Draft Greater Cambridge Local Plan for consultation

The strategic priority to achieve net zero carbon by 2050 is welcome but inadequate given the urgent need to limit warming to 1.5°C. We recommend amending this to read “Help Greater Cambridge transition to net zero carbon before 2050, by ensuring that developments are: sited in places that help to minimise carbon emissions: designed to the highest achievable standards for energy and water use; adapt to and mitigate against climate risks; make use of low-carbon materials and retrofitting; pursue net negative carbon; avoid high-emission activities like intensive livestock or industrial operations and are resilient to current and future climate risks, including flooding.”
We recommend that throughout this policy and the whole Local Plan the phrase “changing climate” should be replaced with “climate crisis”. Overall, the draft Local Plan focuses too heavily on end-state emissions; the policies place should place more emphasis on reducing short-term and cumulative carbon impacts from development.

We welcome Policy CC/SD and the requirement for Sustainability Statements, which provides a clear mechanism for developers to demonstrate compliance with climate and sustainability policies. However, the supporting information should clarify that statements must, at minimum, show how developments meet the standards set out in relevant policies, rather than addressing issues only “where relevant.”
Point 2. The wording should be amended as follows: “Sustainability Statement …. including: ….. d) sustainable travel, with a focus on reducing car travel, supporting walking and cycling as a priority, with supporting electric vehicles as a secondary measure, in line with Policy I/ST.”
We also recommend amending the third bullet point in the Supporting Information to read “Promote sustainable transport with active travel as the highest priority, ensuring developments are designed to minimise car use and prioritise walking, cycling and public transport, with electric vehicle provision as a complementary measure.”

We support this policy and the use of the cooling hierarchy, prioritising passive solutions. However, new developments and existing areas should integrate green spaces, trees and water features as “cooling corridors,” helping to mitigate the urban heat island effect and promoting equality in access to cooler environments.
Point 1: Reword: “Planning applications must demonstrate that design solutions have been appropriately integrated and respond proportionately and actively to the emerging climate crisis.”
Point 2: The explanation of meaning of the word “development” (currently only seen if you click on this word) should be included in the wording: “This policy applies to development in its widest sense, including buildings and streets, space and places, and also applies to redevelopment, including refurbishment.” This policy should also include the requirement that “All applications must include design solutions that first formally evaluate, and second actively and effectively reduce existing and/or any future Urban Heat Island Effect. Applications should consider urban-scale cooling through green and blue infrastructure, connected cooling corridors and impacts on existing buildings, ensuring equitable access to cooler environments.”
Point 3: delete the words “where possible”.

We support the strong operational emissions requirements in this policy but point 8 on construction and embodied carbon is too weak. Net zero buildings policies must address upfront emissions from construction, materials and land-use change. The policy should set clear expectations for prioritising recycled and low-carbon materials, apply to retrofit as well as new buildings, and include standards for building lifetime. Emissions from demolition, soil, vegetation or existing structures should be considered, ensuring refurbishments improve energy efficiency and renewable energy generation wherever possible.
We recommend amending point 8 to read “All major developments must calculate whole life carbon emissions using a nationally recognised whole life carbon assessment tool and demonstrate actions to reduce up-front embodied carbon emmissions (modules A1-A5 of the RICS methodology) through good design and material efficiency. This should include reducing emissions associated with construction plant. and minimise embodied carbon through prioritising recycled and low-carbon materials, efficient design and reducing emissions from construction plant. Proposals must also account for emissions from demolition, soil disturbance and removal of existing structures. These requirements apply to both new buildings and major refurbishments. Developments should maximise building longevity and adaptability to reduce whole-life carbon impacts, ensuring that upfront emissions are minimised alongside operational emissions.”

We strongly support points 1, 4 and 5.
For point 2, we feel it extremely important that the 80 l/person/day standard should be applied throughout. We recommend deleting point 2b and amending point 2a to read “for all new residential development, regardless of number of dwellings, water usage of no more than 80 litres/person/day. ….To achieve this level, some form of water reuse or recycling will be necessary…”
Point 2c should be reworded to reflect the Shared Standards (https://www.anglianwater.co.uk/siteassets/developers/new-content/p--c/shared-standards-in-water-efficiency-for-local-plans.pdf), which call for stronger requirements: “For new, extended or redeveloped non-residential buildings, full credits within the 4 water categories (WAT01, WAT02, WAT03, and WAT04) for BREAAM standard within a minimum score of 3 credits within WAT01 Water Consumption issue category, or an equivalent standard set out in any future update to BREAAM. The applicant will be required to justify and evidence why full credits is not practicable for the development.”
Point 3 (concerning how water efficiency is demonstrated) should also be reworded to reflect the Shared Standards: “A Water Efficient Design Statement must be submitted with the application at the earliest stage to demonstrate how policy requirements have been met and will be maintained in relation to water efficient design. The statement shall provide, as a minimum, the following: a) Baseline information relating to existing water use within a development site; and b) Full calculations relating to expected water use within a proposed development (such as water efficient fixtures and fittings, rainwater/stormwater harvesting and reuse, or greywater recycling).”
We recommend two new points be added to reflect the Shared Standards:
New point 6: “Prior to the first occupation of development a completion certificate shall be submitted to the Local Planning Authority confirming the design standard has been verified and fully implemented.”
New point 7: “All new and refurbished buildings must be fitted with an in-property leak detection system by 2030, capable of rapidly notifying the occupant of any internal leaks within 24 hours. Where feasible, this should be integrated with a smart water meter; if not, an alternative effective leak detection device should be installed.”
These measures are essential to address the serious water stress in Greater Cambridge and ensure sustainable, resilient development in line with the Shared Standards.

We support this policy’s emphasis on integrated water management and strongly support the emphasis on nature-based solutions in point 1.d. In point 4.e, we recommend amending “where reasonably practicable” to “wherever practicable” as in 1.d, since permeable hard surfaces are essential for effective drainage.
For point 4.h: Given that maintenance of SuDS is fundamental to their long term function and that many SUDS in Cambridge do not function correctly (e.g. (a) the Trinity Gate development where a SuDS maintenance plan was a planning condition and required features within private curtilage were to be maintained by owners; however, the owners do not seem to have been made aware of this and it is unclear if the SuDS will be maintained properly; and (b) the new development behind Thornton Road, where the new 'wetland' created by the SuDS is highly unstable, fluctuating between a dried wasteland of herbage and inundation by flash floods). Point (4h) currently worded "details of the future management, maintenance and adoption of the SuDS are provided to ensure they will function effectively over the lifetime of the development" must also include very specific wording to require responsibility for management and maintenance to be clearly assigned, including details of the future management, maintenance, with clear responsibilities defined etc.

We welcome the strong precautionary approach of this policy and fully support making flooding a separate policy issue, rather than including it with the previous policy as was the case in the first draft of the Local Plan. In point 1.a, we recommend deleting the exception stating “(this is not necessary if the proposal is on an allocated site and consistent with the allocated use).” Removing this exception would ensure that flood risk is assessed consistently for all developments, recognising that allocation does not remove or reduce real and increasing flood risks under climate change.

We strongly welcome this policy. We especially support the strong encouragement for solar PV on existing buildings and above car parks, helping to maximise generation on already developed land. The requirement to plan for decommissioning, including the retention of biodiversity net gain, is also very welcome and reflects good long-term environmental stewardship. We also welcome the inclusion of the heat network zoning study boundary in point 8 (though note the typo “zooming” in the introduction) and look forward to further development of district heating opportunities in Cambridge and the wider area.

We welcome this policy, particularly its strong emphasis on circularity, designing out waste, and building for longevity, as well as the welcome presumption in favour of retrofit and reuse over demolition. However, we remain concerned that opportunities to meet development needs through reuse and retrofit are not being proactively assessed, for example by bringing empty or under-used buildings back into use. The policy should also include clearer, stronger requirements on reducing embodied carbon, with less reliance on “viability”, and provide more guidance on retrofit best practice and the use of low-carbon and carbon-storing materials to future-proof delivery. To this end, we recommend strengthening point 1 to read “All development proposals must take all reasonable opportunities to minimise the development’s embodied carbon content through the careful choice, use and sourcing of materials, with departure from this requirement permitted only where clearly justified by robust evidence.”

We welcome this policy and agree that protecting land-based carbon sinks is essential to addressing climate change. However, the policy should explicitly protect significant existing carbon stores, including soils, woodlands, grasslands and wetlands, not just peatlands or future sequestration opportunities. Disturbance of established habitats can cause immediate carbon release that outweighs slow future sequestration gains, yet this risk is not adequately addressed. We therefore recommend adding a new point after point 2 to state “All major development proposals must avoid the disturbance of established habitats, such as soils, woodlands, grasslands, and wetlands, that contain significant carbon stocks, unless there is no feasible alternative and no resulting net loss of carbon. The protection of existing carbon stores shall take precedence over any potential future carbon sequestration measures.” We are also concerned that the wording on peat allows harmful exceptions; given peat’s critical importance, development on peatland should be ruled out entirely to avoid irreversible carbon loss.