CC/DC: Designing for a changing climate

Like it. Policy needs to be adopted as soon as possible - like now!

Support

Agree in principle. This policy sets out to to take account of changing climate, such as heat waves and flash flood, when designing developments but refers only to new dwellings for low overheating risk. It should be expanded to include large industrial developments such as the Waste Water Treatment Plant proposal to relocate to Honey Hill, especially the office block and visitor centre. More detail is needed to ensure such commercial developments do not suffer from, or contribute to, flood risk after prolonged periods of rain or flash flooding and their operation does not contribute to released heat production. Some existing retail buildings use a "heat barrier" to ensure their entrances are warm; this contributes to CO2 production, is expensive and adds to heat spill. New buildings should use alternative entrance methods to preserve heat and reduce CO2production, and where possible efforts should be made to adjust existing retail buildings. Tree cover as a cooling mechanism cannot be achieved quickly in large urban developments but grass cove, which contributes equally to CO2 absorption, has similar effects and green landscaping allows surface drainage. These also follow the Dasgupta principles of the economics of biodiversity https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/957292/Dasgupta_Review_-_Abridged_Version.pdf

We support this policy.
Design led approach p33: How does one decide which approach is applicable?
Could it be considered obligatory to use tm59 on larger developments?
Would CIBSE TM52 be appropriate for non-domestic buildings

(Flood Risk Team) Support the mention of SuDS in this policy. It would be good to ensure that drainage and SuDS are included in this. We are receiving more and more queries on whether surface water proposals are going to include consideration for climate change, so having this written in policy would be useful.

The Wildlife Trust support the inclusion of the policy and its proposed scope.

The current wording in relation to the cooling hierarchy proposed within this policy is considered to be too technical and not clear and will be difficult to work in practice. This is contrary to paragraph 16 (d) of the NPPF that requires Plans to contain policies that are clearly written and unambiguous.

The current wording in relation to the cooling hierarchy proposed within this policy is considered to be too technical and not clear and will be difficult to work in practice. This is contrary to paragraph 16 (d) of the NPPF that requires Plans to contain policies that are clearly written and unambiguous.

Huntingdonshire District Council has no comment on this matter.

Persimmon Homes state that it is not appropriate to refer to guidance within policy as this can be ever-changing and is guidance not set policy.

Incomplete policy - Expand to include industrial developments

This policy sets out to to take account of changing climate, such as heat waves and flash flood, when designing developments but refers only to new dwellings for low overheating risk. It should be expanded to include large industrial developments such as the Waste Water Treatment Plant proposal to relocate to Honey Hill, especially the office block and visitor centre. More detail is needed to ensure such commercial developments do not suffer from or contribute to flood risk after prolonged periods of rain or flash flooding and their operation does not contribute to released heat production.

We strongly support the proposed policy and the “cooling hierarchy”. Passive measures should be the top priority for keeping buildings cool in the heat waves that are to come, as this will reduce the overall cost, reduce energy consumption and improve wellbeing

I see no mention of installing Ground Source Heat Pumps underneath Green Spaces. If these community systems are not put in before the infrastructure, it will be hideously expensive to retrofit. Putting Ground Source Heat Pumps underneath green spaces is something to seriously consider before these green spaces are put to grass.

The desire for large areas of glass on modern residential buildings without adequate shading results in a large warming effect on the dwelling. Consideration should be given to this with a warming environment and passive solutions mandated to avoid overheating and further energy use for cooling.

CC/DC: Designing for a changing climate

4.18. New buildings will need to include adaptations to the changing climate. In particular, increased temperatures and changing rainfall patterns have been highlighted as key considerations for climate change adaptation strategy, prioritising passive solutions where possible to reduce the need for artificial cooling.
4.19. Our scheme will utilise a sitewide approach to reduce climate risks, including the integration of sustainable drainage systems as part of the landscape design, the use of urban greening to reduce heat build-up in developed areas through increased tree canopy cover and integrated green space.
4.20. Buildings will be designed to reduce the risk of overheating through two primary courses of action. Firstly, heat gain into buildings will be minimised through fenestration design and external shading where needed. Secondly, natural ventilation strategies will be employed to ensure buildings are able to purge excess heat effectively.
4.21. All overheating measures will be thoroughly tested in accordance with the Good Homes Alliance Overheating Tool to ensure the risk of overheating is minimised. Additional analysis will be conducted where required, accounting for future weather scenarios with increased air temperatures. This will be developed in more detail once dwelling designs are more advanced.

The policy does not set any limits for how many homes need to be passively designed and built, just a priority ordering, which will be left up to the developer to choose from with no clear goals to reach.

Countryside support the proposed policy and agree that developments should take a holistic approach to their design to account for climate change and weather events. This approach is consistent with the NPPF which requires Local Plans to take a proactive approach to mitigating and adapting to climate change.

Countryside has recently committed to becoming a net zero company by 2030 and have released a report ‘Pathfinder: Marking out the route to Net Zero’4 which sets out the principles that Countryside will follow to respond to the global call to arms for climate action. Land to the west of Cambridge Road, Melbourn will benefit from the action plan set out in the Pathfinder report to deliver its commitments. A key element of the approach is to follow a fabric first approach to the design of dwellings to achieve high levels of efficiency through improving window glazing, air tightness, roof insulation, wall thickness and improved floor insulation and underfloor heating.

In addition to adopting a fabric first approach to reduce heating demand, Countryside will also apply the principles of their energy hierarchy to help reduce both regulated and unregulated energy usage. This includes supplying only A-rated energy efficient appliances, using smart meters and smart thermostats to reduce energy consumption by learning living and heating patterns, developing a suite of e-learning packages and support material to help households reduce consumption and live more efficiently.

The site also presents an opportunity to provide significant landscaping as shown on the Illustrative Masterplan. This can contribute to urban greening and increasing tree canopy across the site, which is currently an arable field, reducing climate risks through landscape design. In relation to sustainable drainage, it was confirmed through the previous outline application that a suitable drainage system can be delivered as part of the proposals that incorporates the use of SuDS doesn’t increase the risk of flooding on or off site and accounts for climate change allowances.

3 https://www.countrysideproperties.com/sites/default/files/2021-11/Pathfinder%20-%20Marking%20out%20the%20route%20to%20net%20zero.pdf

Support

Cambridge East is being designed to mitigate and respond to climate change, and as a result we welcome the proposed Local Plan policies. Buildings will be designed to reduce overheating given their proposed orientation, ventilation, and through the appropriate design of streets and green infrastructure. Site wide approaches will also be adopted, including SuDS and urban greening. Cambridge East will be fully compliant with the policies proposed.

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

We support the proposals.
BREEAM excellent should be required for all public buildings.

TMLC supports the design led approach to tackling climate change within new developments.

Draft Policy CC/DC requires all development to adopt a design led approach to climate change adaptation with approaches integrated into architectural design. The draft Policy includes a hierarchy, which commences at Passive design as a preference, with full building mechanical ventilation/cooling system with lowest preference.
We support this Policy and acknowledge the importance of recognising how development and construction methods can positively contribute to reduce the impacts of climate change.

It is noted that the Aspinall Verdi Viability Study which accompanies the Draft Local Plan states that to meet Policy CC/DC no additional build cost has been included for in the viability assessment, with Aspinall Verdi stating that they “assume that the heat mitigation can be built into the design at no additional cost”.

Whilst there may be scope to introduce some passive design through materials, the hierarchy also includes mechanical ventilation. Mechanical Ventilation is not included within typical build cost, and we therefore raise concerns whether the Plan viability has accounted for sufficient costs to fully deliver this Policy across all developments within Greater Cambridge.

Draft Policy CC/DC requires all development to adopt a design led approach to climate change adaptation with approaches integrated into architectural design. The draft Policy includes a hierarchy, which commences at Passive design as a preference, with full building mechanical ventilation/cooling system with lowest preference.
We support this Policy and acknowledge the importance of recognising how development and construction methods can positively contribute to reduce the impacts of climate change.
We question, however, whether a sufficient costs has been attributed within the Plan’s Viability Study to enable comprehensive delivery of this Policy. It is noted that the Aspinall Verdi Viability Study which accompanies the Draft Local Plan states that to meet Policy CC/DC no additional build cost has been included for in the viability assessment, with Aspinall Verdi stating that they “assume that the heat mitigation can be built into the design at no additional cost”.
Whilst there may be scope to introduce some passive design through materials, the hierarchy also includes mechanical ventilation. Mechanical Ventilation is not included within typical build cost, and we therefore raise concerns whether the Plan viability has accounted for sufficient costs to fully deliver this Policy across all developments within Greater Cambridge.
Notwithstanding this, Land to the East Side of Cambridge Road, Melbourn offers the opportunity to deliver a scheme that is located in proximity to sustainable modes of transport thereby promoting the use of more sustainable modes of transport and mitigating the impact of climate change. A future scheme will also be designed in a way to ensure that climate change adaption is integrated into the scheme’s design.
The residential elements of the scheme will deliver low carbon housing and benefit from electric charging points, promoting the use of electric vehicles. In accordance with the aspirations of the Greater Cambridge emerging Local Plan, low water consumption will also be promoted to reduce water usage and positively contribute to water recycling where possible.

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 welcomes these policy principles. Use of green roofs, SuDS, street trees etc.. will help make new urban environments suitable for a changing climate whilst also contributing to biodiversity goals within the Greater Cambridge area. Although this also relates to CC/NZ, we would also draw your attention to the use of green walls to help regulate building temperature and provide insulation.

Although not necessarily relevant to high-level policy wording, we would expect GC to develop guidance on design – eg: use of biodiverse and/or biosolar roofs (not sedum), the need for SuDS source control, the necessity for biodiverse planting schemes and trees suitable to the climate conditions we expect etc…

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

This draft Policy introduces requirements to design buildings in accordance with the Good Homes Alliance Overheating in New Homes Tool and Guidance. Countryside 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.
Countryside 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.
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 requirement 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.
As this requirement is proposed to be introduced with the revised changes to the Building Regulation in 2022, Countryside 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.
Countryside 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.

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.