Greater Cambridge Local Plan Preferred Options

This policy introduces requirements for water efficiency in new domestic and nondomestic development in the form of the following:
• 80 litres per person per day for domestic development; and
• Full BREEAM credits for Wat 01 for non-domestic development.
Countryside acknowledge that the Greater Cambridge area is under water stress and there is a strong encouragement for all new development to improve water efficiency however with respect to draft Policy CC/ WE we have the following comments:
• We agree with the statement on Page 26 of the Topic Paper that the highest water efficiency standard that can be requested by local authorities is 110 l per person per day (pppd).
• We also agree that achieving 80lppd will require either rainwater harvesting and/ or greywater recycling. Both systems introduce significant maintenance requirements (and therefore cost) for homeowners and introduce technology that has not been tested ‘en-masse’. Countryside’s experience of trialling grey water recycling is that it is unreliable and likely to cause maintenance issues for homeowners
• Given the unreliability of greywater recycling Countryside believe the only practical mechanism to achieve the 80lpppd would be through the use of rainwater harvesting systems which have the following constraints;
‒ Such systems are more difficult for flats given that communal harvesting tanks (which are more expensive) would be necessary; and
‒ Greater Cambridge is already one of the driest areas in the UK and climate change is predicated to reduce rainfall in Greater Cambridge by 47% it is highly likely that rainwater harvesting will not capture sufficient rain to meet the policy target and will therefore be ineffective.
• Given the above, Countryside believe that the GCLP should implement the Government’s technical standard for water efficiency for Policy CC/ WE which is 110 lpppd. This would be viable, deliverable and achievable for all new dwellings within GC. Should technology such as grey water recycling become viable during the lifetime of the plan then this could be considered as a means to improve water efficiency beyond the target of 110 lpppd.

This draft Policy introduces requirements to design buildings in accordance with the Good Homes Alliance Overheating in New Homes Tool and Guidance. Countryside recognise the fact that all buildings will need to be designed to adapt to a warming climate and that, depending on the building type and location, this may necessitate the use of a range of measures as recommended in the Good Homes Alliance toolkit such as shading, thermal mass and different modes of ventilation. The policy requires new development to complete the Good Homes Alliance toolkit and implement the cooling hierarchy to minimise the impact of overheating.
Countryside believe that this policy may be ineffective as it requires each developer to implement the guidance in a manner that is appropriate for their site and which therefore may differ from one development to the next.
In January 2021, the Government confirmed the introduction of the FHS and also consulted on the introduction of a range of new building regulation requirements one of which was the introduction of an overheating testing requirement for residential development. This will require all new homes to undergo modelling during detailed design to identify any impact from overheating and then implement mitigation measures accordingly.
As this requirement is proposed to be introduced with the revised changes to the Building Regulation in 2022, Countryside believes that the policy would be unsound on the basis that it is introducing an unnecessary additional burden on development given that it duplicates the requirement of the building regulations.
Countryside believe that to reduce the planning and administrative burden upon the housebuilding sector in Greater Cambridge, Policy CC/ DC should be deleted on the grounds that its objectives will be required via Building Regulations.

This policy places requirements upon new development to manage their waste and embrace the principles of the circular economy. The policy requires the following from new development proposals:
• The submission of a Construction Environmental Management Plan (CEMP) proportionate to the size and scale of development
• Provision of adequate waste and material storage facilities on site in accordance with the RECAP Waste Management Design Guide (or successor)
• Submission of a Circular Economy Statement with each application.
Countryside fully support the strategic objective of the policy in terms of its objectives to reduce waste and, perhaps more importantly, encourage circular economy principles in development. As explained earlier in these representations, reducing waste is one of our key objectives and one in which progress is clearly being made on our sites.
We fully support the requirement to submit a CEMP for our sites as this is something that we already commit to as part of our best practice approach to waste management and environmental protection.
With respect to the provision of waste management facilities on site, Countryside agree that the correct storage and handling of waste and raw materials is a critical step to responsible management of materials and the prevention of pollution. All of our construction sites deploy best practice measures for the prevention of pollution and provide facilities for the separation and recycling of waste. We therefore support this objective of draft Policy CC/ CE but would ask that the policy recognises that large housebuilders such as Countryside with large and efficient supply chains may use bespoke techniques and practices on site which are not referenced in any guidance but which fully comply with all legislation and best practice.
With respect to the submission of a circular economy statement, Countryside are happy to provide such information with an application although we would request that this is proportionate to the size and scale of the development in question.

This policy will protect important land based carbon sinks such as peatland and woodland projects whilst encouraging new development to promote biodiversity and carbon sequestration.
We recognise the importance of peatlands and woodland to carbon sequestration and agree that these should be protected where possible. It is important to note however that with respect to new development, there can often be many carbon sequestration benefits associated with the creation of multi-functional green infrastructure and onsite planting which should be recognised when considering the overall ‘carbon performance’ of new development.
Countryside therefore believe that the draft policy should contain text to support new development if it can be demonstrated that the green infrastructure and woodland it provides will sequester carbon. We believe this should be recognised as one of the many environmental benefits that new development can provide.

The evidence base for the GCLP First Proposals document includes the Greater Cambridge Housing and Economic Land Availability Assessment (HELAA) (September 2021). Within the HELAA the site is assessed under two separate parcels: east of Horningsea Road (site reference 47647) and west of Ditton Lane (site reference 40516). The document provides a site assessment through a ‘traffic light’ colour coding, with both parcels receiving a ‘red’ outcome for suitability and ‘green’ for both availability and achievability.
The suitability assessment contains a number of issues that the Council have considered. These are set out within the table below, with comments provided in response to this on behalf of Countryside together with our revised assessment of the site when considered as a whole.
It is therefore considered that the issues identified by the Council as being ‘red’ or ‘amber’ would not prohibit the allocation and eventual development of the site. All of these issues can be dealt with through the provision of additional information to a planning application or through mitigation as part of the development of the site. As such, the site is considered to be suitable for the development proposed, and the Council are therefore urged to reconsider the site for allocation as part of the Greater Cambridge Local Plan.