Greater Cambridge Local Plan Issues & Options 2020

Q12 – Q15 Biodiversity and green spaces Natural England fully supports recognition of continued biodiversity decline and pressure on Greater Cambridge’s biodiversity and green spaces from water shortage, pollution and development pressure. We welcome the Councils’ commissioning of an evidence based study to inform how the Local Plan can achieve an enhanced and expanded green infrastructure network to guide where development is planned and to deliver new and improved wildlife areas and green spaces. We are pleased that this is being considered in the context of the Natural Cambridgeshire Local Nature Partnership’s (LNP) vision to ‘double nature’ across the County, natural capital investment within the Ox-Cam Arc and the LNP’s Developing with Nature Toolkit. Through our early engagement with the Councils we have already indicated the potential risks to designated wildlife sites associated with increased visitor pressure from new development. We are pleased that this issue will be addressed through the Local Plan Green Infrastructure & Biodiversity evidence base. We have provided the Council’s with detailed advice on this through our previous correspondence. The effects of recreational pressure will need to be fully assessed through the HRA and Sustainability Appraisal (SA). Mitigation to address any adverse impacts will need to be identified. Consideration should be given to the findings and recommendations of the recent Footprint Ecology Visitor Survey* commissioned by the National Trust which predicts significant increases in recreational pressure to Wicken Fen Site of Special Scientific Interest (SSSI) and Ramsar site, part of the Fenland Special Area of Conservation (SAC) and the Vision Area associated with nearby development such as Waterbeach New Town. The findings also indicate risks to other nearby sites such as the adjoining Cam Washes SSSI; this nationally important site is already at risk from recreational pressure and disturbance to the notified bird interest by people and dogs. As discussed above it is crucial that the Integrated Water Study tackles the issue of decreasing water resources and pressure on the natural environment including chalk streams and other wetland habitat and associated species. A number of nationally designated water-dependent designated sites are potentially at risk as are several important locally designated sites. Impacts to sites downstream such as the internationally designated Ouse Washes SAC, Special Protection Area (SPA), and Ramsar site and Wicken Fen. We welcome that these sites are included within the 15km buffer for assessment of effects through the HRA. Opportunities for retrofitting and tightening water consumption targets must be prioritised. However, the Study also needs to identify opportunities for strategic projects to increase water storage, incorporating extensive wetland habitat creation and restoration of degraded peat soils, and implementation of multi-functional SUDS. We support acknowledgement of the multi-functional benefits of green infrastructure for people’s enjoyment and wellbeing, water storage, absorbing carbon emissions and improving biodiversity. The need to improve and connect green spaces is recognised alongside the need to balance rural biodiversity with other demands on the countryside such as agriculture. The Plan’s biodiversity policy should recognise the hierarchy of international, nationally and locally designated sites across Greater Cambridge. This should be accompanied by a map of the existing ecological network and enhancement opportunity areas. This should be used to guide site allocations / development away from more sensitive areas and to identify opportunities for developers to deliver net biodiversity gain enhancements, noting the Combined Authority’s Doubling Nature Vision i.e. 100% gain. Natural England’s Cambridgeshire Accessible Natural Greenspace Analysis 2010 indicates a deficit in accessible greenspace across Greater Cambridge, particularly South Cambridgeshire. The new Local Plan offers a significant opportunity to address this through the preparation of a biodiversity and green infrastructure enhancement strategy, with the various elements (open space, biodiversity rich habitat, community orchards, allotments etc.) delivered by developers through appropriate policy requirements for major allocations. We support the Councils’ indication that individual development will need to deliver biodiversity net gain (BNG) through measures such as design, landscaping, phasing and monitoring. We agree that BNG can be required for all developments; this is irrespective of whether a loss has occurred. Requirements for smaller developments to deliver through developer contributions for can be set out in a separate BNG / biodiversity policy. It would be helpful if such a document was given the status of an SPD to ensure it was given adequate weight in planning decisions. Given the scale of the environmental challenges and opportunities facing the natural environment a biodiversity SPD could outline how the aspiration of doubling with nature will be delivered on the ground, how BNG will be addressed and how biodiversity enhancement will be priorities and delivered. We will be pleased to discuss this further with the Councils. We would also advise that the costings for delivering the required biodiversity and green infrastructure elements of the local plan is included in the Local Plan’s Infrastructure Delivery Plan (or similar document) – so that the investment required in the natural environment is transparent and are factored into costings for delivering sustainable developments. The plan should recognise that social and economic benefits can be delivered through environmental gains, in addition to enhancing biodiversity. Natural England has a significant evidence base for this, including the Microeconomic Evidence for the Benefits of Investment in the Environment 2 (MEBIE2). Annex A includes more detailed advice to help the Council embed biodiversity net gain into the relevant Local Plan policies. Further advice on what we would expect to be included within Plan policies, including the biodiversity policy, is provided in Annex B. *Saunders P., Lake S., Lily D., Panter C., (2019) Visitor Survey of the National Trust’s Wicken Fen 100 Year Vision Area. Unpublished Report by Footprint Ecology.

Q12 – Q15 Biodiversity and green spaces Natural England fully supports recognition of continued biodiversity decline and pressure on Greater Cambridge’s biodiversity and green spaces from water shortage, pollution and development pressure. We welcome the Councils’ commissioning of an evidence based study to inform how the Local Plan can achieve an enhanced and expanded green infrastructure network to guide where development is planned and to deliver new and improved wildlife areas and green spaces. We are pleased that this is being considered in the context of the Natural Cambridgeshire Local Nature Partnership’s (LNP) vision to ‘double nature’ across the County, natural capital investment within the Ox-Cam Arc and the LNP’s Developing with Nature Toolkit. Through our early engagement with the Councils we have already indicated the potential risks to designated wildlife sites associated with increased visitor pressure from new development. We are pleased that this issue will be addressed through the Local Plan Green Infrastructure & Biodiversity evidence base. We have provided the Council’s with detailed advice on this through our previous correspondence. The effects of recreational pressure will need to be fully assessed through the HRA and Sustainability Appraisal (SA). Mitigation to address any adverse impacts will need to be identified. Consideration should be given to the findings and recommendations of the recent Footprint Ecology Visitor Survey* commissioned by the National Trust which predicts significant increases in recreational pressure to Wicken Fen Site of Special Scientific Interest (SSSI) and Ramsar site, part of the Fenland Special Area of Conservation (SAC) and the Vision Area associated with nearby development such as Waterbeach New Town. The findings also indicate risks to other nearby sites such as the adjoining Cam Washes SSSI; this nationally important site is already at risk from recreational pressure and disturbance to the notified bird interest by people and dogs. As discussed above it is crucial that the Integrated Water Study tackles the issue of decreasing water resources and pressure on the natural environment including chalk streams and other wetland habitat and associated species. A number of nationally designated water-dependent designated sites are potentially at risk as are several important locally designated sites. Impacts to sites downstream such as the internationally designated Ouse Washes SAC, Special Protection Area (SPA), and Ramsar site and Wicken Fen. We welcome that these sites are included within the 15km buffer for assessment of effects through the HRA. Opportunities for retrofitting and tightening water consumption targets must be prioritised. However, the Study also needs to identify opportunities for strategic projects to increase water storage, incorporating extensive wetland habitat creation and restoration of degraded peat soils, and implementation of multi-functional SUDS. We support acknowledgement of the multi-functional benefits of green infrastructure for people’s enjoyment and wellbeing, water storage, absorbing carbon emissions and improving biodiversity. The need to improve and connect green spaces is recognised alongside the need to balance rural biodiversity with other demands on the countryside such as agriculture. The Plan’s biodiversity policy should recognise the hierarchy of international, nationally and locally designated sites across Greater Cambridge. This should be accompanied by a map of the existing ecological network and enhancement opportunity areas. This should be used to guide site allocations / development away from more sensitive areas and to identify opportunities for developers to deliver net biodiversity gain enhancements, noting the Combined Authority’s Doubling Nature Vision i.e. 100% gain. Natural England’s Cambridgeshire Accessible Natural Greenspace Analysis 2010 indicates a deficit in accessible greenspace across Greater Cambridge, particularly South Cambridgeshire. The new Local Plan offers a significant opportunity to address this through the preparation of a biodiversity and green infrastructure enhancement strategy, with the various elements (open space, biodiversity rich habitat, community orchards, allotments etc.) delivered by developers through appropriate policy requirements for major allocations. We support the Councils’ indication that individual development will need to deliver biodiversity net gain (BNG) through measures such as design, landscaping, phasing and monitoring. We agree that BNG can be required for all developments; this is irrespective of whether a loss has occurred. Requirements for smaller developments to deliver through developer contributions for can be set out in a separate BNG / biodiversity policy. It would be helpful if such a document was given the status of an SPD to ensure it was given adequate weight in planning decisions. Given the scale of the environmental challenges and opportunities facing the natural environment a biodiversity SPD could outline how the aspiration of doubling with nature will be delivered on the ground, how BNG will be addressed and how biodiversity enhancement will be priorities and delivered. We will be pleased to discuss this further with the Councils. We would also advise that the costings for delivering the required biodiversity and green infrastructure elements of the local plan is included in the Local Plan’s Infrastructure Delivery Plan (or similar document) – so that the investment required in the natural environment is transparent and are factored into costings for delivering sustainable developments. The plan should recognise that social and economic benefits can be delivered through environmental gains, in addition to enhancing biodiversity. Natural England has a significant evidence base for this, including the Microeconomic Evidence for the Benefits of Investment in the Environment 2 (MEBIE2). Annex A includes more detailed advice to help the Council embed biodiversity net gain into the relevant Local Plan policies. Further advice on what we would expect to be included within Plan policies, including the biodiversity policy, is provided in Annex B. *Saunders P., Lake S., Lily D., Panter C., (2019) Visitor Survey of the National Trust’s Wicken Fen 100 Year Vision Area. Unpublished Report by Footprint Ecology.

Q12 – Q15 Biodiversity and green spaces Natural England fully supports recognition of continued biodiversity decline and pressure on Greater Cambridge’s biodiversity and green spaces from water shortage, pollution and development pressure. We welcome the Councils’ commissioning of an evidence based study to inform how the Local Plan can achieve an enhanced and expanded green infrastructure network to guide where development is planned and to deliver new and improved wildlife areas and green spaces. We are pleased that this is being considered in the context of the Natural Cambridgeshire Local Nature Partnership’s (LNP) vision to ‘double nature’ across the County, natural capital investment within the Ox-Cam Arc and the LNP’s Developing with Nature Toolkit. Through our early engagement with the Councils we have already indicated the potential risks to designated wildlife sites associated with increased visitor pressure from new development. We are pleased that this issue will be addressed through the Local Plan Green Infrastructure & Biodiversity evidence base. We have provided the Council’s with detailed advice on this through our previous correspondence. The effects of recreational pressure will need to be fully assessed through the HRA and Sustainability Appraisal (SA). Mitigation to address any adverse impacts will need to be identified. Consideration should be given to the findings and recommendations of the recent Footprint Ecology Visitor Survey* commissioned by the National Trust which predicts significant increases in recreational pressure to Wicken Fen Site of Special Scientific Interest (SSSI) and Ramsar site, part of the Fenland Special Area of Conservation (SAC) and the Vision Area associated with nearby development such as Waterbeach New Town. The findings also indicate risks to other nearby sites such as the adjoining Cam Washes SSSI; this nationally important site is already at risk from recreational pressure and disturbance to the notified bird interest by people and dogs. As discussed above it is crucial that the Integrated Water Study tackles the issue of decreasing water resources and pressure on the natural environment including chalk streams and other wetland habitat and associated species. A number of nationally designated water-dependent designated sites are potentially at risk as are several important locally designated sites. Impacts to sites downstream such as the internationally designated Ouse Washes SAC, Special Protection Area (SPA), and Ramsar site and Wicken Fen. We welcome that these sites are included within the 15km buffer for assessment of effects through the HRA. Opportunities for retrofitting and tightening water consumption targets must be prioritised. However, the Study also needs to identify opportunities for strategic projects to increase water storage, incorporating extensive wetland habitat creation and restoration of degraded peat soils, and implementation of multi-functional SUDS. We support acknowledgement of the multi-functional benefits of green infrastructure for people’s enjoyment and wellbeing, water storage, absorbing carbon emissions and improving biodiversity. The need to improve and connect green spaces is recognised alongside the need to balance rural biodiversity with other demands on the countryside such as agriculture. The Plan’s biodiversity policy should recognise the hierarchy of international, nationally and locally designated sites across Greater Cambridge. This should be accompanied by a map of the existing ecological network and enhancement opportunity areas. This should be used to guide site allocations / development away from more sensitive areas and to identify opportunities for developers to deliver net biodiversity gain enhancements, noting the Combined Authority’s Doubling Nature Vision i.e. 100% gain. Natural England’s Cambridgeshire Accessible Natural Greenspace Analysis 2010 indicates a deficit in accessible greenspace across Greater Cambridge, particularly South Cambridgeshire. The new Local Plan offers a significant opportunity to address this through the preparation of a biodiversity and green infrastructure enhancement strategy, with the various elements (open space, biodiversity rich habitat, community orchards, allotments etc.) delivered by developers through appropriate policy requirements for major allocations. We support the Councils’ indication that individual development will need to deliver biodiversity net gain (BNG) through measures such as design, landscaping, phasing and monitoring. We agree that BNG can be required for all developments; this is irrespective of whether a loss has occurred. Requirements for smaller developments to deliver through developer contributions for can be set out in a separate BNG / biodiversity policy. It would be helpful if such a document was given the status of an SPD to ensure it was given adequate weight in planning decisions. Given the scale of the environmental challenges and opportunities facing the natural environment a biodiversity SPD could outline how the aspiration of doubling with nature will be delivered on the ground, how BNG will be addressed and how biodiversity enhancement will be priorities and delivered. We will be pleased to discuss this further with the Councils. We would also advise that the costings for delivering the required biodiversity and green infrastructure elements of the local plan is included in the Local Plan’s Infrastructure Delivery Plan (or similar document) – so that the investment required in the natural environment is transparent and are factored into costings for delivering sustainable developments. The plan should recognise that social and economic benefits can be delivered through environmental gains, in addition to enhancing biodiversity. Natural England has a significant evidence base for this, including the Microeconomic Evidence for the Benefits of Investment in the Environment 2 (MEBIE2). Annex A includes more detailed advice to help the Council embed biodiversity net gain into the relevant Local Plan policies. Further advice on what we would expect to be included within Plan policies, including the biodiversity policy, is provided in Annex B. *Saunders P., Lake S., Lily D., Panter C., (2019) Visitor Survey of the National Trust’s Wicken Fen 100 Year Vision Area. Unpublished Report by Footprint Ecology.

Nothing chosen

Q12 – Q15 Biodiversity and green spaces Natural England fully supports recognition of continued biodiversity decline and pressure on Greater Cambridge’s biodiversity and green spaces from water shortage, pollution and development pressure. We welcome the Councils’ commissioning of an evidence based study to inform how the Local Plan can achieve an enhanced and expanded green infrastructure network to guide where development is planned and to deliver new and improved wildlife areas and green spaces. We are pleased that this is being considered in the context of the Natural Cambridgeshire Local Nature Partnership’s (LNP) vision to ‘double nature’ across the County, natural capital investment within the Ox-Cam Arc and the LNP’s Developing with Nature Toolkit. Through our early engagement with the Councils we have already indicated the potential risks to designated wildlife sites associated with increased visitor pressure from new development. We are pleased that this issue will be addressed through the Local Plan Green Infrastructure & Biodiversity evidence base. We have provided the Council’s with detailed advice on this through our previous correspondence. The effects of recreational pressure will need to be fully assessed through the HRA and Sustainability Appraisal (SA). Mitigation to address any adverse impacts will need to be identified. Consideration should be given to the findings and recommendations of the recent Footprint Ecology Visitor Survey* commissioned by the National Trust which predicts significant increases in recreational pressure to Wicken Fen Site of Special Scientific Interest (SSSI) and Ramsar site, part of the Fenland Special Area of Conservation (SAC) and the Vision Area associated with nearby development such as Waterbeach New Town. The findings also indicate risks to other nearby sites such as the adjoining Cam Washes SSSI; this nationally important site is already at risk from recreational pressure and disturbance to the notified bird interest by people and dogs. As discussed above it is crucial that the Integrated Water Study tackles the issue of decreasing water resources and pressure on the natural environment including chalk streams and other wetland habitat and associated species. A number of nationally designated water-dependent designated sites are potentially at risk as are several important locally designated sites. Impacts to sites downstream such as the internationally designated Ouse Washes SAC, Special Protection Area (SPA), and Ramsar site and Wicken Fen. We welcome that these sites are included within the 15km buffer for assessment of effects through the HRA. Opportunities for retrofitting and tightening water consumption targets must be prioritised. However, the Study also needs to identify opportunities for strategic projects to increase water storage, incorporating extensive wetland habitat creation and restoration of degraded peat soils, and implementation of multi-functional SUDS. We support acknowledgement of the multi-functional benefits of green infrastructure for people’s enjoyment and wellbeing, water storage, absorbing carbon emissions and improving biodiversity. The need to improve and connect green spaces is recognised alongside the need to balance rural biodiversity with other demands on the countryside such as agriculture. The Plan’s biodiversity policy should recognise the hierarchy of international, nationally and locally designated sites across Greater Cambridge. This should be accompanied by a map of the existing ecological network and enhancement opportunity areas. This should be used to guide site allocations / development away from more sensitive areas and to identify opportunities for developers to deliver net biodiversity gain enhancements, noting the Combined Authority’s Doubling Nature Vision i.e. 100% gain. Natural England’s Cambridgeshire Accessible Natural Greenspace Analysis 2010 indicates a deficit in accessible greenspace across Greater Cambridge, particularly South Cambridgeshire. The new Local Plan offers a significant opportunity to address this through the preparation of a biodiversity and green infrastructure enhancement strategy, with the various elements (open space, biodiversity rich habitat, community orchards, allotments etc.) delivered by developers through appropriate policy requirements for major allocations. We support the Councils’ indication that individual development will need to deliver biodiversity net gain (BNG) through measures such as design, landscaping, phasing and monitoring. We agree that BNG can be required for all developments; this is irrespective of whether a loss has occurred. Requirements for smaller developments to deliver through developer contributions for can be set out in a separate BNG / biodiversity policy. It would be helpful if such a document was given the status of an SPD to ensure it was given adequate weight in planning decisions. Given the scale of the environmental challenges and opportunities facing the natural environment a biodiversity SPD could outline how the aspiration of doubling with nature will be delivered on the ground, how BNG will be addressed and how biodiversity enhancement will be priorities and delivered. We will be pleased to discuss this further with the Councils. We would also advise that the costings for delivering the required biodiversity and green infrastructure elements of the local plan is included in the Local Plan’s Infrastructure Delivery Plan (or similar document) – so that the investment required in the natural environment is transparent and are factored into costings for delivering sustainable developments. The plan should recognise that social and economic benefits can be delivered through environmental gains, in addition to enhancing biodiversity. Natural England has a significant evidence base for this, including the Microeconomic Evidence for the Benefits of Investment in the Environment 2 (MEBIE2). Annex A includes more detailed advice to help the Council embed biodiversity net gain into the relevant Local Plan policies. Further advice on what we would expect to be included within Plan policies, including the biodiversity policy, is provided in Annex B. *Saunders P., Lake S., Lily D., Panter C., (2019) Visitor Survey of the National Trust’s Wicken Fen 100 Year Vision Area. Unpublished Report by Footprint Ecology.

Q16 – Q19 Wellbeing and social inclusion We agree that addressing requirements for climate change and green spaces, in addition to other national planning policy requirements will help to promote wellbeing and social inclusion. This should be a key consideration in the preparation of the Local Plan biodiversity and green infrastructure evidence base. Access to sustainable transport and access to nature, close to people’s homes, can have a significant influence on mental and physical wellbeing. As indicated above there is an accessible natural greenspace deficit across Greater Cambridge, and particularly South Cambridgeshire. This needs to be addressed through the new Local Plan to improve opportunities for people, to improve health and wellbeing, in addition to delivering wider environmental benefits including air quality and climate change. Creation of an enhanced and extended ecological network brimming with high quality open space, biodiversity rich habitat, community orchards, allotments etc. will make a significant contribution towards enhanced wellbeing.

Q16 – Q19 Wellbeing and social inclusion We agree that addressing requirements for climate change and green spaces, in addition to other national planning policy requirements will help to promote wellbeing and social inclusion. This should be a key consideration in the preparation of the Local Plan biodiversity and green infrastructure evidence base. Access to sustainable transport and access to nature, close to people’s homes, can have a significant influence on mental and physical wellbeing. As indicated above there is an accessible natural greenspace deficit across Greater Cambridge, and particularly South Cambridgeshire. This needs to be addressed through the new Local Plan to improve opportunities for people, to improve health and wellbeing, in addition to delivering wider environmental benefits including air quality and climate change. Creation of an enhanced and extended ecological network brimming with high quality open space, biodiversity rich habitat, community orchards, allotments etc. will make a significant contribution towards enhanced wellbeing.

Q16 – Q19 Wellbeing and social inclusion We agree that addressing requirements for climate change and green spaces, in addition to other national planning policy requirements will help to promote wellbeing and social inclusion. This should be a key consideration in the preparation of the Local Plan biodiversity and green infrastructure evidence base. Access to sustainable transport and access to nature, close to people’s homes, can have a significant influence on mental and physical wellbeing. As indicated above there is an accessible natural greenspace deficit across Greater Cambridge, and particularly South Cambridgeshire. This needs to be addressed through the new Local Plan to improve opportunities for people, to improve health and wellbeing, in addition to delivering wider environmental benefits including air quality and climate change. Creation of an enhanced and extended ecological network brimming with high quality open space, biodiversity rich habitat, community orchards, allotments etc. will make a significant contribution towards enhanced wellbeing.

Q16 – Q19 Wellbeing and social inclusion We agree that addressing requirements for climate change and green spaces, in addition to other national planning policy requirements will help to promote wellbeing and social inclusion. This should be a key consideration in the preparation of the Local Plan biodiversity and green infrastructure evidence base. Access to sustainable transport and access to nature, close to people’s homes, can have a significant influence on mental and physical wellbeing. As indicated above there is an accessible natural greenspace deficit across Greater Cambridge, and particularly South Cambridgeshire. This needs to be addressed through the new Local Plan to improve opportunities for people, to improve health and wellbeing, in addition to delivering wider environmental benefits including air quality and climate change. Creation of an enhanced and extended ecological network brimming with high quality open space, biodiversity rich habitat, community orchards, allotments etc. will make a significant contribution towards enhanced wellbeing.

With regard to air quality and health, the Plan should strive to develop a strategy and related policies that enable more sustainable travel and reduced reliance / use of private cars. Greater Cambridge requires a significantly enhanced sustainable transport network including enhanced and safer walking and cycling networks and better, cheaper and more frequent public transport. In addition to cleaner air and better health this will benefit wildlife and climate change.

A design policy should promote Natural Cambridgeshire’s Developing with Nature Toolkit to maximise opportunities within the design of the development to provide sufficient area of high quality multi-functional green infrastructure, including sustainable drainage (SuDS) to deliver net gain for biodiversity, landscape and accessible open space to meet people’s recreational and health needs. Sufficient high quality multi-functional green infrastructure, connected to the wider GI network, should form the framework for the built development, Appropriately designed and managed green infrastructure can also provide significant climate change mitigation including urban cooling and a wide range of other environmental services including wildlife habits, SUDS, high quality landscape, food production. Developers should be encouraged to follow Natural England’s Accessible Natural Greenspace Guidance detailed in 'Nature Nearby'.