Greater Cambridge Local Plan Issues & Options 2020

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.

4.3 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 redevelopment of Kett House and 10 Station Road could address the big themes in the following ways: ● Climate Change – Brookgate and Aviva recognise the climate emergency and wish to deliver a development that embraces the new agenda to work towards net zero carbon. The proposed commercial-led development will be designed to a high quality and incorporate low carbon technologies and energy efficiency measures. 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 future and existing residents. ● Wellbeing and Social Inclusion – the proposals would incorporate public-facing commercial uses to offer a choice of services for workers and residents in the area. The proposals would also 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 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.

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4.5 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 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. 4.7 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. 4.8 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. 4.9 Kett House and 10 Station Road is a brownfield site in a highly sustainable location with access to key transport links including the train station (which is 300 metres east of the site), the Chisholm trail link and numerous other public transport connections including local bus services and the proposed metro connections. The proposed commercial-led development on the site, in a highly desirable location for commercial development offers real opportunities to deliver low carbon, or even net zero carbon development due to the high value of the area.

4.10 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. 4.11 The densification and redevelopment of brownfield sites such as Kett House and 10 Station 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

4.12 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. For example, for some developments, Passivhaus energy standards may be achievable (going well above and beyond minimums set out in the Building Regulations), but for others, Building Regulations may need to be followed but an offset solution, such as a green bond or offset fund, could be used to achieve a net carbon reduction. Possible options need to be worked up in more detail as the Plan progresses and must build in flexibility.

4.13 The Local Plan should form a flexible policy framework, so as not to stifle the benefits of new technology or modern methods of construction. 4.14 As set out above, the redevelopment of Kett House and 10 Station Road can contribute towards adapting to climate change and achieving net zero carbon by providing more energy efficient buildings on site. The opportunities for achieving the Council’s climate change targets are more achievable through the allocation of higher density development in central locations such as the Travis Perkins site as investment can be made into achieving high standards of sustainability on site.

4.15 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. 4.16 Kett House and 10 Station Road could improve the natural environment by providing high quality public open space on site with potential for biodiversity features such as green roofs. In addition to this, strategic off site opportunities offer the opportunity to significantly increase biodiversity other than providing site specific biodiversity improvements.

4.17 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. 4.18 Public open space is proposed as part of the proposed redevelopment of the site. Public realm improvements including tree lined avenues and small pocket parks can contribute to the city’s green space network and contribute towards improving air quality.

4.19 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. Strategic off-site opportunities offer the opportunity to significantly increase biodiversity other than providing site specific biodiversity improvements.