Draft Greater Cambridge Local Plan for consultation

Policy BG/TC lacks clarity and certainty and should be deleted.

Bellway object to Policy BG/TC.
The statutory requirement to deliver a minimum 10% Biodiversity Net Gain already provides a robust, outcome-based mechanism for securing ecological enhancement. This framework is flexible, evidence-led and capable of responding to site-specific circumstances. The proposed tree canopy requirement appears to duplicate or cut across the BNG regime, without sufficient justification, and risks prioritising a single ecological metric over a balanced planning judgement.
The requirement for major development to demonstrate a minimum of 30% tree canopy cover on site risks introducing an inflexible and prescriptive constraint that could undermine development capacity, density and viability and may not result in an efficient use of land.
The policy and supporting text state that canopy cover should be calculated using a Council-approved calculator or metric. However, neither the policy itself nor the Biodiversity and Green Spaces Topic Paper identifies what calculator or methodology is intended to be used. In the absence of a defined and agreed approach, the policy lacks clarity and certainty.

We request that Policy WS/NC is deleted or substantially modified as set out above.

Bellway object to Policy WS/NC.
Specifically, Point 4 states that proposals for residential developments of 200 or more dwellings (or multiple smaller sites that cumulatively exceed this threshold), must be informed by detailed assessments of community needs and include strategies to address those needs.
It is understood that these assessments should be prepared by the Council as part of their Infrastructure Delivery Plan, and the responsibility should not fall on developers to determine which community needs a development should meet.
Further, Regulation 122(2) of the Community Infrastructure Levy Regulations 2010 (as amended) set out the clear tests required for obligations to be applied to planning permission, these are as follows:
(a) necessary to make the development acceptable in planning terms;
(b) directly related to the development; and
(c) fairly and reasonably related in scale and kind to the development
It is not the responsibility of new development to address existing need, and the policy is ambiguously worded, creating uncertainty that may impose an additional burden on development through an approach that is inconsistent with CIL Regulation tests. If the Council is to pursue this policy, it needs to be clear that development only needs to address matters which meet the CIL Regulations tests set out above.

The respondent recommends amending the policy to align better with national guidelines, advocating for a balance between the loss of high-quality agricultural land and broader sustainability and development objectives.

Bellway objects to Policy J/AL.
The current wording of criterion (1)(b) places an unduly onerous burden on land promoters and landowners, particularly where sites contain Grade 1, 2 or 3a agricultural land.
Whilst the policy appropriately reflects the principle that the irreversible loss of high-quality agricultural land should be avoided where possible, the requirement to demonstrate that “the development cannot be located on areas of poorer quality land” is overly prescriptive. This goes beyond national policy, which states at footnote 65 of the NPPF (2024) that, where significant development of agricultural land is necessary, areas of poorer quality land should be preferred, rather than requiring proof that no alternative location exists.
As drafted, the policy effectively introduces an agricultural land sequential test, similar to that applied in flood risk policy. This approach is not supported by national guidance and places a disproportionate evidential burden on applicants. The policy should therefore be amended to better align with national policy with the loss of best and most versatile agricultural land to be balanced against wider sustainability and development objectives through the planning balance.

Viability should be referenced in the Policy text, rather than just in the supporting text.

Bellway supports the Council’s ambition to ensure that the GCLP supports the delivery of affordable housing. However, noting that viability testing is mentioned at point 9.15 of the supporting text, we consider that the appropriateness of viability tested route should be explicitly mentioned within the wording of the Policy instead.

The Policy should not include a mandatory percentage.

Bellway objects to Draft Policy H/CB.
We object to the proposed mandatory requirement for 5% self-build homes as part of any development. Such a blanket approach across all developments is unjustified and self-build provision should only be sought on sites where there is a demonstrable need. This would be inconsistent with the Self-build and Custom Housebuilding Act, which focuses on demand registers, not quotas.
The current wording of the policy requires that even flatted developments must provide 5% custom-build units. While the supporting text clarifies that self-build flats would be delivered as custom-finish units, these are often already incorporated by developers as part of standard delivery models. As such, the requirement does not result in any meaningful additional benefit but instead places an unnecessary and disproportionate burden on developers.

The respondent requests that designations under Policy I/SI on the Policies Map be updated before the Regulation 19 Consultation to reflect the latest developments with East West Rail.

Bellway objects to Draft Policy I/SI, specifically with reference to the designation of land to the southwest of Comberton on the Policies Map.
The wording of Draft Policy I/SI sets out the important infrastructure that should be safeguarded from any adverse impacts that may advise from development. This includes a range of safeguarding matters, with Point (1b) making specific reference to land identified on the Policies Map which is subject to the East West Rail Safeguarding Direction. We accept the wording of the Draft Policy in principle.
Bellway objects to the identification of land to the southwest of Comberton under this designation (Policy I/SI: East West Rail Scheme) on the Draft Policies Map. Bellway has made formal representations to East West Rail (EWR) during the EWR Non-Statutory Consultation, January 2025. Also prepared by Bidwells, a copy of the EWR Representations is attached for your review (Appendix B).
To summarise, Bellway has an Option Agreement with the Landowner, K B Tebbit Ltd and therefore a legal interest in the land. Bellway strongly objects to the EWR proposals in respect of the proposed alignment of the track to the west and southwest of Comberton, transecting their Site, and the proposed the use of their Site as a construction compound. Bellway and the Landowner have been in subsequent discussions with the EWR Company regarding these matters. They will continue to pursue changes to the EWR Scheme through this route, including forthcoming formal EWR Consultations.
Any designations under Policy I/SI on the Policies Map should be updated in advance of the Regulation 19 Consultation to reflect the latest position with EWR.

The respondent requests that the policy be revised to clarify that objections from utility providers should not automatically halt planning permission, allowing for reasonable mitigation or planning mechanisms.

Bellway objects to Draft Policy I/ID.
Draft Policy I/ID makes continual reference to the Community Infrastructure Levy (CIL) as a way to ensure that schemes are acceptable in planning terms. As CIL has not been adopted in the Greater Cambridge Area, this mechanism for securing contributions via CIL does not yet existing and therefore it is premature to reference this in policy. It is recommended that the policy instead only refers to planning obligations or contributions via Section 106 agreements. This will ensure that the policy is clear, justified, and effective as outlined within the NPPF.
The Policy seeks to ensure sufficient infrastructure capacity to support new development, requiring developers to deliver or fund infrastructure, including via Section 106 or CIL. While the objective of adequate infrastructure is supported, the policy should not allow objections from utility providers, such as water companies, to unreasonably delay or prevent the grant of planning permission. Planning permission should not be refused solely on the basis of current capacity constraints where mitigation or phased delivery is feasible. Appropriate Planning Conditions and/or Obligations should allow for capacity issues to be overcome to ensure that do not unduly restrict housing delivery.
It is therefore requested that Draft Policy I/ID and supporting text be revised to make clear that objections from utility providers cannot automatically prevent the grant of planning permission, and that development should proceed where reasonable mitigation or planning mechanisms can address infrastructure requirements.

Land south of West Street and west of South Street Comberton (Site ID 115659, HELAA Ref. 40152) should be:
Removed from the Policy S/GB (Green Belt) designation on the Policies Map for Regulation 19 Consultation stage;
Removed from the Policy I/SI (Safeguarding Important Infrastructure) designation on the Policies Map for Regulation 19 Consultation stage;
Allocated for Housing development for the Regulation 19 Consultation stage.

Bellway objects to Draft Policy S/RRA.
We object to Draft Policy S/RRA on the basis that there are insufficient site allocations in the Rest of the Rural Area.
In the context of the representations outlined above, Land south of West Street and west of South Street Comberton (Site ID 115659, HELAA Ref. 40152) represents a suitable, deliverable and achievable site to address the acute need for housing within Greater Cambridge.
The attached Letter Representation includes a response to the HELAA Addendum (2025) assessment of the Site and considers the merits of the Site alongside a consideration of the transformed context of national policy since the 2021; most notably the NPPF.
● HELAA Addendum (2025) Response
● Grey Belt
● The Site Opportunity
The Site is suitable, available and achievable for residential development to contribute to the identified needs of Greater Cambridge to deliver housing.
The Site is considered to comprise Grey Belt land in accordance with the NPPF (2024) definition. It should be included in the forthcoming review of Grey Belt sites by LDA and carefully considered for release from the Green Belt under GCLP Regulation 19.
The Site provides an opportunity to deliver a sustainable extension to the existing village settlement of Comberton.
It is hence recommended that Land south of West Street and west of South Street, Comberton is:
• Identified as Grey Belt within the Local Plan and supporting forthcoming Green Belt Assessment
• Removed from the Policy S/GB (Green Belt) designation on the Policies Map for Regulation 19 Consultation stage
• Removed from the Policy I/SI (Safeguarding Important Infrastructure) designation on the Policies Map for Regulation 19 Consultation stage
• Allocated for Housing development for the Regulation 19 Consultation stage

Please see attached Letter Representation.

The GCLP should:

- Remove the Site from the Policy S/GB (Green Belt) designation on the Policies Map
- Allocate the Site for Housing development

Bellway objects to Draft Policy S/RRA.
We object to Draft Policy S/RRA on the basis that there are insufficient site allocations in the Rest of the Rural Area.
In the context of the representations outlined above, Land west of South Street, Comberton (Site ID 115134, HELAA Ref. 40310) represents a suitable, deliverable and achievable site to address the acute need for housing within Greater Cambridge.
The attached Letter Representation includes a response to the HELAA Addendum (2025) assessment of the Site and considers the merits of the Site alongside a consideration of the transformed context of national policy since the 2021; most notably the NPPF.
The Site is suitable, available and achievable for residential development to contribute to the identified needs of Greater Cambridge to deliver housing. The Site is considered to comprise Grey Belt land in accordance with the NPPF (2024) definition. It should be included in the forthcoming review of Grey Belt sites by LDA and carefully considered for release from the Green Belt under GCLP Regulation 19. The Site provides an opportunity to deliver a sustainable extension to the existing village settlement of Comberton.
The Site should be
- Identified as Grey Belt within the Local Plan and supporting forthcoming Green Belt Assessment
- Removed from the Policy S/GB (Green Belt) designation on the Policies Map for Regulation 19 Consultation stage
- Allocated for Housing development for the Regulation 19 Consultation stage