Draft Greater Cambridge Local Plan for consultation

Redrow requests that Policy CC/WE is amended to:

1. Justify or remove the 100 unit threshold, ensuring any differentiation between scheme sizes is evidence based.
2. Align mandatory water consumption standards with Part G of Building Regulations, with any lower standards treated as aspirational or subject to feasibility and viability evidence.
3. Remove the requirement for dual pipe or water reuse systems unless:
o legally permitted;
o supported by water company infrastructure; and
o demonstrated to be viable and feasible for the specific development.
4. Amend BREEAM requirements to allow a flexible, typology specific approach, rather than requiring full credits in all categories.
5. Ensure Policy CC/WE is consistent with national legislation
6. Avoid duplication by clarifying how CC/WE interacts with CC/SD, CC/IW and CC/NZ.
7. Provide transitional arrangements so that new standards are phased in rather than becoming immediate mandatory requirements.
8. Support the policy with robust local evidence and full whole plan viability testing before finalising the next iteration of the Local Plan.

Object
Redrow recognises the importance of water efficiency in Greater Cambridge, which is a highly water stressed area. However, Policy CC/WE is unsound because it is not justified, not proportionate, and not demonstrably deliverable based on the available evidence, particularly the Integrated Water Management Study (2025) and the Climate Change Topic Paper (2025).

The policy introduces a 100 unit threshold that is neither explained nor supported by any technical rationale. It is unclear why schemes of 100 dwellings or more should be required to meet 80 litres/person/day, while smaller schemes are subject to a different standard. The evidence base does not justify the threshold, nor does it explain how delivering two different requirements across similar typologies will secure consistent water efficiency outcomes.

The requirement for 80 litres/person/day is significantly more demanding than both national Building Regulations (Part G baseline of 125 l/p/d) and the optional 110 l/p/d standard. The policy therefore sets a performance level far tighter than national standards and introduces a requirement that will substantially increase build costs, particularly given that achieving 80 l/p/d will require dual pipe systems, greywater recycling or other reuse technologies. These technologies carry complex design requirements, long term maintenance burdens, operational risks, and meaningful upfront and lifecycle costs. The Integrated Water Management Study (2025) does not demonstrate that widespread adoption of these systems is technically feasible across typical suburban housing layouts, mixed tenure schemes, or multi developer sites.

Despite this, the policy mandates dual pipe reuse systems “subject to changes in legislation,” meaning the policy is premature, potentially unenforceable, and reliant on external regulatory changes that may not occur during the plan period. A Local Plan cannot impose requirements that depend on future, uncertain legislative amendments.

The policy also applies stringent BREEAM water credits to all non residential development, requiring:
• 5 credits under Wat 01;
• full credits for Wat 02 and Wat 03; and
• full Wat 04 credits where water is used in commercial processes.

This is an inflexible, one size fits all approach, and the Topic Paper provides no evidence that these standards are achievable for water intensive uses such as research facilities, laboratories, food production, leisure or hospitality sectors. The policy also fails to consider viability impacts, scale, use type and operational requirements.

Importantly, none of these requirements have been subject to whole plan viability testing, even though they impose substantial capital cost burdens and ongoing maintenance obligations. The cumulative requirements—including reuse system management plans, dual pipe installation, retrofitting expectations for changes of use, and mandatory water butts—have not been tested for deliverability across the plan area. As a result, the policy risks constraining development and reducing the ability to deliver homes and employment premises.

The policy also duplicates matters addressed in other policies (CC/SD, CC/IW, CC/NZ), creating uncertainty and risk of overlapping evidence submissions. This undermines clarity, a key test of soundness.

While Redrow supports improving water efficiency, Policy CC/WE exceeds what can realistically be delivered in the near term, lacks a credible evidence base, and imposes requirements beyond national policy without demonstrating feasibility or viability.

For these reasons, Policy CC/WE is not justified, not effective and not consistent with national policy, and should be redrafted.

Redrow requests that Policy CC/WE is amended to:

1. Justify or remove the 100 unit threshold, ensuring any differentiation between scheme sizes is evidence based.
2. Align mandatory water consumption standards with Part G of Building Regulations, with any lower standards treated as aspirational or subject to feasibility and viability evidence.
3. Remove the requirement for dual pipe or water reuse systems unless:
o legally permitted;
o supported by water company infrastructure; and
o demonstrated to be viable and feasible for the specific development.
4. Amend BREEAM requirements to allow a flexible, typology specific approach, rather than requiring full credits in all categories.
5. Ensure Policy CC/WE is consistent with national legislation
6. Avoid duplication by clarifying how CC/WE interacts with CC/SD, CC/IW and CC/NZ.
7. Provide transitional arrangements so that new standards are phased in rather than becoming immediate mandatory requirements.
8. Support the policy with robust local evidence and full whole plan viability testing before finalising the next iteration of the Local Plan.

Redrow therefore requests that Criterion 6(a) is revised to clarify that development proposals must demonstrate either the presence of adequate wastewater conveyancing infrastructure or that an agreement is in place with the wastewater undertaker to deliver any required infrastructure or capacity upgrades prior to occupation. This amendment maintains the policy’s intention to protect and enhance water quality while ensuring that the requirement is proportionate, achievable and aligned with statutory responsibilities and industry practice.

Redrow objects to the current wording of criterion 3(f) and requests its deletion.

Object

Policy CC/IW sets an overarching framework for integrated water management, which is supported in principle. However Redrow objects to the current wording of criterion 3(f) and requests its deletion. The requirement for green and brown roofs is unevidenced in terms of what this would achieve, and has not been subject to viability testing to demonstrate what burden this would place on developers. Redrow requests this requirement is removed.

Additionally, the current wording of Criterion 6(a) raises concerns because it places full responsibility on the developer to demonstrate that there is sufficient wastewater treatment capacity and adequate conveyancing infrastructure for the entire development.

In practice, only the statutory wastewater undertaker can confirm treatment capacity and any upgrades required to support new development. Developers are unable to assess or guarantee wastewater treatment capacity independently, and therefore the requirement as drafted is neither reasonable nor deliverable.

Water companies are subject to statutory duties under S37 and 94 of the Water Industry Act 1991 (WIA 1991); section 37 of the Act imposes a statutory duty on all water companies to provide and maintain adequate infrastructure and potable water supplies. Section 106 of the WIA 1991 confers the power to connect to a public sewer. Section 106(1) states that the owner of any premises or the owner of any private sewer which drains premises, shall be entitled to have its drains or sewer communicate with the public sewer of any sewerage undertaker and therefore discharge foul water and surface water from those premises or that private sewer. Specifically, in relation to wastewater, the Supreme Court considered this matter in 2009 – see Barratt versus Welsh Water [2009] UKSC 13 (para 23):

“The right to connect to a public sewer afforded by section 106 of the 1991 Act and its predecessors has been described as an “absolute right”. The sewerage undertaker cannot refuse to permit the connection on the ground that the additional discharge into the system will overload it. The burden of dealing with the consequences of this additional
discharge falls directly upon the undertaker and the consequent expense is shared by all who pay sewerage charges to the undertaker. Thus, in Ainley v Kirkheaton Local Board (1891) 60 LJ (Ch) 734 Stirling J held that the exercise of the right of an owner of property to discharge into a public sewer conferred by section 21 of the 1875 Act could not be
prevented by the local authority on the ground that the discharge was creating a nuisance. It was for the local authority to ensure that what was discharged into their sewer was freed from all foul matter before it flowed out into any natural watercourse.”

The provision of sewerage capacity (both networks and treatment) is the subject of a five year rolling Asset Management Plan and its associated Waste and Drainage Management Plan, with progressive works proposed on a long-term basis predicated on growth assumptions, overseen by OFWAT and Defra. Statutory funding includes network reinforcement charges and connection charges to developers as well as on-going sewerage service charges to occupiers. From these funds, the undertaker manages its operation in order to fulfil its duties. Wastewater treatment capacity is judged by anticipated growth and implemented in a ‘staged’ way – i.e. strategically by annual monitoring, rather than in response to specific applications – each stage providing sufficient headroom for growth pending the next stage.

Housebuilders cannot, and should not be expected to, resolve issues related to water services, and by extension the local planning authority cannot require this through policies or conditions. Save for development impacting on European protected sites and species, water companies would not be justified in placing a requirement on developers to demonstrate the capacity of water supply infrastructure prior to the occupation of development, as established in the case of Barratt Homes (referred to above). Doing so would allow the water companies to have significant leverage over developers or Local Planning Authorities seeking to deliver growth. On this basis, it is not considered that the policy has been positively prepared, nor will it be effective in ensuring that sufficient water infrastructure is secured for new developments (NPPF paragraph 36a and 36c tests of soundness).

The policy should instead reflect the established process whereby developers engage with the relevant service provider, and where capacity constraints exist, secure agreement that necessary infrastructure will be delivered in step with the development. Without this amendment, the policy risks imposing obligations outside the control of applicants and would fail the tests of effectiveness and deliverability.

Redrow therefore requests that Criterion 6(a) is revised to clarify that development proposals must demonstrate either the presence of adequate wastewater conveyancing infrastructure or that an agreement is in place with the wastewater undertaker to deliver any required infrastructure or capacity upgrades prior to occupation. This amendment maintains the policy’s intention to protect and enhance water quality while ensuring that the requirement is proportionate, achievable and aligned with statutory responsibilities and industry practice.

Redrow considers that Policy BG/BG should be revised to ensure consistency with national policy, avoid internal policy conflicts, and remain deliverable across a range of sites. The policy should therefore be amended to align with the statutory 10% requirement, and should acknowledge the need to balance BNG delivery with wider plan objectives, housing capacity expectations, and whole plan viability.

Objection

Redrow supports the principle of protecting and enhancing biodiversity and recognises the importance of delivering meaningful biodiversity net gain across Greater Cambridge. However, the requirement in Criterion 2 for all major developments to provide a minimum 20% biodiversity net gain exceeds the mandatory 10% uplift set out in the Environment Act 2021 and does not align with the emerging direction of national policy.

Planning guidance actively discourages LPAs from requiring above the 10% mandated by the Environment Act 2021, stating: “Plan-makers should not seek a higher percentage than the statutory objective of 10% biodiversity net gain, either on an area-wide basis or for specific allocations for development unless justified. To justify such policies they will need to be evidenced including as to local need for a higher percentage, local opportunities for a higher
percentage and any impacts on viability for development. Consideration will also need to be given to how the policy will be implemented.” (emphasis added) (ID: 74-006)

No evidence has been provided as to the need for an increased net gain requirement.

This planning practice guidance is reflected in the draft NPPF which clearly indicates that local planning authorities should not set BNG requirements above the national statutory minimum, which calls into question the soundness of the proposed 20% requirement in terms of consistency with national policy. In addition, the 20% uplift must be considered alongside the cumulative burden of other draft policies that place significant demands on land availability and development capacity, including policies relating to tree canopy provision (BG/TC), green infrastructure (BG/GI), ecology and onsite habitat expectations (BG/EO), water neutrality (WS/NC), housing space and accessibility standards (H/SS), and the densities assumed in the draft site allocations (S/LAC and S/AMC/EB).

Taken together, these policies materially reduce developable area and limit opportunities to achieve efficient densities, challenging the ability of sites—particularly urban or brownfield allocations—to deliver the housing numbers anticipated in the draft Plan. The combined impact also gives rise to significant viability concerns, with the risk that additional land or offsite uplift requirements to meet 20% BNG could compromise the delivery of affordable housing (H/AH) and essential infrastructure (I/ID).

For these reasons, Redrow considers that Policy BG/BG should be revised to ensure consistency with national policy, avoid internal policy conflicts, and remain deliverable across a range of sites. The policy should therefore be amended to align with the statutory 10% requirement, and should acknowledge the need to balance BNG delivery with wider plan objectives, housing capacity expectations, and whole plan viability.

Redrow considers that Policy BG/BG should be revised to ensure consistency with national policy, avoid internal policy conflicts, and remain deliverable across a range of sites. The policy should therefore be amended to align with the statutory 10% requirement, and should acknowledge the need to balance BNG delivery with wider plan objectives, housing capacity expectations, and whole plan viability.

Object

Redrow supports the principle of protecting and enhancing biodiversity and recognises the importance of delivering meaningful biodiversity net gain across Greater Cambridge. However, the requirement in Criterion 2 for all major developments to provide a minimum 20% biodiversity net gain exceeds the mandatory 10% uplift set out in the Environment Act 2021 and does not align with the emerging direction of national policy.

Planning guidance actively discourages LPAs from requiring above the 10% mandated by the Environment Act 2021, stating: “Plan-makers should not seek a higher percentage than the statutory objective of 10% biodiversity net gain, either on an area-wide basis or for specific allocations for development unless justified. To justify such policies they will need to be evidenced including as to local need for a higher percentage, local opportunities for a higher
percentage and any impacts on viability for development. Consideration will also need to be given to how the policy will be implemented.” (emphasis added) (ID: 74-006)

No evidence has been provided as to the need for an increased net gain requirement.

This planning practice guidance is reflected in the draft NPPF which clearly indicates that local planning authorities should not set BNG requirements above the national statutory minimum, which calls into question the soundness of the proposed 20% requirement in terms of consistency with national policy. In addition, the 20% uplift must be considered alongside the cumulative burden of other draft policies that place significant demands on land availability and development capacity, including policies relating to tree canopy provision (BG/TC), green infrastructure (BG/GI), ecology and onsite habitat expectations (BG/EO), water neutrality (WS/NC), housing space and accessibility standards (H/SS), and the densities assumed in the draft site allocations (S/LAC and S/AMC/EB).

Taken together, these policies materially reduce developable area and limit opportunities to achieve efficient densities, challenging the ability of sites—particularly urban or brownfield allocations—to deliver the housing numbers anticipated in the draft Plan. The combined impact also gives rise to significant viability concerns, with the risk that additional land or offsite uplift requirements to meet 20% BNG could compromise the delivery of affordable housing (H/AH) and essential infrastructure (I/ID).

For these reasons, Redrow considers that Policy BG/BG should be revised to ensure consistency with national policy, avoid internal policy conflicts, and remain deliverable across a range of sites. The policy should therefore be amended to align with the statutory 10% requirement, and should acknowledge the need to balance BNG delivery with wider plan objectives, housing capacity expectations, and whole plan viability.

Redrow requests that the Greening Factor requirement is reviewed and amended as follows:
1. Replace the mandatory Greening Factor of 0.4 (residential) and 0.3 (non residential) with a flexible, evidence based standard, such as:

“Major development should seek to achieve a Greening Factor that is appropriate to site context, viability and other policy requirements, and should demonstrate how green and blue infrastructure has been maximised through a design led approach.”

2. Require the Local Planning Authority to produce a technical evidence base demonstrating:
o how the Greening Factor has been calibrated,
o how it interacts with climate and BNG requirements,
o how it impacts viability and density.
3. Ensure that any off site GI contribution requirements are compatible with the national Biodiversity Net Gain framework and avoid double charging.

Object

Redrow supports the overarching principle of protecting and enhancing green and blue infrastructure (GBI) and agrees that GBI should be considered at an early stage. Redrow also supports the intention to strengthen the Greater Cambridge GBI network and its alignment with strategic initiatives. In the case of Redrow’s promoted site—land south of High Street, Hauxton—the proposed development would deliver clear and measurable GBI benefits. These include:

• a significantly enhanced green buffer to the M11, improving landscape character and noise/environmental mitigation; and
• the enhancement of the chalk stream that forms the site’s eastern boundary, creating a biodiversity corridor that reconnects with the River Cam approximately 200m to the north

These enhancements directly support two key Greater Cambridge Strategic Green Infrastructure Initiatives:
1. Revitalising the Chalk Stream Network, and
2. The River Cam Corridor.

Accordingly, Redrow considers its proposed GBI interventions to be entirely aligned with the emerging GCLP’s strategic environmental ambitions.

Redrow is seeking to promote Land south of High Street, Hauxton for residential development. Development of this site will allow provision of a significantly enhanced green buffer to the M11 and the enhancement of a chalk stream along the eastern edge of the site, which connects with the River Cam 200m to the north of the site. This supports priorities 1 (“Revitalising the chalk stream network”) and 2 (“River Cam Corridor”).

Objection

It is unclear why a Greening Factor of 0.4 has been settled on, and how this will interface with other considerations e.g. rooftop solar panels and biodiversity net gain. The provision of additional green infrastructure off site is not considered necessary: this is already covered by both BNG legislation, and by contributions towards on site and offsite open space.

It is considered that achieving a greening factor of 0.4 compromises the ability to deliver viable developments when balancing against other policy requirements as set out in the draft GCLP ,namely Policy BG/BG, Policy BC/TC Policy BG/EO, Policy WS/NC, Policy H/SS. These restrict opportunities for density uplift and achieving the housing numbers as set out under the draft site allocations.

Requested Change

Redrow requests that the Greening Factor requirement is reviewed and amended as follows:
1. Replace the mandatory Greening Factor of 0.4 (residential) and 0.3 (non residential) with a flexible, evidence based standard, such as:

“Major development should seek to achieve a Greening Factor that is appropriate to site context, viability and other policy requirements, and should demonstrate how green and blue infrastructure has been maximised through a design led approach.”

2. Require the Local Planning Authority to produce a technical evidence base demonstrating:
o how the Greening Factor has been calibrated,
o how it interacts with climate and BNG requirements,
o how it impacts viability and density.
3. Ensure that any off site GI contribution requirements are compatible with the national Biodiversity Net Gain framework and avoid double charging.



Mandatory Greening Factors (0.4 for residential / 0.3 for non residential) are not evidently backed by viability testing or completed technical evidence, especially as GI standards are still being developed. This risks undermining deliverability—particularly on brownfield or higher density sites. The policy introduces multiple GI obligations in addition to statutory BNG, creating overlaps or conflicts. On constrained sites, delivering multifunctional GI and 10% BNG on site may be physically unrealistic. Requirements for off site GI contributions where Greening Factors cannot be met—and for contributions to strategic GI initiatives even where no direct impact occurs—could amount to a non CIL compliant levy.

Requested Change

Redrow requests that Policy BG/TC be amended to replace the fixed requirement for 30% tree canopy cover with a flexible, design‑led target that reflects site‑specific opportunities and constraints. The policy should allow canopy cover to be determined through a balanced approach that takes account of landscape character, Biodiversity Net Gain, SuDS, open space requirements, viability and planned housing densities. A revised wording such as:

“Major development should deliver an increase in tree canopy cover appropriate to the site’s context, design and constraints. A canopy target may be agreed with the Local Planning Authority through a proportionate design-led assessment.”

This ensures policy alignment with other draft GCLP requirements and supports deliverable, well‑designed development.

Object

Whilst the general aim to improve tree cover in the District is supported, the requirement for 30% canopy cover is an overly prescriptive approach that doesn’t take into account specific site requirements, landscape character, or the need to balance tree provision with open space requirements, sustainable drainage systems and Biodiversity Net Gain (amongst others).

It is agreed that development proposals should provide an Arboricultural Impact Assessment as relevant and seek to incorporate existing trees and hedgerows where possible.

The policy sets an ambitious but arbitrary and unevidenced canopy target without published viability evidence or feasibility modelling to justify its impact on density and land use. When combined with policy BG/GI, multifunctional GI requirements and mandatory BNG, the canopy target adds additional competing demands for limited land, jeopardising deliverability. This imposes significant land take, is incompatible with denser schemes, and lacks proportionality to site constraints. It is also unclear how this ties in with other nature strategies such as Nature Recovery Schemes.

All major development proposals achieving 30% canopy cover is unnecessary and potentially conflicts with other requirements on BNG, SUDS, response to landscape character, and open space provision. It is considered that draft Policy BG/TC needs to better align with other draft GCLP policies and housing requirements, in order to ensure that the initiatives are implemented.

Requested Change

Redrow requests that Policy BG/TC be amended to replace the fixed requirement for 30% tree canopy cover with a flexible, design‑led target that reflects site‑specific opportunities and constraints. The policy should allow canopy cover to be determined through a balanced approach that takes account of landscape character, Biodiversity Net Gain, SuDS, open space requirements, viability and planned housing densities. A revised wording such as:

“Major development should deliver an increase in tree canopy cover appropriate to the site’s context, design and constraints. A canopy target may be agreed with the Local Planning Authority through a proportionate design-led assessment.”

This ensures policy alignment with other draft GCLP requirements and supports deliverable, well‑designed development.

The policy should be reviewed for potential overlap with other requirements, and to clarify the standards that are currently under exploration. The policy should provide clear, evidence-led, viability-tested standards and greater flexibility for constrained or higher density sites.

Object

Redrow note the Council is proposing a more flexible approach than in the current Local Plan. The draft policy explores adding multiple standards, including:
• Accessible green space
• Parks and recreation space
• Children’s play space and youth space
• 0.55 ha per 1,000 population
• Food growing/allotments (0.4 ha per 1,000)
• Outdoor sports facilities

When combined, these may demand very substantial land‑take within development sites—especially at higher densities. The deliverability of the policy requires careful consideration. Topic Paper 3 and the draft plan include several GI‑related policies (e.g., BG/GI and BG/TC) that already present significant spatial and cost burdens.

Policy BG/EO is not currently justified, proportionate, or deliverable. Many of the key standards—including Accessible Green Space quantities, country park contributions, commercial greenspace ratios, and quality benchmarks—remain “under exploration,” creating significant uncertainty for masterplanning and viability assessment. The combined requirements for accessible greenspace, play space (0.55ha/1,000 population), food growing space (0.4ha/1,000), and outdoor sports facilities risk imposing substantial and untested land take demands, particularly when considered alongside existing GI, tree canopy and Biodiversity Net Gain obligations.

This creates overlapping and potentially conflicting requirements without clarity on prioritisation or flexibility. The policy also risks establishing an informal open space tariff through off site financial contributions absent a clear CIL compliant methodology. For these reasons, the policy should be amended to provide clear, evidence led, viability tested standards, greater flexibility for constrained or higher density sites, and a rationalised approach to cumulative green infrastructure expectations.

Redrow encourages clear guidance on open space provision within developments to help provide certainty when assessing likely site capacity and delivery requirements.

The policy should be revised to ensure flexibility, provide clear evidence based thresholds, support the enhancement of existing community assets where appropriate, and be informed by comprehensive viability testing.

Object
This policy is unsound because it is not adequately justified by the Wellbeing and Social Inclusion Topic Paper (2025) and places disproportionate, uncertain and potentially duplicative obligations on development. While supporting the principle of providing appropriate community facilities, the policy introduces requirements that go significantly beyond what the evidence demonstrates is necessary or deliverable.

The requirement for schemes of 200+ dwellings to undertake detailed community needs assessments and community development strategies is not supported by robust evidence or clear thresholds in the Topic Paper. The paper recognises that community needs vary by settlement and that flexible, place based approaches are often most effective, yet the draft policy imposes an inflexible “one size fits all” model. This risks unnecessary cost, delay and administrative burden without demonstrating additional benefits.

Similarly, the presumption that larger sites must deliver new on site facilities—unless developers can prove that off site provision is advantageous—does not reflect the Topic Paper’s acknowledgement that enhancing existing community facilities is frequently the most effective and sustainable approach. The policy reverses this logic and risks the creation of standalone facilities that may be poorly used or unsustainable to manage in the long term and would not contribute to the funding and maintenance of existing facilities.

The requirement for 129m² of indoor community space per 1,000 population is also insufficiently evidenced. Without proper justification, this imposes a rigid quantitative requirement that may not reflect actual local need.

Additionally, the cumulative impacts of the policy—needs assessments, engagement strategies, on site provision, phasing and meanwhile uses, and long term management and maintenance responsibilities—have not been whole plan viability tested. Given the extensive obligations already placed on development in the emerging Plan (climate, water, energy, biodiversity net gain, affordable housing), the lack of viability evidence is a significant deficiency.

For these reasons, the policy fails the tests of being justified, effective and deliverable. It should be revised to ensure flexibility, provide clear evidence based thresholds, support the enhancement of existing community assets where appropriate, and be informed by comprehensive viability testing.

Requested Change

Redrow support the requirement of submission of HIAs as part of major developments as required by Part 2. However, it is requested that the threshold for full HIAs is increased to 500 dwellings rather than 100 dwellings; a rapid HIA for schemes of 200-500 dwellings; and no requirement for a HIA for schemes of 200 or less dwellings.

Object

For a development of up to 150 dwellings, Policy WS/HD places a disproportionate burden compared with what can realistically be achieved on a non strategic site. While the Topic Paper: Wellbeing and Social Inclusion explains that WS/HD aims to deliver wide ranging health outcomes and draws together multiple thematic requirements across the Plan (including health infrastructure, inclusive design, green/blue space access, food growing and climate resilience), this breadth results in obligations more suited to large strategic sites with the space and critical mass to deliver comprehensive community infrastructure.

The requirement for a full Health Impact Assessment at 100+ dwellings further adds technical cost and complexity for a mid sized scheme, despite the Topic Paper not providing evidence that such developments generate impacts warranting this level of assessment. Without clearer thresholds, proportionality tests, or a mechanism to rationalise overlapping requirements from related policies (open space, GI, active travel, climate adaptation), WS/HD risks imposing unrealistic expectations on smaller residential sites. The policy should therefore be amended to provide size based flexibility, proportionate HIA requirements, and clear alignment with the Topic Paper’s intent, ensuring that non strategic developments are not held to standards only deliverable in strategic growth locations.

Expectations to “support delivery of community and health facilities” also lack a clear mechanism and risk operating as a non CIL compliant levy. Accordingly, Policy WS/HD should be amended to provide clearer triggers, proportionate HIA requirements, and better integration with linked policy areas to ensure deliverability and avoid unnecessary duplication.

Requested Change

Redrow support the requirement of submission of HIAs as part of major developments as required by Part 2. However, it is requested that the threshold for full HIAs is increased to 500 dwellings rather than 100 dwellings; a rapid HIA for schemes of 200-500 dwellings; and no requirement for a HIA for schemes of 200 or less dwellings.

Part 1b) should be revised to remove ambiguity about whether a sequential test will be required

Object

The NPPF states that development should recognise the importance of high quality agricultural land, but does not provide explicit protection. Point 1) is generally supported, though part b) implies a sequential approach to development where it should be demonstrated that lower quality land has been considered first. This is unnecessarily onerous, and a justification for the loss of agricultural land will have already been considered through the first part of the policy (“Sustainability considerations and the need for the development clearly outweigh the impacts of the loss of the economic and other benefits of the land”).