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Comment

Draft Greater Cambridge Local Plan for consultation

Policy CC/SD: Sustainable development and the climate emergency

Representation ID: 204444

Received: 30/01/2026

Respondent: Max Fordham

Representation Summary:

We support this policy, however would like to see it strengthened with a suggested length for the sustainability statement, and we would like to see householders also be required to demonstrate some level of engagement with the range of sustainability issues, particularly water management, climate change adaptation and zero carbon.

Full text:

We support this policy, however would like to see it strengthened with a suggested length for the sustainability statement, and we would like to see householders also be required to demonstrate some level of engagement with the range of sustainability issues, particularly water management, climate change adaptation and zero carbon.

Support

Draft Greater Cambridge Local Plan for consultation

Policy CC/DC: Designing for a changing climate

Representation ID: 204449

Received: 30/01/2026

Respondent: Max Fordham

Representation Summary:

The respondent believes the policy is essential but insufficient and should be strengthened.

Concerns were raised that the phrase 'benefit from cross ventilation where possible' may allow projects to avoid implementing cross ventilation.

The policy should require demonstration of compliance with future climate scenario weather files.

Clarification is needed on 'passive, design-led approaches to reducing excess solar gain' to ensure external measures are included in design expectations.

The respondent suggests incorporating urban heat island mitigation measures, such as shading and 'cool materials', into the design guidelines.

Full text:

We think this is an essential policy and do not think this policy goes far enough and should be strengthened. We think that “benefit from cross ventilation where possible” will allow all projects to claim that it is not viable to deliver cross ventilation. It should seek to require demonstration of meeting future climate scenario weather files. What is meant by “passive, design-led approaches to reducing excess solar gain” should be made more explicit to set an expectation that measures to exclude solar gain externally are part of the design.
Reference to designing using urban heat island mitigation measures such as, shading, and ‘cool materials’ to reduce the urban heat island impact should also be incorporated.

Support

Draft Greater Cambridge Local Plan for consultation

Policy CC/NZ: Net zero carbon new buildings

Representation ID: 204458

Received: 30/01/2026

Respondent: Max Fordham

Representation Summary:

We strongly support this policy, particularly that no new gas or fossil fuel connections are made. However it should be noted that it is not clear what the targets are exactly unless the modelling methodology is more clearly defined. For example – PHPP reports EUI differently than SAP or IES does unless a conversion is added. Please explicitly state the area metric required.
Passivhaus certification should be accepted as compliance with the policy without additional modelling to limit conflict and cost to developers.

Full text:

We strongly support this policy, particularly that no new gas or fossil fuel connections are made. However it should be noted that it is not clear what the targets are exactly unless the modelling methodology is more clearly defined. For example – PHPP reports EUI differently than SAP or IES does unless a conversion is added. Please explicitly state the area metric required.
Passivhaus certification should be accepted as compliance with the policy without additional modelling to limit conflict and cost to developers.

Support

Draft Greater Cambridge Local Plan for consultation

Policy CC/WE: Water efficiency in new developments

Representation ID: 204475

Received: 30/01/2026

Respondent: Max Fordham

Representation Summary:

Support for the policy with a recommendation to strengthen it as a critical issue for Cambridge.
smaller residential: suggest the proposed target of 90-100 litres per person per day is insufficient and should be revised

Advocate for enhanced efficiency reporting requirements for non-residential water users, particularly in relation to process water use, suggesting that this should be included in sustainability statements.

Recommend referencing corporate water efficiency standards from larger organisations to inform policy, particularly for laboratory buildings.

Support for the policy on water recycling but suggest it should include a clear methodology or target efficiency to ensure feasibility and effectiveness, more robust targets proposed for retrofits

Full text:

We support this policy but think it should strengthened as an essential issue for Cambridge.
B for smaller residential developments suggest that 90-100 l/p/day is not strong enough. This is no different than <100 l/p/day.
D. We think that for too long many of the non-residential water users in the city have been able to use vast quantities of water with no requirement to do so efficiently. We support this policy but would like to see it to go further by requesting a response as part of the sustainability statement submitted, on any other relevant process water use within the building and how this has been designed for efficiency, particularly relevant for labs. This would allow the council to influence water efficiency for process loads that are specific to the uses of the building. For evidence some of the corporate water efficiency requirements from some of the larger corporate scientific organisations could be considered,
E. We think this is essential but should be strengthened by giving a methodology or target efficiency. It is unlikely that in most cases water recycling could be easily retrofitted to achieve 5 BREEAM credits, however referencing the methodology and a minimum number of credits will strengthen this requirement.

Comment

Draft Greater Cambridge Local Plan for consultation

Policy CC/RE: Renewable energy projects and infrastructure

Representation ID: 204480

Received: 30/01/2026

Respondent: Max Fordham

Representation Summary:

Generally in support of the first section of this policy.
With respect to district heating - developments should not be forced to connect to a heat network that is not low carbon and does not have a low carbon transition strategy. Carbon intensity and efficiency of the heat network should be part of the feasibility study.

Full text:

Generally in support of the first section of this policy.
With respect to district heating - developments should not be forced to connect to a heat network that is not low carbon and does not have a low carbon transition strategy. Carbon intensity and efficiency of the heat network should be part of the feasibility study.

Support

Draft Greater Cambridge Local Plan for consultation

Policy CC/CE: Supporting a circular economy and sustainable resource use

Representation ID: 204485

Received: 30/01/2026

Respondent: Max Fordham

Representation Summary:

We strongly support this proposal but think it should be strengthened.
Point 1 should reference lean design - this is often the biggest opportunity for reducing embodied carbon - efficient structure, large embodied carbon elements - avoidance of basements and cantilevers
Intensity of landuse should be a consideration for demolition where it is likely to provide buildings that might otherwise be built on virgin soil (or peat outside of cities) (reference policy CC/CS).

Full text:

We strongly support this proposal but think it should be strengthened.
Point 1 should reference lean design - this is often the biggest opportunity for reducing embodied carbon - efficient structure, large embodied carbon elements - avoidance of basements and cantilevers
Intensity of landuse should be a consideration for demolition where it is likely to provide buildings that might otherwise be built on virgin soil (or peat outside of cities) (reference policy CC/CS).

Support

Draft Greater Cambridge Local Plan for consultation

Policy BG/BG: Biodiversity and geodiversity

Representation ID: 204521

Received: 30/01/2026

Respondent: Max Fordham

Representation Summary:

We support this policy but believe it could be made stronger in the following areas. Firstly we suggest that the policy should explicitly state that 10% BNG is a minimum expectation, not the desired outcome, and require higher BNG in defined circumstances (large sites, strategic allocations, sensitive locations). Secondly we suggest a requirement for BNG to contribute toward ecological connectivity i.e. creation and enhancement of ecological networks including river corridors and habitat stepping stones as set out in the Cambridgeshire Nature Recovery Strategy.

Full text:

We support this policy but believe it could be made stronger in the following areas. Firstly we suggest that the policy should explicitly state that 10% BNG is a minimum expectation, not the desired outcome, and require higher BNG in defined circumstances (large sites, strategic allocations, sensitive locations). Secondly we suggest a requirement for BNG to contribute toward ecological connectivity i.e. creation and enhancement of ecological networks including river corridors and habitat stepping stones as set out in the Cambridgeshire Nature Recovery Strategy.

Support

Draft Greater Cambridge Local Plan for consultation

Policy BG/BG: Biodiversity and geodiversity

Representation ID: 204535

Received: 30/01/2026

Respondent: Max Fordham

Representation Summary:

We support this policy but believe it could be made stronger in the following areas. Firstly we suggest that the policy should explicitly state that 10% BNG is a minimum expectation, not the desired outcome, and require higher BNG in defined circumstances (large sites, strategic allocations, sensitive locations). Secondly we suggest a requirement for BNG to contribute toward ecological connectivity i.e. creation and enhancement of ecological networks including river corridors and habitat stepping stones as set out in the Cambridgeshire Nature Recovery Strategy.

Full text:

We support this policy but believe it could be made stronger in the following areas. Firstly we suggest that the policy should explicitly state that 10% BNG is a minimum expectation, not the desired outcome, and require higher BNG in defined circumstances (large sites, strategic allocations, sensitive locations). Secondly we suggest a requirement for BNG to contribute toward ecological connectivity i.e. creation and enhancement of ecological networks including river corridors and habitat stepping stones as set out in the Cambridgeshire Nature Recovery Strategy.

Support

Draft Greater Cambridge Local Plan for consultation

Policy BG/GI: Green and blue infrastructure

Representation ID: 204538

Received: 30/01/2026

Respondent: Max Fordham

Representation Summary:

support

Full text:

support

Support

Draft Greater Cambridge Local Plan for consultation

Policy BG/TC: Improving tree canopy cover and the tree population

Representation ID: 204542

Received: 30/01/2026

Respondent: Max Fordham

Representation Summary:

We support this policy but would like to see it also cover improving tree canopy cover in existing residential areas as well as new developments. We also suggest that the policy explicitly consider equity given the well established link between affluence and tree cover.

Full text:

We support this policy but would like to see it also cover improving tree canopy cover in existing residential areas as well as new developments. We also suggest that the policy explicitly consider equity given the well established link between affluence and tree cover.

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