Greater Cambridge Local Plan Issues & Options 2020

The following comments are made on behalf of the Wildlife Trust. We are the largest local nature conservation charity dedicated to the conservation of nature and have over 35,000 members, and manage over 2,000 hectares of land for nature conservation. These comments follow the questions asked in the Issues and Options consultation where possible, though inevitably go beyond this in places. The Wildlife Trust would like to play an active role alongside the two councils as they prepare this Local Plan, to ensure that it really moves us in the direction of sustainable development, is visionary and looks to the long-term.

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Disagree

Disagree. It is essential that this Local Plan doesn’t just consider detailed requirements up to 2040, but also sets a long-term vision for the future growth of Cambridge, otherwise the opportunity to move to sustainable development will be missed. The sheer scale of growth envisaged from the doubling GVA, CPIER and Ox-Cam Arc proposals will not be sustainable without fundamental changes to the way that development is allocated, planned and delivered. The avoidance of impacts on and large-scale enhancement of the natural environment must be at the heart of a truly sustainable approach. At the current time it is far from clear that the higher levels of growth envisaged could be achieved sustainably. The Greater Cambridge Nature Recovery Network (see below) must form the framework within which all future development is planned. Planning of houses, jobs and infrastructure must not compromise the nature recovery network, but rather sit alongside it and support it. Using the natural environment as the framework within which development is planned is best practice in the design of individual developments and this approach must be translated to Local Plans. Creating a nature recovery network of address the biodiversity crisis, and addressing the challenges of climate change and water resource issues whether adapting to future flood risks or the lack of available water to support the levels of growth envisaged (while still supplying the natural environment), require planning and setting the direction of travel for future growth over a much longer timescale. There is a danger that only planning to 2040 will lead to a continuation of unsustainable growth patterns. This may be the appropriate period for detailed planning, but, a longer term direction of travel will be required if the most sustainable solutions are to be adopted.

Strongly agree

Strongly Agree. For nature to recover it is critical that local authority boundaries do not create a barrier to wildlife moving throughout the nature 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.

Strongly agree

The Wildlife Trust strongly supports the four big themes identified and in particular the inclusion of biodiversity and green spaces and climate change. The natural environment forms the basis of economic and social prosperity and for too long has been an after-thought in public policy focussed solely on jobs, homes and built infrastructure. Sustainable development requires us to live within environmental limits, and not just protect what remains of our natural environment, but to restore and enhance it to reverse the declines caused by previous unsustainable developments and land uses. The Wildlife Trust believes that the Local Plan should identify, describe and map a Greater Cambridge Nature Recovery Network, which is of sufficient scale and scope that it would be capable of delivering a doubling of nature and meeting the informal green space needs of current and future populations. Such a network would also deliver the wider benefits described in the Issues & Options First Conversation document, namely ameliorating the worst effects of flooding, drought, high temperatures; improving health and well-being; absorbing carbon; planting trees; increasing prosperity by making our area an attractive place to live, learn or do business; etc. A Nature Recovery Network would create inspirational landscapes in and around Cambridge which will continue to support its global reputation and image. Working with Cambridge Past, Present and Future and other conservation organisations we have started to pull together an evidence base for such a network in and around Cambridge. Following the principles of the Lawton Report and the government’s 25 Year Environment Plan (places for nature that are “Bigger, Better, Connected”) our approach is based on identifying areas on a ‘landscape scale’ that already have a core of habitats and / or where land is being actively managed for nature. This is still a work in progress and we will be sharing the interim and final outputs of this work with the Councils and submitting it as an evidence base for the Local Plan. However, our initial work has identified 5 priority areas that would form the basis for a “Cambridge Landscapes: Nature Recovery Network”, and these are illustrated and described below: Nature Recovery Network (NRN) – Priority Areas The survey of the green assets around the Cambridge area forms an evidence base on which five areas of focus for a potential Nature Recovery Network (NRN) within a 10km radius of Cambridge have been defined. Each is different in character and may ultimately produce very different opportunities in terms of the two strands of (1) creating habitat and biodiversity in order to enhance our landscape and combat the effects of climate change, and (2) providing natural greenspace for the residents of Cambridge and surrounds to engage with nature and receive benefits in terms of physical and mental health and well-being. The priority areas have been defined by studying landscape features such as the topography, underlying geology (both solid and drift), current habitat and land use, and past habitat and land use. Ownership of land has not been taken into account, but inevitably some land use follows ownership boundaries. 1. Gog Magog Hills This large area of approximately 25 Km2 south-east of Cambridge is defined by where the underlying chalk geology comes to the surface, which corresponds well to the 25m contour line. The southern boundary is marked by the A11, with the urban areas of Cambridge defining the northern boundary and the River Granta and riverside villages the western boundary. The area directly connects with both the Cambridge Fens and River Cam priority areas. It includes the chalk grassland SSSIs of Cherry Hinton Chalk Pits, Fleam Dyke, Gog Magogs golf course and Roman Road, as well as other Wildlife Sites and accessible natural greenspaces such as Wandlebury Country Park, Magog Down and Beechwoods LNR. 2. Wicken Fen vision The National Trust has a long-term vision to extend its Wicken Fen reserve southwards to the edge of the city of Cambridge, covering an area of 50 Km2. The southern part of this vision area provides a gateway from the city. This area has been defined by geographical constraints, with the A14 to the south (marking the northern edge of the city), the River Cam to the west (its own priority area), the B1102 to the east and an approximate distance of 10km from the city centre to the north. While the boundaries are geographical, the area itself is characterised by wet, clay soils. It lies beneath the 10m contour and the underlying geology is Cretaceous marly chalk. Quy Fen SSSI lies within the area showing the potential for the type of habitat which could be restored across it. Quy Water and the Bottisham Lode flow through this area. Further north, the fen peats come to the surface, forming a direct link to the core, northern part of the Wicken Fen vision area. 3. Cambridge Fens East of Cambridge, Fulbourn, Teversham and Wilbraham Fens mark the edge of the Fens landscape character area. Three SSSIs, Fulbourn Fen, Wilbraham Fen and Great Wilbraham Common form the core of this area, which connects then. The area is mainly defined by the 10m contour line in the north and 15m contour line to the south. It comprises both peat and Holocene river terrace gravel surface geology. The A14 forms the northern boundary, separating this area from the Wicken Fen vison south, while the villages of Teversham, the Wilbrahams and Fulbourn also form discrete boundaries being located on the higher ground. 4. River Cam corridor The River Cam, its floodplain and catchment tributaries including Bourn Brook, Cherry Hinton Brook, River Granta and the River Rhee. The corridor around these has been defined by both the topography of the adjacent land, including the floodplain and broadly following the 10m contour line, as well as the Holocene river deposits surface geology. The underlying geology is predominantly Cretaceous gault clay, though the River Granta from Babraham flows down on the Cretaceous marly chalk. The river itself is a wildlife site and it links a number of local wildlife sites, green spaces and historically important green spaces including Grantchester Meadows, the college Backs, many of Cambridge’s commons and Ditton Meadows, as well as several County or City Wildlife Sites such as Cherry Hinton Brook and Skater’s Meadow, LNRs such as Paradise and Bryon’s Pool and other more recently created strategic green space such as those at Trumpington Meadows and Hobson’s Park (Clay Farm). This area is also important in terms of providing accessible natural greenspaces for health and wellbeing. 5. Boulder clay and woodlands This large area of approximately 18 Km2 covers the higher ground (over 25m) to the west of Cambridge and sits upon the recent boulder clay deposits, which overlay the Cretaceous marly chalk and gault clay. Madingley Wood SSSI (an ancient woodland) lies on top of the hill and the ground conditions are conducive to woodland cover. The area extends down to the A428 and M11 in the north and east. The area includes or adjoins the Coton Countryside Reserve (CPPF), Burwash Manor Organic Farm and Lark Rise Farm (Countryside Restoration Trust), all of which are farms not only demonstrating wildlife-friendly practices, but also engaging with the public through a series of permissive footpaths. Thus, there is a great opportunity here to extend this network of wildlife-friendly farming practices, increasing the quantity and quality of accessible farmland and the hedgerow network. The Bin Brook passes through the area, and the Bourn Brook lies to the south. These connect this local landscape area to the strategic West Cambridgeshire Hundreds landscape to the west. In addition to the five priority areas listed above we are also looking at whether there could be an “opportunity area” to the north-west of Cambridge: Fen-edge orchards and droves The area of approximately 15km2 between Cottenham and Histon is completely devoid of any Public Rights of Way. In the past the area was a major producer of fruit, and was covered in orchards, a small number of which remain. This area is underlain by Jurassic and Cretaceous clays and sands, is mostly beneath the 10m contour line and is well drained by a series of ditches and drains, including Beach Ditch, a County Wildlife Site. This could be a strategic area to provide residents of Cottenham, Histon, Oakington, Rampton and Landbeach with an area of countryside to explore by a series of newly created pathways along ditches and old droves, which could be widened to provide wildlife corridors through the area for the benefit of the aquatic plants and animals. As such it could be considered as a “stepping stone” for nature between Cambridge and the wildlife rich areas in the Ouse Valley. It also connects to Northstowe and could provide an area of accessible countryside beyond the relatively constrained urban greenspaces of the new town. The condition of the remaining orchards would need to be assessed, but allowing public access into some of these would provide a link to the heritage of the area. Alternatively, there would be scope to create a number of community orchards, combining wildflower areas and orchard trees, including local varieties of which there are many that were developed in this area. Within each of these landscape-scale areas further work is now being carried out to identify more specific opportunities to create, expand and connect habitats and to ground truth these. We will also be looking at the connections between these landscape areas, to the wider Cambridgeshire strategic nature recovery network beyond, and to nearby smaller scale green infrastructure sites. The boundaries of the areas will therefore be subject to change. This work will be submitted to the Councils later this year and we believe that these opportunities should provide the focus for the future creation / investment in green infrastructure because they will deliver the maximum benefits for nature and people. They will inform the selection of green sites and wildlife habitats emerging from the “call for sites” in Q3. The Nature Recovery Network areas would not be giant parks or nature reserves. They would consist of groupings of individual parks, nature reserves and natural habitats that are linked together by wildlife friendly habitat and farmland. The majority of the land in these areas is farmed and is likely to stay that way during the period of the Local Plan, however there will be opportunities through the new Agriculture Bill to create areas of new habitat on farmland that can buffer, connect or provide stepping-stones between existing habitats. There will be the possibility to create new nature areas and green spaces in each of these landscapes through philanthropy, fund-raising, and carbon offsetting; and the development process / Local Plan should also play an important role in supporting this network, for example through biodiversity net gain, provision of strategic natural greenspace through developer contributions, and by ensuring that any green spaces being created as part of new developments link to and support the Nature Recovery Network wherever possible.

No choices made

All of the themes are interlinked, however, the natural environment forms the basis for all economic activity and life. Therefore biodiversity and green spaces and climate change must form the core component of future sustainable development. Restoring biodiversity will require better land management, which in turn will help to reduce carbon emissions. Restoring biodiversity also goes hand in hand with better soil management practices that can help lock up carbon, as well as ensure more sustainable agricultural land uses and food production. Making space for nature and better management of soils can also reduce flooding downstream and help water percolate back into the ground to replenish the chalk aquifer that provides much of our water. Future development must be within the capacity of the environment to support that development. A critical issue and potential major constraint to the stated ambition of doubling GVA, is the availability of water. At present current patterns of abstraction are unsustainable in that there is insufficient water provided to the natural environment, as evidenced by the parlous state of our chalk rivers and spring fed wetlands. Until this fundamental failing is addressed Cambridge cannot grow sustainably.

The key function of the Local Plan must be to ensure that jobs, housing and leisure are located in places that are accessible to people without having to rely on fossil fuel powered transport. The local plan must play its part in ensuring the highest standards of low or zero carbon and water efficient new buildings; supporting the provision of localised renewable energy networks, water supply and food production; minimising consumption and waste and maximising re-use and recycling. Providing space for nature and habitats (and not just tree planting) will also help to absorb carbon locally.

The consultation document correctly identifies most of the issues and measures that will need to be incorporated into the Local Plan. However, the only comment we would note is that tree planting locally will only form a small part of moving towards zero carbon. Protecting and restoring tropical rainforests would achieve far more carbon benefits than local afforestation. Tree planting with the right trees in the right places is good for many other reasons, but locally with respect to moving towards net zero carbon, the creation of large-scale wetland habitats in the fens, coupled with changes towards alternative farming methods including wet farming crops, could achieve much more by protecting and restoring peat soils than tree planting. In the move towards net zero carbon, the councils and new development should be supporting the priority fenland wetland creation initiatives in Cambridgeshire at Wicken Fen, the Great Fen and adjacent to the Ouse Washes. These will also have wider benefits for biodiversity, flooding and water resource management and health and wellbeing.

Yes, strongly agree

The Wildlife Trust strongly agrees with this approach and the issues identified. Urban areas must be designed to be cooler without energy intensive air conditioning systems, so the inclusion of natural vegetation, trees, and green roofs and walls must become standard practice. These features will also need to be retrofitted to existing urban areas. Sustainable urban drainage systems must work to ensure water is recharged to the ground and aquifer (without causing flooding), but should make provision for grey water systems for non-potable water uses, to reduce the currently unsustainable abstraction of water. New buildings must be designed to use no more than 75 to 80 litres of clean water per person per day.

The following aspects are all relevant to achieving this aim: • The identification of a Nature Recovery Network for the Greater Cambridge area, with this network being explicitly mapped in the local plan, with linkages to neighbouring authorities clearly shown. The Nature Recovery Network should guide the location of all future development so that any new development (not just in the next Local Plan period, but all future plan periods) is located where it does not compromise, damage or fragment the nature network. We have described our emerging work to identify the components of this network in our response to Q6. • All new development should achieve a measurable 20% net gain in biodiversity. New habitats should be created in places that help deliver the Nature Recovery Network. • The Local Plan should provide for the creation of a significant area of new strategic natural greenspace, including large-scale habitat creation. This will make a major contribution to the “Doubling Nature” vision for Cambridgeshire, for which thousands of hectares of new habitats and wildlife-rich green spaces will be required. Several areas should be planned, located where they will provide the natural space for the current and future population, create inspirational landscapes in and around Cambridge, and support the Nature Recovery Network and doubling nature vision. While many of these will be within the Greater Cambridge area, it might also be appropriate to support some of the strategically important areas in the fens and Ouse Valley, including Wicken Fen, Ouse Washes and Great Fen, as these will also be destination sites for residents of the Greater Cambridge area. • Tree planting and woodland / tree cover should be increased, but be based on the principle of the “right tree in the right location”. Increased tree cover can help cool urban areas, reduce air pollution and improve the urban landscape. Woodland creation can provide both new habitats for wildlife and natural greenspaces for access and recreation. Natural regeneration should form a significant element of woodland creation, and tree planting should not occur on important wildlife sites where grassland and / or wetland habitats are important for species of more open habitats. • All new development should have the highest standards of water efficiency and minimise use of water from the chalk aquifer. New developments should also incorporate sustainable urban drainage systems to help water percolate back into the soil and recharge the aquifer, as well as avoid exacerbating flooding elsewhere.

The Issues & Options consultation correctly identifies many of the issues. Cambridgeshire and the Greater Cambridge area has a deficit in strategic accessible natural greenspace, not having any large areas of open access, downland, moorland or coast on the doorstep. The table in appendix 1 of our response shows a high level analysis by county of green infrastructure and particularly accessible natural greenspace (data from national open data sources, except Local Wildlife Sites information from The Wildlife Trusts). This shows that Cambridgeshire is near the bottom of the table for most categories, including open access land, designated nature conservation sites and priority woodland habitats. Further, the Wildlife Trust has estimated that since 2001, taking into account completed developments and current Local Plan allocations, there will be an accumulated deficit in strategic natural greenspace provision in the county in the order of 600 Ha. This is without considering any increased growth rates as being discussed in the current Issues and Options consultation. (Note: This calculation was based on applying the Natural England standard for Suitable Alternative Natural Greenspace of 8 Ha per 1000 population to growth since 2001). Improving the green space network links closely with the Nature Recovery Network that we are proposing to help achieve the doubling nature vision, and providing strategic and local green spaces will form one part of delivering the Nature Recovery Network. Major developments (large urban extensions and new settlements) have generally been providing sufficient green spaces for their new populations, however, this has not addressed the historic accumulated deficit or the needs for the larger number of small and medium sized developments. The Local Plan needs to find a mechanism to deliver sufficient strategic natural green spaces to cater for the growing population from all developments, as well as make up for the historic shortfalls. Without this the current damaging human recreational pressures being recorded on a number of nationally and internationally important nature sites will be exacerbated. All major new developments should be aiming to provide at least 50% green infrastructure, or 40% on site with the remainder off-site. The exact quantum of provision needs further assessment and this must be included within the Greater Cambridge Planning Authorities own green infrastructure evidence base. A policy requirement will be needed to cover provision of Suitable Alternative Natural Greenspace, at sufficient levels to meet the needs of all future development and to address the historic shortfalls. It is likely that a significant proportion of this will need to be provided off-site and this should align with and support delivery of the Nature Recovery Network. The off-site provision may be combined with the Biodiversity Net Gain requirements in some instances, however this won’t always be appropriate as open access may compromise the creation of some high quality habitats and be incompatible with the conservation of some priority species. The new Local Plan must not just provide strategic natural greenspaces, it must also ensure that sufficient local green spaces are provided so that everyone has somewhere within walking distance of their home, as this has the highest benefits in terms of physical and mental health and wellbeing. Where local green spaces have a natural component they will also contribute to the Nature Recovery Network and other wider natural capital benefits. There are parts of Cambridge City and also some villages that have a deficit in local green spaces and the Local Plan must also make active provision to remedy these deficiencies. Achieving Biodiversity Net Gain on New Developments As already mentioned, the Wildlife Trust believes that Greater Cambridge should set a policy requirement for a minimum of 20% biodiversity net gain from new development (excluding householder applications). This is required because of the general impoverishment in biodiversity of the Greater Cambridge area, caused largely by the intensive agriculture practised across most of the area, but also as a result of past development. Cambridgeshire has a much lower percentage of natural habitats than most lowland counties, hence the doubling nature vision that has now been adopted by local councils. A 20% net gain will be required to make a measurable contribution to the doubling nature vision from new development. It is also required, because the way that biodiversity metrics operate, a 10% net gain is easily within the margins of error.