Climate change - general comments:
The aim to “help Greater Cambridge transition to net zero carbon by 2050” is necessary but inadequate. ‘Net zero’ refers to a situation where ongoing emissions of carbon are balanced by carbon sinks. However, the level at which atmospheric carbon eventually stabilises will be determined by the total accumulated emissions up to that point, not by the balance between sources and sinks in that moment. Therefore it is critical to a) radically reduce emissions as early as possible in this time period and b) protect stocks of carbon, such as those in soils and vegetation, to prevent their release to the atmosphere. Without this understanding, the Local Plan risks driving large emissions in the short term (from materials such as
concrete used in building, habitat destruction, operational emissions during building works) in the name of achieving net zero balance in the long term. This is not an effective strategy to avert climate disaster. We note that a total carbon budget for Greater Cambridge of 11 million tonnes for the period 2020-2100 has been calculated (page 143, First Proposals). This must be given equal weighting and emphasis with the net zero target.
We agree with the comment calling for a “degree of flexibility in policies, to allow for changes in approach
and technologies during the timescale of the plan”. It is important that policies and standards are reviewed regularly to keep pace both with emerging evidence and technology, and with evolving national and international policy direction and targets. We look forward to seeing further detail of how this will be achieved.
As with all the aspirations within the Local Plan, success of the policies on new buildings will depend on how well they are implemented by developers. We look forward to seeing more detail on how the Planning Authority will assure quality control as the Local Plan begins to be implemented.

Retrofit
We have a major overarching concern that the First Proposals deal only with new development and largely
ignore the huge challenges posed by Greater Cambridgeshire’s existing built environment. The approach taken by officers in the webinars is to acknowledge this but to say that retrofit is outside the scope of a Local Plan. We do not agree: retrofit will be within the direct scope of the Plan (guiding planning decisions) whenever it involves works which could potentially require planning permission or listed building consent.
We would like to know what proportion of the projected demand for new homes and jobs could be met through a programme of retrofitting and bringing existing buildings into full use (including vacant properties, second homes, etc). We do not know whether this information exists, but it seems an important piece of evidence when assessing the Local Plan.
The Climate Change section should include specific policies covering retrofit. Government Green Homes
targets present serious challenges now, and will get ever more serious during the Plan period, with high risks of carbon (and money) being wasted on inappropriate works. Yet Net Zero Carbon for existing buildings is mentioned only cursorily, on a single page (35) of the Local Plan’s Net Zero Carbon Evidence Base. There is no mention whatsoever of the need for a different approach to buildings of traditional solid wall construction. These may form at least a quarter of the existing stock; this proportion should have been considered and assessed as part of the Evidence Base. It could even be as high as 35%, the proportion quoted in the BRE study “Solid wall heat losses and the potential for energy saving” published by DECC in 2015.
The specific challenges of traditional buildings, and the risks of unforeseen consequences (and of consequent waste, rather than saving, of carbon and money) are highlighted in PAS2035, the Government’s guidance on domestic retrofit, which is referenced in Policy GP/CC. However the PAS is not freely available, but published by the British Standards Institute, costs £190, and so is inaccessible to home owners and others who need the guidance - and the reference in the Policy is futile in its draft form.
The Climate Change section of the Plan should quote key principles and guidance* from PAS 2035 and its non-domestic counterpart PAS 2038 (and reference other freely available advice including from the STBA and IHBC as well as the Government’s own guidance to Private Sector Landlords) in sufficient detail to ensure that people dealing with ALL traditional buildings (not only heritage assets) have access to the appropriate advice and skills to ensure that their buildings are put in good repair, and then suitable retrofit measures are applied as appropriate. This is essential to achieve the aims of the PASs and to minimise unintended consequences.