Greater Cambridge Local Plan Issues & Options 2020

Agree

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

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; prioritising the four themes may require compromise in the balancing exercise in relation to other issues. The Local Plan will need to be on the need for a ‘planning balance’ in order to assess and prioritise the impact of development proposals.

Climate Change, Biodiversity and Green Spaces, Wellbeing and Social Inclusion, Great Places

Response to Question 7 The four big themes are all considered to be important aspects to achieving positive development. All four themes should be used to inform the spatial strategy within the Local Plan in terms of distributing growth and determining planning applications to deliver growth. It is therefore not considered necessary to rank the options in order of preference. 4.4 The proposed development of 104-112 Hills Road could address the big themes in the following ways: ● Climate Change – Pace recognise the climate emergency and wish to deliver a development that embraces the new agenda to work towards net zero carbon. The proposed commercial development will be designed to a high quality and long life-span. It will incorporate low carbon technologies and energy efficiency measures. During operation, the development will be free of fossil fuels and free of carbon emissions. The site is also in a sustainable location with access to excellent public transport connections including the new Chisholm trail link, thereby reducing residents’ reliance on private cars for travel. ● Biodiversity and Green Space – through the provision of on-site green infrastructure to create recreational and ecological assets to be enjoyed by the people of Cambridge. ● Wellbeing and Social Inclusion – the proposals will at its heart incorporate an improved public realm and deliver facilities that will promote healthy lifestyles and wellbeing through the provision of on-site recreation and the site’s accessibility to employment, education, shops and public transport by active and sustainable modes of travel. ● Great Places – there is an opportunity to maximise the site’s potential to deliver densification in a well-connected area, providing open space on site and opportunities for increased recreation.

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. 4.6 Whilst emerging policy should wholeheartedly support use of green modes of transport, such as electric vehicles and bikes/ scooters, a needlessly rigid policy may inadvertently impede progress towards later years in the plan or undermine results by not allowing for site-specific refinement. 4.7 For example, policies requiring the delivery of electric vehicle charging points should be sufficiently flexible to accommodate emerging quick changing technology, as well potential solutions to the current grid challenges in implemented EV charging. Such policies should also include flexibility to enable responses to changing legislation, 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. 4.8 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. 4.9 Where applicants are striving to deliver beyond widely applied ‘standards’, we would urge authorities to apply weight to the benefits of the uplift in standards within the planning balance. 4.10 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. 4.11 The redevelopment of 104-112 Hills Road offers a significant opportunity to regenerate a site and significantly reduce the carbon output of the existing buildings. As part of the emerging proposals, Pace has instructed its design team to prepare a scheme that will deliver an environmentally sustainable, green, smart building fit for the future and this commitment extends to encouraging its future occupants to access the site by green modes of transport, such as public transport, walking, and cycling. Where private vehicles are used there should be a strong emphasis on electric vehicle solutions.

Greater Cambridge is a leading local authority on climate change policy. This can be seen 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 people, 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. 4.13 Development should be promoted within previously developed sites that are highly accessible. Indeed, the densification and redevelopment of brownfield sites such as 104-112 Hills Road offer opportunities to maximise energy efficiency measures on site and achieving low carbon development, thereby helping to achieve the Council’s climate change targets.

Nothing chosen

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 their use, local context and site-specific opportunities and constraints. 4.15 In the context of commercial development, developers should be encouraged to strive to do more that the regulatory minimums, but policies should seek to ensure certainty of delivery. 4.16 Where achieving standards requires a different approach in the design of buildings, the Councils must consider this and apply weight to the benefits of delivering low carbon sustainable development. The Council will need to be cognisant that changes to what are current ‘design’ norms may change as buildings strive to achieve higher environmental standards and reduce their carbon and climate impacts. This may require greater flexibility and a greater degree of understanding in respect to the issues concerned in delivering highly sustainable new developments, and that this will come at a cost.

The Local Plan should form a flexible policy framework, so as not to stifle the benefits of new technology or modern methods of construction. 4.18 As set out above, the redevelopment of 104-112 Hills Road can contribute towards adapting to climate change and achieving net zero carbon by providing a more energy efficient building on site, replacing the previous less efficient buildings. The opportunities for achieving the Council’s climate change targets are more achievable through higher density development in central locations such as 104-112 Hills Road as investment can be made into achieving high standards of sustainability on site.

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 considered. 4.20 104-112 Hills Road will improve the natural environment by providing high quality public open space on site and biodiversity features such as green roofs, green street scape and amenity areas for the people of Cambridge.

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. Public open space is proposed as part of the proposed redevelopment of 104-112 Hills Road. Public realm improvements can contribute to the city’s green space network and contribute towards improving air quality.

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.