Draft Greater Cambridge Local Plan for consultation

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Comment

Draft Greater Cambridge Local Plan for consultation

Great places

Representation ID: 202662

Received: 28/01/2026

Respondent: Mole Architects

Representation Summary:

There should be a clause allowing for increased scale, density, and form in new developments, enabling them to deviate from existing low-density patterns while maintaining good quality.

Policies that mandate car-free streets may lead to negative outcomes, such as rear parking; a balance should be struck to create multi-use streets that accommodate parked cars.

Encouraging robust and flexible building designs is positive, but the current approach may overlook the adaptability of various building types, particularly those that are less adaptable.

There is a lack of emphasis on material quality in the policies regarding skyline and tall buildings, which should be addressed.

Full text:

1/ HIGHER DENSITIES AND BUILDING FORM
how to allow for good quality development that does not follow existing patterns of development in terms of scale and form? The following are perfectly sensible, but should there be a clause that permits an increase in scale, density and form that would allow new developments to be denser than existing? It is often very hard to do something other than follow the scale and form of an existing context as there are clear policies that expect this. The exception ( last para) could be broader than this- many areas outside of those described have very low density detached or semi detached houses and new developments could be both good, appropriate, but deviate from the local character

Policy GP/PP: People and place responsive design
proposals are required to sustain and enhance the unique qualities of their local context and the
area. Proposals will be supported that… enhance character by
ii. Using appropriate local characteristics to inform the siting, massing, scale, form, materials and landscape design of new development.

Policy GP/QD: Achieving high quality development
proposals will be expected to demonstrate how they have addressed the following design principles and requirements:
a. Demonstrate a clear understanding of the character of the built, historic and natural environment, using this understanding to inform design that complements local character and distinctiveness;

Policy GP/HD: Housing density
proposals must make efficient use of land through applying appropriate development densities that reflect local character and context through a design led approach. In determining an appropriate density, a development proposal will need to demonstrate the following requirements:
a. Provides a balanced mix of housing types and sizes;
b .Positively responds to the prevailing character of the area, topography and the wider landscape and/or townscape setting;
c. Protects and enhances heritage assets and their setting through a thorough understanding of the impacts of development on their significance;
d. outlook, daylight, sunlight, noise and disturbance can be satisfactorily addressed; and
e. Other considerations such as car and cycle parking and waste storage can be suitably provided and managed.

Subject to satisfactorily demonstrating the above, higher density development that exceeds local prevailing densities will be supported provided the site is:
f. Within walking and cycling distance of Cambridge City Centre or a Town, District or Local Centre;
g. In close proximity to active travel provision including high quality cycling infrastructure; and
h. Well served by existing or proposed high quality public transport such as the Cambridgeshire Guided Busway, a transport interchange or railway station.


2/ CAR PARKING ON STREETS
Policies that expect streets with no cars can have poor consequences and lead to rear parking. Which is worse? We frequently decry the use of wide boulevards aimed at vehicle movements, rather than the creation of real streets for multiple uses. I don’t see anything wrong with ‘the perception of cars’ in fact fantastic parts of nearly every town has cars parked in the streets.

Policy GP/QD: Achieving high quality development
d. Create safe open spaces and active streets, by providing highway layouts that incorporate well-integrated car parking and landscaping. Proposals should avoid the perception of a car-dominated environment and prioritise safe and convenient pedestrian and cycle movement;

3/ EMBODIED CARBON
To have clauses that encourage robust and flexible buildings is good. But it’s too wholly to be of any use- every building type has been shown to be adaptable; in fact probably the least adaptable is prefabrictaed timber frame, which I suspect is encouraged elsewhere! I’m not sure what the answer is!
Policy GP/QD: Achieving high quality development
l. Create robust and adaptable building forms that can be repurposed over time, helping to extend their lifespan and reduce the carbon impacts associated with demolition and reconstruction.

4/ TALL BUILDINGS
Nothing in here about material quality:
Policy GP/ST: Skyline and tall buildings

Comment

Draft Greater Cambridge Local Plan for consultation

Homes

Representation ID: 202665

Received: 28/01/2026

Respondent: Mole Architects

Representation Summary:

The respondent expresses concern that the requirement for balconies as integral elements of building design may impact the viability of affordable housing.

The respondent questions the feasibility of M4(3) lift requirements for small apartment buildings, suggesting that exceptions should be allowed based on site-specific circumstances.

There is a call for better enforcement and understanding of self and custom build homes, questioning the existence of a genuine market.

The respondent warns that the co-living policy may lead to sub-standard accommodation and suggests setting a maximum allowable cost to prevent market issues.

Concerns are raised regarding the Draft NPPF's restrictions on isolated homes in the countryside, suggesting that the criteria may be outdated and unnecessarily limiting.

Full text:

5/ BALCONIES
Bravo
This’ll affect the Council’s CIP affordable housing as we are endlessly told it is unviable..
Policy H/SS: Residential space standards and accessible homes
e. provide balconies that are designed as integral elements of the building's architecture and not appear as bolt-on additions, with semi-inset or inset balconies encouraged, to support cohesive facade compositions and support usability

6/ LIFTS- M4 (3)


Accessible and adaptable homes
Should this be questioned? It effectively means that small apartment buildings won’t be built, as costs for lifts (both capitol and service charge costs) just don’t stack up in small developments. So we will see more small houses, or larger apartment buildings with internal corridors. I understand the desire, but can there be some nuance and exceptions be expressed as a percentage – in the same way that there’s a reqirement for 5% M4(3) for instance. The Draft NPPF sets out an expectation of 40% M4(2) or M4(3)

7. All new build residential units (including residential annexes) must be designed to be accessible and adaptable in accordance with the
M4(2) standard.
9. Exceptions to meeting the M4(2) and M4(3) standards as set out above will only apply where robust justification is provided that sets out how site- specific circumstances, in addition to the other requirements for the development, make the proposed development impractical, unachievable or unviable.

7/ SELF AND CUSTOM BUILD HOMES
Bravo. But this already exists and has not been enforced. What can be done to understand this scenario better? Is there a genuine market? Has it been given a chance to exist? How can the Council find out and be pro-active?
Policy H/CB: Self and custom build homes-

8/ CO-LIVING
I am concerned that this well-intentioned policy could produce a rash of sub-standard accommodation. The best examples of co-living are clearly liked and there’s a market for them. However the reality is that for developers co-living simply increases a return in £/sqft; I have sat in meetings wheere the calculation is worked out. Every developer will want to do this, and before we know it the cost of land will move up to reflect the new policy, and then everyone will have to do it to deliver a profit- it’ll be baked into the land price. Two things will happen: the ‘good’ developers that deliver this as a quality product won’t be able or interested to fulfill the market; the numbers of people able and willing to pay the enhanced £/ft value will diminish and the developers will be looking for ways to cut costs in delivery to make it work financially.

Could there be an allowable maximum? Hpw does this work with Use classes?

Policy H/CO: Co-living-

9/ HOUSES IN THE COUNTRYSIDE
ISOLATED HOMES

The Draft NPPF related to ‘isolated homes’ ( the existing Para 84)
1. Development proposals for isolated homes in the countryside should only be supported where one or more of the following circumstances apply:
The design is of exceptional quality, in that it:
i is truly outstanding, reflecting the highest standards in architecture, and would help to raise standards of design more generally in rural areas; and
ii would significantly enhance its immediate setting, and be sensitive to the defining characteristics of the local area.

The Cambs Draft policy includes the clause in red below, which seems an unecessary restriction, and relates to a now outdated definition in the NPPF

Policy H/DC: Dwellings in the countryside-
single new bespoke dwellings of exceptional quality will be permitted in the countryside providing all of the following criteria are met:
a. The dwelling would reflect the highest standards in architecture, being recognised as truly outstanding or innovative;
b. The dwelling would significantly enhance its immediate setting;
c. The nature and size of the site, and the design of the dwelling, its landscaping and location on site are sensitive to the defining characteristics of the local area and to wider views; and
d. That there are no existing dwellings on the site capable of being replaced.

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