Draft North East Cambridge Area Action Plan

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Comment

Draft North East Cambridge Area Action Plan

Policy 2: Designing for the climate emergency

Representation ID: 55951

Received: 05/10/2020

Respondent: Natural England

Representation Summary:

Natural England is fully supportive of policy requirements to mitigate and adapt to climate change.
Please note our comments above.

Attachments:

Comment

Draft North East Cambridge Area Action Plan

Policy 4a: Water Efficiency

Representation ID: 55952

Received: 05/10/2020

Respondent: Natural England

Representation Summary:

The Cambridge water environment is under significant pressure from the demands of the existing
population. Groundwater abstraction to supply drinking water combined with surface and
wastewater discharges are impacting on groundwater levels, river flows and water quality; this is
already having an adverse effect on the natural environment, including several statutorily
designated nature conservation sites. Given the severity of the existing situation any new
development, including through NECAAP, will need to demonstrate, as a minimum, that water
supply and surface and waste water disposal demands can be met without further detriment to
groundwater levels, river flows and water quality. As a minimum development should seek to
achieve no further deterioration, however, the aim of any further development should be to reduce
these impacts and, as far as possible, deliver improvements in groundwater levels, river flows and
water quality. Proposed development will also need to ensure and demonstrate sustainable
drainage and flood risk management. These complex issues and deliverable solutions will need to
be addressed through the Integrated Water Management Study / Water Cycle Study (IWMS /
WCS) being undertaken to inform the Greater Cambridge Local Plan.
Whilst targets and requirements outlined in policies 4a -c are welcomed these policies should be
informed by the findings and recommendations of the IWMS/WCS. Any measures to mitigate
adverse environmental impact will need to be detailed and their viability assured, through the AAP.
Their delivery will need to be secured through robust policy requirements.

Attachments:

Comment

Draft North East Cambridge Area Action Plan

Policy 4b: Water quality and demand

Representation ID: 55953

Received: 05/10/2020

Respondent: Natural England

Representation Summary:

The Cambridge water environment is under significant pressure from the demands of the existing
population. Groundwater abstraction to supply drinking water combined with surface and
wastewater discharges are impacting on groundwater levels, river flows and water quality; this is
already having an adverse effect on the natural environment, including several statutorily
designated nature conservation sites. Given the severity of the existing situation any new
development, including through NECAAP, will need to demonstrate, as a minimum, that water
supply and surface and waste water disposal demands can be met without further detriment to
groundwater levels, river flows and water quality. As a minimum development should seek to
achieve no further deterioration, however, the aim of any further development should be to reduce
these impacts and, as far as possible, deliver improvements in groundwater levels, river flows and
water quality. Proposed development will also need to ensure and demonstrate sustainable
drainage and flood risk management. These complex issues and deliverable solutions will need to
be addressed through the Integrated Water Management Study / Water Cycle Study (IWMS /
WCS) being undertaken to inform the Greater Cambridge Local Plan.
Whilst targets and requirements outlined in policies 4a -c are welcomed these policies should be
informed by the findings and recommendations of the IWMS/WCS. Any measures to mitigate
adverse environmental impact will need to be detailed and their viability assured, through the AAP.
Their delivery will need to be secured through robust policy requirements.

Attachments:

Comment

Draft North East Cambridge Area Action Plan

Policy 4c: Flood Risk and Sustainable Drainage

Representation ID: 55954

Received: 05/10/2020

Respondent: Natural England

Representation Summary:

The Cambridge water environment is under significant pressure from the demands of the existing
population. Groundwater abstraction to supply drinking water combined with surface and
wastewater discharges are impacting on groundwater levels, river flows and water quality; this is
already having an adverse effect on the natural environment, including several statutorily
designated nature conservation sites. Given the severity of the existing situation any new
development, including through NECAAP, will need to demonstrate, as a minimum, that water
supply and surface and waste water disposal demands can be met without further detriment to
groundwater levels, river flows and water quality. As a minimum development should seek to
achieve no further deterioration, however, the aim of any further development should be to reduce
these impacts and, as far as possible, deliver improvements in groundwater levels, river flows and
water quality. Proposed development will also need to ensure and demonstrate sustainable
drainage and flood risk management. These complex issues and deliverable solutions will need to
be addressed through the Integrated Water Management Study / Water Cycle Study (IWMS /
WCS) being undertaken to inform the Greater Cambridge Local Plan.
Whilst targets and requirements outlined in policies 4a -c are welcomed these policies should be
informed by the findings and recommendations of the IWMS/WCS. Any measures to mitigate
adverse environmental impact will need to be detailed and their viability assured, through the AAP.
Their delivery will need to be secured through robust policy requirements.

Attachments:

Comment

Draft North East Cambridge Area Action Plan

Policy 5: Biodiversity and Net Gain

Representation ID: 55955

Received: 05/10/2020

Respondent: Natural England

Representation Summary:

Natural England fully supports policy requirements for development to apply the ecological
mitigation hierarchy and for delivery of a minimum 10% measurable biodiversity net gain.

We welcome the proposal to deliver a coherent and high-quality ecological network as part of the
wider green infrastructure network including habitat and water quality improvements to The First
Public Drain, Chesterton Fen and Milton Country Park. Our advice is that the AAP requires a more
ambitious and strategic approach to biodiversity; the AAP should identify and map the existing GI /
ecological network along with viable opportunity areas to create a GI / Biodiversity Expansion and
Enhancement Framework Plan. Whilst this could include areas such as Chesterton Fen and Milton
CP it should draw on the GI and Biodiversity Opportunity Mapping Project being undertaken for the
Greater Cambridge Local Plan and the recommendations / opportunity areas identified in the
Biodiversity Assessment (MKA Ecology, June 2020). This will need to be sufficiently ambitious to
deliver mitigation measures identified through the revised HRA/SA. Policy requirements should be
set to secure delivery of the Framework through each phase of development.

The requirement for ecological assessment should address the HRA recommendation for this to
demonstrate no adverse impact to Eversden and Wimpole Woods SAC functional habitat for
barbastelle bats.

Attachments:

Comment

Draft North East Cambridge Area Action Plan

Policy 7: Legible streets and spaces

Representation ID: 55956

Received: 05/10/2020

Respondent: Natural England

Representation Summary:

We support requirements to integrate Sustainable Drainage System (SUDS) as part of a
comprehensive site-wide approach and for the design to provide sufficient space for trees and
planting to support biodiversity, using native species where possible. These should be ‘multifunctional’
to deliver benefits for people and wildlife.

Attachments:

Comment

Draft North East Cambridge Area Action Plan

Policy 8: Open spaces for recreation and sport

Representation ID: 55957

Received: 05/10/2020

Respondent: Natural England

Representation Summary:

Whilst we support the intention of this policy to protect exiting open space and provide new and
enhanced high quality, multi-functional open space, the delivery of 10ha of open space, the
equivalent size of Parker’s Piece or twice the area of Nun’s Way Recreational Ground, is unlikely
to meet the recreational demands of this sale of development and mitigate the impacts of
recreational pressure offsite. This level of provision falls significantly short of Local Plan open space requirements and is substantially less than the 8ha /1000 population standard advocated
through Natural England’s Suitable Alternative Natural Green Space (SANGS) guidance to meet
people’s needs and protect more sensitive designated sites such as Stow-cum-Quy Fen Site of
Special Scientific Interest (SSSI) and Wicken Fen SSSI, Ramsar site.

We are aware that the HRA / SA are in the process of assessing the recreational pressure impacts
of NECAAP development on designated sites and that these will identify specific mitigation
requirements to address adverse impacts. The HRA recommends discussion with the National
Trust to determine how increased impacts to Wicken Fen will be mitigated. A further
recommendation is for this policy to include a commitment to the provision of alternative natural
greenspace that is specifically designed and managed to alleviate visitor pressure on Wicken Fen
Ramsar and Fenland SAC.

Natural England agrees that further consideration of recreational pressure through the AAP/HRA
should include detailed discussion with the National Trust regarding impacts to Wicken Fen and
the Vision Area. We will be pleased to engage in any discussion. To address this and the wider GI
needs of the development we advise that the AAP should develop a strategic approach to GI and
biodiversity by identifying and mapping the existing network and viable opportunity areas i.e. a GI /
Biodiversity Expansion and Enhancement Framework Plan for expanding and enhancing the
green infrastructure network, including Bramblefields, Chesterton Fen, Milton CP and elsewhere.
This should draw on the GI and Biodiversity Opportunity Mapping Project being undertaken for the
Greater Cambridge Local Plan and the recommendations / opportunity areas identified in the
Biodiversity Assessment (MKA Ecology, June 2020). In particular this should identify viable
opportunity areas for the delivery of GI/biodiversity mitigation measures identified through the
revised HRA/SA, informed through discussion with the National Trust. Policy requirements should
be set to ensure delivery of the Framework through each phase of development.

The scale of development and the level of greenspace currently proposed is likely to result in local
sites such as Bramblefields and Milton CP being overwhelmed by additional visitor pressure. This
is likely to have an adverse impact on biodiversity and people’s enjoyment of these sites. Whilst
we welcome further proposals to enhance linkages to existing open spaces, adverse impacts
associated with the additional pressure, should be addressed through delivery of proportionate
expansion and enhancement measures at these sites.

Natural England will be pleased to offer advice on a draft GI / Biodiversity Framework for the
NECAAP. Our advice is that a strategic level of high-quality greenspace provision will be key to
creating a healthy community and enhancing people’s physical and mental wellbeing. The extent
of accessible natural greenspace provision (i.e. excluding formal sports areas) should be
proportionate to the scale of development, for example whilst quantity of provision should be
broadly aligned with SANGS guidance, green infrastructure design should seek to achieve the
Natural England Accessible Natural Greenspace Standards, detailed in Nature Nearby, including
the minimum standard of 2ha informal open space within 300m of everyone’s home. We advise
that green infrastructure provision should also seek to contribute towards the delivery of the
objectives of the Cambridgeshire Green Infrastructure Strategy for habitat enhancement and
improved connectivity.

Attachments:

Comment

Draft North East Cambridge Area Action Plan

Policy 23: Comprehensive and Coordinated Development

Representation ID: 55958

Received: 05/10/2020

Respondent: Natural England

Representation Summary:

Natural England supports this policy and requirement for development to demonstrate an
appropriate and proportionate contribution to site wide infrastructure including open space.
However, please note our comments above regarding the need for a AAP GI / Biodiversity
expansion and enhancement framework.
The requirement for a masterplan should be to demonstrate how the proposal accords with
GI/Biodiversity Framework and responds to the impacts of climate change, delivers biodiversity net
gain and mitigates environmental constraints.

Attachments:

Comment

Draft North East Cambridge Area Action Plan

Policy 25: Environmental Protection

Representation ID: 55959

Received: 05/10/2020

Respondent: Natural England

Representation Summary:

We generally support this policy and its requirements to protect the natural environment.

Attachments:

Comment

Draft North East Cambridge Area Action Plan

Policy 27: Planning Contributions

Representation ID: 55960

Received: 05/10/2020

Respondent: Natural England

Representation Summary:

We welcome the requirement for appropriate planning contributions on a scheme-by-scheme basis
to finance the early delivery of major strategic infrastructure including open space.

Attachments:

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