Draft Greater Cambridge Local Plan for consultation

Revise the development strategy to ensure that opportunities for sustainable development in well-connected villages served by improving local transport infrastructure are allocated.

Policy S/DS: Development Strategy & Key Diagram

1.2.1 Endurance Estates object to draft Policy S/DS on the grounds that it is not positively prepared or justified when considered against the reasonable alternatives and evidence available.

1.2.2 Draft Policy S/DS, states that, as far as possible, housing and jobs needs will be met in order of preference as follows: (a) within the Cambridge Urban Area, (b) on the edge of Cambridge, (c) at an expanded Cambourne, (d) at other new settlements; and finally (e) in the rural southern cluster and wider rural area at Rural Centres and Minor Rural Centres. The order of preference has been determined in recognition of the sustainability of these locations and are broadly supported by Endurance Estates.

1.2.3 However, the strategy proposed in the Regulation 18 plan relies primarily and increasingly on strategic developments in new settlements for new housing delivery. The draft Plan makes reference to North East Cambridge (including the Waste Water Treatment Works) being the “last remaining significant brownfield site” within the City, which has resulted in the provision of housing within the Urban Area, the most sustainable location within the District, falling from 19% to 11% of the proposed provision. The Draft Policy also confirms that the ‘Edge of Cambridge’ is the second most sustainable location, and so it would be expected that there would be a corresponding increase in the proportion of housing to be delivered on the edge of the City, however the share of housing proposed for ‘Edge of Cambridge’ sites is proposed to fall from 35% in the 2018 Plans to 29% in the Draft. There has also been a decrease in the proportion of dwellings proposed to be delivered through the Rural Area (including through windfalls) – falling from 23% in the 2018 Plans, to just 16% in the proposed draft.

1.2.4 A total of 44% of the identified need is proposed to be delivered through new settlements, up from 23% in the 2018 Plans. The Plan therefore concentrates development on the New Settlements at the expense of every other location across Greater Cambridge. This position is summarised in Table 2 below.

Please refer to Endurance Estates' full representations for Table 2.

Allocate additional sites in villages and on the edge of Cambridge to balance growth across Greater Cambridge and provide more viable and sustainable short-term and medium-term growth options.

Policy S/DS: Development Strategy & Key Diagram

1.2.1 Endurance Estates object to draft Policy S/DS on the grounds that it is not positively prepared or justified when considered against the reasonable alternatives and evidence available.

1.2.2 Draft Policy S/DS, states that, as far as possible, housing and jobs needs will be met in order of preference as follows: (a) within the Cambridge Urban Area, (b) on the edge of Cambridge, (c) at an expanded Cambourne, (d) at other new settlements; and finally (e) in the rural southern cluster and wider rural area at Rural Centres and Minor Rural Centres. The order of preference has been determined in recognition of the sustainability of these locations and are broadly supported by Endurance Estates.

1.2.3 However, the strategy proposed in the Regulation 18 plan relies primarily and increasingly on strategic developments in new settlements for new housing delivery. The draft Plan makes reference to North East Cambridge (including the Waste Water Treatment Works) being the “last remaining significant brownfield site” within the City, which has resulted in the provision of housing within the Urban Area, the most sustainable location within the District, falling from 19% to 11% of the proposed provision. The Draft Policy also confirms that the ‘Edge of Cambridge’ is the second most sustainable location, and so it would be expected that there would be a corresponding increase in the proportion of housing to be delivered on the edge of the City, however the share of housing proposed for ‘Edge of Cambridge’ sites is proposed to fall from 35% in the 2018 Plans to 29% in the Draft. There has also been a decrease in the proportion of dwellings proposed to be delivered through the Rural Area (including through windfalls) – falling from 23% in the 2018 Plans, to just 16% in the proposed draft.

1.2.4 A total of 44% of the identified need is proposed to be delivered through new settlements, up from 23% in the 2018 Plans. The Plan therefore concentrates development on the New Settlements at the expense of every other location across Greater Cambridge. This position is summarised in Table 2 below.

Please refer to Endurance Estates' full representations for Table 2.

Revise the development strategy to incorporate a more flexible approach to employment floorspace provision which recognises the loss of Industrial and Mid-Tech floorspace and support for locations along other radial routes, including the A10 south of Cambridge.

Policy S/DS: Development Strategy & Key Diagram

1.2.1 Endurance Estates object to draft Policy S/DS on the grounds that it is not positively prepared or justified when considered against the reasonable alternatives and evidence available.

1.2.2 Draft Policy S/DS, states that, as far as possible, housing and jobs needs will be met in order of preference as follows: (a) within the Cambridge Urban Area, (b) on the edge of Cambridge, (c) at an expanded Cambourne, (d) at other new settlements; and finally (e) in the rural southern cluster and wider rural area at Rural Centres and Minor Rural Centres. The order of preference has been determined in recognition of the sustainability of these locations and are broadly supported by Endurance Estates.

1.2.3 However, the strategy proposed in the Regulation 18 plan relies primarily and increasingly on strategic developments in new settlements for new housing delivery. The draft Plan makes reference to North East Cambridge (including the Waste Water Treatment Works) being the “last remaining significant brownfield site” within the City, which has resulted in the provision of housing within the Urban Area, the most sustainable location within the District, falling from 19% to 11% of the proposed provision. The Draft Policy also confirms that the ‘Edge of Cambridge’ is the second most sustainable location, and so it would be expected that there would be a corresponding increase in the proportion of housing to be delivered on the edge of the City, however the share of housing proposed for ‘Edge of Cambridge’ sites is proposed to fall from 35% in the 2018 Plans to 29% in the Draft. There has also been a decrease in the proportion of dwellings proposed to be delivered through the Rural Area (including through windfalls) – falling from 23% in the 2018 Plans, to just 16% in the proposed draft.

1.2.4 A total of 44% of the identified need is proposed to be delivered through new settlements, up from 23% in the 2018 Plans. The Plan therefore concentrates development on the New Settlements at the expense of every other location across Greater Cambridge. This position is summarised in Table 2 below.

Please refer to Endurance Estates' full representations for Table 2.

Revise the approach to new settlements to ensure that employment opportunities, as well as housing, are provided as part of these new communities.

Policy S/DS: Development Strategy & Key Diagram

1.2.1 Endurance Estates object to draft Policy S/DS on the grounds that it is not positively prepared or justified when considered against the reasonable alternatives and evidence available.

1.2.2 Draft Policy S/DS, states that, as far as possible, housing and jobs needs will be met in order of preference as follows: (a) within the Cambridge Urban Area, (b) on the edge of Cambridge, (c) at an expanded Cambourne, (d) at other new settlements; and finally (e) in the rural southern cluster and wider rural area at Rural Centres and Minor Rural Centres. The order of preference has been determined in recognition of the sustainability of these locations and are broadly supported by Endurance Estates.

1.2.3 However, the strategy proposed in the Regulation 18 plan relies primarily and increasingly on strategic developments in new settlements for new housing delivery. The draft Plan makes reference to North East Cambridge (including the Waste Water Treatment Works) being the “last remaining significant brownfield site” within the City, which has resulted in the provision of housing within the Urban Area, the most sustainable location within the District, falling from 19% to 11% of the proposed provision. The Draft Policy also confirms that the ‘Edge of Cambridge’ is the second most sustainable location, and so it would be expected that there would be a corresponding increase in the proportion of housing to be delivered on the edge of the City, however the share of housing proposed for ‘Edge of Cambridge’ sites is proposed to fall from 35% in the 2018 Plans to 29% in the Draft. There has also been a decrease in the proportion of dwellings proposed to be delivered through the Rural Area (including through windfalls) – falling from 23% in the 2018 Plans, to just 16% in the proposed draft.

1.2.4 A total of 44% of the identified need is proposed to be delivered through new settlements, up from 23% in the 2018 Plans. The Plan therefore concentrates development on the New Settlements at the expense of every other location across Greater Cambridge. This position is summarised in Table 2 below.

Please refer to Endurance Estates' full representations for Table 2.

Policy S/DS: Development Strategy & Key Diagram

1.2.1 Endurance Estates object to draft Policy S/DS on the grounds that it is not positively prepared or justified when considered against the reasonable alternatives and evidence available.

1.2.2 Draft Policy S/DS, states that, as far as possible, housing and jobs needs will be met in order of preference as follows: (a) within the Cambridge Urban Area, (b) on the edge of Cambridge, (c) at an expanded Cambourne, (d) at other new settlements; and finally (e) in the rural southern cluster and wider rural area at Rural Centres and Minor Rural Centres. The order of preference has been determined in recognition of the sustainability of these locations and are broadly supported by Endurance Estates.

1.2.3 However, the strategy proposed in the Regulation 18 plan relies primarily and increasingly on strategic developments in new settlements for new housing delivery. The draft Plan makes reference to North East Cambridge (including the Waste Water Treatment Works) being the “last remaining significant brownfield site” within the City, which has resulted in the provision of housing within the Urban Area, the most sustainable location within the District, falling from 19% to 11% of the proposed provision. The Draft Policy also confirms that the ‘Edge of Cambridge’ is the second most sustainable location, and so it would be expected that there would be a corresponding increase in the proportion of housing to be delivered on the edge of the City, however the share of housing proposed for ‘Edge of Cambridge’ sites is proposed to fall from 35% in the 2018 Plans to 29% in the Draft. There has also been a decrease in the proportion of dwellings proposed to be delivered through the Rural Area (including through windfalls) – falling from 23% in the 2018 Plans, to just 16% in the proposed draft.

1.2.4 A total of 44% of the identified need is proposed to be delivered through new settlements, up from 23% in the 2018 Plans. The Plan therefore concentrates development on the New Settlements at the expense of every other location across Greater Cambridge. This position is summarised in Table 2 below.

Please refer to Endurance Estates' full representations for Table 2.

Revise the policy to include clear triggers for remedial action for failure to meet housing or employment targets.

Policy S/DS: Development Strategy & Key Diagram

1.2.1 Endurance Estates object to draft Policy S/DS on the grounds that it is not positively prepared or justified when considered against the reasonable alternatives and evidence available.

1.2.2 Draft Policy S/DS, states that, as far as possible, housing and jobs needs will be met in order of preference as follows: (a) within the Cambridge Urban Area, (b) on the edge of Cambridge, (c) at an expanded Cambourne, (d) at other new settlements; and finally (e) in the rural southern cluster and wider rural area at Rural Centres and Minor Rural Centres. The order of preference has been determined in recognition of the sustainability of these locations and are broadly supported by Endurance Estates.

1.2.3 However, the strategy proposed in the Regulation 18 plan relies primarily and increasingly on strategic developments in new settlements for new housing delivery. The draft Plan makes reference to North East Cambridge (including the Waste Water Treatment Works) being the “last remaining significant brownfield site” within the City, which has resulted in the provision of housing within the Urban Area, the most sustainable location within the District, falling from 19% to 11% of the proposed provision. The Draft Policy also confirms that the ‘Edge of Cambridge’ is the second most sustainable location, and so it would be expected that there would be a corresponding increase in the proportion of housing to be delivered on the edge of the City, however the share of housing proposed for ‘Edge of Cambridge’ sites is proposed to fall from 35% in the 2018 Plans to 29% in the Draft. There has also been a decrease in the proportion of dwellings proposed to be delivered through the Rural Area (including through windfalls) – falling from 23% in the 2018 Plans, to just 16% in the proposed draft.

1.2.4 A total of 44% of the identified need is proposed to be delivered through new settlements, up from 23% in the 2018 Plans. The Plan therefore concentrates development on the New Settlements at the expense of every other location across Greater Cambridge. This position is summarised in Table 2 below.

Please refer to Endurance Estates' full representations for Table 2.

Policy S/JH: New Jobs and Homes

1.1.1 Endurance Estates object to Draft Policy S/JH on the basis that the proposed requirement for both jobs and homes is insufficient to meet the real-world need in and around Cambridge. In the case of the extent of housing provision, the proposed housing supply is also considered to be insufficient to ensure full delivery of the identified needs with the proposed buffer of 6.5% insufficient to provide flexibility and ensure a robustness of delivery. As a result, the draft Plan is not considered to be positively prepared and is unlikely to meet the needs in terms of housing and infrastructure delivery.

1.1.2 The Regulation 18 Draft Plan aims to meet the objectively assessed needs between 2024-2045 for 73,300 jobs and a minimum of 48,195 new homes.

1.1.3 The need for significant growth across Greater Cambridge is clear. The UK Government has repeatedly expressed its ambition to substantially increase the delivery of homes across the country, with a particular focus on Cambridge in recognition of Cambridge’s role as a leading European hub for science and technology innovation which is an engine for economic growth that, if managed correctly, can continue to thrive.

1.1.4 The relative strength of Cambridge is well documented and evidenced. The 2014 City Deal sought to “enable a new wave of innovation-led growth by investing in infrastructure, housing and skills that will facilitate the continued growth of the Cambridge Phenomenon”.

1.1.5 More recently, the Government has continued to further strengthen its support for growth around Cambridge. The Case for Cambridge (March 2024) report states that the Life Sciences sector alone employs 23,000 people in over 600 companies in the Cambridge region, with a combined turnover of £9bn, making Cambridge Europe’s largest cluster. The current Government is equally clear that they intend to capitalise upon the previous success of the region with Matthew Pennycook confirming in August 2024. the following (emphasis our own):
“We believe that the recent focus on Cambridge and its untapped economic potential are entirely warranted. The city’s strengths in knowledge-intensive businesses and its unique innovation ecosystem are well documented, with strong connections between investors, researchers, businesses and local government. The economic growth of Cambridge has been a phenomenal success and we should seek to maximise the potential contribution that Greater Cambridge could make to the UK economy”.

1.1.6 While recognising the need for Growth, Matthew Pennycook went on to recognise some of the difficulties which have emerged as a failure to account for sufficient levels of growth:
“Success has clearly come with costs; expensive housing, traffic jams and air pollution are daily concerns for many residents and risk deterring those who want to live, work and study in the city”, before identifying that “I recognise that in recent years much has been delivered, there remain significant barriers to realising the area’s full potential. The Deputy Prime Minister and I are determined to help remove them and overcome the issues that have held up planned development for essential housing and laboratory space.”

1.1.7 As shown in the table below, when compared to the First Proposals Draft, Greater Cambridge is now proposing 8.7% more homes on an annual basis. This is in the context of a Standard Method which has increased by almost 30% as outlined in the Consultation Strategy Topic Paper. At the same time, the latest Draft Plan proposes around 25% more jobs across the plan period, meaning there is an increasing disparity between the relatively ambitious jobs target and a less ambitious housing target.

1.1.8 Please refer to Table 1 in the attached document for a comparison between First Proposals and December 2025 Consultation Drafts.

1.1.9 Endurance Estates are supportive of the acknowledgement that the proposed employment figures outlined in the First Proposals were insufficient, to fully capitalise upon the Government’s ambition for the region. However, Endurance Estates consider that the true need is likely greater still than the 73,300 jobs that is being planned for as part of the Regulation 18 Draft Local Plan.

1.1.10 In terms of Housing, it is disappointing that Greater Cambridge are not pursuing an increase in the planned housing figures to correspond to the comparatively ambitious jobs target. Endurance Estates contend that failing to plan for an ambitious housing figure to deliver against the deficiencies outlined in the August 2024 letter from Matthew Pennycook, potentially jeopardises the continued economic success of Cambridge.

1.1.11 Paragraph 3.43 of the Strategy Topic Paper explains this change by highlighting that Cambridge’s current commuting ratio is below 1, meaning there is a greater number of employees who are in-commuting to the region. Whilst this is acknowledged, this fact is arguably a demonstration of historic under-delivery of housing relative to jobs growth, rather than a coherent justification for this approach moving forward. In light of this, it is therefore disappointing that Greater Cambridge are content to pursue only the minimum housing requirements, effectively shifting residual housing demands into neighbouring authorities, which risks embedding unsustainable commuting patterns and increasing pressure on existing infrastructure in and around the City.

1.1.12 It is considered that it is not sufficient or sustainable to plan for higher jobs growth without fully addressing corresponding housing needs, and to rely upon in-commuting. Such a strategy risks increasing strain on key infrastructure whilst also driving up property values due to a shortage of supply relative to demand. As evidenced within the Case for Cambridge report, it is already the case that economic growth in the region is being held back by a lack of adequate housing supply relative to demand, which is evident when considering that South Cambridgeshire has one of the highest house price-to-earnings ratios in the Country. ONS data confirms that the median house price reached £425,025 in 2024, equating to 9.5x median earnings, compared to a median house price of £290,000 (7.7x median earnings) across England as a whole.

1.1.13 In addition to aiming beyond the mandatory housing target, it is the view of Endurance Estates that Greater Cambridge should adopt a more substantial housing supply buffer than the 6.5% currently proposed. The First Proposals draft had included a 10% buffer over the 2,111 dwellings annual requirement which was identified at the time.

1.1.14 At very least, a higher housing supply buffer to provide flexibility of delivery, and to ensure a robustness of supply should be introduced. Endurance Estates consider that the current buffer of 6.5% (excluding any potential delivery at the former Wastewater Treatment Works site) is insufficient and fails to recognise the delivery challenges which have historically held back early delivery on the large-scale strategic sites within Greater Cambridge.

1.1.15 When considering the default 5% buffer applied to 5-Year Housing Land Supply Assessments, the 6.5% buffer on the identified need for the whole 18 year Plan period will offer little comfort in the event that any of the new settlements are delayed.

1.1.16 Endurance Estates’ view of the Trajectory and Five-Year Housing Land Supply included at Appendix E of the Regulation 18 Plan will be outlined in separate representations, however it is worth noting that with such a slight buffer, any small deviation in terms of delivery could result in the Council being unable to demonstrate a 5-year housing land supply upon, or shortly after, adoption of the plan. At present, Savills estimate Greater Cambridge can demonstrate only around 4-years’ supply, primarily as a result of overly optimistic assumptions around delivery at the new settlements which have been delayed by late delivery of essential infrastructure – including Waterbeach Railway Station and the C2C busway which have resulted in delays to the Waterbeach New Town East and Bourn Airfield developments respectively.

1.1.17 The continued dependency upon strategic scale new settlements for the majority of the planned housing delivery, presents significant risk to Greater Cambridge’s ability to maintain a 5 year housing land supply. As a consequence of the inadequate buffer proposed, even a relatively minor delay on one or more of the new settlements could jeopardise the plan-led system and could leave the district open to speculative development to plug the shortfall.

1.1.18 In light of the significant infrastructure challenges across the Cambridge region, and the mixed track record of delivery in recent years, a more substantial buffer would be prudent.

1.1.19 As a result, it is Endurance Estates’ view that Greater Cambridge should employ a housing land supply buffer of over 10% and preferably circa 15-20% above the Standard Method figure. Such a buffer would provide the authority with flexibility in light of any delays with the delivery of the large number of strategic sites / new settlements resulting under-delivery versus the housing trajectory, and therefore reduce the risk of being unable to demonstrate and maintain a sufficient 5YHLS or failing to meet the identified housing requirement for the Plan period in full with the danger that this could further hold back the local economy.

The arbitrary limits, which stymie sustainable growth should be deleted prior to the Regulation 19 Consultation Draft Plan.

1.3.1 Endurance Estates wishes to object to Policy S/SH, and in particular the arbitrary indicative limits on the scale of housing developments set out. The indicative housing limits do not ensure the continued vitality of the villages, nor recognise their sustainability for proportionate and controlled housing growth. As a result of the proposed hierarchy, the policy is not considered to be positively prepared or justified, as it will result in unmet need across the villages of the District.

1.3.2 The Settlement Hierarchy seeks to direct the majority of new housing to Cambridge first, then Edge of Cambridge followed by the New Settlements. It is acknowledged that Cambridge is constrained by a lack of available sites, however, as outlined in Endurance Estates’ representations to Policy S/DS, the majority of development is proposed to be directed to the New Settlements (the third tier). This overlooks sustainable and available Edge of Cambridge locations, where there is capacity to provide additional housing and employment land in sequentially preferable locations in terms of sustainability.

1.3.3 The rural areas of South Cambridgeshire are ageing rapidly, Cambridgeshire Insight estimate that the greatest increase in population will be in the elderly population, with a 55% increase in the 80-84 age population and a 45% increase in the over 85s. This rapid aging is a challenge to villages which do not see any growth, and risks jeopardising the ongoing provision of key services including rural schools and local shops –– jeopardising continued provision of one of the key features which make them sustainable locations to live.

1.3.4 A controlled and proportional level of growth is the best way to ensure the continued vitality of rural villages. In this context, Paragraph 82 of the NPPF confirms that in rural areas, “planning policies and decisions should be responsive to local circumstances and support housing developments that reflect local needs”, whilst Paragraph 83 states that “To promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities”. The current Draft Plan is not considered to sufficiently address local needs or circumstances and is therefore not in accordance with national policy.

1.3.5 Sites should preferably be brought forward through the plan-led process, however if not, policies such as Policy S/SH should be sufficiently flexible to ensure that moderate development can come forward.

1.3.6 It is considered that the apparently arbitrary ‘indicative’ limits upon developments of 30 dwellings in Minor Rural Centres and just 8 dwellings in Group Villages will result in small, piecemeal development which fails to ensure the continued vitality of key village services.

1.3.7 The 8 dwelling indicative limit imposed upon Group Villages is particularly harmful as it would jeopardise affordable delivery, which as per both the adopted Plans and proposed Policy H/AH, are typically secured only through schemes of 10 or more dwellings. Under the policy, Group Villages would effectively be reliant upon rural exceptions sites to deliver any affordable housing which is considered unlikely to be sufficient to meet the affordable housing needs in villages across the district.

1.3.8 There is an inconsistency between the draft Policy S/SH and Figure D1 of Appendix D which provide the housing requirements for the designated rural areas.

1.3.9 The arbitrary limits, which stymie sustainable growth should be deleted prior to the Regulation 19 Consultation Draft Plan. The limits as proposed are not justified and are not consistent with the NPPF.

Review Policy S/SH against Appendix D and correct any inconsistencies.

1.3.1 Endurance Estates wishes to object to Policy S/SH, and in particular the arbitrary indicative limits on the scale of housing developments set out. The indicative housing limits do not ensure the continued vitality of the villages, nor recognise their sustainability for proportionate and controlled housing growth. As a result of the proposed hierarchy, the policy is not considered to be positively prepared or justified, as it will result in unmet need across the villages of the District.

1.3.2 The Settlement Hierarchy seeks to direct the majority of new housing to Cambridge first, then Edge of Cambridge followed by the New Settlements. It is acknowledged that Cambridge is constrained by a lack of available sites, however, as outlined in Endurance Estates’ representations to Policy S/DS, the majority of development is proposed to be directed to the New Settlements (the third tier). This overlooks sustainable and available Edge of Cambridge locations, where there is capacity to provide additional housing and employment land in sequentially preferable locations in terms of sustainability.

1.3.3 The rural areas of South Cambridgeshire are ageing rapidly, Cambridgeshire Insight estimate that the greatest increase in population will be in the elderly population, with a 55% increase in the 80-84 age population and a 45% increase in the over 85s. This rapid aging is a challenge to villages which do not see any growth, and risks jeopardising the ongoing provision of key services including rural schools and local shops –– jeopardising continued provision of one of the key features which make them sustainable locations to live.

1.3.4 A controlled and proportional level of growth is the best way to ensure the continued vitality of rural villages. In this context, Paragraph 82 of the NPPF confirms that in rural areas, “planning policies and decisions should be responsive to local circumstances and support housing developments that reflect local needs”, whilst Paragraph 83 states that “To promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities”. The current Draft Plan is not considered to sufficiently address local needs or circumstances and is therefore not in accordance with national policy.

1.3.5 Sites should preferably be brought forward through the plan-led process, however if not, policies such as Policy S/SH should be sufficiently flexible to ensure that moderate development can come forward.

1.3.6 It is considered that the apparently arbitrary ‘indicative’ limits upon developments of 30 dwellings in Minor Rural Centres and just 8 dwellings in Group Villages will result in small, piecemeal development which fails to ensure the continued vitality of key village services.

1.3.7 The 8 dwelling indicative limit imposed upon Group Villages is particularly harmful as it would jeopardise affordable delivery, which as per both the adopted Plans and proposed Policy H/AH, are typically secured only through schemes of 10 or more dwellings. Under the policy, Group Villages would effectively be reliant upon rural exceptions sites to deliver any affordable housing which is considered unlikely to be sufficient to meet the affordable housing needs in villages across the district.

1.3.8 There is an inconsistency between the draft Policy S/SH and Figure D1 of Appendix D which provide the housing requirements for the designated rural areas.

1.3.9 The arbitrary limits, which stymie sustainable growth should be deleted prior to the Regulation 19 Consultation Draft Plan. The limits as proposed are not justified and are not consistent with the NPPF.

More flexibility needs to be introduced into the application of the policy through changes to the detailed wording, in particular, part C of the draft Policy where it should refer to “where possible”. Refer to Endurance Estates' full representations for details.

1.6.1 Endurance objects to Policy CC/NZ since the proposed requirements of the draft Policy are considered to be unduly onerous and are not justified, positively prepared or consistent with National Policy.

1.6.2 Endurance has particular concerns regarding the requirement under part B of the draft Policy in relation to total energy use intensity. It is noted that these requirements go beyond Building Regulations requirements. The Government has provided guidance to local planning authorities that suggest that Local Planning Authorities should not go beyond the requirements of Building Regulations.

1.6.3 The Government’s Written Ministerial Statement (WMS) issued in December 2023, confirms that the government “does not expect” councils to set standards above current or planned Building Regulations and that inspectors should reject such policies unless the council can provide a “well-reasoned and robustly costed rationale” showing the policy was viable. Whilst the Courts have subsequently confirmed LPAs can set energy efficiency standards above national regulations, these need to be robustly justified by local circumstances and backed by evidence.
1.6.4 Moreover, we note that the consultation draft NPPF published in December 2025 reinforces this point by setting an “expectation” that local plans should not replicate or go further than nationally set building standards except for in relation to housing accessibility and water efficiency in “exceptional circumstances”.

1.6.5 It is considered that the proposed policy requirements are unduly onerous and have not been sufficiently justified by local or exceptional circumstances or through robust evidence showing they are both necessary and viable.

1.6.6 In addition, more flexibility needs to be introduced into the application of other aspects of the policy through changes to the detailed wording, in particular, part C of the draft Policy where it should refer to “where possible”.