Question 12. How should the Local Plan help us improve the natural environment?

The Local plan provides an opportunity not just to improve the natural environment for its own sake (which is important); but to harness some of the increasingly evidenced thinking with regard to resilience within the urban environment through nature-based solutions9. Through a considered approach to the natural environment, sustainability, climate change, social, economic, environmental impacts, and emergency preparedness all can benefit. The Local Plan can be instrumental in improving the natural environment, for example through the allocation of a managed green infrastructure network that contributes to wellbeing, biodiversity, the protection of water courses and urban greening. The Local Plan is also an opportunity to set out urban greening requirements10 to meet its proposed 'doubling nature' aspiration. Cambridge Science Park North is being developed as a location that can provide compensatory improvements to a substantial (circa 90 hectares) area of land, which will remain within the Green Belt, but will replace currently low ecological value private agricultural land with: • A network of new green infrastructure; with links to Milton Country Park, Histon & Impington, and Arbury and Kings Hedges. • Woodland planting of sufficient scale to provide meaningful woodland carbon capture11. • Landscape and visual enhancements taking existing agricultural land and creating a valuable green asset for neighbouring communities and employees. • Improvements to biodiversity, habitat connectivity and the introduction of natural capital to an area of low ecological value agricultural land. • New and enhanced walking and cycle routes, linking into the planned improvements to Mere Way; and • Improved access to new recreational and playing field provision for all. 9 For example see: https://ec.europa.eu/easme/en/news/nature-based-solutions-are-helping-address-urban-challenges 10 For example see: https://www.london.gov.uk/what-we-do/environment/parks-green-spaces-and-biodiversity/urban-greening 11 The Forestry Commission suggests that a new native woodland can capture 300-400 tonnes of CO2 equivalent per hectare (tCO 2e/ha) by year 50, and 400-500 tCO 2e/ha by year 100.

This Local Plan must deliver effective policy which protects and enhances natural capital. We support delivery of net gain for new development. Such policy must be flexible enough to enable creative and cost-effective solutions for the delivery of net gain and support the Vision for the Natural Future of Cambridgeshire in 2050 as outlined by Natural Cambridgeshire and affiliated organisations. An off-site net gain solution should be clearly allowed for by policy. While it is a Local Plan priority as a part of one of the four big themes, the Local Plan policy must allow for a planning judgement and balanced decision to allow for site and development specific issues to be taken into account.

4.14 This Local Plan must deliver effective policy which protects and enhances natural capital. We support delivery of net gain for new development. Such policy must be flexible enough to enable creative and cost-effective solutions for the delivery of net gain and support the Vision for the Natural Future of Cambridgeshire in 2050 as outlined by Natural Cambridgeshire and affiliated organisations. An off-site net gain solution should be clearly allowed for by policy. While it is a Local Plan priority as a part of one of the four big themes, the Local Plan policy must allow for a planning judgement and balanced decision to allow for site and development specific issues to be taken into account. 4.15 For reference as to how Land to the north of Station Road could improve the natural environment please refer to Section 2 of these representations, the Vision Document prepared by Allies and Morrison, the Sustainable Transport Appraisal prepared by Vectos, the Preliminary Ecological Appraisal prepared by Ecology Solutions and the Arboricultural Survey prepared by Haydens. A site that can offer 10% net biodiversity gain.

5.11 This Local Plan must deliver effective policy which protects and enhances natural capital. We support delivery of net gain for new developments. Such policy must be flexible enough to enable creative and cost-effective solutions for the delivery of net gain and support the Vision for the Natural Future of Cambridgeshire in 2050 as outlined by Natural Cambridgeshire and affiliated organisations. 5.12 An off-site net gain solution should be clearly allowed for by policy. While it is a Local Plan priority as a part of one of the four big themes, the Local Plan policy must allow for a planning judgement and balanced decision to allow for site and development specific issues to be considered. A policy basis to facilitate off-site biodiversity net gain is essential for smaller and medium sized developments. As recognised in the NPPF, small and medium developments, with their ability to be delivered early in the plan period at pace, will play an important role in meeting housing requirements and supporting existing villages. Such sites may best secure biodiversity net gain by contributing to an offsite initiative. A strategy for the delivery of off-site biodiversity net gain funded through development contributions would allow the Council new green infrastructure and biodiversity habitats to be strategically planned, which in turn, would provide greater benefit than the provision of small, uncoordinated and connected new habitats across a range of new developments. Nonetheless on-site measures are also possible at many sites such as suitable hedge habitats, green spaces, wildlife corridors and enabling hedgehogs to move freely between plots.

5.13 Developing green infrastructure at Land to the north of Main Street, Shudy Camps, would enhance the natural environment. Also, part of the proposal is an area of open space on the western side, ensuring this space is accessible to new and existing residents. This open space will provide: ● Recreation opportunities, through the provision of play spaces; ● Exercise opportunities using linked footpaths; and ● Sustainable development features including landscaping and tree planting. 5.14 The site therefore contributes to supporting biodiversity, increasing opportunities for recreation and exercise, mitigating and adapting to climate change and enhancing the landscape’s character. 5.15 This Local Plan must deliver effective policy which protects and enhances the natural world by making the environment better for all. There are many ways to provide appropriate solutions at a local level; both on and off-site solutions seem germane. These approaches need to be creative and cost-effective and in step with the Vision for the Natural Future of Cambridgeshire in 2050 (Natural Cambridgeshire and affiliated organisations). Robust site specific decision making which is flexible and takes a balanced account of local needs is an appropriate approach.

5.11 This Local Plan must deliver effective policy which protects and enhances natural capital. We support delivery of net gain for new development. Such policy must be flexible enough to enable creative and cost-effective solutions for the delivery of net gain and support the Vision for the Natural Future of Cambridgeshire in 2050 as outlined by Natural Cambridgeshire and affiliated organisations. An off-site net gain solution should be clearly allowed for by policy. While it is a Local Plan priority as a part of one of the four big themes, the Local Plan policy must allow for a planning judgement and balanced decision to allow for site and development specific issues to be taken into account. 5.12 Land to the west of Mill Street, Gamlingay presents an opportunity to help improve the natural environment and to also protect existing ecological features within the surrounding area through the delivery of on and off-site green infrastructure. As part of the proposals, a substantial amount of on-site and off-site open space will be provided, comprising 2.53ha in total and forming 59% of the total site area. The open space will deliver new recreation assets for the village and also incorporating ecological enhancements. The proposals include multi-function open space that is connected by a network of footpaths, providing permeability throughout the site and to the rest of the village. Ecological enhancements would include native tree, shrub and hedgerow planting and could also incorporate areas of wildflower meadow and community orchards. The site therefore contributes to supporting biodiversity, increasing opportunities for recreation, mitigating and adapting to climate change and enhancing landscape character.

Legislation will require mandatory biodiversity net gain. Paragraph 20 and 20d of the revised NPPF sets out a new requirement for local authorities to develop strategic policies which set out an overall strategy for the pattern, scale and quality of development, and the conservation and enhancement of the natural environment, including landscape and green infrastructure and climate change mitigation/adaptation. The proposal for a new community at the Six Mile Bottom Estate will provide a significant net gain. The proposal will retain woodland areas and hedgerows throughout to allow wildlife to continue to thrive. Will establish expansive semi-natural area reserved for wildlife with managed access so that ecology can thrive. The proposal also includes a new multifunctional 3km long linear park running through the settlement with play parks, sports pitches, picnic areas, allotments, running and cycle routes.

3.4 This Local Plan must deliver effective policy which protects and enhances natural capital. It must be a robust and up-to-date policy framework to be effective. By example, the on-going protection of the field east of The Lawns, Clerk Maxwell Road under the strict protection applied by the adopted policy 67 undermines the validity and robustness of the network of protected open spaces. 3.5 The Local Plan should establish a policy basis to protect those spaces that are particularly important to Greater Cambridge. The application of what appears as a blanket designation of the majority of open spaces does little to convey a robust and carefully selected protected open space. This is represented by Appendix 2 to this representation which shows all the currently Protected Open Spaces and their 400m isochrone to reflect the 400m described in adopted Cambridge Policy 67. This arises through an assessment criteria that is too broad and essentially forms a ‘catch all’. The City is largely covered by such spaces. 3.6 The land east of The Lawns has not been actively used since 2003, yet it retains the full protection of Policy 67 to the same degree as the most valuable open spaces in Cambridge; that cannot be appropriate or reasonable.

Landscape scale cross boundary opportunities are as important as Green Infrastructure delivery within development sites and there should be more emphasis on the relationship between development and existing GI. Current policies focus narrowly on the potential impacts on sites protected by international designations, but additional population pressure is an issue for habitats and site managers at all GI sites. The approach to GI planning and delivery set out in the consultation document should address this issue. The Local Plan should also set out a strategic ambition for GI delivery and management over the Plan period, consistent with the Natural Cambridgeshire ‘Doubling Nature’ vision for Cambridgeshire. As an LNP member, the National Trust shares this ambition and supports the work of CPPF, the Wildlife Trust and others in formulating proposals for a Nature Recovery Network. ‘Cambridge Landscapes’ identifies 5 priority areas that would form the basis of this Network. The Local Plan is key mechanism for delivering this vision and should endorse this approach. Coupled to this, the wider Natural Capital Plan for the Ox-Cam Arc, also in preparation, will be a relevant consideration

We believe that the Local Plan should identify, describe and map a nature recovery network, which is of sufficient scale and scope that it would be capable of delivering a doubling of nature and meeting the informal green space needs of current and future populations. Such a network would also deliver the wider benefits described in the Issues & Options First Conversation document, namely ameliorating the worst effects of flooding, drought, high temperatures; improving health and wellbeing; absorbing carbon; planting trees; increasing prosperity by making our area an attractive place to live, learn or do business; etc. A nature recovery network would create inspirational landscapes in and around Cambridge which will continue to support its global reputation and image. Working with the Wildlife Trust and other conservation organisations we have started to pull together an evidence base for such a network in and around Cambridge. Following the principles of the Lawton Report and the government’s 25 Year Environment Plan (places for nature that are “Bigger, Better, Connected”) our approach is based on identifying areas on a ‘landscape scale’ that already have a core of habitats and/or where land is being actively managed for nature. This is still a work in progress and we will be sharing the interim and final outputs of this work with the Councils and submitting it as an evidence base for the Local Plan. However, our initial work has identified 5 priority areas that would form the basis for a “Cambridge Landscapes – Nature Recovery Network”, these are illustrated and described below: Nature Recovery Network – Priority Areas (NRN) The survey of the green assets around the Cambridge area forms an evidence base on which five areas of focus for potential Nature Recovery Networks (NRN) within a 10km radius of Cambridge have been defined. Each is different in character and may ultimately produce very different opportunities in terms of the two strands of (1) creating habitat and biodiversity in order to enhance our landscape and combat the effects of climate change, and (2) providing natural greenspace for the residents of Cambridge and surrounds to engage with nature and receive benefits in terms of physical and mental well-being. The broad areas have been defined by studying landscape features such as the topography, underlying geology (both solid and drift), current habitat and land use, and past habitat and land use. Ownership of land has not been taken into account, but inevitably some land use follows ownership boundaries. 1. Gog Magog Hills This large area of approximately 25 Km2 south-east of Cambridge is defined by where the underlying chalk geology comes to the surface, which corresponds well to the 25m contour line. The southern boundary is marked by the A11, with the urban areas of Cambridge defining the northern boundary and the River Granta and riverside villages the western boundary. The area directly connects with both the Cambridge Fens and River Cam NRNs. It includes the chalk grassland SSSIs of Cherry Hinton Chalk Pits, Fleam Dyke, Gog Magogs golf course and Roman Road, as well as other Wildlife Sites and accessible natural greenspaces such as Wandlebury Country Park, Magog Down and Beechwoods LNR. 2. Wicken Fen vision The National Trust has a long-term vision to extend its Wicken Fen reserve southwards to the edge of the city of Cambridge, covering an area of 50 Km2. The southern part of this vision area provides a gateway from the city. This area has been defined by geographical constraints, with the A14 to the south (marking the northern edge of the city), the River Cam to the west (its own NRN area), the B1102 to the east and an approximate distance of 10km from the city centre to the north. While the boundaries are geographical, the area itself is characterised by wet, clay soils. It lies beneath the 10m contour and the underlying geology is Cretaceous marly chalk. Quy Fen SSSI lies within the area showing the potential for the type of habitat which could be restored across it. Quy Water and the Bottisham Lode flow through this area. Further north, the fen peats come to the surface, forming a direct link to the core, northern part of the Wicken Fen vision area. 3. Cambridge Fens East of Cambridge, Fulbourn, Teversham and Wilbraham Fens mark the edge of the Fens landscape character area. Three SSSIs, Fulbourn Fen, Wilbraham Fen and Great Wilbraham Common form the core of this area, which connects then. The area is mainly defined by the 10m contour line in the north and 15 m contour line to the south. It comprises both peat and Holocene river terrace gravel surface geology. The A14 forms the northern boundary, separating this area from the Wicken Fen vison south, while the villages of Teversham, the Wilbrahams and Fulbourn also form discrete boundaries being located on the higher ground. 4. River Cam corridor The River Cam, its floodplain and catchment tributaries including Bourn Brook, Cherry Hinton Brook, River Granta and the River Rhee. The corridor around these has been defined by both the topography of the adjacent land, including the floodplain and broadly following the 10m contour line, as well as the Holocene river deposits surface geology. The underlying geology is predominantly Cretaceous gault clay, though the River Granta from Babraham flows down on the Cretaceous marly chalk. The river itself is a Wildlife Site and it links a number of local wildlife sites, green spaces and historically important green spaces including Grantchester Meadows, the college Backs, many of Cambridge’s commons and Ditton Meadows. This area is also significantly important in terms of providing natural greenspace for health and wellbeing. 5. Boulder clay and woodlands This large area of approximately 18 Km2 covers the higher ground (over 25m) to the west of Cambridge and sits upon the recent boulder clay deposits, which overlay the Cretaceous marly chalk and gault clay. Madingley Wood SSSI (an ancient woodland) lies on top of the hill and the ground conditions are conducive to woodland cover. The area extends down to the A428 and M11 in the north and east. The area includes or adjoins the Coton Country Reserve (CPPF), Burwash Manor Organic Farm and Lark Rise Farm (Countryside Restoration Trust), all of which are farms not only demonstrating wildlife-friendly practices, but also engaging with the public through a series of permissive footpaths. Thus, there is a great opportunity here to extend this network of wildlifefriendly farming practices, increasing the quantity and quality of the hedgerow network. The Bin Brook passes through the area, and the Bourn Brook lies to the south. These connect this local landscape area to the strategic West Cambridgeshire Hundreds NRN to the west. In addition to the five above we are also looking at whether there could be an “opportunity area” to the north-west of Cambridge: Fen-edge orchards and droves The area of approximately 15km2 between Cottenham and Histon is completely devoid of any Public Rights of Way. In the past the area was a major producer of fruit, and was covered in orchards, a small number of which remain. This area is underlain by Jurassic and Cretaceous clays and sands, is mostly beneath the 10m contour line and is well drained by a series of ditches and drains, including Beach Ditch, a County Wildlife Site. This is a strategic area to provide residents of Cottenham, Histon, Oakington, Rampton and Landbeach an area of countryside to explore by a series of newly created pathways along ditches and old droves, which could be widened to provide wildlife corridors through the area for the benefit of the aquatic plants and animals. As such it could be considered as a “stepping stone” for nature between Cambridge and the wildlife rich areas in the Ouse Valley. It also connects to Northstowe and could provide an area of accessible countryside beyond the relatively constrained urban greenspaces of the new town. The condition of the remaining orchards would need to be assessed, but allowing public access into some of these would provide a link to the heritage of the area. Alternatively, there would be scope to create a number of community orchards, combining wildflower areas and orchard trees, including local varieties of which there are many that were developed in this area. Within each of these landscape scale areas further work is now being carried out to identify more specific opportunities to create, expand and connect habitats and to ground truth these. We believe that these opportunities should provide the focus for the future creation/investment in green infrastructure because they will deliver the maximum benefits for nature and people. Work will also be looking at the connections between these landscape areas and with adjacent or smaller scale green infrastructure. This work will be submitted to the Councils later this year. The nature recovery network areas would not be giant parks or nature reserves. They would consist of groupings of individual parks, nature reserves and natural habitats that are linked together by wildlife friendly habitat. The majority of the land in these areas is farmed and is likely to stay that way during the period of the Local Plan, however there will be opportunities through the new Agriculture Bill to create areas of new habitat on farmland that can buffer, connect or provide stepping-stones between existing habitats. There will be the possibility to create new nature areas and green spaces in each of these landscapes through philanthropy, fund-raising and carbon-offsetting; and the development process/Local Plan should also play an important role in supporting this network, for example through developer contributions/biodiversity net gain and by ensuring that any green spaces being created by new developments link to and support the Nature Recovery Network wherever possible. In addition to the Nature Recovery Network we also propose the following measures to help improve the natural environment: • All new development should achieve a measurable 20% net gain in biodiversity. New habitats should be created in places that help deliver the nature recovery network (see above). • Policies which ensure the highest standards of water efficiency and minimise use of water from the chalk aquifer.

The following aspects are all relevant to achieving this aim: • The identification of a Nature Recovery Network for the Greater Cambridge area, with this network being explicitly mapped in the local plan, with linkages to neighbouring authorities clearly shown. The Nature Recovery Network should guide the location of all future development so that any new development (not just in the next Local Plan period, but all future plan periods) is located where it does not compromise, damage or fragment the nature network. We have described our emerging work to identify the components of this network in our response to Q6. • All new development should achieve a measurable 20% net gain in biodiversity. New habitats should be created in places that help deliver the Nature Recovery Network. • The Local Plan should provide for the creation of a significant area of new strategic natural greenspace, including large-scale habitat creation. This will make a major contribution to the “Doubling Nature” vision for Cambridgeshire, for which thousands of hectares of new habitats and wildlife-rich green spaces will be required. Several areas should be planned, located where they will provide the natural space for the current and future population, create inspirational landscapes in and around Cambridge, and support the Nature Recovery Network and doubling nature vision. While many of these will be within the Greater Cambridge area, it might also be appropriate to support some of the strategically important areas in the fens and Ouse Valley, including Wicken Fen, Ouse Washes and Great Fen, as these will also be destination sites for residents of the Greater Cambridge area. • Tree planting and woodland / tree cover should be increased, but be based on the principle of the “right tree in the right location”. Increased tree cover can help cool urban areas, reduce air pollution and improve the urban landscape. Woodland creation can provide both new habitats for wildlife and natural greenspaces for access and recreation. Natural regeneration should form a significant element of woodland creation, and tree planting should not occur on important wildlife sites where grassland and / or wetland habitats are important for species of more open habitats. • All new development should have the highest standards of water efficiency and minimise use of water from the chalk aquifer. New developments should also incorporate sustainable urban drainage systems to help water percolate back into the soil and recharge the aquifer, as well as avoid exacerbating flooding elsewhere.

The Rhee an important tributary of the River Cam flows through Steeple Morden Parish. All the chalk stream tributaries and springs that are supplied with water from the aquifer are under considerable stress particularly in the summer months. Therefore they need greater protection from over abstraction and enable them to adapt to climate change. Greater willingness of District Council to support Tree Preservation Orders for both groups of trees as well as individual specimens in the wider countryside as well as in the immediate village envelope.

Every development and Planning application to consider how it is affecting the environment. A need to improve the environment should be at the heart of every application including offsite improvements Confer Homes England purchase of off-site land. Listen and encourage participation of the local community. Place responsibility and autonomy at local level. Engage local teams/co-operatives to build up into national groups with the same interests to maximise re-use of ideas, proven solutions. Create local front-line jobs to do this so people can work where they live.

ECC notes that its states “both Councils have recognised the pressure on the natural environment and want to explore how the next Local Plan can do more to improve the green infrastructure network. This will form a key part of the overall development strategy for the area and will be an important part of the wider response to climate change” (page 34). ECC supports this approach. To assist it may be worth noting that the restoration of mineral extraction sites offers an almost unique opportunity to dictate the final form of a landscape. There is the opportunity to consider existing mineral workings as part of emerging Green Infrastructure assessments to understand how their after-uses may best contribute to the delivery of the wider green network and/or deliver biodiversity net-gain within the GCAs and beyond.

Developments should be mandated to provide and/or enhance a specified amount of habitat for indigenous species. The impact of development on watercourses – volume, direction, etc, should have greater priority. Better grey water management, specifically individual dwelling and/or local recycling should be advanced. More areas should be left wild to encourage biodiversity and not unnecessarily manicured.

This Local Plan must deliver effective policy which protects and enhances natural capital. We support delivery of net gain for new development. Such policy must be flexible enough to enable creative and cost-effective solutions for the delivery of net gain and support the Vision for the Natural Future of Cambridgeshire in 2050 as outlined by Natural Cambridgeshire and affiliated organisations. An off-site net gain solution should be clearly allowed for by policy. While it is a Local Plan priority as a part of one of the four big themes, the Local Plan policy must allow for a planning judgement and balanced decision to allow for site and development specific issues to be taken into account. Land off Beach Road, Cottenham presents an opportunity to help improve the natural environment and through the delivery of on-site green infrastructure. Open space will be included in proposals to deliver new recreation assets for the village and also incorporate ecological enhancements. Proposals could include multi-function open space that is connected by a network of footpaths, providing permeability throughout the site and to the rest of the village. Ecological enhancements could include native tree, shrub and hedgerow planting and could also incorporate specific areas of habitat creation. The site would therefore contribute to supporting biodiversity, increasing opportunities for recreation, mitigating and adapting to climate change and enhancing landscape character.

4.40 Biodiversity enhancement is supported by green infrastructure which can include parks and recreation grounds as well as wild spaces such as woodland, scrubland and grassland. Water bodies also strongly contribute to the natural environment and biodiversity, and can bring wider site benefits such as surface water management. For these reasons integrated blue and green infrastructure provided with new development is a key mechanism for improving the natural environmental whilst addressing key climate change resilience issues such as flood risk. The Local Plan should recognise development which contributes to green and blue infrastructure and encourage biodiversity net gain where feasible.

Conservation and enhancement of the natural environment is an important facet of sustainable development. There is an important synergy between the historic and natural environment. Landscape parks and open space often have heritage interest, and it would be helpful to highlight this. It is important not to consider ‘multi-functional’ spaces only in terms of the natural environment, health and recreation. It may be helpful to make reference in the text to the role GI can have to play in enhancing and conserving the historic environment. It can be used to improve the setting of heritage assets and to improve access to it, likewise heritage assets can help contribute to the quality of green spaces by helping to create a sense of place and a tangible link with local history. Opportunities can be taken to link GI networks into already existing green spaces in town or existing historic spaces such as church yards to improve the setting of historic buildings or historic townscape. Maintenance of GI networks and spaces should also be considered so that they continue to serve as high quality places which remain beneficial in the long term. Landscape parks and open space often have heritage interest, and it would be helpful to highlight this. It is important not to consider ‘multi-functional’ spaces only in terms of the natural environment, health and recreation. It may be helpful to make reference in the text to the role GI can have to play in enhancing and conserving the historic environment. It can be used to improve the setting of heritage assets and to improve access to it, likewise heritage assets can help contribute to the quality of green spaces by helping to create a sense of place and a tangible link with local history. Opportunities can be taken to link GI networks into already existing green spaces in town or existing historic spaces such as church yards to improve the setting of historic buildings or historic townscape. Maintenance of GI networks and spaces should also be considered so that they continue to serve as high quality places which remain beneficial in the long term. In Cambridge the Commons, green corridors, wedges and fingers as well as the green belt provide an important component of the landscape setting of the historic city of Cambridge. These features help to make Cambridge the special and unique place that it is today. They also serve to protect heritage assets and their settings. Cows grazing in the meadows close to the city centre, the iconic views of The Backs, the Commons and meadows all play a crucial role and form part of the character of this historic city. Maintaining and enhancing these features is critical to the future of this City.

Please refer to the Sustainability Vision Statement which seeks out opportunities to bring the big themes to life in every aspect of the project.

5.13 This Local Plan must deliver effective policy which protects and enhances natural capital. We support delivery of net gain for new development. Such policy must be flexible enough to enable creative and cost-effective solutions for the delivery of net gain and support the Vision for the Natural Future of Cambridgeshire in 2050 as outlined by Natural Cambridgeshire and affiliated organisations. An off-site net gain solution should be clearly allowed for by policy. While it is a Local Plan priority as a part of one of the four big themes, the Local Plan policy must allow for a planning judgement and balanced decision to allow for site and development specific issues to be taken into account. 5.14 The development of the Gas Field, Madingley Road presents an opportunity to improve the natural environment through the provision of on-site green infrastructure. As part of the proposals, as shown in the attached Vision Masterplan, a substantial amount of open space will be provided on-site, providing a new ecological and recreation asset but also incorporating ecological enhancements. The proposal includes multi-functional public open space including parklands, woodlands and nature reserves which are connected by green corridors to enhance and build upon existing corridors in the surrounding landscape. This will contribute to providing important habitat for a range of wildlife and plant species. The site therefore contributes to supporting biodiversity, increasing opportunities for recreation, mitigating and adapting to climate change and enhancing landscape character.

Minimise development. Stop building on it.

4.15 This Local Plan must deliver effective policy which protects and enhances natural capital. We support delivery of net gain for new development. Such policy must be flexible enough to enable creative and cost-effective solutions for the delivery of net gain and support the Vision for the Natural Future of Cambridgeshire in 2050 as outlined by Natural Cambridgeshire and affiliated organisations. An off-site net gain solution should be clearly allowed for by policy. While it is a Local Plan priority as a part of one of the four big themes, the Local Plan policy must allow for a planning judgement and balanced decision to allow for site and development specific issues to be taken into account. 4.16 Kett House and 10 Station Road could improve the natural environment by providing high quality public open space on site with potential for biodiversity features such as green roofs. In addition to this, strategic off site opportunities offer the opportunity to significantly increase biodiversity other than providing site specific biodiversity improvements.

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.

- Make the case that some areas need to be left inaccessible so that wildlife can thrive - Make the case that that excessive ‘tidiness’ must be avoided in some areas. For example the existing hedges and verges on Barnwell Drive appear to be thriving without excessive interference. - Make the case for continuing some livestock grazing such as practised in the Cam Corridor through Ditton Meadows and the green corridor proposed in Q3 above. - Recognise the existing role of private green spaces and promote environment friendly practices in them.

4.11 This Local Plan must deliver effective policy which protects and enhances natural capital. We support delivery of net gain for new development. Such policy must be flexible enough to enable creative and cost-effective solutions for the delivery of net gain and support the Vision for the Natural Future of Cambridgeshire in 2050 as outlined by Natural Cambridgeshire and affiliated organisations. An off-site net gain solution should be clearly allowed for by policy. While it is a Local Plan priority as a part of one of the four big themes, the Local Plan policy must allow for a planning judgement and balanced decision to allow for site and development specific issues to be taken into account.

4.12 This Local Plan must deliver effective policy which protects and enhances natural capital. We support delivery of net gain for new development. Such policy must be flexible enough to enable creative and cost-effective solutions for the delivery of net gain and support the Vision for the Natural Future of Cambridgeshire in 2050 as outlined by Natural Cambridgeshire and affiliated organisations. An off-site net gain solution should be clearly allowed for by policy. While it is a Local Plan priority as a part of one of the four big themes, the Local Plan policy must allow for a planning judgement and balanced decision to allow for site and development specific issues to be taken into account.

Summary 5.7 In summary, the Trust is seeking to ensure that the future criteria adopted for the justification and designation of POS is reconsidered, and that there is a set of requirements which should be met rather than just one. In doing so, the Trust would like to ensure that there is a removal of a ‘blanket approach’ to the designating of sites and instead only specific areas of high importance included within a site. Full Text: 5.3 Most of the Bell School site is designated as Protected Open Space (POS) in the Local Plan 2018. Policy 67 seeks to protect all open space whether designated or undesignated. It makes no differentiation between Protected Open Space and undesignated space. All are considered protected by virtue of meeting just one of the assessment criteria as listed in Appendix I of the Local Plan. 5.4 The Issues and Options consultation makes it clear there is a need to consider how attractive, accessible and well-designed open space is created and protected as well as looking at how to improve, add to and connect up our green spaces. The Trust is in favour of supporting improvements to the natural environment and improving the green space network, however, there is a need for consideration to be given to those existing allocations and whether they fulfil the objectives of future policy. 5.5 The site at the Bell School provides an attractive area of open space for the students and staff of the school. The Trust consider this to be an important feature of the site which should be retained, and over the years have employed a groundsman to maintain the attractive grounds. However, since its designation as POS some of the areas included within the designation contribute far less in terms of quality and are not visible from outside of the site. The opportunity to improve or connect this site with other green spaces is not currently possible and particularly since the development of Ninewells to the south and south east of the site. 5.6 The Trust is not seeking to remove the designation of the site but suggest that as part of the consultation process there should be a review of the criteria against which POS is considered, and in allocating or retaining POS a need to ensure that there is a set of criteria against which all sites are assessed and all elements should be met in order to warrant its designation.

2.12 IWM Duxford incorporates a significant land area in which the operation and retention of the airfield greenspace and habitats is directly dependent on protecting the ability to fly historic aircraft in acrobatic displays. Similarly, the landscape setting of the airfield with views across flat open countryside to the ridge of hills to the south is a fundamental aspect of its heritage significance. 2.13 This importance is acknowledged in paragraph 8.36 of the 2018 local plan which states ‘given its national significance, the District Council will give IWM Duxford special consideration within the context of protecting the quality of the surrounding landscape in this sensitive site on the edge of the Cambridge Green Belt’. 2.14 Similarly, the present local plan (para 10.37) requires developments within the Aerodrome Safeguarding Zone to be subject to consultation with IWM. The extent of the safeguarding is shown on Figure 13 in the Local Plan and broadly requires consultation on buildings over 10m tall within 2km of the airfield and 45m tall within 10km. As the latter covers parts of neighbouring authorities in North Hertfordshire and Uttlesford Districts, it is vital that the ‘duty to cooperate’ with neighbouring authorities is adhered to. 2.15 The IWM consider it vital that this special consideration is retained within the Greater Cambridge Plan and that the safeguarding consultation is more strictly enforced by being tied to a specific policy within the new plan. This will protect the IWM’s ability to fly from the airfield and its important landscape setting.

3.23 Part of the proposal is inclusion of a nature reserve, wetlands, grassland and woodland to the west of the high street. This open space will provide: ● Recreation opportunities, through the provision of play spaces; ● Exercise opportunities using linked footpaths; and, ● Sustainable development features including landscaping and tree planting. 3.24 The site therefore contributes to supporting biodiversity, increasing opportunities for recreation and exercise, mitigating and adapting to climate change and enhancing the landscape’s character. 3.25 This Local Plan must deliver effective policy which protects and enhances the natural world by making the environment better for all. There are many ways to provide appropriate solutions at a local level; both on and off-site solutions seem relevant. These approaches need to be creative and cost-effective and in step with the Vision for the Natural Future of Cambridgeshire in 2050 (Natural Cambridgeshire and affiliated organisations). Robust site-specific decision making which is flexible and takes a balanced account of local needs is an appropriate approach.

No response proposed.