Greater Cambridge Local Plan Issues & Options 2020

Brickyard Farm, Boxworth Farm, Boxworth, Cambridge

85 - 2025: 85.56

Site 47353 map

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Response to Question 2 - ADDITIONAL INFORMATION Proposed Employment Allocation 4.2 This submission, sits alongside and expands upon the ‘Brickyard Farm, Boxworth- Strategic Housing and Economic Land Availability Assessment Call for Site and Broad Locations, Supplementary Statement, December 2019’, prepared by Turley (a copy of which is provided at Appendix 2). 4.3 As highlighted within that submission, it is considered that the site provides a unique opportunity to deliver employment floorspace adjacent to A14. 4.4 The site has the capacity to deliver circa 251,000 sq. m of employment floorspace (achieving less than 30% site coverage) set within extensive landscaping, including the creation of a Country Park on the broad location of the existing Highways England compound area. 4.5 The masterplan has been formulated first and foremost against the backdrop of advice from Bidwells (please refer to Appendix 3 for full details) indicating a serious shortage of good quality industrial stock across Cambridgeshire and limited deliverable land for development, with live enquiries from occupiers seeking a presence in the area of 29,000 sq. of B2 space and 33,000 sq. of B8 floorspace. Market Assessment and Need 4.6 The aforementioned masterplan and proposed site allocation has been formulated following advice from Bidwells and supported by an employment ‘Needs’ Report, prepared by Turley Economics (Appendix 4). 4.7 These show a clear shortfall in suitable space to meet operator requirements. The shortfalls and opportunities are considered in detail within the aforementioned assessment and our responses to questions 24 to 28 in the preceding section of this report. Access and Highways 4.8 In terms of access, ADC Infrastructure Limited have been instructed from an early stage to inform and address access requirements for the site, including capacity assessments based on circa 251,000 sq. of employment floorspace. 4.9 The capacity assessment results confirm that a roundabout would be the appropriate access solution from a safety and capacity point of view given the HGV movements turning in and out of the site associated with employment uses. The roundabout would ensure no queuing and only minor delays of only a few seconds. 4.10 Moreover, the masterplan (Appendix 1) shows the roundabout is located to also provide the appropriate forward visibility splays of 215m. The masterplan also shows the section of Boxworth Road between the Cambridge Services roundabout and the site access widened to provide a 7.3 m wide carriageway and a 3 m wide shared use footway/cycleway on the northern side of the road. 4.11 In terms of accessibility, the nature of employment use and the location of the site mean that travel by car will be unavoidable. Notwithstanding this, consideration has been given to the accessibility of the site for employees by alternative means of travel to the private car. 4.12 One feasibility options is the provision of a shuttle bus from the site to Longstanton Park and Ride. Busway routes A, B and D provide buses up to every 7 minutes linking with Cambridge, and every 15 minutes linking with Huntingdon. The Park and Ride site would be a 15 minutes shuttle bus link from the site, using the B1050 and A14. The Park and Ride site is already set up to accommodate buses and it is staffed during the day, provides an office, waiting area and toilets. 4.13 In terms of timetable, combined, the A, B and D routes provide a frequent weekday and Saturday service, between 0700 to 2030 hours, with hourly frequency through to around 2345 hours. 4.14 In addition to the shuttle bus link, options will be explored in respect of cycling and cycleways and a host of measures, including car sharing which can be borne out through Travel Plans. 4.15 In terms of sustainability credentials, these are set out in more detail in response to Questions 8, 9 and 10 below. 4.16 Nevertheless, Newlands Developments take their sustainability credentials very seriously, taking a holistic approach including, as a minimum, energy and water efficient construction, maximising accessibility (such as the shuttle bus option), enhancing biodiversity and taking a responsible approach to the ongoing occupation and operation of their buildings.

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Response to Question 3 4.17 Given the masterplan provides substantial landscape buffers and the potential to create a Country Park on the broad site of the current Highways England compound site, it is considered that the site can deliver biodiversity benefits through the provision of green spaces and wildlife habitats.

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Nothing chosen

4.18 In general terms, Local Plans are encouraged to look forward at least 15 years when setting strategic policies as set out in paragraph 22 of the NPPF. The emerging Local Plan seeks a period of 20 years up to 2040. Given the period required through to adoption, we consider this date to be a reasonable and realistic light-time for the Plan. 4.19 That notwithstanding, and in order to respond to long-term requirements of particular uses and major improvements in infrastructure of which there are few in the region i.e. the A14 improvements, the Oxford, Milton Keynes and Cambridge Arc and the Cambridge to Norwich technology corridor, it is considered that the Local Plan should provide sufficient flexibility to respond for business and industry locational and demand changes that may result and in line with up-to-date market and needs assessments for all uses.

Nothing chosen

4.20 In addition to the cross-boundary issues identified, which we considered are of regional and national importance, the role and opportunities linkages to Felixstowe play within this economic corridor should not be underestimated. 4.21 The site’s location along the newly improved A14 provides a unique opportunity to address a long-standing need for a site capable of meeting the needs of national employment and logistic operators in close proximity to Cambridge.

Nothing chosen

4.22 We agree with the principle of the big-themes. This is however tempered by the ability of new development to accommodate the wide ranging planning policy requirements of Local Plans, especially in terms of viability.

4.23 The Local Plan will play a key part in achieving net zero carbon by 2050. Newlands Developments welcomes the 2050 target, and are already taking steps towards net zero carbon including the design and construction of highly insulated building envelopes with air tightness values well beyond those required by building regulations, installation of solar photovoltaics and highly efficient all electric heating strategies. 4.24 The details which underpin emerging zero carbon policy will be critical to ensure that aims are achievable and that development viability is not impacted. Rather than Greater Cambridge developing their own standard around net zero buildings, it would make sense to apply a recognised standard applied elsewhere in the UK, for example the UK Green Building Council’s Net Zero Carbon Buildings Framework (April 2019) and RIBA’s Sustainable Outcomes Guide (2019). This will help promote a common understanding across project teams and ensure that knowledge from projects elsewhere is relevant and directly applicable to those in Greater Cambridge in terms of what does and does not work as well as helping avoid the situation where national operators such as Newlands Developments are required to respond to varying standards across their estate. 4.25 Whilst the UKGBC Net Zero Framework covers both construction and operational carbon, it is the latter from new development which relates principally to the net zero target. This is due to the significant current challenges of designing for low carbon construction. It is recommended that the approach set out for construction carbon in the new London Plan Policy SI2 Minimising Greenhouse Gas Emissions should be adopted. This policy requires an assessment of construction carbon together with a description of actions taken to reduce these emissions, however it does not require net zero construction i.e. the offsetting of residual construction carbon following any reduction measures. 4.26 RIBA recognises the challenges presented by achieving net zero carbon, particularly for construction emissions, and has developed a series of climate change metrics for new buildings (covering operational energy, embodied carbon and potable water use) with targets for 2020, 2025 and 2030 that go increasingly beyond current performance to ensure that net zero carbon deadlines are met. This approach intends to help ensure the goal of net zero is achieved in a manner that recognises potentially significant technical and commercial implications to be addressed over this timeframe. 4.27 The ambition for net zero operational development requires building design that accords with the ‘energy hierarchy’ (by prioritising a “fabric first” approach) which is the most cost-effective means of driving down operational energy and carbon. It must be recognised however that such an approach is unlikely to achieve net zero in full. Therefore it is recommended that a minimum on-site CO2 reduction target of 35% below Building Regulations 2013 Part L is set through the application of the energy hierarchy. This target aligns with the London Plan which requires residual CO2 emissions up to zero carbon to be addressed via s106 contribution to that Local Planning Authority’s carbon offset fund. This arrangement makes it difficult or impossible to understand how these funds are invested and therefore Newlands Developments’ view is that Greater Cambridge’s zero carbon policy should provide the option for greater control by developers in relation to carbon offsetting, whether in part or in full, as long as such measures are of suitably high quality to address important considerations relating to offsetting. This approach will help address potential viability concerns associated with offsetting and help maximise the amount of offsetting that can be achieved for a given sum of money whilst maintaining offset quality and climate benefit. 4.28 Encouraging all-electric heating strategies within the Local Plan will allow development to connect to the national grid which is rapidly decarbonising, removing the reliance on natural gas which cannot currently be fully decarbonised. Electricity can also be purchased via Power Purchase Agreements (PPAs) or Renewable Energy Guarantees Origin (REGO) certificates which guarantee that an equivalent amount of electricity was produced from 100% renewable sources. 4.29 It should be noted that BREEAM does not recognise this route to net zero carbon within its Energy Section. For example, a building which offsets 35% carbon emissions using on-site renewables may not meet the mandatory number of credits within Ene 01 for an Excellent rating if the primary energy demand and/or heating and cooling demand is only a slight improvement over the notional. Including targets such as ‘mandatory number of credits for Excellent’ or ‘Outstanding’ should not be encouraged within the Local Plan as this can negatively impact the goal to achieve net zero carbon. 4.30 In summary, Newlands Developments supports the growing need to evaluate and seek to reduce construction carbon to contribute to Greater Cambridge’s net zero aspirations and use RIBA’s embodied carbon targets to help inform building design and construction however any proposal to achieve net zero construction must be subject to viability assessment.

4.31 Greater Cambridge recognises that carbon offsetting should be supported through tree planting. This recognition aligns with the UKGBC Net Zero Carbon Framework, and should be extended to recognising that whilst the Council can facilitate local planting schemes, developers should be given the flexibility to choose which offsetting schemes they fund and organise their own schemes to achieve net zero carbon. 4.32 Newlands Developments produce resource efficient buildings by specifying recyclable frame and envelopes, carpets with 80% recyclable yarns and naturally produced floor coverings. These materials reduce embodied carbon emissions associated with material production and end-of-life, which should be recognised within the Local Plan by requiring development to consider embodied carbon and reduce emissions where feasible.

Yes, strongly agree

4.33 Newlands Developments strongly agree with Greater Cambridge that climate adaptation and resilience features should be required for all new development. The UKCP18 climate projections predict that the UK will experience increased summer and winter temperatures, reduced summer rainfall, increased winter rainfall and increased extreme weather events. 4.34 Newlands Developments currently includes a number of features to protect buildings and their occupants against the impacts of climate change. This includes rainwater harvesting and water saving sanity fittings and extensive Sustainable Drainage Systems (SuDS) which provide additional benefits such as biodiversity enhancement, recreation opportunities for building users and mitigating urban heat island effects.

4.35 The UK Climate Change Risk Assessment updated in 2017 identifies key risks associated with the effects of climate change. In relation to the built environment and the proposed development these include reduced summer water availability, increased winter rainfall and increased summer temperatures. 4.36 Greater Cambridge acknowledges these risks but will need to ensure that the Local Plan policy addresses each issue comprehensively and fairly. Overheating is a significant risk to homes and businesses and is not currently fully assessed within building regulations. The Government has scheduled a consultation later in 2020 to improve the approach to assessing overheating risk as part of Building Regulations. Newlands Developments welcomes this and are already committed to undertaking overheating calculations on our new buildings to protect the future occupants. 4.37 Requirements for increasing planting within a development i.e. green roofs and green walls can reduce flooding, urban heat island effect and increase the biodiversity of a site. However, requiring installation of green walls and roofs in particular can come become detrimental to climate change mitigation measures such as solar photovoltaics and air source heat pumps. Where green walls are required, extensive irrigation may be required which becomes detrimental to avoiding water scarcity. 4.38 It is our recommendation therefore, that instead of recommending specific climate change adaptation features such as green walls and roofs, a ‘climate change adaptation’ study should be required to allow developers and design teams to take a flexible approach, managing the risks of climate change which are greatest to their buildings and occupants depending on use and location. 4.39 Another low cost approach to promoting climate change resilience in new development is providing high albedo (e.g. white) roofs to reflect summer sun and reduce overheating risks within buildings. Such as approach should consider potential adverse impacts from solar glare.