Draft Greater Cambridge Local Plan for consultation

We support the overall ambition of Policy CC/DC

Policy CC/NZ stipulates the levels of energy use that will be allowed for new development, how renewable energy should be used to meet that energy need, and how whole life carbon emissions (emissions associated with constructing buildings) should be considered.

We support the ambition of Policy CC/NZ.

Policy CC/WE sets the levels of water efficiency that new developments must comply with, responding to the water supply pressures facing Greater Cambridge and the need to protect the water environment.
Part 1 requires for new development to demonstrate that there will be an adequate water supply available to serve the development.
Part 2 sets out the water efficiency thresholds to be adhered to. Of relevance, for residential development of 100 or more dwellings, water usage of no more than 80 litres/person/day and for residential development of less than 100 dwellings, water usage of between 90 to 100 litres/person/day.
The remaining parts discuss water efficiency measures to be included.
CIP supports in principle the importance of new developments to include water efficiency measures. However, the wording as proposed under criteria 1 places full responsibility on the developer to demonstrate sufficient capacity rather than the relevant provider. Water and sewerage companies have a legal duty under sections 37 and 94 of the Water Industry Act 1991 to "maintain, improve, and extend" their networks to meet future development needs and to effectively deal with sewage.
The draft wording of Policy CC/WE is therefore not consistent with national legislation. It is requested that the wording is amended to ensure liability is not solely placed on the developer.
It should be noted that the water efficiency requirements proposed under part 2, specifically point b which requires all major residential developments of 100 or more dwellings to restrict water usage to 80 litres/person/day are onerous and currently difficult to achieve and implement in practice. Higher costs may impact viability of developments.

Requested Change
The draft wording of Policy CC/WE is not consistent with national legislation. It is requested that the wording is amended to ensure liability is not solely placed on the developer.
Proposed updated policy wording as follows:

1.All development proposals (with the exception of householder applications) are required to undertake pre-application engagement with the relevant water provider to confirm water supply availability to serve the development.

Removal of Part 2a of Policy CC/WE

COMMENT
Policy CC/IW establishes the principles for water management including ensuring proposals provide appropriate sustainable drainage systems alongside protecting and enhancing water quality.
Criteria 6 of Policy CC/IW concerns water quality. Specifically, part a of criteria 6 states that all development proposals must demonstrate there is capacity for wastewater treatment and adequate wastewater conveyancing infrastructure to serve the whole development.
CIP supports in principle the importance of forthcoming proposals to ensure and deliver appropriate water management but request that the wording as drafted in part a of criteria 6 is updated to ensure it is not the sole responsibility of the developer to demonstrate sufficient capacity.

REQUESTED CHANGE
Proposed updated policy wording as follows:

To protect and enhance water quality, all development proposals must demonstrate that:
6a.there is adequate wastewater conveyancing infrastructure to serve the whole development, or an agreement is in place with the relevant service provider to ensure the provision of the necessary infrastructure to support the capacity for wastewater treatment prior to the occupation of the development (where development is being phased, this must be demonstrated for each phase before first occupation)

That the word ‘exceptional’ is removed in the wording of part 2d Policy CC/CE.

COMMENT
Policy CC/CE sets out how development proposals should incorporate circular economy principles into schemes including for demolition and construction, and operational waste management.
Part 1 states the importance of opportunities to reduce embodied carbon. Part 2 states there will be a presumption in retention and reuse of existing buildings over demolition. Justification for demolition will only be accepted if proposals can accord with set criteria listed out under parts 2 a-c (e.g. disrepair / energy efficiency) or compliance with part 2d in terms of benefits of demolition outweighing carbon savings.
Parts 3-4 concern operational waste management with Part 5 requiring the provision of circular economy statements for residential development of 150 dwellings or more.
CIP in principle supports the importance of waste minimisation. However, it is requested that in the wording of part 2d that the word ‘exceptional’ is removed to accommodate for other site considerations and viability (e.g. delivery of affordable housing and infrastructure, compliance with modern building standards).
We support the principle of prioritising refurbishment and circularity, but greater clarity is needed to recognise that refurbishment opportunities are often constrained by tenure, heritage protections and the practical limitations of converting many non‑residential buildings, where viability and building form frequently make demolition the only realistic option. We therefore consider that circularity requirements should be aligned with existing policy thresholds and underpinned by clear, nationally consistent methodologies—ideally through a future Part Z of the Building Regulations—to ensure assessments are deliverable, proportionate and integrated with whole‑life carbon policy.
REQUESTED CHANGE
That the word ‘exceptional’ is removed in the wording of part 2d Policy CC/CE.

COMMENT
Draft policy BG/BG concerns biodiversity uplift and enhancement. Criteria 1 requires all development to provide a minimum of 10% BNG (biodiversity net gain) against the baseline BNG value. Criteria 2 requires all major development to provide a minimum of 20% uplift. Criteria 3 outlines the requirements for offsite BNG provision where required, with the remaining criteria then setting out the principles for ensuring the adequate protection of biodiversity and geodiversity
CIP supports in principle the importance of biodiversity protection and associated enhancement around the Greater Cambridge Area.
However, the 20% uplift required for major developments as set out under criteria 2 of draft policy BG/BG reflects the guidance contained in the SPD and is the uplift that current CIP schemes adhere to. However, we note the direction of travel in the new draft NPPF which states local planning authorities should not be going above 10% uplift, the mandatory national requirement as set out in the Environmental Act 2021. The 20% uplift would be inconsistent with national legislation.
In tandem with other policy considerations set out draft GCLP policies, namely Policy BG/TC, BG/GI, Policy BG/EO, Policy WS/NC, Policy H/SS, these policies in conjunction restrict opportunities for density uplift and achieving the housing numbers as set out under the draft site allocations listed in draft policy S/LAC: Other site allocations in Cambridge and draft policy S/AMC/EB: East Barnwell.
There are also risks for site viability to accommodate for these considerations, essential in delivering affordable housing requirements (draft policy H/AH) and infrastructure delivery (draft policy I/ID).
REQUESTED CHANGE
It is considered that draft Policy BG/BG needs to better align with other draft GCLP policies and housing requirements, in order to feasibly achieve a 20% BNG uplift.

COMMENT
Policy BG/GI of draft GCLP seeks to protect and enhance green and blue infrastructure, and identifies a number of strategic green infrastructure initiatives. Part 4 specifically states that for major residential developments or residential led developments, proposals must meet a minimum Greening Factor of 0.4. Where this cannot be met on site, offsite opportunities will be explored.
CIP supports in principle initiatives to improve the green infrastructure network around the Greater Cambridge Area. However, it is considered that achieving a greening factor of 0.4 compromise 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 listed in draft policy S/LAC: Other site allocations in Cambridge and draft policy S/AMC/EB: East Barnwell.
There are also risks for site viability to accommodate for these considerations, essential in delivering affordable housing requirements (draft policy H/AH) and infrastructure delivery (draft policy I/ID).
It is considered that draft Policy BG/GI needs to better align with other draft GCLP policies and housing requirements, in order to ensure that the initiatives are implemented.
REQUESTED CHANGE
To request that the requirement to achieve a greening factor of 0.4 is more aligned with other policy requirements in order to accommodate for feasibility in achieving green infrastructure initiatives.

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.

COMMENT
Policy BG/TC of the draft GCLP seeks to improve tree canopy cover and afford protection for existing trees with criteria set out for proposals to refer to for aboricultural considerations.
Amongst other things, the policy requires that major developments achieve a future tree canopy cover of at least 30%, demonstrated through a Tree Canopy Cover Assessment. Lower percentages may be agreed with the Local Planning Authority (LPA) if justified by ecological, historical, landscape, or operational reasons.
CIP supports in principle the protection of existing trees and initiatives to promote further planting. However, it is considered that the requirement to provide a minimum of 30% tree canopy cover is onerous and would be difficult to deliver when balancing for other site-specific constraints and considerations. This particularly applies for previously developed brownfield sites in more urban locations where higher densities of development are directed in the settlement hierarchy, and often required to achieve site viability. The tree canopy cover assessment is also not yet finalised.
In tandem with other policy considerations set out draft GCLP policies, namely Policy BG/BG, BG/GI, Policy BG/EO, Policy WS/NC, Policy H/SS this restricts opportunities for density uplift and achieving the housing numbers as set out under the draft site allocations listed in draft policy S/LAC: Other site allocations in Cambridge and draft policy S/AMC/EB: East Barnwell. There are also risks for site viability to accommodate for these considerations, essential in delivering affordable housing requirements (draft policy H/AH) and infrastructure delivery (draft policy I/ID).
REQUESTED CHANGE
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.

COMMENT
Policy BG/PO concerns the protection and provision of open space. Of relevance, criteria 2 stipulates the requirements for open space replacement which should be
a. located within a suitable distance of the original site having regard to the Natural England Accessible Greenspace Accessibility Standards and
b. fully available for use before the area of open space to be lost can be redeveloped.
CIP supports in principle the protection of existing open space and mechanisms to achieve this. However, there are concerns that point b of criteria 2 requiring replacement open space to be in operation prior to the loss of existing space does not accommodate for practicalities regarding site deliverability, construction and access. This is particular for previously developed brownfield sites where redevelopment may need to be phased to allow for demolition if relevant, and associated implementation of green and blue infrastructure.
REQUESTED CHANGE
To request that replacement open space does not need to be in operation prior to any loss and an interim period can be allowed for to accommodate for any associated replacement, and such flexibility is introduced in the policy wording of BG/PO.

Policy WS/HD concerns how new development can support the promotion of everyday health wellbeing and lifestyles of residents. Part 1 of the policy sets out principles new developments should incorporate to facilitate the delivery of healthy lifestyles. Part 2 sets out the thresholds for when HIAs will be required with full HIAs required for proposals of 100 dwellings or more or 5,000m2 of gross internal floorspace (GIA).
CIP supports in principle the importance of new developments in promoting healthy and active lifestyles. However, part 1 of Policy WS/HD relists principles that are addressed in other policies in draft GCLP linked to housing, biodiversity and green spaces.
For consistency and avoidance of replication, it is preferred that explicit reference is made to the relevant policies which further set out the principles listed in Policy WS/HD and therefore avoid unnecessary wording included in Policy WS/HD.
CIP 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 for schemes of 200 or less dwellings there is no requirement for a HIA.
REQUESTED CHANGE
For part 1 to be amended to include explicit reference to the relevant policies which expand upon the principles listed under Part 1 of WS/HD.

To request the threshold of a full HIA submission is increased to 500 dwellings, a rapid HIA for schemes of 200-500 dwellings and for schemes of 200 or less dwellings there is no requirement for a HIA.