Question 9. How do you think we should be reducing our impact on the climate? Have we missed any key actions?

5.8 Greater Cambridge is a leading local authority on climate change policy, such as through the early declaration of a climate change emergency and also through the newly adopted Sustainable Development SPD. This leadership should continue, as it is central to the sustainable development of Cambridge, leading to better development for humans, the environment, and for economic development. It should be borne in mind that Cambridge's knowledge economy increasingly demands high sustainability standards: sustainability, health and wellbeing, with climate change at the heart, is a key part of continuing Cambridge's economic development. This should remain a priority as part of a policy framework the recognises climate change as a key part of sustainable development across social, environmental and economic objectives.

See response to Question 8. Tree planting can be an effective way of mitigating carbon emissions through providing an increased ‘carbon sink’, as long as it takes place in a strategic manner, in the right place (so, for example avoiding peat soils or species-rich grassland habitats). We believe that the plan will have far greater benefits if it also identifies where other options for habitat creation may be more effective and appropriate. As above, this may include re-wetting peatland soils in the wider Cambridgeshire area through wetland creation and enabling more climate-friendly land-management in the farmed landscape.

Greater Cambridge is a leading local authority on climate change policy, as demonstrated by the early declaration of a climate change emergency and also the newly adopted Sustainable Development SPD. This leadership should continue, as it is central to the sustainable development of Cambridge, leading to better outcomes for people, the environment, and for economic development. It should be borne in mind that Cambridge's knowledge economy demands increasingly high sustainability standards: with health and wellbeing, informed by this need to minimise climate change, as a key focus for its continuing economic development. This should remain a priority as part of a policy framework that recognises climate change as a key part of sustainable development across social, environmental and economic objectives.

5.8 Greater Cambridge is a leading local authority on climate change policy, as demonstrated by the early declaration of a climate change emergency and also the newly adopted Sustainable Development SPD. This leadership should continue, as it is central to the sustainable development of Cambridge, leading to better outcomes for people, the environment, and for economic development. It should be borne in mind that Cambridge's knowledge economy demands increasingly high sustainability standards, with health and wellbeing, informed by this need to minimise climate change, as a key focus for its continuing economic development. This should remain a priority as part of a policy framework the recognises climate change as a key part of sustainable development across social, environmental and economic objectives.

4.8 Greater Cambridge is a leading local authority on climate change policy, such as through the early declaration of a climate change emergency and also through the newly adopted Sustainable Development SPD. This leadership should continue, as it is central to the sustainable development of Cambridge, leading to better development for humans, the environment, and for economic development. It should be borne in mind that Cambridge's knowledge economy increasingly demands high sustainability standards: sustainability, health and wellbeing, with climate change at the heart, is a key part of continuing Cambridge's economic development. This should remain a priority as part of a policy framework the recognises climate change as a key part of sustainable development across social, environmental and economic objectives.

5.9 Greater Cambridge is a leading local authority on climate change policy, such as through the early declaration of a climate change emergency and also through the newly adopted Sustainable Development SPD. This leadership should continue, as it is central to the sustainable development of Cambridge, leading to better development for humans, the environment, and for economic development. It should be borne in mind that Cambridge's knowledge economy increasingly demands high sustainability standards: sustainability, health and wellbeing, with climate change at the heart, is a key part of continuing Cambridge's economic development. This should remain a priority as part of a policy framework that recognises climate change as a key part of sustainable development across social, environmental and economic objectives.

5.7 Greater Cambridge is a leading local authority on climate change policy, such as through the early declaration of a climate change emergency and also through the newly adopted Sustainable Development SPD. This leadership should continue, as it is central to the sustainable development of Cambridge, leading to better development for people, the environment, and for economic development. It should be borne in mind that Cambridge's knowledge economy increasingly demands high sustainability standards: sustainability, health and wellbeing, with climate change at the heart, is a key part of continuing Cambridge's economic development. This should remain a priority as part of a policy framework that recognises climate change as a key part of sustainable development across social, environmental and economic objectives.

5.7 Greater Cambridge is a leading local authority on climate change policy, such as through the early declaration of a climate change emergency and also through the newly adopted Sustainable Development SPD. This leadership should continue, as it is central to the sustainable development of Cambridge, leading to better development for humans, the environment, and for economic development. It should be borne in mind that Cambridge's knowledge economy increasingly demands high sustainability standards: sustainability, health and wellbeing, with climate change at the heart, is a key part of continuing Cambridge's economic development. This should remain a priority as part of a policy framework that recognises climate change as a key part of sustainable development across social, environmental and economic objectives.

Trinity College Cambridge fully support the list of climate change mitigation measures provided and would recommend the addition of the following: • Supporting initiatives to increase opportunities for virtual renewable energy generation, sharing, trading and procurement, including community participation and affordability initiatives. • Requiring a circular economy strategy and approach to building and infrastructural design and construction (e.g. refurbishment, upcycling, design for disassembly, material passports etc.). • Supporting local and community initiatives and amenities that encourage residents to stay local and travel short distances on foot, by bicycle and non-fossil fuel transport. • Reinforcing the infrastructure required to support electric vehicles. The new Local Plan should positively support car free and car limited development in accordance with the requirements of the NPPF6. In assessing mobility associated with developments, the emerging Local Plan should resist predict and provide7 approaches that often lead to increases in highway capacity instead taking a decide and provide approach. The latter ensures sustainable travel patterns are promoted, walking and cycling are prioritised, and shared travel and new green technology is supported. Tied into this are the opportunities for Cambridge to play a leading role in the development of emerging technologies to accomplish local, national and international carbon targets. For example, Cambridge Consultants based on Cambridge Science Park partnered with Redbarn Group to develop VeriTherm, a fast and simple tool to verify the thermal performance of new buildings. In a letter of support from the UK’s Ministry of Housing, Communities & Local Government, the Ministry stated that they are: “ …keen that [VeriTherm] is further developed and a workable method to measure the thermal performance of homes comes to market" and continued, “this product could therefore contribute to reducing CO2 emissions from homes, reducing occupant bills and to the UK meeting its carbon budgets. ” Cambridge Science Park North will be pioneering, developing, prototyping and testing new green technology. Therefore, the new Local Plan should seek to support and encourage research and development, prototype development and high-tech and skilled manufacturing to support the achievement of net zero. 6 NPPF (February 2019) paragraph 122c

Greater Cambridge is a leading local authority on climate change policy, such as through the early declaration of a climate change emergency and also through the newly adopted Sustainable Development SPD. This leadership should continue, as it is central to the sustainable development of Cambridge, leading to better development for humans, the environment, and for economic development. It should be borne in mind that Cambridge's knowledge economy increasingly demands high sustainability standards: sustainability, health and wellbeing, with climate change at the heart, is a key part of continuing Cambridge's economic development. This should remain a priority as part of a policy framework that recognises climate change as a key part of sustainable development across social, environmental and economic objectives.

4.9 Greater Cambridge is a leading local authority on climate change policy, such as through the early declaration of a climate change emergency and also through the newly adopted Sustainable Development SPD. This leadership should continue, as it is central to the sustainable development of Cambridge, leading to better development for humans, the environment, and for economic development. It should be borne in mind that Cambridge's knowledge economy increasingly demands high sustainability standards: sustainability, health and wellbeing, with climate change at the heart, is a key part of continuing Cambridge's economic development. This should remain a priority as part of a policy framework the recognises climate change as a key part of sustainable development across social, environmental and economic objectives.

5.7 We consider Greater Cambridge is a leading local authority on climate change policy, that in general is working towards appropriate climate change goals. A key action that the Local Plan should seek to address is ensuring that there is an integrated approach with neighbouring councils. 5.8 In relation to this area of South Cambridgeshire, there is a significant issue with traffic between Cambridge and Haverhill (Suffolk). To reduce local traffic, a viable and reliable alternative to the car is needed. The options seem to involve either reinstating the railway from Haverhill to Cambridge from the new Cambridge South Station via Linton and the Shudy Camps halt or introduce a dedicated bus way. A cycleway along the old roman road route from Haverhill to Cambridge may also assist the decarbonisation process. 5.9 We applaud the early declaration of a climate change emergency and recently adopted Sustainable Development Supplementary Planning Document (SDSPD). This leadership is essential and central to the sustainable development of Cambridge, its people, their environment, and long term economic development. 5.10 It should be borne in mind that Cambridge's knowledge based economy increasingly demands high sustainability standards. Becoming carbon neutral is a priority consistent with a healthy population and is crucial to Cambridge's continuing economic development. This priority is part of the planning policy framework and recognises minimising climate change is part of sustainable development (social, environmental and economic).

5.9 Greater Cambridge is a leading local authority on climate change policy, such as through the early declaration of a climate change emergency and also through the newly adopted Sustainable Development SPD. This leadership should continue, as it is central to the sustainable development of Cambridge, leading to better development for humans, the environment, and for economic development. It should be borne in mind that Cambridge's knowledge economy increasingly demands high sustainability standards: sustainability, health and wellbeing, with climate change at the heart, is a key part of continuing Cambridge's economic development. This should remain a priority as part of a policy framework the recognises climate change as a key part of sustainable development across social, environmental and economic objectives.

The Plan’s impact on climate change can be reduced most effectively by avoidance and we question whether reliance on mitigation measures is enough to achieve a net zero carbon target.

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.

Over the next decade, new approaches and technologies will be developed that will enable developments to better reduce their climate impact. It is also likely that national targets for this will become more stringent. Given that the Local Plan is proposed to cover the period to 2040, the Plan will need to be flexible enough to be able to encourage these new features as and when they become available. This could be achieved by continually updating SPDs (such as the Sustainable Design & Construction SPD, which we support) or alternatively, policy wording could refer to “best practice” or “highest standards”. As a centre for research and new thinking, we feel that Greater Cambridge should be at the forefront of adopting such practices and therefore we want to see a Local Plan that will encourage the Greater Cambridge construction industry to test new ideas and be early adopters. All new public buildings should be developed and constructed to achieve the BREEAM Certification of Excellence. The Government is currently undertaking a Consultation on Future Homes Standards, and the relevant high standard arising from this exercise should be applied initially. • Food security and reducing carbon emissions is a priority that requires quality farm land to be retained as farm land. Building on productive local farm land can result in more food imports and carbon emissions through transportation. Release of the most productive farm land for construction should be avoided. • We would like to see large new developments laid-out in ways which prioritise cycling, walking and public transport rather than private vehicles. There are examples from the Netherlands of housing estates laid out in this way, such as Houten (https://itdpdotorg.wpengine.com/wpcontent/uploads/2014/07/22.-092211_ITDP_NED_Desktop_Houten.pdf). Such developments are also usually much more community-oriented. Most developers do not want to include measures to reduce car use as they see easy car access as a selling-point for their properties, so how can the Local Plan bring about change in this regard? • Adapting to climate change cannot be achieved without co-ordination of planning across many areas. Transportation and utilities infrastructure must be joined up with buildings and construction. • Consideration needs to be given to existing housing stock and commercial premises, which make up the majority of buildings. How can the Local Plan or the Councils support property owners to retro-fit their buildings so they can use electricity and be more energy efficient? • Discouraging the use of gardens as development sites would assist carbon sequestration. Urban greenspace, including gardens, are important for urban biodiversity, water absorption, urban cooling, and carbon offsetting (trees and vegetation). Gardens and allotments are important for the health and wellbeing of residents. The Councils’ policy to prevent “garden grabbing” needs more rigorous enforcement, and the provision of more allotments associated with major new developments should be encouraged. • Consideration needs to be given to existing housing stock and commercial premises, which make up the majority of buildings, and which will be subject to Government retrofit targets. Current 2030 Clean Growth Strategy targets for as many buildings as possible to reach EPC Band C by 2030, and Minimum Energy Efficiency Standard requirements for all private rented sector buildings could have a massive impact on the character of Greater Cambridge’s buildings and places. The choices made on what measures to take, and how, will be crucial to minimising harm to valued places, streetscapes and buildings. The Plan needs to tackle these issues. • The Local Plan should seek appropriate balances between heritage significance and climate change mitigation and adaptation. Building owners should be encouraged to keep their buildings in good repair, and to improve their efficiency as far as is compatible with their character and their fabric. There will be many and sometimes very difficult choices, which need to be made on well-informed basis with a clear assessment of the issues and balances involved. Some recent cases (New Court, Trinity College, and 1 Regent Street) highlight an urgent need for owners, agents, Planning Committee members and the public to be more informed about the issues at both individual building level, and in terms of the cumulative impacts on the character of Cambridge. The Local Plan and the Councils will need to support and help guide these choices. While helpful free guidance to private sector Landlords is available (at https://www.gov.uk/guidance/domestic-private-rented-property-minimum-energyefficiency-standard-landlord-guidance, and similarly for non-domestic), the Government’s guidance on the vast majority of the work is only being published through the British Standards Institute, at exorbitant cost. Government advice on domestic retrofits is given in PAS (Publicly Available Specification) 2035:2019.energy efficiency – Specification and guidance; PAS 2038, now in preparation will cover non-domestic buildings. • Consideration needs to be given in the Plan to both requiring projects to comply with these standards, and publicising their advice and requirements in accessible, user-friendly form. See also advice available from the Sustainable Traditional Building Alliance stbauk.org. • A vital aspect of PAS 2035, and the forthcoming PAS 2038, is that they promote and define high-quality retrofit that supports, among a range of criteria, “protection and enhancement of the architectural and cultural heritage as represented by the building stock”. Appropriate balances have to be struck between energy efficiency improvements and preservation and enhancement of the heritage. We commend the principles set out in Parts L1B and L2B of the Building Regulations, which promote energy efficiency actions, insofar as they can be achieved without damage to the character or fabric of buildings of historic or breathable construction. {FULL EXTRACT FROM PAS 2035:2019: “0.1 Context 0.1.1 Statutory national targets for the reduction of greenhouse gas emissions in response to the threat of climate change imply that very significant improvements need to be made in the energy efficiency of the UK’s building stock, including nearly all its 27 million domestic buildings. ….. This PAS supports work towards those objectives by promoting and defining technically robust and responsible “whole-building” domestic retrofit work, i.e. high-quality work, that supports: • improved functionality, usability and durability of buildings; • improved comfort, health and well-being of building occupants and visitors; • improved energy efficiency, leading to reduced fuel use, fuel costs and pollution (especially greenhouse gas emissions associated with energy use); • reduced environmental impacts of buildings; • protection and enhancement of the architectural and cultural heritage as represented by the building stock; • avoidance of unintended consequences related to any of the above; • minimization of the “performance gap” that occurs when reductions in fuel use, fuel cost and carbon dioxide emissions are not as large as intended or predicted. 0.1.2 The requirements and guidance presented in this PAS are intended to apply to improvement measures in the context of a holistic approach to retrofit that takes the points listed above into account. The holistic approach considers the building as a system of elements, interfaces and occupants that interact, and not as a set of elements that are independent of each other or of occupants’ practices and lifestyle. “} • Further key guidance for work to older buildings is provided in British Standard BS 7913:2013: “ The most effective way of ensuring energy efficiency and sustainability is to keep historic buildings in good repair so that they last as long as possible, do not need replacement and do not suffer from avoidable decay that would require energy and carbon to rectify……. Elements such as walls can be over a third less energy efficient if damp…” • Buildings of traditional solid wall construction (pre 1919, and many pre 1939) will require a different approach to more modern (cavity wall) construction. Retrofit measures suitable for modern buildings may be wholly unsuitable for these older buildings which perform very differently in terms of moisture. Ill-chosen retrofit measures can waste both money and carbon on both the original and subsequent remedial works (see, e.g., FIshwyck, Preston. • There are very serious shortages of traditional building repair and refurbishment knowledge and skills, due to the construction industry’s long-term failure to provide training in them on the scale needed. This skills shortage now seriously risks compromising retrofit efforts, and the Local Plan should seek to encourage local development and dissemination of the skills needed. The Colleges and other owners of historic building estates could play a part in a strategy for developing skills. What is equally urgently needed is increasing the capacity and availability of conservation staff to provide vital impartial advice. • Whole life carbon is a key issue for both new buildings and retrofits, and repairs, e.g. using cement mortar prevents re-use of carbon-intensive fired and quarried materials. A circular economy approach should be encouraged, with whole-life audits for retrofit projects as per BS EN 15978:2011. Taking all these factors into consideration, a baseline assessment of the implications, for Cambridge’s historic environment, of current Government retrofit targets is urgently needed.

Agree with the items listed but we should also encourage re-use and recycling.

The consultation document correctly identifies most of the issues and measures that will need to be incorporated into the Local Plan. However, the only comment we would note is that tree planting locally will only form a small part of moving towards zero carbon. Protecting and restoring tropical rainforests would achieve far more carbon benefits than local afforestation. Tree planting with the right trees in the right places is good for many other reasons, but locally with respect to moving towards net zero carbon, the creation of large-scale wetland habitats in the fens, coupled with changes towards alternative farming methods including wet farming crops, could achieve much more by protecting and restoring peat soils than tree planting. In the move towards net zero carbon, the councils and new development should be supporting the priority fenland wetland creation initiatives in Cambridgeshire at Wicken Fen, the Great Fen and adjacent to the Ouse Washes. These will also have wider benefits for biodiversity, flooding and water resource management and health and wellbeing.

The following could improve Steeple Morden’s specific response to climate change: More frequent Bus service including a regular service to the Rail Station and support for a dial a bus. Cycle path to the Rail Station and other local amenities such as Village College. Support for community renewable energy schemes including possible joint schemes with neighbouring villages. Identification of county and district council land suitable for tree planting including roadside planting. Greater protection for mature trees that are providing carbon sequestration now. Community composing schemes. Support for increase in meadows and their management. High speed electric vehicle changing points.

• Broad aspirations about reducing our impact on the climate must be translated into specific planning policies and subsequent development that will prioritise, enable and encourage cycling. • Land-use planning goes hand-in-hand with sustainable transport. Any significant development must have a mix of uses including accommodation, amenity, education, and employment — to give people a chance to access everyday needs without travelling far. • The Local Plan, in every aspect, needs to enable and encourage a full-scale transition away from private car dependency and towards walking, cycling and public transport. Every development must be fully permeable with safe, convenient and high-quality walking and cycling routes. We should plan for a sharp curtailment of car usage in new and existing developments. • The amount of land devoted to car parking and roads should be reduced in favour of more space for trees and plantings, which will help to absorb carbon and make our streets nicer places. They will also help keep us cool and shaded as temperatures rise. Having shady trees to cycle under in the summer will make cycling a more enjoyable experience and will encourage more people to cycle. “A reduction of close to 2% in [Greenhouse Gas (GHG)] emissions is observed for an increase of 7% in the length of the bicycle network. Results show the important benefits of bicycle infrastructure to reduce commuting automobile usage and GHG emissions.” (Zahabi, 2016) “For residents living near the Comox Greenway, their daily transportation GHG emissions decreased by 20.90% after the greenway’s construction. Adjusting for covariates and the control group, the greenway was associated with a significant reduction of -0.40 kg CO2e/day and -5.30 MJ/day (p = 0.001). The change in emissions was attributed to a reduction in [vehicle-kilometres-travelled (VKT)], enabled through the provision of high-quality active transportation infrastructure through cycling facilities and other streetscape improvements.” (Ngo, 2018) “If done well, reducing sprawl can improve quality of life while reducing emissions. Successful approaches likely differ among cities, especially between developing versus developed countries. In some cases, improving urban schools or reducing crime rates would decrease migration to suburbs and exurbs. Other cities may need to increase the supply of affordable, attractive medium- and high-density housing. Pedestrian- and bicycle-friendly neighborhoods, convenient mass transit, and land-use mixing (e.g., allowing retail near residences) can allow people to drive less each day if they wish (potentially increasing the density-VKT elasticity magnitude).” (Marshall, 2008) Evidence for our response to Question 9. • Zahabi, Seyed Amir H., et al (2016). Exploring the link between the neighborhood typologies, bicycle infrastructure and commuting cycling over time and the potential impact on commuter GHG emissions. Transportation Research Part D: Transport and Environment, Volume 47. • Ngo, Victor Douglas, et al (2018). Effects of new urban greenways on transportation energy use and greenhouse gas emissions: A longitudinal study from Vancouver, Canada. Transportation Research Part D: Transport and Environment, Volume 62. • Marshall, Julian D. (2008). Reducing urban sprawl could play an important role in addressing climate change. Environ. Sci. Technol. 2008, 42, 9, 3133–3137.

9. How do you think we should be reducing our impact on the climate? Have we missed any key actions? Make grey water use mandatory in new developments. Expect communal heating systems in significant developments. Design for tree inclusions in new developments. Encourage electricity generation from renewable sources and accommodate some space for these in large developments

ECC acknowledges that paragraph 4.1.3 refers to ‘promoting patterns of development that enable travel by low-carbon modes such as walking, cycling and public transport’. It is recommended that actions are incorporated to promote low-carbon forms of transport to key centres, including London Stansted, Harlow Gilston Garden Town and Great Chesterford. This would ensure that consideration is given to minimising the future impact of growth on climate change and the environment. ECC considers that a logical approach would be to ensure that travel by low-carbon modes is enhanced to key centres.

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.

• Broad aspirations about reducing our impact on the climate must be translated into specific planning policies and subsequent development that will prioritise and encourage cycling. • Land-use planning goes hand-in-hand with sustainable transport. Any significant development must have a mix of uses including accommodation, amenity, education, and employment - to give people a chance to access everyday needs without travelling far. • The Local Plan, in every aspect, needs to be enabling and encouraging a full-scale transition away from private car dependency and towards walking, cycling and public transport. Every development must be fully permeable with safe, convenient and high-quality walking and cycling routes.

A number of the issues correctly raised in relation to reducing impacts on the climate are applicable to all policies and developments. The preparation of the Local Plan should therefore focus on those issues that have the most impact on the decision-making for the Local Plan, including: - promoting patterns of development that reduce the need to travel; and - locating development where a choice of travel options exist other than the private car. We would add: - - encouraging transport choices that have less impact on the climate, such as walking, cycling and public transport; - promoting self-containment and sustainable settlements, where public transport can easily be supported and a wide range of facilities and services are within walking and cycling distance; - allocating development where public transport infrastructure already exists, is planned, or can be provided, to encourage sustainable travel.

Ensure your buildings don’t waste energy and encourage business to review how they use their energy. See above.

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's assertion that Plan-making should be ambitious. Southern & Regional Developments (Swavesey) consider that the policy approach to meet this aspiration should be to promote patterns of development that enable travel by low-carbon modes such as walking, cycling and public transport. The focus of the Climate Change strategy should therefore seek to focus development within sustainable communities where everyday needs can be accessed by these modes of transport. To achieve this, development must be provided to reinforce existing rural settlements at Minor Rural Centres such as Swavesey to ensure that suffcient population is resident to support existing schools, social facilties, health services and businesses. Any strategy that continues to focus develoment at only the largest settlements will cause the smaller sustainable locations to fail and cause an over-concentration of environmental impacts. Summary of Comments: To achieve this objective existing rural communities must be supported through appropriate expansion.

4.31 Greater Cambridge recognises that carbon offsetting should be supported through tree planting. This recognition aligns with the UKGBC Net Zero Carbon Framework, and should be extended to recognising that whilst the Council can facilitate local planting schemes, developers should be given the flexibility to choose which offsetting schemes they fund and organise their own schemes to achieve net zero carbon. 4.32 Newlands Developments produce resource efficient buildings by specifying recyclable frame and envelopes, carpets with 80% recyclable yarns and naturally produced floor coverings. These materials reduce embodied carbon emissions associated with material production and end-of-life, which should be recognised within the Local Plan by requiring development to consider embodied carbon and reduce emissions where feasible.

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.

Food security and reducing carbon emissions is a priority that requires quality farmland to be retained as farmland. Building on productive local farmland can result in more food imports and carbon emissions through transportation. Release of the most productive farmland for construction should be absolutely avoided. Consideration needs to be given to existing housing stock and commercial premises, which make up the majority of buildings. The Government’s 2030 Clean Growth Strategy targets are for as many buildings as possible to reach EPC Band C by 2030. And government Minimum Energy Efficiency Standard requirements for all private rented sector buildings could have a massive impact on the character of Greater Cambridge’s buildings and places. The choices made on what measures to take, and how, will be crucial to minimising harm to valued places, streetscapes and buildings. The Plan needs to tackle these issues. The Local Plan should take a pro-active strategic approach in promoting appropriate approaches to retrofit, promoting public awareness of the issues and challenges, and ensuring the skills and capacity which are needed. There is a serious lack of freely-available Government advice on retrofit. Helpful free guidance to private sector Landlords is available (at https://www.gov.uk/guidance/domestic-private-rented-property-minimum-energy-efficiency-standard-landlord-guidance, and similarly for non-domestic), but the Government’s guidance on the vast majority of retrofit is only being published through the British Standards Institute, at exorbitant cost. PAS (Publicly Available Specification) 2035:2019, which guides domestic retrofits, costs £190 to non-BSI members (PAS 2038 which will guide commercial retrofits is in preparation). BS 7913:2013, which gives vital guidance for buildings of traditional construction, costs £214 to non-BSI members. Consideration needs to be given in the Plan to both requiring projects to comply with these standards, and publicising their advice and requirements in accessible, user-friendly form. See also advice available from the Sustainable Traditional Building Alliance stbauk.org. The Local Plan should seek appropriate balances between heritage significance and climate change mitigation and adaptation. A vital aspect of PAS 2035, and the forthcoming PAS 2038, is that they promote and define high-quality retrofit that supports, among a range of criteria, “protection and enhancement of the architectural and cultural heritage as represented by the building stock”. Building owners should be encouraged to optimise performance by keeping their buildings in good repair as encouraged by BS 7913:2013: “ The most effective way of ensuring energy efficiency and sustainability is to keep historic buildings in good repair so that they last as long as possible, do not need replacement and do not suffer from avoidable decay that would require energy and carbon to rectify……. Elements such as walls can be over a third less energy efficient if damp…” Building owners should be encouraged to improve energy efficiency as far as is compatible with their character and their fabric as encouraged in Part L of the Building Regulations. Buildings of traditional solid wall construction (pre 1919, and many pre 1939) will require a different approach to more modern (cavity wall) construction. Retrofit measures suitable for modern buildings may be wholly unsuitable for these older buildings which perform very differently in terms of moisture. Ill-chosen retrofit measures can waste both money and carbon on both the original and subsequent remedial works (see, e.g., FIshwyck, Preston). There will be many and sometimes very difficult choices, which need to be made on a well-informed basis with a clear assessment of the issues and balances involved. Some recent cases (New Court, Trinity College, and 1 Regent Street) highlight an urgent need for owners, agents, Planning Committee members and the public to be more informed about the issues at both individual building level, and in terms of potential cumulative impacts on the character of Cambridge. There are very serious shortages of traditional building repair and refurbishment knowledge and skills, due to the construction industry’s long-term failure to provide training in them on the scale needed. This skills shortage now seriously risks compromising retrofit efforts. The Local Plan should seek to encourage local development and dissemination of the skills needed. The Colleges and other owners of historic building estates could play a part in a strategy for developing skills. What is equally urgently needed is increasing the capacity and availability of local authority conservation staff to provide vital impartial advice. Taking all these factors into consideration, a baseline assessment of the implications of current Government retrofit targets for Cambridge’s historic environment is urgently needed. This assessment should draw on international best practice, e.g. the Climate Heritage Network http://climateheritage.org and the San Antonio City Climate Action and Adaptation Plan https://www.sanantonio.gov/gpa/News/ArtMID/24373/ArticleID/17359/San-Antonio-City-Council-adopts-Climate-Action-and-Adaptation-Plan.