CC/NZ: Net zero carbon new buildings

All new builds to be to highest standards of insulation, solar energy collection, etc

Marshall is supportive of the net zero requirement of the Local Plan, which is in line with the ambitions at Cambridge East. The aspirations look to achieve net zero operational carbon and embodied carbon. Any remaining carbon will be offset at a site, local, and regional scale. Marshall’s ambition would be to ensure that any offsetting would be undertaken locally where possible.

Marshall also welcome the prospect of developing a more detailed approach to the use of materials with low embodied carbon, and to the achievement of a circular economy. Whilst carbon reduction is an intrinsic aspect of the Cambridge East ambition, as a team we welcome more specific emerging policies so that we can work with the authorities to test our vision.

ARU supports a Net Zero Carbon policy which aligns with its own Zero Carbon targets. ARU also agree that requirements should be ambitious but also need to be realistic/deliverable. It is though considered that requirements such as these are best set at a national level, with consistent methodologies (and expertise). Any policy also needs to differentiate between new buildings and refurbished buildings, recognising the difficulty in refurbishments meeting the same standards as new buildings.

Notwithstanding these comments, the policy needs to clarify that m2 refers to GIA and clarify that Total Energy Use Intensity (EUI) targets exclude renewable energy contribution. Higher education teaching facilities EUI targets also need amending and disaggregating as follows:
a. General HE teaching space – 65 kWh per m2 per year
b. HE science/lab/medical teaching/research space – 150 kWh per m2 per year
c. HE office space – 55 kWh per m2 per year

The proposed policy approach for net zero carbon from new buildings is innovative and challenging relative to energy targets. The University supports the overall approach given its own science-based target to deliver a zero carbon estate, but we note that in some cases the proposed standards are so tight that they require a more nuanced approach with slight relaxations where there is a reasonable justification, as follows:

A space heating demand of 15-20 kwh/m2/p.a for domestic and non-domestic buildings

This is very close to Passivhaus Standard. This in effect mandates triple glazing, mechanical ventilation with heat recovery, and the highest standards of insulation and air-tightness. We recommend allowing a relaxation where site constraints mean solar access is poor or an optimal form factor cannot be achieved.

Total energy use intensity (EUI) of 35 kwh/m2 for residential

This EUI goes beyond the exemplary ‘Passivhaus’ standard. We ask that an illustrative energy budget based on a real example be provided to show how this is achievable in practice.
We recommend allowing a relaxation where site constraints mean solar access is poor or an optimal form factor cannot be achieved.
Use of EUI could unfairly penalise smaller dwellings. For example, someone using a fridge and a cooker in a dwelling of 50m2 uses double the kWh/m2 for those appliances as the same person in a dwelling of 100m2; there is no dsign solution for that. We recommend a space efficiency factor be applied.

150kwh/m2 for research space

Actual EUI will be highly variable depending on the nature of the research. The University’s Civil Engineering Building was predicted to consume 80kWh/m2/yr and is achieving 77kWh/m2/yr. The Heart & Lung Research Institute, however, is predicted at 245kwh/m2/yr as it will have to provide high rates of ventilation and contains energy intensive equipment.

We suggest ‘process energy’ such as autoclaves, ultra-low temperature equipment, fume extraction etc. fall outside the research space EUI standard. Efficiency relating to this type of non-standard consumption can be demonstrated through the BREEAM ENE07 credit for ‘Energy efficient laboratory systems’.

100% renewable energy provision, preferably on-plot

Efficient PV could deliver 120kWh/yr per m2 of panel. In effect, this means roof mounted PV will struggle to meet demand where two storeys each have an EUI of 55kWh/m2/yr, even if 100% of the roof is covered in PV and there is no shadowing. This means significant renewable energy will have to be sourced elsewhere on-site or off-site for buildings above two storeys.

This policy proposal implies any non-domestic building of more than one storey will require 100% of the roof to be covered in PV (unless we see significant increases in PV efficiencies). We recommend that clarification be given that this policy should not be at the expense of equally environmentally beneficial proposals such as roof mounted air source heat pumps, roof level amenity space, and ‘green roofs’.

Policy should clarify that where peak PV output is likely to exceed building demand, and the local Distribution System Operator has insufficient capacity to receive the excess, then the offsetting route will be acceptable.
As grid carbon factor drops, it is possible that the carbon emitted to manufacture and install a PV array and associated infrastructure will exceed the lifetime carbon savings. This should be recognised in Policy for future proofing.

Offsetting only to be used in specific circumstances (e.g. insufficient roof space) with such buildings future proofed to enable 100 zero carbon through upgrades

Policy should clarify the accountancy requirements for this policy. For example that a Power Purchase Agreement for 100% renewable electricity will be accepted. Also, that If the applicant makes an advance investment in offsite renewable energy, this will be regarded as an offset ‘bank’ for future construction projects.

General comments

Confirmation is sought as to whether the proposed policy would apply to major refurbishment as well as new build
The proposed Energy Use Intensity figures are defined in kWh/m2. Confirmation is sought as to whether m2 is defined as gross internal floor area, and is kWh is defined as metered energy.
An exception to EUI standards should be allowable where building usage will be exceptionally efficient in use of space e.g. hot desking to maximise occupancy, or extended opening hours.
A definition of how EUI will be predicted is sought – in practice will the ‘most likely’ scenario in the range of outcomes defined in a CIBSE ‘TM54’ Operational Energy Evaluation carried out by a competent professional be accepted?
EUI does not take into account the desirability of storage to relieve pressure on the grid, minimising need to switch on high carbon electricity generators. Storage in the form of batteries, thermal stores and inter-seasonal storage in the ground should be encouraged. Confirmation is sought that higher EUIs associated with energy storage will be accepted where this brings a net saving in grid carbon.
We welcome the requirement to measure embodied carbon for large projects as this is in line with existing University Design Standards. We note there is a big disparity between the threshold sizes for non-residential and residential development and suggest these be treated more equally.

Policy CC/N2 – Net Zero Carbon New Buildings (P145) and Policy CC/DC – Designing for a Challenging Environment (P152)

These policies seek to set the amount of energy use that will be allowed in new development and to ensure that all new dwellings must be designed to achieve a low risk of overheating.

Croudace Homes support such initiatives. They are already developing to the standard of New Homes and fully intended to deliver housing at Fowlmere, were it to come forward, to the highest building and sustainability standards.

These and the other environmental policies demonstrate that development should not be promoted on the basis of transport links alone, but rather wider regard has to be had to the scope of the site for development of the highest sustainability standards in terms of energy consumption, access to renewable and sensitivity to, and ability to work with, the immediate environment.

Recommendation: Support

Section 3.1: Climate Change

COMMENT

Section 3.1 set out the approach to tackling climate change and includes the following policies:

Policy CC/NZ: Net Zero Carbon New Buildings: The promoted development will be net zero carbon in operation, taking a holistic approach that implements energy efficient buildings alongside a dedicated solar farm and solar PV on roofs. Given the fast pace of technological advancement and evolution, the development will assess the available options at the time of construction so as to be able to deliver a sustainable, viable, project.

Policy CC/FM: Flooding and Integrated Water Management: The prevailing surface water strategy to be adopted is a network of positive drainage consisting of, and not limited to, the following SuDS features:
• Open swales / rills;
• Living Roofs
• Blue Roofs (these can also be used in areas of Living Roof)
• Attenuation Basins (with some localised pond/wetland features);
• Porous Paving (where feasible);
• Bio-retention areas; and
• Rainwater Harvesting.

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.

Setting appropriate levels of energy use that will be allowed for in new development should be the remit of Building Regulations and not the Planning system.

Vistry Group’s purpose is to deliver sustainable homes and communities across all sectors of the UK housing market. Key to this purpose is a successful and ambitious sustainability strategy.

Their strategy launched in 2021 and is focussed on three priority areas of People, Operations and Homes & Communities. It includes a commitment to setting carbon reduction targets consistent with reduction required to keep warming at 1.5°C and the development of a roadmap to deliver net zero carbon homes.

Policy CC/NZ sets the levels of energy use that will be allowed for new development, how renewable energy should be used to meet that energy need and how whole-life carbon emissions should be taken into account. Whilst the Church Commissioners for England fully support the Councils’ overarching climate change aspirations, in accordance with paragraph 16 of the NPPF, Plans need to be aspirational but also deliverable. The emissions targets as set out within the policy are considered to be extremely ambitious, aiming for London Energy Transformation Initiative (“LETI”) targets. The Council should ensure that the use of such targets outside of London is evidenced and achievable.

This policy will require residential developments of 150 homes or more to calculate whole life carbon emissions through a nationally recognised Whole Life Carbon Assessment and demonstrate actions to reduce life-cycle emissions.
The principle of this Policy is not necessarily disputed, and it is supported that the First Proposals include reference to climate change.
We note in the accompanying Aspinell Verdi Viability Assessment (2021) that a “net zero carbon cost has been explicitly included in the appraisals” and this is welcomed. It is understood that the additional costs included allow for installation of a heat pump, mechanical ventilation with heat recovery (MVHR) and photovoltaics, with the costs allowed for as follows:
• Semi-detached house: £12,880 (10% increase on cost);
• Mid-terrace: £13,985 (13% increase on cost);
• Flats: £7,568 – based on 40 flats (5% increase on cost).
It is unclear whether in all instances installation of a heat pump, mechanical ventilation with heat recovery (MVHR) and photovoltaics will be sufficient to demonstrate a net zero carbon cost as this will vary from development to development, and therefore whether sufficient cost.

This policy will require residential developments of 150 homes or more to calculate whole life carbon emissions through a nationally recognised Whole Life Carbon Assessment and demonstrate actions to reduce life-cycle emissions.

The principle of this Policy is not necessarily disputed, and it is supported that the First Proposals include reference to climate change.

We note that a net zero carbon cost has been explicitly included in the appraisals and this is welcomed. It is understood that the additional costs included allow for installation of a heat pump, mechanical ventilation with heat recovery (MVHR) and photovoltaics, with the costs allowed for as follows:

• Semi-detached house: £12,880 (10% increase on cost);
• Mid-terrace: £13,985 (13% increase on cost);
• Flats: £7,568 – based on 40 flats (5% increase on cost).

It is unclear whether in all instances installation of a heat pump, mechanical ventilation with heat recovery (MVHR) and photovoltaics will be sufficient to demonstrate a net zero carbon cost as this will vary from development to development, and therefore whether sufficient cost has been allowed for through the viability study to accommodate for this Policy requirement.

Policy CC/WE requires developments to meet high standards of water efficiency, with residential development designed to achieve a standard of 80 litres/person/day unless demonstrate impracticable.
It is acknowledged that there are issues with current over-abstraction of the Chalk aquifer and this is having a detrimental impact on environmental conditions. It is also understood that, to address this, Greater Cambridge are seeking to adhere to ambitious water efficiency targets.
The Aspinall Verdi Viability Study (2021) states that an “extra over cost has been included for additional water standards costs with reference to Code for Sustainable Homes levels 5 and 6 (Housing Standards Review Cost Impacts report, DCLG 2014). Baseline allowance of £9 per unit to Code levels 3 & 4, and £2,697 to achieve Code levels 5 & 6 based on Department of Communities and Local Government Housing Standards Review Cost Impact, September 2014 by EC Harris.”
It is noted that these cost figures are greater than 7 years out of date, and whilst it is welcomed that these figures have been subsequently index linked, resulting in a combined figure of £3,109 per dwelling, the industry as a whole has noted that build cost and the cost of materials has significantly increased in recent years. We recommend that these figures are updated (rather than being index linked) to ensure that the evidence is robust and therefore meets the tests of soundness.
We remain concerned, therefore, whether a 2% uplift represents a sufficient increase in build costs to allow for the delivery of CC/WE.
Notwithstanding this, whilst it is clearly desirable for new development to achieve the highest possible water efficiency, the mandatory national standard set out in the Building Regulations is 125 litres/person/day. NPPG Paragraph 56-014-20150327 states that where there is a clear local need, Local Plan policies can require a tighter optional requirement of 110 litres/person/day.
The Councils’ acknowledge that the 80 litres/person/day goes beyond what Local Authorities are currently able to require but considers there is a strong case for greater water efficiency in Greater Cambridge based upon strong evidence provided by the Integrated Water Management Study. This would make full use of water efficient fixtures and fittings, water reuse measures on site including surface water and rainwater harvesting, and grey water recycling. It acknowledges that the cost effectiveness improves with the scale of the project.
The Councils’ 80 litres/person/day target is not considered realistic. Instead, it is considered that the tighter optional requirement of 110 litres/person/day should be encouraged. It may be appropriate to set tighter standards for certain site allocations but a blanket requirement of 80 litres/person/day is not realistic.

The Greater Cambridgeshire Local Plan is supported by a Greater Cambridge Local Plan Strategic Spatial Options Assessment (November 2020).
The Assessment identifies that current over-abstraction of the Chalk aquifer is having a detrimental impact on environmental conditions. It acknowledges that none of the Councils’ growth strategies offer an opportunity to mitigate the existing detrimental impacts and there is no environmental capacity for additional development in the new Local Plan to be supplied with water by increased abstraction from the Chalk aquifer.
Major new water supply infrastructure is proposed and will be operational in mid-2030s, however, development in the interim will need to reduce abstraction through the implementation of ambitious targets for water efficiency. Such targets will be required to be addressed across all new developments.
It is understood that all development within Greater Cambridgeshire will need to adhere to such ambitious water efficiency targets and therefore there is no growth strategy that has a lesser water usage impact than another.
In so far as utilising recycling systems, the Assessment suggests that large sites are able to successfully use recycling to reduce demand for potable water. We disagree with this statement. Whilst retrofitting developments may be expensive, new development (regardless of scale) is able to adopt rainwater recycling systems. It is unclear why the statement specifically restricts water recycling usage to “large developments”. Land to the East Side of Cambridge Road, Melbourn, is able to adopt a rainwater recycling system if this is a requirement set by Local Policy.
The Assessment also identifies the potential for introducing flood management and SuDS schemes to deliver multifunctional benefits including biodiversity enhancements. Land to the East Side of Cambridge Road, Melbourn presents an opportunity for delivering a scheme which includes SuDS that provide multifunctional benefits including an opportunity to benefit and enhance designated wildlife sites.
Overall, however, the Assessment recommends that growth should be concentrated in new settlements or urban extensions that avoid high flood risk and have high standards for the design of flood risk management, water usage and re-use, and blue-green infrastructure.
This recommendation follows a Location Opportunities and Constraints Categorisation and Scoring which assesses and score each of the proposed growth strategies.
Minor Rural Centres (including Melbourn) are assessed as having a red rating for flood risk due to potential existing fluvial flood and surface water flood risk. Wastewater and Quality are assessed as amber, subject to local WRC capacity. The red flood risk rating is despite Paragraph 4.2.1 of the Assessment stating “flood risk does not differentiate between the growth scenarios”.
Land to the East Side of Cambridge Road, Melbourn is located within Flood Zone 1 with low risk of surface water flooding. In this regard the Site should be assessed as having a Green or Amber Flood Risk rating. In either instances, the Site should be given a total constraints score of -6. This score would result in the same overall scoring as the proposed recommended growth strategy of locating growth within new settlements or urban extensions. This amendment would also introduce the summary of “Good Opportunities”, thereby also improving the overall combined constraints and opportunities score for development within Minor Rural Centres and Group Villages.
It is therefore disputed as to why development within the Minor Rural Centres and Group Villages have been disregarded as an appropriate growth strategy if they are able to meet the ambitious water usage targets and implement water recycling systems.

TMLC notes the importance of ensuring new buildings are as low carbon as possible. TMLC supports the overall aims of this proposed policy.

The objective to achieve net zero carbon is supported. Technology will move faster than the Local Plan process so any policy should avoid being too prescriptive in relation to specific technology types. Clarity should be given on the requirements of Whole Carbon Assessments and what they should contain.

The National Trust supports the ambitions of this policy, which is consistent with our strategy to achieve net zero from our operations.

Policy requirements should be ambitious yet deliverable. The proposals that all heating should be provided through low carbon fuels (not fossil fuels), and no new developments should be connected to the gas grid, are supported. The space heating requirements proposed in the Plan exceed Building Regulations and the Topic Paper states that the requirements included in the Plan are in line with the recommendations of the Committee on Climate Change and also align with those recommended by the London Energy Transformation Initiative. It is important that the requirements are demonstrably deliverable in the context of new development In Greater Cambridge. Likewise, an ambition for proposals to generate at least the same amount of renewable energy (preferably on-plot) as they demand over the course of a year is understood but also needs to be demonstrably deliverable in the context of new development In Greater Cambridge.

We support the proposed policy direction. The policy direction should apply to the delivery of new floorspace only. The policy should also allow for viability considerations, as not all developments will be able to meet other requirements and obligations required by the emerging Greater Cambridge Local Plan.

RSPB fully supports the approach taken in this policy. All new development must meet net zero carbon for space heating and power usage, whilst minimising embodied carbon if we are to meet our goals under the Climate Change Convention.

Great Shelford Parish Council has a concern that the Planning Authority cannot guarantee this and would welcome comment on how this will be enforced.

Great Shelford Parish Council would expect every new building to be built to net zero standards, for example with solar panels and either ground or air source heat pumps. Not just built to the minimum planning standards of the day (currently 10% renewable). With such a major project, we should be aiming for 22nd century building standards, not early 21st century needs.

Draft policy CC/NZ sets a high threshold of 150 homes for calculating whole life carbon emissions. Support should also be expressed for developments of <150 dwellings where this information is provided voluntarily.

What support will be available for developers in seeking to meet the high standards proposed? Will the potential impact on viability be taken into consideration? Regardless of the chosen approach, it would be useful to include further guidance/information in a supplementary planning document (SPD).

Cambourne Town Council understands the need for this policy as it addresses the aims contained in the vision.

This policy is not being adhered to - the full carbon cost of the NEC site is not described. Claiming the NEC is the most sustainable brownfield site is disingenuous because it isn't a brownfield site - it has a recently upgraded, fully operational sewage plant on the site, and a range of industrial/commercial businesses. The area is being turned into a brownfield site by destroying the plant and moving the businesses. The carbon cost of destroying the plant, decontaminating, digging new tunnelling and constructing a new plant, less than a mile away is extremely carbon intensive and wasteful.

Shepreth Parish Council (SPC) notes that transport carbon is more of a problem than building carbon. The latest construction technologies should be enshrined in planning and building regulation.

This policy introduces new levels of energy use that will be allowed for new development and how renewable energy should be used to meet that energy need. It also introduces requirements for the assessment of whole life carbon by new development and address the potential issue of carbon offsetting.
The policy introduces the following parameters for energy use for new buildings in order to achieve Net Zero for Operational emissions:
• A space heating demand of 15-20kwh per meter square per year for residential and non-residential buildings.
• All heating provided through low carbon sources and not fossil fuels with no new development connected to the gas grid.
• All buildings should achieve a total Energy Use Intensity (EUI) target for both regulated and unregulated energy of no more than 35kWh per m2 per year with a range of different EUI targets for non-domestic buildings as set out in the policy.
• New development should generate at least the same amount of renewable energy (preferably on-plot) as they demand over the course of a year and this should include all regulated and un-regulated energy. In large developments the energy generation can be averaged across the development to compensate for the inability of specific dwellings to meet the target
• Offsetting can only be used as a last resort and the building should be future proofed to allow residents or tenants to enable the achievement of net zero dwellings.
• To target Net Zero for Construction residential developments of greater than 150 dwellings or 1,000m2 should calculate the whole life carbon of the development and present measures to reduce these.
Whilst Countryside recognise the importance of addressing climate change, we do have a number of concerns that draft Policy CC/ NZ is unsound on the basis that it is not viable or deliverable and may reduce the delivery of much needed affordable and private housing within the Greater Cambridge (GC) area. We have summarised our concerns below which we hope are helpful to the authorities in their search for sound and effective climate change policies within the GCLP.
• It is noted that the dwelling energy efficiency targets within draft Policy CC/ NZ go significantly beyond building regulations including the proposed Future Homes Standard 2025 although the Topic Paper (page 17) states that the standards proposed are not as onerous as the passivhaus standard but do go beyond the proposed FHS. The passivhaus standard is widely recognised as the highest construction standard that is currently available in the UK for residential development as it requires complex construction techniques and therefore carries a cost premium. Analysis of this standard and others compared to the targets within Policy CC/ NZ have identified the following:
‒ The passivhaus standard requires an EUI of less than 120 kWh m2 per annum compared to the policy target of 35KWh per m2- thereby suggesting that the draft policy target is in fact considerably more onerous than passivhaus.
‒ The EUI within the draft policy CC/NZ appears to have been taken from the recommendations from the London Energy Transformation Initiative (LETI) climate emergency guide which was created to introduce higher standards in Greater London where new development is dominated by low/ high rise apartments that are inherently more energy efficient than typical single and family housing types.
‒ The passivhaus standard requires a space heating demand of 15 kWh m2 per annum compared to a draft policy target of 15 – 20 kWh m2 thereby suggesting close alignment between the two on this specific issue.
‒ Draft Policy CC/NZ requires applicants to address both regulated and unregulated energy as opposed to the FHS which deals with regulated energy alone. The Government have made this important differentiation because the use of unregulated energy (e.g. power used by televisions and appliances) is the responsibility of the homeowner and not the housebuilder and is extremely difficult to quantify accurately at construction stage.
‒ To hit the EUI target of 35KWh per m2 the Evidence base document estimates that the following will be required although no exact details are available:
(a) Low U-values that exceed the requirements of the proposed FHS
(b) Mechanical Ventilation with Heat Recovery (MVHR) to recover waste heat from the dwellings
(c) A high level of air-tightness to prevent cold air ingress and heat loss from the dwelling
All of the measures identified above are characteristic of implementing the passivhaus standard.
‒ The cost of implementing Policy CC/ NZ has been estimated at between 10% and 13% above that required to build to current Building Regulations. No detailed analysis of the assumptions behind this calculation were available however. It is claimed that this cost is achievable on the basis that significant costs are required to implement the FHS and therefore the costs identified by the Evidence base are an over-estimate and are therefore acceptable. Countryside believe it is extremely important to obtain the detailed evidence behind these costs as in our experience the cost of building to passivhaus standards (or extremely close) is likely to be significantly higher than those quoted in the Evidence base paper.
• Given the above it would appear that the Policy CC/ NZ is implementing on-site energy efficiency standards much more closely aligned to passivhaus which presents significant challenges to the housebuilding industry for the following reasons:
‒ Building to passivhaus requires a complete transformation of the on-site construction process and supply chain which would significantly delay housing delivery and increase costs of new dwellings particularly for the small and medium sized house builders.
‒ The cost of constructing houses to passivhaus is likely to be significantly higher than that identified in the evidence base although a direct comparison is difficult in the absence of the detail behind the assumptions in the Evidence Base. Achieving air-tightness levels close to passivhaus and installing MVHR are extremely costly forms of construction.
The GCLP states that it has considered alternatives to the draft policy and targets with one being the use of the Government’s FHS as the principal metric for sustainable housing. Countryside fully support the introduction of the FHS in 2025 as it will deliver many of the strategic requirements of draft Policy CC/ NZ which include:
• An all-electric energy strategy thereby allowing the carbon footprint of the dwelling to fall each year in line with grid decarbonisation
• Dwellings will have very high levels of insulation and likely require triple glazing to ensure maximum heat retention.
‒ Each home built to the FHS will require the extensive use of renewable energy technologies in which are likely to include Air Source Heat Pumps and Photovoltaic cells.
‒ There would a consistent, deliverable standard for all new dwellings in Greater Cambridge thereby providing a level playing field for all housing developers. For Bourn Airfield this would provide opportunities for smaller housebuilders and self-build to deploy the same high standard even if this was for a limited number of plots.
Whilst the detailed energy demand / performance metrics for the FHS is unknown at this time the Government have confirmed that dwellings built to this standard will reduce carbon emissions by 75% compared to those built under the current 2013 Building Regulation.
Countryside therefore believe that Policy CC/ NZ of the GCLP should utilise the FHS as the main metric for the construction of energy efficient housing. The use of this standard will also provide greater support to the small and medium (including self-build) housing sector which we believe is critical to ensure greater supply and diversity of affordable housing to the consumer.
In addition to the concern’s with respect to the on-site standards presented in draft Policy CC/ NZ, Countryside also have reservations with respect to other aspects of the Policy which are:
• It is unreasonable to prohibit all new developments to connect to the gas grid as it is possible that for buildings such as care homes and health facilities gas may still be the most suitable fuel for heating given the bespoke heating requirement of these health facilities. Given that some of Countryside’s sites are large enough (such as Bourn Airfield) to permit the delivery of critical social infrastructure such as schools and health facilities, there may be a technical requirement for gas in some form to our large sites.
• The requirement for new dwellings to generate at least the same amount of renewable energy as they demand over the course of the year is extremely challenging given that it must include both regulated and unregulated energy for which it is difficult to estimate the exact quantum of energy needed given it is entirely dependent on the occupiers use of appliances.
• The offsetting policy (although lacking in detail) would appear to be based on the cost of providing additional PV cells to generate the quantum of energy that remains from the development site after all on-site measures have been deployed. At this time however there appears to be no data with respect to the cost of this offsetting policy and how any money will be spent with absolute certainty to ensure ‘additionality’. Without any costs or viability information this aspect of the policy fails the test of soundness. It is evident however that this policy will add a significant (albeit unknown at this time) cost to new housing which ultimately will feed into higher house prices and greater affordability challenges. We look forward to seeing the detail of this policy but would urge the authorities to fully explore the viability of this carbon offsetting and its impact upon the delivery of affordable housing before it is adopted.
• The requirement to calculate Whole Life Carbon (WLF) in construction would increase the importance of reducing embodied carbon within the supply chain, particularly for small and medium sized developers. For Countryside however, we are already committed to reducing our embodied (scope 3 emissions) within the supply chain have set ambitious targets to reduce these over time. The requirement to submit a WLC assessment for each application places an unnecessary burden upon our new development activities as this work is already part of our corporate commitments. To ensure this policy does not negatively affect housing delivery we would request that the acceptable evidence to demonstrate policy compliance could be details of our corporate commitment and progress to date.
Summary of Representations to Policy CC/ NZ:
In summary, Countryside support the strategic objective of the GCLP to positively address climate change through progressive policies in the plan. We are concerned however that the policies as they stand are unsound as they propose to introduce some of the highest sustainability requirements in the country without a complete evidence base. In order to make this policy sound and facilitate the delivery of much needed high-quality affordable and private housing we recommend the following amendments to Policy CC/ NZ:
• Publication of a complete and full evidence base for stakeholder comments before these draft policies are developed further.
• Adoption of the FHS as the energy efficiency target for new housing and remove the requirement for additional renewable energy deployment.
• Allow flexibility with respect to the use of gas in new developments where gas use is necessary for health/ occupant wellbeing

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.

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.

Agree with the energy standards for new homes going further than existing building regulations.
Planners to encourage & preferably enforce carbon neutral/eco friendly developments.

Broad support for Policy CC/NZ: Net zero carbon new buildings.
Minor OBJECT that the Policies as written are rather aspirational than achievable and needs refinement of issues such as:
• avoidance of new build. This is a higher priority since this avoids embodied carbon, One, rather dated, source describes 65to 80% of such emissions lasting 20 to 200 years. The economic and housing growth targets proposed in the Plan are excessive. The proposed relocation of the WWTW is a second prime example of avoidable new build.
• reuse of existing buildings should be emphasised (Grafton Centre?)
• a ‘brownfield first’ policy for new building
• halting the use of scarce farm land for solar energy generation
• recognising that not all electricity has the same cost and carbon content. Peak power is much worse the shorter the time period over which it occurs also depending on the time of day and year when it occurs.
Solar installations might be mandated on all industrial buildings, new and existing. The cost, cost sharing and carbon footprint of district heating/cooling needs to be investigated and a comparison made of air source and ground source HPs. It is insufficient, even if convenient, to treat each building in isolation.
The role of the grid to supply part of the demand must be described since this has access to low cost and carbon sources as well as providing resilience.
Does the Plan envisage “smart” demands that avoid short duration peaks in the system?
The role of hot water storage should be described since this avoids use of power in short duration peak periods.

I have three specific objections to the draft Plan

1. Carbon emissions
The Draft Local Plan does not follow a 'brownfield first' approach. It is therefore not consistent with national government policy as expressed repeatedly, recently by the Prime Minister. Greenfield building maximises carbon emissions. The Local Plan should encourage urban intensification.
There are vast swathes of second quality post war two storey developments in and around Cambridge. These could and should be replaced or augmented with additional storeys to add 50% or more to the housing stock in the City, all within easy pedestrian or cycling distance of the city centre.
Old airfields such as those being developed in Cambridgeshire are not true brownfields; only their disused run-ways and any associated buildings are and the former could be easily cleared and used as a source of recycled aggregate. Most of the former Bourn airfield is productive farmland. The massive greenfield building and infrastructure programme contained in the Draft Local Plan breaches all obligations for sustainable development. Embodied carbon emissions are 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.
According to the recent Cambridge and Peterborough Climate Commission report, at the present rate the Region will have used up all of its 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. The obvious conclusion is that all unsustainable growth has to be curbed.
This means that the intensification of housing in Cambridge should use sustainable building techniques based around wood and recycled materials.
The Climate Change Committee has argued in its 2018, 2019 and 2020 Annual Reports to Parliament that UK local and imported emissions arising from construction (the UK imports most of its building materials, even the bricks are made in Belgium or Holland), must be reduced if the UK is to meet its now legal emission targets.

2. Transport
Climate change should be the single most important consideration in all aspects of transport planning and operation, and the Draft Local Plan fails to do this.
Only by intensification of housing in the City can the car borne carbon emissions be avoided.
Annual Reports to Parliament by the Climate Change Committee have consistently made the point that ‘Surface Transport’ is the greatest source of greenhouse gas emissions in the UK. Therefore, all transport planning should: (a) seek to minimise all forms of travel by locating the dwellings required within walking and cycling distance of work and leisure facilities, discouraging commuting and leisure travel
(b) encourage use of digital communications,
(c) where travel is essential, encourage active travel and/or use of public transport,
(d) provide carbon efficient forms of public transport, particularly light rail and heavy rail on the most heavily used routes. The ancient proposals for a Cambridge underground railway should be revived.
Road widening and road building proposals should be abandoned with immediate effect. The only consideration for any road layout changes, other than road safety, should be the question “Will it reduce net carbon emissions from construction and use?”. Clearly, some small schemes which ease traffic flow will reduce emissions from acceleration, but those that increase road use will not.

3 Inadequate water and waste water provision
(a) Water
Cambridge City and South Cambridgeshire already have an unsustainable supply of potable water. In 2021 the Environment Agency published “Water stressed areas – final classification 2021” which included the fact that the supply areas of Cambridge Water and Anglian Water are areas of serious water stress, Appendix 3 states Cambridge Water needs to reduce abstraction by 22 megalitres per day from levels current at 1st July 2021, and Anglian Water needs to reduce abstraction by 189 megalitres per day from levels current at 1st July 2021.
(b) Wastewater
The local sewage system is currently inadequate, evidenced by the number of sewage spills by Anglian Water sewage works into the Cam Valley. Currently, there are no plans to improve failing combined sewer overflows. Cambridge saw 622 hours of untreated waste water enter the rivers in 2020, yet Anglian Water is proposing to move the one sewage works in the area which has been upgraded and has sufficient capacity until 2050, the main Cambridge works, into the Green Belt and to spend at least £227 million of public money to do so.
To date there have been no upgrades at any of the smaller works in the area while more and more taps are still being connected. The Environment Agency has already warned at least one Cambridgeshire local planning authority, East Cambs District Council, that they must stop looking at the sewage requirements of single planning applications and instead look at the cumulative effects.

Contents
1. Introduction 1
2. Taylor Wimpey’s Corporate Commitment to creating a more sustainable business 2
3. The Greater Cambridge Local Plan Policies 4
4. Summary of Representations 12










































Colin Morrison colin.morrison@turley.co.uk
Client
Taylor Wimpey Strategic Land
Our reference
TAYS3107

December 2021

1. Introduction

1. These representations to the Greater Cambridge Local Plan (GCLP) have been produced by Turley Sustainability on behalf of Taylor Wimpey with respect to their existing and potential future land interests within the Greater Cambridge Area. These representations are focused on the Climate Change Theme of the GCLP and specifically the following policies:

1.1.1 CC/NZ: Net Zero Carbon in New Buildings

1.1.2 CC/WE: Water Efficiency in New Developments

1.1.3 CC/DC: Designing for a changing climate

1.1.4 CC/ FM: Flooding and Integrated Water Management

1.1.5 CC/ RE: Renewable Energy projects and infrastructure

1.1.6 CC/ CE: Reducing Waste and supporting the local economy

1.1.7 CC/ CS: Supporting land-based carbon sequestration

2. Taylor Wimpey 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.

2. Taylor Wimpey’s Corporate Commitment to creating a more sustainable business

3. Taylor Wimpey have a strong corporate commitment to sustainability, environmental and social governance as can be seen from the recent publications on their website of their 2020 Sustainability Report1 and their 2021 Environment Strategy2.

4. Launched in 2021 the Environment Strategy sets out the company’s long term commitment to protecting the environment for future generations by reducing their environmental impact and making it easier for their customers to live a sustainable lifestyle.

5. The strategy focuses on the environmental impacts that are deemed critical to the business which are set our below along with some of the key targets to reduce these impacts:

1.5.1 Climate Change: Protect our planet and our future by playing our part in the global fight to stop climate change:

1.5.1.1 Achieve our science-based carbon reduction target through a range of measures which include reducing operational carbon emission intensity by 36% by 2025 from a 2019 baseline and reducing carbon emissions intensity from our supply chain and customer homes by 24% by 2030, from a 2019 baseline.

1.5.2 Nature: Improve access to and enable enjoyment of nature for customers and communities by regenerating the natural environment on our developments:

1.5.2.1 Increase natural habitats by 10% on new sites from 2023 and include our priority wildlife enhancements from 2021 which includes hedgehog highways, bug hotels and creating 20,000 more nature friendly gardens by 2025

1.5.3 Resources and waste. Protect the environment and improve efficiency for our business and our customers by using fewer and more sustainable resources:

1.5.3.1 Cut our waste intensity by 15% by 2025 and use more recycled materials. By 2022 publish ‘a towards zero waste’ strategy for our sites.

6. One of the key targets within the GCLP is to transition to a net zero carbon Cambridge by 2050. As stated above Taylor Wimpey have a strong corporate commitment to reducing their carbon footprint and have adopted science based carbon reduction targets against which there has been significant progress to date in the form of:

1.6.1 30% reduction in carbon emission intensity since 2013

1 https://www.taylorwimpey.co.uk/corporate/sustainability/2020-sustainability-review
2 https://www.taylorwimpey.co.uk/corporate/sustainability/2020-sustainability-review

1.6.2 39% reduction in absolute carbon emissions since 2013; and

1.6.3 58% green electricity purchased for their sites and corporate emissions;

7. These corporate commitments are resulting in more efficient and environmental friendly construction sites where there is a continued focus to reduce energy use, waste generation and improve our nature and biodiversity impacts.

3. The Greater Cambridge Local Plan Policies

8. Taylor Wimpey 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.

9. Where necessary these representations make reference to the GCLP Climate Change Topic Paper3 which summarises the evidence to support each of the policies and is hereafter referred to as the Topic Paper.

10. 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 Taylor Wimpey reserve the right to amend our representations once this material has been reviewed.

11. Taylor Wimpey 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. Taylor Wimpey look forward to reviewing the next iteration of the draft GCLP.

Policy CC/ NZ: Net Zero Carbon New Buildings

12. This policy introduces new levels of energy use that will be allowed for new development and how renewable energy should be used to meet that energy need. It also introduces requirements for the assessment of whole life carbon by new development and address the potential issue of carbon offsetting.

13. The policy introduces the following parameters for energy use for new buildings in order to achieve Net Zero for Operational emissions:

1.13.1 A space heating demand of 15-20kwh per meter square per year for residential and non-residential buildings.

1.13.2 All heating provided through low carbon sources and not fossil fuels with no new development connected to the gas grid.

1.13.3 All buildings should achieve a total Energy Use Intensity (EUI) target for both regulated and unregulated energy of no more than 35kWh per m2 per year with a range of different EUI targets for non-domestic buildings as set out in the policy.


3 https://consultations.greatercambridgeplanning.org/sites/gcp/files/2021- 08/GCLP%20Climate%20Change%20Topic%20Paper.pdf

1.13.4 New development should generate at least the same amount of renewable energy (preferably on-plot) as they demand over the course of a year and this should include all regulated and un-regulated energy. In large developments the energy generation can be averaged across the development to compensate for the inability of specific dwellings to meet the target

1.13.5 Offsetting can only be used as a last resort and the building should be future proofed to allow residents or tenants to enable the achievement of net zero dwellings.

1.13.6 To target Net Zero for Construction residential developments of greater than
150 dwellings or 1,000m2 should calculate the whole life carbon of the development and present measures to reduce these.

14. Whilst Taylor Wimpey recognise the importance of addressing climate change, we do have a number of concerns that draft Policy CC/ NZ is unsound on the basis that it is not viable or deliverable and may reduce the delivery of much needed affordable and private housing within the Greater Cambridge (GC) area. We have summarised our concerns below which we hope are helpful to the authorities in their search for sound and effective climate change policies within the GCLP.

1.14.1 It is noted that the dwelling energy efficiency targets within draft Policy CC/ NZ go significantly beyond building regulations including the proposed Future Homes Standard 2025 although the Topic Paper (page 17) states that the standards proposed are not as onerous as the passivhaus standard but do go beyond the proposed FHS. The passivhaus standard is widely recognised as the highest construction standard that is currently available in the UK for residential development as it requires complex construction techniques and therefore carries a cost premium . Analysis of this standard and others compared to the targets within Policy CC/ NZ have identified the following:

1.14.1.1 The passivhaus standard4 requires an EUI of less than 120 kWh m2 per annum compared to the policy target of 35KWh per m2-thereby suggesting that the draft policy target is in fact considerably more onerous than passivhaus.

1.14.1.2 The EUI within the draft policy CC/NZ appears to have been taken from the recommendations from the London Energy Transformation Initiative (LETI) climate emergency guide5 which was created to introduce higher standards in Greater London where new development is dominated by low/ high rise apartments that are inherently more energy efficient than typical single and family housing types.

1.14.1.3 The passivhaus standard6 requires a space heating demand of 15 kWh m2 per annum compared to a draft policy target of 15 – 20

4 https://www.passivhaustrust.org.uk/what_is_passivhaus.php#2
5 https://www.leti.london/_files/ugd/252d09_3b0f2acf2bb24c019f5ed9173fc5d9f4.pdf
6 https://www.passivhaustrust.org.uk/what_is_passivhaus.php#2

kWh m2 thereby suggesting close alignment between the two on this specific issue.

1.14.1.4 Draft Policy CC/NZ requires applicants to address both regulated and unregulated energy as opposed to the FHS which deals with regulated energy alone. The Government have made this important differentiation because the use of unregulated energy (e.g. power used by televisions and appliances) is the responsibility of the homeowner and not the housebuilder and is extremely difficult to quantify accurately at construction stage.

1.14.1.5 To hit the EUI target of 35KWh per m2 the Evidence base document estimates that the following will be required although no exact details are available:

(a) Low U-values that exceed the requirements of the proposed FHS

(b) Mechanical Ventilation with Heat Recovery (MVHR) to recover waste heat from the dwellings

(c) A high level of air-tightness to prevent cold air ingress and heat loss from the dwelling

All of the measures identified above are characteristic of implementing the passivhaus standard.

1.14.1.6 The cost of implementing Policy CC/ NZ has been estimated at between 10% and 13% above that required to build to current Building Regulations. No detailed analysis of the assumptions behind this calculation were available however. It is claimed that this cost is achievable on the basis that significant costs are required to implement the FHS and therefore the costs identified by the Evidence base are an over-estimate and are therefore acceptable. Taylor Wimpey believe it is extremely important to obtain the detailed evidence behind these costs as in our experience the cost of building to passivhaus standards (or extremely close) is likely to be significantly higher than those quoted in the Evidence base paper.

1.14.2 Given the above it would appear that the Policy CC/ NZ is implementing on- site energy efficiency standards much more closely aligned to passivhaus which presents significant challenges to the housebuilding industry for the following reasons:

1.14.2.1 Building to passivhaus requires a complete transformation of the on-site construction process and supply chain which would significantly delay housing delivery and increase costs of new dwellings particularly for the small and medium sized house builders.

1.14.2.2 The cost of constructing houses to passivhaus is likely to be significantly higher than that identified in the evidence base although a direct comparison is difficult in the absence of the detail behind the assumptions in the Evidence Base. Achieving air- tightness levels close to passivhaus and installing MVHR are extremely costly forms of construction and is likely to contribute to a significant cost increase above current Building Regulations that has not been identified by the Evidence base.

15. The GCLP states that it has considered alternatives to the draft policy and targets with one being the use of the Government’s FHS as the principal metric for sustainable housing. Taylor Wimpey fully support the introduction of the FHS in 2025 as it will deliver many of the strategic requirements of draft Policy CC/ NZ which include:

1.15.1 An all-electric energy strategy thereby allowing the carbon footprint of the dwelling to fall each year in line with grid decarbonisation

1.15.2 Dwellings will have very high levels of insulation and likely require triple glazing to ensure maximum heat retention.

1.15.2.1 Each home built to the FHS will require the extensive use of renewable energy technologies in which are likely to include Air Source Heat Pumps and Photovoltaic cells.

1.15.2.2 There would a consistent, deliverable standard for all new dwellings in Greater Cambridge thereby providing a level playing field for all housing developers.

16. Whilst the detailed energy demand / performance metrics for the FHS is unknown at this time the Government have confirmed that dwellings built to this standard will reduce carbon emissions by 75% compared to those built under the current 2013 Building Regulation.

17. Taylor Wimpey therefore believe that Policy CC/ NZ of the GCLP should utilise the FHS as the main metric for the construction of energy efficient housing. The use of this standard will also provide greater support to the small and medium (including self- build) housing sector which we believe is critical to ensure greater supply and diversity of affordable housing to the consumer.

18. In addition to the concern’s with respect to the on-site standards presented in draft Policy CC/ NZ, Taylor Wimpey also have reservations with respect to other aspects of the Policy which are:

1.18.1 It is unreasonable to prohibit all new developments to connect to the gas grid as it is possible that for buildings such as care homes and health facilities gas may still be the most suitable fuel for heating given the bespoke heating requirement of these health facilities. Given that some of Taylor Wimpey’s sites are large enough to permit the delivery of critical social infrastructure such as schools and health facilities, there may be a technical requirement for gas in some form to our large sites.

1.18.2 The requirement for new dwellings to generate at least the same amount of renewable energy as they demand over the course of the year is extremely challenging given that it must include both regulated and unregulated energy for which it is difficult to estimate the exact quantum of energy needed given it is entirely dependent on the occupiers use of appliances.

1.18.3 The offsetting policy (although lacking in detail) would appear to be based on the cost of providing additional PV cells to generate the quantum of energy that remains from the development site after all on-site measures have been deployed. At this time however there appears to be no data with respect to the cost of this offsetting policy and how any money will be spent with absolute certainty to ensure ‘additionality’. Without any costs or viability information this aspect of the policy fails the test of soundness. It is evident however that this policy will add a significant (albeit unknown at this time) cost to new housing which ultimately will feed into higher house prices and greater affordability challenges. We look forward to seeing the detail of this policy but would urge the authorities to fully explore the viability of this carbon offsetting and its impact upon the delivery of affordable housing before it is adopted.

1.18.4 The requirement to calculate Whole Life Carbon (WLF) in construction would increase the importance of reducing embodied carbon within the supply chain, particularly for small and medium sized developers. For Taylor Wimpey however, we are already committed to reducing our embodied (scope 3 emissions) within the supply chain have set ambitions targets to reduce these over time. The requirement to submit a WLC assessment for each TW application places an unnecessary burden upon our new development activities as this work is already part of our corporate commitments. To ensure this policy does not negatively affect housing delivery we would request that the acceptable evidence to demonstrate policy compliance could be details of our corporate commitment and progress to date.

Summary of Representations to Policy CC/ NZ:

19. In summary, Taylor Wimpey support the strategic objective of the GCLP to positively address climate change through progressive policies in the plan. We are concerned however that the policies as they stand are unsound as they propose to introduce some of the highest sustainability requirements in the country without a complete evidence base. In order to make this policy sound and facilitate the delivery of much needed high-quality affordance and private housing we recommend the following amendments to Policy CC/ NZ:

1.19.1 Publication of a complete and full evidence base for stakeholder comments before these draft policies are developed further.

1.19.2 Adoption of the FHS as the energy efficiency target for new housing and remove the requirement for additional renewable energy deployment.

1.19.3 Allow flexibility with respect to the use of gas in new developments where gas use is necessary for health/ occupant wellbeing

Policy CC/ WE: Water Efficiency in new developments.

20. This policy introduces requirements for water efficiency in new domestic and non- domestic development in the form of the following:

1.20.1 80 litres per person per day for domestic development; and

1.20.2 Full BREEAM credits for Wat 01 for non-domestic development

21. Taylor Wimpey 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:

1.21.1 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).

1.21.2 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’. Taylor Wimpey’s experience of trialling grey water recycling is that it is unreliable and likely to cause maintenance issues for homeowners

1.21.3 Given the unreliability of greywater recycling TW believe the only practical mechanism to achieve the 80lpppd would be through the use of rainwater harvesting systems which have the following constraints;

1.21.3.1 Such systems are more difficult for flats given that communal harvesting tanks (which are more expensive) would be necessary; and

1.21.3.2 Greater Cambridge is already one of the driest areas in the UK7 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.

1.21.4 Given the above, TW 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.

Policy CC/ DC Designing for a Changing Climate.


7 https://consultations.greatercambridgeplanning.org/sites/gcp/files/2021-
08/GCLP%20Climate%20Change%20Topic%20Paper.pdf. Page 20, Section 5.1

22. This draft Policy introduces requirements to design buildings in accordance with the Good Homes Alliance Overheating in New Homes Tool and Guidance8. Taylor Wimpey recognise the fact that all buildings will need to be designed to adapt to a warming climate and that, depending on the building type and location, this may necessitate the use of a range of measures as recommended in the Good Homes Alliance toolkit such as shading, thermal mass and different modes of ventilation. The policy requires new development to complete the Good Homes Alliance toolkit and implement the cooling hierarchy to minimise the impact of overheating.

23. Taylor Wimpey believe that this policy may be ineffective as it requires each developer to implement the guidance in a manner that is appropriate for their site and which therefore may differ from one development to the next.

24. In January 2021, the Government confirmed the introduction of the FHS and also consulted on the introduction of a range of new building regulation requirements one of which was the introduction of an overheating testing requirement9 for residential development. This will require all new homes to undergo modelling during detailed design to identify any impact from overheating and then implement mitigation measures accordingly.

25. As this requirement is proposed to be introduced with the revised changes to the Building Regulation in 2022, Taylor Wimpey believes that the policy would be unsound on the basis that it is introducing an unnecessary additional burden on development given that it duplicates the requirement of the building regulations.

26. Taylor Wimpey believe that to reduce the planning and administrative burden upon the housebuilding sector in Greater Cambridge, Policy CC/ DC should be deleted on the grounds that its objectives will be required via Building Regulations.

Policy CC/ CE: Reducing Waste and Supporting the Circular Economy

27. This policy places requirements upon new development to manage their waste and embrace the principles of the circular economy. The policy requires the following from new development proposals:

1.27.1 The submission of a Construction Environmental Management Plan (CEMP) proportionate to the size and scale of development

1.27.2 Provision of adequate waste and material storage facilities on site in accordance with the RECAP Waste Management Design Guide (or successor)

1.27.3 Submission of a Circular Economy Statement with each application

28. Taylor Wimpey fully support the strategic objective of the policy in terms of its objectives to reduce waste and, perhaps more importantly, encourage circular economy principles in development. As explained earlier in these representations,

8 https://goodhomes.org.uk/wp-content/uploads/2019/07/GHA-Overheating-in-New-Homes-Tool-and- Guidance.pdf
9https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_d
ata/file/953752/Draft_guidance_on_heating.pdf

reducing waste intensity is one of our key objectives and one in which progress is clearly being made on our sites.

29. We fully support the requirement to submit a CEMP for our sites as this is something that we already commit to as part of our best practice approach to waste management and environmental protection.

30. With respect to the provision of waste management facilities on site, Taylor Wimpey agree that the correct storage and handling of waste and raw materials is a critical step to responsible management of materials and the prevention of pollution. All of our construction sites deploy best practice measures for the prevention of pollution and provide facilities for the separation and recycling of waste. We therefore support this objective of draft Policy CC/ CE but would ask that the policy recognises that large housebuilders such as Taylor Wimpey with large and efficient supply chains may use bespoke techniques and practices on site which are not referenced in any guidance but which fully comply with all legislation and best practice.

31. With respect to the submission of a circular economy statement, Taylor Wimpey are happy to provide such information with an application although we would request that this is proportionate to the size and scale of the development in question.

Policy CC/ CS Supporting land-based carbon sequestration.

32. This policy will protect important land based carbon sinks such as peatland and woodland projects whilst encouraging new development to promote biodiversity and carbon sequestration.

33. Protecting nature and biodiversity is one of Taylor Wimpey’s key objectives within its Environment Strategy. We recognise the importance of peatlands and woodland to carbon sequestration and agree that these should be protected where possible. It is important to note however that with respect to new development, there can often be many carbon sequestration benefits associated with the creation of multi-functional green infrastructure and on-site planting which should be recognised when considering the overall ‘carbon performance’ of new development.

34. Taylor Wimpey therefore believe that the draft policy should contain text to support new development if it can be demonstrated that the green infrastructure and woodland it provides will sequester carbon. We believe this should be recognised as one of the many environmental benefits that new development can provide.

4. Summary of Representations

35. Taylor Wimpey are pleased to provide our representations to the GCLP in order to ensure the policies are sound and deliverable and facilitate the delivery of much needed private and affordable homes within Greater Cambridge.

36. Taylor Wimpey have a strong corporate commitment to positively address the causes of climate change and reduce our environmental impact and we believe we are making positive progress towards our targets.

37. We fully support many of the strategic objectives of the policy but do feel that some of the detailed targets and requirements within each policy (and specifically Policy CC/ NZ) will bring significant additional financial and technical burden to the house building industry and particularly those in the small, medium and self-build sectors. These policies are likely to have a significant impact upon the land value as these additional costs must result in lower land prices to accommodate the additional construction costs.

38. If the recommendations contained within these representations are implemented then we believe this will create a policy framework capable of meeting the significant demand for housing within the region.

39. We would be pleased to discuss our representations in greater detail with the joint authorities.