Greater Cambridge Local Plan Preferred Options

The University supports the proposed policy direction for West Cambridge to develop as an Innovation District, in accordance with Cambridge City Council’s resolution to grant outline planning permission (16/1134/OUT). We agree that it is important to provide a mix of complementary uses to support research activities; the new Shared Facilities Hub will open in 2022 and proves a new model for shared workspace to support agile working, collocated with a café, restaurant and retail facilities with active frontages located next to new high quality urban realm. We agree that as well as providing high quality walking and cycling connections, development should maximise the opportunity provided by public transport improvements such as the proposed Greater Cambridge Partnership Cambourne to Cambridge scheme. The University is working collaboratively with the Greater Cambridge Partnership in order to deliver part of the Cambrourne to Cambridge scheme along Charles Babbage Road in West Cambridge, and to deliver part of the proposed Comerton Greenway through the site.

Please note, however, the forthcoming outline planning permission for West Cambridge does not include the development of additional residential units, and that part of policy should be deleted. The University is focussing its delivery of housing at North West Cambridge.

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The University notes the proposed allocation for storage and distribution uses. The University can confirm that it has no objection to the proposed allocation, and being owner of part of the site, will work positively with the Local Planning Authority and adjoining landowners/promoters to refine the details of the allocation and bring forward the site, if allocation is taken forward in the Plan.

The University supports the Councils’ aim for Greater Cambridge to transition to net zero carbon by 2050, by ensuring that development is sited in places that help to limit carbon emissions, is designed to the highest achievable standards for energy and water use, and is resilient to current and future climate risks.

The proposed policy approach for net zero carbon from new buildings is innovative and challenging relative to energy targets. The University supports the overall approach given its own science-based target to deliver a zero carbon estate, but we note that in some cases the proposed standards are so tight that they require a more nuanced approach with slight relaxations where there is a reasonable justification, as follows:

A space heating demand of 15-20 kwh/m2/p.a for domestic and non-domestic buildings

This is very close to Passivhaus Standard. This in effect mandates triple glazing, mechanical ventilation with heat recovery, and the highest standards of insulation and air-tightness. We recommend allowing a relaxation where site constraints mean solar access is poor or an optimal form factor cannot be achieved.

Total energy use intensity (EUI) of 35 kwh/m2 for residential

This EUI goes beyond the exemplary ‘Passivhaus’ standard. We ask that an illustrative energy budget based on a real example be provided to show how this is achievable in practice.
We recommend allowing a relaxation where site constraints mean solar access is poor or an optimal form factor cannot be achieved.
Use of EUI could unfairly penalise smaller dwellings. For example, someone using a fridge and a cooker in a dwelling of 50m2 uses double the kWh/m2 for those appliances as the same person in a dwelling of 100m2; there is no dsign solution for that. We recommend a space efficiency factor be applied.

150kwh/m2 for research space

Actual EUI will be highly variable depending on the nature of the research. The University’s Civil Engineering Building was predicted to consume 80kWh/m2/yr and is achieving 77kWh/m2/yr. The Heart & Lung Research Institute, however, is predicted at 245kwh/m2/yr as it will have to provide high rates of ventilation and contains energy intensive equipment.

We suggest ‘process energy’ such as autoclaves, ultra-low temperature equipment, fume extraction etc. fall outside the research space EUI standard. Efficiency relating to this type of non-standard consumption can be demonstrated through the BREEAM ENE07 credit for ‘Energy efficient laboratory systems’.

100% renewable energy provision, preferably on-plot

Efficient PV could deliver 120kWh/yr per m2 of panel. In effect, this means roof mounted PV will struggle to meet demand where two storeys each have an EUI of 55kWh/m2/yr, even if 100% of the roof is covered in PV and there is no shadowing. This means significant renewable energy will have to be sourced elsewhere on-site or off-site for buildings above two storeys.

This policy proposal implies any non-domestic building of more than one storey will require 100% of the roof to be covered in PV (unless we see significant increases in PV efficiencies). We recommend that clarification be given that this policy should not be at the expense of equally environmentally beneficial proposals such as roof mounted air source heat pumps, roof level amenity space, and ‘green roofs’.

Policy should clarify that where peak PV output is likely to exceed building demand, and the local Distribution System Operator has insufficient capacity to receive the excess, then the offsetting route will be acceptable.
As grid carbon factor drops, it is possible that the carbon emitted to manufacture and install a PV array and associated infrastructure will exceed the lifetime carbon savings. This should be recognised in Policy for future proofing.

Offsetting only to be used in specific circumstances (e.g. insufficient roof space) with such buildings future proofed to enable 100 zero carbon through upgrades

Policy should clarify the accountancy requirements for this policy. For example that a Power Purchase Agreement for 100% renewable electricity will be accepted. Also, that If the applicant makes an advance investment in offsite renewable energy, this will be regarded as an offset ‘bank’ for future construction projects.

General comments

Confirmation is sought as to whether the proposed policy would apply to major refurbishment as well as new build
The proposed Energy Use Intensity figures are defined in kWh/m2. Confirmation is sought as to whether m2 is defined as gross internal floor area, and is kWh is defined as metered energy.
An exception to EUI standards should be allowable where building usage will be exceptionally efficient in use of space e.g. hot desking to maximise occupancy, or extended opening hours.
A definition of how EUI will be predicted is sought – in practice will the ‘most likely’ scenario in the range of outcomes defined in a CIBSE ‘TM54’ Operational Energy Evaluation carried out by a competent professional be accepted?
EUI does not take into account the desirability of storage to relieve pressure on the grid, minimising need to switch on high carbon electricity generators. Storage in the form of batteries, thermal stores and inter-seasonal storage in the ground should be encouraged. Confirmation is sought that higher EUIs associated with energy storage will be accepted where this brings a net saving in grid carbon.
We welcome the requirement to measure embodied carbon for large projects as this is in line with existing University Design Standards. We note there is a big disparity between the threshold sizes for non-residential and residential development and suggest these be treated more equally.

Achieving all five BREEAM WAT01 water conservation credits is an extremely challenging standard that is likely to go beyond the limits of viability for smaller projects, projects with limited roof collection area, and projects with functions that do not fit the BREEAM standardised calculation methodology. There is a risk of ‘white elephant’ grey water recycling and rainwater harvesting systems that are too small to be sustainable in terms of maintenance and operating cost and ask that guidance on the appropriate threshold of viability be provided; ideally in the form of worked examples for typical building types (office, education, industrial).

We support the aim to increase and improve the network of habitats for wildlife, and green spaces for people, ensuring that development leaves the natural environment better than it was before.

The University supports the policy intention to control the biodiversity impacts from development, including the principle of biodiversity net gain.

As far as our Biodiversity Action Plan (BAP) is concerned our Vision is to 'Deliver a significant and measurable improvement in the biodiversity of the University of Cambridge estate, and the Greater Cambridge Area more generally, in a manner that educates and inspires an appreciation of the natural environment, and that encourages interventions, research and innovation to enhance and protect biodiversity for future generations.'

The Environment Act 2021 will require a mandatory 10% minimum biodiversity net gain across the country. We note that at an Oxford-Cambridge Arc level, the local authorities have agreed a set of Arc Environmental Principles that include the aims of doubling the area of land managed primarily for nature, and to deliver a minimum 20% biodiversity net gain on development sites. These ambitions, together with the relatively low level of designated sites and priority habitats in Greater Cambridge, form the Councils’ justification for development to bring further net gains beyond the 10% proposed nationally. Any target will have financial and operational implications, however, which should also be considered as part of the evidence base. We therefore consider it would be appropriate for the local authorities to assess the impact of a 20% net gain target (or indeed any other target that would exceed the national 10%) on the viability of development to meet the objectively assessed needs for jobs and homes for the plan period.

We support the policy intention for development proposals to include green infrastructure, providing benefits for people, wildlife and planet by
- Reinforcing and enhancing landscape and townscape
- Supporting delivery of biodiversity net gain, and connecting where appropriate to the wider ecological network
- Promoting healthy living
- Protecting and enhancing the water environment.
- Enhancing access and connectivity
- Providing environmental enhancement; and
- Supporting climate mitigation and adaptation.

We support the policy intention to:
- Preserve, protect and increase the amount and distribution of tree canopy cover
- Protect and enhance the tree population on site
- Protect existing trees of value
- Protect existing hedgerows and the surrounding land that supports them, and to require the planting of new ones where appropriate
- Provide sufficient space above and below ground for trees and other vegetation to mature; and
- Provide appropriate replacement tree or hedgerow planting, where felling is proved necessary.

We agree that the Local Plan should continue to include policies which identify and protect open spaces, including village greens, parks, sports and recreation areas, allotments, community orchards and Protected Village Areas, and Local Green Space. Also, that policy should continue to recognise that in some cases development on open space may be appropriate if it has limited qualities and would lead to overall quality or quantity improvements.