Policy 4a: Water Efficiency

Showing comments and forms 1 to 7 of 7

Support

Draft North East Cambridge Area Action Plan

Representation ID: 53716

Received: 04/10/2020

Respondent: Ms Clara Todd

Representation Summary:

YES.

Full text:

YES.

Object

Draft North East Cambridge Area Action Plan

Representation ID: 53737

Received: 04/10/2020

Respondent: Mr Jon Pavey

Representation Summary:

The cost of the water supply / plumbing systems for most, if not all, non-residential developments will be a very small element of the overall building development and operation costs. An economically viability test leaves open the opportunity for spurious challenges to achieving the BREEAM 5 credit standard. It dulls innovative thinking and shifts the burden (and cost) of the water resource challenge to users of the environment (boaters, nature lovers, wildlife, Cambridge Water). This is an unacceptable let-out.
The BREEAM 5 credit standard does not preclude developments which depend on industrial levels of water use, but requires significantly lower usage levels than the baseline. In a water stressed catchment like the Cam, this is not an unreasonable ask. And if it cannot be achieved at what the developer considers to be at an economic cost, it is better for all of us if that particular type of development was sited elsewhere - where water stress is not an issue.
Therefore "or economically viable" should be removed from the phrase "unless it can be demonstrated that such provision is not technically or economically viable".

Full text:

The cost of the water supply / plumbing systems for most, if not all, non-residential developments will be a very small element of the overall building development and operation costs. An economically viability test leaves open the opportunity for spurious challenges to achieving the BREEAM 5 credit standard. It dulls innovative thinking and shifts the burden (and cost) of the water resource challenge to users of the environment (boaters, nature lovers, wildlife, Cambridge Water). This is an unacceptable let-out.
The BREEAM 5 credit standard does not preclude developments which depend on industrial levels of water use, but requires significantly lower usage levels than the baseline. In a water stressed catchment like the Cam, this is not an unreasonable ask. And if it cannot be achieved at what the developer considers to be at an economic cost, it is better for all of us if that particular type of development was sited elsewhere - where water stress is not an issue.
Therefore "or economically viable" should be removed from the phrase "unless it can be demonstrated that such provision is not technically or economically viable".

Comment

Draft North East Cambridge Area Action Plan

Representation ID: 54707

Received: 05/10/2020

Respondent: Cam & Ely Ouse Catchment Partnership

Representation Summary:

Cambridge is a global city and a centre for world research and development, particularly in the fields of health and life sciences. As such, the Cam and Ely Ouse Catchment Partnership recognises the need for growth planned within the North East Cambridge Area Action Plan. However, Cambridge faces significant water challenges and any water committed to supplying development within the North East Cambridge Area Action Plan will be being taken from an environment currently under pressure. The Cam and Ely Ouse Catchment Partnership therefore fully supports the use of the most stringent water efficiency standards for both residential and non-residential development, considering the 80 litres/person/day standard outlined in Policy 4a as the necessary target to work towards site sustainability.

Full text:

Cambridge is a global city and a centre for world research and development, particularly in the fields of health and life sciences. As such, the Cam and Ely Ouse Catchment Partnership recognises the need for growth planned within the North East Cambridge Area Action Plan. However, Cambridge faces significant water challenges and any water committed to supplying development within the North East Cambridge Area Action Plan will be being taken from an environment currently under pressure. The Cam and Ely Ouse Catchment Partnership therefore fully supports the use of the most stringent water efficiency standards for both residential and non-residential development, considering the 80 litres/person/day standard outlined in Policy 4a as the necessary target to work towards site sustainability.

Object

Draft North East Cambridge Area Action Plan

Representation ID: 55665

Received: 02/10/2020

Respondent: St John's College

Agent: Savills

Representation Summary:

The draft policy states that “Proposals for non-residential development must achieve 5 BREEAM credits for water use (Wat 01), unless it can be demonstrated that such provision in not technically or economically viable”.

Current applications 20/03523/FUL (South Cambs) and 20/03524/FUL (Cambridge City) for Phase 1 at the St John’s Innovation Park will achieve 4 of the 5. The reason that 5 credits are not being targeted at this stage is due to the limitations of roof area available for rainwater harvesting on building 1 plus the additional sanitaryware fittings that would be included in the transport hub. As such the required flow rates to achieve a 55% reduction could be prohibitive from a performance perspective”.

It is agreed that a more ambitious target than the existing Local Plan target of 2 of the 5 should be included, but to enable balancing of different considerations, 4 out of 5 should be the minimum.

Attachments:

Comment

Draft North East Cambridge Area Action Plan

Representation ID: 55747

Received: 05/10/2020

Respondent: Brookgate

Agent: Bidwells

Representation Summary:

Neutral:
Policies 4a, b and c set standards and expectations for development across all
water related issues.
Brookgate broadly support these policies from a climate change resilience and in-combination
climate change impacts perspective. However, Policy 4c needs to be
aligned with Environment Agency guidance on climate change allowance:
(https://www.gov.uk/guidance/flood-risk-assessments-climate-change-allowances).

Attachments:

Comment

Draft North East Cambridge Area Action Plan

Representation ID: 55952

Received: 05/10/2020

Respondent: Natural England

Representation Summary:

The Cambridge water environment is under significant pressure from the demands of the existing
population. Groundwater abstraction to supply drinking water combined with surface and
wastewater discharges are impacting on groundwater levels, river flows and water quality; this is
already having an adverse effect on the natural environment, including several statutorily
designated nature conservation sites. Given the severity of the existing situation any new
development, including through NECAAP, will need to demonstrate, as a minimum, that water
supply and surface and waste water disposal demands can be met without further detriment to
groundwater levels, river flows and water quality. As a minimum development should seek to
achieve no further deterioration, however, the aim of any further development should be to reduce
these impacts and, as far as possible, deliver improvements in groundwater levels, river flows and
water quality. Proposed development will also need to ensure and demonstrate sustainable
drainage and flood risk management. These complex issues and deliverable solutions will need to
be addressed through the Integrated Water Management Study / Water Cycle Study (IWMS /
WCS) being undertaken to inform the Greater Cambridge Local Plan.
Whilst targets and requirements outlined in policies 4a -c are welcomed these policies should be
informed by the findings and recommendations of the IWMS/WCS. Any measures to mitigate
adverse environmental impact will need to be detailed and their viability assured, through the AAP.
Their delivery will need to be secured through robust policy requirements.

Attachments:

Comment

Draft North East Cambridge Area Action Plan

Representation ID: 56137

Received: 05/10/2020

Respondent: U+I PLC.

Agent: We are Town

Representation Summary:

We want to achieve the 110lpppd target and go further but there must be a level playing field in NEC and across Greater
Cambridge in general. Rainwater harvesting and greywater provisions need to be planned in now so that they can be built
into the masterplanning. Feasibility work underway but AAP must reflect demands of potential landtake and loss of
developable area.
More consideration needs to be given to external demands eg irrigation. And encourage use of water recovery systems
on site.

Attachments: