Greater Cambridge Local Plan Preferred Options

Executive summary

The proposed policy is to achieve a 20% Net Gain in Biodiversity with a focus on the use of the Defra metric. However, species specific measures including nest boxes for cavity-nesting bird species, such as swifts, which are Red Listed and in significant decline, do not count in the Defra metric. Government guidance in the NPPG and the National Model Design Code, as well as several authorities, including RIBA and NHBC, support the installation of nest boxes in new developments as a low cost and effective way of achieving biodiversity gain (detailed references below).
As nest bricks are not included in the DEFRA BNG metric, they need to be included in the policy. We strongly suggest that the ‘Biodiversity and geodiversity’ Policy in the new Local Plan should include some specific wording to reference what other measures, including those for species inhabiting the built environment, will be used to assess biodiversity gain – mentioning swift boxes and bat boxes, as in the text of the ‘GC LP First Proposals’ document:
‘Nest boxes designed for swifts will also be suitable for starlings, house sparrows and tits, and will provide a low-cost way of achieving significant net gain in biodiversity’
At least a 1:1 ratio of nest bricks to dwellings is generally accepted now as good practice, with separate provision for bats depending on the characteristics of the site.

Biodiversity net gain

We have concerns that with the focus on the Defra metric for calculating biodiversity net gain, which is based only on green habitats, there is a danger that important biodiversity opportunities for species with measures such as nest bricks, roosting bricks, hedgehog highways etc may be given less emphasis or be overlooked completely. It is not clear in the ‘Policy Direction’ of the ‘Biodiversity and geodiversity’ part of the First Proposals’ document how such species measures are to be taken account of alongside the results of the Defra metric in assessing overall net gain in biodiversity. Given that much of the development in Greater Cambridge is in more ‘urban areas’ either within Cambridge City or new towns such as Northstowe then we believe these urban species are an important part of bringing nature close to people and an effective way of helping our declining wildlife.
We welcome the recognition of this in the text of the ‘GC LP First Proposals’ document on page 169 under the heading ‘Why is this policy needed’:
‘The focus for biodiversity enhancements is intended to be within the boundary of a site, and could include providing wildlife areas, trees, or smaller measures such as including bat or swift boxes’
Government guidance

The significance of species-specific measures in biodiversity net gain is emphasised by 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.'

The recently published National Model Design Code: part 2 - guidance notes (20/07/21) also makes reference to bat and bird boxes and bird bricks. In Section N.3 Biodiversity, page 25: "Integrating Habitats: Biodiversity can be enhanced through facilitating habitats and routes for wildlife, for example, incorporating trees, wildflowers, ponds, bat and bird boxes, bee and bird bricks and hedgehog highways."

https://www.gov.uk/government/publications/national-model-design-code

The case for nest boxes

Swifts in the UK are on the Birds of Conservation Concern (BoCC) Red List and are classified as Endangered on the IUCN Red List assessment of extinction risk for Great Britain. Their numbers declined by 58% between 1995 and 2018, and by 41% in just 10 years up to 2018, that is over 5% per annum! Sparrows and starlings are also Red Listed in the UK.

The decline of birds such as swifts, which have nested for generations in older houses in holes and cavities under the eaves and in walls, is highlighted in a recent report – the Environment Agency, Chief Scientists Group (2021) The state of the environment: the urban environment:

The state of the environment: the urban environment - GOV.UK (www.gov.uk)

Loss of nest sites in older buildings is thought to be a significant factor in their decline and many new houses have been built with no new nest sites incorporated. Bird and bat boxes are relatively cheap, easy to integrate into new builds (generally as swift or bat bricks) and are sustainable needing no ongoing maintenance. Also, swift bricks successfully cater for other bird species such as house sparrow, starling, blue tit, great tit and house martin and can be considered as a ‘universal nest brick’, in numbers equal to the number of dwellings, as noted in:

https://cieem.net/swift-bricks-the-universal-nest-brick-by-dick-newell/

Support for incorporation of nest boxes in new developments
The Royal Institute of British Architects (RIBA) in: Gunnell, K., Murphy, B. and Williams, C., Designing for Biodiversity: A technical guide for new and existing buildings, RIBA Publishing & Bat Conservation Trust (2013).
An excellent recent report produced by the NHBC Foundation from a collaboration between the RSPB and Barratt Developments gives significant guidance on these issues on page 42 onwards, which includes providing nest sites (nest bricks) at a ratio of one per dwelling.
NHBC Foundation, Report NF 89, ‘Biodiversity in new housing developments: creating wildlife-friendly communities’ (April 2021). Available at:
Biodiversity in new housing developments: creating wildlife-friendly communities - NHBC Foundation
An expected new British Standard, BS 42021, ‘Biodiversity and the built environment: Specification for the Design and Installation of Bird Boxes’ is expected to give box/brick specification and a level of installation in new builds in line with current good practice.
(Proposed publication start date 07/02/22)
https://standardsdevelopment.bsigroup.com/projects/2017-03102#/section

Current good practice for nest boxes – Planning Authorities

The 1:1 ratio of nest bricks to dwellings was first outlined in the award-winning Exeter City Council Residential Design Guide SPD (2010). A number of planning authorities have adopted similar guidelines – for example Oxford, Cornwall, Brighton and Plymouth and South West Devon.

Within the OxCam Arc, Oxford City Council are leading the way with guidance on this issue. The recent Oxford City Council Technical Advice Note 8 entitled ‘Biodiversity – Planning Application Guidance’ gives an ‘expected provision’ of bird nest sites for building dependent birds’ at a rate of 1 per house and 1 per 2 flats, with separate provision for ‘bat roost sites’ at a rate of 1 per 5 houses and 1 per 10 flats.

https://www.oxford.gov.uk/info/20067/planning_policy/745/planning_policy_-_technical_advice_notes_tan

Case studies
The Duchy of Cornwall adopted the same principle of one nest site per dwelling in 2015, and a good example of the provision of a general type of integral box for all cavity nesting birds is the Nansledan development in Newquay:

https://www.rspb.org.uk/our-work/rspb-news/news/stories/the-duchy-of-cornwall-giving-swifts-a-home/

Our own local projects with developers (e.g., Taylor Wimpey and Hopkins Homes) at Northstowe, Cambourne West, Melbourn and elsewhere indicate an increasing willingness to engage with integral nest box projects already acknowledged in 2021 by clear environment strategies:
https://www.taylorwimpey.co.uk/corporate/sustainability/environment-strategy
Significant success has already been achieved in Cambridge and surrounding villages with substantial new swift and sparrow colonies established.
An example from Poland also demonstrates the effectiveness of nest boxes:
https://link.springer.com/content/pdf/10.1007/s10531-021-02334-0.pdf

In conclusion
We strongly suggest that the ‘Biodiversity and geodiversity’ Policy in the new Local Plan should include some specific wording to reference what other measures, including those for species inhabiting the built environment, will be used to assess biodiversity gain – mentioning swift boxes and bat boxes, as in the text of the ‘GC LP First Proposals’ document.
Submitted on behalf of:
Action for Swifts; Fulbourn Swifts; Over and Swavesey Swift Conservation Project 2020

We would urge you not to overlook the chalk streams arising around Fulbourn and Great Wilbraham, which feed the Little Wilbraham River which flows into Quy Water and ultimately into the Cam. Historically some of these streams have maintained a small area of wetland within the Fulbourn Fen Nature Reserve (SSSI) where hundreds of wild orchids bloom in early summer.
However, the springs adjacent to the Fulbourn Nature Reserve east of the village, which arise close to the 15m contour, are often dry due to the depleted water table level, largely due to the scale of water abstraction from the underlying aquifer by the Cambridge Water Company from the Fleam Dyke Pumping Station. As a result, the area of wetland and the small chalk streams running through the site are often entirely dependent on water specially pumped from a borehole at Dungate Farm to the east of the A11 as part of a water augmentation scheme. This is not considered to be a long-term sustainable solution to protect the biodiversity of the local flora and fauna.
The springs at the north western end of the village emerge at a lower level, nearer the 10m contour, and are usually flowing year-round into the chalk stream at Poor Well and into the drainage ditch system all flowing north towards the Caudle Ditch, which links to the Little Wilbraham River. The drainage ditches to the east of Fulbourn also connect to the Little Wilbraham River (there is a Preservation Society) flowing past the SSSI at Wilbraham Common and feeding the fen reed bed area at Wilbraham Fen, which is another SSSI which supports significant biodiversity including some important bird species, such as marsh harriers, migrant warblers and cranes. Also, there is a County Wildlife Site on the River designated for water plants. This fen area along the Little Wilbraham River is within Area 4 ‘Enhancement of the eastern fens’ of the Greater Cambridge Strategic Green Infrastructure Initiatives.
Many residents of Fulbourn and The Wilbrahams value these chalk streams and the Wilbraham River and we feel that it should be recognised as part of the River Cam corridor south east of Cambridge. This topic is covered in the Submission Draft of the Fulbourn Neighbourhood Plan.
There is a Wilbraham River Preservation Society:
Home | Wilbraham River Protection Society (thewrps.org)

We support the ‘Proposed policy direction’ as outlined in the GC LP ‘First proposals’ document to ‘include policies which identify and protect open spaces, including village greens, parks, sports and recreation areas, allotments, community orchards and Protected Village Amenity Areas, and Local Green Space’
It is essential that the publicly owned open spaces are protected and developed by communities for social, amenity and biodiversity value to improve these environments, encourage community cohesion and contribute to the widely recognised health benefits of bringing nature close to homes and provide safe and attractive areas for recreation.
In our established city suburbs and villages, open green spaces such as those on housing estates, village greens, parks, recreation grounds, allotments, community orchards, cemeteries and burial grounds together with private gardens, green spaces and small areas of woodland provide a series of green networks to enable wildlife to traverse and thrive within the built environment. In many cases these networks link to green infrastructure in the surrounding countryside.
In recent years there has been a significant loss of privately owned gardens, green spaces and small patches of mature trees for house extensions, new housing plots, parking in front gardens and garden offices, and even where planning permission is required there is often little mitigation required for biodiversity loss. This appears to be steadily reducing the available green habitat within the city suburbs and villages and it seems likely that the value of the green networks is being reduced. The development of garden land and subdivision of existing plots is covered by proposed Policy H/GL in the ‘First Proposals’ document, but clearly these areas are linked as regards impact on biodiversity.
So, this emphasises the value of publicly owned green space and that it is important to have a Policy in place to enable local communities to take steps to protect them from future development. Parish Councils and local community volunteers can then develop them as multifunctional spaces including the enhancement of green infrastructure to benefit wildlife.
Submitted on behalf of Fulbourn Swifts Group

We support the ‘Proposed policy direction’ as outlined in the GC LP ‘First proposals’ document to provide green open space on new developments for recreation and socialising, while noting that these spaces should be multifunctional and provide opportunities for food growing, community orchards and space for nature. The latter is important to have on site to help provide a good environment and contribute to the widely recognised health benefits of green vegetation close to homes.
However, for maximum benefit to wildlife and people, it is important to retain and provide quality native species green infrastructure (as opposed to miniature ornamentals) in the area immediately around houses, rather than houses being marooned in an area of largely hard landscaping or green open space separated from islands of higher value green space around the edges. On many new housing developments, the landscaping close to homes tends to consist mainly of miniature ornamentals, which are often of little value for nature and are cut back so hard in maintenance regimes that they provide little green vegetation to enhance the appearance of the limited open space.
However, the enrichment of the habitat with some native species hedges and shrubs or non-natives known to be of benefit to wildlife (see reference below) close to homes will attract a wider range of birds into local green spaces and gardens. Provided these shrubs are maintained appropriately, to allow good growth and seasonal flowering and fruiting, they will provide good habitat for a wide range of invertebrates, birds and small mammals For sparrows in particular, hedges and shrubs for shelter are very important close to potential nest sites, such as in newly installed swift nest bricks. This would also provide a more pleasant environment to support the health and wellbeing of residents. These issues are particularly important where most of the quality biodiversity enhancement for a development is proposed either relatively remote from the main blocks of housing or are even in the form of financial contributions for off-site provision.
An excellent recent report produced by the NHBC Foundation from a collaboration with the RSPB and Barratt Developments gives significant guidance on these issues on page 29 onwards.
NHBC Foundation, Report NF 89, ‘Biodiversity in new housing developments: creating wildlife-friendly communities’ (April 2021). Available at:
Biodiversity in new housing developments: creating wildlife-friendly communities - NHBC Foundation

Submitted on behalf of:
Action for Swifts; Fulbourn Swifts; Over and Swavesey Swift Conservation Project 2020

We support the ‘Proposed policy direction’ as outlined in the GC LP ‘First proposals’ document to resist ‘inappropriate development of residential gardens and the subdivision of existing plots’
In our established city suburbs and villages, larger private gardens, green spaces and small areas of woodland form a series of green networks together with publicly owned open green spaces such as those on housing estates, village greens, parks, recreation grounds, allotments, community orchards, cemeteries and burial grounds to enable wildlife to traverse and thrive within the built environment. In some cases, these networks link to green infrastructure in the surrounding countryside.
These privately owned spaces often with mature trees and shrubs also contribute to the local character, particularly in some of the villages.
In recent years there has been a significant loss of privately owned gardens, green spaces and small patches of mature trees for house extensions, hard landscaping, new housing plots, hard standing for parking in front gardens and garden offices. It is understandable why this is happening and some issues are not under the control of Council Policy
However, even where planning permission is required there is often little mitigation required for biodiversity loss. This appears to be steadily reducing the available green habitat within the city suburbs and villages and it seems likely that the value of the green networks is being reduced. For subdivision of plots, where there are no applicable TPOs the land is usually cleared of mature trees and shrubs before planning permission is sought and then little or no measures are put in place to address biodiversity loss.
Such measures are relatively cheap with items such as swift nest bricks (easily built high into the gable ends or under the eaves) available from £30 per unit, trees from £50 and shrubs from £20 and easy to provide hedgehog friendly fencing costing just a little more than a standard fence.
So, we suggest that this Policy should include specific mention of the type of mitigation/enhancement for biodiversity that will be required where permission is given to develop such sites.