Draft Greater Cambridge Local Plan for consultation
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Draft Greater Cambridge Local Plan for consultation
Policy S/JH: New jobs and homes
Representation ID: 204027
Received: 30/01/2026
Respondent: E W Pepper Ltd
Agent: Bidwells
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Draft Policy S/JH should be viewed as a minimum requirement for 73,300 jobs and 48,195 homes, as evidence suggests a higher need of between 67,600 and 90,900 jobs.
The Central growth scenario of 73,200 jobs is conservative and does not reflect the full growth potential of the Cambridge economy, which expanded by nearly 4,000 jobs annually during 2010-2020.
The Local Plan should incorporate higher-growth scenarios to align with national policy objectives for sustainable economic growth and productivity.
Additional sites in Greater Cambridge should be allocated to respond to higher growth potential, including E W Pepper's sites in Guilden Morden, Steeple Morden, Arrington, and Kneesworth.
A higher number of new homes is necessary to meet the needs of the existing population and support future economic growth, aligning with the Strategic Priority in the Draft GCLP.
Object
Draft Greater Cambridge Local Plan for consultation
Policy S/DS: Development strategy
Representation ID: 204043
Received: 30/01/2026
Respondent: E W Pepper Ltd
Agent: Bidwells
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
The respondent objects to Policy S/DS, stating that the allocation of only 10,330 homes between 2024 and 2045 is insufficient for sustainable growth in Greater Cambridge.
There is a concern about the focus on a few large strategic sites for housing development, particularly in the Rural Area, with a lack of small and medium-sized sites.
The proposed strategy does not align with the NPPF's requirement to enhance rural community vitality, as it relies heavily on windfall developments rather than planned allocations.
The respondent highlights that the current approach allocates only 3.5% of the housing requirement to small sites, which is below the NPPF's 10% target.
The draft plan's reliance on a small number of large sites, which require significant infrastructure, raises concerns about their timely delivery and overall feasibility.
The respondent argues for a balanced approach that includes more allocations in rural villages to support local housing needs and prevent population imbalance.
The lack of housing in smaller villages is seen as a constraint on sustainable development, forcing new households to relocate away from their communities.
The respondent calls for the GCLP to identify a broader range of housing sites in South Cambridgeshire's rural areas to promote sustainable growth and support local economies.
Object
Draft Greater Cambridge Local Plan for consultation
Policy S/SH: Settlement hierarchy
Representation ID: 204056
Received: 30/01/2026
Respondent: E W Pepper Ltd
Agent: Bidwells
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Specifically, we do not consider that the indicative maximum scheme sizes are necessary for the Group and Infill Villages. Schemes should be encouraged to make an efficient and effective use of land whilst delivering housing development that is appropriate and helps in meeting the needs of the local community. Often small windfall sites (under the thresholds indicated from Group and Infill Villages) will provide limited or no affordable housing.
Object
Draft Greater Cambridge Local Plan for consultation
Policy S/DE: Defined development extents
Representation ID: 204068
Received: 30/01/2026
Respondent: E W Pepper Ltd
Agent: Bidwells
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
The respondent objects to Draft Policy S/DE, stating that current settlement envelopes around villages are too restrictive, limiting opportunities for growth.
They suggest that more consideration should be given to identifying suitable land within and adjacent to village boundaries for sustainable growth, particularly in non-Green Belt areas.
The respondent believes that new developments could enhance community sustainability by increasing footfall and enabling new facilities, amenities, and transport improvements alongside housing.
They argue that such developments would contribute positively to a sound and sustainable spatial strategy for the new Local Plan.
Object
Draft Greater Cambridge Local Plan for consultation
Policy S/RRA: Other site allocations in the rest of the rural area
Representation ID: 204091
Received: 30/01/2026
Respondent: E W Pepper Ltd
Agent: Bidwells
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
EW Pepper objects to Policy S/RRA. The following sites should be allocated for housing development, in the following settlements:
Guilden Morden – HELAA Refs. 40300 (Land south of Church Street, east of High Street) and 40304 (Land off Swan Lane), which have been submitted for consideration as a consolidated proposal.
Guilden Morden – HELAA Ref. 40315 (Land at Town Farm)
Steeple Morden – HELAA Ref. 40294 (Land to the west of Brook End)
Arrington – HELAA Ref. 40292 (Land to the southwest of Ermine Way)
Kneesworth – HELAA Ref. 40299 (Land to the east of Old North Road)
Object
Draft Greater Cambridge Local Plan for consultation
Policy CC/SD: Sustainable development and the climate emergency
Representation ID: 204093
Received: 30/01/2026
Respondent: E W Pepper Ltd
Agent: Bidwells
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
We support the intent of Draft Policy CC/SD. We support CC/SD(2) which applies a proportionate approach to sustainability statements.
However, we request the addition of the words “where appropriate” when listing the range of issues to address in sustainability statements, to provide the flexibility intended here.
Object
Draft Greater Cambridge Local Plan for consultation
Policy CC/DC: Designing for a changing climate
Representation ID: 204097
Received: 30/01/2026
Respondent: E W Pepper Ltd
Agent: Bidwells
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
We support the intent of Draft Policy CC/DC.
However, we object to the word “must” at CC/DC(1) as this creates a requirement leaving little to no discretion for decision makers. The word “should” would be more appropriate, setting out an expectation unless justified otherwise, which aids decision makers in reaching a balanced judgement.
Object
Draft Greater Cambridge Local Plan for consultation
Policy CC/NZ: Net zero carbon new buildings
Representation ID: 204104
Received: 30/01/2026
Respondent: E W Pepper Ltd
Agent: Bidwells
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
We object to Draft Policy CC/NZ.
The Draft Policy goes beyond existing sustainability standards for planning, without consideration for impacts on viability and deliverability.
Whilst we welcome the ambition to ensure that all buildings help to meet zero-carbon targets, there needs to be greater flexibility within the policy wording. There should also be clarity regarding what is required and what is aspirational.
Object
Draft Greater Cambridge Local Plan for consultation
Policy CC/WE: Water efficiency in new developments
Representation ID: 204110
Received: 30/01/2026
Respondent: E W Pepper Ltd
Agent: Bidwells
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
The respondent objects to Policy CC/WE, stating it exceeds national and industry guidance by mandating rainwater or greywater harvesting on all major developments, which may not always be feasible.
The use of the word 'must' in the policy is questioned, as it limits discretion for decision makers; 'should' is suggested to allow for balanced judgement.
The policy imposes stricter internal water-use requirements for developments over 100 dwellings, which the respondent supports but finds unjustified based solely on development size.
The respondent argues that internal water use is influenced more by occupant behaviour and dwelling specifications than by the scale of development, suggesting the policy may be arbitrary.
The respondent recommends applying a consistent, evidence-based standard across all residential developments or providing clear justification for higher requirements for larger schemes.
Object
Draft Greater Cambridge Local Plan for consultation
Policy BG/BG: Biodiversity and geodiversity
Representation ID: 204117
Received: 30/01/2026
Respondent: E W Pepper Ltd
Agent: Bidwells
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
The respondent objects to Policy BG/BG, arguing that the national requirement for a minimum 10% Biodiversity Net Gain (BNG) is sufficient for ecological enhancement.
The proposed increase to 20% BNG for major developments in Greater Cambridge is deemed unsound due to a lack of adequate justification and inconsistency with national legislation.
The national BNG framework is seen as providing necessary clarity for planning, and any local requirements exceeding this must be justified and based on specific ecological conditions.
The respondent believes that the approach in Policy BG/BG lacks a robust evidence base and fails to demonstrate that it is proportionate or deliverable.
There is concern that Policy BG/BG undermines policy certainty by imposing a fixed uplift without sufficient justification, and any additional BNG should be considered a material benefit rather than a mandatory requirement.