Draft Greater Cambridge Local Plan for consultation

Comment

Representation ID: 209198

Received: 30/01/2026

Respondent: Urban & Civic

Agent: David Lock Associates

The draft policy makes no mention of any on-going role for the SPD, which is obviously pursuant to the extant policy, but is still critical. The SPD was deliberately formulated as a ‘Delivery Plan’ and delivery is still at a very early stage. It needs to be carried forward as its Spatial Framework Plan is the basis for achieving comprehensive development.

Nevertheless, the SPD Framework Plan is a diagram for interpretation and translation into Parameter Plans and
proposals, it can’t just be adopted as a Policy ‘compliance plan.’

Comment

Representation ID: 209199

Received: 30/01/2026

Respondent: Urban & Civic

Agent: David Lock Associates

The Policy seeks to adopt a loose diagram as a compliance plan; it is not consistent with the SPD Framework Plan or the extant OPP parameter plans (though it states it is).

This needs to be comprehensively reviewed and amended. SCDC need to consider carefully the purpose and status any plan that accompanies the Policy. If such a plan is included, it needs explanation and clarity in relation to the technical work underpinning it.

Comment

Representation ID: 209200

Received: 30/01/2026

Respondent: Urban & Civic

Agent: David Lock Associates

The transport position, particularly in relation to the A10, is complex and tied to the phasing of the permitted development and a monitor and manage regime. The Policy does not reflect this or capture the access or transport
proposals accurately.

Comment

Representation ID: 209201

Received: 30/01/2026

Respondent: Urban & Civic

Agent: David Lock Associates

The draft policy includes some new requirements which are inconsistent with the extant permissions, don’t reflect progress, or are in very direct conflict, so are not necessarily capable of being implemented without fettering planned implementation.

Notably Gypsy and Traveller pitches are now required by Policy but are not required by the extant permission or the SPD.

It also presents land uses as fixed amounts when many should be expressed as ‘potential for’.

Comment

Representation ID: 209202

Received: 30/01/2026

Respondent: Urban & Civic

Agent: David Lock Associates

The draft policy does not include the northern buffer area in the allocated area (Denny Abbey and surrounds) but this is referred to in the Policy.

There is a new requirement for a ‘Strategic Enhancement Area’ – this is outside the Policy boundary and there is no explanation of what is now expected.

Comment

Representation ID: 209203

Received: 30/01/2026

Respondent: Urban & Civic

Agent: David Lock Associates

U&C is supportive of the proposed new policy to support build to rent proposals and guide their delivery, but would like to highlight and seek clarification in relation to one important missed opportunity and seek an amendment to the Policy.

Point 1a of the policy indicates an expectation that build to rent should only reflect the wider context in terms of scale and location, which in many cases will be new housing. In some circumstances, this would be a missed opportunity. The Policy should be amended to acknowledge scope for an exception. Where design coding seeks more prominent development that is deliberately differentiated from the surrounding context, build to rent may present a good way to deliver more intense/impactful development.

Comment

Representation ID: 209204

Received: 30/01/2026

Respondent: Urban & Civic

Agent: David Lock Associates

Some clarification in relation to Point d would be beneficial. The requirement for build to rent development to be professionally managed and subject to a management plan is vital, but it is not necessary for the whole scheme to be managed by one management operator.

One operator will likely manage the housing component of any such proposal, but in a number of circumstances, not least where build to rent is integrated into mixed use development, supporting uses, outdoor spaces or associated public realm might beneficially fall into different management arrangements, such as a site wide estate management company.

Comment

Representation ID: 209205

Received: 30/01/2026

Respondent: Urban & Civic

Agent: David Lock Associates

U&C question whether it is proportionate and appropriate that all applications will be required to submit a sustainability statement without any consideration of the type of development or the context such as where large-scale development is delivered in phases and sustainability is addressed strategically.

In this circumstance, the policy approach might impact supporting infrastructure or enabling works and impose an unnecessary burden on the preparation of planning applications, which in turn might impact delivery.

U&C have also found that establishing sitewide and key phase level strategies are an effective mechanism for establishing appropriate sustainability targets (including
those related to climate). Therefore, U&C further suggest that the policy is amended to acknowledge that where sitewide or phased sustainability strategies are in place already a conformity statement should be submitted rather than a standalone sustainability statement.

Comment

Representation ID: 209206

Received: 30/01/2026

Respondent: Urban & Civic

Agent: David Lock Associates

U&C suggest that the draft Policy is amended so that the flexibility applied to minor applications is extended to major applications (ie a Sustainability Statement may form part of a Design and Access Statement or Planning Statement for the proposal in certain circumstances).

Comment

Representation ID: 209207

Received: 30/01/2026

Respondent: Urban & Civic

Agent: David Lock Associates

The draft Policy also requires Circular Economy reporting. It should be expanded to define what is required in relation to different scale and forms of development in this respect particularly if the expectation is that it will apply to outline proposals and strategic scale development.