We have submitted a response to the consultation on the Waterbeach New Town SPD. This is important, because the South Cambs local plan has agreed that 8000-9000 new homes will be built on the old Waterbeach baracks site. This SPD (Supplementary Planning Document) matters, because it will influence the decisions on planning applications here for the next 25 years.
The published vision is for “an environmentally sustainable new town, where it is easy for people to make the transition to a low carbon lifestyle.. [with] radical reductions in carbon emissions” This is attractive but rather like the misleadingly healthy-looking labelling of junk food , whats on the outside is very different from whats inside.
With guidance from a few experts in the planning system and how new housing developments can support the UK achieving Net Zero Carbon emissions , we have submitted the comments below.
We will monitor future progress, aiming to achieve content that matches the vision. Do sign up to our mailing list to be kept informed, or follow us on twitter.
Here is our submission.
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 its 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.
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 requirements 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
- 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 here
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).