CC/CE: Reducing waste and supporting the circular economy

Local recycling and production of local electricity is key- little Barford Power station is a gas turbine facility. Alternative power sources are needed west of Cambridge.

More community bins, like those on Eddington, to be built in new settlements.

The Construction Environmental Management Plan should prioritize on-site re-use and recycle over off-site in order to minimize emissions from transport.
Could prescriptive waste targets be considered?
Very difficult to benchmark for differing building types, but would impose obligations on designers to design out waste from the start, when it is much easier to have a bigger impact.

(Minerals and Waste) Inclusion of this policy is supported, however it is suggested that the Circular Economy is given priority over Reducing Waste in the title, as it has a much wider scope. It is also suggested that the Councils may wish to consider explicitly linking this policy with Policy CC/NZ: Net zero carbon new buildings; as these two policies interact with each other.
The waste hierarchy proposed by the Draft Plan reads “Refuse, Reduce, Reuse, Repurpose, Recycle”. It is appreciated that this is based on the “5 r’s”, but to avoid confusion the Councils may wish to either clarify in the policy or supporting text that ‘refuse’ is seeking to minimise avoidable resource use and not the refusal of planning permissions or development outright. The waste hierarchy as set out in Appendix A of the National Planning Policy for Waste (October 2014) is: Prevention, Preparing for Re-use, Recycling, Other recovery, Disposal.
Reference to the requirement for the RECAP guide is welcomed and accords with Policy 14 of the Cambridgeshire and Peterborough Minerals and Waste Local Plan (MWLP).
The mineral and waste planning authority (MWPA) has noted that Policy CC/6: Construction Methods which embedded consideration of waste management within the South Cambridgeshire Plan appears, by being embedded in that Plan to have been particularly effective, and inclusion of this policy is welcomed.
When referring to resources to be considered, the MWPA wishes that aggregate and other minerals are included and highlighted for consideration by applicants.
The MWPA would welcome further discussion on this topic, potentially as part of a SoCG.

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

Huntingdonshire District Council supports the proposed policy to promote the reuse and/or recycling of materials arising from demolition works on development sites. The policy also asks that developments demonstrate “how the proposals design and construction will reduce material demands and enable building materials, components and products to be disassembled and re-used at the end of their useful life”.

This policy would provide benefits not just in Greater Cambridge, but to the surrounding district by reducing construction transport and associated emissions.

It is considered that potential contamination from the reuse of materials be considered in the policy to ensure there are no adverse impacts with regards to water pollution downstream.

Agree in principle. Should include how the removal and transport of materials from demolition and remediation works should be included in the CEMP to reduce the impact of carbon footprint of HCVs.

Supported –

We support the proposed policy

Does this mean that planning will be supportive of creative solutions including within domestic design?

Only part of the waste picture. Difficult to run any domestic recycling or repair operation in this area as economic model struggles (rents too high). You have to go to St Ives or Newmarket or Saffron Walden to find really good second hand furniture shops - there's a tiny bit here and there.

Would be great to have a re-use economy here including library of things - would need top level support and spaces allocated. The economics don't seem to work. Needs more support.

CC/CE: Reducing waste and supporting the circular economy

4.25. The objective of this policy is to reduce the amount of waste being sent to landfill, both during the construction and operational phases of development. Circular economy principles are seen as the best means of ensuring materials stay in their highest use state for the longest period of time, with disposal and end of life considerations forming part of the development design principles.
4.26. Operational waste should be managed in accordance with relevant Waste Management Design Guidance, aiming to provide adequate, flexible and easily accessible waste storage for site occupants.
4.27. Circular economy principles will therefore be combined with the whole life carbon assessment to minimise the carbon embodied in construction materials, and ensure materials and buildings are capable of being reused and adapted over their lifespan.
4.28. The design of buildings will be carefully considered to allow for disassembly and material repurposing at the end of useful life. The scheme will adopt a ‘materials bank’ approach to construction. Dynamically and flexibly designed buildings will be incorporated into the circular economy, where materials in buildings sustain their value. This will lead to waste reduction and the use of fewer virgin resources.
4.29. During design development, the design team will examine the potential to include innovative approaches to operational waste management, including underground refuse systems in higher density areas of development.

There is no absolute standard for achieved performance of the developments. Given that developers are prone to create credible-looking “plans” and then depart from them in practice, we would like to see absolute metrics of waste and circularity applied to new developments.

the outlined measures are limited to construction waste. Residential waste also needs consideration, e.g. innovative residential waste arrangements to enhance reuse, recycling, waste-to-energy or useful products, e.g. compost.

Support

Marshall is supportive and agree that a holistic approach should be taken to reducing waste and supporting the circular economy.

We support the proposals.

Where possible existing buildings should be reused. Planning policy should prioritise reuse of buildings over demolition and rebuild. There is a growing body of evidence that the ‘greenest building is one that already exists’. (Carl Elefante quoted in the Architect’s Journal Retrofirst campaign https://www.architectsjournal.co.uk/news/opinion/the-greenest-building-is-the-one-that-already-exists and https://www.architectsjournal.co.uk/news/opinion/join-our-retrofirst-campaign-to-make-retrofit-the-default-choice ).

The climate change section should include policies covering retrofit. This will become increasingly important as higher energy efficiency standards are required. These targets present serious challenges now and will get ever more serious during the Plan period, with both major impacts on individual buildings and townscapes, and high risks of carbon (and money) being wasted on inappropriate works.

Retrofit will be within the direct scope of the Plan (guiding planning decisions) whenever it involves works which could potentially require planning permission or listed building consent. There will be difficult decisions to be made regarding retaining traditional features which contribute positively to the heritage, character and public realm (which is part of what makes Cambridge a great place) versus changes to those buildings to improve their energy efficiency. It is important that the policies in the Plan recognise this and provide guidance on how this should be assessed, so that good decisions are made.

A high proportion of the buildings in Greater Cambridge will be of traditional solid wall construction. The Climate Change section of the Plan should quote key principles and guidance from PAS 2035 and its non-domestic counterpart PAS 2038 (and reference other freely available advice including from the STBA and IHBC as well as the Government’s own guidance to Private Sector Landlords) in sufficient detail to ensure that people dealing with all traditional buildings (not only heritage assets) have access to the appropriate advice and skills to ensure that their buildings are put in good repair, and then suitable retrofit measures are applied as appropriate. See https://stbauk.org/whole-house-approach/. This is essential to achieve the aims of the PASs and to minimise unintended consequences.

Policy CC/CE states that developments should be supported by a Construction Environmental Management Plan, which should include an outline of the approach to site waste management and how construction waste will be addressed following a waste hierarchy.

It should be acknowledged that CEMPs are usually prepared at a detailed design stage when the site layout is secured. This will need to be recognised appropriately through the future Policy wording to ensure that the future Policy is effective.

he policy should apply to major developments only. For minor developments, commensurate requirements should be outlined in the policy.

RSPB supports the policy principles set out, which are an important element of reducing the embodied carbon of new development and the efficient usage/re-use of limited resources.

Members of Great Shelford Parish Council are concerned that the LPA is not looking at this aspect when looking at increasing jobs and growing business. They strongly feel that growth cannot continue indefinitely as there are simply not the resources available, e.g. water.

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

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:
• The submission of a Construction Environmental Management Plan (CEMP) proportionate to the size and scale of development
• Provision of adequate waste and material storage facilities on site in accordance with the RECAP Waste Management Design Guide (or successor)
• Submission of a Circular Economy Statement with each application
Countryside 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, reducing waste is one of our key objectives and one in which progress is clearly being made on our sites.
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.
With respect to the provision of waste management facilities on site, Countryside 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 Countryside 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.
With respect to the submission of a circular economy statement, Countryside 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.

Climate change – reducing waste and supporting the circular economy
60. While CPRE supports and positively encourages the principle of reducing waste and supporting the circular
economy, it deems Policy CC/CE far too weak. Worse, the draft Local Plan is not in accordance with the
first principles quoted in this policy: “construction waste will be addressed following the waste hierarchy
and the 5 r’s of waste management: Refuse, Reduce, Reuse, Repurpose, Recycle.”
61. All unnecessary construction should be Refused and all construction Reduced. This includes the excessive
building across South Cambridgeshire proposed by the draft Plan.
62. Existing constructions should be Reused, Repurposed or Recycled. This applies not just within the
Cambridge region but right across the country with Cambridgeshire doing whatever it can to encourage the
reusing, repurposing and recycling of the nearly 1 million empty homes in the UK and the recycling of the
1.3 million brownfield sites across the UK before permitting further greenfield construction around
Cambridge.
63. These principles apply to construction as a whole, not just to construction waste. Their proper application
will have a major effect in reducing greenhouse gas emissions.

Thank you for consulting Historic England on the First Proposals Public Consultation for the Greater Cambridge Local Plan. As the Government’s adviser on the historic environment Historic England is keen to ensure that the protection of the historic environment is fully considered at all stages and levels of the local planning process.

Cambridge is a beautiful, compact and historic city. It is also an historic seat of learning with a very high concentration of highly graded heritage assets. Much of the city is covered by Conservation Area status. The river corridor, green fingers and open spaces, with cows grazing in meadows even at the heart of the city, shape the character of the townscape and landscape.

Although a relatively flat landscape, the elevated positions to the west and south of the Cambridge afford important views across the city skyline, which is one of extensive tree cover and emerging spires. The flatter Fens landscape to the north and east provides very long-distance views of the City and the big east Anglian skies.

The surrounding rural hinterland of South Cambridgeshire comprises over 100 villages, each with their own unique character and heritage. New settlements are an important feature of the district, with their own special identity and are growing rapidly.

We recognise the area faces intense pressure for growth, driven by both the economic success and the attractiveness of the area, in large part a consequence of

its rich architectural and cultural heritage. This growth must be carefully managed to ensure that the very things that contribute to its success are not harmed in the process.

It is for this reason that Historic England is keen to ensure that the emerging plan gives full consideration to the historic environment, both in the choice of site allocations and policy criteria for sites, as well as through a robust and clear suite of historic environment and other policies that seek to both protect but also enhance the historic environment.

We have reviewed the Draft Plan and consultation material with a view to providing advice on heritage matters.

As a general comment, Historic England welcomes emerging plan and work undertaken to date. We have however identified below some of the key issues to be addressed in progressing the next iteration of the Plan: This should be read in conjunction with Appendix A which provides more detailed comments on these and other more minor issues.

a) Site Assessment and the need for Heritage Impact Assessments

We are pleased to note that a degree of site assessment has already been undertaken in relation to the historic environment. These are set out in the HELAA Report, especially Appendix 4.

To date, the assessment of sites is fairly high level and brief but provides a useful starting point, in particular helping to identify immediate showstoppers. We note that many of the sites are shown as amber.

As we have discussed previously, the need for further assessment of heritage in terms of significance, impact on that significance, potential mitigation and enhancements etc will be needed for the site allocations. There is currently an insufficient evidence base in this regard. We therefore welcome your commitment to undertake Heritage Impact Assessments for site allocations. These should be prepared prior to the next draft of the Local Plan.

This further assessment, known as Heritage Impact Assessment (HIA) should follow the 5 step methodology set out in out in our advice note, HEAN 3 on Site Allocations in Local Plans https://historicengland.org.uk/images- books/publications/historic-environment-and-site-allocations-in-local-plans/.

HIAs should be proportionate (both to the scale of the site and the assets affected). All potential sites will need to be appraised against potential historic environment

impacts. It is imperative to have this robust evidence base in place to ensure the soundness of the Plan. We recommend that the appraisal approach should avoid merely limiting assessment of impact on a heritage asset to its distance from, or inter-visibility with, a potential site.

Site allocations which include a heritage asset (for example a site within a Conservation Area) may offer opportunities for enhancement and tackling heritage at risk, while conversely, an allocation at a considerable distance away from a heritage asset may cause harm to its significance, rendering the site unsuitable.

Impacts on significance are not just based on distance or visual impacts, and assessment requires a careful judgment based on site visits and the available evidence base. Cumulative effects of site options on the historic environment should be considered too.

The following broad steps might be of assistance in terms of assessing sites:

• Identify the heritage assets on or within the vicinity of the potential site allocation at an appropriate scale
• Assess the contribution of the site to the significance of heritage assets on or within its vicinity
• Identify the potential impacts of development upon the significance of heritage asset
• Consider how any harm might be removed or reduced, including reasonable alternatives sites
• Consider how any enhancements could be achieved and maximised
• Consider and set out the public benefits where harm cannot be removed or reduced

The HIAs should assess the suitability of each area for development and the impact on the historic environment. Should the HIA conclude that development in the area could be acceptable and the site be allocated, the findings of the HIA should inform the Local Plan policy including development criteria and a strategy diagram which expresses the development criteria in diagrammatic form.

Which sites require HIA?

Ideally all sites should have an HIA, albeit proportionate to the site and heritage sensitivities.

For existing allocations being carried forward into this Local Plan, the HIA is less about the principle of development (that has already been established through previous plan allocation) and more about exploring capacity, height, density and any heritage mitigation and enhancement opportunities so that these can then be

included in the updated policy wording.

For new allocations, the HIA will be a more holistic view and consider both the principle of development as well as the other matters identified above.

b) Policy Wording for sites

If, having completed the heritage impact assessments, it is concluded that a site is suitable for allocation, we would remind you to include appropriate policy criteria for the historic environment in the policy. Please refer to the advice we give on policy wording in the attached table.

It can be helpful to refer to an HIA in the policy wording. Concept diagrams can also be useful to include in the plan to illustrate key site considerations/ recommendations.

c) Edge of Cambridge sites

The Plan proposes carrying forward a number of partially built out allocations on the edge of the City as well as some minor extensions to these. The Plan also proposes revisiting the dwelling capacity/density for some of these sites e.g. Eddington.

Proposals for North East Cambridge are very high density and also quite tall.

The Plan also includes a very large new allocation at East Cambridge (previously released from the Green Belt and allocated in the 2006 Plan, although not in the 2018 Plan). The number of dwellings now being proposed represents a significant increase in density from the 2006 Plan.

We have some concerns regarding these densities and heights on edge of Cambridge sites. Development at very high densities/heights and the potential impact on the overall setting of this historic city. HIAs should give careful consideration to the issue of development and site capacity and height – we will be looking for evidence in this regard.

d) Historic Environment Policy

We welcome your intention to include a policy for the Historic Environment. This should cover both designated and non-designated heritage assets. Policy wording should be in line with the NPPF but we are also looking for a local flavour.

Policies should be spatially specific, unique to the area, describing the local characteristics of the area and responding accordingly with policies that address the local situation.

You should also include a policy for Heritage at Risk and a policy for historic shopfronts. For further detail see Appendix A.

e) Design Policy

We welcome the proposals for a design policy on the plan. We note that this policy is also intended to address tall buildings. We are concerned that the policy might become overly long and detailed, given it is covering such a wide and important range of issues and wonder whether separating out tall buildings into a separate policy might be helpful?

f) Tall Buildings Study and Policy

Related to the above, given the growth pressures that we would anticipate Cambridge is likely to experience over the coming years, we are pleased to see that the matter of Tall buildings and the skyline will be addressed in policy.

We had understood that you were commissioning a study in relation to tall buildings and the skyline policy. Is this still proposed to inform the policy in the next draft of the Local Plan?

See our advice note HEAN 4 and the consultation draft of HEAN 4. Any policy should indicate what considerations are needed for taller buildings, where buildings may or may not be appropriate etc. and in particular consider in the impact on the historic environment.

We broadly welcome policy 60 and Appendix F of the 2018 Cambridge City Local Plan. However, we consider that this could be further supplemented to indicate which areas may or may not be suited to taller buildings. Our advice note in relation to tall buildings provides further guidance in this respect

We have been having discussions with the team preparing The North East Area Action Plan in relation to tall buildings studies and have provided a detailed advice letter in that regard. Please refer to our advice letters in relation to NEA Action Plan and tall buildings for further information on our position.

g) Other Supporting Evidence

We welcome the preparation of the HELAA although consider that further, more detailed evidence is needed in relation to heritage impact and so welcome your intention to prepare HIAs for site allocations.

We broadly welcome the Strategic Heritage Impact Assessment including the baseline study of the setting of Cambridge. However, we have expressed some concerns regarding some aspects of this baseline, in particular the weighting given to some of the key characteristics and aspects of setting of Cambridge including views. Further detail is given in Appendix A.

We welcome the evidence in relation to landscape character assessment. We do however continue to suggest that it would also be helpful to commission Historic Landscape Characterisation work for inform this Plan and future growth in the area.

We welcome the production of the Sustainability Appraisal. We would comment however that since many of the site allocations are grouping together under particular policies, the different impacts for individual sites are not always drawn out in the assessment tables – this sometimes has the effect of neutralising the scoring.

Historic England – Ox Cam research work

Historic England has commissioned consultants to undertake some work looking at development in the OxCam Arc. ‘Measuring Impact: Managing Change’ looks at the question, ‘How should the form of growth in the Oxford-Cambridge arc positively respond to the Historic Environment’. This research is due to report in the next few months and we hope to be able to share this with you at that time as it may provide useful evidence to inform your Local Plan work.

Other comments

In preparation of the forthcoming Greater Cambridge Local Plan, we encourage you to draw on the knowledge of local conservation officers, archaeologists and local heritage groups.

Please note that absence of a comment on an allocation or document in this letter does not mean that Historic England is content that the allocation or document forms part of a positive strategy for the conservation and enjoyment of the historic environment or is devoid of historic environment issues. Where there are various options proposed for a settlement, identification of heritage issues for a particular

allocation does not automatically correspond to the support for inclusion of the alternative sites, given we have not been able to assess all of the sites.

Finally, we should like to stress that this opinion is based on the information provided by the Council in its consultation. To avoid any doubt, this does not affect our obligation to provide further advice and, potentially, object to specific proposals, which may subsequently arise where we consider that these would have an adverse effect upon the historic environment.

We trust that these comments are helpful to you in developing the Local Plan. Should you have any queries, please do not hesitate to contact us.

We suggest it might be helpful to set up a meeting to discuss our comments and, in particular, heritage impact assessments and policy wording for site allocations.
Please feel free to suggest some dates.

Support but would like to see more avoidance by reuse of buildings.

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.

Whilst the HBF and our members understand the need to reduce waste and promote recycling within development we are concerned that such issue need to be set out in a separate statement to support the application. Councils are placing more and more requirements on applicants without having the resources and knowledge to assess these reports or provide the necessary advice and guidance to applicants on such matters. The housebuilding Industry recognises the need for a more circular economy and but any such requirements on such matter must be done through national regulation not through local plans to ensure they are applied consistently across the Country and can be delivered effectively.

Vision and development strategy
Vision and aims
THE VISION
The vision is contradictory, misconceived and undemocratic, unquestioning, unachievable, and based on inadequate evidence. The draft Plan and this whole consultation are premature.

It is contradictory in that the vision of a big decrease in climate impacts is totally undermined by blindness to fundamental incompatibilities between growth and carbon reduction. Its claims of sustainability and Net Zero are not credible given that the carbon costs of construction are not included in the Plan’s definition of a Net Zero Carbon building.

It is misconceived and undemocratic in that it claims to want “the variety of homes and jobs we need” when all the proposed options involve levels of growth dictated by a combination of Government fiat (through both imposed housing targets and four growth corridors led by the Ox Cam Arc) and the ambitions of a local oligarchy (exemplified by Cambridge Ahead) which is unrepresentative of the people of Greater Cambridge. The Arc proposals are in direct conflict with the “levelling up” agenda, will not deliver “levelling up” in terms of Cambridge’s inequalities (notably affordable housing) and should not be taken as justification for the level of growth being proposed (https://smartgrowthuk.org/wp-content/uploads/2021/09/The_Overheated_Arc_Part_3_September_2021.pdf).

The Plan’s “predict and provide” approach fails to even question the desirability or deliverability of this imposed growth. Nor does it begin to tackle the severe challenges arising from past and present growth, notably in terms of affordability (in the most unequal city in England), and transport capacity issues (first identified by Holford 70 years ago), both of which have been exacerbated by growth, and will be further exacerbated, not diminished, by the growth now proposed.

It is unachievable in that
a) it ignores environmental capacity limits, most immediately in relation to water issues, but also in relation to the physical character of Greater Cambridge, and the capacity challenges of accommodating the intense activity of a 21st century city within the built fabric and spaces of a historic University town and its hinterland.
b) its claims to increase nature, wildlife and green spaces rely on a quantum of development that, considered holistically, will have an opposite effect.
c) the Plan’s growth proposals will compound the damaging impacts of current growth on our unique heritage and landscapes.

Its evidence base is incomplete and inadequate. Inexcusably, it has no assessment whatever of environmental capacity (a fundamental issue for the Plan) other than in relation to water supply. The Climate change evidence is inadequate and misleading, notably because it uses a definition of Net Zero Building which omits the embodied carbon of construction. There is no review or assessment of the success or failure of current local plan or other policies. This is compounded by the woefully inadequate historic environment evidence base, which has no strategic consideration of Cambridge as a world famous historic city, and is so incomplete that it only mentions one Conservation Area Appraisal (the Historic Core) when all the city’s Conservation Areas are covered by Appraisals, and fails to use the readily available evidence contained within them.
The draft Plan and the whole consultation are premature pending
1) A thorough understanding and appreciation of the current character of Greater Cambridge and its environmental capacity
2) The forthcoming Water Resources East consultation on the Regional Water Plan, on which these proposals depend
3) Transport solutions which can be accommodated in the space available, including those currently and imminently out for consultation on transport capacity and links within and outside the city.

THE AIMS
The Plan’s aims do not include what is arguably the most vital: how to maintain, enhance, and provide more equitable access to what makes Cambridge special, in the face of the combined challenges of growth and Climate Change. This should be a key priority of the Historic Environment Strategy which is required by the NPPF, but absent from the First Proposals.

As someone from the Tech industry said in a meeting last year with Stephen Kelly, Director of Planning: “Malta has concrete high rises, no one goes there. The Tech sector comes here because it’s a nice place to be. If Cambridge takes a predict and provide approach, it will accelerate into catastrophe.”

How much development, and where – general comments
No more development allocations until issues arising from existing approved growth have been identified and tackled. This means waiting for the Regional Water Plan and coherent publicly-endorsed proposals for tackling existing congestion and capacity issues, challenging the assumptions underlying the Ox Cam Arc, and carrying out a holistic assessment of environmental capacity and the limits to growth. All in line with the principles of Doughnut Economics which the City Council says that it has adopted.

The evidence base is seriously inadequate in relation to environmental capacity. There is no evaluation of the success or failure of existing policies in maintaining the special character of Cambridge, an aim which the new Plan seeks to maintain. Such consideration needs to include not only impacts of the form, scale and location of new development, but also of the transport and other infrastructure required by it. Current growth is putting massive, and unresolved pressures on the capacity of existing transport links, and the physical capacity of Cambridge’s roads system and public realm.

The GCP’s Making Connections proposals, currently under consultation, attempt to resolve some of the challenges, but have no detailed assessment of the capacity of Cambridge’s streets to take the extra volumes of bus and cycle traffic being proposed. Given that Cambridge’s congestion problems are historic, and compounded by growth, this consultation on Local Plan proposals for additional growth is premature in the absence of credible and detailed proposals to tackle current capacity issues.
S/DS: Development strategy
How can the proposals aim for net zero with this sheer volume of proposed development (while whole-life costing of large new proposals is welcome, what about the carbon cost of developments in the pipeline? - see above and comments on CC/NZ below).
No mention of impacts of transport links required for these proposals. Need to ensure that these are brought forward in concurrently with the Local Plan proposals.
Cambridge urban area
Cambridge urban area - general comments

Massive environmental capacity issues, with inadequate space in City streets and public realm to cater for existing traffic, let alone approved growth already in the pipeline – even before considering these First Proposals. The capacity issues have to be tackled, with additional growth allowed only if they can be resolved.

No mention of Covid and opportunities for city centre residential / other uses resulting from potential radical changes in retail.
No new cultural or provision for other “city-scale” needs, so putting the city centre under even greater pressure.

S/NEC: North East Cambridge
Vividly illustrates the issues. Gross over development.
Edge of Cambridge
Edge of Cambridge - general comments
The Green Belt assessment is not fit for purpose, because it ignores historic environment designations and landscape character constraints.

This highlights a vital flaw of the Plan, its failure to take a holistic view of the combination of different elements (including historic and natural environment) which make up the character of Greater Cambridge. The Government may have tried to artificially separate the natural and built environment with its Environment Act, but that doesn’t mean this approach should be followed in Cambridge!

Climate change
Climate change - general comments

The definition of a Net Zero Carbon building set out in the Evidence Base does not include its embodied carbon: this is a very serious omission which undermines all claims made about the sustainability of new development, and raises questions about the claimed sustainability credentials of all the Growth options being proposed.

Already out of date in terms of Government targets (e.g. the Heat and Buildings Strategy, not mentioned in the draft Plan), and rapidly developing guidance and best practice.
Support regular reviews to keep pace with developing technology, standards, Government targets (e.g. the Heat and Buildings Strategy, not mentioned in the draft Plan), and rapidly developing guidance and best practice. There are also serious quality control challenges in relation to whether aspirational aims are actually delivered. How will this be done? Outline planning permissions must be subject to the aspirations articulated in draft local plan. How will this be done?
Projects proposed to help achieve net zero need to be both delivered and SAFEGUARDED, throughout the Plan period, to ensure that the aims are delivered (e,g, need to ensure that biodiversity / natural capital / “doubling nature” (sic) and any other such schemes are protected from subsequent inappropriate changes of use or management)
Agree that development should be located so that low carbon transport links can be accessed. However, such locations should not be chosen based on proposed busways – the delivery of these is uncertain and their construction generates carbon emissions through the embodied carbon in the building materials, tree felling reducing carbon capture, maintenance and serving works, and lighting, contrary to the Council’s net zero carbon agenda.

CC/NZ: Net zero carbon new buildings
The definition of a Net Zero Carbon building set out in the Evidence Base does not include its embodied carbon: this is a very serious omission which undermines all claims made about the sustainability of new development, and raises questions about the claimed sustainability credentials of all the Growth options being proposed.

Support recognition of embodied carbon, also whole life carbon (see CC/CE). build for future re-use, including requiring use of lime mortar not cement to enable re-use of fired and quarried materials.

Where possible, existing buildings should be re-used (“The greenest building is the one that already exists”– Carl Elefante https://www.architectsjournal.co.uk/news/opinion/the-greenest-building-is-the-one-that-already-exists quoted in the Architect’s Journal Retrofirst campaign https://www.architectsjournal.co.uk/news/opinion/join-our-retrofirst-campaign-to-make-retrofit-the-default-choice)

Require whole-life assessments whenever demolition of an existing building is proposed. (e.g. false net zero claims made for new Kings College development on Barton Rd – no mention of the embodied carbon of the buildings demolished to make way; same applies to the Flying Pig replacement) .

CC/CE: Reducing waste and supporting the circular economy
Support recognition of embodied carbon, also whole life carbon (see CC/CE). build for future re-use, including requiring use of lime mortar not cement to enable re-use of fired and quarried materials.

Where possible, existing buildings should be re-used (“The greenest building is the one that already exists”– Carl Elefante https://www.architectsjournal.co.uk/news/opinion/the-greenest-building-is-the-one-that-already-exists quoted in the Architect’s Journal Retrofirst campaign https://www.architectsjournal.co.uk/news/opinion/join-our-retrofirst-campaign-to-make-retrofit-the-default-choice)

Require whole-life assessments whenever demolition of an existing building is proposed. (e.g. false net zero claims made for new Kings College development on Barton Rd – no mention of the embodied carbon of the buildings demolished to make way; same applies to the Flying Pig replacement) .

Incredibly, no mention of retrofit in the Climate Change topic paper! The Council’s apparent view that retrofit is not within the scope of the Plan is mistaken. The only place in which retrofit is mentioned, and far too narrowly, is in policy GP/CC in the Great Places paper. This is one of several instances where a holistic approach should require read-across between Policies in different sections (e.g. also between historic environment and natural environment).

Retrofit will be within the direct scope of the Plan (guiding planning decisions) whenever it involves works which could potentially require planning permission or listed building consent.
[Case in point is the new Institute for Sustainability Leadership building (conversion of former telephone exchange) on Regent St. Major impact on appearance of building which makes (or made) a positive contribution to the Conservation Area, not a heritage asset but requiring planning permission. The submitted justification included every possible assessment criterion apart from townscape / heritage impact (shockingly not even considered by the applicants!). What has been approved and is now being built involved losing the window detailing which was a key part of the building’s character. Since that scheme was approved, PAS 2038 (non-domestic retrofit guidance) has come into force: it would have required a more comprehensive approach by the applicants, and might have led to a different decision. ]

Retrofit is also within the scope of the Sustainable Design and Construction SPD, which needs to be updated to include embodied carbon, over the whole life cycle of construction (including retrofit and refurbishment), as set out in British Standard BS EN 15978:2011:
SEE ATTACHED
(slide by Alice Moncaster)

This Climate Change section should include specific policies covering retrofit, which will feature ever more strongly as Govt targets for Band C etc bite. These targets present serious challenges now, and will get ever more serious during the Plan period, with high risks of carbon (and money) being wasted on inappropriate works. Yet Net Zero Carbon for existing buildings is mentioned only cursorily, on a single page (35) of the Local Plan’s Net Zero Carbon Evidence Base.

There is no mention whatsoever of the need for a different approach to buildings of traditional solid wall construction. These form at least a quarter of the existing stock; this proportion should have been considered and assessed as part of the Evidence Base. It could even be as high as 35%, the proportion quoted in the BRE study “Solid wall heat losses and the potential for energy saving” published by DECC in 2015.

The specific challenges of traditional buildings , and the risks of unforeseen consequences (and of consequent waste, rather than saving, of carbon and money) are highlighted in PAS2035, the Government’s guidance on domestic retrofit, which is referenced in Policy GP/CC. However the reference to PAS 2035 in the Policy is futile in its draft form because the PAS (although Government guidance) is not freely available, but published by the British Standards Institute, costing £190, and so is inaccessible to home owners and others who need the guidance.

The Climate Change section of the Plan should quote key principles and guidance* from PAS 2035 and its non-domestic counterpart PAS 2038 (and reference other freely available advice including from the STBA and IHBC as well as the Government’s own guidance to Private Sector Landlords) in sufficient detail to ensure that people dealing with ALL traditional buildings (not only heritage assets) have access to the appropriate advice and skills to ensure that their buildings are put in good repair, and then suitable retrofit measures are applied as appropriate. See https://stbauk.org/whole-house-approach/. This is essential to achieve the aims of the PASs and to minimise unintended consequences.
*including (e.g.) section 0.1.1 of PAS 2035:
SEE ATTACHED

Biodiversity and green spaces
Biodiversity and green spaces - general comments
Serious environmental capacity issues (see above), particularly in relation to intensification of pressures on green spaces..

BG/BG: Biodiversity and geodiversity
Projects proposed to help achieve net zero need to be both delivered and SAFEGUARDED, throughout the Plan period, to ensure that the aims are delivered (e,g, need to ensure that biodiversity / natural capital / “doubling nature” and any other such schemes are protected from subsequent inappropriate changes of use or management)

BG/GI: Green infrastructure
Flawed in that green infrastructure and historic environment re considered separately (see comments on Edge of Cambridge, River corridors, and Protecting open spaces). A holistic approach is essential – see NPPF definition of the historic environment..

BG/RC: River corridors
The River Cam Corridor initiative does not mention the historic environment, historic environment designations, or conservation area appraisals. High risks of more intensive use. no mention of environmental capacity issues or recognition that there may be capacity limits to growth or access by either/both local people and visitors (impacts of punt operators on Cam, etc). No mention of historic environment designations. No consideration of areas under particular threat. No consideration of historic / characteristic uses and land management. The whole river corridor from Byron’s Pool to Baits Bite, and its historic uses are vital parts of the historic and cultural as well as landscape character of Cambridge and should be safeguarded. Grantchester Meadows, one of the key river corridor historic and cultural spaces, is the only vital section of the corridor currently without Conservation Area designation; it is currently threatened by visitor pressures and by possible removal of the grazing cattle which play a vital part in traditional water meadow management.

BG/PO: Protecting open spaces
No mention that many open spaces are historic, and form part of the historic environment (see NPPF definition of the historic environment) need to consider their significance as a whole, not just in terms of green infrastructure. Historic environment and local identity are vital elements of the wellbeing identified here

BG/EO: Providing and enhancing open spaces
Open space is not just green space - what about the market square, Quayside etc etc? Need to manage existing pressures, and avoid harmful intensification of use, on all open spaces, and ensure that new development does not increase these pressures. The river corridor is particularly vulnerable.


Wellbeing and inclusion
Wellbeing and inclusion - general comments
There are no documents in the Document Library to support this theme. Why not?

The Topic Paper highlights the importance of place and space, but its text is focused on new developments, and does not mention the contribution made to wellbeing by the beauty and special character of existing places, including the city of Cambridge, the towns and villages, and valued countryside. The historic environment is a vital part of wellbeing.

Nor is Covid mentioned, even though the pandemic has highlighted the vital importance of access to local green space, and to local fresh food. Small local producers have continued to provide when the supermarkets supply chains fail. Cambridge market, and the local producers who sell from it, continues to provide a lifeline of health and wellbeing for many people, as well as providing vital opportunities for business start-ups including makers as well as food sellers.

There is no assessment of existing cultural activities, of current demands for space, or of demands for new space arising from either existing approved growth or that now proposed. Nor is there any assessment of related opportunities in terms of under-used retail space post-Covid. This is a totally inadequate baseline for a credible Plan.

The forthcoming Cultural Infrastructure Strategy for Greater Cambridge will need to recognise Cambridge’s international cultural significance in terms of both its historic environment (which meets UNESCO’s Outstanding Universal Value criteria for World Heritage sites), and its past and present cultural activities. The Local Plan should include policies to protect this significance, and specifically to support cultural activities, and to provide for, and safeguard, public and private spaces for arts and other activities.

Great places policies
Great places – general comments

The Great Places paper refers to Heritage Assets, but completely fails to recognise that the city of Cambridge is a heritage asset of worldwide significance which meets UNESCO’s Outstanding Universal Value criteria for World Heritage status. This significance derives from the combination of its built and natural heritage. The draft Plan fails to recognise the vital role which this special character plays in making Cambridge a great place to live in, work, study, and visit.

The draft Plan also fails to recognise the historic relationships between Cambridge as a market town, its market, and its productive hinterland.

The draft Plan’s approach involves a false separation between Landscape and Townscape (Objective 6) and Historic Environment (Objective 7), which for Cambridge has resulted in inadequate consideration and valuation of the historic city in its historic landscape setting, with historic landscape and open spaces considered as green infrastructure but not as historic environment.

Cambridge’s special character has been, and continues to be, under severe threats from the quantum of already approved growth (built developments and pressures on both streets and green spaces). There are severe environmental capacity issues in trying to accommodate the demands of a 21st century city within what remains the built fabric and spaces of a medieval market town. These fundamental conflicts between growth on the one hand and environmental capacity and special character on the other should have been recognised as a key challenge for the draft Local Plan. so why wasn’t the Historic Environment Baseline Study prioritised, and published as part of the Nov 2020 tranche?

But the draft Plan documents include no assessment of current pressures, let alone the impacts of the draft First Proposals.

Instead, para 3.2.4 of the Strategic Heritage Impact Assessment: baseline makes a totally unevidenced statement that:
“3.2.4 Future growth in Cambridge has the potential to strengthen and reinforce these characteristics, enabling the City to meet contemporary environmental, economic and social drivers without undermining its economic identity".

Overall, the Evidence base for Great Places is inadequate, and the proposals are premature pending a thorough review of the success or failure of existing policies.


GP/LC: Protection and enhancement of landscape character
Over-intensification of use is a major threat to landscape character.

GP/GB: Protection and enhancement of the Cambridge Green Belt
I strongly support protection of the Green Belt, but the Green Belt assessment is not fit for purpose, because it ignores historic environment designations and landscape character constraints.

The Council appears to have forgotten that the Green Belt was set up to protect the setting of the historic University city.

GP/QP: Establishing high quality landscape and public realm
Serious issues of street capacity.

GP/HA: Conservation and enhancement of heritage assets
A vital issue given totally inadequate consideration and priority. The historic environment (not just heritage assets) is a vital part of Cambridge, not just in terms of Great Places, but also for Wellbeing, and for the city’s prosperity.

The historic environment, and its capacity (or not) to withstand existing growth (let alone new growth proposed) should have been considered at the start of the Great Places chapter. Understand what you have, then consider its capacity for change
Fails to consider anything other than designated heritage assets. No consideration of heritage significance of Cambridge as a whole, or of the heritage significance of undesignated buildings, spaces, and intangible heritage –notably Cambridge’s market, which pre-dates the University, and Grantchester meadows.
The Heritage Impact Assessment is not fit for purpose, and clearly written by consultants who have limited knowledge of Cambridge, and of issues, policies, and initiatives relating to its historic environment. There is no mention of any Conservation Area appraisal apart from the Historic Core, and no cumulative assessment of significance and issues identified in these Appraisals.
.
The “Strategic Heritage Impact Assessment: baseline” is woefully inadequate in both its scope and its approach:
a) In its scope, because it confines itself to stages 1 (identify the historic assets” and 2 (“define and analyse the settings”) of Historic England’s ”Settings of Heritage Assets: Good Practice Guide”, without considering the dynamic of the city as a whole, what has been happening in its recent years, or the potential impacts of currently approved growth. It is almost as if the Council asked for an updated version of the 1971 publication “Cambridge Townscape”, whilst completely disregarding the award-winning conservation plan approach of the 2006 Historic Core Appraisal which sought to understand not just the physical character of Cambridge but its dynamic, and threats and opportunities, as part of shaping policies.

b) while the document references the Historic Core Conservation Area Appraisal, it does not even mention other Conservation Area Appraisals (ignoring the complete Appraisal coverage of the City's Conservation Areas) or issues and opportunities identified therein. Nor does it mention the Suburbs and Approaches Studies. It is all too clear that the consultants have taken only a superficial look at the baseline information.

c) I would have expected consultants preparing this “high level” document to consider the historic environment, and the extent of designations, strategically (a great opportunity for this combined Plan) - but the document does not even consider the extent to which Cambridge’s historic and cultural landscape (including the river corridor from Byron’s pool to Baits Bite Lock) is or is not protected.

d) The study completely fails to assess the significance of Cambridge as a whole. Dennis Rodwell’s “Conservation and Sustainability in Historic Cities” puts Cambridge on a similar level of international significance to Venice.

e) For the options involving development in and adjacent to Cambridge, it seems to assume that most problems can be resolved by Design, completely ignoring environmental capacity issues. At a most immediate level, what if any detailed assessment has been made of the wider visual impacts of tall buildings on the North-East Cambridge site?

There are fundamental environmental capacity issues in terms of pressures on the character and spaces of the historic core and surrounding landscape, due to not only the additional volumes of development, people and traffic being generated by the proposed additional growth, but all of these arising from existing approved growth plus the transport links required to enable it.

There is no assessment whatever of the cumulative impacts on landscape, townscape and environmental capacity of all the GCP and other proposals including busways, City Access, Greenways, Active Travel schemes etc.

A third-party, holistic overview is essential to identify and try to resolve some of these key strategic issues and balances, and consider to what extent further growth is viable. In relation to heritage, growth is seriously threatening what makes Cambridge Special. I suggest that Historic England’s Historic Places Panel are invited to visit Cambridge and provide strategic recommendations which can inform the Local Plan.

The flaws in the current approach are exemplified by a claim in the Strategic Heritage Impact Assessment: baseline:
“3.2.4 Future growth in Cambridge has the potential to strengthen and reinforce these characteristics, enabling the City to meet contemporary environmental, economic and social drivers without undermining its economic identity"
This statement can only be described as unevidenced, shockingly ignorant and ludicrously complacent.
Moving from strategic issues to safeguarding individual heritage assets and their settings, there are serious questions in relation to the effectiveness of existing policies which are proposed to be carried forward.

A case in point is the former Mill Road Library a grade II listed building of high public significance, which was recognised to be “at risk” but ignored by both the City and County Councils during the development and approval of the City’s Depot site redevelopment. This was a massive opportunity which would not have been missed had the City complied with its own Local Plan policy regarding heritage assets. While the County has belatedly refurbished the former Library, it has not been integrated as a public building within the new development. It appears that the County may now be offering this public building, built for the public, for private sale!

GP/CC: Adapting heritage assets to climate change
This policy is basically very good -but should relate to all buildings of traditional construction, and needs some updating. Needs direct read-across to CC/NZ. See my comments on CC/NZ.
Supporting documents on which we are consulting
Sustainability Appraisal (incorporating the requirements of the Strategic Environmental Assessment)

The Sustainability Appraisal fails to tackle the key environmental capacity issues arising from existing growth, let alone that now proposed.

The whole definition of “Sustainable Development” is too narrow given that since 2010 the UN has included Culture as the 4th pillar of Sustainable Development - and Cambridge's historic environment is a cultural asset of worldwide significance.

Within the current UK sustainability assessment process (dating from 2004 and excluding culture), there is a separation between Landscape and Townscape (Objective 6) and Historic Environment (Objective 7), which for Cambridge has resulted in inadequate consideration and valuation of the historic city in its historic landscape setting, with historic landscape and open spaces considered as green infrastructure but not as historic environment.

This should be key to all development and this could go further in terms of sustainability
We endorse net zero carbon in new builds and this should be a priority.
We are concerned about the lack of water in South Cambridgeshire so water efficiency is a priority.
A priority for all developments. Further research needs to be undertaken to understand the future challenges we face.
A priority for all developments
A priority for all developments we need to keep ahead of new renewable technologies and review these yearly.
Key. (See document)
Key

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:
• The submission of a Construction Environmental Management Plan (CEMP) proportionate to the size and scale of development
• Provision of adequate waste and material storage facilities on site in accordance with the RECAP Waste Management Design Guide (or successor)
• Submission of a Circular Economy Statement with each application.
Countryside 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, reducing waste is one of our key objectives and one in which progress is clearly being made on our sites.
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.
With respect to the provision of waste management facilities on site, Countryside 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 Countryside 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.
With respect to the submission of a circular economy statement, Countryside 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.