Draft Greater Cambridge Local Plan for consultation

Comment

Representation ID: 211284

Received: 29/01/2026

Respondent: Woolsington One Ltd

Agent: Claremont Planning Consultancy

It is considered that the provisions of draft Policy BG/GI of the Draft Plan conflict with the proposed
requirements of Policy BG/BG through identification that, in addition to the biodiversity net gain
requirements identified, all major residential developments must meet a minimum Greening
Factor of 0.4. This would require major residential developments to achieve at least 40% green
space provision. Whilst the application of a Greening Factor of 0.4 is consistent with Natural
England guidelines, it should be acknowledged within the policy text that this is an aspirational
target to be achieved where possible, rather than a requirement which must be met. It is
recommended that the policy text is amended to reflect this to ensure that the policy is applied in
accordance with Natural England guidance and to ensure that it is clear to both developers and
decision makers how they should react to development proposals, whilst providing a reasonable
and robust policy framework that supports development being realised.

Comment

Representation ID: 211285

Received: 29/01/2026

Respondent: Woolsington One Ltd

Agent: Claremont Planning Consultancy

Policy PG/TC of the Draft Plan proposes to require that all major development proposals must
demonstrate, via a Tree Canopy Cover Assessment, how it will achieve a minimum future canopy
cover of 30%. It is considered that this proposed requirement is onerous, and fails to appropriately
acknowledge that this requirement will not be achievable on all development sites. Whilst the draft
policy text acknowledges that there may be ecological, historical, landscape, or operational
reasons to justify why a canopy cover of less than 30% is achievable; the policy must also
recognise that there may be viability reasons why that level of tree canopy cover sought is not
achievable for developments. To ensure that the application of this policy does not unduly
constrain the viability, and resultant delivery of development, it is recommended that the policy is
reframed as an aspiration that should be achieved wherever possible. A similar approach has
been advocated by the Inspector examining the Dudley Local Plan recently, where modifications
have been suggested to ‘encourage’ delivery of a minimum level of tree canopy cover, rather then
require as the Plan originally suggested prior to examination, with the modification suggested to
ensure soundness.

Comment

Representation ID: 211286

Received: 29/01/2026

Respondent: Woolsington One Ltd

Agent: Claremont Planning Consultancy

The aspirations of Policy WS/HD are supported in principle in accordance with the provisions of
Chapter 8 of the Framework. However, Part b of the draft Policy text requires new developments
to deliver community and health facilities to meet the needs generated by the development. Whilst
it is recognised that it is essential that development is supported by the requisite infrastructure, it
is recommended that the policy text is amended to identify that this infrastructure could be secured
through on-site provision or by financial contribution towards off-site provision. It is considered that the reference at Part f of the Policy towards ensuring that developments are designed to
mitigate the impact climate change is removed, given that the Draft Plan already contains
extensive policies relating to climate change and the mitigation measures that are required of
development.

Comment

Representation ID: 211287

Received: 29/01/2026

Respondent: Woolsington One Ltd

Agent: Claremont Planning Consultancy

Policy WS/NC of the Draft Plan identifies the requirement for new developments to include or
contribute to the delivery of services and facilities necessary to meet the needs of the
development. Whilst this is supported, it is considered that Policy WS/NC represents an
unnecessary duplication of Policy WS/HD which already incorporated the requirement for
developments to address the infrastructure requirements they generate. As such, it is
recommended that the requirements of these policies is consolidated into a single policy, to
ensure that each of the policies contained within the Draft Plan serves a clear purpose as required
by Paragraph 16 of the Framework.

Comment

Representation ID: 211288

Received: 29/01/2026

Respondent: Woolsington One Ltd

Agent: Claremont Planning Consultancy

Policy H/AH of the Draft Plan sets out the Councils’ position with respect to the provision of
affordable housing on new developments, and seeks to secure 40% of new homes on major
developments as affordable units of accommodation. The draft Policy text however identifies that
all schemes are required to deliver affordable housing on site, which is not supported and this
policy approach fails to recognise that there may be circumstances in which provision of
affordable housing off-site may be preferable. It is therefore recommended that the Policy text is
revised to identify a preference for on-site affordable housing delivery, however that off-site
affordable housing provision will be accepted where robust justification for this approach is
provided.

Comment

Representation ID: 211289

Received: 29/01/2026

Respondent: Woolsington One Ltd

Agent: Claremont Planning Consultancy

Policy H/ES of the Draft Plan makes provision for the development of rural exception sites within
parishes on small sites adjoining a defined development extent of Minor Rural Centres, such as
Cottenham, which is supported. Whilst it is appreciated that evidence of the social or economic
need for affordable housing is required to be demonstrated as part of rural exception site
proposals; the identification at Part a of the draft Policy that the need identified should be expected
to persist in the long term is objected to. Paragraph 82 of the Framework establishes the national
policy position in relation to rural exception sites, and simply requires that such schemes
demonstrate that they will contribute towards meeting identified local needs. The proposed
requirement within the Draft Plan for the need identified to be expected to persist in the long term
is considered to conflict with the provisions of the Framework in this regard. Moreover, the
Councils should be seeking to support rural exception schemes which address identified local
needs for affordable housing at the time of submission, regardless of whether such needs are
envisaged to persist in the longer term. It is therefore requested that the draft Policy text is
amended to remove this requirement.

Comment

Representation ID: 211290

Received: 29/01/2026

Respondent: Woolsington One Ltd

Agent: Claremont Planning Consultancy

Draft Policy H/SS seeks to identify internal and external residential space standards. With regards
to internal residential space standards, the draft Policy identifies that the Councils will apply the
Government’s Technical Housing Standards – Nationally Described Space Standards to all new
residential units. Whilst the implementation of the Nationally Described Space Standards is
supported, the draft Policy text replicates the detailed requirements and guidance relating to the
application of these standards. It is not considered necessary for this guidance to be replicated
within the draft Policy text, given that is already provided within the Government’s Technical
Housing Standards document. To ensure that the draft Policy does not include unnecessary
duplication of national planning policy and guidance, this additional detail should be removed from
the Policy text and the Policy amended to refer to the Government’s technical Housing Standards
document as providing the requisite clarification of how the standards are to be implemented.

Comment

Representation ID: 211291

Received: 29/01/2026

Respondent: Woolsington One Ltd

Agent: Claremont Planning Consultancy

Policy H/CB contained within the Draft Plan seeks to introduce a requirement for all development
proposals of 20 or more dwellings to provide at least 5% of new homes as serviced plots for
custom and self build houses or flats. Whilst the Council is seeking to adopt a positive approach
to meeting the need for self and custom build housing in accordance with Paragraph 63 of the
Framework; it is considered that the proposed policy requirement for at least 5% of homes on
schemes of 20 or more dwellings to be provided for self or custom build housing is excessive,
and the delivery of these plots is likely to be onerous for small and medium sized sites. The
requirements to deliver more Self Build plots / units through relatively small developments and
related small to medium sized house builders is likely to detrimentally influence the viability of
schemes of such scale and harm the success of these smaller developers. This could have a
knock-on effect on the delivery of windfall dwelling delivery, to the detriment of overall housing
provision.

Comment

Representation ID: 211292

Received: 29/01/2026

Respondent: Woolsington One Ltd

Agent: Claremont Planning Consultancy

Draft Policy I/ST seeks to promote sustainable transport and connectivity through new
developments, which is supported in accordance with Paragraph 110 of the Framework.
However, Part 3 of the draft Policy text identifies that developments will only be permitted where
they do not have an unacceptable impact on transport and highway safety. This part of the Policy
must be amended, whereby the proposed wording presently conflicts with Paragraph 116 of the
Framework which is explicit that development should only be prevented or refused on highways
grounds if there would be an unacceptable impact on highway safety or the residual cumulative
impacts on the road network would be severe. This amendment should be implemented to ensure
that the Draft Plan is capable of being found sound at Examination in accordance with Paragraph
36 of the Framework which requires that Local Plans must be consistent with national policy.

Comment

Representation ID: 211293

Received: 29/01/2026

Respondent: Woolsington One Ltd

Agent: Claremont Planning Consultancy

Policy I/EV outlines the proposed parking standards that are to be applied to new developments.
Accordingly, the draft Policy provides guidance with regards to the design considerations to inform
car and cycle parking provision, as well as the quantitative parking standards to be applied. Whilst
the proposed parking standards are considered to be acceptable in principle; the draft Policy text
is lengthy and consideration should be given as to whether it may be appropriate to include
reference to the compliance with the parking standards within the parking text with the parking
standards themselves instead provided within an appendix to the Local Plan or alternatively within
a separate Parking Standards Supplementary Planning Document