Comment

Representation ID: 56136

Received: 05/10/2020

Respondent: U+I PLC.

Agent: We are Town

Focused on individual buildings – needs a site-wide approach eg on masterplanning for climate change; on transport and
neighbourhood hubs. Plus infrastructure? Also add something on post-occupancy evaluation?
Unfortunate lag in evidence base (Greater Cambridge Net Zero study).
Policy focused on here & now – how is it to be future-proofed?
a - Construction Standards: Good aspirations – welcome construction certification requirements such as BREEAM
Excellent/ Outstanding. Also support the need for a site wide community sustainability framework.
However there are limitations to the use of particular frameworks. Passivhaus is better for operational carbon reduction
and there are concerns over use of BREEAM communities. Other tools are more flexible – given timescales involved this is
essential.
b - Adaptation to climate change: All flat roofs must contain an element of green roof provision (p51) – Is this the right
approach? What about if it’s used as a communal / private terrace? What about solar panels? Should prescribe standards
and allow developers flexibility in achieving them according to the site and building rather than arbitrarily dictating eg
green/brown roofs.
Fully support the move to undertake CIBSE TM52 and 59 analysis in order to inform design and ensure comfort is
addressed. Modelling alone is not enough but requires adjustments to designs to be undertaken.
c - Carbon Reduction: Aspiration is good and pleased that further work will be done. Is there a recognised form of
‘Assured Performance Certification’? What about a prohibition on use of fossil fuels on site?
d - Water – see policy 4 below.
e - Site Construction Waste. Good to see this addressed but opportunity has been missed to set a holistic benchmark
target for construction waste. What about infrastructure waste?