Draft North East Cambridge Area Action Plan

Nothing chosen

The policies to address climate resilience and change are welcome although we feel they fall some way short and are underachieving, with some obvious gaps. • The BREEAM ‘excellent’ set as a minimum standard only delivers a 25% carbon reduction, with an Energy Performance Ratio (EPR) ranging between 0.36 and 0.54. The Natures Arc Vision is for zero carbon emissions, therefore an ambitious and deliverable minimum BREEAM standard must be applied for an EPR of 0.90 to deliver zero net CO2 emissions. • Reference is made to green roofs, however the term ‘…..must contain an element of green roof…’ is open to provide as little as possible. For example, 5m² of sedum matting can be interpreted as ‘an element’. This policy would benefit from a challenging target for green roof provision of 3.2m² of green roof/person. ²⁹, ³⁰, ³¹ • Blue roofs are not referenced at all. These we would like to see included within the climate resilient measures if this scheme is to attain anywhere near its potential. A biosolar blue-green roof would be the ultimate level of climate resilient design.⁸ • There is no reference to the use of green walls as an additional technique for thermal regulation of buildings, absorption of atmospheric pollutants or attenuating run-off. • Solar panels are but inferred in Policy 2C and Policy 3 links to the Cambridge and South Cambridge Plans which make passing reference in Policies 29 and CC3, paragraph 4.17, • We would like to see all forms of street lighting be solar powered to ensure it contributes to reductions in carbon. Also, in respect of the impacts lighting has on wildlife as identified in the Biodiversity Assessment, the amount of lighting should be minimised and dark corridors for wildlife provided.³² • Water consumption and deficit is a national issue, the Cambridge area being no exception. We believe the proposed minimum 110ltr/person/day is totally unacceptable. There must be greater emphasis on an achievable target of 80ltr/person/day with all private and commercial dwellings using grey water recycling and increasing the capacity of rainwater harvesting. To this end, use of blue roofs would also contribute in accordance with Policy 4a of Water Efficiency.³³ • We are sceptical of the term ‘…reasonably practicable…’ in respect of source control management at the surface. Knowledge and design of SuDS source control is such there is seldom justifiable cause to send water below ground often into crates or through pipes to basins.³⁴ • The same ‘…reasonably practicable…’ terminology has also been used for off-setting potable water demand, which is liable to lead to under achieving. • While welcoming the use of future proofing we treat this with caution. Unless fully costed and justifiable as a last alternative, this leaves developers with a ‘get-out’ on delivering sustainability and climate resilience. While future proofed capacity to retrofit is helpful the costs, potentially more than at time of construction, can be limiting for a future occupier to meet, for example in green roof provision. ________________________________________ Qualifying points to responses: ⁸Green roofs help alleviate heat island effect, absorb atmospheric pollutants, provide summer and winter thermo-regulation of building temperature, acoustic insulation and reduce rates of run-off. Blue-green roofs provide protracted water storage which can either be released more slowly back into the system or for other purposes that will reduce the impacts on potable water supplies. This might also include the irrigation of green wall systems. ²⁹Based on the area required to meet Net Gain and estimated from the 18,000-population given. This is reasonably comparable to the area of green roofs/per person in the City of London. which is approximately 100ha larger, with less than half the resident population forecasted for NE Cambridge and where there are 5.47ha of green roof at 6.21m²/PP. ³⁰https://livingroofs.org/wp-content/uploads/2019/05/LONDON-LIVING-ROOFS-WALLS- REPORT_MAY-2019.pdf ³¹https://livingroofs.org/london-map-green-roof-boroughs/city-of-london/ ³²The guidance published by Bat Conservation Trust will additionally benefit other mammals, birds and invertebrates affected by street lighting: https://theilp.org.uk/publication/guidance-note-8- bats-and-artificial-lighting/ ³³Unequivocal evidence shows aquifers are suffering acutely from over abstraction, resulting in low flows across the catchment and impacting on rivers and wetland SSSI’s. This needs to be addressed by an ambitious policy that sets stringent targets for water efficiency. ³⁴Pipe to basin and or crates solutions compromise the opportunity to create hard and soft landscape features that manages surface water in a way contributory to placemaking as one of the objectives outlined in the policy.