Draft Greater Cambridge Local Plan for consultation

Comment

Representation ID: 208969

Received: 30/01/2026

Respondent: Persimmon Homes East Midlands

While the intent is understood, the policy is not sound as drafted. The policy introduces undefined obligations resulting is a policy that is overly vague, lacks objective compliance tests, and is potentially unenforceable in development management. There is no definition of ‘significant harm’ to peat meaning the policy is not implementable. The wording "meaningful" in part 6, is a non-enforceable aspiration. The policy also requires peat-related soil management plans but does not specify requirements and provides no evidence of costs. No work has been presented to demonstrate that the policy is deliverable and viable, particularly for small or medium‑sized sites.

Comment

Representation ID: 208970

Received: 30/01/2026

Respondent: Persimmon Homes East Midlands

We support the principle of addressing health impacts through development. However, a threshold of 20 dwellings is unusually low and risks being disproportionate, particularly on small or medium sized sites where impacts can be addressed through standard planning tools and contributions. We recommend raising the threshold to align with national practice (for example 200 units) or alternatively apply HIAs only where a screening assessment identifies specific health impacts that require further work. A higher site threshold of circa 200 units is much more likely to make the policy sound. Where sites allocated for development are consistent with the policies in the local plan the council should be clear that an HIA is not required.

Comment

Representation ID: 208971

Received: 30/01/2026

Respondent: Persimmon Homes East Midlands

We support the principle of ensuring that larger developments respond to community needs, however, the wording in limb 4, could be construed to place the onus on the applicant to assess community needs and produce a strategy to meet them. The policy would be more effective and proportionate if it required that major applications demonstrate how they have engaged with the LPA and relevant providers to meet identified needs, rather than placing the responsibility on applicants to determine those needs. Suggested amendment to read: “For developments of 200 dwellings or more, applicants should engage with the Council and relevant service providers at pre-application stage to ensure that proposals address identified community needs and contribute to any site-wide strategy”.

Comment

Representation ID: 208972

Received: 30/01/2026

Respondent: Persimmon Homes East Midlands

Support the use of design codes and plot passports, but mandating both for outline planning permissions is inflexible, and an either/or approach should be adopted. Policy seems to prohibit custom finish or custom build in houses, which is contrary to national policy. Amendments sought to provide clarity that custom finish proposals can apply to both houses and flats where external design is fixed, whereas external customisation is generally not appropriate for flatted schemes.

Comment

Representation ID: 208973

Received: 30/01/2026

Respondent: Persimmon Homes East Midlands

The policy requirements for a 15-year covenant and the availability of tenancies of up to 3 years are consistent with national guidance and industry practice. However, to ensure the policy is effective and does not inadvertently constrain delivery, suggest clarify that the 3 year tenancy is an option available to residents rather than a minimum term that must be taken, and that the covenant period can be reviewed where the scheme is demonstrated to be unviable or no longer capable of delivering Build to Rent use.

Comment

Representation ID: 208974

Received: 30/01/2026

Respondent: Persimmon Homes East Midlands

The identified need is overwhelmingly rural and not generated by new settlements, and the ANA explicitly recommends a criteria based policy and only lists inclusion within strategic sites as an option, not an evidence-led requirement. Part 3 of the Policy goes beyond the evidence base, and should be deleted. There are practical delivery problems with providing pitches within strategic sites – issues with finding 1-2 hectares within tight masterplans, integrating the pitches in a way that works operationally, and willingness of traveller households to relocate. The Viability Assessment does not take account of providing pitches within strategic sites.

Comment

Representation ID: 211405

Received: 30/01/2026

Respondent: Persimmon Homes East Midlands

The draft Plan’s blanket requirement for 20% BNG on major development is not justified, not shown to be effective, and risks being inconsistent with national policy. The HRA simply notes BNG uplift and treats it as general mitigation; it contains no local need analysis or viability testing for a >10% requirement. The SA recognises a viability risk around any demand to provide 20% BNG, and states 10% would be sufficient to protect designated sites. There are material contradictions between the Council’s Topic Paper and its Viability Report that fatally undermine the case for 20%. The current proposed blanket 20% BNG requirement for all major applications would be contrary to the emerging national policy direction for securing biodiversity net gain in new development.

Comment

Representation ID: 211406

Received: 30/01/2026

Respondent: Persimmon Homes East Midlands

The policy effectively locks in an Urban Greening Factor‑type requirement without any viable evidence base or defined methodology. Policy BG/GI adopts the standards in principle, meaning applicants cannot quantify: the level of urban greening required; its spatial implications on layout/density; or the cost of compliance. This fails NPPF requirements for clarity and enforceability. There is a major evidence gap, particularly because urban greening factor significantly impacts developable area and costs. Substantial amendments are required to ensure the policy meets national tests of soundness and does not prevent the delivery of sustainable development.

Comment

Representation ID: 211407

Received: 30/01/2026

Respondent: Persimmon Homes East Midlands

We support the delivery of a greener urban environment. However, Policy BG/TC’s requirement for 30% tree canopy presents concerns in terms of justification and deliverability. A 30% cover figure is at the upper end of national benchmarks (e.g.: National Design Guide 20% urban minimum) and will only be achievable if it is clear that the policy counts both existing canopy and new planting toward the target, and that canopy is measured at maturity rather than at completion of development. The Viability Assessment does not appear to model the costs of achieving and maintaining 30% canopy cover. We therefore recommend amendments to allow existing canopy to count toward the requirement, and to assess canopy at a defined future year.

Comment

Representation ID: 211408

Received: 30/01/2026

Respondent: Persimmon Homes East Midlands

Policy I/EV 2(h) stipulates that cycle parking for residential developments must be located in a purpose-built area at the front of the house or within a garage. This is unduly prescriptive and risks excluding secure and convenient solutions that are widely used and accepted elsewhere. We recommend amending the policy to allow secure cycle storage in a range of suitable locations, subject to accessibility and design considerations, rather than restricting solutions to the front of a house or garage. Suggested wording is “Cycle parking should be secure, covered and convenient, and may be provided in a purpose-built area at the front or rear of the house, within a garage, or in other suitable locations subject to design and access considerations”.