Biodiversity (Chapter 6)

The adopted Cambridge and South Cambridgeshire Local Plans contain policies requiring “no net loss in biodiversity”.
However, in England Biodiversity Net Gain (BNG) is mandatory under Schedule 7A of the Town and Country Planning Act 1990 (as inserted by Schedule 14 of the Environment Act 2021). Nationally, developers must deliver a BNG of at least 10% for all developments to deliver more or a better quality natural habitat than there was before development.

The draft SPD incorporates the introduction of statutory BNG of 10% (Para 6.4) but also sets out …” an aspirational vision to achieve 20% BNG encouraged as best practice”, for which there is no national requirement, nor does this requirement appear in adopted plan policies. It is noted that the amended draft has now dropped the original SPD intention to incorporate the 20% BNG level within the new GCLP.

Caius seeks confirmation that the emerging GCLP will only seek the statutory BNG of 10% and will not seek a 20% BNG as a minimum. Whilst at this stage the wording appears discretionary, Caius (along with its partners IWM and Henry Boot Developments) is concerned that the stated intention to encourage 20% BNG could give rise to uncertainty in viability assessments and pressure to deliver the 20% target in negotiations without justification, delaying delivery of important development projects.

If the planning authorities wish to encourage 20% BNG then this should be a matter for an independent Inspector of the emerging Local Plan to review by way of an EiP based on whether it will actually impact viability of development, as this is outside the remit of the SPD.

Whilst Pigeon welcome a number of the changes made to this section to highlight that the provision of 20% BNG is only an aspirational target to be encouraged it is considered that it should go further by adding the words “where possible” as a reflection of the fact that provision of 20% BNG will simply not be possible in many cases, particularly many smaller, more constrained sites within the Cambridge urban area or within village settlement frameworks.

Endurance is concerned that the aspirational target for 20% BNG goes beyond the requirements of the adopted Development Plan, contrary to Planning Practice Guidance.

Endurance considers that there is insufficient policy support to justify the use of planning obligations for these services and is concerned that the Councils appear to be introducing new policy approaches which go beyond the requirements of the adopted Development Plan contrary to the PPG. As such, it is considered that the proposed approach within the draft SPD would not meet the statutory and policy tests within Regulation 122 and the NPPF.

Please find attached representation submitted on behalf of our client, Vistry Strategic Land and Major Projects, regarding the draft Planning Obligations SPD.

1) Page 45- para 6.12- Chapter 6 Biodiversity
Reference should be made to the local needs/characteristics of the local area /informed by the LNRS Cambridgeshire (2025).

2)Para 6.13- ‘Adequate ecological information’- reference the LNRS is needed

3)Para. 6.15- Habitat Surveys- local Biodiversity Audits should be referred to ( for example Gamlingay Local Biodiversity Audit – (in draft 2025).

4)Para 7.9- Page 50 Also should reference Neighbourhood Plans in terms of community facility needs and infrastructure.

5)Page 63 Para 10.11 Other relevant transport strategies- reference needed to local Neighbourhood Plans (i.e. GAM8 policy in Gamlingay Neighbourhood Plan specifically relates to active travel infrastructure)

6) Page 77 para. 13.6- Should reference that developers should seek early engagement with the ‘Local Burial Authority’ concerning needs for burial space. This reference should encompass both town and parish councils and district councils who have this remit.

7) General comment- Page 118 para 21.5 keeping important local village PROWs open throughout build programmes is essential for keeping local facilities accessible to their residents. Resources should be made available for temporary diversions to be in place at all times.

8)Page 122- para.22.10 – reference is made to both Gamlingay and Bassingbourn GP practices. Please develop a clear protocol what happens in these areas with regard to providing healthcare infrastructure. There needs to be a clear alternative approach and clarification here, to ensure these communities do not lose out. What is the procedure in these areas?

1) Page 45- para 6.12- Chapter 6 Biodiversity
Reference should be made to the local needs/characteristics of the local area /informed by the LNRS Cambridgeshire (2025).

2)Para 6.13- ‘Adequate ecological information’- reference the LNRS is needed

3)Para. 6.15- Habitat Surveys- local Biodiversity Audits should be referred to ( for example Gamlingay Local Biodiversity Audit – (in draft 2025).

4)Para 7.9- Page 50 Also should reference Neighbourhood Plans in terms of community facility needs and infrastructure.

5)Page 63 Para 10.11 Other relevant transport strategies- reference needed to local Neighbourhood Plans (i.e. GAM8 policy in Gamlingay Neighbourhood Plan specifically relates to active travel infrastructure)

6) Page 77 para. 13.6- Should reference that developers should seek early engagement with the ‘Local Burial Authority’ concerning needs for burial space. This reference should encompass both town and parish councils and district councils who have this remit.

7) General comment- Page 118 para 21.5 keeping important local village PROWs open throughout build programmes is essential for keeping local facilities accessible to their residents. Resources should be made available for temporary diversions to be in place at all times.

8)Page 122- para.22.10 – reference is made to both Gamlingay and Bassingbourn GP practices. Please develop a clear protocol what happens in these areas with regard to providing healthcare infrastructure. There needs to be a clear alternative approach and clarification here, to ensure these communities do not lose out. What is the procedure in these areas?

1) Page 45- para 6.12- Chapter 6 Biodiversity
Reference should be made to the local needs/characteristics of the local area /informed by the LNRS Cambridgeshire (2025).

2)Para 6.13- ‘Adequate ecological information’- reference the LNRS is needed

3)Para. 6.15- Habitat Surveys- local Biodiversity Audits should be referred to ( for example Gamlingay Local Biodiversity Audit – (in draft 2025).

4)Para 7.9- Page 50 Also should reference Neighbourhood Plans in terms of community facility needs and infrastructure.

5)Page 63 Para 10.11 Other relevant transport strategies- reference needed to local Neighbourhood Plans (i.e. GAM8 policy in Gamlingay Neighbourhood Plan specifically relates to active travel infrastructure)

6) Page 77 para. 13.6- Should reference that developers should seek early engagement with the ‘Local Burial Authority’ concerning needs for burial space. This reference should encompass both town and parish councils and district councils who have this remit.

7) General comment- Page 118 para 21.5 keeping important local village PROWs open throughout build programmes is essential for keeping local facilities accessible to their residents. Resources should be made available for temporary diversions to be in place at all times.

8)Page 122- para.22.10 – reference is made to both Gamlingay and Bassingbourn GP practices. Please develop a clear protocol what happens in these areas with regard to providing healthcare infrastructure. There needs to be a clear alternative approach and clarification here, to ensure these communities do not lose out. What is the procedure in these areas?