Draft Greater Cambridge Local Plan for consultation

Remove reference to CIL until this is adopted.
Request revisions to the policy to clarify that utility company objections cannot automatically prevent development and that reasonable mitigation should allow for progress

Brookgate Land Ltd and Network Rail Infrastructure Ltd object to policy I/ID as currently worded.
The policy makes continual reference to Community Infrastructure as a way to ensure that schemes are acceptable in planning terms (in addition being mentioned under Policy I/ST: Sustainable transport and connectivity and Policy: WS/NC: Meeting the needs of new and growing communities). As CIL has not been adopted in the Greater Cambridge Area, the mechanism for securing contributions via CIL does not yet exist 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 S106 agreements. This will ensure that the policy is clear, justified, and effective as outlined within the NPPF.
The policy also 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 development.
Development should not be halted solely on the basis of current capacity constraints where mitigation or phased delivery is feasible. Appropriate conditions and/or obligations should allow for capacity issues to be overcome to ensure that do not unduly restrict housing delivery or the timely delivery of development.
It is therefore requested that the policy and/or supporting text be revised to make clear that objections from utility companies cannot automatically prevent development, and that development should proceed where reasonable mitigation or planning mechanisms can address infrastructure requirements.

Brookgate Land Ltd and Network Rail Infrastructure Ltd support Policy CC/DC which sets clear, design-led criteria to ensure high-quality, sustainable and inclusive places in order to respond to the climate crisis. This aligns with Brookgate Land Ltd and Network Rail Infrastructure Ltd’s vision for Cambridge North and Station Road West, which both will be led by these guiding principles.

However, Brookgate Land Ltd and Network Rail Infrastructure Ltd wish to seek clarification on a number of points within the policy to ensure it is flexible and achievable for future developments.

At point 2 it is noted that ‘Development proposals should reflect the cooling hierarchy’. It is not considered that the cooling hierarchy would be appropriate for all forms of development and imposition of the cooling hierarchy for minor scale developments would be disproportionate, placing unnecessary burden on applicants. It is therefore requested that the policy is worded to ensure that the cooling hierarchy will apply to major developments only.

Point 3 of the policy states that ‘All new dwellings shall be designed to benefit from cross ventilation where possible.’ While the inclusion of the phrase ‘where possible’ is welcomed and introduces an appropriate degree of flexibility, the supporting text goes on to state that ‘single aspect dwellings should be avoided for all schemes as effective passive ventilation can be difficult or impossible to achieve.’

This supporting text is overly restrictive and the rigid application of dual-aspect requirements can reduce significantly the number of homes capable of being built within developments, limit density or lead to an undesirable trade-off with habitable space. The policy also does not sufficiently recognise site-specific constraints that may make cross-ventilation or dual-aspect layouts inappropriate or unachievable. In particular, the following circumstances may impact delivery of dual aspect units:
• proximity to railway lines or major roads, where openings may exacerbate noise or air quality impacts;
• heritage assets or conservation areas; and,
• constrained urban sites.

All of the above may reasonably necessitate single-aspect dwellings as part of a well-considered design solution. It is therefore requested that the policy and supporting text more clearly acknowledge that the appropriateness of cross ventilation and single-aspect dwellings should be assessed on a case-by-case basis, informed by site-specific constraints and design-led discussions, rather than applying a blanket presumption against single-aspect dwellings.

Suggest removing EUI and space heating targets to comply with NPPF 2025 draft policy PM13, as these will be addressed in the upcoming Building Regulations Part L 2025 update.
There should be flexibility in EUI targets to allow for a transitional period before 2040.
Greater flexibility at shell and core stage.

Brookgate Land Ltd and Network Rail Infrastructure Ltd object to policy CC/NZ. The policy goes above and beyond existing sustainability benchmarks without consideration for impacts on viability and deliverability. Whilst Brookgate Land Ltd and Network Rail Infrastructure Ltd welcome the ambition to ensure that all buildings help to meet zero-carbon targets, there needs to be greater flexibility within the policy wording.
Firstly, requiring net zero operational emissions at the shell and core stage is not appropriate where the future end user and operational profile are not yet known. Such a requirement risks imposing impractical obligations and may deter occupier delivery or investment.
With regard to Part A, all new dwellings and non-domestic buildings are expected to achieve a space heating demand of 15-20 kwH per meter squared per year. This figure is in line with Climate Change Committee, LETI Net Zero definition and Passivhaus standard, which are higher than other national standards and therefore placing unrealistic expectations on developers.
With regard to Part B, the EUI targets are split between uses. For residential dwellings, the targets are set at 35 kWh per meter squared per year which is aligned with LETI Net Zero definition and the National Grid Future Energy Scenarios. The policy once again goes above and beyond national standards.
It is also understood that the Building Regulations Part L 2025 update/Future Homes Standard is due to include specific EUI targets once published. As EUI targets will be published in this legislation, it is suggested they are removed to ensure that the draft policy complies with NPPF 2025 draft policy PM13 (Setting Standards) and the now withdrawn PPG 1, which states that planning policies should not replicate matters already addressed by Building Regulations.
Furthermore, the table 1in the supporting document compares the 2025 and 2040 EUI targets set out in the UK Net Zero Carbon Buildings Standard and demonstrates that the EUI requirements exceed existing targets, with no flexibility to allow dwellings to benefit from a transitional period ahead of 2040.

Finally, it is also noted that all other uses include a requirement to meet the UK Net Zero Carbon Buildings Standard 2030 targets. The pilot study published in 2025 did not include any information on EUI targets noting that these would be added once sufficient data is collected. We are therefore unable to comment on these targets without clarity on what they may be

Change the word 'must' to 'should' in order to remove mandated requirements.
Policy should not impose stricter guidelines on developments over 100 dwellings
Rainwater harvesting should be context-led
Removal of BREEAM requirements as this is not mentioned elsewhere in the plan.
Greater flexibility in the requirements of grey water in private amenity spaces.

Brookgate Land Ltd and Network Rail Infrastructure Ltd object to the proposed wording of Policy CC/WE.
The policy goes beyond national and industry guidance by effectively mandating rainwater or greywater harvesting on all major developments, which will not always be appropriate or deliverable. This is particularly the case for commercial led development, where such systems may conflict with operational requirements, site constraints, or viability. National policy promotes proportionate, context-led approaches to water efficiency.
Brookgate Land Ltd and Network Rail Infrastructure Ltd also query the use if the word ‘must’ within the policy as this creates a mandatory requirement leaving little to no discretion for decision makers. The use of the word ‘should’ outlines an expectation unless justified otherwise, which aids decision makers in reaching a balanced judgement.
With regard to potable water, the policy applies a stricter internal water-use requirement to developments of over 100 dwellings. While the aim of reducing water consumption is supported, it is unclear why development size alone justifies a higher standard. Internal water use is largely determined by occupant behaviour and individual dwelling specifications, rather than the overall scale of a development. Residents cannot reasonably be expected to use less water simply because they live in a larger scheme. As drafted, the policy risks being arbitrary and may fail the tests of justification and effectiveness. It should either apply a consistent, evidence-based standard across all residential development or provide clear evidence explaining why a higher requirement is appropriate only for larger schemes.
Furthermore, the policy requires commercial units to achieve all five BREEAM water credits (WAT 01–05), with flexibility applied only to WAT 01. In practice, achieving all BREEAM credits is often challenging and may not be feasible in all circumstances. It is also noted that the remainder of the draft Plan is largely silent on BREEAM. As drafted, the policy would therefore require all commercial developments engage with a qualified BREEAM assessor to demonstrate the credits have been achieved, irrespective of scale or complexity, resulting in additional cost. This raises concerns regarding proportionality, particularly for smaller or less complex commercial schemes.
Finally, at point 5 the draft policy requires all new dwellings with private outdoor amenity space to provide a water butt for rainwater collection or irrigation. It is requested that the policy is worded to allow for sufficient flexibility in the provision of rainwater collection in private amenity spaces. The policy should have due consideration for where other forms of water collection are proposed on Site and recognition that rainwater harvesting may impact usability of the private amenity spaces or may be entirely impractical to deliver.

Confirmation on the definition of a 'significant part'
Recognition in the policy that there may be other planning benefits that outweigh presumption in favour of retrofit.

Brookgate Land Ltd and Network Rail Infrastructure Ltd object to the proposed wording of policy CC/CE.
While Brookgate Land Ltd and Network Rail Infrastructure Ltd support the policy’s objectives and the promotion of circular economy principles, these are already embedded within Brookgate Land Ltd and Network Rail Infrastructure Ltd’s standard development approach, with embodied carbon routinely assessed through scheme design and delivery.
Further clarity is also requested on the policy wording. The policy states that proposals involving the demolition of a building, in whole or a significant part, should be accompanied by a full justification. Clarification is needed on what constitutes ‘a significant part’ to avoid ambiguity.
While the emphasis on retrofit is supported, the policy does not appear to allow for other material benefits that may outweigh the presumption in favour of repairing, refurbishing, and re-using. It is recommended that the policy acknowledges that, in certain circumstances, demolition may be acceptable where justified by wider planning benefits.
Flexibility should be added to the policy to make it clear that if the viability and deliverability of refurbishment, retrofit or reuse places considerable doubt, then demolition and redevelopment is the only realistic option for the Site.

Revert to national 10% requirement, with 20% as a 'nice to have'

The proposed requirement to uplift the mandatory minimum to 20% BNG for major development is considered unsound, as it is not adequately justified and is inconsistent with national policy. The uplift is not supported by a robust evidence base and does not sufficiently demonstrate that it is proportionate or deliverable across all sites.
The national BNG framework provides clarity and certainty for plan-making and decision-taking. Any local requirement exceeding the statutory minimum must therefore be clearly justified, flexible, and grounded in site-specific ecological capacity and viability.
Policy BG/BG risks undermining policy certainty by imposing a fixed uplift beyond the national framework without adequate justification. Any BNG delivered above the mandatory 10% requirement should be treated as a material benefit in the planning balance, rather than a fixed policy requirement.

Remove 30% requirement mandate and word the policy to allow for flexibility.

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.
Chapter 11 of the National Planning Policy Framework (2024) is clear that planning policies should promote the effective use of land in meeting the need for homes and other uses, particularly in sustainable locations. The need for making an effective use of land is further strengthened through the direction of travel set out in L2 of the draft NPPF, supporting densification.
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 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 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

Remove the requirement for a community needs assessment as this doubles up on the IDP

Brookgate Land Ltd and Network Rail Infrastructure Ltd object to policy WS/NC as currently drafted. The policy is ambiguously worded, creating uncertainty that may impose an additional and unwarranted burden on development.
Specifically, point 4 states that proposals for residential developments of 200 or more dwellings (or multiple smaller sites that cumulatively exceed this threshold), as well as employment developments over 5,000 m², 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.

Define what constitutes a cultural and creative hub, expected quantum, floorspace thresholds and relevant use classes.

Brookgate Land Ltd and Network Rail Infrastructure Ltd object to this policy as currently worded.
The policy wording is overly broad and lacks sufficient clarity, contrary to the requirements of the NPPF for policies to be clear and effective. In particular, the policy fails to define what constitutes a ‘cultural and creative hub’, providing no indication of expected quantum, floorspace thresholds, or relevant use classes.
The reliance on imprecise terminology, such as ‘a mix of cultural activities’ does not establish any meaningful or measurable criteria against which proposals can be assessed. As a result, the policy introduces a significant degree of uncertainty for both applicants and decision-makers, creating scope for inconsistent interpretation and application.

Recommended that Policy BG/EO be revised to allow open space assessments on a case-by-case basis, promoting a flexible approach that aligns with national policy.

Brookgate Land Ltd and Network Rail Infrastructure Ltd object to the proposed wording of Policy BG/EO.
The policy introduces a requirement for open space associated with commercial developments without clarity on the quantum required. The policy is insufficiently flexible and does not reflect the operational and spatial requirements of employment and commercial development.
The National Planning Policy Framework (2024), including the direction of travel set out in Policy L2 of the draft NPPF, is clear that planning policies should support economic growth and make effective use of land in sustainable locations. Applying a generic open space expectation to commercial development risks constraining efficient site layouts and reducing development capacity, contrary to national policy and the Government’s stated ambition to support growth in the commercial sectors, as set out in Policies E1–E3 of the draft NPPF.
Policy BG/EO should therefore be reconsidered to allow open space provision to be assessed on a case-by-case basis, adopting a flexible and proportionate approach that recognises the functional requirements of employment uses and aligns with national policy on effective land use, economic growth and plan deliverability.