Draft Greater Cambridge Local Plan for consultation

As a consequence of the above a more detailed assessment of the smaller sites, including North of Willingham Road, Over, HELAA reference 40323, should be undertaken and proper reasoning be given as to why such sites have or have not been taken forward for inclusion in the plan. This should form the basis of a smaller sites assessment document which ensures that at least 20% of the allocations in the Local Plans are on sites of between one and two and a half hectares.

Having carried out a detailed review of the draft plan, there are numerous concerns about the structure of the Plan, the content of the Plan, and the way in which the Plan fails to account for the forthcoming update in the National Planning Policy Framework.
In brief, the overarching concerns are as follows:
• The plan contains too many references to other documents which need to be read in conjunction with it. This makes the Plan overly large, hard to use and therefore a source of potential confusion. The plan is in itself, overly verbose.
• The Plan is too focused on large development schemes. Policies do not account for the needs of or processes for small schemes. Neither is there a proper distinction between urban and rural areas.
• The NPPF is due to be updated in June/July 2026. A substantive draft is available, and while accepting that this may change somewhat, it should be made clear that it has been considered. Alternatively the plan should be paused to allow this to occur.
To expand on the above; the Plan has a dearth of residential sites to the west of Cambridge, with particularly limited residential allocations within the northwestern quadrant. The plan fails to recognise that residents not only reside in and travel to Cambridge, but also work to the west.
There is too great a focus on very large developments - failing to recognise that smaller developments in Group Villages, such as Over, can be quickly delivered, maintaining the Councils delivery of housing and assisting in sustaining the services and facilities of Group Village. Such sites also recognise that not all residents wish to live in large, high density developments.
An appropriate example would be the land submitted at North of Willingham Road, Over, HELAA reference 40323. Sites such as this need to be reviewed to ensure that the smaller sites are appropriately represented. It is clear at this stage that they are not and this could potentially render the Plan unsound.
Better distribution of new housing would also allow the objective of the Local Plan to be achieved which states that “As well as planning to meet the overall need in terms of the number of new homes, our policies seek to ensure that the right mix of house types and tenure is delivered. We want homes to be of a high quality, we therefore set minimum sizes for rooms and outdoor space. We also require homes to be adaptable, so they can meet need through people’s lives”. After tenure it is recommended that in the right places is included.
Due regard needs to be given Draft NPPF HO6: Planning for a diverse mix of sites which seeks to
a. Allocate land to accommodate at least 10% of the housing requirement on sites no larger than one hectare, and a further 10% on sites of between one and two and a half hectares, unless there are strong reasons why these targets cannot be achieved.

However, no residential development in Over is allowed for. Some residential growth would allow residents to be located close to their place of work, assisting with sustainability, an objective which the plan is seeking to achieve. Over is also in very close proximity to the large industrial/commercial allocations at Policy S/RRA/SCS: Land to the south of Cambridge Services, A14, Policy S/RRA/BBP and Land at Buckingway Business Park, Swavesey which are not subject to any associated allocations for residential development.

The aims of this policy are supported, although the level of information/evidence sought should be commensurate with the scale and type of development.

The overarching objectives of this policy are supported.

This policy should be amended to be proportionate to the size of scheme to which it is being applied.

This policy is generally supported, but again, the requirements sought should be proportionate to the development.

A detailed assessment of the sites being considered for allocation and not deferred until later

These issues must be explored during the preparation of the Plan and not left until the submission of applications. If such exploration is not evidenced, it could render allocations undeliverable.

The principles of this policy are supported

The policy should be amended to state 10% and if 20% is to be sought this should relate to specific sites with detailed justification for an enhanced BNG requirement.

The proposal to seek a 20% BNG is contrary to the advice in the draft NPPF, which if adopted in its current form advocates that “Development plans should only set local standards for biodiversity net gain which are in excess of the statutory net gain requirement where this is for specific site allocations, and is fully justified and deliverable. Any such requirements should not extend to categories of development which are exempt from statutory biodiversity net gain”.
The basis for this policy is not appropriately evidenced and fails to recognise that the policy has implications for the delivery of sites. In addition, if off-site credits must be secured, are these available? Even if such credits are available these are prohibitively expensive and will have cost implications affecting other benefits which a site is able to provide. The statutory requirement for BNG is 10% and development should proceed on this basis.
It is of note that local responses to the earlier iteration of the plan supported a higher target of 20%, but is this based on emotional views rather than how BNG operates in realistic market conditions?
A strategic assessment should be produced by the Council to understand the impacts on viability of an additional 10% BNG above that which the Environment Act/ draft NPPF requires. This assessment should demonstrate that a shift from 10% to 20% would not materially impact viability, particularly if this is delivered on site. It should also be based on specific sites rather than a blanket approach.

This policy is confusing and does not clearly state whether this refers to public areas of the site or the entirety of it. A 30% tree cover will be very different if it is site wide as opposed to public areas. When taking into account SuDs etc and other BNG requirements, it is questionable whether this is achievable on all sites, in practical terms. Also, it needs to be stated what is major development, as at this juncture it appears to be schemes of more than 10 dwellings.