Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 58610

Received: 13/12/2021

Respondent: Cambridge Past, Present and Future

Representation Summary:

CambridgePPF supports a policy which
• references that the targets prioritise a fabric first approach.
• will achieve more than Building Regulations and Future Homes/building standards.
• recognises embodied carbon
• requires whole life assessment of carbon
• require limitations in terms of planned kWhr/m2/day

Full text:

The policy should reference that the targets prioritise a fabric first approach which involves maximising the performance of the construction components and materials making up the building fabric before the use of mechanical and electrical building systems. This can help reduce capital and operational costs, improve energy efficiency and reduce carbon emissions. The fabric first approach minimises the need for energy consumption through air-tightness, super high insulation, solar gain, natural ventilation, the thermal mass of the building fabric, using energy from occupants, electronic devices etc. Focussing on the building fabric first, is generally considered to be more sustainable than relying on energy saving technology, or renewable energy generation, which can be expensive, can have a high embodied energy and may or may not be used efficiently by the consumer.

We support a policy which aims to achieve more than Building Regulations and Future Homes/building standards.

We support a policy direction which recognises embodied carbon. However, it is noted that embodied carbon is not included in all of the findings of the evidence base (Net zero carbon study (2021)). This undermines the claims made about the sustainability of new development and raises questions about the claimed sustainability credentials of the preferred growth option.

Cambridge Past, Present & Future strongly supports the proposals to require, by planning condition, whole-life assessment of carbon, including embodied carbon, construction, and building disposal through circular economy.

Cambridge Past, Present & Future welcomes the proposals in the LUC supporting report, to require limitations in terms of planned kWhr/m2/day; we particularly welcome the detail given for different types of development. Clearly these requirements can only be guidelines in the assessment of building design at Detailed Planning Application stage but they are valuable in themselves and as markers to sustainability requirement.