Question 8. How should the Local Plan help us achieve net zero carbon by 2050?

5.4 The increased focus on climate change is welcomed. Climate change policy and good practice is changing quickly, and the plan will need to build in suitable flexibility to accommodate these changes within the lifetime of the new Local Plan. Climate change scenarios predict extensive changes by 2050, much of which is dependent on government and human action so there is substantial uncertainty over outcomes. 5.5 A needlessly stringent policy may inadvertently impede progress towards later years in the plan, or undermine results by not allowing for site-specific refinement. Energy policies should include flexibility for changing legislation, and technology, as well as the opportunity to refine a plan-wide policy for site specifics. As the Zero Carbon Futures Symposium Report (2019) submitted within the evidence base notes on page 10: where targets are too limited, and without consideration of project contexts, policy can drive dysfunctional behaviour such as photovoltaic solar panels being installed on North facing roofs merely to achieve policy compliance not to produce effective carbon reductions. 5.6 If the new Local Plan is to achieve its ambitious targets on climate change, the Councils should consider new ways of achieving net zero. It should recognise that seeking to achieve net zero on all sites regardless of their location and site-specific factors may not be feasible. Linked initiatives such as an offsetting scheme, secured through S106 financial contributions, could be an appropriate way of achieving net zero for small and medium developments. As recognised in the NPPF, small and medium developments, with their ability to be delivered early in the plan period at pace, will play an important role in meeting the Councils housing requirements and the needs of existing villages. Such sites may best secure net zero by contributing to an offsite initiative as well as minimising their own carbon dioxide emissions. This can be done through measures such as high insulation standards and the use of solar panels. 5.7 If an offsetting scheme is the preferred mechanism, then the Councils will need to set out a clear, appropriate and practical way to implement this, which will mean identifying strategic off-setting projects with Greater Cambridge, and potentially beyond, in collaboration with other key stakeholders. Any financial obligations towards an offsetting scheme will need to meet the statutory tests and considered in the context of viability. 5.8 Allowing for changing technologies and approaches should also help with viability as technology and approaches improve and are more widely adopted, thereby reducing costs. Escalating targets and policies may be able to accommodate these changes, while providing clarity to developers on the costs of development over time. 5.9 The local plan Sustainability Appraisal (SA) should address variable climate change scenarios, as we would expect that different climate change scenarios will be of interest at examination. Lack of rigorous assessment of these scenarios in the SA could lead to the plan being found unsound.

Southern & regional Developments (Cottenham) believe that achieving net zero carbon emissions as an objective of the plan is an ambitious goal which does comply with paragraph 16a of the National Planning Policy Framework's assertion that Plan-making should be ambitious. However, the NPPF also stresses that with this aspiration, Plan-making should be deliverable. Given the cost and complexities involved in achieving such a target, Southern & Regional Developments (Cottenham) consider that this is not a realistic objective over the life time of the Plan alone, particularly given the proposed timeframe that is until 2040, not 2050. Whilst the Plan should incorporate aspirational efforts in realising a net zero carbon Plan area, these efforts should not be to the detriment to the existing communities with Plan area and not to the other aspects of the Plan in ensuring sustainable development is achieved. As such, the requisite levels of development must be planned for and implemented to meet the needs of the Plan area. This includes a primary objective of the new Plan in ensuring that adequate levels of housing and employment land are implemented to meet the needs of the new Plan period. This may be jeopardised if the Plan inappropriately places emphasis on achieving net zero carbon emissions beyond the plan period, when infrastructure is to be delivered and standards beyond national requirements may give rise to issues of viability and deliverability if restrictive planning policies relating to this objective are applied. Summary of Comments: This objective must ensure that it is deliverable and does not prevent the Plan from engaging with its other requirements, such as housing delivery.

5.4 The proposed housing at Land to the north of Main Street, Shudy Camps, provides residents with low-carbon futures. It is an opportunity to work towards achieving the goal of net zero carbon by 2050. These houses would be designed and constructed in a manner to ensure that energy use is reduced and that renewable forms are used. The site is also located in a sustainable location, where residents would not be reliant on the private car for their daily needs. 5.5 The local plan Sustainability Appraisal (SA) will address various climate change scenarios. We expect different climate change scenarios will be an important part of the examination. 5.6 We aim to work assiduously to ensure the carbon footprint of development at the site is optimised. For instance, we envisage including electric vehicle (EV) charging points as the electricity network develops; photovoltaic cells, well insulated dwellings and sustainable heating systems to enable residents to live comfortably and with minimal environmental impact.

5.4 The increased focus on climate change is welcomed. Climate change policy and good practice is changing quickly, and the plan will need to build in suitable flexibility to accommodate these changes within the lifetime of the plan. Climate change scenarios predict extensive changes by 2050, much of which is dependent on government and human action so there is substantial uncertainty over outcomes. 5.5 A needlessly stringent policy may inadvertently impede progress towards later years in the plan or undermine results by not allowing for site-specific refinement. For example, policy for electric vehicle charging points should be sufficiently flexible to accommodate that quickly changing technology, as well the current grid challenges in implemented EV charging places. Energy policies should include flexibility for changing legislation, and technology, as well as the opportunity to refine a plan-wide policy for site specifics. As the Zero Carbon Futures Symposium Report (2019) submitted within the evidence base notes on page 10: where targets are too limited, and without consideration of project contexts, policy can drive dysfunctional behaviour such as photovoltaic solar panels being installed on north facing roofs merely to achieve policy compliance not to produce effective carbon reductions. 5.6 Allowing for changing technologies and approaches should also help with viability as technology and approaches improve and are more widely adopted, thereby reducing costs. Escalating targets and policies may be able to accommodate these changes, while providing clarity to developers on the costs of development over time. 5.7 The local plan sustainability appraisal should address variable climate change scenarios, as we would expect that different climate change scenarios will be of interest at examination. Lack of rigorous assessment of these scenarios in the SA could lead to the plan being found unsound. 5.8 Land to the west of Mill Street, Gamlingay is considered to present an opportunity to contribute to successfully achieving the goal of net zero carbon by 2050 through the delivery of housing which would allow future residents to live low-carbon lifestyles. Houses would be designed and constructed in a manner to ensure that energy use is reduced and that renewable forms are used. The site is also located in a sustainable location, whereby future residents would not be reliant on the private car for their daily needs. Gamlingay is one of the largest villages in the District and has a wide range of services and facilities which are within walking and cycling distance of the site and the proposals look to enhance pedestrian connectivity into the village.

Achieving net zero carbon emissions as an objective of the plan is an ambitious goal which directly complies with paragraph 16a of the National Planning Policy Framework assertion that Plan-making should be ambitious. Southern and Regional Developments (Willingham) aspire to meet this approach but that it should not impact upon the Plan-making process, which should ensure the resulting policy approach is deliverable. Given the cost and complexities involved in achieving such a target, it is considered that this is not a realistic objective at this time and caveats are required to be included within any related policy that reflects this position. Whilst the Plan can incorporate aspirational efforts in realising a net zero carbon Plan area, this should not be to the detriment to the other aspects of the Plan in ensuring that the requisite levels of development are implemented to meet the needs of the Plan area. This includes a primary objective of the new Plan in ensuring that adequate levels of housing and employment land is implemented to meet the needs of the new Plan period. This may be jeopardised if the Plan inappropriately places emphasis on achieving net zero carbon emissions given issues of viability and deliverability which may arise if such restrictive planning policies relating to this objective are applied in reality. Summary of Comments: This objective must ensure that it is deliverable and does not prevent the Plan from engaging with its other requirements, such as housing delivery.

The increased focus on climate change is welcomed. Reducing the Greater Cambridge area’s contribution to climate change, through mitigating impacts on climate change, will require promoting energy efficiency, renewable and low carbon energy generation and encouraging use of sustainable transport. Only development at scale will support the creation of new on-site infrastructure, such as schools and local centres, which could reduce the need for people to travel elsewhere to find these amenities. The proposal for a new community at Six Mile Bottom would be able to incorporate low-carbon and energy efficient design, such as district heating networks. Importantly, the proposal at Six Mile Bottom would provide an integrated and holistic new community, reducing the need to travel for work and for services. Location along a public transport corridor will facilitate the use of public transport for longer distance travel. The potential to provide a new station differentiates Six Mile Bottom from other options in the sub-region The Government has published a challenging timetable for dealing with energy emissions for buildings through the Building Regulations. That includes proposals that local plans should not set energy standards ahead of the Building Regulations. We agree with the government’s proposed approach on this matter. The local plan should focus on locating development in sustainable locations, the layout of development and ensuring that allocations are made where they can deliver low/zero carbon developments. If the Plan is to achieve its ambitious targets on climate change, the most appropriate way to do this is through development of a scale to support the necessary infrastructure to achieve this. The local plan Sustainability Appraisal (SA) should address variable climate change scenarios, as we would expect that different climate change scenarios will be of interest at examination. Lack of rigorous assessment of these scenarios in the SA could lead to the plan being found unsound.

Achieving net zero carbon emissions as an objective of the plan is an ambitious goal which directly complies with paragraph 16a of the National Planning Policy Framework assertion that Plan-making should be ambitious. However, it also stresses that with this aspiration, Plan-making should be deliverable and given the cost and complexities involved in achieving such a target, it is considered that this is not a realistic objective. Whilst the Plan can incorporate aspirational efforts in realising a net zero carbon Plan area, this should not be to the detriment to the other aspects of the Plan in ensuring that the requisite levels of development are implemented to meet the needs of the Plan area. This includes a primary objective of the new Plan in ensuring that adequate levels of housing and employment land is implemented to meet the needs of the new Plan period. This may be jeopardised if the Plan inappropriately places emphasis on achieving net zero carbon emissions given issues of viability and deliverability which may arise if such restrictive planning policies relating to this objective are applied in reality. Summary of Comments: This objective must ensure that it is deliverable and does not prevent the Plan from engaging with its other requirements, such as housing delivery.

When framing their priorities the councils should be mindful that they are working within the parameters of the existing legislative and policy framework as it relates to plan-making. The councils’ broader aspirations should not undermine the key objective of appropriately defining and then meeting housing and other development needs through suitable and deliverable sites. Recognising the national housing shortage and the well-documented problems with affordability of homes Greater Cambridge, the councils should carefully consider the consequences of introducing planning policy burdens on new development recognising that the costs of these will ultimately be passed onto the consumer and reduce the ability of new development to viably mitigate its impact or deliver benefits in other areas (e.g. through affordable housing and infrastructure). The soundness of any future plan will turn on among other things its compliance with national planning policy. Paragraph 50, b) of the NPPF states that “Any local requirements for the sustainability of buildings should reflect the Government’s policy for national technical standards.” The Planning Practice Guidance (PPG) expands on this provision stating that policies requiring higher energy performance standards than building regulations “should not be used to set conditions on planning permissions with requirements above the equivalent of the energy requirement of Level 4 of the Code for Sustainable Homes (this is approximately 20% above the current Building Regulations across the build mix).” The ambitions of the plan around energy efficiency should be framed in light this guidance otherwise the resultant policies will not be sound for want of compliance with national policy. Finally, we would emphasise the need for any enhanced energy standards adopted as part of the local plan to incorporate appropriate allowances for viability and feasibility in line with paragraph 153 a) of the NPPF 2019.

We question whether high levels of growth are compatible with addressing climate change. The most effective way the Local Plan can help achieve net zero carbon is to limit growth to sustainable levels. As a society, until we are able to build and sustain carbon neutral communities, high levels of growth will result in higher levels of carbon and make it harder to achieve net zero carbon by 2050. • Building on greenfield sites or farmland will reduce the capacity for carbon sequestration and should thus be avoided. The loss of quality agricultural land means more food has to be imported into the UK, or more intensive farming techniques will need to be employed to make up the shortfall – both of which would increase carbon emissions. • The consultation emphasises the need for new development to be “carbon-neutral”. This can be misleading in that it implies some equality in carbon input in energy supply with carbon emissions. However, the creation and maintenance of a new development can have carbon consequences just as great as energy efficiency. What is needed is a Total Carbon Budget for a development, including the embedded carbon captured in materials, transport and construction emissions. All new developments should be required to provide a Circular Economy Statement as has recently been introduced to the London Plan, in order to address the embedded carbon within existing buildings and ensure that new buildings could be easily recycled in future. • Proposals for adaptation and retrofit of the existing building stock should also be on a “whole life” basis, minimising embedded carbon. The Local Plan’s 2040 horizon is 10 years beyond current Government Clean Growth Strategy targets for retrofitting dwellings to Band C. There are serious practical issues as well as major townscape implications involved in trying to meet these targets, plus skills and knowledge issues in relation to buildings of traditional construction (almost all pre-1919 buildings, and many between 1919 and 1939). There have been well-documented cases across the UK where well-intentioned but inappropriate measures have led to waste of money (and carbon). Balances need to be struck between short term measures and longer term “deep retrofits” (which may require costly undoing of previously installed measures. The Plan needs to take a strategic approach to these challenges. • Carbon sequestration will obviously be an important mitigation factor in Greater Cambridge yet it receives little consideration. Sequestration is more than just tree planting as there are other carbon sinks, like soil. Natural grassland is actually a better carbon sink than most forms of woodland because of the substantial below ground storage. • Electricity charging points for electric vehicles should be mandated for all new developments. Utility gas should not be installed in new developments. • New developments should be conceived so that residents can if they choose be car free. This involves consideration of the location of development, provision of services and infrastructure for walking, cycling and public transport. • For large developments either ground source, air source, or communal heating should be prioritised. • In the spatial planning of new developments, the Councils seem to feel that there is an inherent need to minimise the movement between jobs and homes so as to reduce vehicle emissions, but this is very difficult to resolve in a highly mobile society. Our view is that colocating housing and employment may be a useful theory in determining spatial planning but in practice it has relatively limited relevance. It may work in certain situations, such as in large new high-density mixed developments in the urban area, where employment uses would help to support community services such as shops. An example would be Cambridge North East Fringe or Cambridge Airport. However, research into the Cambridge Phenomenon found that workers change jobs regularly, but not their housing – this means that even if workers live close to their employer initially, over time they would commute elsewhere to work. Therefore, in our view, the availability of good public transport or cycle infrastructure is more important for determining new housing and employment locations. • Supporting working from home is one way that the need for travel can be reduced, and this can also support more vibrant communities. We would like to see policies in the Local Plan that encourage home working, for example new houses to be designed so that home offices can be created by occupants. • The Local Plan is constrained by national planning policy, guidance and regulations. It is clear that many of these are not capable of delivering net zero carbon by 2050. We believe that it would be politically difficult for national government to prevent a local authority from proposing local policies or targets that could achieve net zero carbon – even if they are not supported by national policy. We would encourage the councils to be brave and show leadership, and if necessary, challenge national government.

The key function of the Local Plan must be to ensure that jobs, housing and leisure are located in places that are accessible to people without having to rely on fossil fuel powered transport. The local plan must play its part in ensuring the highest standards of low or zero carbon and water efficient new buildings; supporting the provision of localised renewable energy networks, water supply and food production; minimising consumption and waste and maximising re-use and recycling. Providing space for nature and habitats (and not just tree planting) will also help to absorb carbon locally.

• One of the best ways the Local Plan can help us achieve net zero carbon by 2050 is by ensuring a rapid transition to sustainable transport. How and where we plan our new developments and integrate them with existing developments will be critical to enabling that transition at the scale we require. • Every development must prioritise walking, cycling and public transport over private cars (including electric cars). • Developments in Cambridge and the surrounding area should be required to plan for at least 40% of short/medium-distance trips to be taken by pedal cycle or electrically-assisted pedal cycle, comparable to role model cities in the Netherlands (Sutton, 2017). • New developments must be planned around dense walking and cycling networks and local transport hubs (not car-reliant park & rides). • Walking and cycling networks must be in place before dwellings are occupied. • New and existing developments should seek to minimise car usage, prevent rat-running, and keep neighbourhood streets compact to reduce their negative impact. • Housing should be on quiet neighbourhood streets that are good for cycling because they have very low levels of car traffic. • Schools should never be on major roads. • All employment, entertainment, shopping and community facilities should be easily accessed by cycling and have accessible cycle parking for all types of cycle. “If the EU cycling rate was the same as it is in Denmark, where the average person cycles almost 600 miles (965km) each year, then the bloc would attain anything from 12% to 26% of its targeted transport emissions reduction, depending on what forms of transport the cycling replaced.” (Walker, 2011) “[When] evaluating different transport modes, it is the bicycle that allows for important greenhouse gas savings. Although not a carbon free mode of transport, the bicycle’s [greenhouse gas] emissions are over 10 times lower than those stemming from individual motorized transport. pedelecs, despite their electric assistance, are also found to have greenhouse gas emissions in the same range as ordinary bicycles.” (Blondel, 2011) “Public transport, walking and cycling have a key role in tackling carbon emissions, as well as delivering the co-benefits of decarbonisation such as cleaner air and a healthier society.” (HM Government, 2019) “In 76 cities in the Netherlands (municipalities with more than 50,000 inhabitants), the inhabitants travel for trips up to 7.5 km more often by bicycle than by car. [...] At the larger distances, between 7.5 and 15 kilometers, the bicycle share of residents is still substantial. At longer regional distance, bicycles and e-bikes currently capture one-third of the bike/car mode split.” (te Avest, 2017) Evidence for our response to Question8. •Walker,Peter(2011).EU could cut its transport greenhouse gas emissions by more than 25% if every country’s cycling rate was the same as Denmark’s.The Guardian: Dec 12th, 2011. www.theguardian.com/environment/2011/dec/12/cycle-like-danes-cut-emissions •Benoît Blondel, et al (2011). Cycle more often to cool down the planet!. European Cyclists’ Federation. • HM Government (2019). Leading on Clean Growth: The Government Response to the Committee on Climate Change’s 2019 Progress Report to Parliament —Reducing UK emissions. • Sutton,Mark(2017). Netherlands further builds on cycling’s modal share, hitting 51% in Utrecht. cyclingindustry.news/netherlands-further-builds-on-cyclings-modal-share-hitting51-in-utrecht/ • te Avest, Richard (2017). Bicycle gains ground on car,also outside the big cities (translated). www.goudappel.nl/actueel/fietse-bike-verovert-terrein-op-auto-%C3%B3%C3%B3k-buitende-grote-steden/.

Require developments to be walking/cycling promoting, restrict car use, insist on matching infrastructure (especially public transport working through the days and evenings) and building design codes that demand sustainable developments. The required policies to be clear and not challengeable on appeal and above all enforce the requirements.

ECC recommends that priority be given to delivering sustainable transportation in determining the future spatial development approach throughout GCA. Attention should be given to delivering sustainable travel and transportation infrastructure (walking, cycling and public transport). It is recommended that development be future proofed to provide for autonomous vehicles and other innovations that may be accommodated in the future without major re-investment in infrastructure.

1.4 The Greater Cambridge area is consistently ranked as one of the best places to live in the UK with a strong economy that continues to outperform other cities. As a result of the continued job creation in the area Greater Cambridge experiences high levels of in-commuting due to years of persistent under-delivery of new homes. This has resulted in the city and surrounding villages becoming increasing unaffordable for people employed in the area and those who have grown up here. 1.5 The limitations to the existing rail network serving the city means that those who in-commute are increasingly reliant on private modes of transport that are predominantly powered by carbon-based fuels. The increasing number of these vehicles travelling through Cambridge and the outlying villages is creating environmental impacts at both the local and global level. Even with the promotion of electric vehicles, which rely on electricity from a heavily carbon-based national grid, the need to travel into the area will only be reduced once the supply of new homes increases in line with new jobs. 1.6 The key for the Greater Cambridge Local Plan is to plan positively for housing growth in areas where residents will have access to existing services and facilities and sustainable travel options to access employment and education whilst minimising the impact on local landscapes. Public transport is a good alternative to the private car but in many areas the service is not convenient enough for all residents. Therefore, by promoting sites that are within cycling distance of Cambridge, such as our clients’ site, residents will have greater control over their own travel and can choose sustainable modes to meet their daily needs

The housebuilding industry, through the HBF, recognises that there is a need to move towards stronger measures to improve the environmental performance of new residential development. This is in terms of reducing carbon emissions in new homes, providing gains in biodiversity on all developments, green infrastructure and improving the environment around new developments. However, the HBF, and our members, consider a national and standardised approach to improving such issues as the energy efficiency of buildings, the provision of renewable energy and the delivery of electric vehicle charging points to be the most effective approach that balances improvements with continued deliver of housing and infrastructure. It is the industry’s preference for a national approach to improving the environmental performance of residential developments, rather than local authorities setting their own standards. We consider this is necessary to allow research and development and supply chains to focus upon responding to agreed national targets, and for training providers to plan their programmes to equip the labour force to meet these new requirements. It is fundamentally inefficient to create a plurality of standards. The industry will clearly need to take into account the Government’s measures on the Future Homes Standard and Bio-Diversity Gain – both of which will be mandatory for new residential developments in 2020. In terms of these new regulatory targets applying to new development from 2025 onwards – to deliver the objectives of the Future Homes Standard – the industry, with the leadership of the HBF, will be commissioning work to consider what the industry can do, taking into account developments in research and product development within that time-frame, and what new standards can feasibly be adopted and implemented by the industry. Therefore, when considering their approach to such matters the councils should ensure that they are working within the current policy and legislative framework and not seeking to deliver a different range of standards that will work against the collective drive on this matter. The importance of a collective approach will also balance the cost of delivering the energy efficiency improvements required alongside other planning obligations and development aspirations that the Councils are seeking to deliver through the GCLP, such as meeting housing needs in full and improving the affordability of homes in this area. The Councils will therefore need consider the consequences of introducing planning policy burdens on new development recognising that the costs of these will ultimately be passed onto the consumer or leave some sites undeliverable. Prior to the future standards the Councils must take account of current guidance which sets out the approach that Councils should take with regard to technical standards relating to energy efficiency with paragraph 50 of the NPPF stating that: “Any local requirements for the sustainability of buildings should reflect the Government’s policy for national technical standards.” The Planning Practice Guidance (PPG) expands on this provision outlining that policies requiring higher energy performance standards than building regulations should not be used to set conditions on planning permissions with requirements above the equivalent of the energy requirement of Level 4 of the Code for Sustainable Homes. As such the aspirations of this plan with regard to improving the energy efficiency of new homes must be made within the context of this guidance if the plan is to be consistent with national policy and found sound.

1.4 The Greater Cambridge area is consistently ranked as one of the best places to live in the UK with a strong economy that continues to outperform other cities. As a result of the continued job creation in the area Greater Cambridge experiences high levels of in-commuting due to years of persistent under-delivery of new homes. This has resulted in the city and surrounding villages becoming increasing unaffordable for people employed in the area and those who have grown up here. 1.5 The limitations to the existing rail network serving the city means that those who in-commute are increasingly reliant on private modes of transport that are predominantly powered by carbon-based fuels. The increasing number of these vehicles travelling through Cambridge and the outlying villages is creating environmental impacts at both the local and global level. Even with the promotion of electric vehicles, which rely on electricity from a heavily carbon-based national grid, the need to travel into the area will only be reduced once the supply of new homes increases in line with new jobs. 1.6 The key for the Greater Cambridge Local Plan is to plan positively for housing growth in areas where residents will have access to existing services and facilities and sustainable travel options to access employment and education whilst minimising the impact on local landscapes. Public transport is a good alternative to the private car but in many areas the service is not convenient enough for all residents. Therefore, by promoting sites that are within cycling distance of Cambridge, such as Bennell Farm, residents will have greater control over their own travel and can choose sustainable modes to meet their daily needs

• I am amazed that the “Local plant first conversation” document has not mentioned peat restoration anywhere or ceasing farming on peatland. I was fascinated and horrified to read in the Cambridgeshire Net Zero report that when emissions from farming on peatland are taken into account Cambridgeshire's emissions almost double(!), see Figures 4.3 and 4.4. https://consultcambs.uk.engagementhq.com/3017/documents/3609 • One of the best ways the Local Plan can help us achieve net zero carbon by 2050 is by ensuring a rapid transition to sustainable transport. How and where we plan our new developments and integrate them with existing developments will be critical to enabling that transition at the scale we require. • Every development must prioritise walking, cycling and public transport over private cars (including electric cars). • Developments in Cambridge and the surrounding area should be required to plan for at least 40% of trips by bicycle. • New developments must be planned around dense walking and cycling networks and local transport hubs (not car-reliant park & rides). • Walking and cycling networks must be in place before dwellings are occupied. • New and existing developments should seek to minimise car usage, prevent rat-running, and keep neighbourhood streets compact to reduce their negative impact. • Housing should be on quiet neighbourhood streets that are good for cycling because they have very low levels of car traffic. • Schools should avoid being on major roads. • All employment, entertainment, shopping and community facilities should be easily accessed by cycling and have accessible cycle parking for all types of cycles.

The Issues and Options report correctly recognises that a key impact of reaching net zero carbon targets is the minimisation of vehicular movements. Section 4.1 identifies that we need to plan for alternatives to private car use. Public transport is not only more efficient, it reduces traffic queues (and therefore impacts positively on productivity), it is better for health and wellbeing*, and is socially inclusive as it allows equal mobility for those without access to a car (and for those who do not wish to own a car). There are two key factors that can assist in reducing car travel and increasing public transport: placing jobs, leisure facilities and shopping in close proximity to housing thereby reducing the need to travel and increasing ‘self-containment’; and providing new development in locations that provide alternatives to the private car – in particular good public transport services. A further requirement to reduce on the risk of Climate Change is to minimise the energy used to construct new development, and to power its running costs with over 40% of UK emissions arising from built property**. Whilst costs of achieving more sustainable buildings will be similar regardless of the location of development, there will be greater opportunity for carbon reduction to be achieved where development is at sufficient scale to allow for the efficient operation of combined heat and power and similar shared energy networks. * Transport planning for healthier lifestyles, see section 1.2 ** UK Green Building Council, 2019.

Lolworth Developments Ltd (LDL) has submitted a 100ha employment site proposal to the 'Call for Sites' consultation in March 2019. LDL has submitted further supporting evidence as to why the site is the best location to serve the area and the 'final mile' into Cambridge. See Strategic Case Report and Vision Document submitted under Q2. The increased focus on climate change is welcomed. Climate change policy and good practice is changing quickly, and the plan will need to build in suitable flexibility to accommodate these changes within the lifetime of the plan. Climate change scenarios predict extensive changes by 2050, much of which is dependent on government and human action so there is substantial uncertainty over outcomes. A needlessly stringent policy may inadvertently impede progress towards later years in the plan, or undermine results by not allowing for site-specific refinement. For example, policy for electric vehicle charging points should be sufficiently flexible to accommodate that quickly changing technology, as well the current grid challenges in implemented EV charging places. Energy policies should include flexibility for changing legislation, and technology, as well as the opportunity to refine a plan-wide policy for site specifics. As the Zero Carbon Futures Symposium Report (2019) submitted within the evidence base notes on page 10: where targets are too limited, and without consideration of project contexts, policy can drive dysfunctional behaviour such as photovoltaic solar panels being installed on North facing roofs merely to achieve policy compliance not to produce effective carbon reductions. Allowing for changing technologies and approaches should also help with viability as technology and approaches improve and are more widely adopted, thereby reducing costs. Escalating targets and policies may be able to accommodate these changes, while providing clarity to developers on the costs of development over time. The local plan Sustainability Appraisal (SA) should address variable climate change scenarios, as we would expect that different climate change scenarios will be of interest at examination. Lack of rigorous assessment of these scenarios in the SA could lead to the plan being found unsound. Summary of Comments: Please see summary above. Summary The increased focus on climate change is welcomed. Climate change policy and good practice is changing quickly, and the plan will need to build in suitable flexibility to accommodate these changes within the lifetime of the plan. Climate change scenarios predict extensive changes by 2050, much of which is dependent on government and human action so there is substantial uncertainty over outcomes.

Thakeham is of the view that the Local Plan should focus on delivering growth across the District, in order to provide new sustainable transport links, new homes, including affordable homes, and new employment opportunities which link to and sustain existing and new settlements. The provision of new sustainable transport links and flexible employment spaces in settlements will reduce the reliance on travel across the wider district, especially by private car. Thakeham also urge the Councils’ to review potential allocation sites based on the credentials of the developer, and work with environmentally focused developers like Thakeham to deliver high quality, sustainable developments. Thakeham are forerunners in creating sustainable communities and have committed that from 2025, every Thakeham home will be zero carbon in its lifetime use. In addition, we have committed to reducing carbon from the production of every Thakeham home, mitigating any remaining impact through offsetting schemes. As a business, we have committed to being zero carbon by 2025, and are well on the way to achieving this. Thakeham believes in a proactive approach and as a result of our commitments we are streets ahead of other developers in the industry and are demonstrating a capacity to change the future of UK new housing, 25 years ahead of current UK Government targets.

Lolworth Developments Ltd (LDL) has submitted a 100ha employment site proposal to the 'Call for Sites' consultation in March 2019. LDL has submitted further supporting evidence as to why the site is the best location to serve the area and the 'final mile' into Cambridge. See Strategic Case Report and Vision Document submitted under Q2. The increased focus on climate change is welcomed. Climate change policy and good practice is changing quickly, and the plan will need to build in suitable flexibility to accommodate these changes within the lifetime of the plan. Climate change scenarios predict extensive changes by 2050, much of which is dependent on government and human action so there is substantial uncertainty over outcomes. A needlessly stringent policy may inadvertently impede progress towards later years in the plan, or undermine results by not allowing for site-specific refinement. For example, policy for electric vehicle charging points should be sufficiently flexible to accommodate that quickly changing technology, as well the current grid challenges in implemented EV charging places. Energy policies should include flexibility for changing legislation, and technology, as well as the opportunity to refine a plan-wide policy for site specifics. As the Zero Carbon Futures Symposium Report (2019) submitted within the evidence base notes on page 10: where targets are too limited, and without consideration of project contexts, policy can drive dysfunctional behaviour such as photovoltaic solar panels being installed on North facing roofs merely to achieve policy compliance not to produce effective carbon reductions. Allowing for changing technologies and approaches should also help with viability as technology and approaches improve and are more widely adopted, thereby reducing costs. Escalating targets and policies may be able to accommodate these changes, while providing clarity to developers on the costs of development over time. The local plan Sustainability Appraisal (SA) should address variable climate change scenarios, as we would expect that different climate change scenarios will be of interest at examination. Lack of rigorous assessment of these scenarios in the SA could lead to the plan being found unsound. Summary The increased focus on climate change is welcomed. Climate change policy and good practice is changing quickly, and the plan will need to build in suitable flexibility to accommodate these changes within the lifetime of the plan. Climate change scenarios predict extensive changes by 2050, much of which is dependent on government and human action so there is substantial uncertainty over outcomes. Summary of Comments: Please see summary above

Ensure developments maximise energy conservation initiatives, dwellings have the highest standards of energy conservation and recycling (water, etc). Introduce subsidised electric cycle provision in larger developments. Use local waste to generate power locally via a contained system that does away with refuse lorries. Promote electric powered public transport. Negotiate affordable public transport fares. Encourage car sharing schemes. For larger developments, have a transport strategy that considers minimalising the journeys of developer’s plant. Identify areas suitable for PV panels, wind turbines and hedge/tree planting. Promote charging points. Encourage schools to address climate change, energy conservation and recycling issues. Take a holistic view of the Local Plan, not a piecemeal approach. How do developments impact the whole region? How do they impact each other? Encourage everyone to recognise how climate change affects them individually and what they can do personally to mitigate it. In liaison with other bodies, encourage healthy communities – physical exercise, social interaction, communal events, peaceful places, intergenerational befriending and general befriending schemes. Ensure communities are designed to be people friendly, dementia friendly and take account of disabled people’s needs.

The increased focus on climate change is welcomed. Climate change policy and good practice is changing quickly, and the plan will need to build in suitable flexibility to accommodate these changes within the lifetime of the plan. Climate change scenarios predict extensive changes by 2050, much of which is dependent on government and human action so there is substantial uncertainty over outcomes. Greater Cambridge - Regulation 18 Consultation – Land off Beach Road, Cottenham Page 4 A needlessly stringent policy may inadvertently impede progress towards later years in the plan or undermine results by not allowing for site-specific refinement. For example, policy for electric vehicle charging points should be sufficiently flexible to accommodate that quickly changing technology, as well the current grid challenges in implemented EV charging places. Energy policies should include flexibility for changing legislation, and technology, as well as the opportunity to refine a plan-wide policy for site specifics. As the Zero Carbon Futures Symposium Report (2019) submitted within the evidence base notes on page 10: where targets are too limited, and without consideration of project contexts, policy can drive dysfunctional behaviour such as photovoltaic solar panels being installed on North facing roofs merely to achieve policy compliance not to produce effective carbon reductions. The local plan sustainability appraisal should address variable climate change scenarios, as we would expect that different climate changes scenarios will be of interest at examination. Lack of rigorous assessment of these scenarios in the SA is could lead to the plan being found unsound. Land off Beach Road, Cottenham is considered to present an opportunity to contribute to successfully achieving the goal of net zero carbon by 2050 through the delivery of housing which would allow future residents to live low-carbon lifestyles. Houses would be designed and constructed in a manner to ensure that energy use is reduced and that renewable forms are used. The site is also located in a sustainable location, whereby future residents would not be reliant on the private car for their daily needs. Cottenham is one of the largest villages in the District and has a wide range of services and facilities, which are within walking and cycling distance of the site.

Achieving net zero carbon emissions as an objective of the plan is an ambitious goal which directly complies with paragraph 16a of the National Planning Policy Framework assertion that Plan-making should be ambitious. However, it also stresses that with this aspiration, Plan-making should be deliverable and given the cost and complexities involved in achieving such a target, Southern & Regional Developments (Swavesey) consider that this is not a realistic objective at this time. Whilst the Plan can incorporate aspirational efforts in realising a net zero carbon Plan area, this should not be to the detriment to the other aspects of the Plan in ensuring that the requisite levels of development are implemented to meet the needs of the Plan area. This includes a primary objective of the new Plan in ensuring that adequate levels of housing and employment land is implemented to meet the needs of the new Plan period. This may be jeopardised if the Plan inappropriately places emphasis on achieving net zero carbon emissions given issues of viability and deliverability which may arise if such restrictive planning policies relating to this objective are applied in reality. Summary of Comments: This objective must ensure that it is deliverable and does not prevent the Plan from engaging with its other requirements, such as housing delivery.

4.23 The Local Plan will play a key part in achieving net zero carbon by 2050. Newlands Developments welcomes the 2050 target, and are already taking steps towards net zero carbon including the design and construction of highly insulated building envelopes with air tightness values well beyond those required by building regulations, installation of solar photovoltaics and highly efficient all electric heating strategies. 4.24 The details which underpin emerging zero carbon policy will be critical to ensure that aims are achievable and that development viability is not impacted. Rather than Greater Cambridge developing their own standard around net zero buildings, it would make sense to apply a recognised standard applied elsewhere in the UK, for example the UK Green Building Council’s Net Zero Carbon Buildings Framework (April 2019) and RIBA’s Sustainable Outcomes Guide (2019). This will help promote a common understanding across project teams and ensure that knowledge from projects elsewhere is relevant and directly applicable to those in Greater Cambridge in terms of what does and does not work as well as helping avoid the situation where national operators such as Newlands Developments are required to respond to varying standards across their estate. 4.25 Whilst the UKGBC Net Zero Framework covers both construction and operational carbon, it is the latter from new development which relates principally to the net zero target. This is due to the significant current challenges of designing for low carbon construction. It is recommended that the approach set out for construction carbon in the new London Plan Policy SI2 Minimising Greenhouse Gas Emissions should be adopted. This policy requires an assessment of construction carbon together with a description of actions taken to reduce these emissions, however it does not require net zero construction i.e. the offsetting of residual construction carbon following any reduction measures. 4.26 RIBA recognises the challenges presented by achieving net zero carbon, particularly for construction emissions, and has developed a series of climate change metrics for new buildings (covering operational energy, embodied carbon and potable water use) with targets for 2020, 2025 and 2030 that go increasingly beyond current performance to ensure that net zero carbon deadlines are met. This approach intends to help ensure the goal of net zero is achieved in a manner that recognises potentially significant technical and commercial implications to be addressed over this timeframe. 4.27 The ambition for net zero operational development requires building design that accords with the ‘energy hierarchy’ (by prioritising a “fabric first” approach) which is the most cost-effective means of driving down operational energy and carbon. It must be recognised however that such an approach is unlikely to achieve net zero in full. Therefore it is recommended that a minimum on-site CO2 reduction target of 35% below Building Regulations 2013 Part L is set through the application of the energy hierarchy. This target aligns with the London Plan which requires residual CO2 emissions up to zero carbon to be addressed via s106 contribution to that Local Planning Authority’s carbon offset fund. This arrangement makes it difficult or impossible to understand how these funds are invested and therefore Newlands Developments’ view is that Greater Cambridge’s zero carbon policy should provide the option for greater control by developers in relation to carbon offsetting, whether in part or in full, as long as such measures are of suitably high quality to address important considerations relating to offsetting. This approach will help address potential viability concerns associated with offsetting and help maximise the amount of offsetting that can be achieved for a given sum of money whilst maintaining offset quality and climate benefit. 4.28 Encouraging all-electric heating strategies within the Local Plan will allow development to connect to the national grid which is rapidly decarbonising, removing the reliance on natural gas which cannot currently be fully decarbonised. Electricity can also be purchased via Power Purchase Agreements (PPAs) or Renewable Energy Guarantees Origin (REGO) certificates which guarantee that an equivalent amount of electricity was produced from 100% renewable sources. 4.29 It should be noted that BREEAM does not recognise this route to net zero carbon within its Energy Section. For example, a building which offsets 35% carbon emissions using on-site renewables may not meet the mandatory number of credits within Ene 01 for an Excellent rating if the primary energy demand and/or heating and cooling demand is only a slight improvement over the notional. Including targets such as ‘mandatory number of credits for Excellent’ or ‘Outstanding’ should not be encouraged within the Local Plan as this can negatively impact the goal to achieve net zero carbon. 4.30 In summary, Newlands Developments supports the growing need to evaluate and seek to reduce construction carbon to contribute to Greater Cambridge’s net zero aspirations and use RIBA’s embodied carbon targets to help inform building design and construction however any proposal to achieve net zero construction must be subject to viability assessment.

Yes, strongly agree. In designing new development there is an opportunity to secure high standards for climate adaptation and resilience features. Historic England is broadly supportive of the goal to achieve net zero carbon by 2020. A sustainable approach should secure a balance between the benefits that such development delivers and the environmental costs it incurs. The policy should seek to limit and mitigate any such cost to the historic environment. We invite a specific policy relating to the inclusion of renewable technologies within Conservation Areas and with regard to historic buildings and the wider historic landscape. Listed buildings, buildings in conservation areas and scheduled monuments are exempted from the need to comply with energy efficiency requirements of the Building Regulations where compliance would unacceptably alter their character and appearance. Special considerations under Part L are also given to locally listed buildings, buildings of architectural and historic interest within registered parks and gardens and the curtilages of scheduled monuments, and buildings of traditional construction with permeable fabric that both absorbs and readily allows the evaporation of moisture. In developing policy covering this area you may find the Historic England guidance Energy Efficiency and Historic Buildings – Application of Part L of the Building Regulations to historically and traditionally constructed buildings https://content.historicengland.org.uk/images-books/publications/energy-efficiencyhistoric-buildings-ptl/heag014-energy-efficiency-partlL.pdf/ to be helpful in understanding these special considerations. We invite a specific policy relating to the inclusion of renewable technologies within Conservation Areas and with regard to historic buildings and the wider historic landscape. A sustainable approach should secure a balance between the benefits that such development delivers and the environmental costs it incurs. The policy should seek to limit and mitigate any such cost to the historic environment. Listed buildings, buildings in conservation areas and scheduled monuments are exempted from the need to comply with energy efficiency requirements of the Building Regulations where compliance would unacceptably alter their character and appearance. Special considerations under Part L are also given to locally listed buildings, buildings of architectural and historic interest within registered parks and gardens and the curtilages of scheduled monuments, and buildings of traditional construction with permeable fabric that both absorbs and readily allows the evaporation of moisture. In developing policy covering this area you may find the Historic England guidance Energy Efficiency and Historic Buildings – Application of Part L of the Building Regulations to historically and traditionally constructed buildings https://content.historicengland.org.uk/images-books/publications/energy-efficiencyhistoric-buildings-ptl/heag014-energy-efficiency-partlL.pdf/ to be helpful in understanding these special considerations.

All new developments should be required to provide a Circular Economy Statement as has recently been introduced to the London Plan, in order to address the embedded carbon within existing buildings and ensure that new buildings could be easily recycled in future. Whole life carbon is a key issue for retrofits as well as new buildings, and repairs, e.g. using cement mortar prevents re-use of carbon-intensive fired and quarried materials. A circular economy approach should be encouraged in all cases, with whole-life audits for retrofit projects as per BS EN 15978:2011. The Local Plan’s 2040 horizon is 10 years beyond current Government Clean Growth Strategy targets for retrofitting dwellings to Band C. There are serious practical issues as well as major townscape implications involved in trying to meet these targets, plus skills and knowledge issues in relation to buildings of traditional construction (almost all pre-1919 buildings, and many between 1919 and 1939). There have been well-documented cases across the UK where well-intentioned but inappropriate measures have led to waste of money (and carbon). The 2030 targets involve very significant risks: balances need to be struck between short term measures and longer term “deep retrofits” (which may require costly undoing of previously installed measures). The additional 10 years in the Local Plan’s horizon should allow planning over a timescale which could enable a thorough strategic assessment of the issues, followed by delivery of knowledge and skills and capacity-building on the scale needed in time for a programme, at scale, to meet the Statutory 2050 targets.

Please refer to the Sustainability Vision Statement which seeks out opportunities to bring the big themes to life in every aspect of the project.

European Property Venures (Cambridgeshire) believe that achieving net zero carbon emissions as an objective of the plan is an ambitious goal which does comply with paragraph 16a of the National Planning Policy Framework's assertion that Plan-making should be ambitious. However, the NPPF also stresses that with this aspiration, Plan-making should be deliverable. Given the cost and complexities involved in achieving such a target, European Property ventures (Cambridge) consider that this is not a realistic objective over the lif time of the Plan alone, particulalry given the proposed timeframe that is until 2040, not 2050. Whilst the Plan should incorporate aspirational efforts in realising a net zero carbon Plan area, these efforts should not be to the detriment to the existing communities with Plan area and not to the other aspects of the Plan in ensuring sustainable development is achieved. As such, the requisite levels of development must be planned for and implemented to meet the needs of the Plan area. This includes a primary objective of the new Plan in ensuring that adequate levels of housing and employment land are implemented to meet the needs of the new Plan period. This may be jeopardised if the Plan inappropriately places emphasis on achieving net zero carbon emissions beyond the plan period, when infrastrcuture is to be delivered and standards beyond national requirements may give rise to issues of viability and deliverability if restrictive planning policies relating to this objective are applied. Summary of Comments: This objective must ensure that it is deliverable and does not prevent the Plan from engaging with its other requirements, such as housing delivery.

5.5 The increased focus on climate change is welcomed. Climate change policy and good practice is changing quickly, and the plan will need to build in suitable flexibility to accommodate these changes within the lifetime of the plan. Climate change scenarios predict extensive changes by 2050, much of which is dependent on government and human action so there is substantial uncertainty over outcomes. 5.6 A needlessly stringent policy may inadvertently impede progress towards later years in the plan, or undermine results by not allowing for site-specific refinement. For example, policy for electric vehicle charging points should be sufficiently flexible to accommodate that quickly changing technology, as well the current grid challenges in implemented EV charging places. Energy policies should include flexibility for changing legislation, and technology, as well as the opportunity to refine a plan-wide policy for site specifics. As the Zero Carbon Futures Symposium Report (2019) submitted within the evidence base notes on page 10: where targets are too limited, and without consideration of project contexts, policy can drive dysfunctional behaviour such as photovoltaic solar panels being installed on North facing roofs merely to achieve policy compliance not to produce effective carbon reductions. 5.7 Allowing for changing technologies and approaches should also help with viability as technology and approaches improve and are more widely adopted, thereby reducing costs. Escalating targets and policies may be able to accommodate these changes, while providing clarity to developers on the costs of development over time. 5.8 The local plan Sustainability Appraisal (SA) should address variable climate change scenarios, as we would expect that different climate change scenarios will be of interest at examination. Lack of rigorous assessment of these scenarios in the SA could lead to the plan being found unsound. 5.9 The site is considered to present an opportunity to contribute to successfully achieving the goal of net zero carbon by 2050 through the delivery of housing/buildings which would allow future residents or employees to live low-carbon lifestyles. Buildings would be designed and constructed in a manner to ensure that energy use is reduced and that renewable forms are used. The site is also located in a sustainable location, whereby future users would not be reliant on the private car for their daily needs. Nearby facilities and services are within walking and cycling distance of the site and the proposals look to enhance pedestrian connectivity.