Question 14. How do we achieve biodiversity net gain through new developments?

Natural Cambridgeshire’s Developing with Nature Toolkit seeks to achieve a net gain in biodiversity through new development. It is agreed that development can deliver significant biodiversity enhancements. It is suggested that in deciding sites to allocate for development the emerging GCLP assesses not only whether the potential impacts on protected species and habitats can be mitigated but also whether development can deliver biodiversity enhancements. A Preliminary Ecological Appraisal has been undertaken of the site at land north of Oakington Road in Cottenham. The site comprises semi-improved grassland, arable, scrub and scattered trees. The promoted development would retain any ecological features on the site. The Appraisal identified a number of ecological enhancements that could be incorporated into the promoted development.

2.23 As a matter of general principle, we support a greater integration of development into the natural environment. Biodiversity net gain can be achieved in a number of ways but in relation to meeting the housing needs of the Greater Cambridge area the focus should be on site selection which minimises impacts on established biodiversity resources but equally, using development to secure regeneration and enhancement. So, for example, the enhanced value of habitat can often better be secured by positive management – such as new tree planting of appropriate species - rather than simply seeking to preserve existing poor-quality vegetation. 2.24 We would also support the principle of off-site biodiversity projects where focused habitat creation can be delivered that helps support and encourage notified species and which can be more effective, in our view, than attempting to encourage the on-site coexistence of habitat and human occupation. That does not of course preclude taking action through design to allow for the encouragement of flora and fauna within our built-up areas. 2.25 As noted, the majority of the overall site area is residential curtilage and there is significant scope to regenerate unmanaged scrub and trees. Development would not however affect previously undisturbed open countryside. 2.26 As is demonstrated in the attached plans, the proposed development could be landscaped in a means that will encourage biodiversity and fulfil other functional requirements.

4.18 The new Local Plan must ensure that policy in this matter is sufficiently flexible to accommodate the required biodiversity net gain in the most effective and efficient way for each development, with both on-site and off-site solutions possible.

2.27 The response to question 13 above sets out how the residential-led development of the site will achieve biodiversity net gain from the current intensive arable production which sees limited ecology restricted to the field margins. 2.28 This will be seen with the inclusion of green corridors, enhanced boundary planting, formal open green space, allotment provision and the potential community woodland. As previously stated, such provision will be multifunctional contributing to biodiversity net gain and this will include SuDS provision. 2.29 Finally, it should be noted that those areas shown as development on the illustrative masterplan will also contribute to biodiversity net gain. This will include the rear gardens of new homes and the more formal soft landscaping associated with the later living provision which will all enhance the position from the current arable production. 2.30 Biodiversity net gain can be measured through the emerging DEFRA toolkit and we would be confident that the proposals shown on the concept masterplan would demonstrate a biodiversity net gain through that method. In the event that an off-site payment to support biodiversity net gain is required, we would support the Authority putting in place a formal mechanism through which such contributions can be pooled to provide material beneficial improvement to biodiversity within the District, through the delivery of strategic projects.

Natural Cambridgeshire’s Developing with Nature Toolkit seeks to achieve a net gain in biodiversity through new development. It is agreed that development, and in particular large-scale development with sufficient land available, can deliver significant biodiversity enhancements. It is suggested that in deciding sites to allocate for development the emerging GCLP assesses not only whether the potential impacts on protected species and habitats can be mitigated but also whether development can deliver biodiversity enhancements. Land South of Milton Road, Impington incorporates significant areas for open space and landscaping within the Community Park element of the proposal which could be utilised to deliver biodiversity enhancements across the site in order to ensure that a net biodiversity gain is achieved.

Natural Cambridgeshire’s Developing with Nature Toolkit seeks to achieve a net gain in biodiversity through new development. It is agreed that development can deliver significant biodiversity enhancements. It is suggested that in deciding sites to allocate for development the emerging GCLP assesses not only whether the potential impacts on protected species and habitats can be mitigated but also whether development can deliver biodiversity enhancements. A Preliminary Ecological Appraisal (prepared by Applied Ecology Ltd) was submitted with the call for sites submission for land off Shepreth Road in Foxton. The promoted development includes a new area of public open space with substantial new native tree, thicket and wildflower meadow to enhance the overall biodiversity of the site. The hedges and trees along the north western boundary would be retained and protected, and native hedge and tree species would be planted to strengthen the existing boundaries. It is considered that the promoted development would deliver biodiversity enhancements.

3.16 It is important that biodiversity net gain is secured as part of new developments and a minimum of 10% target is considered to be an appropriate requirement for greenfield sites. 3.17 The site presents an opportunity to deliver biodiversity net gains. The site is currently arable fields of low ecological value and the development proposals, through a landscape led approach (as shown on the Opportunities and Constraints Plan), will seek to deliver open space that is functional whilst also creating resilient habitats which will provide important habitat for a range of wildlife and plant species.

5.14 The new Local Plan must ensure that policy in this matter is sufficiently flexible to accommodate the required biodiversity net gain in the most effective and efficient way for each development, with both on-site and off-site solutions possible. 5.15 The Council should develop a strategic offsetting mechanism. This would allow for new green infrastructure and biodiversity habitats to be strategically planned to provide greater benefit than the provision of small, uncoordinated and connected new habitats across a range of new developments.

5.16 Land to the north of Main Street, Shudy Camps, presents an opportunity to deliver biodiversity net gains. The site is currently arable fields of low ecological value and the development proposals, through a landscape-led approach, will seek to deliver open space that is functional whilst also creating resilient and diverse habitats. 5.17 The new Local Plan should ensure a sufficiently flexible policy to enhance and sustain additional biodiversity in an effective and efficient way that is optimised for each development, adopting onsite and off-site solutions.

4.1.1 It is important that the long-term impacts are considered when reviewing proposals for biodiversity net gain taking into account that many of the measures provided as part of developments will need to mature beyond the build period. 4.1.2 Gladman also take the opportunity to note that if off-site mitigation provides the best opportunity for biodiversity gain, then the policy should be flexible enough to allow for this and it should not be ruled out from the planning application process. 4.1.3 These considerations should be taken into account when drafting a policy with regards to achieving biodiversity net gain.

5.15 The new Local Plan must ensure that policy in this matter is sufficiently flexible to accommodate the required biodiversity net gain in the most effective and efficient way for each development, with both on-site and off-site solutions possible. 5.16 Land to the west of Mill Street presents an opportunity to deliver biodiversity net gains. The site is currently arable fields of low ecological value and the development proposals, through a landscape-led approach, will seek to deliver open space that is functional whilst also creating resilient habitats. The ecological appraisal accompanying these representations confirms that, through the delivery of on-site and off-site open space, the proposals could deliver a biodiversity net gain of 10%.

The new Local Plan should recognise that the most effective and efficient way to achieve biodiversity net gain through new developments is for its integration into new communities from the outset. Development should be of a sufficient scale so new green infrastructure and biodiversity habitats can be strategically planned, this will provide greater benefit than the provision of small, uncoordinated and connected new habitats across a range of new small developments. The proposal for a new community at the Six Mile Bottom Estate allows for new green infrastructure and biodiversity habitats to be strategically planned. The proposal will retain woodland areas and hedgerows and establish expansive semi-natural area reserved for wildlife with managed access so that ecology can thrive.

Natural Cambridgeshire’s Developing with Nature Toolkit seeks to achieve a net gain in biodiversity through new development. It is agreed that development, and in particular large-scale development with sufficient land available, can deliver significant biodiversity enhancements. It is suggested that in deciding sites to allocate for development the emerging GCLP assesses not only whether the potential impacts on protected species and habitats can be mitigated but also whether development can deliver biodiversity enhancements. The promoted development at land off Station Road in Willingham would retain any ecological features on site and seek to provide ecological enhancements. It should be noted that there is sufficient space within the site to include those ecological enhancement measures on site in conjunction with development.

Executive summary Provision of integral swift boxes achieves Biodiversity Net Gain at low cost. Swift boxes are the nearest there is to a general-purpose bird box for small cavity-nesting species including house sparrows, starlings, bluetits, great tits and occasionally other species such as house martins and tree sparrows. While measurable Biodiversity Net Gain relates to the provision of green habitat, the birds attracted to such habitat need somewhere to breed in urban, suburban and rural environments alike. Swifts, in particular, need help; they have declined at an average rate of 5.4% per annum over the last 10 years and by 60% in the last 25 years. Integral swift boxes also provide roosting space in winter for small birds, insects such as butterflies and the occasional bat. The Royal Institute of British Architects (RIBA) recommends a 1:1 ratio between bird nest/roost boxes and dwellings in new development. Surveys show that 75% of householders think that integral bird boxes are a good idea, 25% are neutral and <1% are not in favour. Birds in the urban environment are good for people's mental health and well-being. Background As noted in your Issues and Options Documentation, National Policy requires new developments to achieve biodiversity net gain. This process will include mitigation measures where wildlife would be impacted, enhancement of existing habitats such as native hedgerows and where possible the introduction of habitats and features to encourage additional wildlife such as birds, bats or bees. The health benefits of bringing nature and green spaces close to homes is well known. This can take the form of small open spaces, trees, hedgerows of native species, shrubberies and climbing plants to provide nectar for bees and other invertebrates and food for birds. It is also to provide nesting sites for birds close to the dwellings and ensure that there are ‘corridors’ for hedgehogs, small mammals and amphibians under garden fences. This is highlighted in Government Guidance on the NPPF issued on 21 July 2019 (see below): https://www.gov.uk/government/news/brokenshire-orders-house-builders-to-protect-wildlife https://www.gov.uk/guidance/natural-environment Paragraph 23 of this Guidance headed 'How can biodiversity net gain be achieved?' includes at the end of the first sub paragraph 'Relatively small features can often achieve important benefits for wildlife, such as incorporating 'swift bricks' and bat boxes in developments and providing safe routes for hedgehogs between different areas of habitat.' Swifts Swifts migrate to the UK from Africa every summer and they spend their life almost entirely on the wing and only come into land when nesting. They feed, sleep, collect nesting material and mate in flight. They hunt for insects over meadows, woods and open water and can travel many kilometres to do so. In typical nesting behaviour, small groups of birds fly very fast along the roof tops at the level of the eaves, screaming as they go – one of the iconic sights and sounds of summer. Decline of Cavity Nesting Birds Cavity nesting birds include swifts (largely building dependent in the UK), sparrows and starlings (urban birds). These species have nested for generations in older houses in holes and cavities under the eaves and in walls. However, they are in dramatic decline – sparrows and starlings are Red Listed and although swifts are only Amber Listed this is on a technicality as data is required over 25 years and at the time of the last assessment this data was not available for swifts. Swifts have declined at an average rate of 5.4% per annum over the last 10 years and by 60% in the last 25 years, so the swift may well move from the Amber to the Red list at the next BoCC revision in 2021. The most recent estimate is that in 2016 there were around 59,000 pairs of swifts in the UK. In addition, according to the International Union for Conservation of Nature (IUCN) criteria the swift is classified as ‘endangered’ in the UK. Although sparrows suffered a big decline some years ago, the population has been more stable in recent years and it is estimated that there are over 5 million pairs – almost 100 pairs of house sparrows to every pair of swifts. One big factor in the decline of all three is likely to be the loss of nesting sites through building renovation and insulation and more rigorous standards in new build homes. The inclusion of special nest bricks in new houses is therefore an important step in helping to halt this decline. For further information on the plight of the swift see Day et al (2019) (reference 1) and: https://actionforswifts.com https://swift-conservation.org Proposed Choice of Box Size and Type Swift boxes are frequently used by other cavity-nesting small birds such as house sparrows, starlings, great tits and bluetits and occasionally tree sparrows and house martins. A local example is at Edgecombe Flats in Cambridge. In 2010 Cambridge City Council, with help from Action for Swifts, installed 71 external swift boxes on their properties at Edgecombe Flats. In the first year, two pairs of swifts moved into boxes and small increasing numbers were observed in subsequent seasons. When a survey was carried out by the RSPB in 2016 it was found that the boxes had been occupied by 12 pairs of swifts, with evidence of many pairs of house sparrows and a few great tits! http://actionforswifts.com/2016/08/edgecombe-flats.html At Fulbourn (see Case Study) starlings and sparrows regularly use the swift boxes and in 2016 there were also 5 pairs of house martins recorded. At a Duchy of Cornwall development at Tregunnell Hill in Newquay, where an average of 1 swift box per residential home was installed, within a couple of years one third of the boxes were occupied by sparrows together with a pair of swifts: https://www.rspb.org.uk/our-work/rspb-news/news/stories/the-duchy-of-cornwall-giving-swifts-a-home/ Sparrow boxes are smaller and usually produced as 3 nest chambers in one unit (sparrow terrace) – these are too small to be used by swifts or starlings – and there is evidence that they are rarely used by more than one pair of sparrows. Occupation by a single pair of great tits or bluetits is more common. While they are colonial breeders, single boxes at least a metre apart may be preferable for both sparrows and swifts. Nest cups for swallows and house martins may be best left to new residents to provide, as many people may be put off by the level of fouling from these species. The most popular nest box likely to be purchased by families would be a tit box and given that tits will use swift bricks there seems little point in making specific provision within a scheme. In general, it is not considered a sustainable practice to place boxes in trees on new housing developments because of the problems of long-term maintenance and the potential for vandalism. Boxes within the building structure are strongly to be preferred rather than those fixed externally to the walls, as these would need longer term maintenance and their appearance can deteriorate relatively quickly. Exceptions could be for specialist species such as owls where boxes made of durable materials should be securely fixed into healthy mature trees in wooded areas. We conclude that swift boxes are the nearest there is to a general-purpose bird box for small cavity-nesting species including house sparrows, starlings, blue tits, great tits and occasionally other species such as house martins and tree sparrows. Case Study - The Swifts Development, Fulbourn This project involved the incorporation of 276 swift nest boxes (more than 1 per household) into the new houses during the re-development of the 1960s built Windmill Estate, which was home for over 150 families, as well as a large colony of swifts. Phased re-development over a number of years enabled the swifts to start to colonise the new boxes while some of the old nest sites were still available and being used. Within 6 years (to 2014) a colony of swifts that was potentially threatened by the re-development had become well established in the new housing areas with over 50% of the 168 internal boxes being used (reference 2). It is interesting to note that of the 108 external boxes less than 5% were in use. It is estimated that this project now houses over 100 pairs of Swifts. Overall it is one of the most successful nest box projects in the UK and in 2011 Rob Mungovan of SCDC received the Institute of Ecology and Environmental Management ‘Tony Bradshaw Best Practice Award’ for the project. In the 2014 survey it was also noted that 17 swift boxes (15 external and 2 internal) were being used by starlings and 9 internal boxes were used by house sparrows. Proposed Level of Nest Box Provision in New Developments In the SCDC Biodiversity SPD (2009) in Chapter 3 on ‘The Development Process’ the following points from page 34 are particularly relevant: 3.77 Biodiversity Issue B7 - Biodiversity Provision in the Design of New Buildings 1. That on all major housing developments 50% of the dwellings will have features such as bird, bat or insect boxes provided in close association with the properties. On all other sites suitable provision for biodiversity enhancements shall be negotiated to achieve a similar standard. At least a 1:1 ratio of nest bricks per dwelling is generally accepted now as good practice – a level of provision outlined in the award-winning Exeter City Council Residential Design Guide SPD (2010). Stephen Fitt of the RSPB South West Regional Office has been working with Exeter Planners over a period of 10 years on the implementation of the biodiversity requirements of this guide and there is acceptance that in many cases the most suitable box type for all cavity nesting birds is the swift brick. A similar standard was adopted by the Town and Country Planning Association and the Wildlife Trusts in 2012 (reference 3) and The Royal Institute of British Architects (RIBA) in 2013 (reference 4). The Duchy of Cornwall adopted the same principles in 2015, and a good example of the provision of a general type of integral box for all cavity nesting birds is the Nansleden development by The Duchy of Cornwall in Newquay: https://www.rspb.org.uk/our-work/rspb-news/news/stories/the-duchy-of-cornwall-giving-swifts-a-home/ The Cornwall Council Biodiversity Guide (2018) (reference 5) gives prescriptive measures for the provision of bat and bird boxes, again at the rate of 1 nest place per new dwelling. This document also includes a case study on Nansleden mentioned above. https://www.cornwall.gov.uk/media/38341273/biodiversity-guide.pdf The recent Oxford City Council Technical Advice Note on Biodiversity (reference 6) gives an ‘expected provision’ of bird nest sites for building dependent birds (i.e. swifts) at a rate of 1 per house and 1 per 2 flats, with separate provision for bats at a rate of 1 per 5 houses. Provision of such nest boxes in schools, student accommodation and hotels is addressed by a ratio of 1 per 250 m2 floor space. https://www.oxford.gov.uk/info/20067/planning_policy/745/planning_policy_-_technical_advice_notes_tan We conclude that provision of integral boxes, such as swift boxes, at a ratio of at least 1:1 per dwelling is the modern standard to accommodate a range of cavity nesting birds in new developments. Choice and Location of Swift Bricks There is now a good range of swift bricks on the market and developers can choose models best suited to blend in with their external finishes. It should be noted that for ease of installation those swift bricks compatible with UK brick sizes would be ideal. Also, there are types available, which are designed to be more easily retro-fitted to existing structures for projects where there is an element of refurbishment as well as new build. A useful Guide sponsored by Action for Swifts, Swift Conservation and the RSPB lists the models of swift bricks available in the UK (reference 7), and there is also Guidance for the placement of swift bricks in residential developments (reference 8) Enforcement Our experience of monitoring the installation of bird boxes at Northstowe and elsewhere in South Cambridgeshire has highlighted to us the difficulty of enforcement. Where there are complex schemes across a development to provide biodiversity net gain how can one be sure that they have been put in place, and even more so how are they to be maintained long term? - these are housing developments not nature reserves! Perhaps it is better to focus on providing a pleasant green environment around people’s homes with obvious features like integral bird boxes, bee and bat boxes, green infrastructure and hedgehog corridors, and have developers provide funds for more complex natural schemes off site where ongoing maintenance can be assured more easily. Green Infrastructure In order to provide a pleasant environment to support the health and wellbeing of residents it is important to retain and provide green infrastructure in the area immediately around new houses rather than houses being marooned in an area of hard landscaping separated from islands of higher value green space around the edges. Retention of existing natural hedgerows and trees and planting of new native trees, hedging and shrubs close to the dwellings will provide a suitable environment for people, birds, animals and invertebrates. These should link to the wider green corridors to encourage wildlife to live within and move through the development and to and from adjacent habitats. While swifts will travel far, if necessary, to find food, the enrichment of the habitat close to homes will attract a wider range of birds into gardens. For sparrows in particular hedges and shrubs for shelter are important close to potential nest sites. Boundaries should be permeable and ideally planted with hedging or fences with small gaps at the base to permit the movement of hedgehogs, amphibians and small mammals. Suitable shrubs and herbaceous planting can be used to encourage insects and bees. Community engagement An MSc study (reference 9), which involved interviewing residents of housing developments with integral swift bricks installed, found that 75% of the people thought that the bricks were a good thing and 85% said that their decision to buy a house would be unlikely to be negatively influenced by the presence of such a brick. From the start of the re -building of The Swifts Development, Fulbourn, the community – householders and villagers – were kept aware of plans for installation of swift boxes and Fulbourn Swifts Group was formed. Members of this group, including some residents of The Swifts estate, have monitored the progress of the swift colony and are involved in swift conservation projects locally. Such groups contribute to community cohesion and help to promote social wellbeing. Across the UK there are over 80 citizen groups participating in The Swifts Local Network raising awareness, raising funds, installing nest boxes, providing education and generally supporting the conservation of swifts and other aspects of biodiversity under threat. A good example of what can be done by a developer is provided by The Duchy of Cornwall, which is planning to install between 5,000 and 8,000 swift boxes on new developments across the south of England over the next 30 years and a new citizen science survey has been instigated, which will involve residents of three new developments in Cornwall observing and reporting on the species that take up the nest boxes in their neighbourhood: https://www.rspb.org.uk/our-work/rspb-news/news/stories/the-big-birdbox-survey/ Conclusions The inclusion of versatile swift bricks, which can be used by a range of species, in all new developments (including small infill) in line with current best practice (at least 1:1 ratio) is a sustainable and cost-effective way of contributing to gains in biodiversity and bringing nature close to people. This should be part of a wider environmental plan which includes the provision of green infrastructure near to the houses so that species such as sparrows can benefit from shelter (hedges and shrubbery) and foraging areas. The need to incorporate just one box type across the whole site could also provide advantages for the builders and help to address compliance issues. Developments of flats, offices, hotels and other commercial premises should also be required to make provision for these boxes to encourage a variety of species on those sites. There should be separate provision for special birds such as owls, bats and solitary bees according to the nature and location of the site being developed. References 1. Day, J., Mayer, E., Newell, R., (2019), ‘inpractice’ – Bulletin of the Chartered Institute of Ecology and Environmental Management, Issue 104 June, p.38 2. Willis, J. (2015) ‘Common Swift Monitoring 2014, The Swifts Development Fulbourn’, Fulbourn Swifts Group for Carter Homes. 3. Planning for a Healthy Environment; Good Practice for Green Infrastructure and Biodiversity. The Town and Country Planning Association and The Wildlife Trusts (2012) 4. Gunnell, K., Murphy, B. and Williams, C., Designing for Biodiversity: A technical guide for new and existing buildings, RIBA Publishing & Bat Conservation Trust (2013). 5. Cornwall Council Biodiversity Guide (2018) available here: https://www.cornwall.gov.uk/media/38341273/biodiversity-guide.pdf 6. Oxford City Council Technical Advice Note: Biodiversity – Planning Application Guidance available at: https://www.oxford.gov.uk/info/20067/planning_policy/745/planning_policy_-_technical_advice_notes_tan 7. Newell, R., (2019) ‘Facts About Swift Bricks’, Action for Swifts, Swift Conservation and RSPB, available here: https://tinyurl.com/swiftbricks 8. Newell, R., (2019) ‘Guidance for Including Bird Boxes in Residential Development’, Action for Swifts, available at: http://actionforswifts.com/2019/02/guidance-for-including-bird-boxes-in.html ; http://actionforswifts.com/p/rbbg.html 9. Roberts, S. (2017) ‘The attitudes of housing occupants to integral bird and bat boxes.’ Unpublished MSc thesis, University of Gloucestershire. Summary available here: https://actionforswifts.blogspot.com/search?q=roberts

Executive summary Provision of integral swift boxes achieves Biodiversity Net Gain at low cost. Swift boxes are the nearest there is to a general-purpose bird box for small cavity-nesting species including house sparrows, starlings, bluetits, great tits and occasionally other species such as house martins and tree sparrows. While measurable Biodiversity Net Gain relates to the provision of green habitat, the birds attracted to such habitat need somewhere to breed in urban, suburban and rural environments alike. Swifts, in particular, need help; they have declined at an average rate of 5.4% per annum over the last 10 years and by 60% in the last 25 years. Integral swift boxes also provide roosting space in winter for small birds, insects such as butterflies and the occasional bat. The Royal Institute of British Architects (RIBA) recommends a 1:1 ratio between bird nest/roost boxes and dwellings in new development. Surveys show that 75% of householders think that integral bird boxes are a good idea, 25% are neutral and <1% are not in favour. Birds in the urban environment are good for people's mental health and well-being. Background As noted in your Issues and Options Documentation, National Policy requires new developments to achieve biodiversity net gain. This process will include mitigation measures where wildlife would be impacted, enhancement of existing habitats such as native hedgerows and where possible the introduction of habitats and features to encourage additional wildlife such as birds, bats or bees. The health benefits of bringing nature and green spaces close to homes is well known. This can take the form of small open spaces, trees, hedgerows of native species, shrubberies and climbing plants to provide nectar for bees and other invertebrates and food for birds. It is also to provide nesting sites for birds close to the dwellings and ensure that there are ‘corridors’ for hedgehogs, small mammals and amphibians under garden fences. This is highlighted in Government Guidance on the NPPF issued on 21 July 2019 (see below): https://www.gov.uk/government/news/brokenshire-orders-house-builders-to-protect-wildlife https://www.gov.uk/guidance/natural-environment Paragraph 23 of this Guidance headed 'How can biodiversity net gain be achieved?' includes at the end of the first sub paragraph 'Relatively small features can often achieve important benefits for wildlife, such as incorporating 'swift bricks' and bat boxes in developments and providing safe routes for hedgehogs between different areas of habitat.' Swifts Swifts migrate to the UK from Africa every summer and they spend their life almost entirely on the wing and only come into land when nesting. They feed, sleep, collect nesting material and mate in flight. They hunt for insects over meadows, woods and open water and can travel many kilometres to do so. In typical nesting behaviour, small groups of birds fly very fast along the roof tops at the level of the eaves, screaming as they go – one of the iconic sights and sounds of summer. Decline of Cavity Nesting Birds Cavity nesting birds include swifts (largely building dependent in the UK), sparrows and starlings (urban birds). These species have nested for generations in older houses in holes and cavities under the eaves and in walls. However, they are in dramatic decline – sparrows and starlings are Red Listed and although swifts are only Amber Listed this is on a technicality as data is required over 25 years and at the time of the last assessment this data was not available for swifts. Swifts have declined at an average rate of 5.4% per annum over the last 10 years and by 60% in the last 25 years, so the swift may well move from the Amber to the Red list at the next BoCC revision in 2021. The most recent estimate is that in 2016 there were around 59,000 pairs of swifts in the UK. In addition, according to the International Union for Conservation of Nature (IUCN) criteria the swift is classified as ‘endangered’ in the UK. Although sparrows suffered a big decline some years ago, the population has been more stable in recent years and it is estimated that there are over 5 million pairs – almost 100 pairs of house sparrows to every pair of swifts. One big factor in the decline of all three is likely to be the loss of nesting sites through building renovation and insulation and more rigorous standards in new build homes. The inclusion of special nest bricks in new houses is therefore an important step in helping to halt this decline. For further information on the plight of the swift see Day et al (2019) (reference 1) and: https://actionforswifts.com https://swift-conservation.org Proposed Choice of Box Size and Type Swift boxes are frequently used by other cavity-nesting small birds such as house sparrows, starlings, great tits and bluetits and occasionally tree sparrows and house martins. A local example is at Edgecombe Flats in Cambridge. In 2010 Cambridge City Council, with help from Action for Swifts, installed 71 external swift boxes on their properties at Edgecombe Flats. In the first year, two pairs of swifts moved into boxes and small increasing numbers were observed in subsequent seasons. When a survey was carried out by the RSPB in 2016 it was found that the boxes had been occupied by 12 pairs of swifts, with evidence of many pairs of house sparrows and a few great tits! http://actionforswifts.com/2016/08/edgecombe-flats.html At Fulbourn (see Case Study) starlings and sparrows regularly use the swift boxes and in 2016 there were also 5 pairs of house martins recorded. At a Duchy of Cornwall development at Tregunnell Hill in Newquay, where an average of 1 swift box per residential home was installed, within a couple of years one third of the boxes were occupied by sparrows together with a pair of swifts: https://www.rspb.org.uk/our-work/rspb-news/news/stories/the-duchy-of-cornwall-giving-swifts-a-home/ Sparrow boxes are smaller and usually produced as 3 nest chambers in one unit (sparrow terrace) – these are too small to be used by swifts or starlings – and there is evidence that they are rarely used by more than one pair of sparrows. Occupation by a single pair of great tits or bluetits is more common. While they are colonial breeders, single boxes at least a metre apart may be preferable for both sparrows and swifts. Nest cups for swallows and house martins may be best left to new residents to provide, as many people may be put off by the level of fouling from these species. The most popular nest box likely to be purchased by families would be a tit box and given that tits will use swift bricks there seems little point in making specific provision within a scheme. In general, it is not considered a sustainable practice to place boxes in trees on new housing developments because of the problems of long-term maintenance and the potential for vandalism. Boxes within the building structure are strongly to be preferred rather than those fixed externally to the walls, as these would need longer term maintenance and their appearance can deteriorate relatively quickly. Exceptions could be for specialist species such as owls where boxes made of durable materials should be securely fixed into healthy mature trees in wooded areas. We conclude that swift boxes are the nearest there is to a general-purpose bird box for small cavity-nesting species including house sparrows, starlings, blue tits, great tits and occasionally other species such as house martins and tree sparrows. Case Study - The Swifts Development, Fulbourn This project involved the incorporation of 276 swift nest boxes (more than 1 per household) into the new houses during the re-development of the 1960s built Windmill Estate, which was home for over 150 families, as well as a large colony of swifts. Phased re-development over a number of years enabled the swifts to start to colonise the new boxes while some of the old nest sites were still available and being used. Within 6 years (to 2014) a colony of swifts that was potentially threatened by the re-development had become well established in the new housing areas with over 50% of the 168 internal boxes being used (reference 2). It is interesting to note that of the 108 external boxes less than 5% were in use. It is estimated that this project now houses over 100 pairs of Swifts. Overall it is one of the most successful nest box projects in the UK and in 2011 Rob Mungovan of SCDC received the Institute of Ecology and Environmental Management ‘Tony Bradshaw Best Practice Award’ for the project. In the 2014 survey it was also noted that 17 swift boxes (15 external and 2 internal) were being used by starlings and 9 internal boxes were used by house sparrows. Proposed Level of Nest Box Provision in New Developments In the SCDC Biodiversity SPD (2009) in Chapter 3 on ‘The Development Process’ the following points from page 34 are particularly relevant: 3.77 Biodiversity Issue B7 - Biodiversity Provision in the Design of New Buildings 1. That on all major housing developments 50% of the dwellings will have features such as bird, bat or insect boxes provided in close association with the properties. On all other sites suitable provision for biodiversity enhancements shall be negotiated to achieve a similar standard. At least a 1:1 ratio of nest bricks per dwelling is generally accepted now as good practice – a level of provision outlined in the award-winning Exeter City Council Residential Design Guide SPD (2010). Stephen Fitt of the RSPB South West Regional Office has been working with Exeter Planners over a period of 10 years on the implementation of the biodiversity requirements of this guide and there is acceptance that in many cases the most suitable box type for all cavity nesting birds is the swift brick. A similar standard was adopted by the Town and Country Planning Association and the Wildlife Trusts in 2012 (reference 3) and The Royal Institute of British Architects (RIBA) in 2013 (reference 4). The Duchy of Cornwall adopted the same principles in 2015, and a good example of the provision of a general type of integral box for all cavity nesting birds is the Nansleden development by The Duchy of Cornwall in Newquay: https://www.rspb.org.uk/our-work/rspb-news/news/stories/the-duchy-of-cornwall-giving-swifts-a-home/ The Cornwall Council Biodiversity Guide (2018) (reference 5) gives prescriptive measures for the provision of bat and bird boxes, again at the rate of 1 nest place per new dwelling. This document also includes a case study on Nansleden mentioned above. https://www.cornwall.gov.uk/media/38341273/biodiversity-guide.pdf The recent Oxford City Council Technical Advice Note on Biodiversity (reference 6) gives an ‘expected provision’ of bird nest sites for building dependent birds (i.e. swifts) at a rate of 1 per house and 1 per 2 flats, with separate provision for bats at a rate of 1 per 5 houses. Provision of such nest boxes in schools, student accommodation and hotels is addressed by a ratio of 1 per 250 m2 floor space. https://www.oxford.gov.uk/info/20067/planning_policy/745/planning_policy_-_technical_advice_notes_tan We conclude that provision of integral boxes, such as swift boxes, at a ratio of at least 1:1 per dwelling is the modern standard to accommodate a range of cavity nesting birds in new developments. Choice and Location of Swift Bricks There is now a good range of swift bricks on the market and developers can choose models best suited to blend in with their external finishes. It should be noted that for ease of installation those swift bricks compatible with UK brick sizes would be ideal. Also, there are types available, which are designed to be more easily retro-fitted to existing structures for projects where there is an element of refurbishment as well as new build. A useful Guide sponsored by Action for Swifts, Swift Conservation and the RSPB lists the models of swift bricks available in the UK (reference 7), and there is also Guidance for the placement of swift bricks in residential developments (reference 8) Enforcement Our experience of monitoring the installation of bird boxes at Northstowe and elsewhere in South Cambridgeshire has highlighted to us the difficulty of enforcement. Where there are complex schemes across a development to provide biodiversity net gain how can one be sure that they have been put in place, and even more so how are they to be maintained long term? - these are housing developments not nature reserves! Perhaps it is better to focus on providing a pleasant green environment around people’s homes with obvious features like integral bird boxes, bee and bat boxes, green infrastructure and hedgehog corridors, and have developers provide funds for more complex natural schemes off site where ongoing maintenance can be assured more easily. Green Infrastructure In order to provide a pleasant environment to support the health and wellbeing of residents it is important to retain and provide green infrastructure in the area immediately around new houses rather than houses being marooned in an area of hard landscaping separated from islands of higher value green space around the edges. Retention of existing natural hedgerows and trees and planting of new native trees, hedging and shrubs close to the dwellings will provide a suitable environment for people, birds, animals and invertebrates. These should link to the wider green corridors to encourage wildlife to live within and move through the development and to and from adjacent habitats. While swifts will travel far, if necessary, to find food, the enrichment of the habitat close to homes will attract a wider range of birds into gardens. For sparrows in particular hedges and shrubs for shelter are important close to potential nest sites. Boundaries should be permeable and ideally planted with hedging or fences with small gaps at the base to permit the movement of hedgehogs, amphibians and small mammals. Suitable shrubs and herbaceous planting can be used to encourage insects and bees. Community engagement An MSc study (reference 9), which involved interviewing residents of housing developments with integral swift bricks installed, found that 75% of the people thought that the bricks were a good thing and 85% said that their decision to buy a house would be unlikely to be negatively influenced by the presence of such a brick. From the start of the re -building of The Swifts Development, Fulbourn, the community – householders and villagers – were kept aware of plans for installation of swift boxes and Fulbourn Swifts Group was formed. Members of this group, including some residents of The Swifts estate, have monitored the progress of the swift colony and are involved in swift conservation projects locally. Such groups contribute to community cohesion and help to promote social wellbeing. Across the UK there are over 80 citizen groups participating in The Swifts Local Network raising awareness, raising funds, installing nest boxes, providing education and generally supporting the conservation of swifts and other aspects of biodiversity under threat. A good example of what can be done by a developer is provided by The Duchy of Cornwall, which is planning to install between 5,000 and 8,000 swift boxes on new developments across the south of England over the next 30 years and a new citizen science survey has been instigated, which will involve residents of three new developments in Cornwall observing and reporting on the species that take up the nest boxes in their neighbourhood: https://www.rspb.org.uk/our-work/rspb-news/news/stories/the-big-birdbox-survey/ Conclusions The inclusion of versatile swift bricks, which can be used by a range of species, in all new developments (including small infill) in line with current best practice (at least 1:1 ratio) is a sustainable and cost-effective way of contributing to gains in biodiversity and bringing nature close to people. This should be part of a wider environmental plan which includes the provision of green infrastructure near to the houses so that species such as sparrows can benefit from shelter (hedges and shrubbery) and foraging areas. The need to incorporate just one box type across the whole site could also provide advantages for the builders and help to address compliance issues. Developments of flats, offices, hotels and other commercial premises should also be required to make provision for these boxes to encourage a variety of species on those sites. There should be separate provision for special birds such as owls, bats and solitary bees according to the nature and location of the site being developed. References 1. Day, J., Mayer, E., Newell, R., (2019), ‘inpractice’ – Bulletin of the Chartered Institute of Ecology and Environmental Management, Issue 104 June, p.38 2. Willis, J. (2015) ‘Common Swift Monitoring 2014, The Swifts Development Fulbourn’, Fulbourn Swifts Group for Carter Homes. 3. Planning for a Healthy Environment; Good Practice for Green Infrastructure and Biodiversity. The Town and Country Planning Association and The Wildlife Trusts (2012) 4. Gunnell, K., Murphy, B. and Williams, C., Designing for Biodiversity: A technical guide for new and existing buildings, RIBA Publishing & Bat Conservation Trust (2013). 5. Cornwall Council Biodiversity Guide (2018) available here: https://www.cornwall.gov.uk/media/38341273/biodiversity-guide.pdf 6. Oxford City Council Technical Advice Note: Biodiversity – Planning Application Guidance available at: https://www.oxford.gov.uk/info/20067/planning_policy/745/planning_policy_-_technical_advice_notes_tan 7. Newell, R., (2019) ‘Facts About Swift Bricks’, Action for Swifts, Swift Conservation and RSPB, available here: https://tinyurl.com/swiftbricks 8. Newell, R., (2019) ‘Guidance for Including Bird Boxes in Residential Development’, Action for Swifts, available at: http://actionforswifts.com/2019/02/guidance-for-including-bird-boxes-in.html ; http://actionforswifts.com/p/rbbg.html 9. Roberts, S. (2017) ‘The attitudes of housing occupants to integral bird and bat boxes.’ Unpublished MSc thesis, University of Gloucestershire. Summary available here: https://actionforswifts.blogspot.com/search?q=roberts

The National Trust supports the Local Nature Partnership’s (Natural Cambridgeshire) Developing with Nature Toolkit, which aims to achieve a 20% net gain in biodiversity across development sites. This will help ensure the application of consistent standards throughout the Local Plan area.

We would like to see the Local Plan support greater use of the Developing with Nature Toolkit. Could planning applications be required to include a completed toolkit score sheet? Or could those applicants that complete the toolkit and achieve a high score be looked upon favourably? • We believe that Greater Cambridge should set a policy requirement for a minimum of 20% biodiversity net gain from new development (excluding householder applications). This is required for two main reasons: i. the way that biodiversity metrics operate, a 10% net gain is within the 10% margin of error for creating replacement habitat, meaning that in reality there may be no actual gain when it is delivered. This is the main reason why there has been a change in National Planning Policy because the previous “no net loss” policy was in some cases delivering a 10% loss. In effect, a 10% net-gain policy does not guarantee an actual 10% gain in biodiversity. In order to guarantee a 10% net gain would require a 20% net gain policy. ii. because of the general impoverishment in biodiversity of the Greater Cambridge area, caused largely by the intensive agriculture, but also as a result of past development. Cambridgeshire has a much lower percentage of natural habitats than most lowland counties. In order to deliver the vision to double nature that has been adopted by the local councils a 20% net gain will be required to make a measurable contribution. The Greater Cambridge planning authority will need to identify a Nature Recovery Network within the Local Plan but should also prepare a Nature Recovery (or Biodiversity & Green Infrastructure) Strategy that supports this (either as a full Development Plan Document or a Supplementary Planning Document). We have suggested a nature recovery network for Cambridge in our answer to question 12. The development process/Local Plan should 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. • There is a debate to be had about whether better biodiversity gains could be achieved through off-site biodiversity off-setting versus delivering them on-site. For example, evidence has shown that on-site habitat creation for Great Crested Newts has often been unsuccessful and as a consequence a new system is being introduced that will use developer contributions to create new habitat off-site. The well-being benefits to the new residents of on-site biodiversity provision (which also makes more attractive developments which uplift sales prices) needs to be weighed-up against off-setting nearby where greater biodiversity benefits can be achieved. This is likely to be more of an issue for small/medium sized developments that often find it difficult to include suitable space on the development site. • One problem of biodiversity offsetting is that the results are often not known for years (think how long it takes a tree to mature) and sometimes fail (ponds without water for example). There is no mechanism for redressing this and therefore no incentive (other than a moral one) for developers to get it right. The Local Plan should include a mechanism to record and monitor implementation of the biodiversity net gain system and the delivery of both on-site and off-site habitat creation. • We would encourage the Local Plan to promote landscape design that supports greater biodiversity. This requires a culture change within the development sector and also from the house-buying public in order to accept such changes. For example, to recognise that meadows or rough grassland have much greater benefits than amenity grassland, even if at certain times of the year that means they look ‘untidy’. That gaps in garden fencing are essential for the movement of animals such as hedgehogs. This is already changing but we would encourage the Local Plan to do what is possible to make this mainstream. Not only is this better for wildlife but it should be much more cost-effective to have a meadow which is cut once or twice a year than amenity grassland which is cut regularly. There are some trends that we are seeing in new developments which are not helpful to biodiversity and which it would be helpful if the Local Plan could address: i. The provision of bird and bat boxes without consideration of whether there is already sufficient provision of these in the neighbourhood or whether there is suitable habitat to support the species that these boxes have been put up for. We have seen developments/applications where this is not the case. Boxes do not provide the habitat that species need to survive (ie food). If there is not sufficient habitat or there are already boxes in place then putting up boxes on new developments is a waste of time/money. We would like to see the Local Plan (or any associated SPD) place greater emphasis on habitat creation. ii. Sustainable Urban Drainage Schemes are moving away from being ponds (ie holding permanent water) to becoming swales (ie not holding permanent water). We suspect this is because swales are easier to create and maintain and have lower health & safety risks. However permanent ponds provide much richer wildlife diversity and are increasingly important in helping species during extreme weather (especially heat and drought). We would like the Local Plan to support SUDS that include at least some permanent water. iii. The creation of habitats on developments sites that are surrounded by roads or buildings, making it dangerous or very difficult for creatures to get to, or leave. Habitats should be linked within and through development sites for ecological connectivity – or located on the edge of the development site if they are adjacent to green space/countryside.

Local Plan policies should establish a minimum requirement for Biodiversity Net Gain (we have suggested 20%). The Greater Cambridge planning authority will need to identify a Nature Recovery Network within the Local Plan but should also prepare a Nature Recovery (or Biodiversity & Green Infrastructure) Strategy that supports this (either as a full Development Plan Document or a Supplementary Planning Document). Ideally this document would be prepared covering the whole county. Biodiversity off-setting does not replace the mitigation hierarchy and internationally and nationally important nature conservation sites and irreplaceable habitats must be excluded, as adverse impacts on these should be avoided at all costs. The Nature Recovery Strategy should describe how Biodiversity Net Gain will be calculated. Where there are cases of biodiversity losses or insufficient net gains, the strategy will need to set out a mechanism and process for developers to arrange for biodiversity off-sets elsewhere through accredited habitat banks, or else through the payment of a tariff to provide for the necessary biodiversity off-sets. The strategy will need to set out how the councils will use the tariff collected. The nature recovery strategy would need to establish the rules for where biodiversity off-sets will be acceptable, including the balance between any strategic county-wide provision (e.g. large fenland wetland creation projects) versus local provision within the Greater Cambridge area. We would expect the majority of off-site biodiversity measures to be provided in or immediately adjacent to the Greater Cambridge area, but a proportion should be used to support internationally and nationally strategic projects elsewhere in Cambridgeshire. It would be advantageous to establish one or more habitat banks locally, to help ensure offsets are directed to the best locations and biodiversity off-set sites should ideally be secured permanently. The strategy could also make provision for a fee system paid for by developers to enable the local councils to have the resources to properly record and monitor implementation of the biodiversity net gain system and the delivery of both on-site and off-site habitat creation.

Mandatory inclusion of requirements for biodiversity net gain for every development. Encourage participation of residents with clear measurements of the effects to encourage everyone to meet stretch goals. Less need to travel for every day work decreases carbon emissions and pollution. Increase the community who are interested in maintaining and promoting biodiversity in the place where they live, and they are bringing up their children. Consider using Hedges rather than fences in place of Fences in new development. Consult with Environment committees on your local Parish Councils, they will have done a lot of the groundwork. Their local knowledge is essential for understanding the bigger picture. Build from bottom up.

• Unless the site is previously brown-field or intensive agriculture, true and effective biodiversity net gain is often not achieved. Also the density of development may militate against this aim. Short cut grass for recreation does not achieve biodiversity. Undisturbed, wilder land is required. • The way site density is calculated militates against achieving biodiversity enhancement. Developers should provide additional adjacent land exclusively for ‘natural’ spaces, both wild and semi-wild. If this cannot be achieved on site then the required enhancement must be achieved off-site. Such biodiverse areas must be properly managed and funded, in perpetuity, which means professional inspection and assessment, and the will of the authorities to take action if they are not properly maintained.

New developments, such as that on land to the rear of Nos. 67-69 High Street, Meldreth can achieve biodiversity net gain through the inclusion of green corridors, enhanced boundary planting and open space provision. There is the potential for major developments to provide a greater level of enhancement through allotment provision, community woodlands, and woodland walks. Furthermore, SuDS features also have the potential to provide net gains in biodiversity. In terms of the submitted indicative master plan that relates to land rear of Nos. 67-69 High Street, Meldreth, the proposal would contribute to biodiversity through the rear gardens of new homes and soft landscaping provided within the site. It is also proposed to provide open space within the site as part of the development scheme. The plan as submitted is indicative at this stage and represents an initial design concept. There is scope to amend the layout to include further net gain in biodiversity.

The Issues and Options report correctly identifies that net gains can be achieved at building design level through to strategic landscape management level. Net gain can also be achieved through off-site measures, although it would seem appropriate that mitigation is carried out on site where applicable. In this context, larger scale sites will be more favourable because of their ability to provide green infrastructure alongside built development and other infrastructure . In carrying out biodiversity assessments, value should be placed on the longevity of new communities and new natural habitats associated with them. These habitats are designed to be retained in perpetuity. Existing trees and hedgerows may be given high biodiversity value because of their longevity, but it should also be recognised that older trees will eventually die. New environmental features and natural habitats can have significant ecological value as they mature over a period of decades following construction.

Lolworth Developments Ltd (LDL) has submitted a 100ha employment site proposal to the 'Call for Sites' consultation in March 2019. LDL has submitted further supporting evidence as to why the site is the best location to serve the area and the 'final mile' into Cambridge. See Strategic Case Report and Vision Document submitted under Q2. The new Local Plan must ensure that policy in this matter is sufficiently flexible to accommodate the required biodiversity net gain in the most effective and efficient way for each development, with both onsite and off-site solutions possible. Working with developers who can deliver this in taking a holistic approach to sites capable of development. Summary: The new Local Plan must ensure that policy in this matter is sufficiently flexible to accommodate the required biodiversity net gain in the most effective and efficient way for each development, with both onsite and off-site solutions possible. Summary of Comments: Please see summary above.

Lolworth Developments Ltd (LDL) has submitted a 100ha employment site proposal to the 'Call for Sites' consultation in March 2019. LDL has submitted further supporting evidence as to why the site is the best location to serve the area and the 'final mile' into Cambridge. See Strategic Case Report and Vision Document submitted under Q2. The new Local Plan must ensure that policy in this matter is sufficiently flexible to accommodate the required biodiversity net gain in the most effective and efficient way for each development, with both onsite and off-site solutions possible. Working with developers who can deliver this in taking a holistic approach to sites capable of development. Summary The new Local Plan must ensure that policy in this matter is sufficiently flexible to accommodate the required biodiversity net gain in the most effective and efficient way for each development, with both onsite and off-site solutions possible. Summary of Comments: Please see summary above.

Develop an ecological viability standard.

Natural Cambridgeshire’s Developing with Nature Toolkit seeks to achieve a net gain in biodiversity through new development. It is agreed that development can deliver significant biodiversity enhancements. It is suggested that in deciding sites to allocate for development the emerging GCLP assesses not only whether the potential impacts on protected species and habitats can be mitigated but also whether development can deliver biodiversity enhancements. An Ecological Appraisal has been undertaken of the site at Beach Road in Cottenham. This confirms that the site is dominated by intensively managed arable land which is of negligible ecological value. The Appraisal identified a number of ecological enhancements that could be incorporated into the promoted development and would result in net biodiversity gains across the site.

4.43 A flexible approach should be adopted when requiring new development to achieve biodiversity net gain. Policy which includes requirements to install particular features such as green roof and green wall should be avoided, as this can be to the detriment of other sustainability measures such as solar PVs. Furthermore, green roofs and walls may not be appropriate for certain building types such as typical logistics uses where the additional loading requirements from substrate and water retention can risk the viability of the project. 4.44 A holistic approach should be undertaken, encouraging biodiversity solutions which provide additional benefits such as recreation, climate change mitigation and climate change resilience. Green roofs will likely contribute to the embodied carbon of a development due to the requirement of additional loading and reinforcement required to the building structure, which may outweigh the ecological benefits. Tree and hedgerow planting however, are likely to be more effective at absorbing CO2 and providing habitat for a broader range of faunal species. 4.45 The same applies to living walls, which although give a strong, green aesthetic to a building, are likely to require recirculatory water systems which may increase the embodied carbon and operational energy of the project. Furthermore, green walls are unlikely to support many faunal species, and will mainly be limited to insects and foraging birds. 4.46 It is therefore recommended that a biodiversity net gain is required for new development, which should be calculated using a nationally recognised method such as the DEFRA Biodiversity Metric. The developer and design team should be responsible for identifying an ecological outcome which is most appropriate for the site to achieve the net gain. 4.47 It must be recognised by the Local Plan that biodiversity net gain is not always possible to achieve on all sites. Where biodiversity offsetting is required, a transparent system is required so that developers have a clear understanding of costs and outcomes that do not impair development viability. Opportunities for the Local Plan to align local carbon offsetting requirements (e.g. tree planting) with biodiversity offsetting should also be pursued to maximise efficiencies and opportunities between these initiatives. 4.48 Newlands Developments is committed to achieving ecological enhancements on all sites.

Please refer to the Sustainability Vision Statement which seeks out opportunities to bring the big themes to life in every aspect of the project. In terms of shaping a policy that addresses biodiversity net gain, the NPPF (paragraph 175) identifies that when determining planning applications, local planning authorities should apply the following principle: "if significant harm to biodiversity resulting from a development cannot be avoided (through locating on an alternative site with less harmful impacts, adequately mitigated, or, as a last resort, compensated for, the planning permission should be refused". Marshall would support a policy that encourages individual proposals to achieve a 10% net gain, but this policy should consider mechanisms that enable sites to approach this net gain flexibly depending on the specific site context, e.g. off-site where necessary and appropriate.

Claremont Planning are instructed on behalf of European Property Ventures(Cambridgeshire) to submit representations to influence the emerging plan's consideration of green spaces alongside the emerging strategy to address the cause of Climate Change. It is advanced that the enhancement of the biodiversity of existing settlements can only be delivered through development that recognises the necessity to deliver improved green spaces and ecological enhancements. Farming practises can not be relied upon to deliver such enhancements and the only means of positively contributing to the green space and ecological qualities of any settlement is through the development influence of land. European Property Ventures (Cambridgeshire) contend that land within their control at Oakington has the ability to provide new Green Space within parts of their site that are influenced by local drainage patterns. The frontage of their Dry Drayton Road site has the potential to contribute toward the provision of new green spaces that will positively influence the setting of the village, which alongside residential development will provide public access to natural environments that occur with the emerging plan's objective to contribute new green spaces through the development strategy. The resulting green space on the site would be multi-functional through he mitigation of flood waters and a positive drainage strategy, defining a landscaped edge to the south through a new development framework limit and significant enhancement through orchard planting around the new dwellings. Summary of Comments: Delivery of green spaces must be recognised as linked to provision of development.

5.17 The new Local Plan must ensure that policy in this matter is sufficiently flexible to accommodate the required biodiversity net gain in the most effective and efficient way for each development, with both on-site and off-site solutions possible.