Draft Greater Cambridge Local Plan for consultation

Remove use of the word 'must'

Brookgate Land Ltd and Network Rail Infrastructure Ltd object to policy GP/HE as worded.
Part 2(b) is overly prescriptive and not fully consistent with national policy or the statutory framework for decision-making in the historic environment. The use of the word ‘must’ risks precluding high-quality, sustainable development by implying an absolute requirement to conserve or enhance heritage assets in all circumstances, rather than allowing for a balanced planning judgement.
National policy and legislation require decision-makers to have special regard to the desirability of preserving heritage assets, while weighing this against the scale of harm, site context and public benefits.
Policy GP/HE should therefore be amended to adopt more proportionate wording that reflects this balanced approach, consistent with the NPPF 2024 and statutory duties.

Recommend amending policy GP/HA to align with statutory wording and the NPPF approach, advocating for more proportionate language that allows for a comprehensive assessment of impacts on heritage significance.

Brookgate Land Ltd and Network Rail Infrastructure Ltd object to policy GP/HA as worded. The proposed policy wording does not allow for any harm to designated heritage assets and fails to recognise the balancing exercise required by both the National Planning Policy Framework (2024) and the Planning (Listed Buildings and Conservation Areas) Act 1990.
The statutory duties under Sections 66 and 72 of the 1990 Act require decision-makers to have special regard to the desirability of preserving the setting of listed buildings and special attention to preserving or enhancing the character or appearance of conservation areas. These duties do not impose an absolute prohibition on harm, but instead require any harm to be identified and weighed in the planning balance.
Similarly, the NPPF (2024) explicitly allows for harm to designated heritage assets where this is justified and outweighed by public benefits, through a structured assessment of significance, harm and justification. The proposed policy wording fails to reflect this approach and is therefore inconsistent with national policy and legislation.
The use of mandatory language in Part 2 of the policy - specifically the wording ‘proposals that affect designated heritage assets, including alterations and extensions, retrofit or new development must’ - overstates the statutory and policy tests and removes the necessary scope for professional judgement and balancing.
In addition, the remainder of Part 2 of the policy, particularly criteria 2(b) - 2(d), adopts a highly restrictive approach by requiring development to be of an ‘appropriate’ scale, form, height and massing. When applied to development that is inherently different in scale or character from nearby listed buildings, these criteria risk effectively precluding larger-scale or strategic development regardless of wider public benefits. This is contrary to the direction of travel set out in the draft NPPF policy, policy E3 notes the locational characteristics of logistics development which in some cases will involve particularly large structures. The policy lacks clarity as to how proposals of a different typology or scale should be assessed.
Policy GP/HA should therefore be amended to reflect the statutory wording and the NPPF approach, replacing mandatory language with more proportionate wording that allows impacts on heritage significance to be assessed in the round, taking account of scale, context and public benefits in accordance with legislation and national policy.

Policy GP/ND should be amended to reflect the NPPF’s proportionate approach and allow impacts to be assessed through balanced decision-making.

Brookgate Land Ltd and Network Rail Infrastructure Ltd object to the proposed wording of Policy GP/NP.
The policy goes beyond national planning policy by seeking to ‘ensure the retention and enhancement’ of non-designated heritage assets. The NPPF does not require retention in all circumstances, but instead requires a balanced judgement, having regard to the significance of the asset and the scale of any harm or loss. The proposed wording removes this necessary flexibility and risks precluding appropriate development regardless of context or public benefits.
Policy GP/ND should be amended to reflect the NPPF’s proportionate approach and allow impacts to be assessed through balanced decision-making.

Brookgate Land Ltd and Network Rail Infrastructure Ltd support Policy J/NE. Since the policy makes specific reference to site allocations, Brookgate Land Ltd and Network Rail Infrastructure Ltd request that the allocations be updated as set out in the supporting statement, to ensure that new employment development can be delivered in accordance with Policy J/NE.

Brookgate Land Ltd and Network Rail Infrastructure Ltd request amendments to policy J/AW to ensure that the policy does not hinder the delivery of much needed commercial development in Cambridge, in line with wider growth ambitions.
In its current format, the policy is unclear on the scale and nature of the employment floorspace this would apply to, which makes it difficult to comment on the impacts. We welcome greater clarity on the requirements for affordable workspace as the policy develops.
It is firstly noted that it is imperative that a viability clause is added in to the policy wording. This could allow for negotiated contributions and provide justification for the alternative delivery mechanisms outlined in the policy such as off-site provision, or financial payments where on-site affordable workspace is not feasible.
Furthermore, it is requested that the policy is drafted to allow developers and/or occupiers an appropriate degree of control over the delivery of affordable workspace on-site. This should allow for flexibility on the location of affordable workspace within the development, duration of occupation and form of affordable workspace. A prescriptive approach where the Council are gifted control of affordable workspace would likely lead to incompatible development. A more flexible approach however, would allow for affordable workspace to be contextual and reasonable, so as to not undermine the developers’ wider ambition.
It is also noted that at point 2b, the policy allows affordable workspace to be managed and operated by the owner where they can demonstrate the necessary skills and experience. Given the absence of existing guidance, it should be clarified how an owner would demonstrate competence to deliver affordable workspace effectively.

Brookgate Land Ltd and Network Rail Infrastructure Ltd support the requirement for affordable housing as outlined in the draft local plan.
However, it is noted that viability testing is mentioned at point 9.15 of the supporting text. Brookgate Land Ltd and Network Rail Infrastructure Ltd consider that the appropriateness of viability tested route should be explicitly mentioned within the policy wording, rather than the supporting text. This will carry greater weight in decision making rather than being perceived as guidance or an aspiration, and will provide greater clarity for developers, especially in light of the increased % requirements for medium scale sites.

Remove requirement for 5% custom build flats.
Policy should reference that self and custom build will only be required where there is a demonstrable need.

Brookgate Land Ltd and Network Rail Infrastructure Ltd object to the 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, particularly in higher-density schemes where viability and deliverability already constrained.

Brookgate Land Ltd and Network Rail Infrastructure Ltd support the policy for Build to Rent Homes in Cambridge.
As set out in Brookgate Land Ltd and Network Rail Infrastructure Ltd’s representations to the Regulation 18 consultation in 2021, we object to the imposition of rigid restrictions on development quantum as outlined in point (a). Such blanket limitations risk unnecessarily constraining appropriate and well-designed development and fail to reflect the varied context and characteristics of individual sites.
Furthermore, it is proposed to remove reference to ‘dominate’ within the policy. Not only is this inherently subjective and open to inconsistent interpretation, but it has not been proven that build to rent has any impact on the character of a wider area in which it is located. In fact, build to rent development can deliver high-quality, long-term, and stable rental alternatives. It is therefore considered that the removal of ‘dominate’ will allow proposals to be assessed on a case-by-case basis, having regard to site-specific circumstances, design quality, and demonstrable planning benefits.
To be effective, the policy should retain sufficient flexibility to respond to changing needs, market conditions, and allow for the delivery of different forms of residential development to meet housing targets.

The policy should adopt a proportionate, evidence-based and site-specific approach, consistent with national policy, to support sustainable transport objectives without undermining development viability or deliverability

Brookgate Land Ltd and Network Rail Infrastructure Ltd object to the proposed wording of Policy I/EV.
The policy would be more effective if it clearly recognised that car parking and EV charging provision must respond to the specific characteristics of individual sites. Large or complex developments often have distinct operational requirements, travel patterns and accessibility constraints that cannot be addressed through uniform or prescriptive standards.
Brookgate Land Ltd and Network Rail Infrastructure Ltd support the objective of ensuring parking provision reflects land use, location, accessibility and EV infrastructure. The policy should therefore adopt a proportionate, evidence-based and site-specific approach, consistent with national policy, to support sustainable transport objectives without undermining development viability or deliverability.

Please refer to submitted statement for a visual of safeguarded area.
It is acknowledged that the safeguarding area identified in figures 2 and 3 has been established by EWR and has undergone separate consultation with landowners. Brookgate Land Ltd has submitted comments to EWR during this consultation, highlighting that the proposed safeguarding land should align with the hybrid planning consent at Cambridge North East. Notably, the land identified for safeguarding includes areas where car parking is to be re-provided for the station in accordance with the franchise agreement. Accordingly, it is requested that the policy be drafted with sufficient flexibility to accommodate evolving EWR requirements within safeguarded areas, rather than automatically resisting development within these zones.
Furthermore, the proposed extent of the safeguarded area at Station Road West would effectively sterilise all development on the Site, a critical issue that has not been addressed within the site allocation. Similar to the above, the safeguarded area does not take into account the two planning permissions that have previously been granted on the Site. The policy should therefore be reviewed to ensure it does not place a restriction on all development in this safeguarding zone and undermine the deliverability of the allocation.