Comment

Representation ID: 55745

Received: 05/10/2020

Respondent: Brookgate

Agent: Bidwells

Neutral:
This policy sets out the range of measures that are proposed to be an integral part
of the design of new development proposals, in order to ensure that new
development responds to the climate emergency. These measures are to ensure
that development in North East Cambridge addresses the twin challenges of
climate change mitigation and adaptation, in a way that enhances the
environmental and social sustainability of the development.
Brookgate broadly support Policy 2. However, 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.
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.
Policy 2, part (b), states that development must be climate-proofed to a range of
climate risks, including flood risk, overheating and water availability. Specific
guidance is then given on how to minimise the risk of overheating and that
overheating analysis must be undertaken to include consideration of future climate
scenarios using 2050 Promethesus weather data. However this data is based on
UKCP09 data rather than UKCP18 climate change projections which are the most
recent data.
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Policy 2, part (b) also states that all flat roofs must contain an element of green roof
provision. This section of the Policy needs to be more flexible to allow on-site
mitigation to be reflective of the baseline ecological conditions. For example, at
Cambridge North where the railway sidings context has created habitat that is
unusual within the AAP area, mitigating for open mosaic habitat (OMH) is required.
The Cambridge North proposals will include a mix of green and brown roof planting
but with the majority being brown roof because this is closer to the OMH habitat
lost. These brown roofs or a combination of brown and green roof planting will form
part of the overall mitigation strategy. Ecologically biodiverse brown roof planting
mixed with a small proportion of green roof is more appropriate for the Cambridge
North Site given the OMH baseline and this is the strategy that the Councils have
approved previously for the consented office and hotel developments.