Waterbeach New Town SPD

I do not agree with the old part of the village being used as a cut through by even more traffic. I think construction traffic shouldn't go through the old village. Waterbeach Community Land Trust should be given some land to build an eco project.The carbon footprint of all the development needs to be minimised.

COMMENTS MADE ON SA SCREENING DOC:
Sustainable eco building with minimal cars outside centre,like Eddington,Cambridge and Houten,cycle town in the Netherlands. Global warming is now drastic 5 years possibly to the point of no return to save the planet. This must now impact on all future building plans. Shouldn't Cambridge lead the way of what is right to do. Build a new town with public transport and cycling as key features. People First as Waterbeach Cycling Campaign argued. RWT had bikes close by and cars only to houses for dropping off in one original plan. Residents are more likely to use their bikes then or walk to the station.

The new station needs direct access from the A10 to go people to switch to the train. The train platform will need to be able to accommodate 12 carriage trains.

The vision in the SPD (described in p30-31) is for Waterbeach as "an environmentally sustainable new town, where it is easy for people to make the transition to a low carbon lifestyle. This means making the best use of energy, water and other natural resources, securing radical reductions in carbon emissions, minimising the environmental impact and being capable of adapting to the impacts of climate change"

This vision is aligned with Policy SS/6 of the newly adopted S Cambs local plan which specifies that Waterbeach New Town "will deliver an example of excellence in sustainable development and healthier living".

We support this.

However, we are objecting to the SPD on the grounds that it needs to demonstrate much more ambition, particularly with regard to energy efficiency and decarbonisation, if it is to come close to delivering on either the policy or the vision.

Much more ambition on energy efficiency and decarbonisation
This policy requirement to deliver excellence in sustainable development has become even more important than it was when the local plan was drafted because of the increasing urgency of addressing climate change. This is given force by the following legislation and policies.

National requirements: The UK's legally binding Climate Act, requires the UK to achieve a reduction in Carbon emissions of at least 80% by 2050. This is a challenging target and likely to be made even more challenging shortly, given the legally binding commitments of the 2015 Paris Agreement, and the recent IPCC report on how we can achieve a global temperature rise of no more than 1.5C. On 15 October 2018 the government officially asked the Committee on Climate Change to advise on whether to set a Net Zero target. Insiders say that it is considered likely that the CCC will advise that the UK should set a net zero target for somewhere between 2045 and 2050. As the construction of Waterbeach New Town won't be fully built until shortly before this, if it is to demonstrate "excellence in sustainable development" must pay serious attention to achieving Net Zero carbon emissions in use and in construction.

The National Planning Policy Framework of July 2018 (para 48) says that "the planning system should support the transition to a low carbon future in a changing climate" and that it should help "shape places in ways that contribute to radical reductions in greenhouse gases" [our emphasis] Simply specifying 'Building Regulations' energy efficiency is not contributing to a "radical reduction in greenhouse gases"

The newly adopted S Cambs local plan specifies that Waterbeach New Town "will deliver an example of excellence in sustainable development and healthier living" and specifies (4.10) "high levels of energy efficiency" When the S Cambs local plan was prepared it's authors may have been in doubt whether they had the power to require higher standards than building regs. However, in clarification of the July 2018 NPPF the government confirmed that local councils do have the power to require this. https://www.ukgbc.org/news/government-confirms-local-authorities-can-set-energy-standards-beyond-part-l-in-nppf/

Energy Efficiency
If Waterbeach New Town is to meet the requirements of the S Cambs local plan to deliver an example of excellence in sustainable development, it is wholly inadequate to specify that homes are built to building regs + 10% carbon reduction due to onsite Renewable Energy. We also note multiple loopholes allowing developers to wriggle out of their responsibilities.

The SPD should specify that all new homes should be Net Zero carbon emissions in operation by 2030. At a very minimum, the required should at least match, and preferably exceed the standards set by other developments. For example:
* Greater Manchester committed on 21st March 2018 to the introduction of a zero carbon standard for all new homes and buildings in the updated GM Spatial Framework
* North West Cambridge ie Eddington required all homes to be CSE Code 5 https://www.cambridge.gov.uk/media/2710/north-west-cambridge-area-action-plan.pdf
* Cambridge City and S Cambs are now a joint planning authority. At a very minimum, the Waterbeach SPD should meet the standards specified in policy 28 of the Cambridge City Local plan, which specifies carbon emissions 44% better than part L of 2006 building regs (ie 19% better than current regs) or what used to be known as CSE Code 4 . Note that Code 4 was commonly used as a standard for Social Housing, so this standard supports aspirations to provide affordable and social housing.

Further detailed Guidance for local authorities on achieving sustainability in new homes is given by the UKGBC here https://www.ukgbc.org/wp-content/uploads/2018/09/Driving-sustainability-in-new-homes-UKGBC-resource-Sept-2018-1.pdf

Decarbonisation
Rather than just requiring developers to "think about" providing smart energy systems, the provision Smart Energy systems should be mandatory. The provision and smart management of significant quantities of on-site renewables and storage will be vital for delivering an attractive place to live well before 2030. Given the limited grid capacity in the area, this is already urgent, and it is only likely to become more important as the power grid further decarbonises, and the demand for electric vehicles and electric (or heat pump) space heating and becomes widespread.

Regular review of targets
As Waterbeach will take 25 years to build, we are calling for regular reviews (say every 5 years) to allow targets to be increased in line with government policy, the advice of the Committee on Climate Change and science based targets for how to achieve the necessary reduction in carbon emissions.

Mitigating climate related Risks
Even if we all act to reduce Carbon emission as fast as is technically possible, we will face increasingly significant risks from our changing climate. To somewhat mitigate these risks for the inhabitants of Waterbeach, the SPD should set firm standards to require developers avoid overheating during heatwaves, particularly in single aspect south facing flats (for example by providing shading, solar control glazing and through ventilation)

Flood risk also needs serious attention, particularly in the high risk areas to the Eastern part of the development, which includes the strategically important areas surrounding the train stations (current and new).

I broadly support the principle of a New Town, and support the South Cambridgeshire District Council (SCDC) vision to have a development with high levels of active transport (cycling and walking), but are concerned that the SPD does not go far enough to deliver such a development.
I am very disappointed to see that the SPD is essentially a combination of the two outline planning applications which have already been submitted by the two New Town developers - Urban and Civic, and RLW. The whole point of an SPD is for the planning authority to create a framework it wants the developers to use in line with the Council's vision and expectations for the community it is creating. This vision should be as aspirational as possible outlining clearly and prescriptively how the developer should undertake the development of the site in adherence to the Council's vision. Instead, it appears the production of this document has been driven by the developers rather than the District Council. The vision presented by SCDC in Section 3 is commendable, but the proposals presented in the subsequent chapters do not support this vision.
It is interesting to note that I cannot see any of the public's concerns that I read or heard when I attended the numerous public consultations in the village have been addressed in the submitted planning applications by the developers, and none of these concerns have been addressed in the SPD.
I do have significant concerns about the impact the development will have on the existing village, especially for residents in the Cody Road area. The SPD needs to be much stronger to ensure that impacts on the existing village are limited.
I have used WBCC document as a framework for my comments and have kept their comment structure to help make my consultation response clear, so I have put structured this document using the same titles as in the document, have put quotations from the SPD in red, with my comments and proposals for changes to the SPD in blue. I have used bold to emphasise my key objections.
Section 3 - Vision
This section gives the vision for the development. I support much of this vision, but the SPD does not provide evidence to realise the vision. Much of this consultation response offers changes to the SPD to help improve the SPD such that the SCDC vision can be met.

I fully support the aspiration for a development that is (page 29), "WELL CONNECTED - Easy to move around, in an environment where active travel and public transport are the norm." There is little evidence in the SPD that the new town will meet this aspiration.

I fully support the statement in the vision (page 30) that, "Walking and Cycling will be given priority", but there is little other evidence in the SPD that this will be the case. An additional clause is required in Section 6 under "Pedestrian and Cycling infrastructure (page 118) to give pedestrians and Cyclists priority. This table should have an entry as follows:
Infrastructure Scheme Description Other Columns...
Pedestrian and Cycle routes within the new development Segregated Cycle routes built along all roads within the development will give cyclists priority through all junctions. Pedestrians will be segregated from Cyclists on all routes. TBC by SCDC.

Section 4 - Towards a spatial framework
This section establishes the key structuring elements of the New Town. Many of these elements will encourage a development with high levels of car use, which does not support the SCDC vision laid out in Section 3.

The SPD proposes (page 40), "A small car park located at the existing entrance to the barracks could enable residents of the village to park close to and then walk to the new town centre." This does not support the SCDC vision stated in Section 3, and I strongly oppose this proposal, and request this proposal is removed from the SPD. A car park in this location will:
● Encourage existing residents to drive around the village rather than walk, cycle or use public transport.
● Increase traffic within the village, making the roads more hostile to pedestrians and cyclists.
● It will also greatly reduce footfall into existing village facilities (shops, eateries).
A small number of disabled only parking spaces close to the town centre (within the development) could be provided for those who have a genuine need to use cars to reach the town centre.

There is a proposal (on page 41) that, "A separate access to the railway station from the village will be created and retained for the benefit of residents of the village and from Horningsea, utilising access from Cody Road". This does not encourage active travel as laid out in the Vision in Section 3 and I strongly oppose this proposal. This proposal:
● Will bring additional traffic through a predominantly residential area within the existing village. Cody Road is the main route for parents and children to access Little Stars Nursery - many of whom walk and cycle. It is also used by residents of the Cody Road estate to take children to school and to walk or cycle into the rest of the village.
● Will encourage existing residents to drive to the new station rather than walk or cycle.
● Will be used as a route for villagers from Landbeach and Cottenham to drive through the village to the station as well as those from Horningsea.
● Will add more traffic to the staggered junction from Way Lane onto Cody Road. This is already busy, and a dangerous crossing to make on bicycle. Adding more traffic to this junction is not acceptable it is also the main route to school by parents and children from Bannold Road and Cody Road.

RLW have claimed in their transport assessment that there will be no additional journeys made through the village, as traffic currently travels through the village to the existing station. Rerouting this traffic through the village to the relocated station will result in these cars passing close to the GP Surgery, Primary School and Little Stars Nursery- which leads to an unacceptable risk to the people (including children), who regularly use these facilities. Additionally, the longer (8 car) trains and large carpark proposed at the station will lead to increased use of the station and more journeys made by car, all of which will pass along Cody Road.

I would like to see all traffic to the new station (including that from the existing village) to be routed through the New Town. This will help drive a modal shift from car to walking/cycling for journeys made to the station from the existing village, and will reduce traffic in the Cody Road area.

Figure 17 (page 42) shows a school located at the A10 entrance of the development site. I strongly oppose this proposal. Locating a school here will encourage parents to drop children off by car, and continue to commute to their workplace by car. Additionally, the proximity of the school to the A10 will lead to elevated exposure to air pollutants for school children.

To encourage fewer car journeys (and to change the mind-set of the next generation of children such that they consider cycling and walking to be the normal modes of transport), schools need to be located away from the primary street network with a 'No parking' zone around them. This is commonplace in Europe and is becoming more popular in UK - eg in Hackney https://www.hackney.gov.uk/school-streets and has considerable air quality benefits for school children both in school, and during their journeys to and from school. Studies have found that people are exposed to higher levels of air pollution inside a vehicle than those cycling or walking outside because particulates build up inside the vehicle[1]. This innovative and important initiative should be used within the New Town, and be enforced through a criterion in the SPD.

Figure 17 (page 42) does not have a complete key, it is unclear what the pink lines on this figure are representing. Please can you provide a complete key?

The criteria for the future location and design of schools (page 43) includes "proximity to primary and secondary road network." This is an unacceptable criterion for both active travel and air quality reasons, and will lead to high levels of car use within the development. This will make journeys by car the easiest way for parents to drop their children off at school, who then will likely continue by car to their place of employment. This clause needs removing from the SPD and replaced with a clause supporting 'no parking zones' around all schools as discussed above.

The primary movement network is presented in Figure 18 on page 45. This shows a highly interconnected road network for cars, with routes bisecting the new town as a whole. This network will encourage car use for journeys within the development, with cars being able to make direct routes between destinations within the development. This road network will also bring external traffic through the middle of the development site. Crossing this road will discourage walking and cycling within the site. The two primary routes bisect at the town centre where there will be the highest concentration of pedestrians and cyclists. I strongly oppose these proposals, which is contrary to the SCDC vision of prioritising walking and cycling.
It would make more sense that primary routes are taken around the edge of the site, with radial connections linking sectors of the development site to the primary route. Connections linking sectors of the development through the middle of the site should be limited to pedestrians, cyclists and public transport. This model has been used great effect in the Netherlands, for example the town of Houten[2]. The primary road network for Waterbeach New Town needs to be taken back to the drawing board to make sure that the development meets the vision of a development with high levels of active transport.
Statements on page 45-46 are directly contradictory:
● Development proposals must emphasise and prioritise sustainable patterns of movement across the New Town (see Principle 1).
● The primary street network will play a key role in the wider character and legibility of the site, as well as being key vehicle routes. Quality of the public realm and surrounding built environment is essential to creating routes which are attractive for walking, cycling and public transport, and which connect rather than divide neighbourhoods.
● The Primary route/ high street will also be a highly active location where social life takes priority over vehicle movement. It will be appropriate to limit and tightly manage vehicle access to the high street and town centre area
The proposal shows a primary route through the middle of the town. Providing a "highly active area" which is "attractive for walking, cycling and public transport" is incompatible with a primary route through the area. This needs to be improved by adopting a different model, such as the Houten model mentioned above.
Page 46 has a proposal that "All pedestrian and cycle routes will be direct, safe, continuous and attractive." It would be good to expand this to include "and also be designed with strong natural surveillance to bolster personal security".
Page 46 lists a link to Chittering as a strategic walking and cycling route, but Figure 31 on Page 70 does not show this as a strategic connection. It is important that this connection is given the status of a strategic connection, with a surface suitable for all weather journeys. Residents in Chittering (which is part of Waterbeach parish) will want to access the New Town and existing village facilities, and currently have no options for cycling to the south.
Page 47 states that "All pedestrian and cycle routes will be direct, safe, continuous and attractive." How can this be the case if they are broken up by primary and secondary vehicle routes? The SPD requires firm guiding principles to make direct, safe, and attractive routes.
On page 60 there is a proposal that, "Some of these proposed dwellings will use the proposed new vehicular access road serving the proposed relocated train station for their access". I strongly object to this proposal. This statement is removed, and there be a clause in the SPD that "All dwellings in the New Town will be connected to the New Town road network and not the village transport network". It is unacceptable for there to be a vehicular link between the village and the new town and we were told categorically in the consultations meetings that this would not happen.
Figure 29 on page 61 shows connections across the land ownership boundary on primary and secondary routes, but not cycle and pedestrian routes (only the vaguely worded "other connections"). It is important that connections across the land ownership boundary for cycle and pedestrian routes are agreed within the SPD as these will become important links through the development. These cycle and pedestrian routes must be afforded the same importance in the SPD as that given to primary/secondary road links. I can see routes not being built, or being built in suboptimal locations unless they are agreed at this stage. Please update the figure to provide firm proposals for these connections.
Table 6 on page 67 gives the land use budget for the development. This table does not include any land allocation for pedestrian/cycle paths off road. This table needs to be amended with an entry for cycle/footpaths to ensure that sufficient land is allocated from the outset for this infrastructure.
In Table 8 starting on page 72, it is stated that (page 73) "Sustainable modes of travel should be phased at the earliest opportunity". This is too vague - this statement should be replaced by "Sustainable modes of travel should be phased before first occupation"
Section 5 - Guiding Principles
Figure 32 on page 84 shows the primary walking and cycling routes being the same as the primary and secondary roads. On page 83, it is stated that Primary streets will include segregated cycle paths, but there is no mention of secondary streets. Cyclists and motor traffic must be segregated on all streets including secondary routes. This is important to make sure that children and other less confident cyclists use cycling as an everyday mode of transport.
On page 85 is the proposal, "When the rail station is relocated, a separate access to the rail station will be created through the village to enable existing residents of the village to be able to access the station without having to go out onto the A10 and access it through the New Town." I strongly oppose this proposal which must be removed from the SPD if SCDC want to achieve their vision of transportation mode shift from everyday car use to other modes of transport (page 7).
On page 85 is the proposal, "Vehicular connections between the village and the new town will be restricted to public transport only. This could be enforced by the use of a bus gate or similar restriction." To ensure that this is delivered, this measure should be a fix, not a guideline.
On page 86 is the proposal "Streets which have a limited role in the movement network should be laid out to discourage through-traffic. A filtered grid of residential streets can facilitate this whilst retaining permeability and a choice of routes for pedestrians and cyclists." To ensure that this is delivered, this measure should be a fix, not a guideline.
On page 87 are proposals for mitigating impacts on the surrounding road network. These should also be fixes rather than guidelines.
Page 88 states that, "In order to mitigate the impact upon the A10, the development must achieve a significant modal shift towards public transport and active travel", and then goes on to describe the following highway improvements: "Strategic highway improvements that could include on or off line dualling of the A10 corridor, and upgrades the junctions on the corridor including Milton Interchange", and, "Local highway improvements to mitigate development impacts at all points where capacity challenges are identified". These two measures will achieve the opposite of modal shift, and will ensure that the development becomes car-centric. These measures should be entirely removed from the SPD.

These 'improvements' to the road network will have an air quality impact. Developments should not be allowed[3] where they are likely to adversely impact an Air Quality Management Area (AQMA). The closest AQMA to the development site is the A14 at Milton. It is essential that impact upon the A10 be mitigated to avoid reducing air quality within this AQMA.
On page 89 is the statement, "Key cycle and bus connections to Cambridge and other key destinations should be phased at the earliest opportunity. The relocated railway station should also be provided as early in the development as possible." This is too vague and needs to be reworded so that the measures are provided before first occupation. It is important that there is a behaviour of active transport from day one. If new residents begin using their cars for common everyday journeys because the infrastructure is not built, it will be more difficult to achieve the behavioural shift later.
Section 6 - Delivering the place
The proposals in 6.2 - Infrastructure Delivery Plan have "trigger" points which defines when the infrastructure will be delivered. WCC have proposed some changes to certain trigger points below, such that active transport is available as an option from Day 1 for all residents of the new town.
● On page 118 are proposals for "Improved and new foot/cycleway from Waterbeach to north of city (including bridge over A10)", with the vague trigger "To be identified through the transport assessment process". This trigger must be changed so that this link is available pre-occupation, as new residents are likely to work in Cambridge and the current options for cycling to Cambridge are dangerous (A10 cycle route) or not suitable for commuting (Hayling Way - river path).
● It is important that the link to Cottenham (page 119) is delivered pre-occupation. This is the location of the secondary school for the development up to the point where the first secondary school will be built in the New Town (trigger point 2000 houses), which is likely to occur at around 2030. It is important that children have the opportunity to cycle to school for the first few years of the development.

● The traffic calming and improvements to junctions within Waterbeach village, on page 121 need to be delivered pre-occupation, or at least before the Train Station is relocated, as the measures will help to mitigate traffic impacts on the village from the Train Station move.

● It is important that the A10 junction (southern access) road on page 122 is delivered pre-occupation, as this will ensure that there is a link to the new station for traffic from outside the village, and will provide a route for construction traffic to access the RLW portion of the site without using the village road network.

Page 140 describes work to be carried out in Phase 1 of the New Town development. To ensure there is no traffic brought through the existing village to the new station, the following bullet point should be added to this list:
● Direct access from the A10 to the relocated station for traffic to access the new station.

Figure 34 on page 141 seems crucial to understanding the phasing of the development, but there is no key provided, and no indication of where the first houses will be located within the phase. It seems to suggest houses will be built along the primary road network, which could be a disaster for sustainable transport aspirations. More clarification is needed in this figure.
Other Issues not covered in the SPD
Routing of Construction Traffic
There is no mention in the SPD of routing of construction traffic for the development. I have concerns that RLW will route construction traffic for their development through the existing village and along the (consented) route to the relocated train station off Cody Road. I cannot accept an SPD which allows construction traffic for the new town to be routed through the village - all construction vehicles need to be routed through the development site directly from the A10 - both for the U&C and RLW developments.

I have uploaded two documents created by Waterbeach Cycling Campaign that provide a vision for the development that reflect my views much better than the SPD .

Emergency Services:
I can find no provision for these in the plan. If the new town is considered to be self-sustaining and the major settlement in the area would it not make more sense for the new town to host the emergency and civic services?

Social responsibility for an ageing population:
Very little mention and nothing stipulated. What thought has been given to enabling this?

Education:
Choices are available at primary school level without the need to travel out of the town. Please could choices be assured at secondary level perhaps as a free school, a school with religious ties or a private education. A significant number of families in the local area do not currently get their first choice of secondary school. Addition of the first wave of New Town children to an area with several oversubscribed schools will make the situation worse. Building schools earlier in the plan would be of benefit to the new town and also many neighbouring communities. (Please explain: If 9,000 homes are estimated to give 15 forms of secondary school entry and there are an additional 3 forms expected from the existing village why is only 2 x 8 form entry planned?)
Please provide at least one 11- 18 educational institution to give the option for maintaining continuity on transition to further education rather than having to change establishments.

Local shops:
How do you ensure a good range of facilities? Are shop units built and let to anyone or do you invite expressions of interest from, for example, a bakery, a newsagents, a convenience store, a café etc....

Tourism:
Tourism could have a positive effect on the local economy. Is there scope to promote visitors/ecotourism to the Fen by providing camping or similar on the eastern outskirts of the development?

Station:
For existing station users outside of Waterbeach village, primary access should be via new town with secondary access for existing village residents only to avoid additional traffic on Bannold Road.

Cycleways:
To improve safety for all, cyclists should have their own cycleway which does not share roads or footpaths but has it's own distinctive design and runs alongside roads and footpaths. Perhaps similar to a Dutch model.

Car parking:
I would like to see a design which encourages people who have chosen to drive to find a safe place to park and then walk a short distance to their destination rather than parking as close as possible and using their hazard warning lights if it is not a safe place!

Footpaths:
A refuse collection plan that does not require bins to be put out on the path would help those with pushchairs and mobility scooters to use footpaths more easily. Developing roads where it difficult to mount the kerb and park across the pavement would also be of benefit to pedestrians.

A10:
Clearer plans are needed. More joined up approach between county transport development and district housing development vital for both short and long term success. It feels like housing developments are being planned before knowing that there is a commitment to improving major highways.

Density of housing:
Too much for a Fen edge town. Developers should bring their numbers back down to 8,000 - 9,000.
Height of housing is not in keeping with fen edge location and should be reduced to 1-2 storey in most areas with some 2 -3 and a small amount of 3-4 in built up areas perhaps with a couple of 6 storey buildings. The number of dwellings proposed should be reduced to reflect this.
Reduce the number of dwellings in order to get housing density right and provide necessary buffer between new settlement and Denny Abbey. i.e. because the open space around Denny Abbey has been considered to count towards the statutory open space provision the remainder of the site is lacking in it's share of open space and should not be made to feel further overcrowded by increasing the housing density from that indicated in the local plan.

Housing style:
Height of housing and urban style not in keeping with fen edge location and neighbouring settlements. Would be very disappointed if house styles matched those seen in the proximity of the Cambridge Biomedical Campus.

Retention of Village identity:
The existing Waterbeach Community is likely to integrate better with the new community if it feels it's own identity is not under threat. Please provide a clearer physical divide (in the form of green space) between the existing development and the new all he way along the southern boundary. This could be set in from the land boundary towards the south eastern side to allow for existing housing on the former barracks area. It will also strengthen the bounds circlular amenity route.

Independent identity for the New Town:
It will feel less like the new town is going to swallow up the village if you give it it's own name and stop calling it 'waterbeach new town'. The two should be able to function independently and sit happily side by side.

Development to meet local need:
How do we ensure this development is used to meet local housing needs and not promoted to Londoners as a commuter town?

I fully endorse the recommendations and suggestions in the Waterbeach Cycling Campaign response to the Waterbeach New Town SPD. I wish the new town to take an ambitious approach to providing a people-first plan for transport, which prioritises the convenience and safety of pedestrians, mobility assistance users and cyclists, over the convenience of motor vehicle drivers.

Please consider my comments to be a copy of these recommendations: http://www.waterbeachcc.com/2018/10/waterbeach-new-town-spd-consultation.html

The vision in the SPD (p30-31) is for Waterbeach as "an environmentally sustainable new town, where it is easy for people to make the transition to a low carbon lifestyle. This means making the best use of energy, water and other natural resources, securing radical reductions in carbon emissions, minimising the environmental impact and being capable of adapting to the impacts of climate change"
This vision is aligned with Policy SS/6 of the newly adopted S Cambs local plan which specifies that Waterbeach New Town "will deliver an example of excellence in sustainable development and healthier living".
We support this.
However, we are objecting to the SPD on the grounds that it needs to demonstrate much more ambition, particularly with regard to energy efficiency and decarbonisation, if it is to come close to delivering on either the policy or the vision.
Much more ambition on energy efficiency and decarbonisation
This policy requirement to deliver excellence in sustainable development has become even more important than it was when the local plan was drafted because of the increasing urgency of addressing climate change. This is given force by the following legislation and policies.
National requirements: The UK's legally binding Climate Act, requires the UK to achieve a reduction in Carbon emissions of at least 80% by 2050. This is a challenging target and likely to be made even more challenging shortly, given the legally binding commitments of the 2015 Paris Agreement, and the recent IPCC report on how we can achieve a global temperature rise of no more than 1.5C. On 15 October 2018 the government officially asked the Committee on Climate Change to advise on whether to set a Net Zero target. Insiders say that it is considered likely that the CCC will advise that the UK should set a net zero target for somewhere between 2045 and 2050. As the construction of Waterbeach New Town won't be fully built until shortly before this, if it is to demonstrate "excellence in sustainable development" must pay serious attention to achieving Net Zero carbon emissions in use and in construction.
The National Planning Policy Framework of July 2018 (para 48) says that "the planning system should support the transition to a low carbon future in a changing climate" and that it should help "shape places in ways that contribute to radical reductions in greenhouse gases" [our emphasis] Simply specifying Building regulations energy efficiency is not contributing to a "radical reduction in greenhouse gases"
The newly adopted S Cambs local plan specifies that Waterbeach New Town "will deliver an example of excellence in sustainable development and healthier living" and specifies (4.10) "high levels of energy efficiency". When the S Cambs local plan was prepared it's authors may have been in doubt whether they had the power to require higher standards than building regs. However, in clarification of the July 2018 NPPF the government confirmed that local councils do have the power to require this. https://www.ukgbc.org/news/government-confirms-local-authorities-can-set-energy-standards-beyond-part-l-in-nppf/
Energy Efficiency
If Waterbeach New Town is to meet the requirements of the S Cambs local plan to deliver an example of excellence in sustainable development, it is wholly inadequate to specify that homes are built to building regs + 10% carbon reduction due to onsite Renewable Energy. We also note multiple loopholes allowing developers to wriggle out of their responsibilities.
The SPD should specify that all new homes should be Net Zero carbon emissions in operation by 2030. At a very minimum, the required should at least match, and preferably exceed the standards set by other developments. For example:
* Greater Manchester committed on 21st March 2018 to the introduction of a zero carbon standard for all new homes and buildings in the updated GM Spatial Framework
* Eddington required all homes to be CSE Code 5
* Cambridge City and S Cambs are now a joint planning authority. At a very minimum, the Waterbeach SPD should meet the standards specified in policy 28 of the Cambridge City Local plan, which specifies carbon emissions 44% better than 2006 building regs (ie 19% better than current regs) or what used to be known as CSE Code 4 . Note that Code 4 was commonly used as a standard for Social Housing, so this standard supports aspirations to provide affordable and social housing

Further detailed Guidance for local authorities on achieving sustainability in new homes is given by the UKGBC https://www.ukgbc.org/wp-content/uploads/2018/09/Driving-sustainability-in-new-homes-UKGBC-resource-Sept-2018-1.pdf
Cambridge Carbon Footprint knows from running Open Eco Homes http://openecohomes.org for 9 years that there is widespread, keen local interest in energy-efficient, sustainable homes: 3,800 people have made detailed tours of eco-homes, many in South Cambs. The huge majority of visitors are inspired to make their own home-energy improvements.
Our volunteers have thermal-imaged new homes with defective insulation and others with acute over-heating in the summer. It's imperative to avoid building new homes that will soon need retrofitting to meet the increasing necessity for climate change mitigation and adaption. Getting this right at the beginning for a small extra cost will save much bigger expenditure later.
Decarbonisation
Rather than just requiring developers to "think about" providing smart energy systems, Smart Energy systems should be mandatory. The provision and smart management of significant quantities of on-site renewables and storage will be vital for delivering an attractive place to live well before 2030. Given the limited grid capacity in the area, this is already urgent, and it is only likely to become more important as electric vehicles, electric space heating and heat pumps become more common.
Regular review of targets
As Waterbeach will take 25 years to build, we are calling for regular reviews (say every 5 years) to allow targets to be increased in line with government policy, the advice of the Committee on Climate Change and science-based targets for how to achieve the necessary reduction in carbon emissions.
Mitigating climate related Risks
Even if we all act to reduce Carbon emission as fast as is technically possible, we will face increasingly significant risks from our changing climate. To somewhat mitigate these risks for the inhabitants of Waterbeach, the SPD should set firm standards to require developers avoid overheating during heatwaves, particularly in single aspect south facing flats (for example by providing shading, solar control glazing and through ventilation)
Flood risk also needs serious attention, particularly in the high-risk areas to the Eastern part of the development, which includes the strategically important areas surrounding the train stations (current and new).

Summary
Overall number of dwellings
Pressure on existing village facilities during the initial phases of developments
Safeguarding transport in the existing village
Green spaces
The A10

Submission
While I understand the rationale for redeveloping the barracks area, I am not in favour of the adjoining area leading to the east. It is far from clear how the two developers will work together.

The Fenland nature of the area should be retained.

The Local Plan references 8-9 thousand units - so development should be contained within these limits.

What provision is there to ensure that existing village facilities already under severe pressure (roads, school intake, doctor's surgery) will cope before we trigger points on the new development are reached?

Access including construction traffic, should be off the A10 which requires upgrading urgently to cope with the increased demand.

The railway station should be retained where it is until at least 2,500 houses the New Town are occupied - or BOTH stations should remain operational, the existing one could serve the existing village, Landbeach and the proposed boating lake.

Many in the existing village moved here because of the good public transport links. They should.not be fairly penalised by the proposals. The existing village should continue to have direct PT links to Cambridge, ideally with a P&R stop serving the new town and the existing village. Once the station is moved then a free shuttle bus should be provided to meet all services.

The new developments at the north of the village (Bannold Road and Cody Road) have shown how easy it is to lose valuable green spaces so the new developments should ensure households can access these easily and feel safe using them.