Draft Greater Cambridge Local Plan for consultation

Object

Representation ID: 208246

Received: 29/01/2026

Respondent: Kings College

Agent: Turley

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

The requirement in point 2 that development proposals must ‘preserve or enhance’ and comply with the rest of strands a) to g) of this policy is not in line with statutory duty in Sections 16, 66 or 72 of the Planning (Listed Buildings and Conservation Areas) Act 1990 (which requires ‘special attention’ to be paid). It is similarly not in accordance with paragraphs 213 to 215 of the NPPF where, in some circumstances, public benefits can outweigh harm to heritage significance. As drafted, this is unreasonably prescriptive. In point 3 (a) who ‘formally’ assesses this (ie whose opinion determines if a building is considered unsound)? Similarly, how could an applicant ever demonstrate that ‘all possible measures’ have been explored in point b). It is not clear if all of strands a), b) and c) must be met or if these are either / or situations.

Object

Representation ID: 208248

Received: 29/01/2026

Respondent: Kings College

Agent: Turley

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

It is unclear how this aligns with policy H/SA which proactively supports the provision of student accommodation recognising that there is identified need in the city. The supporting text to policy H/SA clearly acknowledges the benefit in contributing to addressing housing need as a whole, noting that dedicated college student accommodation removes student population from the housing market. The financial burden imposed by the draft policy would not encourage colleges to actively seek opportunities to provide dedicated accommodation for their students, beyond those exceptions set out in the draft policy. This would risk a situation where a proportion of students who could potentially be housed in college accommodation, are remaining in the private rental market.

Object

Representation ID: 208249

Received: 29/01/2026

Respondent: Kings College

Agent: Turley

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

The definition of “over‑concentration” in multiple‑occupation policy H/MO is unclear. The supporting text at paragraph 4 states that a continuous frontage of 2 or more HMOs immediately adjacent to each other is an over-concentration. Furthermore, that the definition of ‘over concentration’ is still to be refined. Point 1b) should be removed and site‑specific assessment allowed under point 1a).

Object

Representation ID: 208250

Received: 29/01/2026

Respondent: Kings College

Agent: Turley

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

King’s College have concerns regarding this draft Policy. While the intent of this requirement is understood, matters relating to overheating risk, ventilation and internal environmental performance are already comprehensively addressed through the Building Regulations (part O) and associated guidance. Some of our buildings may require large open spaces such as lecture theatres which present unique challenges to issues such as ventilation and overheating. The College therefore requests that the policy be amended to include the following text: Buildings which have heritage and/ or specific functional constraints will be provided additional commercial or technical flexibility with these requirements subject to the provision of evidence.

Object

Representation ID: 208251

Received: 29/01/2026

Respondent: Kings College

Agent: Turley

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

There is no mention in the draft Policy of the need for flexibility where sites are impacted by heritage designations, which of course significantly impact the College. We therefore suggest that the following wording should be inserted into the draft Policy: It is recognised that buildings impacted by heritage designations may have specific constraints and this will be considered in the context of the targets within this Policy. Net‑zero carbon policy CC/NZ imposes space‑heating (15‑20 kWh m⁻²) and EUI (35 kWh m⁻² yr⁻¹) targets equivalent to Passivhaus standards, which are financially and technically onerous; the draft should be amended or withdrawn, with a heritage‑flexibility clause and targets aligned to construction year rather than a fixed 2030 benchmark.

Object

Representation ID: 208252

Received: 29/01/2026

Respondent: Kings College

Agent: Turley

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

In relation to Part C: the renewable‑energy provision wording “where possible” should be interpreted flexibly, and the policy should be amended to read: "Proposals should maximise the deployment of renewable energy where appropriate and viable". Part D also requires new development to calculate whole life carbon emissions through a nationally recognised whole life carbon assessment tool and demonstrate actions to reduce embodied carbon where possible. The College therefore requests that the following text be inserted into this draft Policy: "The Whole Life Carbon Assessment undertaken should be proportionate to the nature and scale of the application".

Object

Representation ID: 210978

Received: 29/01/2026

Respondent: Kings College

Agent: Turley

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

It is not clear at 10.a) what ‘within an existing university or college campus site’ means. As with a number of colleges Kings College has dispersed sites which collectively form the college. It would be unreasonable to seek an affordable housing contribution from student accommodation developments on a site currently within college ownership. It is requested that the text be amended as follows: 10. An affordable housing contribution will not be sought where the proposed development is: a. within an existing university or college campus site, or b. for the redevelopment of a site which, at the date of the adoption of the Plan, is owned by a university or college, and which will continue to be owned by a university or college after the redevelopment to provide student accommodation to meet its needs.

Object

Representation ID: 210979

Received: 29/01/2026

Respondent: Kings College

Agent: Turley

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

The College fully supports the need to improve water efficiency in new developments given the serious issue within the area with respect to water stress. The College assumes that for student accommodation, the target of 5 credits for category Wat01 of BREEAM will be relevant (strand c) of the policy). To achieve these targets will require extensive water management and recycling facilities including potentially rainwater harvesting and greywater recycling. Both of these technologies have considerable commercial and technical implications, particularly with respect to maintenance. The Colleges therefore considers the term ‘unless demonstrated not practicable’ will be applied to decision making and all of the water efficiency targets presented.

Object

Representation ID: 210980

Received: 29/01/2026

Respondent: Kings College

Agent: Turley

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

King’s College fully supports the need for integrated water management and strategic thinking and this has been considered within our site and new development activities. The College does have concerns respect to the application of paragraph 6 of the policy. The policy as currently drafted risks placing an unreasonable and disproportionate evidential burden on applicants at the planning application stage. Policy CC/IW should be implemented flexibly, with appropriate reliance placed on the statutory duties of water companies and ongoing engagement through established mechanisms such as Water Resource Management Plans and Drainage and Wastewater Management Plans.

Object

Representation ID: 210981

Received: 29/01/2026

Respondent: Kings College

Agent: Turley

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

King’s College supports the intent of Policy CC/CE and welcome the flexibility built into paragraph 1 of the policy. However, the College has concerns regarding paragraph 5. It is considered that this requirement relates to the information needed to support a planning application rather than to the policy tests against which proposals should be assessed. As such, this requirement would be more appropriately addressed through the Council’s validation requirements, rather than embedded within the policy itself. The College believes that the submission of such a statement and/or information within a Sustainability Statement should be limited at outline planning application stage given that building design information is very limited at that stage. A CE statement should be reserved for detailed design stage only where it will be more meaningful in terms of information.