - and connecting fragmented green and blue space, this network will benefit both people and wildlife. The RSPB recognises that redeveloping brownfield land can provide opportunities for sustainable development, reduce pressure on other undeveloped land, and offer chances to promote economic regeneration. However, some brownfield sites (Open Mosaic Habitat - OMH) are havens for wildlife and support some of the UK’s most scarce and threatened species. In many cases brownfield sites provide the last ‘wild space’ in urban areas for local communities, allowing them access to nature and consequently improving the communities’ health and well-being. There must therefore be a mechanism to ensure that the most important brownfield sites for biodiversity are identified and protected. The RSPB requests that all brownfield sites being considered for development be supported by an up to date ecological survey and assessment undertaken by a recognised expert (for example, a Chartered Member of the Institute of Ecology and Environmental Management). The plan authorities should investigate how existing green space/habitat can be made more accessible – for example the RSPB reserves at Fen Drayton and Ouse Fen, with connections to the guided busway and new settlement at Northstowe. The RSPB has worked with others to produce guidance on maximising the potential of Sustainable Drainage Systems for people and wildlife: http://ww2.rspb.org.uk/Images/SuDS_report_final_tcm9-338064.pdf

There is increasing evidence of a positive relationship between a person’s access and connection to nature and their health and wellbeing. As above, we believe that future green space provision should aim to be multipurpose – providing recreational opportunities for local communities in a way which also benefits wildlife and, where appropriate, delivers additional environmental benefits such as flood storage potential (for example, St Aidans RSPB reserve near Leeds and our Old Moor reserve near Barnsley). The major development planned for the Greater Cambridge area, and the infrastructure and aggregates needed to support it, provide both the need and the opportunity for equally ambitious green space delivery. Meeting the ‘doubling nature’ target for the Greater Cambridge area will require several thousands of hectares of new wildlife-rich green space. We support the work the Wildlife Trust and Cambridge Past, Present and Future are leading to identify appropriate green space within 10km of Cambridge. There are also major opportunities available out-with that 10km boundary along existing and planned public transport routes into Cambridge. For example we are exploring the scope to improve visitor access to Fen Drayton Lakes and Ouse Fen, which sit on the busway with rapid access to Cambridge and Northstowe and are developing into nationally-important wildlife sites. There are also considerable opportunities in the southern Fens, near the Greater Cambridge boundary. The Local Nature Partnership has identified the Ouse Valley and Fens, both within and adjacent to the Greater Cambridge area, as priority habitat creation areas for the county. These have also been identified at an ‘Oxford-Cambridge Arc’ level as priority areas for nature investment in Cambridgeshire. Together with the Local Nature Partnership we are exploring options for developing this initial agreement into a concrete plan and would welcome the chance to discuss this work with the Greater Cambridge councils.