Draft Greater Cambridge Local Plan for consultation

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Object

Draft Greater Cambridge Local Plan for consultation

Policy BG/TC: Improving tree canopy cover and the tree population

Representation ID: 204123

Received: 30/01/2026

Respondent: E W Pepper Ltd

Agent: Bidwells LLP

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

The respondent objects to Draft Policy BG/TC, arguing that the existing requirement for a minimum 10% Biodiversity Net Gain (BNG) is sufficient for ecological enhancement and that the proposed tree canopy requirement duplicates this framework.

They express concern that the 30% tree canopy cover requirement for major developments may impose inflexible constraints that could negatively impact development capacity, density, and viability, conflicting with national planning policy.

The respondent notes a lack of clarity regarding the calculation method for canopy cover, as the policy does not specify the approved calculator or methodology, leading to uncertainty.

In the context of Greater Cambridge, the respondent highlights that a fixed canopy cover threshold could impose an additional burden on development viability, potentially compromising the deliverability of schemes and the Local Plan's implementation.

Change suggested by respondent:

The tree canopy requirement should be removed, or restated as aspirational only.

Full text:

We object to Draft 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 with respect to trees within a development site.
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. As such, it is not aligned with national planning policy or with the Government’s stated ambition for growth.
The Draft 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.
In the Greater Cambridge context, where sites are often constrained and development viability is already heavily influenced by multiple policy requirements, the introduction of a fixed canopy cover threshold risks placing an additional and unjustified burden on development. This could compromise scheme deliverability and, in turn, the ability of the Local Plan to be implemented as intended.

Object

Draft Greater Cambridge Local Plan for consultation

Policy H/CB: Self and custom build homes

Representation ID: 204127

Received: 30/01/2026

Respondent: E W Pepper Ltd

Agent: Bidwells LLP

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

The respondent objects to Draft Policy H/CB, specifically the mandatory requirement for 5% self-build homes in all developments, arguing it is unjustified and should only apply where there is demonstrable need.

The respondent believes the policy is inconsistent with the Self-build and Custom Housebuilding Act, which emphasises demand registers over quotas.

The requirement for 5% custom-build units in flatted developments is seen as unnecessary, as such units are often already included in standard delivery models by developers.

The respondent argues that the policy does not provide meaningful additional benefits and instead imposes an undue burden on developers.

Change suggested by respondent:

The requirement should be removed from the Policy.

Full text:

We object 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.

Object

Draft Greater Cambridge Local Plan for consultation

Policy I/ID: Infrastructure and delivery

Representation ID: 204132

Received: 30/01/2026

Respondent: E W Pepper Ltd

Agent: Bidwells LLP

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

The respondent objects to Draft Policy I/ID, stating it prematurely references the Community Infrastructure Levy (CIL), which has not been adopted in the Greater Cambridge Area. They recommend that the policy should only refer to planning obligations or contributions via Section 106 agreements.

While supporting the objective of ensuring sufficient infrastructure capacity for new development, the respondent argues that objections from utility providers should not unreasonably delay or prevent planning permission. They suggest that planning permission should not be refused solely due to current capacity constraints if feasible mitigation or phased delivery is possible.

The respondent requests revisions to Draft Policy I/ID to clarify that objections from utility providers cannot automatically prevent planning permission and that development should proceed where reasonable mitigation or planning mechanisms can address infrastructure requirements.

Change suggested by respondent:

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.

Full text:

We object 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.

Comment

Draft Greater Cambridge Local Plan for consultation

Policy GP/LC: Protection and enhancement of landscape character

Representation ID: 206698

Received: 30/01/2026

Respondent: E W Pepper Ltd

Agent: Bidwells LLP

Representation Summary:

The northern boundary of the Land south of Church Street, east of High Street (HELAA Ref. 40300) is currently designated as an Important Countryside Frontage under Policy NH/13 of the South Cambridgeshire Local Plan 2018 and Draft Policy GP/LC proposes to retain this designation. However, the Site does not have a strong countryside character and it is visually enclosed by significant vegetation screening; there are no views out to the countryside side to protect. Furthermore, the Vision document shows how a break in the built development could still be retained through providing new landscaping and open space along the northern boundary. As set out in our comments to Draft Policy GP/LC, the Councils should remove the Important Countryside Frontage designation from this Site.

Change suggested by respondent:

Remove the ICF allocation on the northern boundary of the Land south of Church Street, east of High Street (HELAA Ref. 40300).

Full text:

E W Pepper objects to Draft Policy S/RRA on the basis that there are insufficient site allocations in the Rest of the Rural Area. 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)

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)

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