Greater Cambridge Local Plan Issues & Options 2020

Thank you for consulting Natural England on the above in your email of 20 December 2019. Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development. We support Cambridge City and South Cambridgeshire District Councils’ preparation of a joint Local Plan to ensure a consistent approach to planning across the Greater Cambridge area, with policies aligned with the revised National Planning Policy Framework (NPPF). We welcome the evidence being gathered to inform preparation of the Plan including further research on responding to climate change and the transition to net zero carbon, green infrastructure and biodiversity net gain, landscape and Habitats Regulations Assessment (HRA). The Councils continue to engage with Natural England in the preparation of the relevant aspects of the evidence base and we will be pleased to review and provide comments on the draft documents in due course.

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Q1 and Q5 Stakeholder engagement and cross-boundary issues We support the Councils’ approach to stakeholder engagement and consideration of cross boundary projects including Oxford-Cambridge Arc, the Combined Authority Strategies, Greater Cambridge Partnership, County strategies and neighbouring Local Authorities. Natural England is satisfied that the Councils’ approach meets the relevant duty to cooperate requirements. We agree with the key cross-boundary issues identified including wildlife and green infrastructure, transport and water including supply, quality, waste water and flood risk. The Local Plan will need to take a strategic approach to these issues to ensure that the proposed scale of development is sustainable and will not adversely impact the natural environment. In particular the Local Plan should promote the delivery of a strategic green infrastructure network that is resilient to the scale of development proposed, capable of protecting designated sites and supporting habitat, and delivering the wider range of environmental services to meet development needs. This will require the delivery of a strategic GI network that contributes towards and complements the enhancement objectives of cross-boundary projects such as the Ox-Cam Arc Local Natural Capital Plan and landscape-scale priority areas such as the West Cambridgeshire Hundreds, Cambridgeshire Fens, the Chalk & Chilterns and the National Trust’s Wicken Fen Vision Area.

Nothing chosen

Q1 and Q5 Stakeholder engagement and cross-boundary issues We support the Councils’ approach to stakeholder engagement and consideration of cross boundary projects including Oxford-Cambridge Arc, the Combined Authority Strategies, Greater Cambridge Partnership, County strategies and neighbouring Local Authorities. Natural England is satisfied that the Councils’ approach meets the relevant duty to cooperate requirements. We agree with the key cross-boundary issues identified including wildlife and green infrastructure, transport and water including supply, quality, waste water and flood risk. The Local Plan will need to take a strategic approach to these issues to ensure that the proposed scale of development is sustainable and will not adversely impact the natural environment. In particular the Local Plan should promote the delivery of a strategic green infrastructure network that is resilient to the scale of development proposed, capable of protecting designated sites and supporting habitat, and delivering the wider range of environmental services to meet development needs. This will require the delivery of a strategic GI network that contributes towards and complements the enhancement objectives of cross-boundary projects such as the Ox-Cam Arc Local Natural Capital Plan and landscape-scale priority areas such as the West Cambridgeshire Hundreds, Cambridgeshire Fens, the Chalk & Chilterns and the National Trust’s Wicken Fen Vision Area.

Q2. Whilst Natural England is unable to put forward any sites for consideration we would welcome the opportunity to provide early advice on any proposals for greenspace and wildlife habitat creation e.g. with regard to potential opportunities for enhancement. We have provided some advice on the assessment of sites submitted for consideration as development or greenspace allocations at the end of Annex B.

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Q6 and Q7 the ‘big themes’ The Councils’ visions seem appropriate and aligned with the three pillars of sustainable development. In our view the Plan’s vision should be focused around the ‘big themes’ identified to influence how homes, jobs and infrastructure will be planned over the period to 2040, including climate change, biodiversity and green spaces, wellbeing and social inclusion. We support the big themes and note that they are strongly inter-related and are dependent upon a healthy and resilient natural environment. On this basis the overarching vision for the Plan should be the protection and enhancement of the natural environment, to deliver multi-functional benefits for people and wildlife, including biodiversity net gain, enhanced green infrastructure, soils, geodiversity & landscape, health & wellbeing, sustainable drainage and mitigation & adaptation to climate change.

No choices made

The Councils’ visions seem appropriate and aligned with the three pillars of sustainable development. In our view the Plan’s vision should be focused around the ‘big themes’ identified to influence how homes, jobs and infrastructure will be planned over the period to 2040, including climate change, biodiversity and green spaces, wellbeing and social inclusion. We support the big themes and note that they are strongly inter-related and are dependent upon a healthy and resilient natural environment. On this basis the overarching vision for the Plan should be the protection and enhancement of the natural environment, to deliver multi-functional benefits for people and wildlife, including biodiversity net gain, enhanced green infrastructure, soils, geodiversity & landscape, health & wellbeing, sustainable drainage and mitigation & adaptation to climate change.

We support the Councils’ recognition of the severity of the climate change issue and recognition of the key issues and challenges of reducing our climate impact and the need to adapt to more extreme weather, a hotter climate and a changing ecology. We support key actions to address climate change including:  Using renewable and low carbon energy generation;  Promoting sustainable travel and discouraging car use where possible;  Retrofitting existing buildings;  Rooftop greening – this could be extended to generally extending and enhancing the ecological network We generally support the promotion of climate change adaptation measures including:  Managing flood risk and incorporating SUDS;  Increasing biodiversity and tree planting;  Improving water efficiency. The Plan should prioritise avoiding key factors contributing to climate change (through more greenhouse gases) e.g. pollution, habitat fragmentation, loss of biodiversity and to protecting and enhancing the natural environment’s resilience to change. Green Infrastructure and resilient ecological networks play an important role in aiding climate change adaptation. Development should be located and designed to remove/reduce reliance on car travel, promoting sustainable travel to improve air quality and its contribution to climate change. Development should incorporate multi-functional sustainable drainage and flood risk management measures in accordance with the SPD. Plan policies should focus on securing implementation of an enhanced and extended ecological network that will deliver climate change mitigation in addition to wider environmental services. This should be delivered through appropriate policy requirements. We are aware that an Integrated Water Management Study, incorporating a Water Cycle Study and Strategic Flood Risk Assessment, is being progressed as a key evidence document to inform preparation of the Local Plan. We welcome this and urge for a strong focus /recommendation for the implementation of integrated drainage including multi-functional SUDs in all development, where possible. It should also identify and promote delivery of benefits and opportunities associated with climate change, for example to create more extensive wetland habitats and to protect and enhance the degraded peat soils remaining in the Greater Cambridge area. Without appropriate measures new development will harm Greater Cambridge’s natural natural Page 3 of 15 environment. Measures to avoid impacts must be prioritised. Cambridgeshire is especially dependent on its groundwater which is currently being pumped dry with knock-on effects for the natural environment including water quality and biodiversity. In addition to new buildings climate change requires retrofitting of existing buildings. Revised and more ambitious water consumption targets are also needed. The Plan should include appropriate policies to secure delivery of the recommendations identified through the Integrated Water Study. We would also advise that consideration be given to updating the existing Flood and Water Supplementary Planning Document to reflect current BNG and climate / net zero carbon targets. The Local Plan and relevant policies should reflect the importance of remaining peat soils as a significant carbon store that can help to improve air quality and mitigate against climate change. The development strategy and relevant policies should seek to protect Best and Most Versatile Land, including peat soils, and contribute towards enhancement of degraded peat to deliver a wide range of environmental services including biodiversity, open space, flood risk and drainage benefits, in addition to helping to mitigate climate change. With regard to tree planting for carbon offsetting Natural England advises that planting of trees needs to be considered in the context of wider plans for nature recovery. Tree planting should only be carried out in appropriate locations, taking into consideration potential impacts on existing ecology and the opportunities to create alternative habitats that could deliver better enhancements for people and wildlife, and also store carbon effectively. Where woodland habitat creation is appropriate, consideration should be given to natural regeneration for the economic and ecological benefits this can achieve. Any tree planting should use native and local provenance tree species suitable for the location. Natural England advocates an approach which seeks to increase biodiversity and green infrastructure generally, not simply planting of trees, and protecting / enhancing soils, particularly peat soils.

We support the Councils’ recognition of the severity of the climate change issue and recognition of the key issues and challenges of reducing our climate impact and the need to adapt to more extreme weather, a hotter climate and a changing ecology. We support key actions to address climate change including:  Using renewable and low carbon energy generation;  Promoting sustainable travel and discouraging car use where possible;  Retrofitting existing buildings;  Rooftop greening – this could be extended to generally extending and enhancing the ecological network We generally support the promotion of climate change adaptation measures including:  Managing flood risk and incorporating SUDS;  Increasing biodiversity and tree planting;  Improving water efficiency. The Plan should prioritise avoiding key factors contributing to climate change (through more greenhouse gases) e.g. pollution, habitat fragmentation, loss of biodiversity and to protecting and enhancing the natural environment’s resilience to change. Green Infrastructure and resilient ecological networks play an important role in aiding climate change adaptation. Development should be located and designed to remove/reduce reliance on car travel, promoting sustainable travel to improve air quality and its contribution to climate change. Development should incorporate multi-functional sustainable drainage and flood risk management measures in accordance with the SPD. Plan policies should focus on securing implementation of an enhanced and extended ecological network that will deliver climate change mitigation in addition to wider environmental services. This should be delivered through appropriate policy requirements. We are aware that an Integrated Water Management Study, incorporating a Water Cycle Study and Strategic Flood Risk Assessment, is being progressed as a key evidence document to inform preparation of the Local Plan. We welcome this and urge for a strong focus /recommendation for the implementation of integrated drainage including multi-functional SUDs in all development, where possible. It should also identify and promote delivery of benefits and opportunities associated with climate change, for example to create more extensive wetland habitats and to protect and enhance the degraded peat soils remaining in the Greater Cambridge area. Without appropriate measures new development will harm Greater Cambridge’s natural natural Page 3 of 15 environment. Measures to avoid impacts must be prioritised. Cambridgeshire is especially dependent on its groundwater which is currently being pumped dry with knock-on effects for the natural environment including water quality and biodiversity. In addition to new buildings climate change requires retrofitting of existing buildings. Revised and more ambitious water consumption targets are also needed. The Plan should include appropriate policies to secure delivery of the recommendations identified through the Integrated Water Study. We would also advise that consideration be given to updating the existing Flood and Water Supplementary Planning Document to reflect current BNG and climate / net zero carbon targets. The Local Plan and relevant policies should reflect the importance of remaining peat soils as a significant carbon store that can help to improve air quality and mitigate against climate change. The development strategy and relevant policies should seek to protect Best and Most Versatile Land, including peat soils, and contribute towards enhancement of degraded peat to deliver a wide range of environmental services including biodiversity, open space, flood risk and drainage benefits, in addition to helping to mitigate climate change. With regard to tree planting for carbon offsetting Natural England advises that planting of trees needs to be considered in the context of wider plans for nature recovery. Tree planting should only be carried out in appropriate locations, taking into consideration potential impacts on existing ecology and the opportunities to create alternative habitats that could deliver better enhancements for people and wildlife, and also store carbon effectively. Where woodland habitat creation is appropriate, consideration should be given to natural regeneration for the economic and ecological benefits this can achieve. Any tree planting should use native and local provenance tree species suitable for the location. Natural England advocates an approach which seeks to increase biodiversity and green infrastructure generally, not simply planting of trees, and protecting / enhancing soils, particularly peat soils.

Nothing chosen

We support the Councils’ recognition of the severity of the climate change issue and recognition of the key issues and challenges of reducing our climate impact and the need to adapt to more extreme weather, a hotter climate and a changing ecology. We support key actions to address climate change including:  Using renewable and low carbon energy generation;  Promoting sustainable travel and discouraging car use where possible;  Retrofitting existing buildings;  Rooftop greening – this could be extended to generally extending and enhancing the ecological network We generally support the promotion of climate change adaptation measures including:  Managing flood risk and incorporating SUDS;  Increasing biodiversity and tree planting;  Improving water efficiency. The Plan should prioritise avoiding key factors contributing to climate change (through more greenhouse gases) e.g. pollution, habitat fragmentation, loss of biodiversity and to protecting and enhancing the natural environment’s resilience to change. Green Infrastructure and resilient ecological networks play an important role in aiding climate change adaptation. Development should be located and designed to remove/reduce reliance on car travel, promoting sustainable travel to improve air quality and its contribution to climate change. Development should incorporate multi-functional sustainable drainage and flood risk management measures in accordance with the SPD. Plan policies should focus on securing implementation of an enhanced and extended ecological network that will deliver climate change mitigation in addition to wider environmental services. This should be delivered through appropriate policy requirements. We are aware that an Integrated Water Management Study, incorporating a Water Cycle Study and Strategic Flood Risk Assessment, is being progressed as a key evidence document to inform preparation of the Local Plan. We welcome this and urge for a strong focus /recommendation for the implementation of integrated drainage including multi-functional SUDs in all development, where possible. It should also identify and promote delivery of benefits and opportunities associated with climate change, for example to create more extensive wetland habitats and to protect and enhance the degraded peat soils remaining in the Greater Cambridge area. Without appropriate measures new development will harm Greater Cambridge’s natural natural Page 3 of 15 environment. Measures to avoid impacts must be prioritised. Cambridgeshire is especially dependent on its groundwater which is currently being pumped dry with knock-on effects for the natural environment including water quality and biodiversity. In addition to new buildings climate change requires retrofitting of existing buildings. Revised and more ambitious water consumption targets are also needed. The Plan should include appropriate policies to secure delivery of the recommendations identified through the Integrated Water Study. We would also advise that consideration be given to updating the existing Flood and Water Supplementary Planning Document to reflect current BNG and climate / net zero carbon targets. The Local Plan and relevant policies should reflect the importance of remaining peat soils as a significant carbon store that can help to improve air quality and mitigate against climate change. The development strategy and relevant policies should seek to protect Best and Most Versatile Land, including peat soils, and contribute towards enhancement of degraded peat to deliver a wide range of environmental services including biodiversity, open space, flood risk and drainage benefits, in addition to helping to mitigate climate change. With regard to tree planting for carbon offsetting Natural England advises that planting of trees needs to be considered in the context of wider plans for nature recovery. Tree planting should only be carried out in appropriate locations, taking into consideration potential impacts on existing ecology and the opportunities to create alternative habitats that could deliver better enhancements for people and wildlife, and also store carbon effectively. Where woodland habitat creation is appropriate, consideration should be given to natural regeneration for the economic and ecological benefits this can achieve. Any tree planting should use native and local provenance tree species suitable for the location. Natural England advocates an approach which seeks to increase biodiversity and green infrastructure generally, not simply planting of trees, and protecting / enhancing soils, particularly peat soils.

We support the Councils’ recognition of the severity of the climate change issue and recognition of the key issues and challenges of reducing our climate impact and the need to adapt to more extreme weather, a hotter climate and a changing ecology. We support key actions to address climate change including:  Using renewable and low carbon energy generation;  Promoting sustainable travel and discouraging car use where possible;  Retrofitting existing buildings;  Rooftop greening – this could be extended to generally extending and enhancing the ecological network We generally support the promotion of climate change adaptation measures including:  Managing flood risk and incorporating SUDS;  Increasing biodiversity and tree planting;  Improving water efficiency. The Plan should prioritise avoiding key factors contributing to climate change (through more greenhouse gases) e.g. pollution, habitat fragmentation, loss of biodiversity and to protecting and enhancing the natural environment’s resilience to change. Green Infrastructure and resilient ecological networks play an important role in aiding climate change adaptation. Development should be located and designed to remove/reduce reliance on car travel, promoting sustainable travel to improve air quality and its contribution to climate change. Development should incorporate multi-functional sustainable drainage and flood risk management measures in accordance with the SPD. Plan policies should focus on securing implementation of an enhanced and extended ecological network that will deliver climate change mitigation in addition to wider environmental services. This should be delivered through appropriate policy requirements. We are aware that an Integrated Water Management Study, incorporating a Water Cycle Study and Strategic Flood Risk Assessment, is being progressed as a key evidence document to inform preparation of the Local Plan. We welcome this and urge for a strong focus /recommendation for the implementation of integrated drainage including multi-functional SUDs in all development, where possible. It should also identify and promote delivery of benefits and opportunities associated with climate change, for example to create more extensive wetland habitats and to protect and enhance the degraded peat soils remaining in the Greater Cambridge area. Without appropriate measures new development will harm Greater Cambridge’s natural natural Page 3 of 15 environment. Measures to avoid impacts must be prioritised. Cambridgeshire is especially dependent on its groundwater which is currently being pumped dry with knock-on effects for the natural environment including water quality and biodiversity. In addition to new buildings climate change requires retrofitting of existing buildings. Revised and more ambitious water consumption targets are also needed. The Plan should include appropriate policies to secure delivery of the recommendations identified through the Integrated Water Study. We would also advise that consideration be given to updating the existing Flood and Water Supplementary Planning Document to reflect current BNG and climate / net zero carbon targets. The Local Plan and relevant policies should reflect the importance of remaining peat soils as a significant carbon store that can help to improve air quality and mitigate against climate change. The development strategy and relevant policies should seek to protect Best and Most Versatile Land, including peat soils, and contribute towards enhancement of degraded peat to deliver a wide range of environmental services including biodiversity, open space, flood risk and drainage benefits, in addition to helping to mitigate climate change. With regard to tree planting for carbon offsetting Natural England advises that planting of trees needs to be considered in the context of wider plans for nature recovery. Tree planting should only be carried out in appropriate locations, taking into consideration potential impacts on existing ecology and the opportunities to create alternative habitats that could deliver better enhancements for people and wildlife, and also store carbon effectively. Where woodland habitat creation is appropriate, consideration should be given to natural regeneration for the economic and ecological benefits this can achieve. Any tree planting should use native and local provenance tree species suitable for the location. Natural England advocates an approach which seeks to increase biodiversity and green infrastructure generally, not simply planting of trees, and protecting / enhancing soils, particularly peat soils.