Draft Greater Cambridge Local Plan for consultation

The policy’s aims for managing river and tidal flood risk are supported, but its application to surface water flooding is often overly precautionary and unclear. National policy confirms that the Sequential Test is not required where a site-specific Flood Risk Assessment shows negligible or manageable risk. Policy CC/FM should therefore align more clearly with the NPPF, as applying the Sequential Test to all surface water flood risk sites places a disproportionate burden on small and windfall developments.

The objective to enhance biodiversity is supported, but a blanket 20% biodiversity net gain requirement is considered disproportionate for small and medium-sized sites. Small, constrained urban and brownfield sites face practical and viability challenges, risking reduced delivery. A scaled approach is recommended, with exemptions for sites under 0.2 hectares, 10% net gain for sites between 0.2 and 1 hectare in line with national policy, and 20% reserved for sites over 1 hectare, maintaining biodiversity outcomes while supporting site viability.

A scaled approach is recommended: 10% for 10 to 15 dwellings, 20% for 16 to 25 dwellings and 30% for 26 to 30 dwellings. This would improve viability, certainty and housing delivery while still securing affordable homes.

The need for affordable housing is recognised, but a fixed 40% requirement is often unviable for small and medium-sized schemes delivered by SME developers. While suitable for large strategic sites, it creates a delivery gap for schemes of 10 to 30 dwellings, leading to stalled sites or protracted viability negotiations.

The policy’s support for sustainable travel is welcomed, and cycling is recognised as central to Cambridge’s character. However, concern is raised about the expectation for cycle stores to be located at the front of every dwelling. This can be impractical or harmful in constrained urban sites, conservation areas, or where better access exists from the side or rear. The requirement is therefore considered overly restrictive, and it is recommended that greater flexibility is allowed, with cycle storage assessed on a case-by-case basis based on convenience and context.

The restriction of garden land subdivision to framework-only sites is disappointing. Experience shows that subdividing long-established garden land just outside frameworks has supported self-build and small-scale housing without relying on greenfield sites.

We therefore suggest that the policy is reworded to formally define and support this form of sustainable brownfield development in the countryside for example:
Proposals for the reuse of buildings in the countryside for residential use will be supported where:
a.
The existing building is, or would be, eligible for conversion to residential use under Class Q of the General Permitted Development Order (or any successor legislation), or where a realistic fallback position can be demonstrated;
b.
The proposal relates to previously developed land and does not result in the unjustified extension of development into the open countryside;
c.
The scale, massing and overall footprint of the proposed development are comparable to the existing building, or to that which could be delivered under Class Q;
d.
The design delivers a higher-quality and more attractive outcome than the conversion of the existing building;
e.
The proposal results in an improved relationship with the surrounding landscape and enhances the visual appearance of the site within its rural context; and
f.
The development complies with all other relevant policies of the Development Plan.

Over the years, we have worked on a number of agricultural barn conversions that meet the criteria of Class Q of the General Permitted Development Order (GPDO) 2015, some of which can provide attractive opportunities for small developers. However, we frequently encounter large portal-frame barns with extensive footprints that are poorly suited to residential use. Their deep floor plans and utilitarian form rarely result in a high-quality or attractive appearance within the countryside.

On several occasions, we have worked collaboratively with the Council to develop more appropriate and visually appealing schemes by relying on what is commonly referred to as a “fallback position”. This typically involves securing Class Q approval based on the existing footprint, while proposing a more sympathetic, agriculturally inspired building form that responds more positively to its rural context.

While this approach is often supported in principle, it is frequently treated as a departure from policy. This is largely because the existing policy is out of date and conflicts with the provisions of Class Q. The proposed policy appears to replicate this issue and therefore requires reconsideration.

We support many of the Draft Local Plan’s strategic objectives, including meeting housing need, addressing climate change and enhancing the environment. However, our representation focuses specifically on residential development delivered by SME developers on windfall sites, small brownfield sites and sensitive urban redevelopment within existing sustainable locations, which can often be delivered more quickly and sustainably than larger strategic sites.

The national decline in SME developers is well documented and evident locally, with several established local companies we have worked with having ceased trading in recent years. While this reflects a range of economic and regulatory pressures, the Local Plan presents a valuable opportunity to improve the deliverability of small and brownfield sites and to better support SME developers, who remain critical to housing delivery and urban regeneration.

This position is supported by national policy, with the Government noting that smaller firms provide local jobs and train eight out of ten construction apprentices yet have seen their market share fall significantly to larger developers.

Set out below are our comments on specific policies where targeted refinements could materially improve the deliverability of small sites and better support SME development.

The Local Plan should emphasise that reports and initial information requirements must be proportionate to the scale of development. Requiring excessive technical reports at an early stage can be costly and high risk for SME developers, potentially discouraging the delivery of small sites. Where detailed information is necessary, it should be limited to what is reasonable and, where possible, secured through planning conditions rather than required at the point of submission.

We trust that these comments will be given due consideration and would be pleased to engage further with Greater Cambridge Shared Planning on the issues raised.

We support many of the Draft Local Plan’s strategic objectives, including meeting housing need, addressing climate change and enhancing the environment. However, our representation focuses specifically on residential development delivered by SME developers on windfall sites, small brownfield sites and sensitive urban redevelopment within existing sustainable locations, which can often be delivered more quickly and sustainably than larger strategic sites.

The national decline in SME developers is well documented and evident locally, with several established local companies we have worked with having ceased trading in recent years. While this reflects a range of economic and regulatory pressures, the Local Plan presents a valuable opportunity to improve the deliverability of small and brownfield sites and to better support SME developers, who remain critical to housing delivery and urban regeneration.

This position is supported by national policy, with the Government noting that smaller firms provide local jobs and train eight out of ten construction apprentices yet have seen their market share fall significantly to larger developers.

Set out below are our comments on specific policies where targeted refinements could materially improve the deliverability of small sites and better support SME development.

The Local Plan should emphasise that reports and initial information requirements must be proportionate to the scale of development. Requiring excessive technical reports at an early stage can be costly and high risk for SME developers, potentially discouraging the delivery of small sites. Where detailed information is necessary, it should be limited to what is reasonable and, where possible, secured through planning conditions rather than required at the point of submission.

We trust that these comments will be given due consideration and would be pleased to engage further with Greater Cambridge Shared Planning on the issues raised.