Draft Greater Cambridge Local Plan for consultation

Object

Representation ID: 209208

Received: 30/01/2026

Respondent: Urban & Civic

Agent: David Lock Associates

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

U&C objects to a universal requirement for all development to provide a minimum of 20% biodiversity net gain, unless exempt under the Environment Act 2021. As
drafted the policy is inconsistent with UK Government legislation (which requires a minimum of 10%) and introduces a blanket constraint that may well frustrate necessary development. Particularly in circumstances when standalone applications are brought forward as a component part or to support wider proposals this is likely to have unintended consequences.

Comment

Representation ID: 209209

Received: 30/01/2026

Respondent: Urban & Civic

Agent: David Lock Associates

Whilst U&C support the provision of well designed, integrated and functional green infrastructure within developments, it is concerned over the apparent duplication of policy and guidance that is referred to in this policy.

It requires developments to achieve a number of ‘initiatives’ and ‘objectives’: Urban Greening Factor, Green
Infrastructure Initiatives and Building for Nature. There is no supporting evidence to demonstrate whether these initiatives’ and ‘objectives’ are all compatible and necessary and how compliance is to be tested. The draft Policy lacks clarity and as written is difficult to interpret.

Comment

Representation ID: 209210

Received: 30/01/2026

Respondent: Urban & Civic

Agent: David Lock Associates

Adoption of an Urban Greening Factor Target of 0.4 is applied to ‘all major residential development’ is also of greatest concern. This method and practice have potential
value at a fine grain, small scale and particularly within defined urban sites; it is however extremely difficult to see how it can be scaled up and applied to larger scale development, delivered in phases.

We urge SCDC to consider again the practicality of the proposed approach and its purpose when large scale development is subject to broader land use budget calculation and monitoring against prescriptive standards,
such as open space provision and biodiversity net gain.

Purpose, method and a clear demonstration of it could work is absent and very necessary if this approach is to be considered further.

Object

Representation ID: 209211

Received: 30/01/2026

Respondent: Urban & Civic

Agent: David Lock Associates

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

U&C object to the affordable housing Policy as drafted. A target of 40% is welcomed as long as it is explicit that this may not be achievable in all circumstances.

The Policy fails to acknowledge, apart from in an oblique reference within the supporting text, which is inadequate for clarification, that viability is relevant.

To maintain a blanket requirement of 40% minimum on all sites without exception or scope for negotiation, requires that the Authority demonstrate that 40% is achievable on all sites, in all circumstances, at all points across the plan period and having regard to all other considerations that go to viability.

That is simply not possible, the scope for exception is therefore essential to make the policy sound.

Comment

Representation ID: 211749

Received: 30/01/2026

Respondent: Urban & Civic

Agent: David Lock Associates

The draft policy wording currently suggests the museum, which is a private enterprise can be protected. While space for the museum can be secured (and is), planning cannot protect a private enterprise.

Comment

Representation ID: 211750

Received: 30/01/2026

Respondent: Urban & Civic

Agent: David Lock Associates

The draft policy presents a different and unsubstantiated position on the heritage value and retention of existing features, which conflicts with the extant OPP and the robust heritage impact assessment work that supported the OPP and the SPD.

Comment

Representation ID: 211751

Received: 30/01/2026

Respondent: Urban & Civic

Agent: David Lock Associates

The draft policy draws conclusions on drainage which don’t reflect the extensive technical work undertaken that supported planning applications and the SPD.

Comment

Representation ID: 211752

Received: 30/01/2026

Respondent: Urban & Civic

Agent: David Lock Associates

The draft policy does not reflect the way Design Codes are being used to guide detailed design at the phase level.

Comment

Representation ID: 211753

Received: 30/01/2026

Respondent: Urban & Civic

Agent: David Lock Associates

U&C suggest that draft Policy reference to ‘the submission of an appropriate energy assessment incorporating Passivhaus energy performance calculations’ is amended.

Standard Assessment Procedure (SAP) calculations are the UK Government’s approved method for assessing the energy performance of new residential dwellings and ensure compliance with relevant regulations, the Building Regulations Part L.

Object

Representation ID: 211754

Received: 30/01/2026

Respondent: Urban & Civic

Agent: David Lock Associates

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

U&C is extremely concerned that the targets (Part B, bullet no.1) proposed relate to Total Use (regulated and unregulated) for homes when developers/housebuilders have absolutely no control over unregulated energy use
within the home and mechanisms to achieve this at scale do not exist at the present time.

This target is not universally achievable.

U&C suggest that the criteria which states ‘All dwellings must achieve an EUI of no more than 35 kWh per meter squared per year’ should be amended to set a target for regulated energy use only. This is more realistic and better reflects the UK Government’s Net Zero 2050 strategy.