North East Cambridge Area Action Plan Issues and Options 2019

Thank you for consulting Natural England on the above in your email of 11 February 2019. Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.

Natural England has no objection to the proposed regeneration of the North East Cambridge (NEC) Area, the principle of which is established in the recently adopted Local Plans. However, this is subject to the inclusion of robust policies within the Area Action Plan (AAP) to ensure delivery of a truly sustainable development including provision of strategic high quality multifunctional open space, with a long-term management strategy, to meet the needs of people and wildlife. We would expect the scale of development to deliver a green infrastructure network along the lines of similar developments elsewhere such as Cambourne, Trumpington Meadows and Waterbeach New Town. Development through the AAP should be guided by an established green infrastructure and biodiversity framework to ensure the NEC Area is capable of delivering the range of environmental services and natural capital required to meet the needs of the scale and nature of proposed development.

We note that the planning process for the future location of the Water Recycling Centre is outside the scope of this AAP and that this will be progressed by the County Council as the Local Planning Authority for waste matters.

Natural England welcomes proposals to undertake further environmental assessment work to inform preparation of the AAP, including air quality and noise assessments and habitat surveys. Whilst the majority of the NEC Area is brownfield land it supports significant local biodiversity interest and opportunities for enhancement. Advice should be sought from relevant sources including the Council ecologists and the Wildlife Trusts. Retention of all existing biodiversity interest and identification of opportunities for environmental enhancement should be a priority for the development of the green infrastructure and biodiversity framework and long-term enhancement and management strategy for the AAP.

The NEC Area Today
Figure 4.8 shows the extent of existing green and blue Infrastructure across the NEC area. However, we believe there may be additional areas of green infrastructure that are not included on the map. This should be confirmed and amended if necessary through the proposed ecological survey work.

We welcome recognition of ecological constraints in section 4.13; however, these are positives, not negatives, and should be seen as significant areas for retention and enhancement and the focus for development of a green infrastructure and biodiversity framework for the AAP. The AAP provides a unique opportunity for the enhancement, extension and improved connectivity of areas such as Bramblefields Local Nature Reserve (LNR), the protected hedgerow on the east side of Cowley Road (City Wildlife Site) and the First Public Drain wildlife corridor and other habitats including ponds and areas of woodland, scrub and grassland. The AAP should take every opportunity to retain and enhance as much of the natural environment as possible and to provide biodiversity rich green corridors across the site and beyond.

Section 4.20 and 4.22 acknowledge the requirement to deal with potential contaminated land and other environmental issues such as minimising light pollution which we fully support.

Vision and Strategic Objectives
Natural England supports the AAP vision and objectives for 'a socially and economically inclusive, thriving, and low carbon place for innovative living and working; inherently walkable where everything is on your doorstep'. We welcome the objective for green spaces to be a core part of the place structure extending, connecting and improving biodiversity to achieve a net gain and integrating Sustainable Drainage Systems within the development. As mentioned above, we believe the AAP should be developed around a robust green infrastructure framework for the site to ensure delivery of the full range of environmental services required to meet the needs of the proposed scale and nature of development: recreation, health and well-being, biodiversity, landscape, drainage, flood management, sustainable travel, climate change and adaptation. We note the following statement:

"Green infrastructure capitalises on the network of existing trees and landscape but also extends this to create an overall framework to improve biodiversity and linkages to the wider countryside. Embedded into this framework will be the water management network that improves the First Drain and adds richness to the landscape. A new green space at a district scale will enrich the heart of this new place and provide the kind of multifunctional space that is so typical of Cambridge and central to public life."

Whilst we fully support the above we would expect a development of this magnitude to deliver significantly greater than 'district scale' green infrastructure, although we are unclear what this really means. We have provided further advice on green infrastructure provision below.

Place Making
Sections 6.14 and 6.15 discuss creating a healthy community which we fully support. Our advice is that a strategic level of high quality greenspace provision will be key to creating a healthy community and enhancing people's physical and mental wellbeing. The extent of accessible natural greenspace provision (i.e. excluding formal sports areas) should be proportionate to the scale of development, for example 8ha 11000 population is advocated through the Suitable Alternative Natural Green Space (SANGS) guidance to meet people's needs and protect more sensitive designated sites such as Stow-cum-Quy Fen Site of Special Scientific Interest (SSSI) and Wicken Fen SSSI, Ramsar site. Whilst quantity of provision should be broadly aligned with SANGS guidance, green infrastructure design should seek to achieve the Natural England Accessible Natural Greenspace Standards, detailed in Nature Nearby, including the minimum standard of 2ha informal open space within 300m of everyone's home.

Further consideration should also be given to significantly enhanced green infrastructure corridors to improve connectivity of green infrastructure within the site and beyond, including green linkages with Milton Country Park. Green infrastructure provision should seek to contribute towards the delivery of the objectives of the Cambridgeshire Green Infrastructure Strategy for habitat enhancement and improved connectivity. The AAP should not rely on existing green space such as Milton Country Park to meet people's recreational needs; the AAP should seek provision of similar area of open space to complement and connect the Country Park.

Natural England agrees that the development of the NEC Area presents an opportunity to create a new network of streets and open spaces that will support and improve movement of people throughout the area. Creation of sufficient informal open space for outdoor recreation, enjoyment of the countryside, walking, cycling and adequate public transport provision will be critical to this. A network of green corridors should provide connectivity to areas off site including the Country Park, the Chisholm Trail and Waterbeach Greenways.

We note and welcome Option C to upgrade connections to Milton Country Park by both foot and cycle, including improving access to the Jane Coston Bridge, the Waterbeach Greenway project including a new access under the A 14. We would welcome consideration of options for a crossing of the railway line and the use of green bridges.

Issue: Green Space provision - Natural England advises that this needs to be addressed through a combination of options A -F to provide strategic high quality, biodiversity-rich multi-functional greenspace. This should seek to meet SANGS standards and be connected through substantial green corridors to open spaces across the site and beyond, including connectivity with Milton Country Park, Waterbeach Greenways and the Chisholm Trail, as discussed above.

Transport
Natural England advocates a focus on sustainable, non-car travel including cycling, walking and public transport.

Retail, Leisure and Community Services & Facilities
We welcome recognition of the multi-functional benefits of open space provision including biodiversity enhancement, landscape, drainage, flood management and health and wellbeing. A development of this scale should provide open space to accommodate formal and informal requirements: informal open space in accordance with SANGS, as discussed above, to provide biodiversity net gain and meet people's informal recreation, physical and mental health needs.

Climate change
We support proposals to contribute towards mitigating and adapting to climate change including the application of sustainable design and construction standards detailed in section 11.7. Natural England welcomes proposals outlined in section 11.14 for policies to integrate a SUDs network into the Fen edge landscape that could help to enhance opportunities for specified species as well as providing a sense of place.

Biodiversity
Natural England supports proposals to achieve measurable biodiversity net gain in accordance with national planning guidance and the Defra 25 Year Environment Plan. Natural England advises that the Council's should not simply strive to meet this target, through encouragement of quick wins such as green roof provision; the AAP should ensure significant long-term gains through development of a biodiversity and green infrastructure framework, delivery and long-term management strategy for the area, to guide wider development. Ecological surveys should identify key habitats for retention, buffering and enhancement and opportunities for creation of a wide range of additional habitat to complement, extend and connect existing habitats.

These areas should incorporate a wide range of environmental services including informal open space, landscaping and SUDS provision. The advice of relevant stakeholders including the Council ecologists, Wildlife Trust and Natural England should be sought on the preparation of a Biodiversity and Green Infrastructure Strategy and its delivery secured through robust plan policies.

Please note that Natural England's Impact Risk Zones (IRZs) have been published since this site was originally allocated for development in the Local Plan, a number of years ago. The IRZs are currently being updated to take into account evidence for recreational pressure risks to designated sites such as Stow-cum-Quy Fen and Wicken Fen. The provision of adequate level and quality of alternative accessible open space within large developments is crucial to mitigating the adverse effects of those developments, through increased recreational pressure, to sensitive designated sites.

We note the statement in section 11.17 that off site improvements may be required if biodiversity net gain cannot be fully achieved on site. Whilst we welcome this we believe that a development of this scale can deliver significant biodiversity net gain within the area boundary subject to proper planning and design from the outset.

Implementation and Delivery
We note and welcome the proposal to prepare a North East Cambridge Infrastructure Delivery Plan to provide a broad assessment of the social and physical infrastructure needed to support the planned development and regeneration of NEC and how these requirements could be met. Natural England advises that this should include identification of green infrastructure needed to deliver the range of environmental services required by the development including recreation, drainage, landscape and biodiversity enhancements.
Natural England supports the intention through the AAP to put in place a Section 106 regime to ensure all proposed developments across NEC contribute equitably to the provision and/or funding of all appropriate infrastructure requirements. We trust that this will include provision of green infrastructure including informal open space and biodiversity.

Interim Sustainability Appraisal
Natural England is satisfied that the Interim Sustainability Appraisal (SA) objectives and framework generally accord with the requirements of the Planning and Compulsory Purchase Act 2004 and the Strategic Environmental Assessment (SEA) Regulations. The SA seeks to address the effects of the AAP on key aspects of the natural environment including designated sites, biodiversity, landscape, green infrastructure and soils. The assessment and recommendations / mitigation will need to be updated as the AAP policies evolve and to take into account the findings and mitigation recommendations of the outstanding environmental assessments.

Other advice: Priority habitats, ecological networks and priority / protected species populations The AAP should be underpinned by up to date environmental evidence including an assessment of existing and potential components of local ecological networks. This assessment should inform the Sustainability Appraisal, ensure that land of least environment value is chosen for development, and that the mitigation hierarchy is followed and inform opportunities for enhancement as well as development requirements for particular sites.

Priority habitats and species are those listed under Section 41 of the Natural Environment and Rural Communities Act, 2006 and UK Biodiversity Action Plan (UK BAP). Further information is available here: Habitats and species of principal importance in England . Local Biodiversity Action Plans (LBAPs) identify the local action needed to deliver UK targets for habitats and species. They also identify targets for other habitats and species of local importance and can provide a useful blueprint for biodiversity enhancement in any particular area.

Protected species are those species protected under domestic or European law. Further information can be found here Standing advice for protected species. Sites containing watercourses, old buildings, significant hedgerows and substantial trees are possible habitats for protected species. Ecological networks are coherent systems of natural habitats organised across whole landscapes so as to maintain ecological functions. A key principle is to maintain connectivity - to enable free movement and dispersal of wildlife e.g. badger routes, river corridors for the migration of fish and staging posts for migratory birds. Local ecological networks will form a key part of the wider Nature Recovery Network proposed in the 25 Year Environment Plan. Where development is proposed, opportunities should be explored to contribute to the enhancement of ecological networks.

Planning positively for ecological networks will also contribute towards a strategic approach for the creation , protection, enhancement and management of green infrastructure, as identified in paragraph 171 of the NPPF.

Water Quality and Resources and Flood Risk Management
Natural England expects the AAP to consider the strategic impacts on water quality and resources as outlined in paragraph 170 of the NPPF. We would also expect the plan to address flood risk management in line with the paragraphs 155-165 of the NPPF. The AAP should contain policies which protect habitats from water related impacts and where appropriate seek enhancement. Priority for enhancements should be focused on statutorily designated and local sites which contribute to a wider ecological network. The AAP should positively contribute to reducing flood risk by working with natural processes and where possible use Green Infrastructure policies and the provision of SUDs to achieve this.

Thank you for consulting Natural England on the above in your email of 11 February 2019. Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.

Natural England has no objection to the proposed regeneration of the North East Cambridge (NEC) Area, the principle of which is established in the recently adopted Local Plans. However, this is subject to the inclusion of robust policies within the Area Action Plan (AAP) to ensure delivery of a truly sustainable development including provision of strategic high quality multifunctional open space, with a long-term management strategy, to meet the needs of people and wildlife. We would expect the scale of development to deliver a green infrastructure network along the lines of similar developments elsewhere such as Cambourne, Trumpington Meadows and Waterbeach New Town. Development through the AAP should be guided by an established green infrastructure and biodiversity framework to ensure the NEC Area is capable of delivering the range of environmental services and natural capital required to meet the needs of the scale and nature of proposed development.

We note that the planning process for the future location of the Water Recycling Centre is outside the scope of this AAP and that this will be progressed by the County Council as the Local Planning Authority for waste matters.

Natural England welcomes proposals to undertake further environmental assessment work to inform preparation of the AAP, including air quality and noise assessments and habitat surveys. Whilst the majority of the NEC Area is brownfield land it supports significant local biodiversity interest and opportunities for enhancement. Advice should be sought from relevant sources including the Council ecologists and the Wildlife Trusts. Retention of all existing biodiversity interest and identification of opportunities for environmental enhancement should be a priority for the development of the green infrastructure and biodiversity framework and long-term enhancement and management strategy for the AAP.

The NEC Area Today
Figure 4.8 shows the extent of existing green and blue Infrastructure across the NEC area. However, we believe there may be additional areas of green infrastructure that are not included on the map. This should be confirmed and amended if necessary through the proposed ecological survey work.

We welcome recognition of ecological constraints in section 4.13; however, these are positives, not negatives, and should be seen as significant areas for retention and enhancement and the focus for development of a green infrastructure and biodiversity framework for the AAP. The AAP provides a unique opportunity for the enhancement, extension and improved connectivity of areas such as Bramblefields Local Nature Reserve (LNR), the protected hedgerow on the east side of Cowley Road (City Wildlife Site) and the First Public Drain wildlife corridor and other habitats including ponds and areas of woodland, scrub and grassland. The AAP should take every opportunity to retain and enhance as much of the natural environment as possible and to provide biodiversity rich green corridors across the site and beyond.

Section 4.20 and 4.22 acknowledge the requirement to deal with potential contaminated land and other environmental issues such as minimising light pollution which we fully support.

Vision and Strategic Objectives
Natural England supports the AAP vision and objectives for 'a socially and economically inclusive, thriving, and low carbon place for innovative living and working; inherently walkable where everything is on your doorstep'. We welcome the objective for green spaces to be a core part of the place structure extending, connecting and improving biodiversity to achieve a net gain and integrating Sustainable Drainage Systems within the development. As mentioned above, we believe the AAP should be developed around a robust green infrastructure framework for the site to ensure delivery of the full range of environmental services required to meet the needs of the proposed scale and nature of development: recreation, health and well-being, biodiversity, landscape, drainage, flood management, sustainable travel, climate change and adaptation. We note the following statement:

"Green infrastructure capitalises on the network of existing trees and landscape but also extends this to create an overall framework to improve biodiversity and linkages to the wider countryside. Embedded into this framework will be the water management network that improves the First Drain and adds richness to the landscape. A new green space at a district scale will enrich the heart of this new place and provide the kind of multifunctional space that is so typical of Cambridge and central to public life."

Whilst we fully support the above we would expect a development of this magnitude to deliver significantly greater than 'district scale' green infrastructure, although we are unclear what this really means. We have provided further advice on green infrastructure provision below.

Place Making
Sections 6.14 and 6.15 discuss creating a healthy community which we fully support. Our advice is that a strategic level of high quality greenspace provision will be key to creating a healthy community and enhancing people's physical and mental wellbeing. The extent of accessible natural greenspace provision (i.e. excluding formal sports areas) should be proportionate to the scale of development, for example 8ha 11000 population is advocated through the Suitable Alternative Natural Green Space (SANGS) guidance to meet people's needs and protect more sensitive designated sites such as Stow-cum-Quy Fen Site of Special Scientific Interest (SSSI) and Wicken Fen SSSI, Ramsar site. Whilst quantity of provision should be broadly aligned with SANGS guidance, green infrastructure design should seek to achieve the Natural England Accessible Natural Greenspace Standards, detailed in Nature Nearby, including the minimum standard of 2ha informal open space within 300m of everyone's home.

Further consideration should also be given to significantly enhanced green infrastructure corridors to improve connectivity of green infrastructure within the site and beyond, including green linkages with Milton Country Park. Green infrastructure provision should seek to contribute towards the delivery of the objectives of the Cambridgeshire Green Infrastructure Strategy for habitat enhancement and improved connectivity. The AAP should not rely on existing green space such as Milton Country Park to meet people's recreational needs; the AAP should seek provision of similar area of open space to complement and connect the Country Park.

Natural England agrees that the development of the NEC Area presents an opportunity to create a new network of streets and open spaces that will support and improve movement of people throughout the area. Creation of sufficient informal open space for outdoor recreation, enjoyment of the countryside, walking, cycling and adequate public transport provision will be critical to this. A network of green corridors should provide connectivity to areas off site including the Country Park, the Chisholm Trail and Waterbeach Greenways.

We note and welcome Option C to upgrade connections to Milton Country Park by both foot and cycle, including improving access to the Jane Coston Bridge, the Waterbeach Greenway project including a new access under the A 14. We would welcome consideration of options for a crossing of the railway line and the use of green bridges.

Issue: Green Space provision - Natural England advises that this needs to be addressed through a combination of options A -F to provide strategic high quality, biodiversity-rich multi-functional greenspace. This should seek to meet SANGS standards and be connected through substantial green corridors to open spaces across the site and beyond, including connectivity with Milton Country Park, Waterbeach Greenways and the Chisholm Trail, as discussed above.

Transport
Natural England advocates a focus on sustainable, non-car travel including cycling, walking and public transport.

Retail, Leisure and Community Services & Facilities
We welcome recognition of the multi-functional benefits of open space provision including biodiversity enhancement, landscape, drainage, flood management and health and wellbeing. A development of this scale should provide open space to accommodate formal and informal requirements: informal open space in accordance with SANGS, as discussed above, to provide biodiversity net gain and meet people's informal recreation, physical and mental health needs.

Climate change
We support proposals to contribute towards mitigating and adapting to climate change including the application of sustainable design and construction standards detailed in section 11.7. Natural England welcomes proposals outlined in section 11.14 for policies to integrate a SUDs network into the Fen edge landscape that could help to enhance opportunities for specified species as well as providing a sense of place.

Biodiversity
Natural England supports proposals to achieve measurable biodiversity net gain in accordance with national planning guidance and the Defra 25 Year Environment Plan. Natural England advises that the Council's should not simply strive to meet this target, through encouragement of quick wins such as green roof provision; the AAP should ensure significant long-term gains through development of a biodiversity and green infrastructure framework, delivery and long-term management strategy for the area, to guide wider development. Ecological surveys should identify key habitats for retention, buffering and enhancement and opportunities for creation of a wide range of additional habitat to complement, extend and connect existing habitats.

These areas should incorporate a wide range of environmental services including informal open space, landscaping and SUDS provision. The advice of relevant stakeholders including the Council ecologists, Wildlife Trust and Natural England should be sought on the preparation of a Biodiversity and Green Infrastructure Strategy and its delivery secured through robust plan policies.

Please note that Natural England's Impact Risk Zones (IRZs) have been published since this site was originally allocated for development in the Local Plan, a number of years ago. The IRZs are currently being updated to take into account evidence for recreational pressure risks to designated sites such as Stow-cum-Quy Fen and Wicken Fen. The provision of adequate level and quality of alternative accessible open space within large developments is crucial to mitigating the adverse effects of those developments, through increased recreational pressure, to sensitive designated sites.

We note the statement in section 11.17 that off site improvements may be required if biodiversity net gain cannot be fully achieved on site. Whilst we welcome this we believe that a development of this scale can deliver significant biodiversity net gain within the area boundary subject to proper planning and design from the outset.

Implementation and Delivery
We note and welcome the proposal to prepare a North East Cambridge Infrastructure Delivery Plan to provide a broad assessment of the social and physical infrastructure needed to support the planned development and regeneration of NEC and how these requirements could be met. Natural England advises that this should include identification of green infrastructure needed to deliver the range of environmental services required by the development including recreation, drainage, landscape and biodiversity enhancements.
Natural England supports the intention through the AAP to put in place a Section 106 regime to ensure all proposed developments across NEC contribute equitably to the provision and/or funding of all appropriate infrastructure requirements. We trust that this will include provision of green infrastructure including informal open space and biodiversity.

Interim Sustainability Appraisal
Natural England is satisfied that the Interim Sustainability Appraisal (SA) objectives and framework generally accord with the requirements of the Planning and Compulsory Purchase Act 2004 and the Strategic Environmental Assessment (SEA) Regulations. The SA seeks to address the effects of the AAP on key aspects of the natural environment including designated sites, biodiversity, landscape, green infrastructure and soils. The assessment and recommendations / mitigation will need to be updated as the AAP policies evolve and to take into account the findings and mitigation recommendations of the outstanding environmental assessments.

Other advice: Priority habitats, ecological networks and priority / protected species populations The AAP should be underpinned by up to date environmental evidence including an assessment of existing and potential components of local ecological networks. This assessment should inform the Sustainability Appraisal, ensure that land of least environment value is chosen for development, and that the mitigation hierarchy is followed and inform opportunities for enhancement as well as development requirements for particular sites.

Priority habitats and species are those listed under Section 41 of the Natural Environment and Rural Communities Act, 2006 and UK Biodiversity Action Plan (UK BAP). Further information is available here: Habitats and species of principal importance in England . Local Biodiversity Action Plans (LBAPs) identify the local action needed to deliver UK targets for habitats and species. They also identify targets for other habitats and species of local importance and can provide a useful blueprint for biodiversity enhancement in any particular area.

Protected species are those species protected under domestic or European law. Further information can be found here Standing advice for protected species. Sites containing watercourses, old buildings, significant hedgerows and substantial trees are possible habitats for protected species. Ecological networks are coherent systems of natural habitats organised across whole landscapes so as to maintain ecological functions. A key principle is to maintain connectivity - to enable free movement and dispersal of wildlife e.g. badger routes, river corridors for the migration of fish and staging posts for migratory birds. Local ecological networks will form a key part of the wider Nature Recovery Network proposed in the 25 Year Environment Plan. Where development is proposed, opportunities should be explored to contribute to the enhancement of ecological networks.

Planning positively for ecological networks will also contribute towards a strategic approach for the creation , protection, enhancement and management of green infrastructure, as identified in paragraph 171 of the NPPF.

Water Quality and Resources and Flood Risk Management
Natural England expects the AAP to consider the strategic impacts on water quality and resources as outlined in paragraph 170 of the NPPF. We would also expect the plan to address flood risk management in line with the paragraphs 155-165 of the NPPF. The AAP should contain policies which protect habitats from water related impacts and where appropriate seek enhancement. Priority for enhancements should be focused on statutorily designated and local sites which contribute to a wider ecological network. The AAP should positively contribute to reducing flood risk by working with natural processes and where possible use Green Infrastructure policies and the provision of SUDs to achieve this.

Thank you for consulting Natural England on the above in your email of 11 February 2019. Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.

Natural England has no objection to the proposed regeneration of the North East Cambridge (NEC) Area, the principle of which is established in the recently adopted Local Plans. However, this is subject to the inclusion of robust policies within the Area Action Plan (AAP) to ensure delivery of a truly sustainable development including provision of strategic high quality multifunctional open space, with a long-term management strategy, to meet the needs of people and wildlife. We would expect the scale of development to deliver a green infrastructure network along the lines of similar developments elsewhere such as Cambourne, Trumpington Meadows and Waterbeach New Town. Development through the AAP should be guided by an established green infrastructure and biodiversity framework to ensure the NEC Area is capable of delivering the range of environmental services and natural capital required to meet the needs of the scale and nature of proposed development.

We note that the planning process for the future location of the Water Recycling Centre is outside the scope of this AAP and that this will be progressed by the County Council as the Local Planning Authority for waste matters.

Natural England welcomes proposals to undertake further environmental assessment work to inform preparation of the AAP, including air quality and noise assessments and habitat surveys. Whilst the majority of the NEC Area is brownfield land it supports significant local biodiversity interest and opportunities for enhancement. Advice should be sought from relevant sources including the Council ecologists and the Wildlife Trusts. Retention of all existing biodiversity interest and identification of opportunities for environmental enhancement should be a priority for the development of the green infrastructure and biodiversity framework and long-term enhancement and management strategy for the AAP.

The NEC Area Today
Figure 4.8 shows the extent of existing green and blue Infrastructure across the NEC area. However, we believe there may be additional areas of green infrastructure that are not included on the map. This should be confirmed and amended if necessary through the proposed ecological survey work.

We welcome recognition of ecological constraints in section 4.13; however, these are positives, not negatives, and should be seen as significant areas for retention and enhancement and the focus for development of a green infrastructure and biodiversity framework for the AAP. The AAP provides a unique opportunity for the enhancement, extension and improved connectivity of areas such as Bramblefields Local Nature Reserve (LNR), the protected hedgerow on the east side of Cowley Road (City Wildlife Site) and the First Public Drain wildlife corridor and other habitats including ponds and areas of woodland, scrub and grassland. The AAP should take every opportunity to retain and enhance as much of the natural environment as possible and to provide biodiversity rich green corridors across the site and beyond.

Section 4.20 and 4.22 acknowledge the requirement to deal with potential contaminated land and other environmental issues such as minimising light pollution which we fully support.

Vision and Strategic Objectives
Natural England supports the AAP vision and objectives for 'a socially and economically inclusive, thriving, and low carbon place for innovative living and working; inherently walkable where everything is on your doorstep'. We welcome the objective for green spaces to be a core part of the place structure extending, connecting and improving biodiversity to achieve a net gain and integrating Sustainable Drainage Systems within the development. As mentioned above, we believe the AAP should be developed around a robust green infrastructure framework for the site to ensure delivery of the full range of environmental services required to meet the needs of the proposed scale and nature of development: recreation, health and well-being, biodiversity, landscape, drainage, flood management, sustainable travel, climate change and adaptation. We note the following statement:

"Green infrastructure capitalises on the network of existing trees and landscape but also extends this to create an overall framework to improve biodiversity and linkages to the wider countryside. Embedded into this framework will be the water management network that improves the First Drain and adds richness to the landscape. A new green space at a district scale will enrich the heart of this new place and provide the kind of multifunctional space that is so typical of Cambridge and central to public life."

Whilst we fully support the above we would expect a development of this magnitude to deliver significantly greater than 'district scale' green infrastructure, although we are unclear what this really means. We have provided further advice on green infrastructure provision below.

Place Making
Sections 6.14 and 6.15 discuss creating a healthy community which we fully support. Our advice is that a strategic level of high quality greenspace provision will be key to creating a healthy community and enhancing people's physical and mental wellbeing. The extent of accessible natural greenspace provision (i.e. excluding formal sports areas) should be proportionate to the scale of development, for example 8ha 11000 population is advocated through the Suitable Alternative Natural Green Space (SANGS) guidance to meet people's needs and protect more sensitive designated sites such as Stow-cum-Quy Fen Site of Special Scientific Interest (SSSI) and Wicken Fen SSSI, Ramsar site. Whilst quantity of provision should be broadly aligned with SANGS guidance, green infrastructure design should seek to achieve the Natural England Accessible Natural Greenspace Standards, detailed in Nature Nearby, including the minimum standard of 2ha informal open space within 300m of everyone's home.

Further consideration should also be given to significantly enhanced green infrastructure corridors to improve connectivity of green infrastructure within the site and beyond, including green linkages with Milton Country Park. Green infrastructure provision should seek to contribute towards the delivery of the objectives of the Cambridgeshire Green Infrastructure Strategy for habitat enhancement and improved connectivity. The AAP should not rely on existing green space such as Milton Country Park to meet people's recreational needs; the AAP should seek provision of similar area of open space to complement and connect the Country Park.

Natural England agrees that the development of the NEC Area presents an opportunity to create a new network of streets and open spaces that will support and improve movement of people throughout the area. Creation of sufficient informal open space for outdoor recreation, enjoyment of the countryside, walking, cycling and adequate public transport provision will be critical to this. A network of green corridors should provide connectivity to areas off site including the Country Park, the Chisholm Trail and Waterbeach Greenways.

We note and welcome Option C to upgrade connections to Milton Country Park by both foot and cycle, including improving access to the Jane Coston Bridge, the Waterbeach Greenway project including a new access under the A 14. We would welcome consideration of options for a crossing of the railway line and the use of green bridges.

Issue: Green Space provision - Natural England advises that this needs to be addressed through a combination of options A -F to provide strategic high quality, biodiversity-rich multi-functional greenspace. This should seek to meet SANGS standards and be connected through substantial green corridors to open spaces across the site and beyond, including connectivity with Milton Country Park, Waterbeach Greenways and the Chisholm Trail, as discussed above.

Transport
Natural England advocates a focus on sustainable, non-car travel including cycling, walking and public transport.

Retail, Leisure and Community Services & Facilities
We welcome recognition of the multi-functional benefits of open space provision including biodiversity enhancement, landscape, drainage, flood management and health and wellbeing. A development of this scale should provide open space to accommodate formal and informal requirements: informal open space in accordance with SANGS, as discussed above, to provide biodiversity net gain and meet people's informal recreation, physical and mental health needs.

Climate change
We support proposals to contribute towards mitigating and adapting to climate change including the application of sustainable design and construction standards detailed in section 11.7. Natural England welcomes proposals outlined in section 11.14 for policies to integrate a SUDs network into the Fen edge landscape that could help to enhance opportunities for specified species as well as providing a sense of place.

Biodiversity
Natural England supports proposals to achieve measurable biodiversity net gain in accordance with national planning guidance and the Defra 25 Year Environment Plan. Natural England advises that the Council's should not simply strive to meet this target, through encouragement of quick wins such as green roof provision; the AAP should ensure significant long-term gains through development of a biodiversity and green infrastructure framework, delivery and long-term management strategy for the area, to guide wider development. Ecological surveys should identify key habitats for retention, buffering and enhancement and opportunities for creation of a wide range of additional habitat to complement, extend and connect existing habitats.

These areas should incorporate a wide range of environmental services including informal open space, landscaping and SUDS provision. The advice of relevant stakeholders including the Council ecologists, Wildlife Trust and Natural England should be sought on the preparation of a Biodiversity and Green Infrastructure Strategy and its delivery secured through robust plan policies.

Please note that Natural England's Impact Risk Zones (IRZs) have been published since this site was originally allocated for development in the Local Plan, a number of years ago. The IRZs are currently being updated to take into account evidence for recreational pressure risks to designated sites such as Stow-cum-Quy Fen and Wicken Fen. The provision of adequate level and quality of alternative accessible open space within large developments is crucial to mitigating the adverse effects of those developments, through increased recreational pressure, to sensitive designated sites.

We note the statement in section 11.17 that off site improvements may be required if biodiversity net gain cannot be fully achieved on site. Whilst we welcome this we believe that a development of this scale can deliver significant biodiversity net gain within the area boundary subject to proper planning and design from the outset.

Implementation and Delivery
We note and welcome the proposal to prepare a North East Cambridge Infrastructure Delivery Plan to provide a broad assessment of the social and physical infrastructure needed to support the planned development and regeneration of NEC and how these requirements could be met. Natural England advises that this should include identification of green infrastructure needed to deliver the range of environmental services required by the development including recreation, drainage, landscape and biodiversity enhancements.
Natural England supports the intention through the AAP to put in place a Section 106 regime to ensure all proposed developments across NEC contribute equitably to the provision and/or funding of all appropriate infrastructure requirements. We trust that this will include provision of green infrastructure including informal open space and biodiversity.

Interim Sustainability Appraisal
Natural England is satisfied that the Interim Sustainability Appraisal (SA) objectives and framework generally accord with the requirements of the Planning and Compulsory Purchase Act 2004 and the Strategic Environmental Assessment (SEA) Regulations. The SA seeks to address the effects of the AAP on key aspects of the natural environment including designated sites, biodiversity, landscape, green infrastructure and soils. The assessment and recommendations / mitigation will need to be updated as the AAP policies evolve and to take into account the findings and mitigation recommendations of the outstanding environmental assessments.

Other advice: Priority habitats, ecological networks and priority / protected species populations The AAP should be underpinned by up to date environmental evidence including an assessment of existing and potential components of local ecological networks. This assessment should inform the Sustainability Appraisal, ensure that land of least environment value is chosen for development, and that the mitigation hierarchy is followed and inform opportunities for enhancement as well as development requirements for particular sites.

Priority habitats and species are those listed under Section 41 of the Natural Environment and Rural Communities Act, 2006 and UK Biodiversity Action Plan (UK BAP). Further information is available here: Habitats and species of principal importance in England . Local Biodiversity Action Plans (LBAPs) identify the local action needed to deliver UK targets for habitats and species. They also identify targets for other habitats and species of local importance and can provide a useful blueprint for biodiversity enhancement in any particular area.

Protected species are those species protected under domestic or European law. Further information can be found here Standing advice for protected species. Sites containing watercourses, old buildings, significant hedgerows and substantial trees are possible habitats for protected species. Ecological networks are coherent systems of natural habitats organised across whole landscapes so as to maintain ecological functions. A key principle is to maintain connectivity - to enable free movement and dispersal of wildlife e.g. badger routes, river corridors for the migration of fish and staging posts for migratory birds. Local ecological networks will form a key part of the wider Nature Recovery Network proposed in the 25 Year Environment Plan. Where development is proposed, opportunities should be explored to contribute to the enhancement of ecological networks.

Planning positively for ecological networks will also contribute towards a strategic approach for the creation , protection, enhancement and management of green infrastructure, as identified in paragraph 171 of the NPPF.

Water Quality and Resources and Flood Risk Management
Natural England expects the AAP to consider the strategic impacts on water quality and resources as outlined in paragraph 170 of the NPPF. We would also expect the plan to address flood risk management in line with the paragraphs 155-165 of the NPPF. The AAP should contain policies which protect habitats from water related impacts and where appropriate seek enhancement. Priority for enhancements should be focused on statutorily designated and local sites which contribute to a wider ecological network. The AAP should positively contribute to reducing flood risk by working with natural processes and where possible use Green Infrastructure policies and the provision of SUDs to achieve this.

Thank you for consulting Natural England on the above in your email of 11 February 2019. Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.

Natural England has no objection to the proposed regeneration of the North East Cambridge (NEC) Area, the principle of which is established in the recently adopted Local Plans. However, this is subject to the inclusion of robust policies within the Area Action Plan (AAP) to ensure delivery of a truly sustainable development including provision of strategic high quality multifunctional open space, with a long-term management strategy, to meet the needs of people and wildlife. We would expect the scale of development to deliver a green infrastructure network along the lines of similar developments elsewhere such as Cambourne, Trumpington Meadows and Waterbeach New Town. Development through the AAP should be guided by an established green infrastructure and biodiversity framework to ensure the NEC Area is capable of delivering the range of environmental services and natural capital required to meet the needs of the scale and nature of proposed development.

We note that the planning process for the future location of the Water Recycling Centre is outside the scope of this AAP and that this will be progressed by the County Council as the Local Planning Authority for waste matters.

Natural England welcomes proposals to undertake further environmental assessment work to inform preparation of the AAP, including air quality and noise assessments and habitat surveys. Whilst the majority of the NEC Area is brownfield land it supports significant local biodiversity interest and opportunities for enhancement. Advice should be sought from relevant sources including the Council ecologists and the Wildlife Trusts. Retention of all existing biodiversity interest and identification of opportunities for environmental enhancement should be a priority for the development of the green infrastructure and biodiversity framework and long-term enhancement and management strategy for the AAP.

The NEC Area Today
Figure 4.8 shows the extent of existing green and blue Infrastructure across the NEC area. However, we believe there may be additional areas of green infrastructure that are not included on the map. This should be confirmed and amended if necessary through the proposed ecological survey work.

We welcome recognition of ecological constraints in section 4.13; however, these are positives, not negatives, and should be seen as significant areas for retention and enhancement and the focus for development of a green infrastructure and biodiversity framework for the AAP. The AAP provides a unique opportunity for the enhancement, extension and improved connectivity of areas such as Bramblefields Local Nature Reserve (LNR), the protected hedgerow on the east side of Cowley Road (City Wildlife Site) and the First Public Drain wildlife corridor and other habitats including ponds and areas of woodland, scrub and grassland. The AAP should take every opportunity to retain and enhance as much of the natural environment as possible and to provide biodiversity rich green corridors across the site and beyond.

Section 4.20 and 4.22 acknowledge the requirement to deal with potential contaminated land and other environmental issues such as minimising light pollution which we fully support.

Vision and Strategic Objectives
Natural England supports the AAP vision and objectives for 'a socially and economically inclusive, thriving, and low carbon place for innovative living and working; inherently walkable where everything is on your doorstep'. We welcome the objective for green spaces to be a core part of the place structure extending, connecting and improving biodiversity to achieve a net gain and integrating Sustainable Drainage Systems within the development. As mentioned above, we believe the AAP should be developed around a robust green infrastructure framework for the site to ensure delivery of the full range of environmental services required to meet the needs of the proposed scale and nature of development: recreation, health and well-being, biodiversity, landscape, drainage, flood management, sustainable travel, climate change and adaptation. We note the following statement:

"Green infrastructure capitalises on the network of existing trees and landscape but also extends this to create an overall framework to improve biodiversity and linkages to the wider countryside. Embedded into this framework will be the water management network that improves the First Drain and adds richness to the landscape. A new green space at a district scale will enrich the heart of this new place and provide the kind of multifunctional space that is so typical of Cambridge and central to public life."

Whilst we fully support the above we would expect a development of this magnitude to deliver significantly greater than 'district scale' green infrastructure, although we are unclear what this really means. We have provided further advice on green infrastructure provision below.

Place Making
Sections 6.14 and 6.15 discuss creating a healthy community which we fully support. Our advice is that a strategic level of high quality greenspace provision will be key to creating a healthy community and enhancing people's physical and mental wellbeing. The extent of accessible natural greenspace provision (i.e. excluding formal sports areas) should be proportionate to the scale of development, for example 8ha 11000 population is advocated through the Suitable Alternative Natural Green Space (SANGS) guidance to meet people's needs and protect more sensitive designated sites such as Stow-cum-Quy Fen Site of Special Scientific Interest (SSSI) and Wicken Fen SSSI, Ramsar site. Whilst quantity of provision should be broadly aligned with SANGS guidance, green infrastructure design should seek to achieve the Natural England Accessible Natural Greenspace Standards, detailed in Nature Nearby, including the minimum standard of 2ha informal open space within 300m of everyone's home.

Further consideration should also be given to significantly enhanced green infrastructure corridors to improve connectivity of green infrastructure within the site and beyond, including green linkages with Milton Country Park. Green infrastructure provision should seek to contribute towards the delivery of the objectives of the Cambridgeshire Green Infrastructure Strategy for habitat enhancement and improved connectivity. The AAP should not rely on existing green space such as Milton Country Park to meet people's recreational needs; the AAP should seek provision of similar area of open space to complement and connect the Country Park.

Natural England agrees that the development of the NEC Area presents an opportunity to create a new network of streets and open spaces that will support and improve movement of people throughout the area. Creation of sufficient informal open space for outdoor recreation, enjoyment of the countryside, walking, cycling and adequate public transport provision will be critical to this. A network of green corridors should provide connectivity to areas off site including the Country Park, the Chisholm Trail and Waterbeach Greenways.

We note and welcome Option C to upgrade connections to Milton Country Park by both foot and cycle, including improving access to the Jane Coston Bridge, the Waterbeach Greenway project including a new access under the A 14. We would welcome consideration of options for a crossing of the railway line and the use of green bridges.

Issue: Green Space provision - Natural England advises that this needs to be addressed through a combination of options A -F to provide strategic high quality, biodiversity-rich multi-functional greenspace. This should seek to meet SANGS standards and be connected through substantial green corridors to open spaces across the site and beyond, including connectivity with Milton Country Park, Waterbeach Greenways and the Chisholm Trail, as discussed above.

Transport
Natural England advocates a focus on sustainable, non-car travel including cycling, walking and public transport.

Retail, Leisure and Community Services & Facilities
We welcome recognition of the multi-functional benefits of open space provision including biodiversity enhancement, landscape, drainage, flood management and health and wellbeing. A development of this scale should provide open space to accommodate formal and informal requirements: informal open space in accordance with SANGS, as discussed above, to provide biodiversity net gain and meet people's informal recreation, physical and mental health needs.

Climate change
We support proposals to contribute towards mitigating and adapting to climate change including the application of sustainable design and construction standards detailed in section 11.7. Natural England welcomes proposals outlined in section 11.14 for policies to integrate a SUDs network into the Fen edge landscape that could help to enhance opportunities for specified species as well as providing a sense of place.

Biodiversity
Natural England supports proposals to achieve measurable biodiversity net gain in accordance with national planning guidance and the Defra 25 Year Environment Plan. Natural England advises that the Council's should not simply strive to meet this target, through encouragement of quick wins such as green roof provision; the AAP should ensure significant long-term gains through development of a biodiversity and green infrastructure framework, delivery and long-term management strategy for the area, to guide wider development. Ecological surveys should identify key habitats for retention, buffering and enhancement and opportunities for creation of a wide range of additional habitat to complement, extend and connect existing habitats.

These areas should incorporate a wide range of environmental services including informal open space, landscaping and SUDS provision. The advice of relevant stakeholders including the Council ecologists, Wildlife Trust and Natural England should be sought on the preparation of a Biodiversity and Green Infrastructure Strategy and its delivery secured through robust plan policies.

Please note that Natural England's Impact Risk Zones (IRZs) have been published since this site was originally allocated for development in the Local Plan, a number of years ago. The IRZs are currently being updated to take into account evidence for recreational pressure risks to designated sites such as Stow-cum-Quy Fen and Wicken Fen. The provision of adequate level and quality of alternative accessible open space within large developments is crucial to mitigating the adverse effects of those developments, through increased recreational pressure, to sensitive designated sites.

We note the statement in section 11.17 that off site improvements may be required if biodiversity net gain cannot be fully achieved on site. Whilst we welcome this we believe that a development of this scale can deliver significant biodiversity net gain within the area boundary subject to proper planning and design from the outset.

Implementation and Delivery
We note and welcome the proposal to prepare a North East Cambridge Infrastructure Delivery Plan to provide a broad assessment of the social and physical infrastructure needed to support the planned development and regeneration of NEC and how these requirements could be met. Natural England advises that this should include identification of green infrastructure needed to deliver the range of environmental services required by the development including recreation, drainage, landscape and biodiversity enhancements.
Natural England supports the intention through the AAP to put in place a Section 106 regime to ensure all proposed developments across NEC contribute equitably to the provision and/or funding of all appropriate infrastructure requirements. We trust that this will include provision of green infrastructure including informal open space and biodiversity.

Interim Sustainability Appraisal
Natural England is satisfied that the Interim Sustainability Appraisal (SA) objectives and framework generally accord with the requirements of the Planning and Compulsory Purchase Act 2004 and the Strategic Environmental Assessment (SEA) Regulations. The SA seeks to address the effects of the AAP on key aspects of the natural environment including designated sites, biodiversity, landscape, green infrastructure and soils. The assessment and recommendations / mitigation will need to be updated as the AAP policies evolve and to take into account the findings and mitigation recommendations of the outstanding environmental assessments.

Other advice: Priority habitats, ecological networks and priority / protected species populations The AAP should be underpinned by up to date environmental evidence including an assessment of existing and potential components of local ecological networks. This assessment should inform the Sustainability Appraisal, ensure that land of least environment value is chosen for development, and that the mitigation hierarchy is followed and inform opportunities for enhancement as well as development requirements for particular sites.

Priority habitats and species are those listed under Section 41 of the Natural Environment and Rural Communities Act, 2006 and UK Biodiversity Action Plan (UK BAP). Further information is available here: Habitats and species of principal importance in England . Local Biodiversity Action Plans (LBAPs) identify the local action needed to deliver UK targets for habitats and species. They also identify targets for other habitats and species of local importance and can provide a useful blueprint for biodiversity enhancement in any particular area.

Protected species are those species protected under domestic or European law. Further information can be found here Standing advice for protected species. Sites containing watercourses, old buildings, significant hedgerows and substantial trees are possible habitats for protected species. Ecological networks are coherent systems of natural habitats organised across whole landscapes so as to maintain ecological functions. A key principle is to maintain connectivity - to enable free movement and dispersal of wildlife e.g. badger routes, river corridors for the migration of fish and staging posts for migratory birds. Local ecological networks will form a key part of the wider Nature Recovery Network proposed in the 25 Year Environment Plan. Where development is proposed, opportunities should be explored to contribute to the enhancement of ecological networks.

Planning positively for ecological networks will also contribute towards a strategic approach for the creation , protection, enhancement and management of green infrastructure, as identified in paragraph 171 of the NPPF.

Water Quality and Resources and Flood Risk Management
Natural England expects the AAP to consider the strategic impacts on water quality and resources as outlined in paragraph 170 of the NPPF. We would also expect the plan to address flood risk management in line with the paragraphs 155-165 of the NPPF. The AAP should contain policies which protect habitats from water related impacts and where appropriate seek enhancement. Priority for enhancements should be focused on statutorily designated and local sites which contribute to a wider ecological network. The AAP should positively contribute to reducing flood risk by working with natural processes and where possible use Green Infrastructure policies and the provision of SUDs to achieve this.

Thank you for consulting Natural England on the above in your email of 11 February 2019. Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.

Natural England has no objection to the proposed regeneration of the North East Cambridge (NEC) Area, the principle of which is established in the recently adopted Local Plans. However, this is subject to the inclusion of robust policies within the Area Action Plan (AAP) to ensure delivery of a truly sustainable development including provision of strategic high quality multifunctional open space, with a long-term management strategy, to meet the needs of people and wildlife. We would expect the scale of development to deliver a green infrastructure network along the lines of similar developments elsewhere such as Cambourne, Trumpington Meadows and Waterbeach New Town. Development through the AAP should be guided by an established green infrastructure and biodiversity framework to ensure the NEC Area is capable of delivering the range of environmental services and natural capital required to meet the needs of the scale and nature of proposed development.

We note that the planning process for the future location of the Water Recycling Centre is outside the scope of this AAP and that this will be progressed by the County Council as the Local Planning Authority for waste matters.

Natural England welcomes proposals to undertake further environmental assessment work to inform preparation of the AAP, including air quality and noise assessments and habitat surveys. Whilst the majority of the NEC Area is brownfield land it supports significant local biodiversity interest and opportunities for enhancement. Advice should be sought from relevant sources including the Council ecologists and the Wildlife Trusts. Retention of all existing biodiversity interest and identification of opportunities for environmental enhancement should be a priority for the development of the green infrastructure and biodiversity framework and long-term enhancement and management strategy for the AAP.

The NEC Area Today
Figure 4.8 shows the extent of existing green and blue Infrastructure across the NEC area. However, we believe there may be additional areas of green infrastructure that are not included on the map. This should be confirmed and amended if necessary through the proposed ecological survey work.

We welcome recognition of ecological constraints in section 4.13; however, these are positives, not negatives, and should be seen as significant areas for retention and enhancement and the focus for development of a green infrastructure and biodiversity framework for the AAP. The AAP provides a unique opportunity for the enhancement, extension and improved connectivity of areas such as Bramblefields Local Nature Reserve (LNR), the protected hedgerow on the east side of Cowley Road (City Wildlife Site) and the First Public Drain wildlife corridor and other habitats including ponds and areas of woodland, scrub and grassland. The AAP should take every opportunity to retain and enhance as much of the natural environment as possible and to provide biodiversity rich green corridors across the site and beyond.

Section 4.20 and 4.22 acknowledge the requirement to deal with potential contaminated land and other environmental issues such as minimising light pollution which we fully support.

Vision and Strategic Objectives
Natural England supports the AAP vision and objectives for 'a socially and economically inclusive, thriving, and low carbon place for innovative living and working; inherently walkable where everything is on your doorstep'. We welcome the objective for green spaces to be a core part of the place structure extending, connecting and improving biodiversity to achieve a net gain and integrating Sustainable Drainage Systems within the development. As mentioned above, we believe the AAP should be developed around a robust green infrastructure framework for the site to ensure delivery of the full range of environmental services required to meet the needs of the proposed scale and nature of development: recreation, health and well-being, biodiversity, landscape, drainage, flood management, sustainable travel, climate change and adaptation. We note the following statement:

"Green infrastructure capitalises on the network of existing trees and landscape but also extends this to create an overall framework to improve biodiversity and linkages to the wider countryside. Embedded into this framework will be the water management network that improves the First Drain and adds richness to the landscape. A new green space at a district scale will enrich the heart of this new place and provide the kind of multifunctional space that is so typical of Cambridge and central to public life."

Whilst we fully support the above we would expect a development of this magnitude to deliver significantly greater than 'district scale' green infrastructure, although we are unclear what this really means. We have provided further advice on green infrastructure provision below.

Place Making
Sections 6.14 and 6.15 discuss creating a healthy community which we fully support. Our advice is that a strategic level of high quality greenspace provision will be key to creating a healthy community and enhancing people's physical and mental wellbeing. The extent of accessible natural greenspace provision (i.e. excluding formal sports areas) should be proportionate to the scale of development, for example 8ha 11000 population is advocated through the Suitable Alternative Natural Green Space (SANGS) guidance to meet people's needs and protect more sensitive designated sites such as Stow-cum-Quy Fen Site of Special Scientific Interest (SSSI) and Wicken Fen SSSI, Ramsar site. Whilst quantity of provision should be broadly aligned with SANGS guidance, green infrastructure design should seek to achieve the Natural England Accessible Natural Greenspace Standards, detailed in Nature Nearby, including the minimum standard of 2ha informal open space within 300m of everyone's home.

Further consideration should also be given to significantly enhanced green infrastructure corridors to improve connectivity of green infrastructure within the site and beyond, including green linkages with Milton Country Park. Green infrastructure provision should seek to contribute towards the delivery of the objectives of the Cambridgeshire Green Infrastructure Strategy for habitat enhancement and improved connectivity. The AAP should not rely on existing green space such as Milton Country Park to meet people's recreational needs; the AAP should seek provision of similar area of open space to complement and connect the Country Park.

Natural England agrees that the development of the NEC Area presents an opportunity to create a new network of streets and open spaces that will support and improve movement of people throughout the area. Creation of sufficient informal open space for outdoor recreation, enjoyment of the countryside, walking, cycling and adequate public transport provision will be critical to this. A network of green corridors should provide connectivity to areas off site including the Country Park, the Chisholm Trail and Waterbeach Greenways.

We note and welcome Option C to upgrade connections to Milton Country Park by both foot and cycle, including improving access to the Jane Coston Bridge, the Waterbeach Greenway project including a new access under the A 14. We would welcome consideration of options for a crossing of the railway line and the use of green bridges.

Issue: Green Space provision - Natural England advises that this needs to be addressed through a combination of options A -F to provide strategic high quality, biodiversity-rich multi-functional greenspace. This should seek to meet SANGS standards and be connected through substantial green corridors to open spaces across the site and beyond, including connectivity with Milton Country Park, Waterbeach Greenways and the Chisholm Trail, as discussed above.

Transport
Natural England advocates a focus on sustainable, non-car travel including cycling, walking and public transport.

Retail, Leisure and Community Services & Facilities
We welcome recognition of the multi-functional benefits of open space provision including biodiversity enhancement, landscape, drainage, flood management and health and wellbeing. A development of this scale should provide open space to accommodate formal and informal requirements: informal open space in accordance with SANGS, as discussed above, to provide biodiversity net gain and meet people's informal recreation, physical and mental health needs.

Climate change
We support proposals to contribute towards mitigating and adapting to climate change including the application of sustainable design and construction standards detailed in section 11.7. Natural England welcomes proposals outlined in section 11.14 for policies to integrate a SUDs network into the Fen edge landscape that could help to enhance opportunities for specified species as well as providing a sense of place.

Biodiversity
Natural England supports proposals to achieve measurable biodiversity net gain in accordance with national planning guidance and the Defra 25 Year Environment Plan. Natural England advises that the Council's should not simply strive to meet this target, through encouragement of quick wins such as green roof provision; the AAP should ensure significant long-term gains through development of a biodiversity and green infrastructure framework, delivery and long-term management strategy for the area, to guide wider development. Ecological surveys should identify key habitats for retention, buffering and enhancement and opportunities for creation of a wide range of additional habitat to complement, extend and connect existing habitats.

These areas should incorporate a wide range of environmental services including informal open space, landscaping and SUDS provision. The advice of relevant stakeholders including the Council ecologists, Wildlife Trust and Natural England should be sought on the preparation of a Biodiversity and Green Infrastructure Strategy and its delivery secured through robust plan policies.

Please note that Natural England's Impact Risk Zones (IRZs) have been published since this site was originally allocated for development in the Local Plan, a number of years ago. The IRZs are currently being updated to take into account evidence for recreational pressure risks to designated sites such as Stow-cum-Quy Fen and Wicken Fen. The provision of adequate level and quality of alternative accessible open space within large developments is crucial to mitigating the adverse effects of those developments, through increased recreational pressure, to sensitive designated sites.

We note the statement in section 11.17 that off site improvements may be required if biodiversity net gain cannot be fully achieved on site. Whilst we welcome this we believe that a development of this scale can deliver significant biodiversity net gain within the area boundary subject to proper planning and design from the outset.

Implementation and Delivery
We note and welcome the proposal to prepare a North East Cambridge Infrastructure Delivery Plan to provide a broad assessment of the social and physical infrastructure needed to support the planned development and regeneration of NEC and how these requirements could be met. Natural England advises that this should include identification of green infrastructure needed to deliver the range of environmental services required by the development including recreation, drainage, landscape and biodiversity enhancements.
Natural England supports the intention through the AAP to put in place a Section 106 regime to ensure all proposed developments across NEC contribute equitably to the provision and/or funding of all appropriate infrastructure requirements. We trust that this will include provision of green infrastructure including informal open space and biodiversity.

Interim Sustainability Appraisal
Natural England is satisfied that the Interim Sustainability Appraisal (SA) objectives and framework generally accord with the requirements of the Planning and Compulsory Purchase Act 2004 and the Strategic Environmental Assessment (SEA) Regulations. The SA seeks to address the effects of the AAP on key aspects of the natural environment including designated sites, biodiversity, landscape, green infrastructure and soils. The assessment and recommendations / mitigation will need to be updated as the AAP policies evolve and to take into account the findings and mitigation recommendations of the outstanding environmental assessments.

Other advice: Priority habitats, ecological networks and priority / protected species populations The AAP should be underpinned by up to date environmental evidence including an assessment of existing and potential components of local ecological networks. This assessment should inform the Sustainability Appraisal, ensure that land of least environment value is chosen for development, and that the mitigation hierarchy is followed and inform opportunities for enhancement as well as development requirements for particular sites.

Priority habitats and species are those listed under Section 41 of the Natural Environment and Rural Communities Act, 2006 and UK Biodiversity Action Plan (UK BAP). Further information is available here: Habitats and species of principal importance in England . Local Biodiversity Action Plans (LBAPs) identify the local action needed to deliver UK targets for habitats and species. They also identify targets for other habitats and species of local importance and can provide a useful blueprint for biodiversity enhancement in any particular area.

Protected species are those species protected under domestic or European law. Further information can be found here Standing advice for protected species. Sites containing watercourses, old buildings, significant hedgerows and substantial trees are possible habitats for protected species. Ecological networks are coherent systems of natural habitats organised across whole landscapes so as to maintain ecological functions. A key principle is to maintain connectivity - to enable free movement and dispersal of wildlife e.g. badger routes, river corridors for the migration of fish and staging posts for migratory birds. Local ecological networks will form a key part of the wider Nature Recovery Network proposed in the 25 Year Environment Plan. Where development is proposed, opportunities should be explored to contribute to the enhancement of ecological networks.

Planning positively for ecological networks will also contribute towards a strategic approach for the creation , protection, enhancement and management of green infrastructure, as identified in paragraph 171 of the NPPF.

Water Quality and Resources and Flood Risk Management
Natural England expects the AAP to consider the strategic impacts on water quality and resources as outlined in paragraph 170 of the NPPF. We would also expect the plan to address flood risk management in line with the paragraphs 155-165 of the NPPF. The AAP should contain policies which protect habitats from water related impacts and where appropriate seek enhancement. Priority for enhancements should be focused on statutorily designated and local sites which contribute to a wider ecological network. The AAP should positively contribute to reducing flood risk by working with natural processes and where possible use Green Infrastructure policies and the provision of SUDs to achieve this.