Greater Cambridge Local Plan Issues & Options 2020

Response to Question 2 - ADDITIONAL INFORMATION 2.1 Land to the north of Station Road, Cambridge is submitted as a potential allocation for employment in the Local Plan. The extent of the site is shown on the site location plan at Appendix 1. 2.2 The Site is located on the north side of Station Road, Cambridge and stretches from the Hills Road/ Station Road junction eastward to Tenison Road. The site is composed of eleven buildings, comprising 1 - 4 Arundel Villas (semi-detached), St Andrews (detached) and 1 - 6 Salisbury Villas (detached). In this document, they are all collectively referred to as the ‘Salisbury Villas’, for simplicity. The villas are currently in Use Class B1(a) (office) and Use Class D1 (language school). 2.3 The villas are set back approximately 16m from Station Road and, what would have originally been separate front gardens, have been joined together to form a second access road, parallel to Station Road, with parking behind a row of mature lime trees. 2.4 The Site can be accessed from Station Road and the junction of Station Road and Tenison Road. 2.5 The Site is surrounded by office development to the east and south, as part of the ‘Area of Major Change’ to the Station Area, and residential properties lie to the north. No.s 55-59 Hills Road and No.s 1-7 Station Road (also within the ownership of Jesus College) lie to the west and are in retail use. The Vision 2.6 The vision is to breathe new life into the Site, continuing the successful transformation of this part of the city and to provide additional capacity to support the clustering in the local area, which has proven so important to Cambridge’s economy. 2.7 In order to guide the future development of the site, the College has developed four core objectives: ● Supporting a sustainable Cambridge by making appropriate and efficient use of a site in a highly accessible location; ● Spearheading solutions to move to a net zero-carbon society in the context of the climate emergency in this highly sustainable and accessible location; ● Delivering a lasting legacy of high-quality architecture with a distinctive character to create a unique sense of place as part of the College’s long-term endowment portfolio; ● Enhancing the green space and public realm at this important gateway into the city centre. 2.8 The supporting Vision Document provides further detail on the significant opportunity that the site presents, informed by additional site assessment work and in light of the four ‘big themes’ identified in the consultation document. The Economic Context 2.9 National Planning Policy confirms that planning policies should help create the conditions in which businesses can invest, expand and adapt (NPPF, paragraph 80). The NPPF specifically states that “Significant weight should be placed on the need to support economic growth and productivity, taking into account both local business needs and wider opportunities for development” (emphasis added). The approach taken should allow each area to build on its strengths, counter any weaknesses and address the challenges of the future. 2.10 The NPPF continues, at paragraph 81, in advising the planning policies should: “a) set out a clear economic vision and strategy which positively and proactively encourages sustainable economic growth, having regard to Local Industrial Strategies and other local policies for economic development and regeneration; b) set criteria, or identify strategic sites, for local and inward investment to match the strategy and to meet anticipated needs over the plan period; c) seek to address potential barriers to investment, such as inadequate infrastructure, services or housing, or a poor environment; and d) be flexible enough to accommodate needs not anticipated in the plan, allow for new and flexible working practices (such as live-work accommodation), and to enable a rapid response to changes in economic circumstances.” 2.11 Paragraph 82 adds that: “Planning policies and decisions should recognise and address the specific locational requirements of different sectors. This includes making provision for clusters or networks of knowledge and data-driven, creative or high technology industries; …at a variety of scales and in suitably accessible locations” 2.12 The Cambridgeshire and Peterborough Independent Economic Review (CPIER) (2018) and the Cambridgeshire and Peterborough Industrial Strategy (2019) provide such a vision and have each outlined ambitious plans for growth over the next 20 years. 2.13 Furthermore, the Cambridgeshire and Peterborough Combined Authority (CPCA) has a target of doubling the regional economic growth (GVA) over the next 25 years as part of the Devolution Deal. This requires the area going beyond what it has achieved in the past (to double an economy over twenty-five years requires an average annual growth rate of 2.81%. Historically, since 1998, the local economy has only grown at around 2.5%.). Achieving this requires employment growth and more importantly productivity growth, as we are already at comparatively high levels of employment 2.14 In order to deliver this ‘step change’ in economic performance, the Consultation document states that around 2,900 homes a year would need to be built in Greater Cambridge if the jobs growth is achieved – an indicative total of 66,700 homes over 2017 – 2040. This compares with 1,800 homes per year to meet local needs using the Government’s standard method. 2.15 There is clearly a need to provide for an amount of housing above the standard methodology to take account of the pressing and worsening affordability issue and to support the aspiration to grow the Greater Cambridge economy and double the GVA across the Greater Cambridgeshire and Peterborough area. The Opportunity 2.16 The Station Road area in Cambridge has changed beyond all recognition since the preparation of the Station Area Development Framework (SADF), adopted in April 2004. Significant development has since come forward in recent years along Station Road as part of the Area of Major Change resulting in the delivery of a bustling city quarter today. The Site now finds itself located at the heart of Cambridge’s newly formed Central Business District (CBD) and it has attracted a number of significant pre-lets; a sign of its desirability. 2.17 The area has seen job growth of 4% since 2015, much of which has been focused along Station Road where 0.5 million sf ft of offices has been built since 2013. The new occupants (such as Microsoft, Amazon, Samsung and Apple) have created a new Research and Development (R&D), AI and business services cluster. Such knowledge intensive industries tend to cluster together, pulled by the forces of agglomeration (easy access to knowledge, workforce, supply chains, markets). 2.18 This clustering has significant benefits to Cambridge and the wider UK economy and to grow this cluster requires office development in close proximity to the existing occupants. However, future business development in the area is constrained by the lack of high-quality office space. All the commercial buildings within the ‘CB1’ masterplan area, along Station Road, now have planning permission or a resolution to grant permission. Current availability in this area is now less than 1.5%, with no Grade A space. 2.19 The supporting Employment Needs Appraisal, prepared by Bidwells LLP, confirms that this limited supply and strong demand has led to significant increases in rent of 32% over the past five years. For the R&D, AI and business services sector, the location decisional drivers are access and ability to recruit the right skill sets. Central Cambridge provides this, but the small size of the core central area, the lack of available space and lack of development pipeline puts that resilience at risk and could undermine the growth of the R&D sector. 2.20 Land to the north of Station Road is the last section of the Station Road area to benefit from a clear and shared long-term vision and so represents a significant opportunity to continue the successful transformation of this part of the city and provide additional capacity to support the further clustering around the Station. 2.21 The Site is within single ownership and capable of delivering a well-designed, high quality development that could make efficient use of a brownfield site, in a highly sustainable location, whilst also being able to respect its historic context. The site’s proximity to Cambridge railway station, links to the Chisholm trail and the transport interchange at the Station also enables opportunities to promote sustainable transport modes. Responding to the Four Big Themes 2.22 Since the submission of the ‘Call for Sites’ representations in March 2019, Jesus College has appointed a masterplanner, Allies and Morrison, to undertake a detailed analysis of the site constraints and opportunities, informed by further technical assessment work. A summary of this assessment work is provided below. These assessments have specifically sought to respond to the four ‘big themes’ of the emerging Local Plan and in turn help shape the emerging concept proposals for the Site. Climate Change 2.23 The two Councils and the County Council have committed to achieve net zero carbon by 2050. In order to meet this challenge, the Local Plan will need to plan for low-carbon lifestyles and encourage low carbon activities and alternatives to private car use. 2.24 The Local Plan will also need to promote highly sustainable patterns for growth, such as densification of underused brownfield sites like Land to the north of Station Road, that enables travel by low-carbon modes thus reducing car use to ease congestion and reduce airborne pollutants. The same measure offers opportunities to promote active travel choices (walking, cycling) to enhance health and wellbeing. 2.25 A Sustainable Transport Appraisal for the Site has been prepared by Vectos and accompanies these representations. This confirms that the site is extremely well located for access to key facilities and services, including transport infrastructure such as Cambridge Railway Station and the Cambridgeshire Guided Busway (CGB) and the city centre; all within a 10 minute walk. Furthermore, there are a number of strategic schemes coming forward which will improve mobility in the area (the Chisholm Trail, extensions to the CGB, Cambridge Autonomous Metro). Along with a rare opportunity to reduce the amount of car parking within a City Centre location. 2.26 A Sustainability Appraisal for the Site has been undertaken by Hoare Lea and this has been incorporated into the accompanying Vision Document. This reviews the emerging concept proposals from a sustainability perspective and outlines a number of climate change mitigation and adaptation measures that could be incorporated into redevelopment proposals for the Site, such as: ● Passive design measures which lower the cooling requirement and have shorter lifecycles, such as solar shading and high fabric performance; ● Improvements to water efficiency, such as water efficient fittings and metering and systems which recover water; ● Design measures to minimise waste volume as far as possible, through the careful selection of materials and the use of techniques such as off-site and modern methods of construction, material consumption, waste volumes, and product quality; ● Improvements to flood resilience through removal of large areas of hardstanding and incorporation of a range of future climate scenarios that better manage the water runoff into the wider city drainage system. Specifically, there is opportunity to explore the integration of measures such as green or blue roofs and sustainable drainage systems; and ● Green infrastructure to offer greater resilience to a warmer and drier climate than currently exists, to provide a 10% net biodiversity gain in ecosystem habitats and to provide broader ecosystem services such as forming part of a sustainable drainage system. 2.27 The operational emissions of a building are defined as those emissions (measured in CO2 equivalent, or “CO2e”) arising from the use of energy in the day to day running of the building from uses such as lighting, heating, ventilation, and equipment. This can be measured in absolute terms but, in order to allow comparability between buildings, is often quoted as an intensity metric, such as CO2e/FTE; which represents the carbon emissions generated from a building on a per full time employee basis. 2.28 Development at scale presents an opportunity to radically reduce the carbon intensity per employee at the site. 2.29 The Local Plan will be required to allocate land to provide for an increase in employment floorspace across Greater Cambridge. These additional jobs will have to be allocated somewhere; there is great benefit to provide these new jobs in a highly accessible location and in a manner that would improve the operational carbon intensity of an existing site. Biodiversity and Green Spaces 2.30 Both Councils have declared biodiversity emergencies and, as members of the Natural Cambridgeshire Local Nature Partnership, the Councils support the Partnership’s vision to double the area of rich wildlife habitats and natural greenspaces within Cambridgeshire and Peterborough. 2.31 Jesus College recognise the importance of improving the natural environment and is committed to achieving net biodiversity gain in respect to potential redevelopment proposals at Land to the north of Station Road, Cambridge. The Site in particular presents an opportunity to greatly improve the public realm along the Station Road frontage and in turn create wellbeing through improved public spaces to relax, move through and socialise. As referred to above, new areas of green infrastructure also provide opportunities to mitigate against climate change, through creating resilient new habitats. 2.32 A site-wide ecological appraisal and background desk study was completed by Ecology Solutions in December 2019 and accompanies these representations. 2.33 The key findings from the appraisal are summarised below: ● There are no statutory or non-statutory designated sites within or directly adjacent to the site; ● The habitats within the site are of limited intrinsic ecological interest; ● There are no overriding ecological constraints to redevelopment of the Site; ● The villas offer potential opportunities for roosting bats and as such further surveys are required. However, there is good scope for providing enhancements for bats as part of any redevelopment proposal; and ● The site presents opportunities to achieve a 10% biodiversity net gain through a sensitively designed, landscape-led scheme which would incorporate, wherever possible, native species of local provenance and those of known value to native wildlife to offer biodiversity gains post-development. 2.34 A Tree Survey and Constraints Plan was prepared by Haydens in January 2020 and accompanies these representations. 2.35 The key findings from the survey work are summarised below: ● A total of sixty-nine individual trees, nine groups of trees and two areas of trees have been surveyed. These were found to be of mixed condition and age providing a variety of amenity benefits; ● Three of the trees are identified as Category A trees (high quality and value). These are as follows: − T012: Austrian Pine − T059: Beech (this tree is located on neighbouring land, but due to its proximity to the boundary, it could nonetheless affect development proposals) − T066: European Lime ● The majority of the other mature trees are classified as Category B (moderate quality and value), with the remainder either category C (low quality and value) or U (remove); ● All the trees along Station Road are Lime and classified as Category B; ● The tree species in the back gardens are more mixed and are mainly either Sycamore, False Acacia or European Lime; and ● Any redevelopment proposal would need to consider the siting and design of the layout in respect to the presence of trees, particularly those of the highest quality, and add new trees where possible. Wellbeing and Social Inclusion 2.36 Cambridge City Council has an Anti-Poverty Strategy which includes an action plan. This identified that while the Cambridge economy continues to thrive, there are high levels of income inequality in the city. Cambridge City Council also has an Air Quality Action Plan 2018-2023 and sets out Cambridge City Council’s priority actions for improving areas of poor air quality in the city and maintaining a good level of air quality in a growing city. 2.37 Redevelopment of Land to the north of Station Road has the potential to achieve ‘good growth’ that promotes wellbeing and social inclusion, as outlined below. These benefits also serve to reinforce the potential of the site for employment densification: ● Securing improvements in air quality through promotion of a car-free development thus reducing car use to ease congestion and reducing airborne pollutants within a designated Air Quality Management Area (AQMA); ● Encouraging healthy lifestyles through provision of employment opportunities in a highly accessible location by low-carbon modes, thus encouraging active travel. The Site is also within five minutes walk of the Botanic Gardens, which provides open space of a scale that can absorb a large number of people, thereby having the capacity to serve high density employment development; ● Proximity to a range of shops and services which offer healthy eating choices; ● Proximity to local services and amenities bringing opportunities for social interaction and community development. Particularly important given a large number of potential employees will not likely be resident in Cambridge and have established local networks; ● Opportunities for new build design to provide all-electric heating and hot water systems to avoid the on-site combustion of fossil fuels and incorporate passive design to support indoor air quality, improved acoustic performance and adequate levels of daylight; ● Creation of a safe and inclusive community through provision of a wide range of jobs; and ● Creation of high-quality buildings and public realm that meet the WELL Building standards and offer natural sociability, interaction and access to nature. Great Places 2.38 Greater Cambridge has a track record as a place where contemporary design and the historic environment co-exist in harmony. A key issue for Land to the north of Station Road will be how to balance heritage with the demands of growth. 2.39 The Site is located within the New Town and Glisson Road Common Conservation Area. 2.40 None of the buildings within the Site are listed, however they are all identified as ‘Buildings of Local Interest’ (51-53 Hills Road and the Station Mews are excluded from this list). In addition, they are identified as ‘Buildings of Positive Townscape Value’ in the New Town and Glisson Road Conservation Area Character Appraisal (2012), (51-53 Hills Road and the Station Mews are excluded from this list). As such, the existing buildings are considered to be “non-designated heritage assets”. 2.41 In light of the above, the College recognise that it is important to understand the relative merits of the existing buildings and land in the context of these designations and the relevant legislation and policy framework. The College have therefore has prepared an Initial Significance Assessment to understand the historic interest of the existing properties, attached. The Assessment concludes the following: ● The villas are ‘non-designated assets’ in their own right, and are therefore subject to the provisions of the NPPF; ● The villas contribute positively to the character and appearance of the Conservation Area (a designated heritage asset) and are therefore subject to the provisions of the NPPF; ● As a group, and in their contribution to the Conservation Area, the Villas hold a value ranging from moderate to good (although some buildings individually have a lower level of value as a result of lower original quality and adaptations to them); and ● The site could however accommodate some form of development within its heritage context and indeed a number of benefits to the character and appearance of the Conservation Area could be secured through any future redevelopment. 2.42 In the case of designated heritage assets (such as Conservation Areas and listed buildings), paragraph 193 of the National Planning Policy Framework (NPPF) explains that, “when considering the impact of a proposed development on the significance of a designated heritage asset, great weight should be given to the asset’s conservation”. In the event that “less than substantial harm” would be caused, the policy requires this harm to be clearly outweighed by public benefits. In the event that substantial harm is caused, this level of harm should be “exceptional and could only be outweighed by substantial public benefits.” 2.43 In the case of non-designated heritage assets (such as locally listed buildings or buildings of positive merit) Paragraph 197 of the NPPF requires a Local Planning Authority to make a “balanced judgement” having regard to the scale of any harm or loss of the heritage asset. 2.44 Ultimately, a balanced judgement would be required for any redevelopment proposals in terms of the impact on the significance of designated and non-designated heritage assets and the public benefits arising. The Site has the potential to deliver significant public benefits, as outlined below: ● The opportunity to deliver high quality B1a (office) accommodation in a Core City District and in a sustainable travel location close to central Cambridge railway station; ● Supporting the local economy and community through expansion of an established R&D and AI Cluster and associated supply chains; inclusive growth that considers the needs of vulnerable groups; can compete on the international office market; and takes a large step toward to meeting regional growth targets; ● Supporting economic growth in a manner that promotes health and wellbeing for employees and the wider community through; - high quality architecture and passive design measures which lower the cooling requirement and have shorter lifecycles, such as solar shading and high fabric performance; - significant improvements to public realm along Station Road frontage; - opportunities to travel sustainably and helping to tackle air pollution, as well as bring physical benefits; ● Improvements to flood resilience through removal of large areas of hardstanding and incorporation of a range of future climate scenarios that better manage the water runoff into the wider city drainage system. Specifically, there is opportunity to explore the integration of measures such as green or blue roofs and sustainable drainage systems; ● Green infrastructure to offer greater resilience to a warmer and drier climate than currently exists, to provide a 10% net biodiversity gain in ecosystem habitats and to provide broader ecosystem services such as forming part of a sustainable drainage system; ● Helping to maximise the benefits arising from major investment in a key public transport corridor associated with sustainable transport and active travel; and ● A landowner who wishes to work the community in order to shape a proposal which meets the needs of and can provide wider benefits to the area. The Emerging Concept Proposals 2.45 The supporting Vision Document includes three potential scenarios for the site to represent the wide-reaching opportunities that the site offers; ● Scenario A – Do nothing (the existing accommodation extends to circa 3,500m2, including outbuildings); ● Scenario B – Retention of Salisbury Villas with development to the rear, potentially linked to the Villas (a total net floor space of circa 16,000m2 could potentially be delivered plus public realm improvements along Station Road); and ● Scenario C – Demolition and redevelopment of Salisbury Villas (a total net floor space of circa 24,000m2 could potentially be delivered plus public realm improvements along Station Road). 2.46 The three scenarios have been assessed within the context of the four ‘big themes’ of the consultation document. The detailed scenarios assessment is included in the Vision Document but for reference a summary is included below. Scenario A: Do nothing 2.47 This scenario represents the status quo. The existing tenants would remain in place, essential repairs to the buildings would continue to be carried out, and the existing hard-standing and car parking would remain. 2.48 However, this also means that none of the potential benefits of redevelopment and the associated investment could be realised: no new floor space would be created for businesses to grow, no additional jobs would be delivered, the public realm would not be revitalised, no new trees would be planted or biodiversity gains implemented, no social value opportunities initiated and the existing villas would remain carbon-intensive and in need of rejuvenation. 2.49 Ultimately, this scenario would provide little opportunity for the Site to contribute to the four big themes and to ‘do nothing’ would represent a significant missed opportunity. Scenario B: Retention of Salisbury Villas with new development to the rear 2.50 This scenario retains and refurbishes the villas, including removing the unsightly outbuildings in the rear gardens. Several of the gardens could be joined to form larger development plots. 2.51 A group of three larger buildings, likely commercial in use, are proposed to the rear of the villas as free-standing buildings. These new buildings are envisaged to be connected to the existing villas through linking elements, but they could also remain separate from the villas with their own access. These linking elements might accommodate stair cores and lifts, and are inserted either side of glazed atriums that provide light and ventilation. Placing the cores in this arrangement creates large and efficient rectangular floor plates with no interruptions. 2.52 The existing villas can be refurbished to comprise reception rooms, meeting rooms, break out spaces, executive offices and other supporting facilities. New deeper basements can also be considered to maximise area. 2.53 The buildings will most likely require some level of articulation and stepping, to mitigate potential overlooking and overshadowing towards the north. Some stepping may also be required along the west boundary towards the houses at Claremont Gardens. 2.54 This Option clearly provides a greater range of benefits when compared to scenario A, in terms of creating a range of new jobs, boosting the local economy and spearheading the move to a net zero-carbon society. Scenario C: Demolition and redevelopment of Salisbury Villas 2.55 This scenario envisages the complete demolition of the villas and their boundary walls in order to create larger development plots for a series of new buildings with efficient and modern floorplates. 2.56 In this scenario, there is an opportunity to move the building line slightly further forward closer to the road, while still retaining the avenue of lime trees and the potential for generous public realm improvements. 2.57 This option delivers the most floor space overall, and has scope for adding greater height to the new buildings along the Station Road frontage as well as notable benefits through the construction of modern, purpose-built commercial floorspace built to the highest environmental standards to create the largest opportunity for new jobs in a highly-accessible location. Summary 2.58 The site represents an opportunity to provide a commercial-led scheme in a highly accessible location; a location that has a proved track-record to attract high calibre businesses. A high-tech AI (Artificial Intelligence) cluster has already formed in the adjacent new commercial buildings; attracted by their modern, efficient floorspace all group together to revel in the wellevidenced benefits of clustering. 2.59 The site is the last piece of Station Road that does not have a long-term Vision for how it should respond to Area of Major Change Policy and the major development changes that are occurring to the Station Area. The site is an underused asset in one of the most accessible and sustainable locations in Greater Cambridge and it is appropriate for the emerging Local Plan to include the site for commercial development. A suite of supporting documents accompany this representation, including a Vision Document to set out an understanding of the existing site and to present three development scenarios that represent the wide-ranging opportunities that the site offers; from a do-nothing scenario to a full redevelopment. Each scenario has its pros and cons, but the greater the development, the greater the benefits for job creation and forming sustainable development. 2.60 The full redevelopment offers the greatest opportunity to achieve the lowest carbon intensity; the lowest carbon per employee on site. 2.61 The Council has recognised the climate emergency and aspires to move to a net zero carbon society. To achieve this, it cannot repeat the pattern of historic decisions and previous planning priorities. It must make some strong choices to prioritise those developments that can maximise long-term sustainable benefits; to so this there will be impacts to other planning matters, not all matters can be prioritised. 2.62 The development potential held by the Site offers the opportunity to achieve a number of significant benefits: ● To reduce the carbon intensity four-fold of the site per employee (CO2e/FTE) as CO2e/FTE from 0.75 for the existing building down to 0.18 through a modern redevelopment; ● To increase the GVA contribution from circa £9 million from the existing buildings to £85 million from a full redevelopment; ● To increase the number of jobs (full time equivalent) from 170 jobs to 1,800 jobs ● To achieve significant public realm benefits to Station Road – including major enhancements for pedestrians and cyclists as a major thorough-fare to Cambridge Station; ● To increase the amount of public open space facing Station Road, from what is currently a completely private and walled site; ● To reduce car parking in a city centre location; ● To deliver bespoke high-quality architecture; a landowner that wishes to engage with stakeholders and provide architecture that will be a legacy to be proud of; and ● To deliver 10% net biodiversity gain.

No uploaded files for public display

Agree

3.1 Agree. 3.2 The proposed Local Plan period up to 2040 is considered appropriate and to accord with the requirements set out within the NPPF for local authorities to identify a sufficient supply and mix of sites between years 1-15 of the plan (Para 67).

Agree

4.1 Agree. 4.2 The four big themes for the Local Plan are considered suitable and all are considered to be important in the consideration of the spatial distribution of growth in the district, and for the determination of planning applications. The four big themes will generate a new way of planning, this may require a different way to make decisions; to allow other impacts to happen in order to achieve these four priorities. The Local Plan policy framework will need to allow for a clear planning balance to take place to assess and prioritise impacts.

4.4 The increased focus on climate change is welcomed. Climate change policy and good practice is changing quickly, and the plan will need to build in suitable flexibility to accommodate these changes within the lifetime of the plan. Climate change scenarios predict extensive changes by 2050, much of which is dependent on government and human action so there is substantial uncertainty over outcomes. 4.5 A needlessly stringent policy may inadvertently impede progress towards later years in the plan or undermine results by not allowing for site-specific refinement. For example, policy for electric vehicle charging points should be sufficiently flexible to accommodate that quickly changing technology, as well the current grid challenges in implemented EV charging places. Energy policies should include flexibility for changing legislation, and technology, as well as the opportunity to refine a plan-wide policy for site specifics. As the Zero Carbon Futures Symposium Report (2019) submitted within the evidence base notes on page 10: where targets are too limited, and without consideration of project contexts, policy can drive dysfunctional behaviour such as photovoltaic solar panels being installed on North facing roofs merely to achieve policy compliance not to produce effective carbon reductions. 4.6 Allowing for changing technologies and approaches should also help with viability as technology and approaches improve and are more widely adopted, thereby reducing costs. Escalating targets and policies may be able to accommodate these changes, while providing clarity to developers on the costs of development over time. 4.7 The local plan Sustainability Appraisal (SA) should address variable climate change scenarios, as we would expect that different climate changes scenarios will be of interest at examination. Lack of rigorous assessment of these scenarios in the SA is could lead to the plan being found unsound. 4.8 The Plan needs a policy framework that priorities climate change and zero carbon in a planning balance judgement.

4.9 Greater Cambridge is a leading local authority on climate change policy, such as through the early declaration of a climate change emergency and also through the newly adopted Sustainable Development SPD. This leadership should continue, as it is central to the sustainable development of Cambridge, leading to better development for humans, the environment, and for economic development. It should be borne in mind that Cambridge's knowledge economy increasingly demands high sustainability standards: sustainability, health and wellbeing, with climate change at the heart, is a key part of continuing Cambridge's economic development. This should remain a priority as part of a policy framework the recognises climate change as a key part of sustainable development across social, environmental and economic objectives.

Nothing chosen

4.10 A policy approach with multiple options for delivering net zero carbon is likely to be most effective in delivering development, as well as carbon neutrality. A multi-pronged approach should allow different solutions for different developments, reflecting context.

4.11 The Local Plan should form a flexible policy framework, so as not to stifle the benefits of new technology or modern methods of construction. 4.12 For reference as to how Land to the north of Station Road could contribute towards adapting to climate change and achieving net zero carbon please refer to Section 2 of these representations, the Vision Document prepared by Allies and Morrison, the Sustainable Transport Appraisal prepared by Vectos, the Preliminary Ecological Appraisal prepared by Ecology Solutions and the Arboricultural Survey prepared by Haydens. 4.13 The Plan needs a policy framework that priorities climate change and zero carbon in a planning balance judgement.

4.14 This Local Plan must deliver effective policy which protects and enhances natural capital. We support delivery of net gain for new development. Such policy must be flexible enough to enable creative and cost-effective solutions for the delivery of net gain and support the Vision for the Natural Future of Cambridgeshire in 2050 as outlined by Natural Cambridgeshire and affiliated organisations. An off-site net gain solution should be clearly allowed for by policy. While it is a Local Plan priority as a part of one of the four big themes, the Local Plan policy must allow for a planning judgement and balanced decision to allow for site and development specific issues to be taken into account. 4.15 For reference as to how Land to the north of Station Road could improve the natural environment please refer to Section 2 of these representations, the Vision Document prepared by Allies and Morrison, the Sustainable Transport Appraisal prepared by Vectos, the Preliminary Ecological Appraisal prepared by Ecology Solutions and the Arboricultural Survey prepared by Haydens. A site that can offer 10% net biodiversity gain.

4.16 This should come through from an up to date base assessment of Greater Cambridge assets, which leads to a Local Plan wide (and beyond) strategy. Development proposals can then be shaped around the identified priorities. As part of a policy framework that allows for off-site mitigation and off-site net gain enhancements can be used to improve the wider green space network. 4.17 Development proposals that can enhance the quantum and connectivity of green and public spaces should be supported.

4.18 The new Local Plan must ensure that policy in this matter is sufficiently flexible to accommodate the required biodiversity net gain in the most effective and efficient way for each development, with both on-site and off-site solutions possible.