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Draft Greater Cambridge Local Plan for consultation
Policy CC/SD: Sustainable development and the climate emergency
Representation ID: 204755
Received: 30/01/2026
Respondent: Hill
Agent: Carter Jonas
Legally compliant? No
Sound? No
Duty to co-operate? Yes
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.
Comment
Draft Greater Cambridge Local Plan for consultation
Policy CC/DC: Designing for a changing climate
Representation ID: 204757
Received: 30/01/2026
Respondent: Hill
Agent: Carter Jonas
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.
Object
Draft Greater Cambridge Local Plan for consultation
Policy CC/NZ: Net zero carbon new buildings
Representation ID: 204770
Received: 30/01/2026
Respondent: Hill
Agent: Carter Jonas
Legally compliant? No
Sound? No
Duty to co-operate? Yes
The respondent supports the principles of Policy CC/NZ but raises concerns that the proposed energy standards exceed the Future Homes Standard, effectively mandating Passivhaus performance.
Concerns are expressed regarding the risk of homogenised architectural forms due to stringent performance criteria affecting design elements like elevational design and fenestration.
Practical issues related to procurement, buildability, and the construction supply chain are highlighted, including potential shortages of materials and skilled labour.
The respondent notes that cost uplifts of 10-20% identified by the Future Homes Hub may not align with the Council's evidence base, necessitating further viability testing.
Inflated costs could lead to delayed housing delivery or reduced affordable housing output, impacting overall housing viability.
The respondent suggests that emerging policy PM13 from the NPPF draft may render Policy CC/NZ inconsistent with national policy once adopted, limiting its weight in decision-making.
While acknowledging that local planning authorities can set higher standards, the respondent argues that such policies must be justified and demonstrate maintained development viability.
The respondent believes that the approach in Policy CC/NZ does not align with the requirements of the 2023 Written Ministerial Statement, Planning – Local Energy Efficiency Standards Update and that the consequences have not been adequately tested.
Object
Draft Greater Cambridge Local Plan for consultation
Policy CC/WE: Water efficiency in new developments
Representation ID: 204777
Received: 30/01/2026
Respondent: Hill
Agent: Carter Jonas
Legally compliant? No
Sound? No
Duty to co-operate? Yes
The respondent supports inclusion of water efficiency measures in new developments but highlights responsibility for adequate water supply should not solely rest on developers; water companies have legal obligations under the Water Industry Act 1991.
The respondent requests deletion of proposed wording in para 1, arguing it is inconsistent with national legislation regarding water supply responsibilities.
The water efficiency threshold of 80 litres/person/day for developments of 100 or more dwellings is deemed onerous and inconsistent with Building Regulations.
The respondent proposes adopting the Future Homes Hub – Water Ready report as a framework for water-stressed areas.
The report suggests enabling measures during transitional periods, such as dual supply pipework, rather than mandating on-site water recycling systems, which could pose risks.
The respondent advocates for upgrading existing housing stock through water utility companies as a more feasible approach to achieving water efficiency gains by 2035.
A balanced, phased approach that considers flexibility around targets exceeding building regulation requirements is requested to avoid undermining deliverability and affordability.
Object
Draft Greater Cambridge Local Plan for consultation
Policy CC/IW: Integrated water management, sustainable drainage and water quality
Representation ID: 204780
Received: 30/01/2026
Respondent: Hill
Agent: Carter Jonas
Legally compliant? No
Sound? No
Duty to co-operate? Yes
The respondent supports the principles of water management outlined in Policy CC/IW but objects to the wording in Para 6a, which places the responsibility on developers to demonstrate wastewater treatment capacity. They argue that this responsibility lies with water and sewerage companies, as per sections 37 and 94 of the Water Industry Act 1991.
The respondent requests the deletion of the draft wording in Para 6 of Policy CC/IW, citing that it is inappropriate to require developers to evidence capacity that is legally the responsibility of water companies.
Object
Draft Greater Cambridge Local Plan for consultation
Policy CC/CE: Supporting a circular economy and sustainable resource use
Representation ID: 204796
Received: 30/01/2026
Respondent: Hill
Agent: Carter Jonas
Legally compliant? No
Sound? No
Duty to co-operate? Yes
The policy should remove the word 'exceptional' from para 2d to consider site viability and other factors such as affordable housing delivery.
Careful consideration is needed for converting non-residential buildings to residential use due to constraints that may limit viability and quality.
Para 2's emphasis on retention may hinder optimal development outcomes and contradict NPPF objectives for efficient land use and densification.
A presumption in favour of retention could create viability challenges, increasing costs and risks for applicants, thus reducing investment appetite.
The policy does not adequately address design implications of retention, impacting layout efficiency, space standards, and accessibility.
A more balanced approach is needed that allows for demolition and redevelopment to meet NPPF objectives for sustainable growth and quality housing.
The 150-dwelling threshold for circularity assessments is inconsistent with other policy triggers, suggesting a need for alignment across thresholds.
Further clarity is needed on the scope and methodology for circularity assessments and their integration with whole life carbon assessments.
Circularity requirements should align with existing policy thresholds and be supported by clear methodologies, potentially through a new Part Z of the Building Regulations.
Object
Draft Greater Cambridge Local Plan for consultation
Policy BG/BG: Biodiversity and geodiversity
Representation ID: 204800
Received: 30/01/2026
Respondent: Hill
Agent: Carter Jonas
Legally compliant? No
Sound? No
Duty to co-operate? Yes
The respondent acknowledges the importance of biodiversity protection in the Greater Cambridge Area.
The 20% uplift for major developments in para 2 of draft policy BG/BG contradicts the new draft NPPF, which mandates a maximum of 10% uplift as per the Environmental Act 2021.
The respondent cites para 74-006-20240214 of the PPG, stating that higher percentages than 10% require justification, which is lacking in the current evidence base.
A proportionate approach is suggested, adopting the 10% national baseline with an aspirational target of 20%, considering site viability and other policy factors.
The respondent warns that additional costs from exceeding the 10% threshold could impact development viability.
The interaction of various draft policies may restrict density uplift and housing delivery, affecting the viability of sites for affordable housing and infrastructure.
Any local policy exceeding the national 10% requirement must assess its impacts on land values, affordable housing delivery, and overall scheme viability.
Object
Draft Greater Cambridge Local Plan for consultation
Policy BG/GI: Green and blue infrastructure
Representation ID: 204812
Received: 30/01/2026
Respondent: Hill
Agent: Carter Jonas
Legally compliant? No
Sound? No
Duty to co-operate? Yes
The respondent supports initiatives to enhance green infrastructure but believes the minimum Greening Factor of 0.4 may hinder viable development and housing supply due to conflicts with other policies.
Concerns are raised regarding the lack of assessment on the cost and impact of the Greening Factor on site viability, particularly in relation to affordable housing and infrastructure delivery.
The respondent suggests that draft Policy BG/GI should better align with other policies in the draft GCLP to facilitate effective implementation of green initiatives.
Clarification is requested on the definition of urban greening and its relation to the Urban Greening Factor (UGF) as per the London Plan.
A recommendation is made to adopt a more proportionate approach to urban greening, proposing an initial UGF target of 0.2 with an aspirational target of 0.4, considering site viability.
Object
Draft Greater Cambridge Local Plan for consultation
Policy BG/TC: Improving tree canopy cover and the tree population
Representation ID: 204816
Received: 30/01/2026
Respondent: Hill
Agent: Carter Jonas
Legally compliant? No
Sound? No
Duty to co-operate? Yes
The respondent supports the protection of existing trees and initiatives for further planting but finds the 30% tree canopy cover requirement too onerous and not a statutory target.
Concerns are raised regarding the feasibility of achieving the 30% canopy cover on previously developed brownfield sites due to higher density development requirements.
The respondent notes that the Tree Canopy Cover Assessment is not finalised and lacks clarity on whether it includes only future tree canopy or other green infrastructure elements.
The policy may restrict opportunities for density uplift and housing supply, impacting site viability and the delivery of affordable housing and infrastructure.
The respondent suggests a phased 'staircase' approach to increase tree canopy cover incrementally every 3–5 years to improve climate resilience without negatively affecting dwelling densities.
Higher canopy targets may require alternative construction methods, which could have cost implications and affect project viability.
Object
Draft Greater Cambridge Local Plan for consultation
Policy BG/PO: Protecting open spaces
Representation ID: 204828
Received: 30/01/2026
Respondent: Hill
Agent: Carter Jonas
Legally compliant? No
Sound? No
Duty to co-operate? Yes
The respondent expresses concern regarding Policy BG/PO, specifically paragraph 2, point b, which mandates that replacement open space must be operational before the existing space is lost. They argue that this requirement does not consider practical aspects of site deliverability, particularly for brownfield sites that may require phased redevelopment.
The respondent highlights that the requirement for full open space provision prior to construction could impact cash flow, site logistics, and overall viability of development projects.