Draft Greater Cambridge Local Plan for consultation

Policy to include similar residential occupancy condition as that of Policy S/WGC.

Amend point 6 to replace 'should' with 'must' : "Gardens surrounding the Grade I Church and Grade II* Babraham Hall must be excluded from development."
Amend point 9 by adding "including views for the higher land to the north from the Gog Magog Hills and Roman Road," between '...wider landscape character' and 'whilst creating ...'
Figure 94/Site plan should identify area of Strategic Enhancement Area

Amend policy to deliver deliver traffic management and bus priority measures on the A1307 to ensure that travel by bus to the Campus from either direction is as convenient and reliable as possible.
a) A busway between the Cambridge Biomedical Campus and the Hinton Way roundabout via the proposed south-easterly expansion
a) A bus lane (if and when needed) along the A1307 westbound to Hinton Way roundabout
b) Signals controls and lead-in bus lanes at the Babraham Research Park access roundabout
c) Priority measures at the A11 interchange or a new bus and active travel bridge over the A11, linking the A1307 and Newmarket Road

To safeguard the dwellings for campus workers, a residential occupancy condition needs to be applied similar to that of policy S/WGC Wellcome Genome Campus.
The policy needs to be strengthened to protect heritage assets and Gog Magog landscape.
The Babraham Research Campus’s expansion, any development on Grange Farm and improved access to Granta Park can all be achieved with more targeted, lower cost interventions:
a) A busway between the Cambridge Biomedical Campus and the Hinton Way roundabout via the proposed south-easterly expansion
a) A bus lane (if and when needed) along the A1307 westbound to Hinton Way roundabout
b) Signals controls and lead-in bus lanes at the Babraham Research Park access roundabout
c) Priority measures at the A11 interchange or a new bus and active travel bridge over the A11, linking the A1307 and Newmarket Road
The policy needs to deliver traffic management and bus priority measures on the A1307 to ensure that travel by bus to the Campus from either direction is as convenient and reliable as possible.

Policy should be strengthened to protect heritage assets by replacing 'should' with 'must'.
1.b. Development must have no unacceptable adverse impacts on the setting of nearby Grade II Listed Buildings, the Temple Café and Restaurant;

Recent buildings on this site have been very intrusive in the landscape, notably on Site 1 (21/03822/FUL). Our concerns expressed at the time of the planning application that this building is too high have been found correct. The building is visible above the tree line from the A1307 Abington and from the A505 and has a detrimental impact on the landscape. It is especially prominent at night when the top floor lights are on (which appears to be even out of working hours).
Amend policy part 1d by inserting 'with development sitting below the tree-line' between '... parkland setting' and 'maintains and enhances ....'

We support the explanation given in the Jobs Topic paper that the plan will not support regional and national distribution proposals but will meet the needs for local distribution (paragraph 3.42 page 18). This prominent site in the countryside is being released to meet the shortfall in Greater Cambridge for industrial and warehousing. The policy needs to ensure that it’s use is restricted to sub-regional logistics and does not become a national facility. The policy refers to meeting the needs for LOCAL warehousing and logistics, but it is not clear how this can be enforced.

We object to householder applications being exempt from Sustainability Statement. If this is a matter of being proportionate to the scale of development, then this is covered by paragraph 2.

The policy should encourage the use of pre-fabrication of sections of new buildings for subsequent site assembly.
Add a bullet point in supporting information:
• Use of Modern Methods of Construction (MMC) such as offsite manufacturing, digital tools and advanced materials.

The policy needs to give developers flexibility in how they comply with policies CC/DC and CC/NZ. It needs to require or incentivise them to achieve a sustainability target above building regulations by adding from a menu of options, scored appropriately: solar panels, battery, enhanced insulation, enhanced glazing, enhanced water capture/recycling, etc. This could, for instance, be coded as bronze, silver and gold, weighted accordingly in the planning balance.
Require the use of low-emissivity glass for south-facing windows unless they are or can be shaded in summer, e.g. by a brise soleil or shutters. If a blanket requirement is not deemed appropriate, it should at least apply for single-aspect dwellings.

Building regulations do not yet specify low-emissivity glass (which reduces solar gain in summer and heat loss in winter). This is especially beneficial for south facing windows that are not shaded in summer.
Similarly, building regulations do not yet mention vacuum glazing, which has higher insulating properties and slower degradation in performance over time. This will come to replace slimline double glazing, which performs poorly over time, as the glazing of choice for retrofitting single glazing in pre-modern windows (e.g. Georgian/Victorian/Edwardian sashes).

The policy needs to be amended to
Set carbon budgets for construction that are consistent with the UK’s Nationally Determined Contributions, as well as its statutory duty to reach net zero by 2050.
Include battery storage as a requirement or option (see recommendations for Policy CC/DC).
Include the embodied carbon emissions of transport infrastructure in the policy.
Include carbon emissions from vehicle movements that are generated by a development when considering operational carbon emissions of the development as a whole.
Clarify how Energy Offsetting will work in practice

Measurability and Enforceability of Energy Targets
In Part A, for the energy consumption target range to be measurable and enforceable, it must include a standard reference room temperature. Occupiers will choose their own ambient temperature, and therefore actual measurements of household or commercial energy consumption for space heating are not a reliable indicator of whether the building fabric and heating system is compliant.
Part B is almost entirely unenforceable because it is outside the control of the developer. The energy requirement for space heating is the only element that can realistically be standardised, measured and enforced.

Critiques of Onsite Energy Generation and Storage
Part C is too vague and unrealistic to be enforceable. For instance, to satisfy the requirement to “achieve all energy demands through onsite energy generation” in winter (when solar generation is lowest and heating demand is highest) would require some combination of wind turbines and long term (multi-day to inter-seasonal) energy storage. The “where possible” caveat is presumably intended to engage Part D, but this would be contested if Part C is deemed to be disproportionately onerous.
Part C should include a requirement for battery storage as an addition or alternative to energy generation. Even without energy generation, energy storage can smooth peaks in electricity demand by charging at off-peak times and discharging at peak times (e.g. to power cooking appliances in the evening), thereby contributing to a meaningful reduction in demand from gas-powered generators which increase the carbon intensity of grid electricity.

As a sidenote, heat batteries are an alternative to a hot water cylinder; one of these will be required where water is heated using a heat pump (since the power output of a heat pump is nowhere close to that of an on-demand boiler). Therefore, a heat battery is not an alternative to an electrical battery.

Embodied Carbon and Construction Targets
Achievable, quantitative targets and clear exceptions must be set if the policy is to be priced into pre-development land values.
The paragraph on Net Zero Buildings requires only measurement, and has no binding influence on the embodied emissions of construction, even though these contribute most to the depletion of the atmospheric carbon budget.

Transport Infrastructure and Cumulative Emissions
There should be a policy that covers the carbon costs of transport infrastructure. All transport infrastructure schemes must achieve net negative cumulative carbon emissions by 2050 (at the very latest), including embodied carbon emissions. Schemes should be prioritised on the basis of the scale and rapidity of the carbon savings they will achieve.

Alignment with National and International Climate Targets
Supporting information §4.20 omits the 2030 target of a 68% reduction (1). The 2035 target is for an 81% reduction on 1990 levels, not 78% as stated (the Nationally Determined Contribution was strengthened at COP29 in 2024) (2).
In the absence of legislation or national guidance on how government departments and local authorities should meet these national targets, local authorities should attempt to estimate what their share of the national carbon budget is and set policies accordingly.
The national Transport Decarbonisation Plan, adopted in 2021, relies mainly on replacing petrol/diesel vehicles with battery-powered models. There is no recognition of, or accounting for, the embodied carbon emissions of new vehicles or new transport infrastructure, even though it is cumulative emissions that are driving climate change, and therefore embodied emissions must be regulated. The Local Plan must not continue to ignore this blind spot.
Part D The policy needs to clarify how the Energy Offsetting will work in practice. Will the Planning Obligations SPD be updated to include Energy Offsetting? An explanation is needed as to how the payment will be calculated, and who will have access to the fund to deliver local projects? The need to deliver offsite projects should not outweigh the policy requirements of CC/RE.

(1) https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1109429/uk-nationally-determined-contribution.pdf
(2) https://www.gov.uk/government/publications/uks-2035-nationally-determined-contribution-ndc-emissions-reduction-target-under-the-paris-agreement

Point 2e: The requirement for sustainability retrofitting of an existing building being developed is commendable, but may not be financially viable, so offsetting contribution instead should be allowed.

Support the policy but suggest amendment part 1 of policy to ensure SuDS requirements are met in full. Amend policy to say 'New development must FULLY incorporate incorporate Sustainable Drainage Systems (SuDS) as part of an Integrated Water Management approach to the design of the whole site.

Support the policy but propose amendment to ensure full information is provided in planning applications as to what has been agreed with which relevant bodies.
Amend part f by adding 'and are included as part of the planning application' at the end
f. The ongoing maintenance and management of any necessary flood defences or flood mitigation measures have been agreed with the relevant bodies and the necessary agreements are in place and are included as part of the planning application.