Date: Our ref: Your ref
1st October 2012 58680
Jo Mills Director of Planning and New Communities South Cambridgeshire District Council
Natural England Consultation Service Hornbeam House Electra Way Crewe Business Park CREWE CW1 6GJ
BY E-MAIL ONLY Dear Ms Mills South Cambridgeshire Local Plan Issues and Options Consultation Thank you consulting Natural England on the South Cambridgeshire Local Plan Issues and Options, in your e-mail dated 12th July 2012. Our comments are as follows. 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. Issues and Options Report 1. Introduction Natural England generally supports the approach of the Issues and Options Report in seeking to prepare a Local Plan that is committed to sustainable development, encouraging development that is of high quality and meets the challenges of climate change. We particularly welcome that the report recognises the value of the existing environment and its importance to local people and visitors alike. The report takes a positive approach to the protection and enhancement of the natural environment including improvement of biodiversity and minimising pollution; we believe this to be a fundamental consideration in the preparation of a plan which, as identified in section 1.3, strikes the right balance between growth and conservation, valuing what makes the area unique and seeks to target growth in the right areas. 2. Vision We welcome the proposed Vision and Objectives identified in the report, particularly protection and enhancement of biodiversity and the requirement for development which responds robustly to climate change, includes sustainable transport and improves access for everyone to services including local open space and green infrastructure (GI). We note and welcome that South Cambridgeshire District Council recognises the issues and options facing neighbouring authorities and has been working closely with these authorities to ensure plans are co-ordinated and wider infrastructure needs are considered.
Development in these locations may pose a significant risk to the local biodiversity interest of this area. Spatial Strategy Issue 8: Sustainable Development – we welcome recognition of the need to prioritise development on brownfield rather than Greenfield land. Issues 10 . We would expect environmental impacts and mitigation requirements to be fully addressed as part of the site allocations and development process. improvements and enhancements to visual amenity and biodiversity. We would therefore welcome a specific policy focusing development on the re-use of previously developed land. Broad Location 7 lies directly between and in close proximity to Cherry Hinton Pit and Gog Magog Golf Course / Roman Road SSSIs and several CWSs.12: . options which have least impact on the natural environment would be preferred. We believe the Development Strategy should seek to identify the most sustainable locations for development. its purposes and functions. Natural England has concerns that development in
. Development Needs Issue 4 Housing Provision – whilst acknowledging the need for the right level of development to meet demand. and the requirement. including impacts on designated sites such as SSSIs and County Wildlife Sites (CWS) and wider biodiversity and strategic GI. Natural England would have particular concerns with proposals for release of Green Belt land where this is likely to have an adverse effect on biodiversity.3. Development in this location may pose significant risk to the effective delivery of this local biodiversity/GI target. Issue 9: Development Strategy . to protect this. particularly ‘designated sites and other features contributing positively to the character of the landscape setting’ and ‘green corridors penetrating into the city’.Natural England would welcome an approach which seeks to enhance the beneficial use of the Green Belt by providing opportunities for outdoor sports and recreation. 4. We welcome recognition of the importance of the Green Belt.500 dwellings and a strategic location for new employment has now been lost. identifies that most of the locations support areas of at least local biodiversity / GI importance and most include landscape essential to preserving the special character and setting of Cambridge. We acknowledge this as a key issue for the new Local Plan to address alongside the wider development needs of the District. We would therefore welcome carrying these functions forward into the new Plan. Assessment of Broad Locations on the Edge of Cambridge.we note that Cambridge East will no longer be developed meaning that a key element of the current strategy that would provide land for approximately 7. ensuring all land of high value multi-functional green space is protected and enhanced and ensuring development minimises impacts and maximises enhancement opportunities wherever possible. Broad Location 6 is a strategic GI site identified through the GI Strategy for chalk grassland restoration. landscape and access/amenity. where the land is not of high environmental value or where it possible to satisfactorily mitigate any impacts. Broad Locations 2 and 3 lie either side of a major green corridor of significant local biodiversity and amenity importance including several CWSs including the River Cam. identified through the NPPF. Appendix 2. We believe that identifying such sites and encouraging appropriate sustainable development of these sites should be a priority for the plan if land of higher multi-functional value in the Green Belt and wider countryside is to be preserved and enhanced. increasing access.
Opportunities to maintain and enhance the natural environment and access to this should be maximised as far as possible. ensure sustainable construction and encourage renewable and low
. Waterbeach and Bourn Airfield . Issue 16 Development Options: Northstowe Reserve – Natural England has been involved in the various masterplanning stages of the Northstowe development and has submitted comments on the current planning application for a first phase of development of 1. to the special interest features of these nationally important sites and on wider biodiversity. NNR and Gamlingay Wood SSSI respectively. Impacts on designated sites through increased recreational pressure should be fully considered – for example Option 28 Fulbourn and options 32-34 Gamlingay are in close proximity to Fulbourn Fen SSSI. particularly through increased access. landscape and access. seeks to minimise flood risk and enhance water quality. We note that allocation of the reserve land is unlikely to provide additional housing in the plan period but could provide flexibility on how the town is developed.this location may pose significant risk. We are aware that Waterbeach airfield supports habitats of significant local biodiversity interest. 5. landscape and access to this. Land quality varies from place to place and the Agricultural Land Classification (ALC) provides a method for assessing the quality of farmland to enable informed choices to be made about its future use within the planning system. biodiversity and flooding. Development should make significant contributions to the aims and aspirations of the Cambridgeshire GI Strategy and the Cambridgeshire BAP. Development Options We welcome consideration of constraints including designated sites.options should have least impact on the natural environment. other than to request that options should have least impact on the natural environment. hence options which protect and enhance this whole area as open space/nature reserve would be preferred. We note that a co-ordinated approach is being taken with Cambridge City Council to look at broad locations for growth in the Green Belt. 6. It helps underpin the principles of sustainable development. Paragraph 112 of the NPPF is relevant when considering the protection of best and most versatile (BMV) agricultural land. Climate Change Natural England welcomes this chapter which promotes multi-functional SUDS.500 homes. except where this would be inconsistent with other sustainability considerations. The Sustainability Appraisal identifies that all general locations could involve development of agricultural land of ALC grades 2 and 3. landscape. Issues 13 -15 – Natural England has no specific comments to make regarding the nature and location of village development. Where significant development of agricultural land is unavoidable. Development of this site should seek to maximise GI creation and enhancement opportunities. other than to request that options should have least impact on the natural environment. in line with the GI Strategy. poorer quality land should be used in preference to that of higher quality (grades 1-3a). Relevant policy should recognise this and seek to ensure that allocation/development protects and enhances the local biodiversity interest of these sites. We have no specific comments regarding the 52 site options. Further information is provided on Natural England’s website. landscape and access.
An update of the Biodiversity SPD would provide a useful guide for developers and help secure the long-term protection. Issue 30 Landscape Character – Natural England strongly advises the inclusion of a policy to require development proposals to reflect and enhance the character and distinctiveness of the landscape. We welcome cross-references to the Cambridgeshire Green Infrastructure Strategy and Cambridgeshire BAP. Relevant policy should recognise this and include a requirement for development to fully assess impacts and provide suitable mitigation/compensation for any impacts. GI. New development should build-in and ensure that consideration is given to the wider landscape based on landscape assessment. See comments above regarding proposals likely to have an adverse impact on high grade agricultural land. arable plants etc. Soils of high environmental value such as wetland soils should also be considered as part of ecological connectivity. orchards. invertebrates. Green Belt. The plan should also recognise that development (soil sealing) can have a major and usually irreversible adverse impact on soils. is often overlooked and losses inadequately mitigated. to include recognition of the relevant NCA. 7. Natural England would welcome a policy to address this. We are satisfied that this section recognises the benefits of GI / open space and vegetation in helping to reduce the effects of climate change and relevant policy should require developers to consider this. A landscape character approach should be used to underpin and guide decisions on development and set out criteria based policies for landscape character areas. We have not provided detailed comments on this section as we generally welcome the approaches identified through Issues 17 . We welcome this and the consideration of designation of Local Green Spaces as set out in the NPPF.. enhancement and management of biodiversity in the District. sustainable drainage and climate change mitigation and protection of trees and other landscape features of amenity and biodiversity value. Development of agricultural land can pose significant threats to biodiversity. brown hare. in line with the NPPF. Issue 31: Agricultural Land – see our comments above. amenity areas.
. We welcome inclusion of policies in relation to these important GI assets. Issue 32 Biodiversity recognises the requirement. Mitigation should aim to minimise soil disturbance and to retain as many ecosystem services as possible through careful soil management during construction. particularly for farmland birds (including BAP and Red List species) and wintering waders. Protecting and Enhancing the Natural and Historic Environment This section seeks to protect and enhance biodiversity. the River Cam and other waterways.27. 8. along with a requirement for developers to seek to reduce habitat loss and fragmentation. for development to minimise negative impacts on biodiversity and provide net gains where possible. Delivering High Quality Places We are pleased that this section includes reference to design principles for high quality landscaping and public spaces that provide opportunities for recreation. The importance of agricultural land in the district for biodiversity should be recognised. Encouragement of green (and brown) roofs is particularly welcomed. Natural England would strongly advise the inclusion of a policy to protect BMV land from development. biodiversity.carbon energy development.
We believe that only those sites where it can be demonstrated that there will be no adverse effect on biodiversity. Policies should require that development will protect the natural environment and make a positive contribution to its enhancement wherever possible. ‘Nature Nearby. One important function of GI is the provision of new opportunities for access to open space. Full consideration should be given to the objectives and aspirations of the Cambridgeshire Green Infrastructure Strategy. particularly where this offers multi-functional benefits. landscape and green corridors within the strategic GI network. given the additional pressures from development. high quality design and long-term maintenance of GI wherever possible.Issue 33 Green Infrastructure – we agree that all new development should be expected to contribute towards the provision of additional GI which contributes to the targets/projects of the GI Strategy. publication reference NE265. including green corridors and PRoW and national trails should be included here. Natural England’s ‘standards for accessible natural greenspace’ (ANGSt) provides a set of benchmarks. available on our website. 9. Issues 34 – 36 – see our comments on the Green Belt above. butterflies and an important invertebrate community. landscape and access should be taken forward. The Local Plan should follow NPPF requirements but also include more detailed guidance to ensure adverse effects on the natural environment are minimised Issue 38 – in line with the new NPPF requirements we believe that open spaces should be identified as Local Green Space where possible. Building a Strong and Competitive Economy Policies and allocations for new/extended development need to fully respect the natural environment. A suitable policy should be included to require that developers minimise impacts and maximise opportunities to enhance and extend the GI network in line with the GI Strategy. More information can be found on Natural England’s publication. hence we welcome these proposals. Developers should be encouraged to ensure multi-functionality. The need to protect and enhance designated sites and GI.
. GI should be an integral part of the creation of sustainable communities and the Local Plan process can provide a useful starting point in the consideration of GI provision and the allocation of sites and policy development through the plan. Delivering High Quality Homes Natural England has no specific comments on the issues relating to delivery standards for housing other than to request that options should have least impact on the natural environment. allotments and waterways including the River Cam provide a range of multi-functional benefits including biodiversity. Accessible Greenspace Guidance’ (March 2010). 10. Issue 74 Tourist Facilities and Visitor Attractions – this section should recognise the importance of the natural environment and landscape setting in attracting and enhancing the experience of visitors and tourists to the district. which should be used to ensure new and existing residential development has access to nature. landscape and access to this. Issue 59 – Cambridge Northern Fringe East – any policy relating to this site should recognise the significant local biodiversity value of the Chesterton Sidings site supporting several rare plant species including the nationally rare Jersey Cudweed. Issues 40 and 41 – community orchards.
air quality and contaminated land.
. The provision and maintenance of adequate. Promoting Successful Communities As with all development. are minimised. GI and landscape. This should be multi-functional and contribute to the targets/projects identified in the Cambridgeshire GI Strategy wherever possible. This should include green infrastructure and open spaces provision which may be required to help divert additional recreational pressure away from more sensitive sites. We welcome additional open space allocations where these contribute to the GI Strategy and provide multi-functional benefits. 12. We would advocate Natural England’s ANGSt standards in relation to open space provision – see comments on GI above. We would welcome a policy to ensure that aviation development at Cambridge Airport is only permitted where it will not have a significant adverse effect on the natural environment. policies should require full consideration of impacts on the natural environment. Site Specific Issues Issue 111: Papworth Everard Hospital Site – this site lies directly adjacent to Papworth Wood SSSI hence we have concerns that development could have an adverse effect on the special interest features of this nationally important woodland. adoption and maintenance in the longterm – again we would advice that this relates specifically to GI provision and related services such as SUDS as this is essential to secure long-term benefits. hence any proposals will need to be subject to detailed assessment to identify impacts and mitigation requirements. We would welcome a specific requirement for the provision of allotments given the multi-functional benefits they offer. Development is likely to require long-term measures to ensure access can be effectively managed/controlled.11. well-designed GI as part of new development should itself be a requirement. The Issues and Options Report does not appear to mention this issue. We welcome the principle of management and maintenance to ensure robust and effective implementation. noise. Natural England would welcome policies to require that the adverse effects of pollution through development. Development could result in increased access to the wood which could be damaging to the interest features. We therefore generally welcome the policy proposals put forward. Promoting and Delivering Sustainable Transport Infrastructure The SA identifies that the options relating to promoting and delivering sustainable transport and infrastructure are likely to contribute positively to sustainability issues. . Issue 82: Developing New Communities – we would strongly welcome a policy which identifies a requirement to ensure non-vehicular access is promoted for people to access services including GI. would be welcomed. including light. ahead of development. Allocations for Rail Freight Interchanges should only include those sites where it can be demonstrated that there will be no adverse effects on the natural environment. Specific requirements should include promotion of non-vehicular access to strategic GI and the wider countryside. including biodiversity. A policy to require provision of appropriate infrastructure and services. 13.
Habitats Regulations Assessment We are satisfied with the conclusion of the initial assessment which suggests no significant effects are likely as a result of the issues and options identified. We welcome acknowledgement that the Council will need to continue to work with stakeholders. Cambridge Water. although in light of our comments above. please contact me using the details below. Anglian Water. For all other correspondence. bridleways and National Trails. please contact the address above. The SA objectives being considered seem appropriate. We have reviewed this assessment alongside the Issues and Options Report and our only other comments are referred to above. Development should seek to protect and enhance designated paths as far as possible. and the Environment Agency. to ensure options selected can be appropriately served by water and waste water infrastructure. We note that a further screening assessment will be carried out at the draft plan stage. For any correspondence or queries relating to this consultation only. social and economic objectives. assessment and recommendations in the report generally meet the requirements of the SEA Regulations in assessing the effects of the Plan on environmental. Sustainability Appraisal We believe the methodology. alone or in combination with other plans. with reference to the local ROWIP. Yours sincerely Janet Nuttall CEnv MIEEM Planning and Conservation Advisor Land Use Operations Cambridge
. further clarification of impacts on issues such as public rights of way may be required.Other comments The Plan should address the need to protect and enhance designated rights of way such as PRoW. and we believe the Local Plan should address this in order to comply with paragraph 75 of the NPPF.