Draft Greater Cambridge Local Plan for consultation

Criteria 7 of the draft policy is deemed too onerous and not proportionate to the existing Cambridge context. The AQMA (designated due to NO2 emissions) was revoked in January 2025. The draft policy likely seeks to avoid any future designations but the current wording is unduly onerous given the latest pollution context. Annual Monitoring data published by the Council shows notable improvements in all monitored pollutants. The Summary of the 2025 annual report confirms ‘There were no measured exceedances in national air quality target annual means for NO2 (40 µg/m3), PM10 (40 µg/m3) and PM2.5 (10 µg/m3). This trend was consistent across the entire monitoring network, including both automatic monitors and diffusion tubes. This improvement is likely due to a combination of factors rather than a single cause, but overall, it represents a positive trend in air quality and public health’. Cambridge also benefits from excellent monitoring data with DEFRA identifying 6 monitoring sites as of 15/01/2026 (Cambridge 2025 annual report noting 5) to reassure that this remains the case.

In this context, a requirement for an air quality statement for all major and minor planning applications is not proportionate and contributes unnecessary cost and burden on applicants, as well as the authority in processing and determining applications.

The policy should instead require an air quality assessment in two scenarios:

1. to accompany any planning applications that warrant a Transport Assessment (whether due to construction or post operation thresholds) given that the major contributor to NO2 and other pollutants is vehicular traffic. Indeed this correlation will continue to decrease with continued promotion of sustainable modes of transport and the adoption of electric vehicles, as the Council’s own Air Quality Annual Status Report shows. As such, it is expected that even this threshold would warrant revisiting as part of the next Plan Review; and
2. Where a major planning application will involve a proposed industrial use with known emissions.

The provision of a more concise air quality statement has limited if any value and is not justified. It is noted that other pollutant contributors such as wood burners are regulated through different mechanisms and announced changes to regulations will further improve the air quality context.

Overall, the draft policy aligns with the ARU Design Principles document. However, there are certain issues with the draft policy wording that warrant further attention as follows:

1.Part B: Total Energy Use Intensity (EUI): vii. Higher education teaching facilities: Equivalent to the UK Net Zero Carbon Buildings Standard 2030 targets (and sub-typologies where available).

Whilst a future planning application may be for a higher education teaching facility (i.e. use class F1), any such proposal can in fact include all manner of sub-categories when assessed against net zero criteria. For instance, space that may be more akin to office space or more energy intensive labs or medical facilities, despite the principal use remaining as education. It is consequently crucial that this policy isn’t interpreted by simplistic use class but instead based on which sub-typology best applies to different extents of the proposed floorspace. It is suggested that this approach should be clarified within the supporting text for the avoidance of doubt.

2. Part C: Energy performance/Onsite Renewable Energy.

It must be recognised that buildings with more than 2 floors are unlikely to be able to meet all their energy demands from on-site generation, which in Cambridge will predominantly mean solar PV. Taking the 87 kWh/m2/yr 2030 EUI figure from the UK Net Zero Carbon Buildings Standard and assuming energy generation of 0.3 kWh per m2 of solar panels (equivalent to 800 kWh per kW installed), it would be impossible for a building of 3 floors or more to generate sufficient energy to meet all its demand, even with the entire roof covered with solar PV. Whilst Part C does state ‘where possible’, ARU is concerned that this draft policy wording would impose an unrealistic expectation, particularly on larger developments. Part C should consequently be updated to simply read ‘Proposals must seek to maximise opportunities to generate on-site renewable energy to serve the development’.

3. Part D: Energy Offsetting and Assured Performance.

Given that ARU (and other energy users) are already funding the installation of new renewable power generation through their electricity bills, the introduction of a local energy offsetting scheme would seem to duplicate this. ARU propose that renewable energy procurement is included within this policy as a route to achieve net zero carbon buildings, as it is within the UK Net Zero Carbon Buildings Standard used for Part C of this policy.