Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 59575

Received: 13/12/2021

Respondent: Campaign to Protect Rural England (CPRE)

Representation Summary:

Policy CC/DC: Designing for a changing climate, is closing the stable door after the horse has bolted.

Full text:

Climate change – development issues
40. CPRE largely supports Policy CC/NZ: Net zero carbon new buildings. However, to be effective it needs to be
taken in conjunction with three further policies which we have not discovered in the draft Local Plan,
namely:
• a ‘brownfield first’ policy for new building
• a policy to minimise the number of new buildings and developments in the Greater Cambridge
region
• a policy to halt the use of scarce farm land for solar energy generation and instead ensure that solar
installations are mandated on all industrial buildings, new and existing. Policy CC/RE: Renewable
energy projects and infrastructure, is totally ineffective in this respect.
41. The draft Local Plan is not consistent with national government policy because it does not follow a
'brownfield first' approach. It is also concerning that the Plan is seeking to build more houses in the
Cambridge area than required by current planning legislation and the ‘five-year land supply’.
42. As stated above, the Plan assumes the development of the Ox-Cam Arc, which is leading to more greenfield
building which maximises carbon emissions. The Local Plan should not be accepting the Arc, instead the
local planning authorities should be firmly resisting this outdated idea of ‘clustering’ of science-based
businesses. These businesses operate globally, increasingly using the internet to minimise business travel
and they can operate anywhere. The development of vaccines during the pandemic has proved the
effectiveness of remote collaborative working on a global scale.
43. Rather than encouraging further building on precious high grade farm land around Cambridge all
responsible local organisations involved in planning, including the University and businesses, should be
encouraging and enabling redevelopments in other regions, where there are up to 1 million empty homes
and space for 1.3 million more on registered brownfield sites.
44. Embedded carbon emissions arising from construction appear to be ignored in the Plan. Cement
manufacture contributes 8% of global carbon emissions which is more than three times the impact of
aviation fuel. Iron and steel production accounts for another 8%. Between them they account for more
emissions than the USA and are second only to China as greenhouse gas emitters.
45. According to the recent Cambridge and Peterborough Climate Commission report, at the present rate the
Region will have used up its entire carbon budget, allocated to meet its legal obligation to reach zero carbon
by 2050, in less than six years; due to the level of planned growth, emissions will accelerate further.
46. The Climate Change Committee, led by Lord Deben, has argued in its 2018, 2019 and 2020 Annual Reports
to Parliament that UK local and imported emissions arising from construction, must be reduced if the UK is
to meet its now legal emission targets. Yet this Plan is seeking to increase construction.
47. Large areas of some ‘brownfield’ sites, such as old airfields like Oakington, Waterbeach and Bourn, are not
brownfield at all. Only their disused runways, hard-standing and associated buildings are brownfield and
most of their area is already turned back to use as productive farmland. It is unacceptable that local
planning authorities are blindly ignoring this fact.
48. All unsustainable growth must be halted as a matter of global and national emergency, yet the level of
building and infrastructure growth contained in the draft Local Plan breaches all obligations for sustainable
development other than those arising from future operation.
49. Policy CC/DC: Designing for a changing climate, is closing the stable door after the horse has bolted.

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