Comment
Greater Cambridge Local Plan Preferred Options
Representation ID: 60604
Received: 13/12/2021
Respondent: Countryside Properties - Fen Ditton site
Agent: Turley
Countryside acknowledge that the Greater Cambridge area is under water stress and there is a strong encouragement for all new development to improve water efficiency. However, we have the following comments:
• We agree that the highest water efficiency standard is 110 l per person per day (pppd).
• We also agree that achieving 80 lppd will require either rainwater harvesting and/or greywater recycling. Both systems introduce significant maintenance requirements (and therefore cost) for homeowners and introduce technology that has not been tested ‘en-masse’.
• Given the unreliability of greywater recycling, the only practical mechanism to achieve the 80 lpppd would be through the use of rainwater harvesting systems which have the following constraints: such systems are more difficult for flats; and Greater Cambridge is already one of the driest areas in the UK and climate change is predicated to reduce rainfall further - it is highly likely that rainwater harvesting will not capture sufficient rain to meet the policy target.
Countryside believe that the GCLP should implement the Government’s technical standard for water efficiency which is 110 lpppd. This would be viable, deliverable and achievable for all new dwellings.
This policy introduces requirements for water efficiency in new domestic and nondomestic development in the form of the following:
• 80 litres per person per day for domestic development; and
• Full BREEAM credits for Wat 01 for non-domestic development.
Countryside acknowledge that the Greater Cambridge area is under water stress and there is a strong encouragement for all new development to improve water efficiency however with respect to draft Policy CC/ WE we have the following comments:
• We agree with the statement on Page 26 of the Topic Paper that the highest water efficiency standard that can be requested by local authorities is 110 l per person per day (pppd).
• We also agree that achieving 80lppd will require either rainwater harvesting and/ or greywater recycling. Both systems introduce significant maintenance requirements (and therefore cost) for homeowners and introduce technology that has not been tested ‘en-masse’. Countryside’s experience of trialling grey water recycling is that it is unreliable and likely to cause maintenance issues for homeowners
• Given the unreliability of greywater recycling Countryside believe the only practical mechanism to achieve the 80lpppd would be through the use of rainwater harvesting systems which have the following constraints;
‒ Such systems are more difficult for flats given that communal harvesting tanks (which are more expensive) would be necessary; and
‒ Greater Cambridge is already one of the driest areas in the UK and climate change is predicated to reduce rainfall in Greater Cambridge by 47% it is highly likely that rainwater harvesting will not capture sufficient rain to meet the policy target and will therefore be ineffective.
• Given the above, Countryside believe that the GCLP should implement the Government’s technical standard for water efficiency for Policy CC/ WE which is 110 lpppd. This would be viable, deliverable and achievable for all new dwellings within GC. Should technology such as grey water recycling become viable during the lifetime of the plan then this could be considered as a means to improve water efficiency beyond the target of 110 lpppd.