Draft Greater Cambridge Local Plan for consultation

Comment

Representation ID: 208314

Received: 30/01/2026

Respondent: Churchill Retirement Living with McCarthy and Stone

Agent: The Planning Bureau Ltd

Whilst Council’s commitment to meeting both its and the UK Government’s target of net zero carbon emissions is commendable, it appears that the Council is going to achieve this through having mandatory carbon and climate standards from adoption of the plan that may go beyond government targets. However, it is our view that any requirement should be ‘stepped’ in line with Government targets and the proposed changes to the building regulations. the council should consider deleting the policy and aligning the Council’s requirement for carbon neutral development with those of Government would therefore be pragmatic, more achievable and consistent with national policy. We would recommend this approach to the whole policy area including embodied carbon as new development will often be far more sustainable in many circumstances including building fabric by use of modern methods of construction but also extending beyond that, such as sustainability through optimisation of use of a site.

Comment

Representation ID: 208315

Received: 30/01/2026

Respondent: Churchill Retirement Living with McCarthy and Stone

Agent: The Planning Bureau Ltd

There can therefore be viability issues with urban greening as there can be significant costs for the installation of green features such as green walls and roofs that is not included in the viability study.
The council should note that the Urban Greening requirements in London have severely impacted on the delivery of housing in London since the London Plan was adopted in 2021, to the degree that the government has recently announced an emergency package of measures aimed at accelerating housing building in London given slow delivery which in our view has been caused by the viability challenges. The council should therefore reconsider the policy requirement and ensure it is realistic and viable.

Comment

Representation ID: 208316

Received: 30/01/2026

Respondent: Churchill Retirement Living with McCarthy and Stone

Agent: The Planning Bureau Ltd

Requiring a 30% tree canopy cover especially for small brownfield sites is not deliverable or realistic and could compromise sustainability development and is therefore contrary to NPPF. Any requirement would also need to be fully evidenced and the requirement incorporated into the viability study. The council should therefore reconsider this element and ensure any such policy approach introduces more flexibility or is deleted.

Comment

Representation ID: 208317

Received: 30/01/2026

Respondent: Churchill Retirement Living with McCarthy and Stone

Agent: The Planning Bureau Ltd

The Council should note that there is a common misconception that older person’s housing places an additional burden on healthcare infrastructure and therefore rather than requiring applicants of older person’s schemes to show that there is capacity in healthcare systems and to show that the scheme will not have a health impact, the policy should instead recognise the health benefits that delivering older people’s housing can bring to individuals. For the plan to be in line with national policy and effective the following wording should be added the policy to recognise the health benefits of older persons housing: "Specialist Housing for older people has a number of health benefits and proposals for such schemes will not be required to submit a Health Impact Assessment".

Comment

Representation ID: 208318

Received: 30/01/2026

Respondent: Churchill Retirement Living with McCarthy and Stone

Agent: The Planning Bureau Ltd

We note that the consultation is supported by the Greater Cambridge Local Plan Viability Report, Aspinal Verdi, October 2025. However, we have concerns with respect to this report and how it has tested specialist housing for older people and also appears to be confused with that respect. Whilst we welcome that the Council have tested extra care housing on brownfield and greenfield sites in accordance with the PPG on Viability and we feel this should be widened to include sheltered housing, we have some concerns with regard to some of the assumptions that have been used and if amended would be likely to make sheltered and extra care housing not viable. As such the Viability Assessment should be re-run using assumptions for unit numbers / GIA / density, unit size, unit mix, non-chargeable/communal space, professional fees, sales and marketing costs, sales periods, empty property costs, external build costs, developer return, sales values.

Comment

Representation ID: 208319

Received: 30/01/2026

Respondent: Churchill Retirement Living with McCarthy and Stone

Agent: The Planning Bureau Ltd

The council should note that open space needs of older people are much less than for mainstream housing. For older people the quality of open space either on site or easily accessible for passive recreation is much more important than formal open space. The Local Plan, if the council decide to set a minimum size for residential outdoor amenity open space, should provide an exemption for older people’s housing schemes but consider the quality and function of the amenity space instead. With respect to flats and maisonettes it should be noted that there are often other planning issues that restrict the incorporation of a balcony on flats such as overlooking and this should also be noted with the policy
For the plan to be consistent with national policy and effective the following text should be added to the end of policy DC1: "Older person’s housing schemes are exempt from the above requirement so long as high quality amenity space suitable for older people is provided on site".

Comment

Representation ID: 208320

Received: 30/01/2026

Respondent: Churchill Retirement Living with McCarthy and Stone

Agent: The Planning Bureau Ltd

The delivery of a suitable level of specialist older persons’ housing will be a substantial undertaking over the Local Plan period and unless action is urgently taken the Council will struggle to address this need. There will be a significant increase in older people and the provision of suitable housing and care to meet the needs of this demographic homes should be a priority of the emerging Local Plan. Developers of older person’s housing schemes should therefore not be required to demonstrate need given the significant need identified and the many benefits that such developments bring. Given also that such developments “help reduce costs to the social care and health systems” (PPG refers), requirements to assess impact on healthcare services and/or make contributions should be avoided and this element should be removed form the policy.The council should also consider removing the policy area from the draft Local Plan given draft policy HO9 within the consultation draft NPPF.