Greater Cambridge Local Plan Preferred Options

Water
We have yet to see data to evidence that Eddington as a benchmark development on sustainability is succeeding in maintaining water usage to 100 litres/person/day. We have asked for this data which we would expect to be available, but as yet have not seen the evidence.
We would like to know how the greywater will be managed and how much land use will be required to support an increase in 1000-1500 housing units.

Medical Centre
It is imperative that the medical centre and pharmacy are provided on site for the existing population of Eddington. We are concerned that Eddington cannot support an increase of housing 1000-1500 without this facility. We understand that the physical building is available, but the delay is with NHS provision. This needs to be resolved before consent is given to a further 1000-1500 dwellings.

Primary School at Eddington
We understand that the purpose-built primary school which was primarily built to support the new population at Eddington is now over-subscribed and residents of Eddington are not being provided with places. This needs to be resolved if the population of the Eddington district is to increase by 1000-1500 dwellings.

Affordable Housing
The First Proposals state that “The North West Cambridge Area Action Plan requires a minimum of
50% affordable housing to meet the needs of Cambridge University and College key workers in housing need”. We presume that the comment on page 83 of the First Proposals, “If need is not demonstrated, provision should be in the form of normal affordable housing” means that in this eventuality only 40% of the new homes would be ‘affordable’. We believe that all new developments over a certain size should provide a minimum of 50% affordable housing and ask that this loophole be taken out (see further comments under H/AH).

Ecologically Sensitive Area within the land parcel known as 'The 19 acre field' - private market housing development site
We ask for clarification on the status and proposed use of the area generally described as an ecologically sensitive area and which has had informal signage displayed for many years not permitting public access.
Will this area be opened for public access? If so, we would ask for safeguards to prevent any resultant threats to the wildlife or environment. We welcome initiatives to increase people’s access to quality green space; however if this is indeed an ecologically sensitive area we would be concerned that use could lead to a decline in the condition of the habitat.

Cambridge Biomedical Campus
In line with our overall comments on the scale of growth planned for Greater Cambridge, we do not support the expansion of the campus. A priority for us in this area is the protection of Nine Wells nature reserve, including indirect impacts from development adjacent to the site itself.

To date, Cambourne has grown rapidly but with a lack of strategic planning, leading to a deficit in infrastructure. We therefore broadly welcome the policy direction set out here and look forward to the further development of plans to achieve the stated aims.

Northstowe
We share the strong concerns expressed by residents of Longstanton and others about the impacts of building to date on local water tables. A Hydrogeological Assessment commissioned by Longstanton Parish Council [1] concluded that local land use change as a result of the development of Northstowe is the most significant impact on the local groundwater elevation. Initial construction at Northstowe lowered the water table to such an extent that ponds have dried out. The development has changed the recharge of local groundwater features and it is unclear whether they will recover. We call for no further building at Northstowe until this issue is fully resolved. We also call for tighter enforcement of the environmental standards the developers are required to meet - our local members describe them as currently ‘getting away with the bare minimum’, resulting in a settlement that is far from sustainable.
[1] http://www.longstanton-pc.gov.uk/ UserFiles/Files/Reports/202105HRWallingfordReport3-
reduced.pdf

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

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

We welcome the proposed policy direction but feel the policy needs to be strengthened at a number of points as explained below. As a broader point: we welcome the ambition shown in applying more rigorous
standards than existing national schemes (such as BREEAM), but have concerns about how this will be
delivered in practice. We look forward to further information on how the Planning Authority, Building Control and other departments will work together to ensure effective delivery of these policies. We are pleased to hear that the Planning Authority currently intends that the policy will apply to minor developments (to be confirmed at later policy stages), and will consider applying the policy to temporary buildings on a case-by case basis.
● Embodied carbon. The recognition of embodied carbon is positive but does not go far enough. 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.
● Retrofit first. A report by the US National Trust for Historic Preservation [1] concluded that “reusing an existing building and upgrading it to be as efficient as possible is almost always the best choice regardless of building type and climate”. Before any new build is undertaken, consideration must be given to reuse of existing buildings. The policy should require a whole-life carbon assessment whenever demolition of an existing building is proposed. This would enable a carbon pay-back time to be calculated: how many years will it take for the carbon savings achieved in a more efficient building to offset the carbon losses incurred in demolition and construction? (see also under Climate Change ‘general comments’ for further discussion about retrofit)
● Use of sustainable materials. Where new build is necessary, the choice of materials must consider their embodied carbon and broader sustainability credentials, as well as their insulating properties. Reuse and recycling of materials should be favoured. The use of timber from sustainably managed (ideally UK) woodland should be promoted. Lime mortar should be used instead of cement wherever possible. Finally, buildings should be designed for longevity.
● Offsetting. We welcome the conditions set out under ‘Part D’ (page 146) that limit the use of offsetting. It is important that offsetting is genuinely a last resort and is not used by developers to avoid meeting net zero requirements on-site. The carbon accounting for any offsetting schemes applied must be rigorous and transparent.
[1] https://living-future.org/wp-content/uploads/2016/11/The Greenest Building.pdf

Water supply has emerged as a key issue for stakeholders during this consultation. We have discussed this in our response to the ‘Vision and Development Strategy’ section. Relevant to the current section: improving water efficiency is vital but is highly unlikely to result in an overall reduction in water use in the face of the proposed levels of development. Our comments below must be taken in this context.
We welcome the ambitious target set for water efficiency and the incorporation into this policy of the findings of the Greater Cambridge Integrated Water Management Study (2021): water efficient fixtures and fittings, water reuse, surface water, greywater integrated on site. We look forward to further detail on how achievement of this target will be enforced and monitored.
We are not clear to what extent wastewater management falls within the remit of the Local Plan. However, sewage management, including separation of surface water drainage from sewers, is a critical element of sustainability for new developments and we would like to see more information on this, or signposting to where such information exists. Similarly, although it is stated that water supply is not within the remit, the importance of “making full use of water re-use measures on site including rainwater harvesting and grey water recycling” is acknowledged. Again we would like to see details of how this will be achieved. Ideally we feel that rainwater harvesting and grey water use in new developments should be mandatory and designed in from the start.

We support the proposed policy direction. We would highlight the need to consider the impact of extreme weather events on existing buildings as well as new ones (tying into our comments about retrofit), and also the need for buildings (and features such as green roofs) to be kept in good condition.

We broadly support the proposed policy direction.
We welcome the statement that “Flood management policies will require that the risk of flooding is not increased elsewhere as a result of new development”. To achieve this it will be essential to assess the cumulative impact of development at catchment level.

We feel this is a highly important policy area, given the potential for landscape impacts. We broadly support the proposed policy direction and look forward to seeing further detail as the plan progresses.