Greater Cambridge Local Plan Preferred Options

The RSPB supports the principles outlined for this policy. Public water supply is a key environmental limiting factor in Greater Cambridge and it is imperative that new development enables much lower per capita consumption rates. As such we agree that ambitious requirements are justified.

RSPB welcomes these policy principles. Use of green roofs, SuDS, street trees etc.. will help make new urban environments suitable for a changing climate whilst also contributing to biodiversity goals within the Greater Cambridge area. Although this also relates to CC/NZ, we would also draw your attention to the use of green walls to help regulate building temperature and provide insulation.

Although not necessarily relevant to high-level policy wording, we would expect GC to develop guidance on design – eg: use of biodiverse and/or biosolar roofs (not sedum), the need for SuDS source control, the necessity for biodiverse planting schemes and trees suitable to the climate conditions we expect etc…

The RSPB supports the principles set out for this policy, particularly with reference to source control. Our experience is that this is often an element which is not implemented well due to supposed practical constraints which are not necessarily justified. We believe that Greater Cambridge have an opportunity to push the boundaries to make this a standard practice in new development. We suggest that references to green roofs should be changed to biodiverse and/or biosolar (to preclude the use of sedum roofs which have limited utility). Where use of permeable surfaces is not practicable, source control should again be implemented.

RSPB supports the principles set out. Renewable energy provision in Greater Cambridge will provide an important contribution towards net carbon neutral targets. However, as with all infrastructure development, it can, and does have negative impacts on biodiversity if located in the wrong place or implemented insensitively to the environment present (eg: presence of priority spp populations and/or priority habitats). Therefore, we also support the provision of biodiversity impact criteria specific to renewable projects. As we mentioned in our previous consultation response, RSPB’s report Energy Futures has mapped how the UK can meet very high renewable energy provision whilst safeguarding nature and we would be pleased to discuss with the Greater Cambridge Councils how our Energy Vision peer-reviewed mapping methodology could be used to help identify suitable sites for renewable and low carbon energy.

RSPB supports the policy principles set out, which are an important element of reducing the embodied carbon of new development and the efficient usage/re-use of limited resources.

RSPB supports the policy principles set out. Peat soils where they occur in Greater Cambridge are a significant potential source of carbon emissions when managed inappropriately. Where biodiversity net gain or green infrastructure provision associated with development can bring peat soils under suitable wetland habitats, this can have very significant benefits for both carbon emissions and biodiversity.

For example, studies have shown that CO2 emissions from cultivated peatland soils can reach c39 tonnes per hectare per year. Restoring this land to lowland wet grassland could reduce emissions by between 27 to 33 tonnes per ha per year, whereas restoration to swamp fen could reduce emissions by 33 to 40 tonnes per ha per year (with the potential for land to in effect become a carbon sink).

RSPB supports the general direction outlined here. We believe that the objective should explicitly include that the plan policies will contribute toward doubling nature in Greater Cambridge – something the councils have signed up to as part of the OxCamArc Environmental Principles. We support objectives for green space which benefit people and nature.

The RSPB fully supports the councils’ approach to require 20% Biodiversity Net Gain from development within the Greater Cambridge Area. We believe that this is justified due to the relative paucity of land managed for nature and of priority habitats, both in Greater Cambridge and in Cambridgeshire county more widely. This approach is required if we are to Double Nature in the plan area.

We support the approach of providing BNG on site where practicable, but contributing to larger, strategic sites when needed. However, we believe that care is needed if linking this to the Green Infrastructure strategic objectives. Although GI and BNG outputs are likely to be complementary, they are separate requirements. Strategic BNG provision should be aligned to help deliver the Local Nature Recovery Strategy once this has been formalised. It is likely that this will incorporate initiatives such as the Cambridge Nature Network and other landscape scale priority areas identified by Natural Cambridgeshire, which in a Greater Cambridge context also include the Great Ouse Valley and West Cambridgeshire Hundreds.

This may be reflected in the policy wording when drafted, but the parts of this policy related to site protection and procedure will obviously need to take full account of the approach taken through the Habitats Regulations to Special Areas of Conservation and Special Protection Areas, and the much more stringent protections and tests applicable to these sites, which is not reflected in the policy direction explanatory text at the moment.

The RSPB support this policy direction, and we are pleased to see that our Ouse Valley reserves, where we have significant green infrastructure ambitions, are included in the ‘Great Ouse Fenland Arc’ priority area. As a potential GI provider, we have struggled to gain contributions from developments in the past, notably from the first phases of Northstowe which is in close proximity to and connected by public transport to our Fen Drayton Lakes site. We will therefore be very keen to ensure there are clear requirements and standards set out in this policy which will enable new development to make a significant contribution to the Greater Cambridge strategic GI initiatives.

We feel that there is an obvious connection between provision of strategic GI and its proximity and transport connectivity to new development, and we believe this should influence which initiatives are supported by a particular development (as an example, various development sites will be in proximity to our Fen Drayton Lakes site, or directly connected via the guided busway). We would therefore like to see policy wording which makes this connection.

We fully support that GI contributions should go towards the establishment, enhancement and on-going management costs, as this latter requirement is often overlooked.

The RSPB support the policy direction outlined and we agree with a policy that supports additional tree planting and canopy cover in developments without setting particular targets (as appropriate provision will vary depending on the site). We believe that the policy will need to require developers to assess suitability of planting to ensure we achieve the right tree in the right place – so for example to preclude planting on inappropriate soils (ie: peat) and/or planting of species that may not be suited to the changed climate envelope when they mature. There are also obvious links and benefits here to achieving biodiversity policy gains by planting native species as a preference.