Draft Greater Cambridge Local Plan for consultation

Comment

Representation ID: 211274

Received: 29/01/2026

Respondent: Woolsington One Ltd

Agent: Claremont Planning Consultancy

Policy S/JH of the Draft Plan identifies that the Councils are planning to deliver a minimum of
48,195 new dwellings across the Plan period from 2024-2045. Part 1b of the Policy identifies that
this overall housing requirement figure includes the provision of affordable housing, and specialist
accommodation to meet the needs of specific groups such as Gypsies, Travellers, Travelling
Showpeople, looked after children, boat dwellers, older people, students, and those with
disabilities.

Comment

Representation ID: 211275

Received: 29/01/2026

Respondent: Woolsington One Ltd

Agent: Claremont Planning Consultancy

It is notable that the housing requirement identified by Policy S/JH of the Draft Plan includes the
provision of specialist housing accommodation. It is acknowledged that Paragraph 61 of the
Framework advises that the housing needs of specific groups are taken into consideration when
planning for the delivery of new homes. Policy S/JH of the Draft Plan however identifies that the
housing needs of specific groups are accounted for within the overall housing requirement of 48,195 dwellings. As set out above, the proposed housing requirement falls short of the
Government’s standard method requirement, the calculation of which does not evidence how it
has included consideration of the housing needs of specific groups, such as older people and
boat dwellings. The Draft Plan is not accompanied by a Housing and Economic Needs
Assessment, such that no evidence is provided identify how the housing needs of specific groups
have been calculated, or the implication of this on the overall housing requirement for the Plan.

Comment

Representation ID: 211276

Received: 29/01/2026

Respondent: Woolsington One Ltd

Agent: Claremont Planning Consultancy

It is considered that the proposed development strategy fundamentally conflicts with the strategic
priority relating to wellbeing and inclusion. The wellbeing and inclusion strategic priority identifies
the Council’s intention to ensure that ‘everyone benefits from the development of new homes and
jobs’. However, it is evident that this priority will not be achieved through the implementation of
the proposed spatial strategy whereby the vast majority of growth is proposed to be located within
the area between the A11 and A14. Figure 8 of the Draft Plan (reproduced below) illustrates how
a significant proportion of the region will not benefit from any jobs or employment growth,
demonstrating that the rural area of the region will not see the benefits of new development.

Comment

Representation ID: 211277

Received: 29/01/2026

Respondent: Woolsington One Ltd

Agent: Claremont Planning Consultancy

With regards to new development at the Minor Rural Centres, such as Cottenham, draft Policy
S/SH identifies that residential development and redevelopment up to an indicative maximum
scheme size of 30 dwellings will be permitted within the defined development extents. The
proposed restriction in the size of new developments and requirement for these to be located
within the defined development extents is objected to. It is notable that Appendix D of the Draft
Local Plan identifies housing requirements for neighbourhood areas within Greater Cambridge,
with a housing requirement of 130 dwellings identified to be delivered at Cottenham between
2024-2045. However, it is unclear how the Councils envisage this number of dwellings being
delivered at the settlement, if the size and location of new developments at Cottenham are
proposed to be restricted to a maximum of 30 dwellings located within defined development
extents. The draft Policies Map which is published for consultation alongside the Draft Local Plan
identifies the defined development extent for Cottenham as being drawn tightly around existing
development at the settlement, such that there no obvious development opportunities within the
defined developed extent that would be sufficient, either on their own or cumulatively, to deliver
the 130 dwelling neighbourhood area requirement identified by the Draft Plan.

Comment

Representation ID: 211278

Received: 29/01/2026

Respondent: Woolsington One Ltd

Agent: Claremont Planning Consultancy

Policy S/DE of the Draft Local Plan seeks to establish that development outside of the defined
development extents will not be permitted unless it comprises a made Neighbourhood Plan
allocation; a Rural Exception Site; or development for agriculture or other uses which need to be
located in the countryside. In keeping with the approach advised within Section 4.3 of these
representations above, it is considered that the policy approach to development outside the
defined development extents should be relaxed to facilitate the development of land located
outside, but adjacent to, the defined development extents for housing where this is required to
meet an identified neighbourhood area housing requirement. As set out above, this amendment
to the draft policy text is considered necessary to facilitate the effective implementation of the
local plan strategy in the event that the neighbourhood area housing requirements are not
proposed to be provided for by new or reviewed Neighbourhood Plans. Woolsington One Ltd’s
promoted site located to the west of Broad Lane, Cottenham represents a suitable, available, and
deliverable site that is located adjacent to the defined development extent which could come
forward for development in the early years of the Plan period and contribute towards meeting the
neighbourhood area housing requirement for Cottenham of 130 dwellings.

Comment

Representation ID: 211279

Received: 29/01/2026

Respondent: Woolsington One Ltd

Agent: Claremont Planning Consultancy

Part 3 of the Draft Plan sets out the proposed site allocations, and vision for the ‘rest of the rural
area’. Section 3.5.1 of the Draft Plan establishes that the Councils are seeking to support the
vitality of the rural settlements in the region, however that there is an aspiration to ensure that
‘lots of new homes’ are not delivered in locations where car travel is the easiest or only way to
travel such that development within the rural area is proposed to be concentrated in and around
the villages that benefit from good transport links and other services.

Comment

Representation ID: 211280

Received: 29/01/2026

Respondent: Woolsington One Ltd

Agent: Claremont Planning Consultancy

Policy CC/SD of the Draft Local Plan proposes to require that all new development proposals
demonstrate and embed the principles of climate change mitigation and adaptation into the
development. Schemes will be required to demonstrate how this has been achieved through the
submission of a Sustainability Statement, with the level of detail provided to be proportionate to
the scale of the development. Draft Policy CC/SD is supported insofar as it reflects the aspirations
of Paragraph 162 of the Framework which establishes that Local Plans should take a proactive
approach to mitigating and adapting to climate change. However, the draft Policy text is
considered to be ambiguous in its current format, whereby the measures that the Councils are
expecting developments to implement are not identified. To ensure that this policy is capable of
being implemented as intended, it is considered essential that a supplementary planning
document is prepared to provide clarification of the climate change mitigation and adaptation
measures that the Council is seeking from new developments. This is necessary to ensure that
the Policy satisfies the requirements of Paragraph 16 of the Framework which requires policies
to be clearly written and unambiguous so that it is evident how a decision maker should react to
the proposals.

Comment

Representation ID: 211281

Received: 29/01/2026

Respondent: Woolsington One Ltd

Agent: Claremont Planning Consultancy

Draft Policy CC/NZ seeks to require that, where appropriate, new development must achieve net
zero operational emissions, which is required to be demonstrated through the submission of an
appropriate energy assessment. This requirement is strongly objected to. Whilst the UK’s legally
binding requirement to achieve net zero carbon by 2050 is recognised; it is considered that the
proposed requirement for new development to achieve net zero operational carbon emissions far
exceeds current building regulations requirements. It should be recognised that the UK is currently
in the process of transitioning towards net zero carbon, through the implementation of the Future
Homes Standard which will require new dwellings to be designed to be ‘zero carbon ready’, rather
than net zero carbon as is proposed by the emerging Local Plan. The Councils are respectfully
reminded of the Written Ministerial Statement made in December 2023 by Baroness Pen1
established that any planning policies which propose local energy efficiency standards for
buildings that go beyond current or planned building regulations should be rejected at examination
if
they do not provide a well-reasoned and robustly costed rationale which ensures that
development remains viable

Comment

Representation ID: 211282

Received: 29/01/2026

Respondent: Woolsington One Ltd

Agent: Claremont Planning Consultancy

Policy CC/WE of the Draft Plan proposed to apply enhanced water efficiency requirements for
new developments. Developments of 100 or more dwelling are proposed to be required to achieve
water usage of no more than 80 litres/person/day, whilst schemes of less than 100 dwellings will
be required to restrict water usage of between 90-100 litres/person/day. The proposed water
efficiency standards far exceed those that are required to be met through building regulations,
and even exceed the revised Water Efficiency Standard of 125 litres/person/day that was
consulted on by the Government in December 2025. The Government’s proposed revisions to
the Water Efficiency Standard are being undertaken in consultation with DEFRA and has been
informed by independent research regarding the infrastructure that needs to be in place to enable
the tighter water efficiency standards that the Government is consulting on to be achieved. It is
notable that the Government’s target is to achieve a reduction in water use to 110 litres/person/per
day by 2050. In light of this national target, it is unclear how the Council considers that the
achievement of a water efficiency target 30 litres below the proposed national 2050 target will be
achievable. The evidence base accompanying the Draft Plan does not address the viability, of
feasibility of achieving these enhanced standards.

Comment

Representation ID: 211283

Received: 29/01/2026

Respondent: Woolsington One Ltd

Agent: Claremont Planning Consultancy

Draft Policy BG/BG proposes that major development proposals in Greater Cambridge must
provide a minimum 20% net gain in biodiversity, representing a 10% uplift against the statutory
requirement which is not supported. The Planning Practice Guidance (PPG) Paragraph 006
(Reference ID: 74-006-20240214) establishes that plan-makers should not seek a higher
percentage of net gain than the statutory objective unless the uplifted requirement is justified with
regards to the local need for a higher percentage, identification of opportunities for a higher
percentage, and any impacts of this on the viability of development. Whilst the evidence base
supporting the Draft Plan identifies opportunity for green infrastructure provision (Greater
Cambridge Green Infrastructure Mapping Baseline Report 2020); the Councils’ justification of the
need for the uplifted net gain requirement is wholly reliant upon the Cambridgeshire Doubling
Nature Vision. This document is not considered to represent an appropriate piece of evidence on
which to base the justification for the uplifted net gain requirement proposed, as this document
presents a vision for doubling nature, rather than an assessment of the locally specific need for
implementing uplifted net gain requirements. Additionally, the evidence base supporting the draft
Policy does not include consideration of the viability implications for major developments to apply
the proposed 20% net gain requirement.