Draft North East Cambridge Area Action Plan

Thank you for seeking Natural England’s views on the above in your email of 20 July 2020. 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. You will be aware that Natural England provided detailed comments in response to consultations on the Issues and Options consultation, in our letter dated 25 March 2019 (ref. 273507), and the draft Habitats Regulations Assessment (HRA), in our letter dated 7 May 2020 (ref. 315290). Natural England Summary Advice Based on the information provided in the AAP, and the findings of the Habitats Regulations Assessment (HRA) and Sustainability Appraisal (SA), Natural England’s overarching advice is that further evidence is required to demonstrate that there is sufficient greenspace provision and water supply / waste water treatment capacity to meet the demands of this scale of development without adverse impact to the natural environment. Our advice is made in the context of the adverse environmental impacts already occurring to meet the recreational and water / waste water needs of the existing population. As indicated previously Natural England has no objection to the proposed regeneration of the North East Cambridge (NEC) Area, the principle of which is established in the recently adopted Local Plans. We support the aim of the AAP to create an inclusive, walkable, integrated, low- carbon new city district within this 182 ha brownfield site located within 15 minutes cycling distance of Cambridge. However, as indicated through the HRA and SA, significant uncertainties remain regarding the potential for NEC development to adversely affect the natural environment, including a number of European and nationally designated sites, through changes in air quality, recreational pressure and water-related impacts. In light of existing environmental pressures the proposed scale of development, in combination with wider growth including Ox Cam Arc and Waterbeach New Town, is likely to require implementation of significant measures to address these issues. Further assessment is required, for example through the Local Plan Water Cycle Study and through traffic modelling and Air Quality Assessment, to inform the recommendations of the HRA and SA and further development of the AAP. Mitigation measures identified as being necessary to avoid adverse harm to the natural environment should not be deferred to developers through high regarding the delivery of essential mitigation measures the AAP will need to specify how and where these measures will be delivered. Robust require ance with these plans should be set in AAP policy. With regard to accessible natural greenspace the AAP, with reference to the findings of the HRA/SA and the Greater Cambridge Local Plan Green Infrastructure and Biodiversity Opportunity Mapping project, should identify the quantum and quality of required provision for development, in- combination with wider growth, to avoid adverse impact on the natural environment. Viable opportunity areas for delivering the required level of greenspace, through expansion and enhancement of the existing GI network, should be identified and mapped, as a Green Infrastructure Framework, or similar, within the AAP. Robust policy requirements should ensure delivery of the framework through each phase of development. Ideally this should be combined ework, identifying similar viable opportunity areas for delivery of biodiversity mitigation and AAP enhancement targets.

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Natural England welcomes the plan Vision and objectives to ensure everyone has access to good quality public open spaces, to enhance health and wellbeing, and for improvements to access to existing green spaces such as Milton Country Park and Chesterton Fen. Requirements for development to contribute towards climate change targets and deliver 10% biodiversity net gain are welcomed in view of Natural Cambridgeshire’s ‘Doubling Nature’ targets and the biodiversity net gain and nature recovery ambitions of the Defra 25 Year Environment Plan. Natural England fully supports the inclusion of climate, water and biodiversity objectives in light of national and local climate and biodiversity emergencies and targets to address these. We welcome recognition that North East Cambridge is located in an area of severe water stress and that groundwater abstraction to meet current demand is already having an adverse effect on several water-dependent nationally designated nature conservation sites and priority habitats such as chalk streams. We fully support the inclusion of open space objectives to address green infrastructure requirements and access to the natural environment. Whilst we generally support NECAAP environmental objectives there is currently no spatial framework for implementing these through the identification of viable opportunity areas. This needs to be addressed with reference to the findings and recommendations of the HRA/SA and the Greater Cambridge Local Plan Green Infrastructure and Biodiversity Opportunity Mapping project.

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We welcome proposed new links, bridges and underpasses, presented in Figure 1.2, to improve access to existing green spaces (Nun’s Way Recreation Ground, Milton CP, Chesterton Fen, Bramblefields LNR) subject to enhancements being made to those sites to increase their sure no adverse impact to biodiversity or people’s enjoyment of those spaces. This needs to be addressed through a delivery plan.

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Natural England has no specific comments to make in response to this question.

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Natural England believes the proposal for 8000 new homes and 20,000 additional jobs is a highly ambitious for such a small site already grid-locked by traffic and lacking significant areas of accessible natural greenspace. Please see our further comments below.

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Please see our comments in relation to green infrastructure provision below.

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Please see our comments in relation to green infrastructure provision below. Natural England’s only other comment is that this should accord with local policy requirements such as Local Plan Policy 60 Tall buildings and the skyline in Cambridge to protect the local landscape and visual amenity.

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We support proposals for new and enhanced on-site green infrastructure through the creation of a linear park and Cowley Triangle, alongside a green High Street and neighbourhood greens. However, Natural England’s view is that the AAP needs to present a green infrastructure framework, or similar, to identify viable opportunity areas for expansion and enhancement of the existing network, sufficient to meet people’s recreational and accessible greenspace needs and mitigate adverse impacts to existing open spaces, including designated sites and priority habitats. Whilst the AAP commits to improving access to nearby green spaces such as Milton Country Park and Chesterton Fen, Natural England believes that provision of 10ha of public parks and squares is wholly inadequate for a development this scale and density. This magnitude of development requires strategic expansion and enhancement of the existing green infrastructure network. The AAP should identify how this will be delivered through a GI framework and delivery plan.

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Natural England supports the NECAAP commitment to deliver 10% measurable biodiversity net gain through improvements to the First Public Drain and linear park and Chesterton Fen along with green linkages to other biodiversity sites. We note that developers will be asked to contribute to improvements at key sites for nature including Milton Country Park and Chesterton Fen. As per our advice on green infrastructure above, we believe these offsite environmental opportunity enhancement areas should be secured and identified within a GI and biodiversity framework plan within the AAP. The AAP should set out how the project/s will be delivered and managed in the long-term. Robust policy requirements should secure delivery / developer contributions towards their delivery.

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We support the proposed measures and objectives including no additional vehicle movements on Milton Road and Kings Hedges Road, priority for cyclists and pedestrians, no through routes, 20mph speed limit and limited car parking. We note that the SA alludes to the potential for the AAP vehicle targets to be exceeded in practice, with risk of significant negative effects on air quality particularly along the A14 Corridor, in combination with other developments to the north and east of Cambridge. It should also be noted that in adjacent neighbourhoods with limited car parking the usual solution is for some residents to use green spaces for parking vehicles. In addition to damaging grassland habitat this also spoils the use of these areas for recreation and has a significant impact on visual amenity of the area leading to urban degradation.