Draft Greater Cambridge Local Plan for consultation

Requested Change

Policy H/AH should include:

• A viability-led flexibility clause, recognising that 40% on site delivery or the prescribed tenure mix may be unviable in some circumstances.
• Provision for cascade mechanisms, allowing tenure adjustments, altered delivery timing, off site provision, or commuted sums where RPs decline to take units or where specific tenures (e.g., social rent) are not deliverable within scheme economics.
• More explicit recognition of RP delivery constraints, ensuring developers are not penalised for market conditions outside their control.
• Clearer circumstances under which off-site provision or commuted sums will be accepted, particularly where on site delivery would compromise overall scheme quality, phasing, or viability.
• Removal of some of the prescriptive elements of the policy regarding bedspaces, which risk becoming out-of-date as soon as the policy is adopted.

Without these adjustments, the policy risks creating delivery bottlenecks, slowing housing completions and undermining the Local Plan’s own supply trajectory. Embedding flexibility in the policy text would make H/AH more responsive to real world delivery issues over a lengthy plan period, while still supporting strong affordable housing outcomes.

Object

Policy H/AH establishes a high and fixed requirement for 40% affordable housing on major residential schemes, with prescribed tenure splits and strict expectations on design, integration, phasing, and occupancy. While the ambition for affordable housing delivery is understood, the policy requires greater flexibility to reflect site specific constraints and the changing viability landscape, as highlighted within the Homes Topic Paper (2025), which acknowledges that delivery of affordable housing will depend on local market conditions, development costs, tenure requirements, and provider participation. It is also noted that the draft Local Plan covers a long time period; there may well be changes to housing needs over the plan period which the policy wouldn’t reflect.

Crucially, the current operating environment for Registered Providers (RPs) – including rising borrowing costs, increased construction and maintenance costs, tighter regulatory expectations, and reduced appetite to take on S106 stock – means that rigid on site requirements may not always be achievable or desirable. The Topic Paper explains that affordable housing delivery must be informed by up to date viability evidence and acknowledges that different sites will have different development economics and opportunities for on site provision (Homes Topic Paper, 2025). This demonstrates a clear need for the policy itself to incorporate explicit flexibility.

Given this need for flexibility, Redrow also considers the policy must be amended to allow for cascade mechanisms within S106 agreements. This is particularly important given current issues facing Registered Providers and take-up of affordable housing, difficulties which are acknowledged in the Council’s own viability assessment. The inclusion of a reference to cascade mechanisms within the policy would remove the need to consider whether cascade mechanisms are policy compliant at the application stage.

Other elements of Policy H/AH are overly prescriptive. Criterion 5(e) sets out the precise number of bedspaces to be provided in affordable homes; this would not allow for the meeting of the most up-to-date evidenced local needs.

Support (in part)

The policy states that developments of 10 or more dwellings must provide a prescribed mix (the values of which are referenced). Redrow believes that a generalised housing mix to be provided across the plan area regardless of settlement type, tenure, or different housing market areas, is overly prescriptive.

Redrow would also highlight that housing needs assessments may not always reflect demands for extra bedrooms which could be used for other uses like studies, given the rise in home working.

Points 2, 3 and 4 are supported. These allow for site-specific variation to housing mix that would better reflect local need.

Redrow request that point 1) be refined to ensure appropriate mixes are provided across urban and rural areas and across different forms of home tenure.

Redrow requests amendments to Policy H/SS to improve flexibility, viability, and compliance with national policy. Fixed private amenity space standards should be removed or made flexible and design‑led, particularly for constrained, heritage, and brownfield sites. Duplication of the NDSS should be replaced with a simple reference. M4(3) wheelchair standards should apply only to affordable homes where the Council nominates occupants. Whole Plan Viability testing is needed to assess cumulative policy impacts and ensure deliverability.

Object (in part)

Redrow supports the intention behind Policy H/SS to ensure high quality, accessible living environments, and recognises the important role of nationally described space standards (NDSS) and accessible housing. However, several elements of the policy are overly prescriptive, inflexible, and insufficiently justified, meaning the policy risks being ineffective and inconsistent with national policy, contrary to the NPPF soundness tests.

Redrow has significant concerns that Policy H/SS takes an unduly rigid approach to external space standards, particularly within Clauses 3–6. The policy imposes fixed minimum private amenity space requirements for all dwellings, including a blanket 30 sqm provision for every house and prescribed balcony dimensions for apartments. Such uniform standards do not take account of the diverse development contexts found across the district. In high density urban locations, constrained infill sites, heritage settings, and conversion projects — including listed buildings — achieving these requirements is often unworkable or would compromise design quality, local character, and appropriate densities. Provision of designated private external space for housing types such as maisonettes may not be possible.

While the draft policy offers a narrow exception for co housing and community led schemes, this does little to assist the many situations where well designed development cannot meet inflexible numerical thresholds due to heritage sensitivities, privacy design solutions, unusual site shapes, or the need to optimise density along sustainable transport corridors. The wording should therefore be amended to include “where practicable”.

The evidence base provides no robust justification for the 30 sqm standard, nor any reasoning for applying the same requirement to all houses irrespective of size or bedroom count. Moreover, imposing fixed minimum garden sizes risks depressing densities and creating internal tensions with site allocation expectations, character policies, brownfield regeneration goals, and the delivery of diverse and efficient housing typologies. A more flexible, design led approach is therefore essential.

The draft policy also reproduces the Nationally Described Space Standards (NDSS) verbatim, despite the fact that the NDSS already applies once adopted in the Local Plan. Repeating the technical content offers no additional policy clarity; instead, it results in unnecessary duplication and makes the policy longer and more difficult to interpret. A clear cross reference to the NDSS would achieve the same purpose more succinctly and effectively.

On accessibility, Redrow continues to support the delivery of M4(2) accessible and adaptable homes. However, the proposed requirement for 10% of affordable dwellings and 5% of market dwellings to meet M4(3) wheelchair user standards conflicts with national guidance. The Planning Practice Guidance states that policies for wheelchair accessible homes should only apply to dwellings where the authority is responsible for allocating or nominating the occupant. As the Council does not nominate occupants for market housing, applying an M4(3) requirement to 5% of market units is not compliant with national policy and should be removed. Furthermore, the draft plan provides no viability evidence demonstrating that M4(3) homes can be viably delivered across a range of market and affordable tenures, site conditions, and densities. These units typically require increased floor areas, step free access, and bespoke parking arrangements, which may not be achievable on constrained, sloping, or complex sites. The cumulative impact of NDSS, M4(2), M4(3), and strict external space requirements has also not been tested as part of Whole Plan Viability.

More widely, Policy H/SS must be considered in the context of the broader and substantial cumulative policy burden imposed by the emerging plan. Housing space and accessibility expectations interact with a wide array of other draft requirements, including net zero carbon standards, water efficiency measures, the proposed greening factor, biodiversity net gain, density targets, Building with Nature principles, and transport and parking standards. The draft plan provides no demonstration that this extensive package of requirements is collectively viable. Without robust testing of cumulative impacts, Policy H/SS risks jeopardising the deliverability of new housing across the plan area.
Given these concerns, Redrow considers that Policy H/SS is not justified, not effective, and not aligned with national policy.

The policy requires revision to introduce greater flexibility, promote genuinely design led solutions, and reflect the varied practical constraints affecting different types of residential development. Redrow therefore requests that: the fixed private amenity space standards be removed or made more flexible; the duplication of the NDSS be deleted in favour of a simple reference; the M4(3) requirement be applied only to affordable homes where the Council nominates occupants; additional flexibility be incorporated for constrained, heritage, conversion, and brownfield sites; Whole Plan Viability testing be undertaken to assess cumulative impacts; and policy wording be refined to ensure that housing mix, density, and open space requirements are applied proportionately and in a balanced manner.

Points 2a) to h) are broadly supported. It is however questioned what is meant by “mobility hubs” and how these would be funded and maintained. Point 3 is broadly in accordance with the NPPF paragraph 116, though the wording could be simplified.

Policy I/ST may want to mention the relevance of development phasing, where transport improvements are secured and implemented over time as communities grow.

Part Object

It is agreed that development should have a vision-led approach to transport in order to reduce reliance on the car. It is agreed that sustainable travel should be promoted as appropriate to location.

This recognises the differing sustainability credentials of urban and rural sites, which is an approach set out in the National Planning Policy Framework. Paragraph 83 of the NPPF states that sustainable development in rural areas will be achieved through the location of housing in places where it will “enhance or maintain the vitality” of rural communities, including where “development in one village may support services in a village nearby”. This explicitly allows for development in villages which may have few services themselves, and does not rule out development in locations that may not be well served by public transport. The NPPF is clear that opportunities for sustainable travel are different in rural and urban locations, and merely locating new homes in proximity to existing homes in rural areas is enough to contribute to sustainable outcomes. This calls for flexibility on the application of sustainable transport policies in rural areas.

Points 2a) to h) are broadly supported. It is however questioned what is meant by “mobility hubs” and how these would be funded and maintained. Point 3 is broadly in accordance with the NPPF paragraph 116, though the wording could be simplified.

Policy I/ST may want to mention the relevance of development phasing, where transport improvements are secured and implemented over time as communities grow.

Points 2a) to h) are broadly supported. It is however questioned what is meant by “mobility hubs” and how these would be funded and maintained. Point 3 is broadly in accordance with the NPPF paragraph 116, though the wording could be simplified.

Policy I/ST may want to mention the relevance of development phasing, where transport improvements are secured and implemented over time as communities grow.

Object

It is agreed that development should have a vision-led approach to transport in order to reduce reliance on the car. It is agreed that sustainable travel should be promoted as appropriate to location.

This recognises the differing sustainability credentials of urban and rural sites, which is an approach set out in the National Planning Policy Framework. Paragraph 83 of the NPPF states that sustainable development in rural areas will be achieved through the location of housing in places where it will “enhance or maintain the vitality” of rural communities, including where “development in one village may support services in a village nearby”. This explicitly allows for development in villages which may have few services themselves, and does not rule out development in locations that may not be well served by public transport. The NPPF is clear that opportunities for sustainable travel are different in rural and urban locations, and merely locating new homes in proximity to existing homes in rural areas is enough to contribute to sustainable outcomes. This calls for flexibility on the application of sustainable transport policies in rural areas.

Points 2a) to h) are broadly supported. It is however questioned what is meant by “mobility hubs” and how these would be funded and maintained. Point 3 is broadly in accordance with the NPPF paragraph 116, though the wording could be simplified.

Policy I/ST may want to mention the relevance of development phasing, where transport improvements are secured and implemented over time as communities grow.

The policy should be amended to ensure proportionality and flexibility. Transport Statements should only be required where appropriate, with minor schemes allowed to address transport matters through Design and Access Statements. The requirement for 5–10% non‑standard cycle parking and one space per bedroom should be justified or removed. Cycle parking standards should be less prescriptive and reflect different urban and rural contexts. EV charging requirements should be deleted as they duplicate Building Regulations. Part 2(h) should allow cycle storage in the most secure and appropriate location (front, side or rear), including rear gardens, to support inclusive, design‑led solutions.

Object

It is agreed that developments should have a vision-led approach to parking. However it is questioned whether all kinds of development need to provide a Transport Statement. This should be proportionate to the size of scheme proposed, and it should be recognised that this information can be part of Design and Access Statements for minor developments.

There is a strong objection to the provision of 5-10% of all parking being for non-standard cycles. No justification has been provided for whether this fits a current or predicted modal split. Cycles now come in a variety of shapes and sizes, making it difficult to predict what an appropriate provision would be.

It is also felt that part 2 of the policy is overly prescriptive. There are many ways in which cycle parking can be designed and it may not always be the case that providing cycle parking at the front of a property is convenient or appropriate. How has the standard of one cycle parking space per bedroom been arrived at?

Whilst the aspiration to increase the modal share of cycling is laudable, not all locations are equally accessible by bike. The policy should take into account the differing cycle connectivity of rural and urban locations.

EV charging provision is now covered by Building Regulations part S so duplication in the Local Plan is unnecessary.

We strongly disagree with Part 2(h), which requires residential cycle parking to be located “in a purpose-built area at the front of the house or within a garage.” This prescription is unnecessarily restrictive and does not reflect the wide range of acceptable, secure and high-quality cycle storage solutions available.

In many cases—particularly in suburban layouts or where private rear gardens are directly accessible—locating cycle storage within rear gardens provides a more secure, less visually intrusive, and better integrated solution than front of plot structures. Rear-garden storage can also reduce street clutter, avoid conflict with heritage or townscape character, and support crime prevention principles by keeping valuable cycles away from the public realm. Provided that storage is easily accessible, appropriately designed, and fit for purpose, rear garden cycle parking can meet all policy aims relating to safety, convenience, and usability.

Front of plot cycle storage works for some suburban formats but is inappropriate or unachievable for:
• terraced homes without front gardens,
• mews courts,
• apartments arranged around courtyards,
• heritage sensitive frontages,
• homes with rear access lanes or secure rear paths.

The policy should explicitly allow the most logical and secure location to be used based on unit type and site layout.

We therefore request that Part 2(h) is amended to explicitly allow rear garden cycle storage where safe, direct access is provided and where this represents the most appropriate solution for layout, design, or security reasons.

Consideration of long tail bikes, cargo bikes and adapted cycles
The policy emphasises accommodating “all types of cycles,” but front of plot stores typically cannot accommodate cargo bikes, trikes or adapted disability cycles without dominating the frontage or obstructing visibility splays. Rear locations often allow for:
• deeper sheds,
• greater manoeuvring space,
• better sight line clearance.

Thus, Part 2(h) is in tension with the inclusive cycling requirement in Part 1(g).

To ensure consistency with good placemaking, crime prevention and design‑coding practice, the policy should be amended to allow cycle storage in the most secure, accessible and context‑appropriate location—whether front, side or rear—based on site layout, dwelling type and architectural character.

Redrow believe the policy is unnecessary. The information requested can be provided in Sustainability Statements. It is suggested that clarity is provided over which substations could benefit from upgrades, with an assessment of timescales for releases or grid upgrades.

Redrow would question whether it is appropriate for all schemes of more than 250 dwellings to provide an Energy Masterplan. The rationale behind the setting of the 250 home / 10,000sq.m threshold is unclear (and in any case would apply to very few developments given the current allocation policy).

To avoid excessive cost and delay, information on energy requirements and proposals can be incorporated within Sustainability Strategies which are already part of the local validation list and covered in the Sustainable Construction SPD. Clear and practical guidance should be provided on how these requirements match the obligations and business plans of National Grid and energy providers, avoiding unrealistic demands on developers.

Part 2 of the policy does not account for the fact that new and upgraded substations can sometimes best be provided at new locations. It is suggested that clarity is provided over which substations could benefit from upgrades, with an assessment of timescales for releases or grid upgrades.

The requirement for full Utilities Statements should be deleted or clarified. The policy should be checked for duplication with s106 and infrastructure tariffs. The phrase "adequate capacity" should be clarified.

Object

The requirement for necessary infrastructure aligns with NPPF paragraph 35. However, the need for infrastructure is broad and may overlap with s106 and emerging Infrastructure Tariffs. This could introduce duplication. Contributions must meet the Reg 122 tests.

Given the wide definition of “infrastructure” as set out in the policy, questions are raised over what it means for there to be “adequate capacity” and how this matches with obligations on providers.

The policy should clarify that an assessment of planning obligations will take into account the latest information in the Council’s Infrastructure Funding Statement. This is to ensure developments do not pay twice for infrastructure via both CIL and planning obligations, and would clarify that the policy has had regard to the relevant tests set out at NPPF 58; that is, they are necessary to make the development acceptable in planning terms, are directly related to the development and are fairly and reasonably related in scale and kind to the development.

There is concern that mandating a full Utilities Statement for all major developments without a clear scope could create additional costs and delays, and generate repetitive and unnecessary reports. Reliance on DNO and provider scoping statements should be permitted to reduce duplication.

The policy on viability is generally supported. Clear parameters should be set for independent review costs and timings to encourage transparency.

The thresholds set at 30 and 250 dwellings appear arbitrary and risk imposing significant technical and financial burdens, adding to the already extensive list of pre application requirements. These obligations—such as assessing mobile coverage, securing agreements with multiple providers, or accommodating future equipment—may be disproportionate for schemes that are not large strategic sites.

Clearer coordination with utilities and network operators at plan making stage would help avoid ambiguity and reduce delays at application stage, ensuring that digital infrastructure requirements remain achievable, proportionate, and consistent with delivery viability.

Object

We welcome the policy’s focus on securing high quality digital and telecommunications infrastructure, which aligns with NPPF paragraph 119 in recognising advanced and reliable communications networks as essential to sustainable growth and community well being. However, flexibility is needed where gigabit capable connections cannot feasibly be delivered, particularly on rural sites where commercial operators may not support full fibre deployment.

The thresholds set at 30 and 250 dwellings appear arbitrary and risk imposing significant technical and financial burdens, adding to the already extensive list of pre application requirements. These obligations—such as assessing mobile coverage, securing agreements with multiple providers, or accommodating future equipment—may be disproportionate for schemes that are not large strategic sites.

Clearer coordination with utilities and network operators at plan making stage would help avoid ambiguity and reduce delays at application stage, ensuring that digital infrastructure requirements remain achievable, proportionate, and consistent with delivery viability.

Suggested Change

Introduce wording that allows the extent of documentation to be proportionate, e.g.:

“…proportionate to the scale, nature and likely impacts of the development, and may not be required where impacts are minimal or can be addressed through standard planning conditions.”

Objection

The policy requires a Noise and Vibration Demolition Environmental Management Plan, a Construction Environmental Management Plan, or a combined DCEMP for all major development and any development that may have adverse effects during construction.

• The requirement is very broad and could capture relatively small schemes unnecessarily.
• It mandates multiple documents before commencement, even where a lighter touch approach would be proportionate.
• Statutory control of construction noise and nuisance already exists under the Control of Pollution Act 1974 and Environmental Protection Act 1990, risking duplication.