Greater Cambridge Local Plan Issues & Options 2020

We question whether high levels of growth are compatible with addressing climate change. The most effective way the Local Plan can help achieve net zero carbon is to limit growth to sustainable levels. As a society, until we are able to build and sustain carbon neutral communities, high levels of growth will result in higher levels of carbon and make it harder to achieve net zero carbon by 2050. • Building on greenfield sites or farmland will reduce the capacity for carbon sequestration and should thus be avoided. The loss of quality agricultural land means more food has to be imported into the UK, or more intensive farming techniques will need to be employed to make up the shortfall – both of which would increase carbon emissions. • The consultation emphasises the need for new development to be “carbon-neutral”. This can be misleading in that it implies some equality in carbon input in energy supply with carbon emissions. However, the creation and maintenance of a new development can have carbon consequences just as great as energy efficiency. What is needed is a Total Carbon Budget for a development, including the embedded carbon captured in materials, transport and construction emissions. All new developments should be required to provide a Circular Economy Statement as has recently been introduced to the London Plan, in order to address the embedded carbon within existing buildings and ensure that new buildings could be easily recycled in future. • Proposals for adaptation and retrofit of the existing building stock should also be on a “whole life” basis, minimising embedded carbon. The Local Plan’s 2040 horizon is 10 years beyond current Government Clean Growth Strategy targets for retrofitting dwellings to Band C. There are serious practical issues as well as major townscape implications involved in trying to meet these targets, plus skills and knowledge issues in relation to buildings of traditional construction (almost all pre-1919 buildings, and many between 1919 and 1939). There have been well-documented cases across the UK where well-intentioned but inappropriate measures have led to waste of money (and carbon). Balances need to be struck between short term measures and longer term “deep retrofits” (which may require costly undoing of previously installed measures. The Plan needs to take a strategic approach to these challenges. • Carbon sequestration will obviously be an important mitigation factor in Greater Cambridge yet it receives little consideration. Sequestration is more than just tree planting as there are other carbon sinks, like soil. Natural grassland is actually a better carbon sink than most forms of woodland because of the substantial below ground storage. • Electricity charging points for electric vehicles should be mandated for all new developments. Utility gas should not be installed in new developments. • New developments should be conceived so that residents can if they choose be car free. This involves consideration of the location of development, provision of services and infrastructure for walking, cycling and public transport. • For large developments either ground source, air source, or communal heating should be prioritised. • In the spatial planning of new developments, the Councils seem to feel that there is an inherent need to minimise the movement between jobs and homes so as to reduce vehicle emissions, but this is very difficult to resolve in a highly mobile society. Our view is that colocating housing and employment may be a useful theory in determining spatial planning but in practice it has relatively limited relevance. It may work in certain situations, such as in large new high-density mixed developments in the urban area, where employment uses would help to support community services such as shops. An example would be Cambridge North East Fringe or Cambridge Airport. However, research into the Cambridge Phenomenon found that workers change jobs regularly, but not their housing – this means that even if workers live close to their employer initially, over time they would commute elsewhere to work. Therefore, in our view, the availability of good public transport or cycle infrastructure is more important for determining new housing and employment locations. • Supporting working from home is one way that the need for travel can be reduced, and this can also support more vibrant communities. We would like to see policies in the Local Plan that encourage home working, for example new houses to be designed so that home offices can be created by occupants. • The Local Plan is constrained by national planning policy, guidance and regulations. It is clear that many of these are not capable of delivering net zero carbon by 2050. We believe that it would be politically difficult for national government to prevent a local authority from proposing local policies or targets that could achieve net zero carbon – even if they are not supported by national policy. We would encourage the councils to be brave and show leadership, and if necessary, challenge national government.

Over the next decade, new approaches and technologies will be developed that will enable developments to better reduce their climate impact. It is also likely that national targets for this will become more stringent. Given that the Local Plan is proposed to cover the period to 2040, the Plan will need to be flexible enough to be able to encourage these new features as and when they become available. This could be achieved by continually updating SPDs (such as the Sustainable Design & Construction SPD, which we support) or alternatively, policy wording could refer to “best practice” or “highest standards”. As a centre for research and new thinking, we feel that Greater Cambridge should be at the forefront of adopting such practices and therefore we want to see a Local Plan that will encourage the Greater Cambridge construction industry to test new ideas and be early adopters. All new public buildings should be developed and constructed to achieve the BREEAM Certification of Excellence. The Government is currently undertaking a Consultation on Future Homes Standards, and the relevant high standard arising from this exercise should be applied initially. • Food security and reducing carbon emissions is a priority that requires quality farm land to be retained as farm land. Building on productive local farm land can result in more food imports and carbon emissions through transportation. Release of the most productive farm land for construction should be avoided. • We would like to see large new developments laid-out in ways which prioritise cycling, walking and public transport rather than private vehicles. There are examples from the Netherlands of housing estates laid out in this way, such as Houten (https://itdpdotorg.wpengine.com/wpcontent/uploads/2014/07/22.-092211_ITDP_NED_Desktop_Houten.pdf). Such developments are also usually much more community-oriented. Most developers do not want to include measures to reduce car use as they see easy car access as a selling-point for their properties, so how can the Local Plan bring about change in this regard? • Adapting to climate change cannot be achieved without co-ordination of planning across many areas. Transportation and utilities infrastructure must be joined up with buildings and construction. • Consideration needs to be given to existing housing stock and commercial premises, which make up the majority of buildings. How can the Local Plan or the Councils support property owners to retro-fit their buildings so they can use electricity and be more energy efficient? • Discouraging the use of gardens as development sites would assist carbon sequestration. Urban greenspace, including gardens, are important for urban biodiversity, water absorption, urban cooling, and carbon offsetting (trees and vegetation). Gardens and allotments are important for the health and wellbeing of residents. The Councils’ policy to prevent “garden grabbing” needs more rigorous enforcement, and the provision of more allotments associated with major new developments should be encouraged. • Consideration needs to be given to existing housing stock and commercial premises, which make up the majority of buildings, and which will be subject to Government retrofit targets. Current 2030 Clean Growth Strategy targets for as many buildings as possible to reach EPC Band C by 2030, and Minimum Energy Efficiency Standard requirements for all private rented sector buildings could have a massive impact on the character of Greater Cambridge’s buildings and places. The choices made on what measures to take, and how, will be crucial to minimising harm to valued places, streetscapes and buildings. The Plan needs to tackle these issues. • The Local Plan should seek appropriate balances between heritage significance and climate change mitigation and adaptation. Building owners should be encouraged to keep their buildings in good repair, and to improve their efficiency as far as is compatible with their character and their fabric. There will be many and sometimes very difficult choices, which need to be made on well-informed basis with a clear assessment of the issues and balances involved. Some recent cases (New Court, Trinity College, and 1 Regent Street) highlight an urgent need for owners, agents, Planning Committee members and the public to be more informed about the issues at both individual building level, and in terms of the cumulative impacts on the character of Cambridge. The Local Plan and the Councils will need to support and help guide these choices. While helpful free guidance to private sector Landlords is available (at https://www.gov.uk/guidance/domestic-private-rented-property-minimum-energyefficiency-standard-landlord-guidance, and similarly for non-domestic), the Government’s guidance on the vast majority of the work is only being published through the British Standards Institute, at exorbitant cost. Government advice on domestic retrofits is given in PAS (Publicly Available Specification) 2035:2019.energy efficiency – Specification and guidance; PAS 2038, now in preparation will cover non-domestic buildings. • Consideration needs to be given in the Plan to both requiring projects to comply with these standards, and publicising their advice and requirements in accessible, user-friendly form. See also advice available from the Sustainable Traditional Building Alliance stbauk.org. • A vital aspect of PAS 2035, and the forthcoming PAS 2038, is that they promote and define high-quality retrofit that supports, among a range of criteria, “protection and enhancement of the architectural and cultural heritage as represented by the building stock”. Appropriate balances have to be struck between energy efficiency improvements and preservation and enhancement of the heritage. We commend the principles set out in Parts L1B and L2B of the Building Regulations, which promote energy efficiency actions, insofar as they can be achieved without damage to the character or fabric of buildings of historic or breathable construction. {FULL EXTRACT FROM PAS 2035:2019: “0.1 Context 0.1.1 Statutory national targets for the reduction of greenhouse gas emissions in response to the threat of climate change imply that very significant improvements need to be made in the energy efficiency of the UK’s building stock, including nearly all its 27 million domestic buildings. ….. This PAS supports work towards those objectives by promoting and defining technically robust and responsible “whole-building” domestic retrofit work, i.e. high-quality work, that supports: • improved functionality, usability and durability of buildings; • improved comfort, health and well-being of building occupants and visitors; • improved energy efficiency, leading to reduced fuel use, fuel costs and pollution (especially greenhouse gas emissions associated with energy use); • reduced environmental impacts of buildings; • protection and enhancement of the architectural and cultural heritage as represented by the building stock; • avoidance of unintended consequences related to any of the above; • minimization of the “performance gap” that occurs when reductions in fuel use, fuel cost and carbon dioxide emissions are not as large as intended or predicted. 0.1.2 The requirements and guidance presented in this PAS are intended to apply to improvement measures in the context of a holistic approach to retrofit that takes the points listed above into account. The holistic approach considers the building as a system of elements, interfaces and occupants that interact, and not as a set of elements that are independent of each other or of occupants’ practices and lifestyle. “} • Further key guidance for work to older buildings is provided in British Standard BS 7913:2013: “ The most effective way of ensuring energy efficiency and sustainability is to keep historic buildings in good repair so that they last as long as possible, do not need replacement and do not suffer from avoidable decay that would require energy and carbon to rectify……. Elements such as walls can be over a third less energy efficient if damp…” • Buildings of traditional solid wall construction (pre 1919, and many pre 1939) will require a different approach to more modern (cavity wall) construction. Retrofit measures suitable for modern buildings may be wholly unsuitable for these older buildings which perform very differently in terms of moisture. Ill-chosen retrofit measures can waste both money and carbon on both the original and subsequent remedial works (see, e.g., FIshwyck, Preston. • There are very serious shortages of traditional building repair and refurbishment knowledge and skills, due to the construction industry’s long-term failure to provide training in them on the scale needed. This skills shortage now seriously risks compromising retrofit efforts, and the Local Plan should seek to encourage local development and dissemination of the skills needed. The Colleges and other owners of historic building estates could play a part in a strategy for developing skills. What is equally urgently needed is increasing the capacity and availability of conservation staff to provide vital impartial advice. • Whole life carbon is a key issue for both new buildings and retrofits, and repairs, e.g. using cement mortar prevents re-use of carbon-intensive fired and quarried materials. A circular economy approach should be encouraged, with whole-life audits for retrofit projects as per BS EN 15978:2011. Taking all these factors into consideration, a baseline assessment of the implications, for Cambridge’s historic environment, of current Government retrofit targets is urgently needed.

Yes, strongly agree

CambridgePPF strongly agrees that additional resilience features for new developments are essential if climate change is to be tackled. • The Local Plan must be sufficiently flexible that it can accommodate the latest technologies and mechanisms to improvements in resilience to climate change – see our response to Q9. Greater Cambridge should be at the forefront of adopting such practices and therefore we want to see a Local Plan that will encourage the construction industry to be early adopters. • Water resource use will be critical for Cambridge if our rivers and wetlands are to support wildlife. We would like to see the highest standards of water efficiency and grey water recycling in all new developments with the aim that water use be reduced to below 80 litres per day per person. We would like the standards set at Eddington to become the new normal for Greater Cambridge. • The Local Plan should encourage a standard of building design and layout that provides efficient insulation to minimise the need both for excessive use of air conditioning in summer and central heating in winter. The provision of large trees can shade buildings, pavements and gardens. • If sea level rises and extreme weather events occur, as some scientists are predicting, then it is likely that new areas may become prone to flooding. This in turn means that the flood zone maps will need to be re-drawn in the coming decades. The Environment Agency will be responsible for this future modelling and its latest information must be incorporated in the Councils’ planning decisions. If this is not possible then the Councils should carry out a future modelling assessment of the flood risk for all new large development sites proposed for the Local Plan. The Plan should include a Policy requiring applicants for all new developments (even in flood zone 1) to submit a statement of possible flood risk based on future climate predictions. Land identified as at risk of future flooding could be considered for biodiversity creation, woodland planting, etc

All new developments should as part of their planning application include a full Carbon Budget. This should cover not just the annual emissions following completion, but also the embedded carbon in the materials, transport, and construction. The master-planning of major developments must include data on the carbon savings and emissions that can be expected from the scheme over its lifetime. A Red/Amber/Green rating should be allocated by officers based on the carbon budget to alert Councillors to the carbon implications arising from the proposal • Major schemes should produce Whole-Life Carbon Assessments that address all impacts associated with the construction, operation, and demolition of buildings and infrastructure. The UK construction industry, a sector known for its resistance to change and for poor collaboration, has seen the recent introduction of several important climate initiatives, such as the London Energy Transformation Initiative (LETI) Energy Design Guide. This sets out the practical steps for the built environment to achieve net zero-carbon by 2050. LETI has also just released its Climate Emergency Design Guide which presents targets for new buildings to achieve net zero by 2030. The Councils should strive to incorporate these standards and targets into all new building design. However, they cannot be considered in isolation but as a core part of the Whole-Life Carbon approach. Many leading construction companies have now committed to either the Better Buildings Partnership or the UK’s industry-wide campaign, Advancing Net Zero. Developers supporting these initiatives should be favoured. • Carbon savings can be achieved by maximising use of existing developed areas before commencing development in new locations. There are several science, technology, and commercial parks in the areas around Cambridge which are not fully developed or where densification is practical.

We believe that the Local Plan should identify, describe and map a 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 wellbeing; 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 the Wildlife Trust 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”, these are illustrated and described below: Nature Recovery Network – Priority Areas (NRN) The survey of the green assets around the Cambridge area forms an evidence base on which five areas of focus for potential Nature Recovery Networks (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 well-being. The broad 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 NRNs. 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 NRN 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 15 m 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. This area is also significantly important in terms of providing natural greenspace 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 Country 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 wildlifefriendly farming practices, increasing the quantity and quality of 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 NRN to the west. In addition to the five 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 is a strategic area to provide residents of Cottenham, Histon, Oakington, Rampton and Landbeach 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 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. Work will also be looking at the connections between these landscape areas and with adjacent or smaller scale green infrastructure. This work will be submitted to the Councils later this year. 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. 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 developer contributions/biodiversity net gain and by ensuring that any green spaces being created by new developments link to and support the Nature Recovery Network wherever possible. In addition to the Nature Recovery Network we also propose the following measures to help improve the natural environment: • 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 (see above). • Policies which ensure the highest standards of water efficiency and minimise use of water from the chalk aquifer.

The Issues & Options consultation identifies many of the issues and we are supportive of what the Councils are already doing and strongly support the Local Nature Partnership’s vision to double the area of rich wildlife habitats and natural greenspace by 2050. However, 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. 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 further growth beyond 2040 (or above current growth rates). This calculation is based on applying the Natural England standard for Suitable Alternative Natural Greenspace of 8 Ha per 1000 population to growth since 2001. Major developments (large urban extensions and new settlements) have generally been providing sufficient green spaces for their developments, however, this has not addressed the historic accumulated deficit. Unfortunately, small and medium sized developments are not providing sufficient strategic open space and so cumulatively they are exacerbating the deficit. Whilst it is essential for people to have green space close to their homes it is inevitable that when they want to take a longer period of well-being activity (such as a walk, cycle ride, picnic with family, nature watching, etc) that they will need/want access to large open spaces which Cambridgeshire is deficient in. This deficit also has implications for biodiversity and may help explain why Cambridgeshire has one of the lowest amounts of land in the UK that is rich wildlife habitat and natural greenspace. Indeed, doubling the amount would only bring Cambridgeshire up to the average for the UK. This deficit also has other implications, one of which is visitor pressure and disturbance at those sites that already exist. This is causing damage to natural and built heritage at some of these locations. The deficit will also be impacting on health and well-being because people find it harder to access, because it is further away or because when they get there it is full (there are several times a year when we have to turn people away from Wandlebury Country Park because it is full). The Local Plan needs to find a mechanism to deliver sufficient strategic natural green spaces to address the current deficit and cater for the growing population. Without this the current damaging human recreational pressures being recorded on a number of nationally and internationally important nature sites will be exacerbated. Would it be possible to use a CIL to ensure that all new developments contribute towards creating more strategic natural greenspace capacity? In terms of where this strategic natural greenspace should be, we believe that this should form part of the Nature Recovery Network that we have proposed in our answer to Question 12. This would ensure that limited resources achieve the maximum benefits for both people and nature.

We would like to see the Local Plan support greater use of the Developing with Nature Toolkit. Could planning applications be required to include a completed toolkit score sheet? Or could those applicants that complete the toolkit and achieve a high score be looked upon favourably? • We believe 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 for two main reasons: i. the way that biodiversity metrics operate, a 10% net gain is within the 10% margin of error for creating replacement habitat, meaning that in reality there may be no actual gain when it is delivered. This is the main reason why there has been a change in National Planning Policy because the previous “no net loss” policy was in some cases delivering a 10% loss. In effect, a 10% net-gain policy does not guarantee an actual 10% gain in biodiversity. In order to guarantee a 10% net gain would require a 20% net gain policy. ii. because of the general impoverishment in biodiversity of the Greater Cambridge area, caused largely by the intensive agriculture, but also as a result of past development. Cambridgeshire has a much lower percentage of natural habitats than most lowland counties. In order to deliver the vision to double nature that has been adopted by the local councils a 20% net gain will be required to make a measurable contribution. The Greater Cambridge planning authority will need to identify a Nature Recovery Network within the Local Plan but should also prepare a Nature Recovery (or Biodiversity & Green Infrastructure) Strategy that supports this (either as a full Development Plan Document or a Supplementary Planning Document). We have suggested a nature recovery network for Cambridge in our answer to question 12. The development process/Local Plan should play an important role in supporting this network, for example through developer contributions/biodiversity net gain and by ensuring that any green spaces being created by new developments link to and support the Nature Recovery Network wherever possible. • There is a debate to be had about whether better biodiversity gains could be achieved through off-site biodiversity off-setting versus delivering them on-site. For example, evidence has shown that on-site habitat creation for Great Crested Newts has often been unsuccessful and as a consequence a new system is being introduced that will use developer contributions to create new habitat off-site. The well-being benefits to the new residents of on-site biodiversity provision (which also makes more attractive developments which uplift sales prices) needs to be weighed-up against off-setting nearby where greater biodiversity benefits can be achieved. This is likely to be more of an issue for small/medium sized developments that often find it difficult to include suitable space on the development site. • One problem of biodiversity offsetting is that the results are often not known for years (think how long it takes a tree to mature) and sometimes fail (ponds without water for example). There is no mechanism for redressing this and therefore no incentive (other than a moral one) for developers to get it right. The Local Plan should include a mechanism to record and monitor implementation of the biodiversity net gain system and the delivery of both on-site and off-site habitat creation. • We would encourage the Local Plan to promote landscape design that supports greater biodiversity. This requires a culture change within the development sector and also from the house-buying public in order to accept such changes. For example, to recognise that meadows or rough grassland have much greater benefits than amenity grassland, even if at certain times of the year that means they look ‘untidy’. That gaps in garden fencing are essential for the movement of animals such as hedgehogs. This is already changing but we would encourage the Local Plan to do what is possible to make this mainstream. Not only is this better for wildlife but it should be much more cost-effective to have a meadow which is cut once or twice a year than amenity grassland which is cut regularly. There are some trends that we are seeing in new developments which are not helpful to biodiversity and which it would be helpful if the Local Plan could address: i. The provision of bird and bat boxes without consideration of whether there is already sufficient provision of these in the neighbourhood or whether there is suitable habitat to support the species that these boxes have been put up for. We have seen developments/applications where this is not the case. Boxes do not provide the habitat that species need to survive (ie food). If there is not sufficient habitat or there are already boxes in place then putting up boxes on new developments is a waste of time/money. We would like to see the Local Plan (or any associated SPD) place greater emphasis on habitat creation. ii. Sustainable Urban Drainage Schemes are moving away from being ponds (ie holding permanent water) to becoming swales (ie not holding permanent water). We suspect this is because swales are easier to create and maintain and have lower health & safety risks. However permanent ponds provide much richer wildlife diversity and are increasingly important in helping species during extreme weather (especially heat and drought). We would like the Local Plan to support SUDS that include at least some permanent water. iii. The creation of habitats on developments sites that are surrounded by roads or buildings, making it dangerous or very difficult for creatures to get to, or leave. Habitats should be linked within and through development sites for ecological connectivity – or located on the edge of the development site if they are adjacent to green space/countryside.

Yes, strongly agree

CambridgePPF agrees with this proposal but with some caveats: • Tree planting must be in selected locations and should not be adopted as a blanket approach across the landscape – we need the right trees in the right places. For example: - tree planting should not take place on natural grasslands and other important ecological habitats. Meadows have declined by over 97% in the past 100 years and are a more threatened habitat than woodland. Natural grasslands are just as effective as woodland in fixing carbon through underground storage. - tree planting should be targeted at locations where it can expand or connect existing woodlands to provide wildlife corridors. This will achieve the biggest benefit for wildlife and is line with both the DEFRA 25 Year Environment Plan and the findings of the Lawton Report. • Biodiversity opportunity mapping is currently being undertaken by a consortium of local environmental organisations, including CambridgePPF, to identify locations where planting would improve woodland connectivity and generate a landscape more resilient to climate change. The Councils should use this approach as a basis for targeting new woodland creation. See our answer to Question 12. • The high values of productive farmland will mean that there are limited opportunities in South Cambridgeshire to convert agricultural land unless public funds are invested. The main opportunities arise in relation to new developments, both on-site and off-site, small copses for wildlife habitat, road verges, hedgerow trees and field margins. House owners should be encouraged to plant trees in their gardens and employees in their workplaces. • When planting new woodland, consideration should be given to: - avoiding the creation of large isolated blocks - using native and wildlife friendly species - using species that may prove to be more resilient to climate change - using a provenance of tree species that has demonstrated resistance to known speciesspecific diseases. • Carbon offsetting through tree planting will be needed to make a significant contribution to the net zero-carbon target. Tree planting will also contribute to the creation of green public space, gain in biodiversity, improvements to air quality, potentially flood alleviation, and improvements to water quality.

CambridgePPF believes that “wellbeing” is too narrowly health-focused and that “quality-oflife” would have been a better term to use because it covers a broader range of community requirements which contribute towards wellbeing, such as access to good schools, medical services, green spaces, and sports facilities – see our response to Q6. • All large developments should be required to meet the standards set out in the revised Cambridgeshire Quality Charter for Growth. • A key requirement for any major new development is to ensure that the essential infrastructure and services to support a viable community are in place when the first properties are occupied. Adding services and facilities in a piecemeal way in the later phases of the development will create a beleaguered community that precludes wellbeing and social harmony – ie don’t repeat what happened at Cambourne.

Set out expected requirements or standards of community engagement at the pre-application stage to encourage public engagement. The standards would be scaled according to the size of the development. • Look favourably upon applications where the developer can demonstrate they have met preapplication engagement requirements. Applications that can demonstrate that they have responded to the feedback from the community in a significant way should also be favoured. • Applications should conform with Design Guides and plans which have been created by the local community, such as Village Design Guides and Neighbourhood Plans. Introduce a programme for all villages/parishes/neighbourhoods to produce a design guide, neighbourhood plan or Conservation Area Appraisal if relevant. • Policy statements in the plan should afford sufficient weight to design guides or neighbourhood plans that have been created by the community (eg by considering them as SPDs), such that applications that do not conform can be turned down without risk of appeal. • Changes should be introduced to the planning process that will encourage greater community engagement. For example: - community groups being allowed to speak at planning committee for longer - the current 3 minutes in total for all community representatives is quite frankly ridiculous and is the kind of thing which makes communities feel that the system is stacked against them. - the on-line system should be improved to make it easier for residents to be made aware of applications and to understand them. Community groups do not have the resources to wade through hundreds of documents and thousands of pages of technical information. For every application we would like to see a summary document produced by planning officers which includes location, drawings, summarises the development, highlights potential planning issues, and signposts to those documents which may be of particular relevance to the community. - introduce an automated notification system that would enable community groups to check-list criteria and receive email notifications of any applications which match that criteria (eg location, size, type, etc). • For large developments requiring a masterplan we would like to see public-friendly, planningfor-real style workshops take place. These should seek to engage the types of people who would be likely to move into the new development.