Draft Greater Cambridge Local Plan for consultation

Object

Representation ID: 205001

Received: 30/01/2026

Respondent: Martin Grant Land Limited

Agent: Pegasus Group

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Draft NPPF Policy N2 acknowledges the burden of delivering biodiversity net gain (BNG) on developments and suggests local standards should only exceed statutory requirements for specific site allocations that are justified and deliverable.

Draft Policy BG/BG lacks clarity on whether the purchase of biodiversity credits should match the 20% BNG requirement if onsite delivery is deemed unfeasible, potentially impacting the viability of major developments.

Requiring 20% BNG onsite may necessitate more land, reducing the developable area and gross development value of major sites, while increased offsite mitigation costs could further affect developer viability.

The supporting text of draft Policy BG/BG acknowledges that smaller sites should not be required to deliver 20% BNG, but major developments may face similar viability challenges.

There is a need for a clear definition of how the efficacy of BNG delivery will be measured, as draft Policy BG/BG introduces uncertainty that could delay planning applications and incur additional costs for developers and Councils.

Comment

Representation ID: 208257

Received: 30/01/2026

Respondent: Martin Grant Land Limited

Agent: Savills

MGL have provided a series of recommendations and suggestions in relation to the policy wording, supporting text and Spatial Framework diagram of Policy S/CBN.

Please refer to the accompanying attachments for further clarification.

Support

Representation ID: 208260

Received: 30/01/2026

Respondent: Martin Grant Land Limited

Agent: Savills

MGL welcomes the approach to defining appropriate density, and avoiding undue prescriptive requirements.

Comment

Representation ID: 208261

Received: 30/01/2026

Respondent: Martin Grant Land Limited

Agent: Savills

MGL fully supports the principles of integrated water management and sustainable drainage.
However, we would like to raise the following points for consideration to ensure the policy is deliverable and
proportionate:

While we recognise the environmental benefits, mandating green or brown roofs on all flat roofs can present significant challenges, particularly for refurbishments. Structural capacity, cost implications, and heritage constraints may make this impractical in some cases. We suggest allowing flexibility where technical or viability issues arise, supported by alternative biodiversity measures.

- Designing for no runoff during small rainfall events is ambitious and may be difficult to achieve on constrained or high-density sites. We recommend considering a performance-based approach that allows equivalent mitigation measures where strict compliance is not feasible.

Support

Representation ID: 208262

Received: 30/01/2026

Respondent: Martin Grant Land Limited

Agent: Savills

The policy reiterates the approach set out in the National Planning Policy Framework, taking into account the impacts of climate change

Comment

Representation ID: 208263

Received: 30/01/2026

Respondent: Martin Grant Land Limited

Agent: Savills

It is important that the reference in 1. to “where practical and viable” is retained in the Policy and that
“where practical and viable” is similarly referenced in Policy S/CBN: Cambourne North 48 where is states “integrate circular economy principles into design (including Zero Avoidable Waste in construction, maximising opportunities for reuse and recycling of materials across whole life-cycle) and will encourage zero waste living in operation for future residents through provision of services and facilities.

Support

Representation ID: 208264

Received: 30/01/2026

Respondent: Martin Grant Land Limited

Agent: Savills

Support. The policy is not unduly prescriptive in cases where peat is not identified on site.

Comment

Representation ID: 208265

Received: 30/01/2026

Respondent: Martin Grant Land Limited

Agent: Savills

Whilst recognising that it should be provided on-site “where this is feasible and effective”, it is important that the policy does retain flexibility to allow for off-site provision where on-site is not demonstrated to be not feasible or not effective.

Comment

Representation ID: 208266

Received: 30/01/2026

Respondent: Martin Grant Land Limited

Agent: Savills

Over the area of Cambourne North and adjacent Strategic Enhancement Area, a future (in 25 years) tree canopy cover of 30% is potentially achievable. Achieving 30% tree canopy cover is likely to be challenging within the S/CBN area alone. Paragraph 5.20 of the Greater Cambridge Local Plan: Topic Paper 3: Biodiversity and Green Spaces summarises the findings of the ‘First Proposals Sustainability Appraisal’, stating that a “high canopy cover requirement could mean that woodland would dominate a development site’s landscape and biodiversity provision, at the expense of a more biodiverse mix of habitats and landscapes.”

A requirement for 30% tree canopy cover in new development is largely instigated by a Woodland Trust recommendation, set out in the ‘Emergency Tree Plan for the UK: How to increase tree cover and address the nature and climate emergency (2020)’ This recommendation is not evidenced regarding its suitability or sustainability.

In this context, it is more appropriate that the tree canopy cover target is reduced to 20% for the site itself, potentially reflected as a specific requirement in Policy S/CBN.

Comment

Representation ID: 208267

Received: 30/01/2026

Respondent: Martin Grant Land Limited

Agent: Savills

MGL recognises the need to address the climate crisis and to ensure that energy usage is reduced wherever possible in the pursuit of reducing emissions. However greater flexibility should be encouraged in order to ensure that it does not compromise development, and the associated socio-economic benefits that development will bring to Cambourne.

The space heating targets may be challenging in certain circumstances and flexibility is therefore needed to reflect built form, design, urban design, placemaking and viability principles. Similarly the EUI targets need to be adaptable to ensure they can respond appropriately to differing site contexts and design constraints. The energy consumption will be very different with different tenants, and might not necessarily be reflective of the specification and design strategy for the building itself. Therefore the EUI targets for non-domestic buildings will be more variable, in practice, than those for domestic buildings, and the associated policy should allow for flexibility in this regard.

While the UK Net Zero Carbon Building Standard provides valuable guidance, its EUI targets have not yet been formally confirmed or adopted. Relying on these provisional figures at this stage could lead to misalignment
with future updates and create unnecessary risk. It is therefore more appropriate to reference established benchmarks and recognised best practice until the standard is finalised. Additionally, the standard is voluntary and is therefore optional for developers. As such it is unreasonable to expect every scheme to adopt a voluntary standard that is likely to have significant implications for cost and viability.