Draft Greater Cambridge Local Plan for consultation

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Object

Draft Greater Cambridge Local Plan for consultation

Policy CC/WE: Water efficiency in new developments

Representation ID: 204556

Received: 30/01/2026

Respondent: Redrow South Midlands

Agent: Carter Jonas

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Representation Summary:

The respondent objects to Policy CC/WE, stating it is unsound due to lack of justification, proportionality, and deliverability based on the Integrated Water Management Study (2025) and Climate Change Topic Paper (2025).

The 100 unit threshold for water efficiency requirements is not supported by technical rationale, leading to confusion about differing standards for schemes of varying sizes.

The requirement for 80 litres/person/day is more stringent than national Building Regulations, potentially increasing build costs significantly due to the need for complex systems like dual pipe installations and greywater recycling.

The policy's reliance on future legislative changes makes it premature and potentially unenforceable, as it cannot impose requirements dependent on uncertain amendments.

The application of stringent BREEAM water credits for non-residential developments lacks flexibility and does not consider the viability impacts or operational requirements of various sectors.

The cumulative requirements of the policy have not undergone whole plan viability testing, risking constraints on development and the delivery of homes and employment premises.

The policy duplicates issues addressed in other policies, creating uncertainty and undermining clarity, which is essential for soundness.

The respondent supports improving water efficiency but believes Policy CC/WE exceeds realistic deliverability and lacks a credible evidence base, necessitating redrafting.

Object

Draft Greater Cambridge Local Plan for consultation

Policy CC/IW: Integrated water management, sustainable drainage and water quality

Representation ID: 204558

Received: 30/01/2026

Respondent: Redrow South Midlands

Agent: Carter Jonas

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Representation Summary:

The respondent supports the overarching framework of Policy CC/IW but objects to the wording of criterion 3(f), requesting its deletion due to a lack of evidence and viability testing regarding the requirement for green and brown roofs.

Concerns are raised regarding criterion 6(a), which places full responsibility on developers to demonstrate sufficient wastewater treatment capacity and infrastructure, a task that should be confirmed by the statutory wastewater undertaker.

The respondent cites statutory duties under the Water Industry Act 1991 and in relation to wastewater cites case law (Barratt versus Welsh Water [2009] UKSC 13 (para 23), emphasising that the burden of wastewater capacity management falls on the undertaker, not developers.

The respondent argues that housebuilders cannot and should not be expected to resolve water service issues and by extension the local planning authority cannot require this through policies or conditions. The policy should reflect the established process of engaging with the relevant service provider, and where capacity constraints exist, securing agreement that necessary infrastructure will be delivered in step with the development.

The respondent requests a revision of criterion 6(a) to clarify that developers must demonstrate either existing adequate infrastructure or an agreement with the wastewater undertaker for required infrastructure or capacity upgrades prior to occupation.

Object

Draft Greater Cambridge Local Plan for consultation

Policy BG/BG: Biodiversity and geodiversity

Representation ID: 204560

Received: 30/01/2026

Respondent: Redrow South Midlands

Agent: Carter Jonas

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Representation Summary:

The respondent supports biodiversity protection but objects to the 20% biodiversity net gain requirement, stating it exceeds the 10% mandated by the Environment Act 2021.

Planning guidance discourages local planning authorities from requiring more than the statutory 10% unless justified, which has not been evidenced in this case.

The draft NPPF indicates that local authorities should not set higher BNG requirements than the national minimum, questioning the soundness of the proposed 20% requirement.

The 20% uplift must be considered alongside other policies that impose significant demands on land availability, potentially reducing developable area and impacting housing delivery.

There are concerns that the cumulative impact of these policies could compromise the viability of developments, particularly affecting the delivery of affordable housing and essential infrastructure.

Object

Draft Greater Cambridge Local Plan for consultation

Policy BG/BG: Biodiversity and geodiversity

Representation ID: 204573

Received: 30/01/2026

Respondent: Redrow South Midlands

Agent: Carter Jonas

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Representation Summary:

The respondent supports biodiversity protection but objects to the 20% biodiversity net gain requirement, stating it exceeds the 10% mandated by the Environment Act 2021.

Planning guidance discourages local planning authorities from setting higher BNG requirements than the statutory minimum without justification, which has not been provided.

The draft NPPF indicates that local authorities should not exceed the national statutory minimum for BNG, raising concerns about the soundness of the proposed 20% requirement.

The cumulative burden of various draft policies could reduce developable area and limit housing delivery, particularly affecting urban or brownfield sites.

The respondent highlights significant viability concerns, suggesting that the 20% BNG requirement could compromise the delivery of affordable housing and essential infrastructure.

The respondent recommends revising Policy BG/BG to align with the statutory 10% requirement and to balance BNG delivery with wider planning objectives and viability.

Object

Draft Greater Cambridge Local Plan for consultation

Policy BG/GI: Green and blue infrastructure

Representation ID: 204578

Received: 30/01/2026

Respondent: Redrow South Midlands

Agent: Carter Jonas

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Representation Summary:

The respondent supports the principle of protecting and enhancing green and blue infrastructure (GBI) and agrees that it should be considered early in the planning process.

The proposed development at land south of High Street, Hauxton, will provide significant GBI benefits, including an enhanced green buffer to the M11 and improvements to the chalk stream, supporting strategic initiatives.

The respondent objects to the established Greening Factor of 0.4, questioning its rationale and impact on other considerations like rooftop solar panels and biodiversity net gain.

The respondent believes that the Greening Factor of 0.4 could hinder viable development and contradicts other policies in the draft GCLP, limiting density and housing numbers.

Concerns are raised regarding the lack of viability testing for mandatory Greening Factors, which may undermine deliverability, especially on brownfield or higher density sites.

The policy's multiple GBI obligations could create overlaps with statutory biodiversity net gain, making it unrealistic to deliver on constrained sites.

Requirements for off-site GBI contributions where Greening Factors are unmet may lead to non CIL compliant levies.

Object

Draft Greater Cambridge Local Plan for consultation

Policy BG/TC: Improving tree canopy cover and the tree population

Representation ID: 204581

Received: 30/01/2026

Respondent: Redrow South Midlands

Agent: Carter Jonas

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Representation Summary:

The requirement for 30% canopy cover is seen as overly prescriptive and does not consider site-specific needs, landscape character, or the balance with open space and other environmental requirements.

Support is expressed for the inclusion of Arboricultural Impact Assessments in development proposals and the incorporation of existing trees and hedgerows.

The canopy target is viewed as ambitious yet arbitrary, lacking evidence or feasibility studies to support its impact on land use and density.

The canopy cover requirement, combined with other policies, creates competing demands for land, potentially jeopardising deliverability and imposing significant land take.

Concerns are raised about the compatibility of the canopy target with denser development schemes and its alignment with other nature strategies, such as Nature Recovery Schemes.

It is suggested that draft Policy BG/TC should better align with other draft GCLP policies and housing requirements for effective implementation.

Object

Draft Greater Cambridge Local Plan for consultation

Policy BG/EO: Providing and enhancing open spaces

Representation ID: 204587

Received: 30/01/2026

Respondent: Redrow South Midlands

Agent: Carter Jonas

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Representation Summary:

The respondent objects to Policy BG/EO, stating it may demand substantial land-take within development sites, particularly at higher densities.

Concerns are raised about the deliverability of the policy, as it requires careful consideration due to existing GI-related policies that impose significant spatial and cost burdens.

The respondent argues that the policy is not justified, proportionate, or deliverable, citing uncertainty around key standards such as Accessible Green Space and outdoor sports facilities.

There is a risk of overlapping and conflicting requirements without clarity on prioritisation or flexibility, particularly regarding existing obligations like Biodiversity Net Gain.

The policy could inadvertently create an informal open space tariff through off-site financial contributions without a clear CIL compliant methodology.

The respondent recommends amending the policy to provide clear, evidence-led, viability tested standards and greater flexibility for constrained or higher density sites.

Clear guidance on open space provision within developments is encouraged to enhance certainty in assessing site capacity and delivery requirements.

Object

Draft Greater Cambridge Local Plan for consultation

Policy WS/NC: Meeting the needs of new and growing Communities

Representation ID: 204589

Received: 30/01/2026

Respondent: Redrow South Midlands

Agent: Carter Jonas

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Representation Summary:

The policy is deemed unsound due to insufficient justification from the Wellbeing and Social Inclusion Topic Paper (2025), imposing disproportionate and duplicative obligations on development.

The requirement for developments of 200+ dwellings to conduct detailed community needs assessments is not supported by robust evidence or clear thresholds.

The policy's 'one size fits all' approach contradicts the Topic Paper's recommendation for flexible, place-based strategies, risking unnecessary costs and delays.

The presumption that larger sites must provide new on-site facilities does not align with the Topic Paper's view that enhancing existing facilities is often more effective.

The requirement for 129m² of indoor community space per 1,000 population lacks sufficient evidence and imposes a rigid quantitative standard that may not reflect local needs.

The cumulative impacts of the policy have not been viability tested, raising concerns given the existing obligations on development in the emerging Plan.

The policy fails to meet the tests of being justified, effective, and deliverable, and should be revised to ensure flexibility and comprehensive viability testing.

Object

Draft Greater Cambridge Local Plan for consultation

Policy WS/HD: Creating healthy new developments

Representation ID: 204595

Received: 30/01/2026

Respondent: Redrow South Midlands

Agent: Carter Jonas

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Representation Summary:

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.

Object

Draft Greater Cambridge Local Plan for consultation

Policy J/AL: Protecting the best agricultural land

Representation ID: 204597

Received: 30/01/2026

Respondent: Redrow South Midlands

Agent: Carter Jonas

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Representation Summary:

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”).

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