Draft Greater Cambridge Local Plan for consultation

Point 1d is a crucial part of the policy and as it relates to point a., it should be given greater prominence and be renumbered as point b.

The policy and supporting information should be strengthened by referring to waste collection as well as storage, and to environment and heritage as well as neighbouring amenity.
Suggested wording for point 2.i. - new text shown in capitals
Ensure the layout and design of development successfully incorporates functional needs such as waste storage AND COLLECTION, recycling and bicycle parking, in a way that does not negatively impact on THE ENVIRONMENT, HERITAGE or neighbouring amenity.

The policy must be backed by a clear commitment to refuse applications that do not meet the highest possible standards of architectural integrity.

It is important to understand that for development to make efficient use of land does not mean that it should lead to high rise residential development. In 2010 CPPF organised a public meeting on tall buildings. The issues discussed then are still relevant today. The presentation by Sir Richard MacCormac, past president of RIBA, demonstrated that traditional terraces and squares are frequently more effective than tower blocks for residential density. For instance, high-density urban family housing can achieve 100 dwellings per hectare. This matches the capacity of tower blocks while remaining significantly more cost-effective and avoiding the complex management problems inherent in high-rise living. Furthermore, studies confirm that walkable communities can be sustained with 2–3 storey family houses and 4–5 storey flats. Such configurations achieve a gross density of 50 dwellings per hectare, which is more than sufficient to prevent suburban sprawl into the Green Belt without compromising the city’s human scale.
Attached is a copy of Richard MacCormac's talk

See Cambridge Past, Present and Future's comments on BG/EO representation ID 203339

Consider whether this section should include policy and/or supporting information on Assets of Community Value.

The policy should justified by use of 3D modelling.
The policy must protect sensitive viewpoints like Red Meadow Hill
The policy or supporting text should clarify how the policy relates to site specific frameworks/masterplans.
The policy should explicitly focus on "Landmark Buildings".
The policy needs to find a way of supporting varied heights and silhouettes and also setting height guidelines in order to avoid overly tall buildings.
Policy must be backed by a clear commitment to refuse applications that do not meet the highest possible standards of architectural integrity.

Suggested amendments to policy text (New text in capitals / deleted text in square brackets)
1. Proposals for taller buildings will be supported where they are appropriate to their location and demonstrate a positive response to the IMMEDIATE AND wider setting. ….

1a. Location, setting and context – applicants must demonstrate through visual appraisals, with supporting accurate visual representations, how the proposals fit within the existing landscape and townscape. [and provide a] A clear assessment of how proposals maintain or enhance the skyline MUST ALSO BE PROVIDED.

1b. ……... For Cambridge, ALL BUILDING proposals must ensure that the character or appearance of Cambridge, as a city of spires and towers emerging above the established tree line, remains dominant from relevant viewpoints.

1c. Scale and massing – applicants must demonstrate using scaled drawings, sections, accurate visual representations and models, how their proposals [will deliver] DEMONSTRATE APPROPRIATE PROPORTIONS BETWEEN HEIGHT, MASSING AND CLUSTERING OF BUILDINGS AND HOW THOSE PROPOSALS WILL DELIVER a [high-quality] BENEFICIAL addition to the skyline…...

1e. Amenity and Microclimate - applicants must demonstrate that there is no adverse impact on neighbouring buildings and open spaces in terms of the diversion of wind, overlooking or overshadowing THROUGH UNEQUIVOCAL AND APPROPRIATE SUPPORTING INFORMATION, and that there is adequate sunlight and daylight within and around the proposals

Cambridge Past, Present & Future is really pleased to see that the city is learning from experience and the new tall buildings policies proposed in the latest plan are a significant improvement from the 2018 plan.

However, whilst we recognise the need for a robust policy to manage height as the city grows, we are concerned that the current approach risks creating a permanent "ring" of tall buildings that will fundamentally alter the character of the Cambridge skyline.

Why has the Vu-City model, mentioned in 2021 Local Plan documents, or equivalent, not been used to present, assess, and justify the draft Plan’s tall buildings proposals? This is a serious omission in communicating a key issue to the public. Once the precedent for tall buildings is established, it becomes a "genie out of the bottle" that is difficult for the planning system to regulate. By prioritizing horizontal density over vertical height, Policy GP/ST can ensure a sustainable, viable, and architecturally appropriate future for Cambridge that protects the unique character of the cityscape.

1. Cumulative Impact and Strategic Locations
The identification of four equidistant sites—West Cambridge, North East Cambridge, East Cambridge, and the Cambridge Biomedical Campus (CBC)—as suitable for tall buildings suggests a shift in the city's profile. We are concerned that this will result in a cluster of tall buildings being visible from almost any vantage point, whether at ground level or from elevated positions.

While we acknowledge that East Cambridge has a less direct visual relationship with the historic core, the other three sites are highly sensitive. We particularly wish to highlight the view from Red Meadow Hill, a key strategic viewpoint. The policy must ensure that development in these areas does not result in a wall of uniform height that competes with the historic "city of spires."

2. Consistency with Existing Masterplans
We seek clarification on how Policy GP/ST interacts with existing site-specific frameworks, particularly the West Cambridge Masterplan. We question whether tall buildings are truly necessary for the delivery of the West Cambridge site’s objectives. Any policy allowing for increased height must be based on a proven functional need rather than a default assumption of density.

3. Architectural Quality and Landmark Buildings
We hold no objection to a tall building policy that delivers genuine architectural excellence. However, the design must be more than a functional exercise in "hiding plant" or maximizing floor plates. To be successful, tall buildings in Cambridge must:
• Demonstrate Architectural Merit: They should be elegant in form, avoiding the "bulky box" aesthetic that currently plagues many modern developments.
• Function as Landmarks: We suggest the policy should explicitly focus on "Landmark Buildings"—structures that are purposefully designed to be singular, distinct markers that add quality to the skyline, rather than just reaching a maximum height limit.

4. The "Flattening" Effect of Height Limits
We are concerned that setting a "maximum height" often becomes a target for developers. This tends to lead to a "flattening" of large commercial development, where every building rises to the same permitted ceiling, resulting in a monotonous and bulky roofscape. This is especially problematic when many developers are involved, because none of them wants to be the one offering the lower height that is required to create the varied heights and silhouettes that is needed to maintain the "incidental" and textured nature of the Cambridge skyline. This results in proposals for even taller buildings to create the variability. The policy needs to find a way of supporting varied heights and silhouettes and also setting height guidelines in order to avoid overly tall buildings.

5. Capability and Resolve
Finally, a policy is only as effective as its enforcement. We are not yet confident that the Councils possess the necessary resolve to push back on poor or mediocre design when developers reach for maximum heights and floor space. Policy GP/ST must be backed by a clear commitment to refuse applications that do not meet the highest possible standards of architectural integrity.

See attached alternative wording
Policy 66 (Paving over front gardens) from the City Council adopted local plan should be retained and updated.
Require developers to contribute to landscape monitoring fund.

This policy GP/QP, gives direction on the expectations of the quality of open green space as well as public realm, while Policy BG/EO: Providing and enhancing open spaces (within the Biodiversity and Greenspace) sets the open space standards. The two policies are so interrelated, should they be in the same topic area, i.e. in Great Places or at least cross referenced?

The definitions of different types of external space seem to be interchanged freely adding to a confusion of terminology. A definition and standard description of each different type of space should be provided in the policy as well as in the supporting information. It should also be standard between topic areas and policies.
The policy focusses mainly on greenspaces. It should also give more direction on the design/content of public realm areas, e.g. streets and civic squares.

The content, purpose and wording of this policy is rather muddled and repetitive, particularly the first two sections. We suggest the text is rationalised and made clearer.
An alternative wording is proposed and attached.

Paving over front gardens
§7.40 supporting this policy states: “To support well designed public realm, the Local Planning Authority promotes the removal of paving in front gardens. When considering paving for front garden, it is encouraged that permeable paving is used.”
This is the only reference in the draft Local Plan to paving over front gardens. Policy 66: Paving over front gardens in the current Local Plan has been dropped. This includes three tests for acceptability for paving over a front garden, and important guidance, including highlighting the fact that it is illegal to drain water from private land over a public footway.
The final sentence of §7.40 states, “you can [should be may] pave without the need for planning permission if you use porous materials for paving, or provision is made to direct run off water from the hard surface to a permeable or porous area or surface within the curtilage of the dwellinghouse.” Compliance is difficult to monitor, in particular whether a soakaway has been installed, and that its volume is sufficient for the area being drained.
Three factors have increased the number of front gardens converted to driveways:
a) Competition for on-street parking in residential areas. Some areas of the city have seen an increase in the number of cars per household (Cherry Hinton, Trumpington, Arbury and East Barnwell), and average car sizes have increased, reducing on-street parking capacity.
b) Avoiding paying for parking permits in Residents’ Parking Zones.
c) Enabling EV charging at home for convenience and significantly lower charging costs.
Factor (c) in particular will see an accelerating number of front gardens paved over in coming years in the absence of an effective policy in the new Local Plan .
Policy 66 from the current local plan should be Retained and updated. Article 4 Directions, for instance, should be considered to protect front gardens in Conservation Areas.

Monitoring and Enforcement of Landscape Quality
While Policy GP/QP emphasises the importance of well-designed green spaces and high-quality public realms, there remains a persistent gap between the "paper" specifications approved and conditioned at the planning stage and the actual quality of landscapes delivered on the ground. We are aware that the Councils have struggled with the delivery of subpar landscaping in new developments, often due to a lack of resources to monitor and enforce approved landscape conditions, specifications and long-term management plans. Without active monitoring, the visual, social, and environmental benefits of new green spaces are frequently lost to poor planting, ground compaction as well as inadequate soil preparation, or the lack of adequate watering and maintenance regimes.
We propose that the Local Plan introduces a specific financial mechanism to address this resource gap. Currently, mechanisms are being established to cover the long-term monitoring and auditing of Biodiversity Net Gain (BNG). We strongly recommend that this approach be extended to include the monitoring and enforcement of general landscaping works.
By requiring developers to contribute to a landscape monitoring fund—similar to the model used for BNG—the Councils could fund the necessary expertise to ensure that:
• Approved conditions and specifications are strictly adhered to during the construction and planting phases.
• Management Plans are being actively followed by the responsible parties post-completion.
• Remedial Action is taken promptly where landscaping fails to meet the conditions and quality standards set out in the permission.

Strongly support, with some proposed amendments.

Consider whether reference should be made to other documents such as Tall Buildings Baseline, Strategy and Guidance (2025) and perhaps the townscape study.

The supporting information should request evidence that due regard has been taken of the GC Landscape Character Assessment and its related studies as part of the pre-application/feasibility stage and not simply accompany the planning application, when it is invariably too late to amend.

Suggested amendments to text shown in capitals
1.a. protect, conserve and enhance the local landscape character, DIVERSITY AND NATURAL BEAUTY as set out….
Insert new 1b
SEEK TO ENSURE THAT CHANGE IS APPROPRIATE TO THE RELEVANT LANDSCAPE CHARACTER TYPE AND AREA, AND THE FEATURES AND CHARACTERISTICS THAT DEFINE THEIR LOCAL DISTINCTIVENESS.

Insert new subsection to part 1
IDENTIFY OPPORTUNITIES TO INTRODUCE NEW AND APPROPRIATE LANDSCAPE FEATURES TO COMPENSATE FOR NEARBY LOSS OR DEGRADATION;

The policy needs to change from a reactive policy (dealing with buildings one by one) to a proactive, landscape-scale policy that views the entire city and its surrounding countryside as a singular heritage asset.

1. Recognition of Universal Significance
• Include a Statement of Significance: The plan must include a formal statement recognising the city’s global heritage value as a cohesive whole.
• Broaden the Scope of Protection: Policy must explicitly recognise the world-heritage significance of the city,

2. Shift from "Narrow" to "Cumulative" Impact Assessment
• End the Reliance on Individual HIAs: Policy should move away from site-specific Heritage Impact Assessments (HIAs) and instead require Cumulative Heritage Impact Assessments.
• Update the Evidence Base: Incorporate Conservation Area Appraisals as a core part of the evidence base to understand how small changes across the city add up to a major impact.
• Address Indirect Growth Impacts: Policy must account for the "inevitable" changes to the city's fabric (layout, transport, and use) that result from massive population growth, rather than just the physical impact of new buildings.

3. Heritage-Driven Green Infrastructure
• Mitigate Visitor Pressure: Planning policy must acknowledge that visitor pressure is a threat to heritage significance at sites like Wimpole and Wandlebury (currently, the plan only mentions this pressure in relation to nature reserves).
• Strategic Park Expansion: Policy should mandate the enlargement of existing parks and the creation of large new green spaces specifically to divert visitor pressure away from sensitive historic sites.

4. Reform of the Historic Environment Strategy
• A Dynamic Strategy Diagram: Figure 133 must be updated to move away from "static" lists. It needs to incorporate:
o The whole life cycle of heritage assets.
o The balance between energy efficiency and durability.
o Ongoing monitoring through regular conservation appraisals.
• Focus on Strategic Evaluation: The strategy must evaluate the city’s historic culture holistically rather than just listing existing planning tools.

5. Formal Commitment to Planning Frameworks
• Complete the "Making Space for People" SPD: This Supplementary Planning Document is required to manage the "intense pressure" on the limited space in the historic core.
• Finalise Historic Core Conservation Area Management Strategy

Cambridge Past, Present & Future expresses profound concern regarding Policy GP/HE, primarily due to the plan’s failure to recognise the overarching significance of Cambridge’s heritage and to assess the cumulative and indirect impacts on it of significantly increasing the population.

The city possesses a world-class built environment and historic landscape that attracts over 8 million visitors annually and serves as a primary driver for global investment, student recruitment, and business retention. Despite the city’s Outstanding Universal Value being formally acknowledged as far back as its 1980s World Heritage Site nomination, the current draft plan contains no overall Statement of Significance. It fails to recognise the world-heritage significance of the city as a cohesive whole, particularly along the vital river corridor extending from Byron’s Pool through Grantchester Meadows to Baitsbite Lock—an area integral to Cambridge’s international identity.

A population increase of 100,000+ will result in more people and more transport in the historic city centre. Changes will inevitably be required to the layout, use and fabric of the city centre to accommodate so many more people. That’s where there’s a risk to our heritage, because this Plan is proposing the growth without adequately considering what changes might follow – indeed the plan doesn’t recognise that this is likely to happen, let alone how it might be addressed.

The same problem exists in our countryside. Historic places like Wimpole and Wandlebury are already under visitor pressure, which is having a negative impact on their heritage significance. What will happen when another 100,000+ people want to visit those places? We believe the Plan must recognise these impacts and present a solution to this problem. It is CPPFs view, shared by Historic England, that the solution is to make the existing parks bigger, as well as creating large new attractive green spaces, to take some of the pressure off. This is what is being proposed in the Green Infrastructure and Open Space sections of the Local Plan and can be cross referenced. In the GI/Open Space section it would be helpful to recognise the heritage problem caused by visitor pressure (at present visitor pressure is referenced only in relation to nature reserves) and the need to mitigate heritage impacts.

Furthermore, the proposed Historic Environment Strategy is fundamentally inadequate, serving as little more than a list of existing tools rather than a genuine strategic evaluation. It is essential that a city with such a rich and diverse historic culture that is experiencing increasing development pressures must have a comprehensive Historic Environment Strategy that addresses the cumulative effect of the myriad of different development proposals. The Historic Environment Strategy Diagram, currently labelled as Figure 133, is too static and focused solely on existing tools. To improve its utility, it should incorporate more dynamic elements that reflect the evolving nature of heritage management. This includes highlighting the balance between energy efficiency, durability, and the whole life cycle of assets. Additionally, the diagram should account for the ongoing monitoring of heritage significance, ensuring that changes over time are captured through regular conservation area appraisals.

The 2021 Strategic Heritage Impact Assessment failed to provide a holistic analysis of the city’s significance or a baseline for considering the impacts of proposed growth, opting instead for a narrow focus on specific development options. By ignoring Conservation Area Appraisals as a key part of the evidence base, the strategy lacks the necessary depth to assess the cumulative heritage impacts of the planned scale of growth for Greater Cambridge. Individual Heritage Impact Assessments are simply too narrow in scope to address these broad, strategic risks to the historic environment.

The effectiveness of this policy is further undermined by a distinct lack of commitment to essential planning frameworks, specifically the failure to produce the "Making Space for People" Supplementary Planning Document (SPD). Although the previous plan acknowledged the necessity of this work, the Council has failed to complete both this SPD and the Historic Core Conservation Area Management Strategy. These documents were intended to identify and reconcile the intense pressures on the limited spaces within the historic core—pressures that have only become more acute following recent proposals for the Market Square and Civic Quarter. Without a commitment to these strategies and a more dynamic approach to the Historic Environment Strategy Diagram, which currently remains too static and ignores the whole life cycle of assets, the proposed policy remains premature and fails to protect the very heritage that defines our city.

Strongly support
Just as Scheduled Ancient Monuments and Conservation Areas are shown on the Policies Map, It would be useful for listed building to be annotated.