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

Housebuilding and commercial building on farm land should be halted or reduced to an absolute minimum. Re-use of existing buildings and proper brownfield sites (not old airfields that are mostly grassland bisected by a few strips of concrete) should be maximised, Central government should be pressed to maximise regeneration, particularly in the Midlands and the North. There should be no new major road building. More attention should be paid to the provision/retention of suitable employment space in local communities to reduce the need for commuting and to prevent rural communities becoming dormitories. High speed broadband should be a priority to encourage home or village working. More consideration must be given to the provision and operation of public transport. Housing density in the City and major developments outside should be high. Ensure that known empty dwellings in the City and District are identified and indexed. If empty for a certain period, the owners should be invited to ensure occupation or the local authorities should have the power to compulsory purchase the properties to renovate them and rent to those on the housing list or offer for sale. CPRE recommends that more research and development is carried out into the environmental capacity of the plan area to determine its ability to accommodate any further growth taking into account the effects on wildlife, bio-diversity, tranquillity, climate change, adaptation, national food supply, flood risk, water supply, actual sustainability and pressure on infrastructure.

4.5 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. 4.6 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. 4.7 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. 4.8 The local plan Sustainability Appraisal (SA) 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. 4.9 Kett House and 10 Station Road is a brownfield site in a highly sustainable location with access to key transport links including the train station (which is 300 metres east of the site), the Chisholm trail link and numerous other public transport connections including local bus services and the proposed metro connections. The proposed commercial-led development on the site, in a highly desirable location for commercial development offers real opportunities to deliver low carbon, or even net zero carbon development due to the high value of the area.

We support the Councils’ recognition of the severity of the climate change issue and recognition of the key issues and challenges of reducing our climate impact and the need to adapt to more extreme weather, a hotter climate and a changing ecology. We support key actions to address climate change including:  Using renewable and low carbon energy generation;  Promoting sustainable travel and discouraging car use where possible;  Retrofitting existing buildings;  Rooftop greening – this could be extended to generally extending and enhancing the ecological network We generally support the promotion of climate change adaptation measures including:  Managing flood risk and incorporating SUDS;  Increasing biodiversity and tree planting;  Improving water efficiency. The Plan should prioritise avoiding key factors contributing to climate change (through more greenhouse gases) e.g. pollution, habitat fragmentation, loss of biodiversity and to protecting and enhancing the natural environment’s resilience to change. Green Infrastructure and resilient ecological networks play an important role in aiding climate change adaptation. Development should be located and designed to remove/reduce reliance on car travel, promoting sustainable travel to improve air quality and its contribution to climate change. Development should incorporate multi-functional sustainable drainage and flood risk management measures in accordance with the SPD. Plan policies should focus on securing implementation of an enhanced and extended ecological network that will deliver climate change mitigation in addition to wider environmental services. This should be delivered through appropriate policy requirements. We are aware that an Integrated Water Management Study, incorporating a Water Cycle Study and Strategic Flood Risk Assessment, is being progressed as a key evidence document to inform preparation of the Local Plan. We welcome this and urge for a strong focus /recommendation for the implementation of integrated drainage including multi-functional SUDs in all development, where possible. It should also identify and promote delivery of benefits and opportunities associated with climate change, for example to create more extensive wetland habitats and to protect and enhance the degraded peat soils remaining in the Greater Cambridge area. Without appropriate measures new development will harm Greater Cambridge’s natural natural Page 3 of 15 environment. Measures to avoid impacts must be prioritised. Cambridgeshire is especially dependent on its groundwater which is currently being pumped dry with knock-on effects for the natural environment including water quality and biodiversity. In addition to new buildings climate change requires retrofitting of existing buildings. Revised and more ambitious water consumption targets are also needed. The Plan should include appropriate policies to secure delivery of the recommendations identified through the Integrated Water Study. We would also advise that consideration be given to updating the existing Flood and Water Supplementary Planning Document to reflect current BNG and climate / net zero carbon targets. The Local Plan and relevant policies should reflect the importance of remaining peat soils as a significant carbon store that can help to improve air quality and mitigate against climate change. The development strategy and relevant policies should seek to protect Best and Most Versatile Land, including peat soils, and contribute towards enhancement of degraded peat to deliver a wide range of environmental services including biodiversity, open space, flood risk and drainage benefits, in addition to helping to mitigate climate change. With regard to tree planting for carbon offsetting Natural England advises that planting of trees needs to be considered in the context of wider plans for nature recovery. Tree planting should only be carried out in appropriate locations, taking into consideration potential impacts on existing ecology and the opportunities to create alternative habitats that could deliver better enhancements for people and wildlife, and also store carbon effectively. Where woodland habitat creation is appropriate, consideration should be given to natural regeneration for the economic and ecological benefits this can achieve. Any tree planting should use native and local provenance tree species suitable for the location. Natural England advocates an approach which seeks to increase biodiversity and green infrastructure generally, not simply planting of trees, and protecting / enhancing soils, particularly peat soils.

- Consider carbon offsetting by increased tree cover in other parts of UK and not focus too much on planting within the county and also recognise any carbon management that takes place within existing gardens and agricultural land - Decarbonisation is picked up in answers to questions on housing and transport.

4.4 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. 4.5 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. 4.6 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. 4.7 The local plan Sustainability Appraisal (SA) 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 could lead to the plan being found unsound.

4.5 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. 4.6 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. 4.7 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. 4.8 The local plan Sustainability Appraisal (SA) 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 could lead to the plan being found unsound.

Development Management Policies can be designed to support this commitment, building on the improvements to be gained through the changes to the Building Regulations and introducing other complementary policies for new buildings and their immediate environments. However, to create a step change to the key issue for Greater Cambridgeshire – transport impacts – this has to come from locating development in a different way to the existing local plan strategies that can truly deliver on the objectives of non-car travel whilst helping to improve the sustainability of the existing settlements and urban environments. We consider that there is an opportunity to improve the relative sustainability of existing settlements through co-locating new development on a scale that can deliver new physical and social infrastructure to seek to reverse the impacts of smaller villages and rural communities. The opportunity to utilise the new rail and road links for non-car travel initiatives such as the CAM should be prioritised above new development in locations that are not able to take advantage of these alternative options.

2.1 Magdalene College fully commits to reducing its impact on the climate and supports the aspirations of the Local Plan with regard to climate change. 2.2 However, it is important to recognise that the vast majority of the College’s building stock is historic – some dating back more than 600 years. Achieving energy efficiency whilst maintaining user comfort and not harming the heritage significance of the buildings is a difficult balancing act.

2.3 Downing College is committed to finding ways to reduce its carbon footprint, whilst improving the performance of its buildings. The College has recently appointed consultants to explore this issue and provide options for the existing building stock and also advise on how future building projects can deliver significant environmental improvements. 2.4 It is widely recognised that, in principle, new buildings can be designed to achieve net zero carbon, even within an historic environment. However, Downing College, as is the case with many of the Cambridge Colleges, has an existing stock of buildings which are either listed in their own right or are located within Conservation Areas. Whilst their adaptation is not prevented, their designations as heritage assets understandably mean that first and foremost their significance needs to be protected and enhanced. 2.5 The College considers that the emerging Local Plan needs to recognise that the means of achieving net zero carbon in a new building is considerably different from adapting or refurbishing a building, especially when heritage assets of varying degrees of importance are located within or adjacent to sites. It is important at this early stage of the emerging Local Plan to understand this context, given that across the Greater Cambridge area there are 89 Conservation Areas and 3,519 listed buildings. 2.6 The College suggests that the Council should undertake a number of pieces of research to inform its evidence base for this emerging Local Plan in respect of this issue. This research should include: ‒ Collaborative research with Historic England and others to identify feasible options and/or a methodology for historic buildings or those in an historic setting to be adapted sensitively in order to improve their thermal performance; ‒ Review of options for carbon offsetting within the Greater Cambridge area and the production of an Supplementary Planning Document SPD) as part of the emerging Local Plan as per the London Plan. If carbon offset funds are considered an appropriate option for the Greater Cambridge area, then the inclusion of a range of funds which are proportionate and relevant to the project that is being carried out should be contained in an SPD including historic and heritage schemes. This recommendation is particularly important for Colleges, such as Downing, which are land locked in the City and have a finite quantity of land for such offsetting as part of future projects. 2.7 By declaring a climate emergency, the Councils have recognised the importance of finding ways to reduce the impact of development on the environment. The College would emphasise that if change is to happen, organisations and research institutes need to collaborate. The emerging Local Plan must incorporate the findings of such research in any future wording and guidance that it produces, offer solutions, and be proactive in its recommendations, rather than putting the entire emphasis on the applicant to provide information and solutions. The process should be two way and rely heavily on experience, lessons learnt from other projects, and best practice

2.1 IWM Duxford is an active airfield which is not located particularly conveniently for public transport networks. It is also a conservation area containing 38 Listed Buildings the environmental performance of which is difficult to improve without impacting their heritage significance. As a major facility within the GC Plan area, these are key issues affecting our ability to achieve carbon neutrality and we therefore look to the new local plan to guide and support our efforts. 2.2 Comments regarding the need to better connect key destinations such as IWM Duxford to public transport facilities are given in answer to Q37. 2.3 Comments regarding the adaptation of historic buildings in response to climate change are in Q9. 2.4 The flying of historic aircraft in itself will never achieve carbon neutrality, and so IWM is actively looking at carbon offsetting. This is again considered further in the comments on Q9. Response to Q9 2.5 In terms of missing key actions, IWM recognises that the present local plan includes policies such as NH/15 (Heritage Assets and Adapting to Climate Change) and that the Council has produced the Sustainable Design and Construction SPD. However, with regard to historic buildings, the latter provides little additional information particularly in terms of advice on how heritage significance should be weighed against energy efficiency in practical ways. 2.6 IWM is also aware that guidance has been produced by Historic England and other respected bodies. The former is often quite specific and relates to specific aspects of building fabric, such as insulation or windows, whilst the latter is often generic or looks at residential building types. Its use is therefore limited given that many of the historic buildings at Duxford were designed for specific functions, of cheap / readily available materials and at a time when comfort and safety were differently perceived. 2.7 This lack of practical information needs to be addressed in the new local plan (and possibly also in revised SPD). What is needed is an understandable methodology for assessing climate change benefits; clearly defining the heritage significance of buildings and their component parts; balancing different levels of harm to different features; how you measure the resultant heritage harm and then to bring all this information together to decide which measures are acceptable. 2.8 IWM feel that the Council needs to work proactively with it and others both in developing an evidence base to support any policy / guidance and consequently learning from best practice, both in Gt Cambridge and elsewhere. A failure of the current local plan policy is that all the emphasis is placed on the applicant to provide information. At a time when the Council has declared a ‘climate emergency’ there needs to be a much more joined up and collaborative approach to this issue. 2.9 There is also a need for clear guidance for situations where carbon offsetting is justified. Altering some of the cheaply-built, utilitarian structures at Duxford to reduce their carbon footprint would fundamentally alter their heritage significance and their authenticity. Similarly, flying historic aircraft cannot in itself be done without a carbon footprint. 2.10 Offsetting is therefore the obvious answer. IWM would be keen to work with the Council to discuss the situations where offsetting is desirable or is acceptable and what form this should take so that it is of direct relevance to the place or issue concerned.

Cambridge University Hospitals NHS Foundation Trust is aware of Government’s commitment to achieving a net zero carbon society by 2050. We are also aware that a number of organisations are campaigning for this date to be brought forward. CUH is supportive of this agenda and wishes to highlight some of the practical and wider considerations in achieving this, which should be taken into account when drafting any policies for the new Local Plan. It is important that a new Local Plan embracing net zero-carbon is agreed and delivered on an accelerated timeline. The IPCC model pathways with no, or limited, overshoot of 1.5 deg.C require carbon emissions to decline by approximately 45% from 2010 levels by 2030. For land-use planning policies to effect this target they need to be introduced promptly. We would recommend that steps on how to achieve this should be brought forward, agreed and implemented as a matter of overriding urgency. Planning policy has an important role to play across the full range of carbon emission sources and sinks. The full scope of these elements should be carefully established and linked to the relevant aspects of planning policy and control. For example, the core circular economy and carbon saving tenets of reuse and recycling can be facilitated by policies that ensure the infrastructure and space to realise these actions to the full is thoughtfully established. We are aware that decarbonising the economy has a number of potential health benefits: including integration of more active travel (walking, cycling), improved air quality, more engagement with nature, reduced congestion and reductions in travel time and consequential improvements to quality of life, to name just a few examples. These objectives are all supported by CUH and our health partners. As an operator of essential hospital infrastructure, CUH is keen to work with the Local Planning Authorities to explore how the policies and objectives set by planning policy will work towards this goal. Policies and criteria will necessarily be wide ranging, considering everything from travel choices (modal share), travel to work areas and home location of staff and visitors, through to the design and performance of our buildings, green infrastructure and biodiversity. We have identified in our response to this Issues & Options consultation some major projects - including a dedicated children’s hospital, the UK’s first cancer hospital, and potential comprehensive redevelopment of the Addenbrooke’s Hospital site, through development of Addenbrooke’s 3 on the CBC Phase 1 and Phase 2 land. All of these projects are subject to business case approval from Government, and funding may be limited. The real world cost implications of policies require careful early consideration. Should project costs render important NHS schemes unaffordable, this would be a very unfortunate and embarrassing unintended consequence of any policies that may be formulated, especially where those projects are clearly in the public interest. This suggests that for health delivery there is an especially poignant balance to be struck: on the one hand there is an urgent and extensive need for carbon reduction, to mitigate the increasingly damaging effects of climate change on our health, and, on the other hand, the potential impacts on existing healthcare delivery of the costs of taking these mitigating actions now. Policies should identify clearly the basis on which schemes should be developed and assessed, following appropriate industry best practice as it evolves, from bodies such as RIBA, CIBSE and the UK Green Building Council. These should be consulted on early, to allow industry to consider the implications. CUH would be pleased to engage with the Joint Councils and its appointed advisor(s) as the emerging thinking develops in this area, to help shape any policies, but also to ensure we build the emerging requirements into our project pipeline. At this early stage, we consider that any policies should also define circumstances in which departures from standards may be permissible, for instance where it can be demonstrated that it is not practical to achieve the objectives. For instance, Addenbrooke’s Hospital and the Rosie requires an energy loading far in excess of any normal commercial operation running 24 hours, seven days a week, 365 days of the year, with significant heat and power requirements in an aging building stock. To maintain critical care for our patients, we also need to build in redundancy to the system (back up supplies etc). The same is likely to be true of laboratories and other specialist users. Achieving net zero carbon is likely to be challenging for all buildings, but as the sector embraces the challenge, the cost of technology will reduce as it becomes increasingly ‘normal’. Given our development horizons, with major projects to be brought forward through planning in the next 3-5 years, and constructed over the next 5-20+ years, we would be keen to understand early the likely policy expectations in this field. Consideration also needs to be given to refurbishment projects, or extensions to the existing hospital, which rely on, for example, existing energy infrastructure. For these, achieving net zero carbon may not be practical or viable. Any policy should reflect very carefully on how it includes any reference to the off-setting of carbon emissions through off-site contributions. It is essential the Plan recognises that net zero carbon is a shared goal according to a fair and transparent allocation of responsibility. Within reason, we would recommend that emissions are measured and offset as and when they occur, thereby encouraging their reduction at source before any consideration of off-setting is brought into play. A very valuable way of introducing additional practical meaning to carbon reduction is through establishing transparently calculated energy use intensity (EUI) criteria for new buildings – these make sound measures of performance, can be readily monitored and are not skewed by variations in the carbon intensity of grid supplies. We also consider that it should be possible, in carefully defined circumstances, to explore the practicality and viability of achieving targets, set against any overriding public interest to ensure that the world-class care and research undertaken at Addenbrooke’s continues

No response proposed.

4.3.1 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. 4.3.2 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. 4.3.3 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. 4.3.4 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.

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 energy efficient homes including affordable homes, and new local employment opportunities which link to and sustain existing villages and settlements in order to achieve net-zero carbon by 2050. The provision of new sustainable transport links (Greenways) and flexible co-working employment spaces in villages, will reduce the reliance on travel across the wider district, especially by private car. The Land east of Long Road, Comberton could deliver part of the proposed Comberton Greenway, as well as much-needed new modern, flexible co-working space in the form of both homes that have been designed to allow working from home and new modern business/flexible co-working space for the wider community, reducing commuter travel, keeping employment local, and supporting new fledgling businesses. The new co-working space could include an office rental space, such as a ‘WeWork’ style initiative, or through rental laboratory space, such as a ‘Biocity’ style concept for the medi-tech sector. This co-working space would be developed in consultation with the community, which could then be gifted to the community as a community asset. Thakeham also urge the Councils’ to review potential allocation sites based on the credentials of the developer, and work with environmentally conscious developers like Thakeham to deliver high quality, sustainable developments. Thakeham are forerunners in creating sustainable developments and have committed that from 2025, every Thakeham home will be Zero Carbon, designed to operate at net-zero carbon in the operation of its heating, lighting, and ventilation.. In addition, we have committed to be Carbon Neutral in production; reducing carbon emissions and mitigating any remaining impact through verified 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 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. Please refer to the appended Vision Document titled 'Land east of Long Road, Comberton' produced by Thakeham

4.4 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. 4.5 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. 4.6 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. 4.7 The local plan Sustainability Appraisal (SA) 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.

Pigeon fully supports the Local Plan’s need to help the Councils achieve net zero carbon by 2050 in recognition of the Climate Emergency. In this context, a key, major factor for the Local Plan in helping to realise this objective is the choice of sustainable locations for development that encourage and enable lifestyle and travel choices that do not generate carbon emissions. Our proposed site is located on a strategic transport corridor which will allow new residents to travel sustainably, utilizing these new public transport links, helping to reduce carbon emissions and also reduce congestion and delay.

4.4 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. 4.5 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. 4.6 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. 4.7 The local plan Sustainability Appraisal (SA) 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.

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 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 Council’s housing requirements and the needs of existing villages. Such sites may best secure net zero by contributing to an offsite initiative or other ways, which further reinforces the need for flexibility in the approach to applying policies. 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.

4.12 The Local Plan is one of many elements in the overall development process that is required to work effectively to help achieve net zero carbon by 2050. The Local Plan influences new development but it can also ensure that development that would improve existing settlements is considered in a more favourable light. The councils should also lobby Government to take a more proactive approach to development and include higher standards for example within Building Regulations to ensure there is a level playing field for all types of development in councils across the country to avoid the current patch work of standards. 4.13 We agree with the approach that in order to achieve net zero carbon by 2050 it is essential to reduce energy usage, promote renewable forms for energy and encourage the use of sustainable forms of transport to reduce the reliance on the use of the private car. We support the pro-active approach of promoting the planting of trees and the use technology such as carbon capture and storage. Proposals that are able to bring land into a more efficient and effective use that capture these elements should be considered favourably in the Local Plan.

This Plan needs to focus on the impact of land use choices on Climate Change, and on the adaptation of new developments to facilitate radical changes in, for example, vehicle use and modal shift in transport, and in sources of energy. These decisions must enable us to meet employment and housing needs and to maximise our use of public transport or zero-carbon modes of transport. In the immediate future, this will require development to be concentrated in urban areas, and on public transport corridors. A failure to meet demand, especially for affordable housing, in proximity to employment will inevitably lead to more distance commuting and car use by families who would otherwise avoid it. Developments should also be designed to adapt to Climate Change- driven changes in, for example risks of extreme weather events; and to support future-proofing of mobility, employment and transport. There will be no unique answers in predicting this, so the Planning Authority needs to engage developers in a continuing debate about these issues and ensure the Local Plan is sufficiently flexible to be able to accommodate and adapt to the fast-paced evolution of technology. The Climate change impact of poorer energy performance housing will remain very substantial unless and until we can retro-fit energy efficiency in the existing housing stock. We would want to see policies which would give support to developments which will bring zero-carbon sources of energy to existing settlements by virtue of the investment in new homes or offices and industry. Similarly, if householders are able to adapt their homes to meet a zero-carbon standard, they should benefit from a permitted development right. The Government’s consultation on a Future Homes Standard is setting an ambitious timetable for improving the environmental performance of new homes; this should be reflected in Building Regulations and should not be duplicated through the Planning processes.

4.5 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 by2050, much of which is dependent on government and human action so there is substantial uncertainty over outcomes. 4.6 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. 4.7 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. 4.8 The local plan Sustainability Appraisal (SA) 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 could lead to the plan being found unsound. 4.9 The Travis Perkins site is a brownfield site in a highly sustainable location with access to key transport links including the train station (which is 650 metres south of the site), the Chisholm Trail link and numerous other public transport connections including local bus services and the proposed metro connections. The proposed mixed-use development on the site, in a highly desirable location for residential and commercial development offers real opportunities to deliver low carbon, or even net zero carbon development due to the high value of the area.

3.10 As part of its sustainability framework, Grosvenor is committed to helping reduce the impacts of climate change by understanding and reducing its carbon footprint across their portfolio. By 2030, Grosvenor will achieve net zero carbon operational emissions from all its directly managed buildings. Grosvenor and USS are committed to working with the Councils to help them achieve net zero carbon by 2050. 3.11 The Local Plan provides the opportunity to plan in a way which focuses on achieving this target. This requires bold decision making and innovative methods to produce a coherent spatial strategy that performs well in sustainability terms. Developments which help meet these targets should be supported. 3.12 The Sustainability Workshop Summary Report prepared by BuroHappold in support of these representations demonstrates Grosvenor’s commitment to this agenda and explains ways in which Trumpington South will address it.

4.5 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. 4.6 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. 4.7 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. 4.8 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.

3.10 As part of its sustainability framework, Grosvenor is committed to helping reduce the impacts of climate change by understanding and reducing its carbon footprint across their portfolio. By 2030, Grosvenor will achieve net zero carbon operational emissions from all its directly managed buildings. Grosvenor and USS are committed to working with the Councils to help them achieve net zero carbon by 2050. 3.11 The Local Plan provides the opportunity to plan in a way which focuses on achieving this target. This requires bold decision making and innovative methods to produce a coherent spatial strategy that performs well in sustainability terms. Developments which help meet these targets should be supported. 3.12 The Sustainability Workshop Summary Report prepared by BuroHappold in support of these representations demonstrates Grosvenor’s commitment to this agenda and explains ways in which Trumpington South will address it.

As part of its sustainability framework, Grosvenor is committed to helping reduce the impacts of climate change by understanding and reducing its carbon footprint across their portfolio. By 2030, Grosvenor will achieve net zero carbon operational emissions from all its directly managed buildings. Grosvenor is committed to working with the authorities to help them achieve net zero carbon by 2050. The Local Plan provides the opportunity to plan in a way which focuses on achieving this target. This requires bold decision making and innovative methods to produce a coherent spatial strategy that performs well in sustainability terms. Developments which help meet these targets should be supported.

The most recent UK Government Climate Change Risk Assessment was published in 2017 (UK Climate Change Risk Assessment 2017) and highlighted the increased risks of flooding and heatwaves in particular, as well as possible interruptions to food production and trade which would have knock on effects on health. We therefore support the inclusion of climate change, and the zero carbon plan, as a key theme within the plan. Climate Change and zero carbon and there links to health can be achived in three key ways: 1. transition from private vehicles to more active, sustainable methods of travel; 2. provision of green spaces to both offset carbon emissions and increase phyiscal activity and improve mental health; 3. designing buildings and homes that can mitigate the risks of colder winters and hotter summers; In each case, the issues and options paper has addressed these steps, which are supported. in addition it would be worth adding that addressing these 3 issues appropriately is likely to provide the greatest health benefit to the most vulnerable people in our community. The local plan should address in it's policies reducing carbon emissions by supporting people to travel - both for business commutes and leisure activities - in sustainable ways (Active Travel), in particular supporting walking and cycling, which has clear benefits for health. There is good evidence that provision of walking and cycling infrastructure is associated with more active travel (A Goodman 2013). Importantly, the evidence also suggests that the greatest benefits are for the most deprived groups in our community. In addition, the National Planning Policy Framework states that planning policies should aim to "enable and support healthy lifestyles … through the provision of safe and accessible green infrastructure, …allotments and layouts that encourage walking and cycling" (Ministry of Housing, Communities & Local Government 2019). In addition the Local Plan should address in it's policies the provision of green space, both formal and informal a mechanism to achieve the zero carbon ambition. Green Spaces also provide co-benefits to health (green spaces are inclusive of: parks, forests, playing fields, river corridors, play areas and cemeteries). They have been shown to significantly reduce the risk of mortality by increasing physical activity and social interactions, and reduce the risk of mental illness and high blood pressure through the positive connections with nature (M Kondo 2018; C Maller 2005). Importantly, the benefits appear to be greatest for children, older people, and those from more deprived backgrounds (S De Vries 2003; G Vanaken 2018). The key determinants of green space usage appear to be proximity and accessibility; whilst it has also been shown that provision of trails (paved or unpaved) increase the likelihood of people using the green space for physical activity sevenfold (E Howard 2002; A Kaczynski 2008). The provision of buildings and housing that can mitigate against the effects of colder winters and hotter summers on health - particularly of the most vulnerable members of the community should be addressed through policies in the new local plan. The Greater Cambridge Sustainable Design and Construction Supplementary Planning Document is supported.

The development at Land to the South East of Cambridge will support the emerging Local Plan’s aims with regards to the theme of climate change, most notably through its location. It is a highly accessible site that can encourage low-carbon transportation use: building on existing habits in this location and enhancing local cycling and walking networks to limit private car use. CEG would also pursue on site elements to bring forward a scheme where homes are high-quality, energy efficient, and well-designed to promote low-carbon lifestyles. This is all to promote a potentially net zero carbon scheme.

4.4 Axis supports the Councils’ commitment to achieve net zero carbon by 2050. However, as climate change policy and best practice is changing quickly, with climate change scenarios predicting extensive changes by 2050, the new Local Plan will need to build in suitable flexibility to accommodate these changes within the plan period. 4.5 The new Local Plan will need to incorporate flexibly worded policies, which recognise that a range of on-site and off-site measures can contribute towards achieving net zero. It should avoid restrictive requirements and targets for meeting net zero carbon. 4.6 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 as 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 Page 15 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. 4.7 If the new Local Plan is to achieve its ambitious targets on climate change the Council should consider new ways of achieving net zero. It should recognise that seeking to achieve net zero on all sites regardless of their site, location and site-specific factors may not be feasible. Linked initiatives such as an offsetting scheme, secured through S106 financial contributes, could be an appropriate way of achieving net zero. 4.8 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. 4.9 The spatial growth strategy for the new Local Plan will have a significant role in achieving net zero carbon across Greater Cambridge. The aim to promote low-carbon lifestyles, encourage low carbon activities, and promote alternatives to private car use is supported. The spatial strategy should support this, with patterns of development that enable travel by low-carbon modes such as walking, cycling and public transport prioritised. 4.10 As part of a hybrid approach, the new Local Plan should recognise the role and scope that larger scale development, which builds upon existing sustainable transport infrastructure, can have in achieving net zero and support the allocation of these sites for development. Station Fields, which is being promoted by Axis, is located along a strategic public transport corridor. The scale of development offers opportunities for creating cost-effective and integrated solutions as part of an overarching climate change strategy. 4.11 We note that the Councils’ have commissioned further work to test the options for higher standards of carbon reduction to understand potential to achieve net zero carbon in new development. This should be made publicly available as part of the Council’s evidence base. 4.12 In addition, the Local Plan’s Sustainability Appraisal (SA) should address variable climate change scenarios, as we would expect that different climate change scenarios as a lack of rigorous assessment of these scenarios in the SA could lead to the plan being found unsound.

Summary: The Local Plan can be instrumental in achieving net zero carbon by 2050 by including planning targets and incentives and planning for heat sharing. Full text: The Local Plan can be instrumental in achieving net zero carbon by 2050, especially in the context of such a significant forecast for urban growth. It could: - Provide incentives and planning targets for reducing construction and operational carbon emissions; - Provide incentives for water management, conservation and recycling; - Require that all development include climate change adaptation measures; - Make development allocations that support heat sharing infrastructure, such as mixed use development that balances cooling-led and heating-led land uses; - Encourage local generation and/or use of renewable energy, such as Energy from Waste, Solar and Ground source energy; - Create a planning fund for investment in local renewables, such as zero carbon heat infrastructure, Virtual Power Stations, Community Energy Schemes; - Require measures that reduce transport emissions that in turn improve human health and support wellbeing such as air quality neutrality targets, prioritise pedestrian and cyclist infrastructure, increase electric vehicle charging stations, increase the number of shared surfaces that prioritise play, pedestrians and green infrastructure.

UDC considers that this should be a top priority for all Local Plans in preparation in order to contribute to responding to the Climate and Ecological Emergency.