Draft Greater Cambridge Local Plan for consultation

Comment

Representation ID: 208958

Received: 30/01/2026

Respondent: Persimmon Homes East Midlands

These representations are made on behalf of Persimmon Homes Ltd (East Midlands) in response to the Draft Greater Cambridge Local Plan. We support the overall vision of creating well-designed, sustainable and resilient communities, and welcome the ambition shown in the draft policies. However, a number of the detailed requirements go beyond national standards or lack sufficient flexibility and therefore risk undermining deliverability or delaying the housing trajectory.

Comment

Representation ID: 208960

Received: 30/01/2026

Respondent: Persimmon Homes East Midlands

We support the principle of embedding climate mitigation and adaptation across the plan. However, as drafted, Policy CC/SD lacks clarity, risks duplication of other policy requirements, and has not been shown to be proportionate, effective or aligned with the national policy framework. While a Sustainability Statement may be helpful, the draft policy does not specify:
• the level of detail expected for different scales of development;
• how evidence should be structured;
• which matters require stand-alone assessments elsewhere in the plan;
• and how duplication will be avoided.
This lack of clarity is inconsistent with the Topic Paper narrative too.

Comment

Representation ID: 208961

Received: 30/01/2026

Respondent: Persimmon Homes East Midlands

CC/SD requires demonstration of compliance with “various policies” related to climate mitigation/adaptation that feature in other policies. Each of these contains its own evidence, technical studies, and in many cases reporting requirements. CC/SD risks duplicating these obligations by requiring applicants to repeat information narratively in a Sustainability Statement, increasing cost and administrative burden without adding planning value. Policy CC/SD also references “carbon sequestration” as one of the matters applicants must address through their Sustainability Statements. This raises significant concerns about justification, scope and proportionality and this is covered in Policy CC/CS.

Comment

Representation ID: 208962

Received: 30/01/2026

Respondent: Persimmon Homes East Midlands

To ensure soundness, we request that Policy CC/SD is revised to provide clarity, avoid duplication and ensure proportionality. We propose the following modifications: “Sustainability Statements must be proportionate to the scale, nature and complexity of the development”, and to delete “carbon sequestration” from the list of matters to be addressed in Sustainability Statements.

Comment

Representation ID: 208963

Received: 30/01/2026

Respondent: Persimmon Homes East Midlands

While we support the principle of requiring development to incorporate climate‑resilient design, the detailed requirements set out within Policy CC/DC particularly the cooling hierarchy raise significant concerns over deliverability, proportionality and soundness. Nowhere in the evidence base is there demonstration that the hierarchical ordering of measures is appropriate for all sites or building types, nor that the hierarchy is compatible with other policies such as CC/NZ. Without evidence, the hierarchy becomes an unjustified design imposition, contrary to NPPF and plan-making tests of soundness. We suggest replace the hierarchy with: “Developments must demonstrate that they have appropriately assessed and mitigated the risk of overheating using a performance‑based approach (e.g., CIBSE TM59), applying passive, active and hybrid cooling measures as appropriate to site context”.

Comment

Representation ID: 208964

Received: 30/01/2026

Respondent: Persimmon Homes East Midlands

UKNZCBS is voluntary, still in pilot, verifies after occupation, does not provide cost evidence, and is “not recommended” to be set as a Local Plan policy requirement. CC/NZ (as drafted) is not shown to be justified, effective, or deliverable against the FHS route. Limb 6 of the Policy states that where a proposal cannot comply with on‑site energy and carbon requirements, a financial contribution will be required. However, no contribution formula, metric or calculation method is provided. In addition to the above, contributions must also meet CIL/S106 legal tests. To ensure the Plan remains sound, we recommend that Policy CC/NZ is amended with modifications to introduce transitional arrangements for fossil fuel phase-out, amends to Limb 6, align policy with Future Homes Standards, and to allow flexibility for large multi-phase developments.

Comment

Representation ID: 208965

Received: 30/01/2026

Respondent: Persimmon Homes East Midlands

It is recognised that Part G of the Building Regulations (2010), which relate to water efficiency, currently apply a technical standard of 125 litres per person per day; with an optional tighter target of 110 l/p/d. A blanket 80 l/p/d risks being unjustified and disproportionate particularly for early-plan delivery. We welcome the publication of the Cambridge Area Water Supply Evidence (2025) that informs the draft policy. However, the mandatory 80 l/p/d standard for all new residential development is not justified. As there is an existing national standard for such areas then the only sound approach is to apply that standard, which remains 110 litres per person per day.

Comment

Representation ID: 208966

Received: 30/01/2026

Respondent: Persimmon Homes East Midlands

Limb 5 - While we support the intent to reduce potable water consumption, the requirement as drafted is technically unclear, operationally problematic and introduces significant long-term management liabilities, particularly for multi-phase or multi-ownership residential developments. Limb 5 fails to acknowledge the fundamental difference between:
• (a) private garden irrigation, and
• (b) shared/communal amenity spaces, which typically fall under a Management Company (MANCO) or Residents’ Management Company (RMC).
To make Limb 5 sound, we propose the following amendments:
• Allow Alternative Water‑Efficient Landscaping Strategies:
“Developers may instead demonstrate compliance through low‑water‑demand planting, drought‑resistant species, soil enhancement and minimisation of irrigation need”.
•Clarify that domestic water butts suffice for private plots:
“For private gardens, individual water butts shall be considered sufficient to meet policy requirements”.

Comment

Representation ID: 208967

Received: 30/01/2026

Respondent: Persimmon Homes East Midlands

While we support the principle of minimising flood risk and ensuring robust SuDS design, this requirement is overly prescriptive, technically unjustified, and undeliverable in many site contexts. It contradicts national and industry SuDS design practice and fails to reflect constraints acknowledged by Lead Local Flood Authorities (LLFAs) and the CIRIA SuDS Manual. A universal requirement for all sites to discharge at or below 2 l/s, regardless of the scale or characteristics of the catchment, fails to reflect these technical realities. To ensure the policy is sound and effective, Limb 1h should be amended to introduce site‑specific flexibility (replacing the blanket requirement) and recognising the practical constraints on flow control.

Comment

Representation ID: 208968

Received: 30/01/2026

Respondent: Persimmon Homes East Midlands

Policy CC/CE which covers a circular economy and sustainable resource use is not sound. As drafted, it is insufficiently precise, not effectively enforceable, and risks duplication with existing regimes. The policy is vague in its duties, lacking clear enforceable requirements. As written, the Statement risks becoming a narrative document rather than a decision tool, which is neither proportionate nor effective for development management. The Plan cites broad aims and cross-references to RICS/RECAP but presents no viability testing for the incremental costs of CC/CE. In the absence of quantified evidence, the policy is not justified or effective.