Draft Greater Cambridge Local Plan for consultation

To ensure sustainability requirements are reflective of, and are not inconsistent, with national standards and guidance.

Policy CC/SD sets out the need for climate change mitigation and adaptation principles to be incorporated into developments.

Hill Residential in principle support Policy CC/SD but are concerned that several requirements exceed national standards, creating inconsistency with the sector agreed pathway set out in the Future Homes Hub One Plan and the Net Zero Transition Plan. Local variation should only be applied where clearly evidence based and viability tested to avoid supply chain fragmentation, increased costs, and risks to deliverability.

Policy CC/DC sets out how developments in terms of design and placemaking should mitigate against the challenge of climate change, including overheating.
Hill acknowledges the importance of new developments to be climate efficient as possible. However, the principles set out under Policy CC/DC largely replicate the principles listed under draft Policy CC/NZ. It is suggested that the two policies are combined to avoid unnecessary repetition.

It is requested that draft Policy CC/NZ is reconsidered and rewritten. Hill propose that the requirement thresholds are amended to reflect consistency with national legislation, including locally stipulated residential energy efficiency standards to not exceed national building regulations, alongside adequate considerations for developer viability to avoid unintended impacts on design quality, deliverability and overall housing supply.

Draft Policy CC/DC to be combined with draft Policy CC/NZ regarding the overlap between the set out principles and requirements.

Policy CC/NZ stipulates the levels of energy use that will be allowed for new development, how renewable energy should be used to meet that energy need, and how whole life carbon emissions (emissions associated with constructing buildings) should be considered.
Hill supports the principles set out under Policy CC/NZ, but the proposed standards significantly exceed the Future Homes Standard and effectively mandate Passivhaus level performance. There are concerns that the imposition of such high standards carries risks for design including the potential for a homogenised architectural form and vernacular, particularly in relation to elevational design and fenestration, as schemes are optimised to meet stringent performance criteria.
In addition, there are practical concerns relating to procurement, buildability, and the capacity of the construction supply chain. At present, there is a risk that materials availability and access to suitably skilled labour are insufficient to support the mainstream delivery of homes to this standard at scale. Viability is also a key consideration, as the Future Homes Hub in their report “Ready for Zero”, identifies cost uplifts in the order of 10–20%. This is significantly higher that the costs identified in the Councils’ own evidence base to support this policy and therefore further viability testing is required alongside evidence around the potential impact on affordability and whether the development industry will be able to meet these standards if the plan is adopted. In any event, inflated costs are likely to lead to delayed delivery or, in some cases, discounted or reduced housing output or reduced levels of affordable housing delivery.
Emerging policy in the consultation draft of the NPPF (published December 2025) will need to be considered, particularly PM13, which confirms that aside from accessibility, water efficiency and nationally described space standards, local plans should not address matters already covered by the Building Regulations. It is also relevant that the latest NPPF consultation proposes amendments to the Planning and Energy Act 2008 to clarify that local plans should not impose energy efficiency standards for residential development that exceed those set out in the Building Regulations. Once adopted, the revised NPPF would supersede the 2023 Written Ministerial Statement, Planning – Local Energy Efficiency Standards Update (WMS). On this basis, if PM13 is retained in its current form, draft Policy CC/NZ would be inconsistent with national policy from the point at which the new NPPF is adopted and would therefore carry only limited weight in decision-making. Draft Policy CC/NZ should conform with National Legislation.
Draft policy PM13 aside, it is acknowledged that the Planning and Energy Act 2008 and WMS do currently allow LPAs to set standards higher than the building regulations. However, the WMS also makes clear that any policy requirement exceeding Building Regulations should be found unsound at examination unless the local planning authority can demonstrate a clear, well-reasoned and robustly costed justification. In particular, the authority must show that 1) development viability is maintained, with full consideration given to impacts on housing delivery and affordability in line with the National Planning Policy Framework; and 2) any additional standards are framed as a percentage uplift against a dwelling’s Target Emissions Rate (TER), calculated using a specified version of the Standard Assessment Procedure (SAP). In this context, Hill does not consider that the approach set out in policies CC/NZ aligns with the requirements of the WMS, nor that the consequences of these policies have been adequately tested through the supporting evidence base.

The water‑stress challenges facing Cambridgeshire are acknowledged, but the proposed requirements exceed what can be delivered sustainably in the near term, given current supply‑chain capacity, cost implications and operational burdens associated with widespread on‑site recycling systems. A phased, evidence‑led approach aligned with the Future Homes Hub Water Ready pathway, using transitional measures and targeted offsetting through water utilities, would provide a more deliverable, lower‑risk route to achieving genuine water efficiency improvements. The policy also needs to provide for some flexibility where achieving the requirement is not possible for practical, viability or legal reasons.

The draft wording of Policy CC/WE para 1 is not consistent with sections 37 and 94 of the Water Industry Act 1991 (national legislation) and places the burden on developers to evidence capacity, despite the required infrastructure improvements being out of their control. It is therefore requested that the wording is deleted as it is unreasonable.
Specifically, the water efficiency threshold should be updated to be consistent for developments containing both less than and more than 100 dwellings, with water usage between 90 to 100 litres/person/day. There is no justification for differing standards. While the water stresses are acknowledged, there has been a failure of statutory authorities and water and sewerage companies to deliver appropriate infrastructure, and inconsistency with national policy will have viability and deliverability implications for all scales of development.

Removal of Part 1
Removal of Part 2a and Part 2b

Proposed updated policy wording as follows:
2. All development must demonstrate highly water efficient design, with a target water usage of no more than 90-100 litres/person/day

Policy CC/WE sets the levels of water efficiency that new developments must comply with, responding to the water supply pressures facing Greater Cambridge and the need to protect the water environment.
Para 1 requires for new development to demonstrate that there will be an adequate water supply available to serve the development.
Para 2 sets out the water efficiency thresholds to be adhered to. Of relevance, for residential development of 100 or more dwellings, water usage of no more than 80 litres/person/day and for residential development of less than 100 dwellings, water usage of between 90 to 100 litres/person/day.
The remaining parts discuss water efficiency measures to be included.
Hill recognises the issues around water stress and supports in principle the importance of new developments to include water efficiency measures. However, a significant part of the problem faced is down to a failure by the water companies and statutory authorities to plan and deliver appropriate infrastructure. The wording as proposed under para 1 places full responsibility on the developer to demonstrate sufficient capacity rather than the relevant provider. Water and sewerage companies have a legal duty under sections 37 and 94 of the Water Industry Act 1991 to "maintain, improve, and extend" their networks to meet future development needs and to effectively deal with sewage. Consequently, it is inappropriate to ask developers to evidence something that they are not legally responsible for and is out of their control.
For these reasons, the draft wording of Policy CC/WE is not considered to be consistent with national legislation. It is requested that the wording is in para 1 is deleted.
The water efficiency requirements proposed under para 2, specifically point b which requires all major residential developments of 100 or more dwellings to restrict water usage to 80 litres/person/day is considered onerous and difficult to achieve and implement in practice.
Part G of the Building Regulations sets a mandatory baseline of 125 l/p/d for new homes, but includes an optional, stricter requirement of 110 l/p/d. The proposed thresholds are therefore not consistent with national requirements, and it is requested that the proposed thresholds are amended to further align with this.
It is acknowledged that the recent consultation on Approved Document Part G “Sanitation, hot water safety and water efficiency” is unlikely to respond adequately to the acute and regionally specific water-stress risks facing Cambridgeshire. In light of this, it is proposed that the Future Homes Hub – Water Ready: A report to inform HM Government’s roadmap for water-efficient new homes (April 2024) is adopted as the more appropriate framework.
The Water Ready report sets out a phased and evidence-led pathway whereby:
• Water-stressed areas adopt a 90 litres per person per day (lpppd) standard from 2030 (to be confirmed in 2027), and a 80 lpppd standard from 2035 (to be confirmed in 2032).
• Seriously water-stressed areas adopt 90 lpppd from 2025, with any further reductions for 2030 and 2035 to be confirmed following sector collaboration and consultation in 2027 and 2032 respectively.
During these transitional periods, the report allows for enabling measures such as “water-reuse-ready” dual supply pipework and developer contributions, which may be more appropriate than mandating on-site water recycling systems prematurely. While there are examples of successful dwelling-level and communal recycling systems, widespread adoption in the near term presents significant risks, including limited supply-chain capacity, increased capital costs, and ongoing operational and maintenance burdens for occupants.
By contrast, upgrading existing local housing stock water related fixtures & fittings, through the incumbent water utility companies, using water-offsetting funds, offers a more equitable and lower-risk route to achieving water efficiency gains up to 2035.Accordingly, it is requested that a more balanced, phased approach which aligns with the Water Ready report is recognised with some flexibility around targets which exceed building regulation requirements (which is contrary to the WMS ), rather than pursuing higher specifications within compressed timeframes that may undermine deliverability and affordability. Such flexibility would allow for unusual viability pressures or legal implications to be considered.

For reasons above, the draft wording of Para 6a of Policy CC/IW is requested to be deleted.

Policy CC/IW establishes the principles for water management including ensuring proposals provide appropriate sustainable drainage systems alongside protecting and enhancing water quality.
Para 6 of Policy CC/IW concerns water quality. Specifically, part a of para 6 states that all development proposals must demonstrate there is capacity for wastewater treatment and adequate wastewater conveyancing infrastructure to serve the whole development.
Hill supports in principle the importance of forthcoming proposals to ensure and deliver appropriate water management However, the wording as proposed under Para 6a places full responsibility on the developer to demonstrate sufficient capacity rather than the relevant provider. Water and sewerage companies have a legal duty under sections 37 and 94 of the Water Industry Act 1991 to "maintain, improve, and extend" their networks to meet future development needs and to effectively deal with sewage. Consequently, it is inappropriate to ask developers to evidence something that they are not legally responsible for. The legal responsibility here is on the water companies.
For these reasons, the draft wording of Para 6 of Policy CC/IW is requested to be deleted.

It is requested that the overall principles set out under Policy CC/CE are amended to have less emphasis on the presumption of retention, with less justification required for demolition and further flexibility included to allow for demolition when appropriate.
This includes amending the draft wording under Para 2 of Policy CC/CE is updated to include the word ‘reasonable’:
“…Demolition will only be acceptable where it is demonstrated to the reasonable satisfaction of the Local Planning Authority that…”
It is further requested that the word ‘exceptional’ is removed in the wording of para 2d Policy CC/CE.
If the policy is retained, additional justification criteria should be included in Para 2 of Policy CC/CE to allow for site viability and modern building requirements, including indoor and outdoor space standards, to be considered when demolition is proposed for redevelopments, alongside allowing for higher densities. We would also propose that strategic sites are excluded from the requirements of this policy.
Further, the threshold for the requirement of circular economy statements should be amended to be consistent to those applied to energy and water strategies and underpinned by a future Part Z of the Building Regulations methodology.

Policy CC/CE sets out how development proposals should incorporate circular economy principles into schemes including for demolition and construction, and operational waste management.
Para 1 states the importance of opportunities to reduce embodied carbon. Para 2 states there will be a presumption of retention and reuse of existing buildings over demolition. Justification for demolition will only be accepted if proposals can accord with set criteria listed out under paras 2 a-c (e.g. disrepair / energy efficiency) or compliance with para 2d in terms of benefits of demolition outweighing carbon savings.
Paras 3-4 concern operational waste management with para 5 requiring the provision of circular economy statements for residential development of 150 dwellings or more.
Hill acknowledges the importance of waste minimisation. However, it is requested that in the drafting of para 2d, the word ‘exceptional’ is removed to accommodate other site considerations and viability (e.g. delivery of affordable housing and infrastructure, compliance with modern building standards or minimum amenity spaces as set out under draft policy Policy H/SS).
The conversion of non-residential buildings to residential use requires careful consideration, as such typologies often do not lend themselves to successful conversion or other material considerations such as constraints of listed building and conservation area protections.
Constraints relating to storey heights, layouts, space standards, structural systems, daylight provision, and thermal performance frequently limit viability and/or quality, with demolition therefore often representing the only feasible outcome. This is acknowledged alongside the recognised value of circularity assessments and whole life carbon assessments.
Para 2 of the policy places undue emphasis on the retention and refurbishment of existing buildings, which risks delivery of optimal development outcomes. Prioritising retention in this way can limit opportunities for effective densification and the efficient use of land, running counter to the current NPPF’s objectives to optimise development potential in well-located and sustainable locations and to support the effective reuse of previously developed land, specifically paragraphs 124, 129 and 130. It is also contrary to the draft NPPF which states in draft national decision making policy L3: achieving appropriate densities that development proposals should make efficient use of land, It goes on to say that “within this context development proposals for residential and mixed-use development within settlements should contribute to an increase in the density of the area in which they are situated. The existing character of an area should be taken into account, in accordance with policy DP3, but should not preclude development which makes the most of an area's potential.”
A presumption in favour of retention also risks introducing significant viability and deliverability challenges. Experience in London where similar policies exist, demonstrates that the evidential burden required to justify demolition can be disproportionate, increasing time, cost and risk for applicants and, in turn, reducing appetite for investment. This can result in compromised schemes that are designed around existing structures rather than delivering high-quality, policy-compliant development.
As drafted, the policy and associated exceptions do not adequately acknowledge the wider design and delivery implications of retention-led approaches. These include constraints on achieving efficient layouts, meeting internal and external space standards, delivering private outdoor amenity space, securing dual-aspect dwellings, and providing fully accessible homes. There is also uncertainty as to the willingness of Registered Providers to acquire affordable housing delivered through non-standard construction methods or with compromised layouts arising from retention.
These considerations highlight the need for a more balanced approach. While the retention and refurbishment of existing buildings clearly has a place, this should not be at the expense of proposals involving demolition and redevelopment where these would better meet the objectives of the NPPF, including optimisation of land, delivery of sustainable growth, and the provision of high-quality homes.
In relation to circularity assessments, the proposed 150-dwelling threshold appears inconsistent with other policy triggers, such as those applied to energy and water strategies. Greater alignment across policy thresholds for major schemes would be beneficial.
We also look forward to further clarity on the scope, methodology, and targets for circularity assessments, together with their relationship to whole life carbon assessment. In our view, these objectives would be most effectively delivered through the introduction of a new Part Z to the Building Regulations.
We consider that circularity requirements should be aligned with existing policy thresholds and underpinned by clear, nationally consistent methodologies, ideally through a future Part Z of the Building Regulations, to ensure assessments are deliverable, proportionate and integrated with whole‑life carbon policy

It is considered that draft Policy BG/BG needs to better align with other draft GCLP policies and housing requirements, with a requirement to achieve 10% BNG uplift consistent with national legislation. A 20% BNG uplift should be an aspirational target and only be required where sites can reasonably accommodate this, having regard to viability and other policy requirements.

Draft policy BG/BG concerns biodiversity uplift and enhancement. Para 1 requires all development to provide a minimum of 10% BNG (biodiversity net gain) against the baseline BNG value. Para 2 requires all major development to provide a minimum of 20% uplift. Para 3 outlines the requirements for offsite BNG provision where required, with the remaining parts then setting out the principles for ensuring the adequate protection of biodiversity and geodiversity
Hill recognises the importance of biodiversity protection and associated enhancement around the Greater Cambridge Area.
However, the 20% uplift required for major developments as set out under para 2 of draft policy BG/BG does not align with the direction of travel in the new draft NPPF which states local planning authorities should not be going above 10% uplift, the mandatory national requirement as set out in the Environmental Act 2021. If adopted as per the consultation draft, the 20% uplift would be inconsistent with national legislation. Further para 74-006-20240214 of the PPG states that “… plan-makers should not seek a higher percentage than the statutory objective of 10% biodiversity net gain, either on an area-wide basis or for specific allocations for development unless justified. To justify such policies, they will need to be evidenced including as to local need for a higher percentage, local opportunities for a higher percentage and any impacts on viability for development. Consideration will also need to be given to how the policy will be implemented”. It is considered that there is no justification in the evidence base as to why the plan should seek to deliver more than 10% or around the impact on viability, especially where offsite delivery and credits are required.
A proportionate approach could involve adopting the 10% national baseline, with an aspirational target towards 20%, where a site can reasonably accommodate this having regard to viability and other policy considerations. In such cases, flexibility across other planning requirements (for example, reduced operational and/or embodied carbon standards and/or urban greening factors (see below) could be considered to help maintain viability. Alternatively, an offsetting mechanism above the 10% threshold could be used to support local nature assets; however, it should be recognised that this additional cost would inevitably have implications for development viability.
In tandem with other policy considerations set out within the draft GCLP (Policies BG/TC, BG/GI, Policy BG/EO, Policy WS/NC, and Policy H/SS), these policies in conjunction restrict opportunities for density uplift and achieving housing delivery. There are also risks for site viability to accommodate for these considerations, essential in delivering affordable housing requirements (draft policy H/AH) and infrastructure delivery (draft policy I/ID).
To maintain an appropriate balance between new homes delivery and the implementation of Biodiversity Net Gain (BNG), any local policy exceeding the national 10% requirement must carefully consider its impacts on land values, affordable housing delivery, Section 106 obligations, Community Infrastructure Levy (CIL) contributions, and overall scheme viability.

To request that the requirement to achieve a greening factor of 0.4 is more aligned with other policy requirements and reflects the feasibility of achieving green infrastructure initiatives. Specifically for the factor to be aligned with 10% Biodiversity Net Gain (BNG) requirements and introducing UGF at a lower initial target of 0.2, with scope for an aspirational target of 0.4 where a site can reasonably accommodate this having regard to viability and other policy considerations.

Policy BG/GI of draft GCLP seeks to protect and enhance green and blue infrastructure, and identifies a number of strategic green infrastructure initiatives. Para 4 specifically states that for major residential developments or residential led developments, proposals must meet a minimum Greening Factor of 0.4. Where this cannot be met on site, offsite opportunities will be explored.
Hill supports in principle initiatives to improve the green infrastructure network around the Greater Cambridge Area. However, it is considered that achieving a greening factor of 0.4 compromises the ability to deliver viable developments when balanced against other policy requirements as set out in the draft GCLP ,namely Policy BG/BG, Policy BC/TC Policy BG/EO, Policy WS/NC, and Policy H/SS. These restrict opportunities for density uplift and delivery of housing supply.
There are also risks for site viability to accommodate for these considerations, essential in delivering affordable housing requirements (draft policy H/AH) and infrastructure delivery (draft policy I/ID). No assessment around the cost or impact on developable area and viability of the proposed policy seems to have been provided in the evidence base and therefore it cannot be justified at this time.
Further, it is considered that draft Policy BG/GI needs to better align with other draft GCLP policies and housing requirements, in order to ensure that the initiatives are implemented.
Clarification is also requested towards the definition of urban greening and whether this refers directly to the Urban Greening Factor (UGF) as set out in the London Plan.
In this context, we respectfully request that any approach to urban greening is proportionate and balanced. Specifically, we suggest aligning Urban Greening Factor (UGF) requirements with a 10% Biodiversity Net Gain (BNG) ceiling and introducing UGF at a lower initial target, such as 0.2. A proportionate approach could involve adopting a factor of 0.2 with an aspirational target of 0.4 where a site can reasonably accommodate this having regard to viability and other policy considerations.

It is considered that draft Policy BG/TC needs to better align with other draft GCLP policies and housing requirements, in order to ensure that the initiatives are implemented. Additional flexibility is also requested to para 2, recognising the impact that such a high level of tree cover could have on density and housing quantum, viability and balancing for blue grey infrastructure delivery.

Policy BG/TC of the draft GCLP seeks to improve tree canopy cover and afford protection for existing trees with criteria set out for proposals to refer to for aboricultural considerations.
Amongst other things, the policy requires that major developments achieve a future tree canopy cover of at least 30%, demonstrated through a Tree Canopy Cover Assessment. Lower percentages may be agreed with the Local Planning Authority if justified by ecological, historical, landscape, or operational reasons. It is considered that these exceptions should also include reduced density and housing quantum, viability and balancing for blue grey infrastructure delivery.
Hill supports in principle the protection of existing trees and initiatives to promote further planting. However, it is considered that the requirement to provide a minimum of 30% tree canopy cover is too onerous and is based on a recommendation by the Woodland Trust rather than a statutory target. Such a requirement would be difficult to deliver when balancing other site-specific constraints and considerations. This particularly applies for previously developed brownfield sites in more urban locations where higher densities of development are directed in the settlement hierarchy, and often required to achieve site viability. It is noted that the tree canopy cover assessment is also not yet finalised and neither the policy nor the supporting evidence clearly explains how tree canopy cover is to be measured. Specifically, it is not clear whether it refers solely to future tree canopy or whether it also includes other landscape or green infrastructure elements such as hedgerows, scrub, structural planting, green walls or green roofs. This distinction is important and requires clarification.
In tandem with other policy considerations set out within draft GCLP (Policies BG/BG, BG/GI, Policy BG/EO, Policy WS/NC, and Policy H/SS), this restricts opportunities for density uplift and delivery of housing supply. There are also risks for site viability to accommodate these considerations; essential in delivering affordable housing requirements (draft policy H/AH) and infrastructure delivery (draft policy I/ID).

Given that Greater Cambridge currently has an estimated baseline tree canopy cover of approximately 13.5%, it would be more appropriate to adopt a phased “staircase” approach, with incremental increases every 3–5 years. This would support improved climate resilience while avoiding unintended consequences for dwelling densities and the design and adaptation of public highways, footpaths, and public realm. In addition, higher canopy targets may necessitate alternative construction approaches, such as piled foundations in place of traditional strip foundations, with associated cost and viability implications.

To request that replacement open space does not need to be in operation prior to any loss and an interim period can be allowed for to accommodate for any associated replacement, and such flexibility is introduced in the policy wording of BG/PO.

Policy BG/PO concerns the protection and provision of open space. Of relevance, para 2 stipulates the requirements for open space replacement which should be
a. located within a suitable distance of the original site having regard to the Natural England Accessible Greenspace Accessibility Standards and
b. fully available for use before the area of open space to be lost can be redeveloped.
Hill is concerned that point b of para 2 requiring replacement open space to be in operation prior to the loss of existing space does not accommodate for practicalities regarding site deliverability, construction and access. Whilst this applies to all types of development, it is particularly relevant for previously developed brownfield sites where redevelopment may need to be phased to allow for demolition if relevant, and associated implementation of green and blue infrastructure. Requiring full open space provision prior to construction and completion of building may have implications on cash flow, deliverability, site logistics and thus viability of a site.