Greater Cambridge Local Plan Preferred Options

We support the proposals.
BREEAM excellent should be required for all public buildings.

Regarding “The plan will set out the approach to runoff rates, including that peak runoff rate should be no greater for the developed site than it was for the undeveloped site.” Whilst we support this, there may be cases where flooding is already a problem and the development provides an opportunity to reduce flood risk, in such cases we would hope that there would be a policy requirement to reduce runoff rates from pre-development levels. For example, a development in the upper water catchment that is subject to flash flooding.

Policy should recognise the value of SuDS for the provision of natural green space and biodiversity and encourage above ground SuDS for this reason. We have seen a number of development proposals where SuDS have been located surrounded by roads, this is problematic because it encourages semi-aquatic wildlife to cross the roads and risk being crushed (eg spawning amphibians) and it fails to recognise ecological principles of connecting habitat (not isolating it with roads). We would welcome wording in the draft Plan that discourages this type of design.

Policy needs to meet requirements of Environment Agency, Lead Local Flood Authority and water companies

Policy must clearly protect the character and appearance of the landscape.
Need clear guidance on where wind and solar farms and energy infrastructure is acceptable.

We support the proposals.

Where possible existing buildings should be reused. Planning policy should prioritise reuse of buildings over demolition and rebuild. There is a growing body of evidence that the ‘greenest building is one that already exists’. (Carl Elefante quoted in the Architect’s Journal Retrofirst campaign https://www.architectsjournal.co.uk/news/opinion/the-greenest-building-is-the-one-that-already-exists and https://www.architectsjournal.co.uk/news/opinion/join-our-retrofirst-campaign-to-make-retrofit-the-default-choice ).

The climate change section should include policies covering retrofit. This will become increasingly important as higher energy efficiency standards are required. These targets present serious challenges now and will get ever more serious during the Plan period, with both major impacts on individual buildings and townscapes, and high risks of carbon (and money) being wasted on inappropriate works.

Retrofit will be within the direct scope of the Plan (guiding planning decisions) whenever it involves works which could potentially require planning permission or listed building consent. There will be difficult decisions to be made regarding retaining traditional features which contribute positively to the heritage, character and public realm (which is part of what makes Cambridge a great place) versus changes to those buildings to improve their energy efficiency. It is important that the policies in the Plan recognise this and provide guidance on how this should be assessed, so that good decisions are made.

A high proportion of the buildings in Greater Cambridge will be of traditional solid wall construction. The Climate Change section of the Plan should quote key principles and guidance from PAS 2035 and its non-domestic counterpart PAS 2038 (and reference other freely available advice including from the STBA and IHBC as well as the Government’s own guidance to Private Sector Landlords) in sufficient detail to ensure that people dealing with all traditional buildings (not only heritage assets) have access to the appropriate advice and skills to ensure that their buildings are put in good repair, and then suitable retrofit measures are applied as appropriate. See https://stbauk.org/whole-house-approach/. This is essential to achieve the aims of the PASs and to minimise unintended consequences.

CambridgeCCP strongly support this policy. Policy needs to link to Biodiversity and Greenspaces policies and policies achieving high quality design.

A significant amount of development will come forward through windfall (or outside the development plan) and the potential impacts of this on biodiversity will need to be dealt with on a case-case basis, therefore it is essential that policies for biodiversity and green spaces are as strong as they can be and that the plan policies protect existing nature rich areas by strongly emphasising the mitigation hierarchy: avoid, minimize, restore and offset.

The overall policy direction is supported and welcomed. However, Cambridge Past, Present & Future consider that future plan policies should be prioritised with the protection of existing interests as the first principle. As the Biodiversity and Green spaces Topic paper 3 indicates at para 3.2:

"The National Planning Policy Framework (2019) paragraphs 174-188 relate to Conserving and enhancing the natural environment. Particularly relevant to biodiversity and geodiversity is paragraph 179b, which sets out that local plans should promote the conservation, restoration and enhancement of priority habitats, ecological networks and the protection and recovery of priority species; and identify and pursue opportunities for securing measurable net gains for biodiversity. "

Thus, the starting point for future policies should be the protection of existing sites of both biodiversity and geodiversity importance. This will give a clear statement of intent from the outset for any future developments. Future policies should also give some detail of what is expected with regard to development affecting these interests; we comment further on this below.

Linkage to wider GCLP Policies

Future GCLP policies for development must not put the protection and enhancement of biodiversity at risk. This means that all of the consequences of any new development or infrastructure for these interests must be assessed fully before being incorporated in the new plan. This is also likely to require action by other statutory bodies to ensure the delivery of new development without causing further harm to existing interests.

Water supply is a good example. Planning decisions that provide for future development can influence the quantity and quality of water with further potential effects on biodiversity in a number of ways. For example, the use of streams and rivers to carry the outfall from sewerage treatment could have critical effects on wildlife. In addition, whilst water availability is, of course, a relevant constraint that the planning system should consider, the capacity of our watercourses to dispose of treated water waste is likely to be a more binding one. Furthermore, consideration must also be given to the climate-change-induced, greater frequency of storm events. Without increased investment by the water authorities the frequency of storm events leading to raw sewerage being discharged is likely to increase, even at current levels of development. It should not be assumed therefore that water authorities will simply be able to accommodate the extra demands of new development. Another potential consequence of planning decisions is the demand for increased abstraction of better quality water from aquifers leading to more pressure on vulnerable wildlife dependent on it. Impacts on wider catchment areas beyond the GCLP area is another issue that will require cooperative working between statutory bodies and adjoining Local Authorities.

CambridgePPF strongly support 20% Biodiversity Net Gain.
The overall intention of this policy direction is welcomed and supported. However, the detail of how the policy is worded to guide and enhance development will be critical and it is likely to require more than one policy to achieve this. It is, of course, appreciated that plan policies have to be developed further - some important issues are touched upon already and this is welcomed. As referred to in our general comments however, the first priority must be the protection and conservation of existing biodiversity and geodiversity interests. With this in mind we have a number of specific comments regarding the principles to underpin this objective. These should be reflected in future policies and/or supporting text in the GCLP:

• Assessment of impacts
All development affecting sites of biodiversity and geodiversity importance and interest should be subject to thorough assessment of impacts based on all relevant information and recent surveys.

• Mitigation and Compensation
The mitigation hierarchy should be followed for any development proposals. We are pleased to note that this has been referenced at section 3.5 of Topic Paper 3, i.e. ‘whereby harm should be preferably avoided, adequately mitigated, or compensated for as a last resort’. Acceptance of proposed mitigation as a way of making a development must be based on proof that it will work and should not be confused with compensation for irrevocable damage to an important site or interest. The distinction between mitigation and compensation is also important as the latter must require justification as an exception. Finally, all mitigation and compensation work should be properly secured in perpetuity if necessary. This is particularly important with regard to compensation. Compensation for permanent damage requires permanent recompense.

• Approach to harmful development
Any development that has an adverse effect (or risk of such effect applying the precautionary principle) should normally be refused. The supporting text with the current first proposals consultation indicates that exceptions will only be made where the public benefits significantly outweigh any adverse impacts. However, more clarity will be needed on how this will work in practice. Again, it is appreciated that the policy wording has still to be written. However, this is such an important issue that a clear statement of intent should be made now. If developments are proven to have an adverse effect or applying the precautionary principle, a risk of an adverse effect, then they should only be normally permitted when clear tests are applied. Arguably this should also include being satisfied that applicants have demonstrated that there are no less damaging alternatives they could pursue.

It is noted that the supporting text with respect of policy BG/BG states:
‘The policy will state that development proposals adversely affecting sites of biodiversity or geological importance will not normally be permitted. Exceptions will only be made where the public benefits significantly outweigh any adverse impacts.’

Clarification will be needed of what tests will be used to determine whether public benefits outweigh adverse impacts on important sites, because an approach solely on a case by case basis could risk a lack of consistency and consequent serious harm to biodiversity interests without sufficient justification. The level of public interest that would need to be demonstrated will also need to be commensurate with the level of interest affected. This level of test may be very high if for example, an internationally of nationally important interest is at risk.

The supporting text also goes on to say:
‘In such cases where development is permitted, we will require that the intrinsic natural features of particular interest are safeguarded or enhanced.’

Presumably the intention here is to safeguard or enhance any remaining features of interest after a damaging development is allowed.

• Biodiversity Net Gain
We strongly support a level of 20% Biodiversity Net Gain for the following reasons:
• Cambridgeshire is one of the most nature depleted counties in England, which is one of the most nature depleted countries in the world.
• Doubling nature in Cambridgeshire would only bring the county to the average for the UK.
• Cambridge Nature Network Report identified that existing habitats within 10km of Cambridge are too small and too fragmented to form a functioning ecological network. To achieve a functioning ecological network sustained effort and investment will be needed over the long term to make habitats better, bigger and more connected.
• Creating new habitats to replace those lost is not an exact science, meaning that some biodiversity offsetting will produce less biodiversity gain than expected. This variability is considered to be around 10%. Therefore a 10% BNG requirement does not guarantee that any individual development would actually achieve a net gain. Only a higher level of BNG, such as 20% has the prospect of achieving this.
• It should be noted that 20% BNG will not achieve the aspiration to double nature unless it were at 50%.
We have two additional comments at this stage. First, that biodiversity net gain must take account of the full value of an affected site including any interests that may have been deliberately damaged prior to a development occurring. Second, the use of planning conditions and obligations to secure the effective long-term management of any on or off site habitat creation referred to the policy supporting text is vitally important and is welcomed. Long term monitoring to ensure that any proposed biodiversity net gain delivers what it seeks to do is also critical. The Defra Biodiversity Metric focuses on the provision of habitat. This may be used to mitigate effects or secure enhancement for species directly affected by a development. However, to ensure that species affected will benefit from habitat provision requires careful monitoring - simply creating new habitat will not necessarily mean the species affected will use it.

We also look forward to seeing more detail on how the proposed policy will seek to secure wider environmental gains.

Cambridge Past, Present & Future welcome the recognition that “Designated biodiversity sites within and close to Greater Cambridge are being impacted by increasing numbers of visitors – an issue that needs to be addressed to protect these vulnerable habitats and the species they support. For nationally designated sites, Natural England have identified Impact Recreation Zones and recommend the application of Suitable Alternative Natural Greenspace standards to inform the quantity of green space provision required for people, to lessen the impacts on these nature sites. Greater Cambridge has relatively few nationally designated nature sites, but many locally designated sites. Ahead of the draft plan we will explore how we can best measure and mitigate the impact of development on these local sites.” In Cambridge Past, Present & Future’s research for the Cambridge Nature Network (http://cambridgenaturenetwork.org/ ) we identified that the creation of new accessible green space in Cambridgeshire has not kept pace with the increase in population over the past 20 years and this has been one of the main drivers of recreational impact on wildlife sites. In addition, many green space sites in Cambridgeshire are wetlands, meaning that although they might cover a large area, the amount of land that can actually be used by the public is often small or limited to paths. Unlike other counties Cambridgeshire does not have large areas of public access woodlands, downland/moorland/heathland or coastline. Our research also identified that generally, larger scale development (such as Cambourne) was providing larger areas of new greenspace but smaller developments were not and therefore it is these that are contributing most towards the problem as they have made up around 50% of the development in Cambridgeshire over the past 20 years. If the Local Plan is to be sustainable (ie not increase recreational impacts more than has already occurred) then ALL new development will need to make a contribution towards creating new Suitable Alternative Natural Greenspace (if none is created through the development). The Local Plan should set out how these contributions are to be collected and the amount that would be required per person. We refer you to the submission by the s106 Officer for South Cambridgeshire District Council who has calculated that this should be £498 per dwelling.

The overall intent and policy direction of this policy is welcomed and supported. The need for development plans to take a strategic approach to maintaining and enhancing networks of habitats and green infrastructure is of critical importance. This objective is a core part of the ‘Cambridge Nature Network’ which is supported by both South Cambridgeshire and Cambridge City Councils and we are pleased that this document has also been referred to. We also agree that green infrastructure initiatives must be included in the development plan rather than a supplementary planning document to provide the strongest possible support.

It is noted that views are sought on the adoption of standards for the provision of green infrastructure such as those set out in ‘Building with Nature’. Adoption of a set of key objectives and principles for the provision of green infrastructure is welcome - although the detail of theses would need careful consideration. As we commented with regard to policy BG/BG, the protection of existing sites must be the first priority. As the explanatory text for standard 11 (Delivers Wildlife Enhancement) of the Building with Nature document notes:

‘This standard emphasises the requirement to follow the Mitigation Hierarchy and create
Net Positive benefits for wildlife. The standard reiterates the need to protect any existing ecological assets as a necessary first step in the development process.’

Any application of standards should also, of course, not simply be used as a green ‘tick list’ or applied to try and make developments acceptable when these would cause permanent harm (or risk of harm) to important biodiversity sites or interests.

We strongly agree that “Opportunity Mapping has identified a number of strategic green infrastructure initiatives which have the potential to enhance the existing network. This policy will require all new development to help deliver or contribute to support delivery of the green infrastructure strategic initiative objectives. Contributions will include the establishment, enhancement and the on-going management costs.” In our research for the Cambridge Nature Network (http://cambridgenaturenetwork.org/) we identified that the creation of new accessible green space in Cambridgeshire has not kept pace with the increase in population over the past 20 years and this has been one of the main drivers of recreational impact on wildlife sites. In addition, many green space sites in Cambridgeshire are wetlands, meaning that although they might cover a large area, the amount of land that can actually be used by the public is often small or limited to paths. Unlike other counties Cambridgeshire does not have large areas of public access woodlands, downland/moorland/heathland or coastline and as a consequence there is poor access to countryside. Our research also identified that larger scale development (such as Cambourne) were providing larger areas of new greenspace but smaller developments were not and therefore it is these that are contributing most towards the problem as they have made up around 50% of the development in Cambridgeshire over the past 20 years. If the Local Plan is to be sustainable (ie not increase recreational impacts more than has already occurred) then ALL new development will need to make a contribution towards creating new strategic greenspace (if none is created through the development). The Local Plan should set out how these contributions are to be collected and the amount that would be required per person. We refer you to the submission by the s106 Officer for South Cambridgeshire District Council who has calculated that this should be £498 per dwelling.
We have noted the Greater Cambridge Green Infrastructure Opportunity Mapping Final Report (2021). We have been trying to arrange a meeting with officers to discuss this and will submit additional comments once we have been able to do so.

The overall intent and policy direction of this policy is welcomed and supported. Protection of existing trees and hedgerows, particularly those of special quality, is especially important.

It is important that the draft Plan or supporting information highlights that trees and woodland are NOT priority habitats in a number of locations in Greater Cambridge, as set out in the Cambridge Nature Network (http://cambridgenaturenetwork.org/). In these locations other habitat types should be prioritized over woodland in the first instance. This includes meadows, fens, wetlands and scrub. The area where woodland creation is prioritised is mainly to the west of Cambridge.

We support retaining existing hedgerows but when creating new habitat it is important to consider that hedgerows are not necessarily better than other linear habitat types in helping to provide ecological connectivity, and therefore in certain locations creating alternative types of linear habitat may be more beneficial – for example a series of ponds or a linear wildflower meadow. This should be reflected in the draft Plan.

The significant amount of space that is required to enable large tree species to reach full maturity, as well as arboricultural costs associated with large trees, means that most new developments now plant tree species which are much smaller when they reach maturity (eg rowan, birch, whitebeam, etc). The benefits of these trees is much lower in terms of urban cooling, urban flooding, sequestering carbon and public amenity (and possibly biodiversity). There is a risk therefore that the benefits of trees within developments is overstated compared to what is actually being delivered. We would like you to consider how this can be addressed (for example a requirement to plant more trees if they are of smaller varieties; or a requirement that a % of new trees are of larger species).

We also note that the supporting text indicates that ‘We recognise that in some instances felling of existing trees or hedgerows may be necessary to meet wider placemaking objectives.’ and look forward to more detail and discussion on how and when the latter will be applied to justify tree and hedgerow removal.

The overall intent and policy direction of this policy is welcomed and supported. We reiterate however, the importance of ensuring that any policies aimed at protecting and enhancing rivers are not undermined by consequential effects of other development that will be brought forward in the new Local Plan, for example the likely demands on water supply and effects on water quality.

The River Cam and its tributaries are the subject of flooding. Natural flood management techniques applied to ditches, drains and streams in the catchments can contribute towards reduced flooding and also have other positive benefits for biodiversity, public amenity and water quality. In order to encourage this approach we would like to see this added to the list of items that could be supported by development proposals.

Planning applications are likely to be required for large scale schemes that can improve water quality or tackle flooding, such as treatment wetlands. There should be an assumption in favour of such applications in the draft Plan.

The river corridor is not just an environmental asset but also an important heritage asset, in landscape terms and in the setting of the historic city. This heritage can also be damaged and sometimes different ways to environmental harm. We would like to see this recognised within the wording of the draft Plan.