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

New developments may be able to include some greenspace but this will rarely compensate for the large areas of greenspace they will absorb without considerable effort. Furthermore developments fragment greenspace and frequently cross important wildlife corridors. We recommend that if new development is undertaken, design should follow the principles expressed in the report of the Wildlife Trusts titled “Homes for people and wildlife - How to build housing in a nature-friendly way”.

4.19 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. 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.

4.13 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. Strategic off-site opportunities offer the opportunity to significantly increase biodiversity other than providing site specific biodiversity improvements.

4.14 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. 4.15 Land at Capital Park presents opportunities to achieve a 10% biodiversity net gain through a sensitively designed, landscape-led scheme which would incorporate, wherever possible, native species of local provenance and those of known value to native wildlife to offer biodiversity gains post-development.

The Biodiversity Impact Metric is proving to be a useful tool in assessing the impacts and creating mitigation strategies for new developments to secure improvements. It is often the case that development can offer improvements above agricultural use given the increase in flora and fauna through its green spaces and planting management strategies – including both cultivated and wildlife areas within developments.

Comment - A new Local Plan is a huge opportunity to boost the natural environment. This should include wildlife spaces being created as part of new developments (as well as recreational spaces) to allow people access to nature in their daily lives. Putting in place requirements for developers to incorporate relevant biodiversity measure into new builds — at a minimum this should include 'swift bricks' and provisions for hedgehogs. SuDS should be essential in slowing the flow of and improving the quality of water entering watercourses. See also the additional relevant items discussed elsewhere in this response.

3.29 Land at Longstowe Estate presents an opportunity to deliver biodiversity net gains. The site is currently a mix of arable fields, residential and agricultural buildings of low ecological value. The development proposals, through a landscape-led approach, will seek to deliver open space that is functional whilst also creating resilient and diverse habitats. 3.30 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.

No response proposed.

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 Mill Lane Site, Sawston provides a number of opportunities to deliver biodiversity enhancements as part of the development proposal for the site. The site’s existing ecological features have been identified and have informed the development of the Vision Document illustrating how the proposed residential development of the site could be delivered. This includes the central tree belt and walking path which runs through the site which contains a mixture of mature hardwood and softwood specimens. It is proposed that this key feature would be retained and utilised to provide both ecological enhancements and amenity opportunities for future and surrounding occupiers. Additionally, existing vegetation along the site’s boundaries would be retained and bolstered, particularly along the site’s northern and western boundaries, providing further opportunities for ecological enhancements. The site’s drainage strategy will provide further opportunities to create a green-blue network across the site.

4.9.1 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.

4.13 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.

2.22. 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. 2.23. 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 for 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. 2.24. It is acknowledged that DEFRA is piloting a ‘biodiversity net gain calculator’ and there is the ability for Local Authorities to prepare their own calculator, it is highly recommended that there is a clear, transparent and consistent guide to assist in the application of such a tool. This will be of benefit to Developers, the Councils and the local community.

Pigeon supports the objective of achieving biodiversity net gain and is committed to achieving net gain through its schemes. In this context, our understanding of the system for calculating and achieving net gain indicates that it will be much more challenging to achieve net gain where development involves sites of initial high environmental value. A key initial strategy of allocating sites for development that are of lower ecological value should be adopted. The Preliminary Ecological Appraisal accompanying this submission shows the relatively low current ecological value of the proposed site south of St Neots Road, Hardwick. This increases the ability to deliver net gain as part of the development of the site and supports its allocation for housing development.

4.14 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. 4.15 Land to the South of Station Road presents opportunities to achieve a 10% biodiversity net gain through a sensitively designed, landscape-led scheme which would incorporate native species of local provenance and those of known value to native wildlife to offer biodiversity gains postdevelopment.

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 For reference as to how land west of High Street Fowlmere could improve the natural environment please refer to Question 2. Development of the site will allow for, retain and enhance existing natural features for the benefit of flora and fauna where appropriate. The retention of trees and hedgerows provides mature planting with aesthetic value that helps to mitigate the visual impact of future development.

4.22 It is important that the councils balance the level of density of a development and the variety of habitats that could be included within the development site itself. There is also the possibility of providing planning contributions for off-site improvements if there is clear evidence that a public area nearby would benefit from investment to increase the wider biodiversity of a development site or within the wider area.

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 was submitted with the previous planning application at Villiers Park produced by agb. The promoted development includes a new area of public open space and the Planting of a native hedgerow on the north-eastern boundary, install wildlife boxes for birds, bats, hedgehogs and insects, and create a log pile. It is considered that the promoted development would deliver biodiversity enhancements. The proposed development at Royston Road has been designed to minimise any impact on the existing natural landscape, with the dwellings being positioned in areas of low biodiversity value within the site. The hedgerows and the majority of the trees along the site boundaries will be retained. Careful consideration and a sensitive approach to the proposed development will result in minimal impacts on habitats of value and result in an enhancement to biodiversity.

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 west of Linton 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. The promoted development could achieve a net gain in biodiversity.

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 which 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. It should be acknowledged that in some instances net biodiversity gains would be more appropriately provided on alternative or existing sites rather than within a development site. It is suggested that the emerging GCLP should also include a policy mechanism that allows for net biodiversity gains to be delivered on alternative sites. The sites promoted by EDBF would retain any ecological features on site and seek to provide ecological enhancements. It should be noted that for most sites there is sufficient space within the site to include those ecological enhancement measures in conjunction with development, or EDBF owns other land in the vicinity that could accommodate offsite ecological enhancements. The circumstances at each site will need to be assessed in terms of their suitability and availability for ecological enhancements.

To improve our environment within a generation and leave it in a better state than we found it will mean that in this area we contribute fully to the creation of a more resilient landscape, with enhanced tree cover, richer in plants and wildlife. This will not happen simply by protecting existing sites, but by identifying where our biodiversity assets and opportunities are; and to prioritise them in land-use planning. This is putting a planning process into a new paradigm, one in which we take an active view of the contribution which areas can make to an overall environmental gain, then to consider the development potential of nominated sites, with a requirement in each case for a net gain from the development proposed. We would welcome this Plan initiating a Cambridge -based Nature Recovery Network, drawing upon examples like the West of England Nature Recovery Network. In doing so the local plan should provide a clear framework and mechanism for new development to be able to contribute to any such District level initiative.

4.19 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. Strategic off site opportunities offer the opportunity to significantly increase biodiversity other than providing site specific biodiversity improvements.

3.25 Biodiversity net gain can be achieved through a combination of off-site and on-site measures. Open space provision should include habitat diversification and creation measures, ensuring that the landscape strategy is responsive to the specific ecological assets on site and in the locality to maximise connectivity and species dispersal potential. Initiatives like SuDS, resource efficiency, biodiversity monitoring and reporting should sit alongside any net biodiversity approach and long term management. 3.26 Should the site be allocated and come forward, Trumpington South can exceed DEFRA’s targets by providing a 25%+ net biodiversity gain through offering a landscaping under Grosvenor’s control that fosters a vibrant community alongside thriving natural environments. Trumpington South provides the opportunity to extend the Trumpington Meadows Country Park providing further valuable contiguous and connected habitats. This would build on the significant biodiversity net gain achieved in the Country Park. There are also opportunities to extend the existing green infrastructure network through the site’s proposed network of green links and interconnected green spaces. Car free zones will also help encourage increased natural habitats.

4.20 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. 4.21 At Papworth, the promotion of land at ‘Site A’ will incorporate the designated Local Green Space known as the ‘Meadow at western end of Church Lane’ (ref: NH/12-063). There are two public footpaths that cross through the site (references: 180/1 and 180/2). These routes could be enhanced to become green routes, and in the long term potentially link with the County’s Greenways initiative.

• Require developers to use Natural Cambridgeshire LNP ‘Developing with Nature’ toolkit. And support the development of the toolkit for small scale development. • Favour development that secure “LNP Developing with Nature charter mark” • Develop a local Biodiversity Net Gain calculator in partnership with the Natural Cambridgeshire Local Nature Partnership and other local authorities in Cambridgeshire to reflect local priorities. And set local target for measurable Biodiversity Net Gain (using BNG calculators) to 20%. • Biodiversity Net Gain schemes that deliver local and county-wide objectives for habitat enhancement, creation and management should be favoured. WITH REFERENCE TO 4.2.3 A healthy and biodiverse environment is important for the wellbeing of all people who live, work and study within Cambridge. The provision of green spaces allows for a diverse range of learning opportunities, to enhance the curriculum offer and enable the school to offer a wider range of extra-curricular activities. It is also important for informal use and to promote the social and emotional development of pupils. • Require all Biodiversity Net Gain schemes to include 30 years (or more) management of biodiversity habitat associated with planning application, to provide sufficient time for habitats to established. • Create robust planning policies requiring developers that are unable to meet on-site BNG to contribute to off-site BNG schemes. To achieve this, a Local Plan wide strategy for biodiversity and green infrastructure to identify local priorities for habitat delivery / biodiversity projects, as part of BNG, that contribute to the local ecological network. This should be based on up-to-date evidence, including a biodiversity audit for the Local Plan area and update condition assessment surveys of all City and County Wildlife Sites. • Develop an in-house Biodiversity Net Gain scheme, whereby developers unable to meet BNG targets, are able to pay SCDC / City Council to create habitat and manage (for a minimum of 30 years). • Adequate resourced Planning Enforcement team to monitor the success of Biodiversity Net Gain schemes and ensure effective remedial action is taken

3.25 Biodiversity net gain can be achieved through a combination of off-site and on-site measures. Open space provision should include habitat diversification and creation measures, ensuring that the landscape strategy is responsive to the specific ecological assets on site and in the locality to maximise connectivity and species dispersal potential. Initiatives like SuDS, resource efficiency, biodiversity monitoring and reporting should sit alongside any net biodiversity approach and long term management. 3.26 Should the site be allocated and come forward, Trumpington South can exceed DEFRA’s targets by providing a 25%+ net biodiversity gain through offering a landscaping under Grosvenor’s control that fosters a vibrant community alongside thriving natural environments. Trumpington South provides the opportunity to extend the Trumpington Meadows Country Park providing further valuable contiguous and connected habitats. This would build on the significant biodiversity net gain achieved in the Country Park. There are also opportunities to extend the existing green infrastructure network through the site’s proposed network of green links and interconnected green spaces. Car free zones will also help encourage increased natural habitats.

Biodiversity net gain can be achieved through a combination of off-site and on-site measures. Initiatives like SuDS, resource efficiency, biodiversity monitoring and reporting should sit alongside any net biodiversity approach. Biodiversity net gain can be delivered on sites under Grosvenor’s control.

Please see section 4.0 of the accompanying representations document. This a site whereby a net biodiversity gain is attainable and also offers up an opportunity to take the pressure of other local nature reserves close to the site including Beechwoods Nature Reserve through provision of a substantial country park.

4.19 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. 4.20 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.

In addition to the examples provided in the Local Plan options document, biodiversity net gain can be achieved through: + Establishing an Urban Greening Factor for developments to achieve/ aspire to will deliver enhancement of existing sites and begin to re-introduce semi-natural haibtats to the urban fabric; + Establishing a strategic green infrastructure network plan and identifying conservation priorities for species will enable developments to feel like they are contributing to a wider benefit than isolated pockets with limited value; + The involvement of specialists in development proposals; + The requirment for long term management strategies that take climate change into consideration.