Draft Greater Cambridge Local Plan for consultation

It should be noted should the draft NPPF (2025) be adopted in its current form with the above requirement in terms of BNG ahead of the GCLP Regulation 19 Consultation then the GCLP will need to be consistent with national policy in the Framework, to ensure it meets the tests set out in paragraph 36 (d) of the NPPF. Suggested revised wording for the policy BG/BG is provided below:
“1. All development must deliver statutory biodiversity net gain (BNG), providing a minimum of 10% BNG against the baseline, unless exempt under the Environment Act 2021, to be provided on-site in line with guidance.”

British Land support the aspiration of the GCLP to ensure development delivers biodiversity net gain. It is noted and that the policy requires all development to deliver the minimum 10% BNG unless exempt and mandated by the Environment Act 2021. However, the requirement for ‘major’ development to deliver 20% BNG is considered inconsistent with national policy and the PPG which states, at Paragraph: 006 Reference ID: 74-006-20240214, that, “plan-makers should seek a higher percentage than the statutory objective of 10% biodiversity net gain, either on an area-wide basis of for specific allocations for development unless justified.”

The delivery of 30% tree canopy cover will be extremely challenging on certain sites where green infrastructure coverage is already high and where there are competing statutory requirements, most notable of which is BNG and which is guided by the Defra metric which can prioritise open grassland (without tree shading) and penalise the delivery of woodland. The draft policy refers to ‘significant’ reason, which carries no definition. We question what constitutes a ‘significant’ reason? Is BNG or the delivery of UK BAP Priority Habitats ‘significant’? When considered together, these may provide a conflicting requirement and impact the delivery of sites.

Greater flexibility on density is needed, including through reframing GP/ST. We would welcome the policy being revised to allow for taller buildings in a wider range of locations than currently specified or greater clarity on the application of Appendix H in the determination of planning applications.

Well-executed densification in suitable places is essential for a growing city. Higher-density development in areas with strong transport and public service provision is fundamental to ensuring long-term viability. There are significant concerns about some of the limits and constraints specified in the current approach to density , particularly the emphasis on conformity and heritage considerations. The automatic assessment triggers linked to building heights across different location types (as per Appendix H: Skyline and tall buildings guidance) risks unduly constraining well-justified higher density developments which would deliver clear benefits in terms of amenity, future transport provision, and long-term viability and sustainability.

The identification and recommendation set out in British Land's wider representations that the Councils should plan for a greater level of growth in turn indicates that the Councils have potentially failed to comply within national policy and guidance with regards to justifying the release of Green Belt land and have not completed the duty to complete an assessment to identify grey belt land. However, it is understood a Green Belt Assessment (which will identify grey belt) is currently being undertaken, though at present it is considered the plan does not accord with national policy as required by paragraph 36(d) of the NPPF. We welcome the opportunity to provide further comment on this assessment at Regulation 19 stage.

Whilst it is understood a revised Green Belt Assessment to support the emerging plan is being prepared, the existing Green Belt Assessment was prepared in 2021 and is now considered to be out of date and not representative of the current position in terms of policy (noting the introduction of grey belt) or in terms of growth targets which underpin the Local Plan. The revised Green Belt Assessment has not been published for consultation in support of the Local Plan and as such the GCSP’s approach to allocating and discounting sites for release within the Green Belt is unclear.

In the context of this broader growth agenda, Iceni’s analysis provides a useful foundation for understanding employment and housing need in Greater Cambridge. However, it predates the forthcoming work being led by the Cambridge Growth Company, which is explicitly focused on enabling a more ambitious scale of growth. The Growth Company is developing a new evidence base, with the intention of going beyond the current local plan approach in both scale and ambition.

Given Cambridge’s position at the forefront of the UK’s innovation economy, the next stage of evidence will need to test whether Iceni’s identified level of need is sufficient to support that ambition. This next phase of plan-making will be critical in assessing whether planning policy and land allocations can genuinely deliver against the Government’s objectives, maintaining Greater Cambridge’s global competitiveness and fully capturing emerging opportunities in life sciences, AI and other innovation-led sectors.

British Land suggest that in terms of identifying need for jobs and housing GCSP and the GCLP ought to plan for a higher growth scenario as outlined within Employment and Housing Needs Case (Volterra 2026). In turn it is proposed that the requirement to plan for higher growth will create the derived demand for additional allocations for jobs and homes, including affordable homes, within Greater Cambridge. Considering this, it is proposed that Land at South Trumpington can contribute to meeting the needs of Greater Cambridge over the plan period.

Further detail and analysis is provided within the submitted documents on behalf of British Land.

The Councils' housing/ jobs evidence will need to evolve to align with the Government’s growth agenda while ensuring the vision can be achieved sustainably, considering infrastructure capacity and deliverability. A shortage of housing and employment space means we miss opportunities to cluster development at the most accessible locations, particularly those that can enhance and support existing sectors near CBC and major employers. Delivering the right employment space and homes in the right location is critical. The importance of contiguous urban extensions to maximise the benefits of agglomeration, makes growth at South Trumpington essential to support clustering and meet future needs.

Alternative sites on the edge of Cambridge, within the Green Belt/ grey belt, which the Councils identify as sustainable locations for homes and jobs in the topic papers that underpin the draft Local Plan, should be explored in accordance with the hierarchy set out in draft policy S/DS. Land at South Trumpington (HELAA Reference 40048), which we suggest scores favourably in HEELA terms, is uniquely placed to contribute to achieve the draft Plan's overall objectives in a sustainable way.

Further detail is provided in the submitted information.

The apparent early determination, in advance of the published Green Belt review, that there are no strategic exceptional circumstances to justify release of Green Belt land, and by extension grey belt release for strategic planning purposes, remains a concern. An over reliance on new settlements poses a risk to the delivery of housing in Greater Cambridge. It is suggested that additional smaller sites on the edge of Cambridge in sustainable locations should be considered by the Councils to support the delivery of housing in the authority and ensure anticipated delivery are maintained throughout the plan period.

Site ID 115169 / HELAA Site ID: 40048

We note that the Councils are continuing to explore the number of hectares per employee to apply
within the requirement for “Accessible Greenspace” (paragraph 3). These standards are important for
promoters and developers of employment sites and mixed-use sites to understand as soon as possible,
and we welcome the ability to review those standards as early as possible.

However, we would comment that the quantum of Accessible Greenspace that a proposal can deliver
will very much be dictated by site context, constraints and opportunities. This will need to be recognised
in the further draft of BG/EO.

Furthermore, it should be acknowledged that the best-in-class schemes, which adopt a design-led
approach to place-making will naturally cater for accessible public realm and greenspace for future
occupiers of the proposed development. In some instances, it will not be appropriate to prescribe a
minimum quantum of greenspace to be delivered, if the scheme provides high-quality space as part of
its response to the specifics of the site.

We would also suggest that for major mixed-use sites, a mandatory target of Accessible Greenspace,
when considered in the round with statutory BNG, the proposed draft tree canopy policy, and the
proposed public open space requirements for housing, may make viability and deliverability challenging.
On a matter of formatting and presentation, the lettering and numbering of the draft policy in paragraph
2, is confusing because at the sub-section labelling is inconsistent and it is unclear whether this reflects
hierarchy or is an error.

Site ID 115169 / HELAA Site ID: 40048

We note that the Councils are continuing to explore the number of hectares per employee to apply
within the requirement for “Accessible Greenspace” (paragraph 3). These standards are important for
promoters and developers of employment sites and mixed-use sites to understand as soon as possible,
and we welcome the ability to review those standards as early as possible.

However, we would comment that the quantum of Accessible Greenspace that a proposal can deliver
will very much be dictated by site context, constraints and opportunities. This will need to be recognised
in the further draft of BG/EO.

Furthermore, it should be acknowledged that the best-in-class schemes, which adopt a design-led
approach to place-making will naturally cater for accessible public realm and greenspace for future
occupiers of the proposed development. In some instances, it will not be appropriate to prescribe a
minimum quantum of greenspace to be delivered, if the scheme provides high-quality space as part of
its response to the specifics of the site.

We would also suggest that for major mixed-use sites, a mandatory target of Accessible Greenspace,
when considered in the round with statutory BNG, the proposed draft tree canopy policy, and the
proposed public open space requirements for housing, may make viability and deliverability challenging.
On a matter of formatting and presentation, the lettering and numbering of the draft policy in paragraph
2, is confusing because at the sub-section labelling is inconsistent and it is unclear whether this reflects
hierarchy or is an error.

Site ID 115169 / HELAA Site ID: 40048

We note that the Councils are continuing to explore the number of hectares per employee to apply
within the requirement for “Accessible Greenspace” (paragraph 3). These standards are important for
promoters and developers of employment sites and mixed-use sites to understand as soon as possible,
and we welcome the ability to review those standards as early as possible.

However, we would comment that the quantum of Accessible Greenspace that a proposal can deliver
will very much be dictated by site context, constraints and opportunities. This will need to be recognised
in the further draft of BG/EO.

Furthermore, it should be acknowledged that the best-in-class schemes, which adopt a design-led
approach to place-making will naturally cater for accessible public realm and greenspace for future
occupiers of the proposed development. In some instances, it will not be appropriate to prescribe a
minimum quantum of greenspace to be delivered, if the scheme provides high-quality space as part of
its response to the specifics of the site.

We would also suggest that for major mixed-use sites, a mandatory target of Accessible Greenspace,
when considered in the round with statutory BNG, the proposed draft tree canopy policy, and the
proposed public open space requirements for housing, may make viability and deliverability challenging.
On a matter of formatting and presentation, the lettering and numbering of the draft policy in paragraph
2, is confusing because at the sub-section labelling is inconsistent and it is unclear whether this reflects
hierarchy or is an error.

Site ID 115169 / HELAA Site ID: 40048

We note that the Councils are continuing to explore the number of hectares per employee to apply
within the requirement for “Accessible Greenspace” (paragraph 3). These standards are important for
promoters and developers of employment sites and mixed-use sites to understand as soon as possible,
and we welcome the ability to review those standards as early as possible.

However, we would comment that the quantum of Accessible Greenspace that a proposal can deliver
will very much be dictated by site context, constraints and opportunities. This will need to be recognised
in the further draft of BG/EO.

Furthermore, it should be acknowledged that the best-in-class schemes, which adopt a design-led
approach to place-making will naturally cater for accessible public realm and greenspace for future
occupiers of the proposed development. In some instances, it will not be appropriate to prescribe a
minimum quantum of greenspace to be delivered, if the scheme provides high-quality space as part of
its response to the specifics of the site.

We would also suggest that for major mixed-use sites, a mandatory target of Accessible Greenspace,
when considered in the round with statutory BNG, the proposed draft tree canopy policy, and the
proposed public open space requirements for housing, may make viability and deliverability challenging.
On a matter of formatting and presentation, the lettering and numbering of the draft policy in paragraph
2, is confusing because at the sub-section labelling is inconsistent and it is unclear whether this reflects
hierarchy or is an error.