Countryside fully supports the strategic commitment by the GCLP to positively address the issue of climate change mitigation and adaptation within the plan period and welcome the opportunity to comment on the draft policies to ensure they evolve to meet the tests of soundness and are both deliverable and viable whilst supporting the delivery of much needed high quality, private and affordable homes within Greater Cambridge.
Bourn Airfield already benefits from a recommendation for outline planning permission and is supported by a strong sustainability strategy that deploys extensive renewable energy technologies across the development.
Countryside supports the emphasis placed on responding positively and proactively to climate change in the Greater Cambridge Local Plan (GCLP). This aligns closely with Countryside’s own ambitions for their business operations and future development sites.
Countryside recognises the recently published findings by the International Panel on Climate Change (IPCC), which makes clear that the chances of crossing the global warming level of 1.5°C in the next few decades is likely unless immediate, rapid and large-scale action is taken.
To ensure Countryside plays its part, the company has recently published its Corporate Strategy ‘Path Finder – Marking Out the Route to Net Zero’ which sets out the company’s strategy to achieving net zero. As part of this strategy Countryside have set science-based carbon targets which have been verified by the Science Based Carbon Institute, and are to:
• Reduce our absolute Scope 1 and 2 emissions by 42% by 2030
• Reduce our Scope 3 emissions by 52% per sqm built by 2030
The GCLP Plan, and its emphasis on climate, will also play a very important role in meeting the challenges put forward by the IPCC. It is important to note that in meeting its net zero ambitions, one of the most important steps that the GCLP can take is to ensure that its spatial distribution strategy directs growth to locations that are sustainable and help to facilitate reductions in GHG emissions by reducing the need to travel by private car for work and leisure.
As a general theme, Countryside support the strategic objectives of the policy but note that the targets presented within the GCLP will introduce some of the highest sustainability standards in the UK at a time when the housebuilding industry is already responding at pace to the introduction of the Governments Future Homes Standard.
Given the volume of new homes required within Greater Cambridge there is a risk that the introduction of these standards will restrict the delivery of new homes particularly given that the supply chain is currently not able to deliver these standards at volume. These challenges will also be particularly acute for smaller housebuilders which may further restrict delivery and diversity within the market.
Whilst Countryside note the ambition of the GCLP, it is important that the sustainability policies do not restrict the delivery of much needed new private and affordable housing across the county. To meet the requirements of the National Planning Policy Framework, these policies must be supported by a robust evidence base and viability assessment that demonstrates these policies and targets are deliverable.
Countryside have reviewed each of the draft policies within the climate change section of the GCLP and have provided representations for each policy which we hope is of assistance to the Greater Cambridge Shared Planning authorities. Our focus is to ensure that each policy is both viable and deliverable whilst facilitating a shared objective of delivering more high quality affordable and private homes in an area with current and growing demand.
Where necessary these representations make reference to the GCLP Climate Change Topic Paper which summarises the evidence to support each of the policies and is hereafter referred to as the Topic Paper.
For draft Policy CC/ NZ, we have also reviewed the evidence base supporting these specific policies which is the Greater Cambridge Net Zero Carbon Evidence Base Non-Technical Summary and which is hereafter referred to as the Evidence Base document. Unfortunately a more detailed review of the full evidence is not possible as only the non-technical summary has been published and therefore Countryside reserve the right to amend our representations once this material has been reviewed.
Countryside welcome the opportunity to comment on these draft policies and would be happy to discuss our comments in greater detail with the authorities. We also recognise that these are currently policy options which will be informed by consultation feedback. Countryside look forward to reviewing the next iteration of the draft GCLP.