Question 11. Are there any other things we should be doing to adapt to climate change? We want to hear your ideas!

Using climate projections to estimate increased flood storage and water resource needs in the Ouse catchment, the plan should identify the level of need for increased flood and water storage capacity up to and beyond 2040, and opportunities for development to enable the provision of this. The early modelling that we are aware of (eg:- the 2019 ITRC Mistral report and Anglian Water’s WRMP projections) raises this as a serious concern. We believe that strategic deployment of nature-based solutions (e.g. wetland creation) both inside and outside of the plan area will be an important way of providing this, whilst also contributing to objectives on biodiversity and green space. The RSPB manage flood and water storage wetlands elsewhere in the UK and are looking to explore options in Greater Cambridge.

To form a flexible policy framework, so as not to stifle the benefits of new technology or modern methods of construction.

4.10 The Local Plan should form a flexible policy framework, so as not to stifle the benefits of new technology or modern methods of construction. 4.11 For reference as to how Land at Frog End could contribute towards adapting to climate change and achieving net zero carbon, please refer to Section 2 of these representations.

5.9 To form a flexible policy framework, so as not to stifle the benefits of new technology or modern methods of construction.

5.9 To form a flexible policy framework, so as not to stifle the benefits of new technology or modern methods of construction.

Within emerging policies, support should be given to innovation in energy and renewable technologies. Cambridge has a key role to play in the research and development of solutions to the climate challenge. For example, CSP is exploring the feasibility of establishing an Energy & Renewal Technologies Centre on the Park. The aim would be to co-locate companies developing related technologies under one roof where they can share facilities, knowledge and best practice. Recognition of the key role businesses within the Greater Cambridge economy should be included within the emerging Local Plan. With the development of Cambridge Science Park North, we can do more of the innovation and development of solutions to adapt to climate change. The proximity to world class talent and impact of clusters of research and development can be the catalyst to continually advance solutions to adaptation to climate change. Faster prototype development enabled through development and manufacturing and the ability to trial solutions all within the Greater Cambridge economy will drive change and accelerate adaptation.

To form a flexible policy framework, so as not to stifle the benefits of new technology or modern methods of construction.

4.11 The Local Plan should form a flexible policy framework, so as not to stifle the benefits of new technology or modern methods of construction. 4.12 For reference as to how Land to the north of Station Road could contribute towards adapting to climate change and achieving net zero carbon please refer to Section 2 of these representations, the Vision Document prepared by Allies and Morrison, the Sustainable Transport Appraisal prepared by Vectos, the Preliminary Ecological Appraisal prepared by Ecology Solutions and the Arboricultural Survey prepared by Haydens. 4.13 The Plan needs a policy framework that priorities climate change and zero carbon in a planning balance judgement.

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.

All new developments should as part of their planning application include a full Carbon Budget. This should cover not just the annual emissions following completion, but also the embedded carbon in the materials, transport, and construction. The master-planning of major developments must include data on the carbon savings and emissions that can be expected from the scheme over its lifetime. A Red/Amber/Green rating should be allocated by officers based on the carbon budget to alert Councillors to the carbon implications arising from the proposal • Major schemes should produce Whole-Life Carbon Assessments that address all impacts associated with the construction, operation, and demolition of buildings and infrastructure. The UK construction industry, a sector known for its resistance to change and for poor collaboration, has seen the recent introduction of several important climate initiatives, such as the London Energy Transformation Initiative (LETI) Energy Design Guide. This sets out the practical steps for the built environment to achieve net zero-carbon by 2050. LETI has also just released its Climate Emergency Design Guide which presents targets for new buildings to achieve net zero by 2030. The Councils should strive to incorporate these standards and targets into all new building design. However, they cannot be considered in isolation but as a core part of the Whole-Life Carbon approach. Many leading construction companies have now committed to either the Better Buildings Partnership or the UK’s industry-wide campaign, Advancing Net Zero. Developers supporting these initiatives should be favoured. • Carbon savings can be achieved by maximising use of existing developed areas before commencing development in new locations. There are several science, technology, and commercial parks in the areas around Cambridge which are not fully developed or where densification is practical.

Absolute bans on development in flood zones. Focus of development to south of City on higher ground. No point building homes that will be flooded before end of life. Where developments have potential to flood, what solutions could be considered to make flood water less prone to affect the properties. Government and organisations with power consider passing autonomy to local organisations and people in the front line. Currently these people are often overlooked. E.g. The current Keep Britain tidy by Government could have encouraged and given value to the local organisations. Identify where the issues are national and controlled by the Government and where local communities should have the autonomy to engage and improve their own areas. Also, would like to see the Government engaging and lobbying businesses to remove some of the big wins in Climate Exchange e.g. Mandatory for packaging to be ECO Friendly at source. Change road construction and road repair materials to suit the higher temperatures, mandatory requirement defined by the Local Plan.

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.

The key aspect of adapting to climate change will be in the location of new development. This must be carefully considered in the Local Plan. For example, regardless of emerging measures for energy efficiency and better building fabric, if development is allocated in settlements with few services or facilities then this will result in the need for more travel compared to development in towns where more facilities are available that are within walking / cycling distance, or connected by public transport. Paragraph 4.1.3 correctly recognises that, as this winter has demonstrated, flooding has become a key issue as events predicted as 1 in 100 year floods are happening more frequently. Caution should therefore be used in allocating sites that are close to existing modelled flood plains, particularly where topographic contours are shallow.

Run a series of events in schools and communities informing people rationally about climate change, what communities and individuals can do to help themselves and your strategy/initiates as community leaders. You refer to water and food security but omit energy security.

4.35 The UK Climate Change Risk Assessment updated in 2017 identifies key risks associated with the effects of climate change. In relation to the built environment and the proposed development these include reduced summer water availability, increased winter rainfall and increased summer temperatures. 4.36 Greater Cambridge acknowledges these risks but will need to ensure that the Local Plan policy addresses each issue comprehensively and fairly. Overheating is a significant risk to homes and businesses and is not currently fully assessed within building regulations. The Government has scheduled a consultation later in 2020 to improve the approach to assessing overheating risk as part of Building Regulations. Newlands Developments welcomes this and are already committed to undertaking overheating calculations on our new buildings to protect the future occupants. 4.37 Requirements for increasing planting within a development i.e. green roofs and green walls can reduce flooding, urban heat island effect and increase the biodiversity of a site. However, requiring installation of green walls and roofs in particular can come become detrimental to climate change mitigation measures such as solar photovoltaics and air source heat pumps. Where green walls are required, extensive irrigation may be required which becomes detrimental to avoiding water scarcity. 4.38 It is our recommendation therefore, that instead of recommending specific climate change adaptation features such as green walls and roofs, a ‘climate change adaptation’ study should be required to allow developers and design teams to take a flexible approach, managing the risks of climate change which are greatest to their buildings and occupants depending on use and location. 4.39 Another low cost approach to promoting climate change resilience in new development is providing high albedo (e.g. white) roofs to reflect summer sun and reduce overheating risks within buildings. Such as approach should consider potential adverse impacts from solar glare.

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.

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

5.12 To form a flexible policy framework, so as not to stifle the benefits of new technology or modern methods of construction.

Protect the Fens from flooding and all best and most versatile farm land above the 6 metre datum from development.

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.

4.13 The Local Plan should form a flexible policy framework, so as not to stifle the benefits of new technology or modern methods of construction. 4.14 As set out above, the redevelopment of Kett House and 10 Station Road can contribute towards adapting to climate change and achieving net zero carbon by providing more energy efficient buildings on site. The opportunities for achieving the Council’s climate change targets are more achievable through the allocation of higher density development in central locations such as the Travis Perkins site as investment can be made into achieving high standards of sustainability on site.

-Yes. The existing commercial and domestic building stock needs more than just increased energy efficiency (your section 4.1.3) since retrofitting is also needed to promote a switch away from fossil fuels (natural gas and coal/oil).

4.10 The Local Plan should form a flexible policy framework, so as not to stifle the benefits of new technology or modern methods of construction.

4.11 To form a flexible policy framework, so as not to stifle the benefits of new technology or modern methods of construction.

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. Question 11 – Other things to adapt to climate change 2.9 The College considers that currently the practice amongst Council officers to resist even relatively minor changes to heritage assets even when the benefit in sustainability terms is quite great needs to fundamentally alter. This practice has very clear implications for institutions with a large portfolio of heritage assets and their ability to meet climate change targets. It is considered that a more balanced and pragmatic approach needs to be adopted by the Council if this issue is to be realistically addressed (see Question 9). Answer to Q9: Question 9 – Reducing our impact on the climate 2.3 In terms of missing key actions, the College recognises that the present local plan includes Policy 30 (energy efficiency improvements in existing buildings) and Policy 63 (works to a heritage asset to address 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. 2.4 The College 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 specific building types. Its use is therefore limited given that historic buildings are hugely varied and often have evolved over centuries and comprise a mixture of construction types and materials. 2.5 This dearth 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 combine all this information together to decide which measures are acceptable. 2.6 The College feel that the Council needs to work proactively with others both in developing an evidence base to support any policy / guidance and consequently learning from best practice, both in 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. 2.7 There is also a need for clear guidance for situations where carbon offsetting is justified to prevent unacceptable harm to heritage significance and for prescription as to the form this offsetting should take when it is justified. Similarly there needs to be guidance on what is expected to show it is proportionate to the scale of harm resulting. 2.8 Finally, in its present form, Policy 63 is imprecise with its requirements for monitoring and its triggering possible remediation works as this is unhelpful and unworkable. There must be a clear rationale for when monitoring is needed and what aspects of heritage significance this is aiming to safeguard. less

(a) Comment - It is imperative that climate change is a core consideration of the new Local Plan and as such it should require developers to incorporate renewable energy generation within its proposals. (b) Comment - On the whole it has been possible to accommodate renewable energy developments. However, it is often the export cable/main that creates problems, particularly in the absence of suitable "grid" infrastructure. Therefore, it is considered that the location of the nearest appropriate grid connection and the potential detrimental effect that connecting into it may cause must also be considered as part of the planning process. (c) Comment - The peatlands of East Anglia, of which a sizeable proportion are within the Cambridgeshire Fens, represent a significant carbon store and efforts should be made to develop a policy on the loss of peat-based soils. Guidance should be taken from the Lowland Agricultural Peat Taskforce when launched by Defra and the East Anglian Fens peat pilot managed by Natural England. (d) Comment - Given that the Greater Cambridge area is within one of the driest areas in the country and is "stressed" during periods of drought it is considered essential that water efficiency incorporating a range of water saving devices is included in the design of not just new homes but any development that utilises potable water. In terms of fixtures and fittings issues such as total water neutrality, are not going to be achieved until all 'old' fixtures and fittings are totally replaced by 'sustainable' fittings. It is also considered that a change of thinking is required to ensure that potable water is provided "at source" rather than being abstracted and pumped several miles to where it is used. It is understood that this is currently being reviewed by the providers of potable water and will presumably be discussed during the preparation of the emerging Water Cycle Strategy (WCS). See also the additional relevant items discussed elsewhere in this response. (e) Comment - Where possible footpaths, cycleways, street lighting, and/or other street furniture should be positioned outside of any protected watercourse and the associated maintenance access. The Boards' prior written consent may be required and they will wish, when appropriate, to be involved in any discussions at the earliest possible stage. The Board will only give consent for hard surfaced "pavements" where a formal hardened road exists and will require that the relevant structure is positioned away from the watercourse on the landward side of the road. See also the additional relevant items discussed elsewhere in this response.

2.11 IWM considers that currently the practice amongst Council officers to resist even relatively minor changes to heritage assets even when the benefit in sustainability and other terms is quite great needs to fundamentally alter. This practice has very clear implications for institutions with a large portfolio of heritage assets and their ability to meet climate change targets. It is considered that a more balanced and pragmatic approach needs to be adopted by the Council if this issue is to be realistically addressed (see Question 9). 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

No response proposed.

4.6.1 To form a flexible policy framework, so as not to stifle the benefits of new technology or modern methods of construction.