Draft North East Cambridge Area Action Plan

Neither agree nor disagree

The Wildlife Trust follows the logic of high density development in this area of the city and agree that it is possible to deliver this type of development whilst also creating a sustainable community. The accessibility of North East Cambridge and the potential for sustainable travel options into the city centre are real benefits. Figure 1 in 2. Context and Objectives shows the future plans for the Area delivering 8000 new homes for 18 000 residents whilst delivering just 10ha of public parks and squares. This aspect of the vision is surprising and seems to be at odds with its stated aims: Strategic Objectives 2 and 4 describe the area being ‘characterful, lively’ and ‘healthy’ where ‘Healthy lifestyles will be enabled through access to open spaces, sports and recreational facilities, public rights of way, local green spaces and active travel choices’. We do not believe that the policies at present contain sufficient scope to deliver on this and will discuss further under Q.7. We are also unconvinced by Objective 1 ‘Green infrastructure will enable everyone to lead healthy lifestyles, and will protect and enhance biodiversity’. Whilst the policies do contain some commendable plans for habitats within the site, these are limited in scale due to the available space and we would argue that for an Action Plan of this scope and ambition, sufficient biodiversity enhancements will not be achieved through green infrastructure alone.

Neutral

No answer given

Neutral

The Wildlife Trust agrees that the location is appropriate for high density buildings, although has no specific comment on building heights. The Trust would like to query the limited acknowledgement given to water resources within policies relating to building density and street layout. Policy 7 says Integrate Sustainable Drainage Systems (SuDS) as part of a comprehensive site-wide approach but no other mention appears in this part of the AAP to an intention to maximise the retention and re-use of water within the district. More soft landscaping, rain gardens and water butts within the public realm would all contribute to this. We acknowledge more detailed consideration is given to water use efficiency in Policies 4a - c and comment on these as part of our response to Q.10.

Mostly not

The onsite mix of public open spaces, as set out in Policy 8 appear to deliver a good mix of different types of urban space, but in terms of the area of space available, it is the Wildlife Trust’s opinion that it is not sufficient. Larger areas of open space will be desired by residents for dog walking, exercise etc and these are not provided on site. The policy says that offsite provision will include Bramblefields LNR, Milton Country Park and Chesterton Fen. We would comment on each of these as follows: Bramblefields LNR is a very small site with a limited range of open space, (much is overgrown with trees and scrub, from which much of its wildlife value stems) and there is no scope here for enlargement of this site. It is used by residents of Chesterton and the local school but seems unlikely to provide a regular destination for residents of NEC. Milton Country Park is at capacity and this AAP should discuss in more detail how that could be overcome, if Milton CP is to be part of the open space provision for NEC. Extending the area of the country park would seem the only way to increase visitor capacity. Whilst the Wildlife Trust is aware of proposals for a new Sports Lake facility between Milton and Waterbeach, these proposals are outside the remit of this AAP, and it is unknown at this stage whether they will be developed, and whether they would provide the right kind of open space and recreation for the residents of NEC, as the proposals seem very focused on lake sports and rowing. Chesterton Fen could be used as part of a green network to link NEC to the wider landscape and provide residents with contact with nature. For example the creation of large ponds or a lake with reedbeds surrounded by a circular walk, hide, occasional viewing platforms, and a cycle route around the perimeter, which links to the River Cam, would certainly provide a more natural open space that cannot be delivered on site. However, the site is still relatively small, and as acknowledged in Policy 8, it is within the floodplain and does sometimes flood, meaning access to the area is likely to be confined to predetermined pathways / boardwalks. Whilst the Wildlife Trust agree that Chesterton Fen can be part of the solution, we cannot currently see how these three sites, as named in the policies, will deliver what is expected of an AAP with ambitions for creating a new city district which is ‘lively, active, low-carbon’. The lack of strategic natural greenspace is likely to displace visitor activity including dog walking and other recreational pursuits to other sites including SSSIs in an around Cambridge. There is also a danger that it will encourage car journeys for these activities. Further, there is already a historic deficit in provision of strategic natural greenspace, from developments between 2000 and 2020, which the Wildlife Trust estimates to be in the order of several hundred hectares (information available on request). As the Context and Objectives section states, the AAP wishes to deliver 8000 new homes. Natural England guidance for SANGS (Suitable Accessible Natural Green Space), which although devised to deal with recreational disturbance to European Protected Sites resulting from housing developments, does represent a useful tool for determining what might need to be delivered, in order for large new housing developments to avoid creating excessive pressure on existing areas of greenspace that are valued for their biodiversity. This guidance recommends 8ha of suitable, accessible natural green space per 1000 new residents. For NEC then, this would equate to 144ha of such green space, to be delivered in order to ensure residents have sufficient space and variety of space to use such that they are not likely to frequently travel to other existing sites for activities such as dog walking and exercise. Without the delivery of a more substantial and ambitious green space, the development of NEC, at the scale proposed, risks putting additional pressure on existing wildlife sites, and this effect is not likely to be solely confined to the city of Cambridge, but could extend to other areas such as Wicken Fen, Fulbourn Fen and Wilbraham Fen, and the woodland SSSIs west of Cambridge, which are already experiencing disturbance and degradation of habitats. Furthermore, requiring residents to drive to access green space seems in contradiction with the stated aim of a low carbon community. Given that Policy 5 (addressed in more detail in Q. 8) states ‘Development shall avoid having any adverse impact on the nature conservation value of….City Wildlife Sites and Country Parks… other areas of natural or semi-natural sites within or adjacent to North East Cambridge’ the Wildlife Trust would query how indirect impacts on such sites can be avoided when so little green space would be delivered from the current policy wording. The Wildlife Trust believe that more new green space is needed, whether this be through a significant extension of Milton Country Park, or a nearby alternative area with significant space, which links, or can be linked sustainably, to the NEC district. This should be reflected in the policy wording to ensure it is taken forward and addressed.

Mostly not

Policy 5 says that ‘Development proposals will be required to deliver a minimum of 10% net gain in biodiversity value..’ and Figure 14 refers to ‘10% biodiversity increase across NEC’. The Wildlife Trust believe that targets for Biodiversity Net Gain (BNG) in large developments should be set at 20%. Because of the inherent uncertainties in creating or restoring, and then maintaining, habitats that achieve their stated aims, aiming higher than 10% shows a real aspiration to an appreciable gain, as well as providing a buffer against future challenges in long term habitat management. We would strongly urge the AAP to consider a move towards a more aspirational and confident BNG target. In terms of offsite habitat creation, which will be required to deliver BNG, we would comment that Chesterton Fen is unlikely to deliver significant gains for biodiversity, given the existing constraints of the site, and its size, and that the clear intention within Policy 8 is for Chesterton Fen to form a part of the solution to delivering recreational and open space for residents of NEC. The Wildlife Trust would broadly support the idea of Chesterton Fen being used to deliver open space for recreational use, with opportunities for biodiversity capitalised on wherever possible. The two objectives can sometimes be delivered together, but on a site the size of Chesterton Fen, with existing neighbouring land uses, this seems unlikely to be able to deliver significant gains for wildlife whilst also delivering for public recreational use. The Wildlife Trust therefore believes that an alternative offsite location is necessary to deliver BNG. Policy wording should reflect the priorities for the various offsite options proposed, so that it is clear what is intended and there is no inappropriate ‘doubling up’. The emerging Cambridge Nature Network should be used to inform locations for maximising the benefits of Biodiversity Net Gain from the NEC development. We support the inclusion of green roof and green walls within accompanying policy text and believe it is an appropriate approach in an urban setting with high density buildings. We would strongly urge an ambitious vision to the delivery of green roofs with consideration given to setting mandatory provision within each development phase. We welcome the specific acknowledgement that ‘extensive areas of biodiverse living roofs are necessary to replace open mosaic habitats which are of significant value’ and would suggest clarity in the policy wording that these should be ‘biodiverse green roofs’ specifically, as opposed to sedum mats. We support the specific wording use ‘integrated bat features’ as opposed to bat boxes placed on the exterior of walls. Improvements to the First Public Drain are welcomed and could reap gains for protected species such as water voles, if provided with sufficient buffers as it flows through the redeveloped site. Improvements to water channels beyond the NEC boundary would be welcomed as an opportunity to increase BNG both within and beyond the site’s boundaries.

Mostly not

Policy 4c simply states that ‘Any flat roof provides an element of green or brown roof’. This sounds vague and open to much interpretation, especially as the term ‘green / brown roof’ is such a broad one. To echo comments made in response to Q8, we would urge that firmer commitment be made within the policies guiding the AAP to extensive areas of biodiverse green roofs, with minimum areas required for each phase of development. Biodiverse roofs can come in a variety of forms, and the Wildlife Trust would support a move away from simply using sedum mats, towards more diverse green roofs. Setting this intention out at the policy stage would be very useful and highlights the aspiration that the North East Cambridge District will deliver a variety of biodiverse roofs which could act as a catalyst for bigger thinking in terms of green roofs in Cambridge. The water efficiency targets in policy 4a are welcome in so far as they go, but as a minimum there must be a commitment to achieve a maximum potable water use per person of 80 litres per person per day (pppd). Water supply in Cambridge comes from the underlying aquifer. There is now a considerable body of evidence that not only is the aquifer unnaturally depressed through over abstraction, but that this has fed through into low flows across the Cam catchment, to the significant detriment of the rivers and wetland SSSIs. This situation needs to be reversed if Cambridge is to grow sustainably, which will require a much more stringent approach to use of water. The Wildlife Trust therefore favours a firm policy commitment for water efficiency to aim for no more than 80 litres pppd, with a proportion of this to be grey water provision, thus reducing potable water use well below 80 litres pppd. There is the opportunity for North-east Cambridge to draw from and improve upon the water efficient design and approach used at the Eddington development.