Draft Greater Cambridge Local Plan for consultation

Comment

Representation ID: 208297

Received: 30/01/2026

Respondent: Girton College

Agent: Turley

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.

Comment

Representation ID: 208298

Received: 30/01/2026

Respondent: Girton College

Agent: Turley

Part a seeks to ensure there is not an over concentration of HMO use in a local area. The draft policy introduces at 1b a restriction to prevent three or more adjacent HMOs or a C3 property being sandwiched between two HMOs. 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. Further that the definition of ‘over concentration’ is still to be refined. This would appear unresolved. It is not clear why two HMOs next to each other is considered an over-concentration when this does not take into account wider context. The intention of the policy is presumably to ensure there is no adverse impact on residential amenity. It is requested that further consideration be given to the definition of over concentration.

Comment

Representation ID: 208299

Received: 30/01/2026

Respondent: Girton College

Agent: Turley

The policy would be clearer if it simply stated ‘developments that cause significant change to the existing skyline and / or are significantly taller….’ As this policy effectively uses the old Cambridge Local Plan Policy and extends it into the villages and rural areas of South Cambridgeshire, the above clarification is even more necessary for Girton College – otherwise any new building or addition to the height, no matter how modest, would break the skyline from somewhere and potentially be unacceptable.

Comment

Representation ID: 208300

Received: 30/01/2026

Respondent: Girton College

Agent: Turley

As there are specific policies relating to both designated and non-designated heritage assets, why is this policy needed? The requirement for a Heritage Impact Assessment could (if considered necessary given the Council’s application validation requirements) be easily added into the other policies. Notwithstanding this comment, in limb b), the meaning of ‘nature’ with respect to heritage assets is not clear.

Comment

Representation ID: 208301

Received: 30/01/2026

Respondent: Girton College

Agent: Turley

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 strands a), b) and c) must be met or if these are either / or situations.

Comment

Representation ID: 208302

Received: 30/01/2026

Respondent: Girton College

Agent: Turley

This increase in biodiversity net gain required for all major development is a significant additional cost which can impact viability and can compromise designs. Inevitably there will always be sites where such gains can be delivered. The site-specific circumstances can make a considerable difference to the ability to include for the creation of on-site habitats and BNG delivery. It is noted that the viability challenge has been recognised by central government. It is requested that the policy requirement should remain at the mandatory threshold of 10%.

Comment

Representation ID: 208303

Received: 30/01/2026

Respondent: Girton College

Agent: Turley

Giron 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 a hall 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.

Comment

Representation ID: 208304

Received: 30/01/2026

Respondent: Girton College

Agent: Turley

The College notes that the Government is progressing the Future Buildings and Homes Standards (FBS/FHS). The College has both residential and non-domestic buildings and so will be impacted by both. 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 wording should be inserted into the draft Policy to reflect space heating targets. Part D of draft Policy CC/NZ introduces the concept of an “Energy offset fund” to enable developers to make payments in lieu of failure to meet the energy and carbon standards. The College is concerned that the policy does not give any detail with respect to the cost of the fund and therefore do not believe this aspect of the draft Policy is sound and in accordance with Paragraph 59 of the NPPF which requires local plan policies to be accompanied by up-to-date viability assessments. The Whole Life Carbon Assessment undertaken should be proportionate to the nature and scale of the application.

Comment

Representation ID: 208305

Received: 30/01/2026

Respondent: Girton College

Agent: Turley

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) is relevant. The use of these technologies has considerable commercial and technical implications, particularly with respect to maintenance. The College therefore considers the term ‘unless demonstrated not practicable’ should be applied to decision making and all of the water efficiency targets presented.

Comment

Representation ID: 208306

Received: 30/01/2026

Respondent: Girton College

Agent: Turley

Girton 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 provision and timely upgrading of wastewater treatment and conveyancing infrastructure is a statutory responsibility of water companies, who are required to plan for and accommodate growth through the relevant regulatory and investment frameworks. The College considers that 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.