Draft Greater Cambridge Local Plan for consultation

To request that the provision of open space is consistent with other policy requirements and would better reflect the practical constraints on housing delivery and the overall developable area.

Policy BG/EO sets out the open space requirements and standards.
Hill in principle support the provision of open space with new developments. However, it is important that such provision is balanced with other policy requirements as set out in the draft GCLP, namely Policy BG/BG, BG/GI, Policy BC/TC, Policy: WS/NC Policy BG/EO and Policy H/SS, which restrict opportunities for density uplift and delivery of housing supply with overall reduction in net developable area. It is equally important that such provision if required to be delivered off site does not result in high financial contributions or risk of delay to development.

To delete para 1 in its entirety, so as to avoid repetition with other draft policies.

To request that the threshold of a full HIA submission is increased to 500 dwellings, a rapid HIA for schemes of 200-500 dwellings; and no requirement for an HIA for schemes of 200 or less dwellings.

Policy WS/HD concerns how new development can support the promotion of everyday health wellbeing and lifestyles of residents. Para 1 of the policy sets out principles new developments should incorporate to facilitate the delivery of healthy lifestyles. Para 2 sets out the thresholds for when HIAs will be needed, with full HIAs required for proposals of 100 dwellings or more or 5,000m2 of gross internal floorspace (GIA).
Hill supports the principle of new developments promoting healthy and active lifestyles. However, para 1 of Policy WS/HD relists principles that are addressed in other policies in draft GCLP linked to housing, biodiversity and green spaces.
For consistency and avoidance of replication, it is preferred that the wording in para 1 is deleted to avoid unnecessary repetition and principles which are addressed under other draft policies.
Hill does not object to the principle of HIAs as part of major developments as required by para 2. However, it is requested that the threshold for full HIAs is increased to 500 dwellings rather than 100 dwellings (to be more proportionate with the HIA requirements), with a rapid HIA for schemes of 200-500 dwellings and no requirement for a HIA for schemes of 200 or less dwellings.

COMMENT
Policy WS/IO sets out how new development will provide training, employment and supply chain opportunities to local residents and businesses through the creation and implementation of an Employment and Skills Plan. For new developments of 10 or more dwellings, schemes will be required to submit and implement an Employment and Skills Plan for the construction stage with the policy then stipulating the associated criteria of what this should include.
Hill supports in principle the initiative to create local employment opportunities through new development and construction and has a strong track record in training programmes and apprenticeships. However, it is important that the requirement for an employment and skills plan does not impact upon timescales for construction commencement and deliverability, particularly if this is important to enable site viability. -Mandatory training, apprenticeships and supply-chain commitments add administrative burden, unforeseen S106-style costs, and procurement complexity, which can be particularly difficult to deliver on smaller urban schemes with short construction programmes.
REQUESTED CHANGE
To allow for flexibility in the policy wording that construction can commence or not be halted should there be difficulties concerning the implementation of an employment and skills plan.

To clarify the threshold for “Developments of sufficient scale” as listed under paras 3 and 5 of Policy WS/NC.

To request paras 3 and 5 of Policy WS/NC are merged for conciseness and avoidance of replication.

To remove the requirement for groups of smaller sites to undertake a detailed assessment of community need.

To request the requirement to provide onsite indoor community facilities as required under para 5 of Policy WS/NC is more aligned with other policy requirements to accommodate for the feasibility in achieving housing requirements and infrastructure delivery.

Clarification is requested over future management of such facilities and assurance that it is not the responsibility of the developer to undergo the task to identify the local need and deficiency for potential future facilities.
Appropriate wording should also be included to reflect for circumstances where improvements or expansions to existing facilities within the immediate area would be more efficient than new onsite deliver

Policy WS/NC of draft GCLP seeks to ensure that new development contributes towards the delivery of new services and facilities to meet the needs of residents. The supporting text to Policy WS/NC identifies the types of services and facilities that the policy applies to, including education, libraries, health, indoor and outdoor sports facilities, and community development. Reference is included to identified and addressing needs, the provision of indoor community facilities and implementation.
Of relevance, para 3 of Policy WS/NC requires that Developments of sufficient scale to generate the need for new on-site facilities will be required to do so, unless it can be demonstrated that there would be advantages in delivering the facilities off site.
Part 4 requires residential developments of 200 dwellings or more, or collections of smaller sites that together exceed this threshold, to be informed by a detailed assessment of community needs and to incorporate strategies to address those needs.
Part 5 concerns the delivery of indoor community facilities, requiring that all housing developments will contribute towards the provision of indoor community facilities to meet the need generated by the development. Developments of sufficient scale to generate the need for new on-site facilities will be required to do so, unless it can be demonstrated that there would be advantages in off-site delivery.
Hill supports the principles behind Policy WS/NC in delivering appropriate community facilities, which are important contributors to community cohesion and place.
The wording, however, as drafted under paras 3 and 5 of Policy WS/NC concerning the delivery of onsite facilities is considered as vague and unclear when the policy requirements will be triggered. The threshold for “Developments of sufficient scale” should be defined and specified. There is also general overlap in the requirements of para 3 and 5 and for purposes of conciseness, it is requested that these are combined.
Regarding para 4, there is a lack of clarity around how the councils intend to define the geographic area within which smaller developments would be required to consider cumulative impacts, or the methodology by which such assessments would be carried out. In practice, it is unlikely that all sites within an area will be brought forward simultaneously, raising the prospect that an early scheme could be expected to assess and address infrastructure impacts in advance of later developments. This would be neither practical nor reasonable and risks conflicting with the tests for planning obligations set out in paragraph 58 of the NPPF. On this basis, Hill considers that the requirement for groups of smaller sites to undertake such assessments should be deleted.

The requirement also to provide onsite indoor community facilities as required under para 5 of Policy WS/NC when balancing against other policy requirements as set out in the draft GCLP, namely Policy BG/BG, BG/GI, Policy BC/TC, Policy BG/EO and Policy H/SS, restrict opportunities for density uplift and delivery of housing supply with a reduction in developable residential area. 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).
It is considered that para 5 of draft policy WS/NC needs to better align with other draft GCLP policies and housing requirements, in order to ensure that such provisions are actually deliverable.
It is important that smaller or medium sized sites are not required to contribute to or deliver facilities beyond their own demand, and that the requirement to provide community facilities does not compromise the speed of site delivery, for example through protracted S106/third party negotiations.
It is also noted that no clarity is provided on who adopts and funds the long term operation of such onsite community facilities. Clarification is requested.
Appropriate wording should also be included to reflect for circumstances where improvements or expansions to existing facilities within the immediate area would be more efficient than new onsite delivery.

To amend the policy wording to include for affordable viability adjustment mechanisms and flexibility to depart from the specified tenure split in appropriate site specific circumstances where an alternative mix can be robustly evidenced and justified.

To allow for policy consideration for clustering of affordable dwellings from a management and maintenance perspective.

Policy H/AH sets out the minimum affordable housing delivery requirements as well as specifying the tenures of affordable housing required to address identified needs.

Hill recognise the importance of affordable housing delivery; however, it is considered that the policy does not include broad viability adjustment mechanisms, except for very narrow exemptions (vacant building credit, Build to Rent, C2 uses). It is requested that further flexibility is provided in the policy wording to allow for considerations to market volatility, build cost inflation or local constraints.

Further, the proposed affordable housing policy has evolved to introduce more prescriptive requirements, particularly in relation to tenure mix on developments of more than 15 dwellings. The policy now requires such schemes to deliver 65% affordable rent, 10% social rent and 25% shared ownership (or other affordable tenures that provide a route to home ownership). As currently drafted, the policy provides no flexibility to depart from the specified tenure split where an alternative mix could be robustly evidenced and justified. In practice, it is common for tenure mixes on larger, more complex/strategic sites to evolve as proposals are refined, often through the preparation of a bespoke, site-wide housing strategy submitted alongside a planning application. Such an approach provides a more effective and responsive mechanism for determining an appropriate affordable housing mix, reflecting site-specific circumstances and identified needs.

It is also requested that regarding the criteria raised in relation to clustering acknowledges for considerations of efficient management of affordable homes in clusters; cost effective maintenance and reduced service charge burden.

To request that the minimum external amenity space requirements are more aligned with other policy requirements and consideration is given to site feasibility and viability in the application of the policy. It is requested that additional policy wording to allow for viability adjustment mechanisms and flexibility in the application of the policy is included in Part 6 of Policy H/SS to depart from the specified standards in appropriate site specific circumstances where such deviations can be robustly evidenced and justified.

It is requested that a maximum cap is included on the total number of affordable M4(3) units on schemes which deliver more than 40% affordable housing, with the M4(3) requirement based on the policy compliant affordable housing position of 40%.
It is requested that a maximum cap is included on the total number of M4(3) market units to be delivered with a maximum cap introduced for schemes of 200 or more dwellings with the M4(3) market requirement only applying to the first 200 dwellings.

Policy H/SS sets out the required standards for internal spaces within new homes, the proportion of accessible and adaptable dwellings to be provided, and the required standards for external private and shared amenity space. Paras 1 and 2 concerns internal residential space standards. Paras 3 and 4 stipulate external residential space standards that should be met or exceeded. This includes for new build, conversions and change of use with houses (irrespective of the number of bedrooms) to provide a minimum of 30 sqm; ground floor apartments (irrespective of the number of bedrooms) to provide a minimum of 10 sqm; and upper floor apartments to have a minimum of 5 sqm, with an additional 1 sqm for each additional bedspace.


Para 5 sets out the design principles for external amenity spaces to adhere to including the encouragement of semi-inset or inset balconies. Para 6 outlines exemptions for provision of private external amenity space. Paras 7-9 concerns accessible and adaptable homes requiring all new residential buildings to be built to M4(2) standard and for development proposals providing 20 or more new build dwellings, 10% of the affordable units and 5% of the market units to be to M4(3) standard.


Hill supports in principle the need to deliver high standards of amenity and accessibility in new homes.

Paras 1 and 2 reference and replicate the NDSS; these continue the application of such standards and the repetition provided by Policy H/SS is unnecessary and should be removed.
The requirements under paras 3 and 4 for the stipulated minimum external residential space standards when balancing against other policy requirements as set out in the draft GCLP, namely Policy BG/BG, BG/GI, Policy BC/TC, Policy BG/EO, and Policy WS/NC may constraint site opportunities. This is particularly relevant for density uplift and delivery of housing; varied sized balconies depending on the quantum of bedrooms add to design complexities including stacking and incurring further costs in construction. To accommodate for the balconies of required size and depth, unit width will need to be increased which may then reduce the number of units per floor; increase circulation area; add extra cores to meet access distances; and increase building footprint or height.

Similarly to paras 7-9 regarding the delivery of required M4(3) units, there may be 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).
It is considered that draft Policy H/SS needs to better align with other draft GCLP policies and housing requirements, in order to ensure that such housing space standards are feasibly deliverable. It is requested that additional policy wording is included to address the external standards stipulated by H/SS to include for viability adjustment mechanisms and flexibility to depart from the specified standards in appropriate site specific circumstances where such deviations can be robustly evidenced and justified.
It is also requested that wording is added to Policy H/SS to allow for a maximum cap on the total number of M4(3) affordable units to be delivered. The draft Policy requires 10% of all affordable units to be provided as M4(3). This is to accommodate developments which may be providing 100% affordable housing and/or where a need for such quantity of M4(3) units would be unnecessary (e.g due to RP preferences/demand). It is suggested that if schemes deliver more than 40% affordable housing, the M4(3) requirement is capped and the number based on the policy compliant affordable housing position.
It is also requested that a maximum cap is included on the total number of M4(3) market units to be delivered. The draft Policy requires that 5% of all market units to be provided as M4(3) units. Such M4(3) market provision is considered unnecessary. The Housing Needs of Specific Groups report shows that the overall need for M4(3) homes is quite low, with 968 units needed across Greater Cambridge. The proposed 5% requirement would result in an excess requirement and a risk that developments have specialist housing which would be difficult to sell. It is suggested therefore that a maximum cap is introduced for schemes of 200 or more dwellings with the M4(3) market requirement only applying to the first 200 dwellings.

To request that the minimum threshold trigger for delivery of self/custom build plots is increased and greater flexibility added to allow a lower proportion of self and custom build homes where there is evidence that there is limited demand or it would not support good placemaking. It is proposed that the 5% threshold trigger should only be applied to schemes containing a minimum of 100 dwellings and should be capped so that it would only apply to the first 500 dwellings. The minimum 12-month marketing period before unused plots can revert to developer delivery should be reduced to six months.

Policy H/CB concerns self and custom build home delivery in Greater Cambridge. Para 1 requires that developments of 20 or more dwellings must provide at least 5% of the new homes as serviced plots for custom and self build houses and/or serviced custom-build flats. Unless specified all custom and self build plots will be classified as market housing as stated under para 2. Para 3 sets out the marketing criteria for custom and self build plots.

Hill requests that there is more flexibility in this provision where it can be demonstrated that there is limited demand and/or it would not support good placemaking. Hill also considers that there is scope for the 5% threshold trigger of 20 dwellings to be increased.

Self/custom buildings reduce the ability to design optimised layouts with standardised unit widths, depths and typologies, resulting in lower densities and reduced overall yield; the servicing of irregular plot shapes or standalone plots incurs further costs. When balanced against other policy requirements as set out in the draft GCLP, (namely Policy BG/BG, BG/GI, Policy BC/TC, Policy BG/EO, and Policy WS/NC) the policy requirement may constrain site opportunities. This is relevant for density uplift and delivery of housing, especially on larger schemes where such levels would result in the requirement to plan for a significant number of self-build/custom homes (for example 150 on a 3000 home scheme), leading to the wrong design and density outcomes. There is also no evidence of demand for this level of custom/self build homes on a single scheme. We have found that there is not a demand for self/custom build plots on large housebuilder led schemes.

Paragraph 61 of the NPPF (2024) is clear in its wording that while the needs of groups with specific housing requirements should be addressed, the overall aim is to meet an area’s identified housing need.
Paragraph 129 of the NPPF (2024) notes that planning policies should support development that makes efficient use of land. As outlined above, there are concerns that an oversupply of self-build/custom builds would result, thereby affecting overall site densities and design/placemaking, and issues with delivery of housing supply.

The draft NPPF further states in draft national decision making policy L3: achieving appropriate densities that:
Development proposals should make efficient use of land,
2. 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.

The requirement for minimum self build plot provision would affect the ability for sites to maximise efficient use and density of land, contrary to Policy L3’s requirements.

Moreover, self/custom build plots typically deliver more slowly than developer built units, causing delays in build out rates, sales receipts and s106/CIL trigger points. They also create difficulties around logistics, with self-builders developing alongside main contractors. The minimum 12 month marketing period before unused plots can revert to developer delivery is a significant delay on build programmes for sites needing timely delivery. This includes the need for bespoke legal agreements, plot passports, boundary definitions and management arrangements for self/custom build plots, causing higher legal and administrative overheads.

To update the wording of para 2h of Policy I/EV to accommodate cycle parking design requirements for alternative residential typologies.

To clarify the type of non-standard cycle parking provision to be provided for in developments as required under Para 3 of Policy I/EV. To also include a development quantum threshold for such provision and specify a fixed percentage provision for the overall non-standard cycle parking provision.

To clarify the threshold for large scale major sites and associated requirement for a site wide electric vehicle charging strategy as requested by para 6 of Policy I/EV.

Policy I/EV sets out the requirements for cycle and vehicle parking. Amongst other things, para 2 concerns cycle parking and sets out associated design principles listed in paras 2a-i. Para 2h states that cycle parking for residential development is to be located in a purpose-built area at the front of the house or within a garage.
Para 3 of Policy I/EV states that at least 5-10% of cycle parking provision must be designed to accommodate nonstandard cycles and should consider appropriate provision for electric charging points.

Para 4 sets out cycle parking standards, with Para 5 confirming disabled parking provision and associated design principles. Para 6 then requires the submission of a site-wide Electric Vehicle charging strategy for large-scale major sites.

The wording as currently stated in para 2h does not accommodate provision in different types of residential dwellings, for example flats or maisonettes, where cycle parking will not be able to be provided in a garage or to the front of a house. It is therefore requested that this is updated to reflect requirements for alternative housing typologies.

The requirement under Para 3 to provide at least 5-10% of non-standard cycle parking is non-specific and does not provide sufficient flexibility for minor developments where such provision is unlikely to be required, nor necessarily feasible to deliver. The wording should be updated to include a threshold for the requirement to non-standard cycle parking provision. The 5-10% range is also regarded as vague and should be clarified. Further, non-standard cycle parking should be defined to specifically reference the alternative cycle parking to be accommodated, such as cargo or electric bike provision.

Para 6 does not specify the threshold for large scale major developments and it is unclear the threshold requirement for the submission of a site wide electric vehicle charging strategy. A defined threshold should be specified.

The wording as proposed under para 3 of Policy I/ID places full responsibility on the developer to demonstrate sufficient capacity rather than the relevant provider. Consequently, it is inappropriate to ask developers to evidence and/or provide sufficient infrastructure capacity that they are not legally responsible for.
For these reasons, the draft wording of para 3 of Policy I/ID is requested to be deleted.

Policy I/ID seeks to ensure there is sufficient infrastructure capacity to support and meet all the requirements arising from the new development, and its associated phasing. Para 1 outlines that proposals will need to make appropriate arrangements for infrastructure improvement and provision. Para 2 outlines infrastructure phasing requirements. Para 3 states the need for proposals to demonstrate sufficient capacity with parts 4 and 5 expanding upon this further. Para 6 confirms the requirements for the submission of a utilities statement.


Hill recognises the importance of infrastructure delivery where this is necessary to support development. The wording under para 3 of Policy I/ID as inserted below:

Proposals for new development will be required to demonstrate adequate capacity exists or can be secured both on and off site to serve the development

It is requested that the wording under para 3 of Policy I/ID is amended to ensure liability is not solely placed on a developer to address all infrastructure deficiencies in an area created by historic failures to deliver, as this would be unreasonable. Any infrastructure requirements should be directly related to the impact of the proposed development. This reflects concerns raised under draft Policy CC/WE.

The wording as proposed under para 6 of Policy I/CM places full responsibility on the developer to demonstrate sufficient capacity rather than the relevant provider. Consequently, it is inappropriate to ask developers to evidence and/or provide sufficient infrastructure capacity that they are not legally responsible for.
For these reasons, the draft wording of para 6 of Policy I/CM is requested to be deleted.

Policy I/CM sets out how developments should contribute to Greater Cambridge’s access to broadband, telecommunication infrastructure and smart infrastructure.
For telecommunications infrastructure, para 6 requires for schemes of 30 or more dwellings to include suitable infrastructure that would support any future rollout of appropriate telecommunications equipment such as small cell mobile communications technology or mobile masts and towers.
Hill do not object to the principle of the policy but request the wording is updated to ensure full responsibility is not placed on the developer to provide the infrastructure that should reasonably be expected to be delivered by a third party or statutory undertaker and/or would be out of the developer’s control.