Draft Greater Cambridge Local Plan for consultation

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Comment

Draft Greater Cambridge Local Plan for consultation

About the Plan

Representation ID: 205096

Received: 30/01/2026

Respondent: Home Builders Federation

Representation Summary:

The respondent acknowledges that the new NPPF will have no weight until formally adopted, but once adopted, the local plan will be a material consideration and significant weight will need to be given to it in particular with regard to DM policies.

The draft NPPF aims to reduce development management policies that exceed national standards, which creates unnecessary burdens. Recommend council review local plan once new NPPF adopted deleting or amending any local plan policies that are inconsistent with the new NPPF to avoid lengthy discussions regarding their weight during application processes.

Attachments:

Object

Draft Greater Cambridge Local Plan for consultation

Policy S/JH: New jobs and homes

Representation ID: 205140

Received: 30/01/2026

Respondent: Home Builders Federation

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Representation Summary:

The housing requirement for Greater Cambridge is set at 48,195 homes over the period 2024-2045, with a minimum need that may require planning for additional housing due to unmet needs in neighbouring areas.
The Duty to Co-operate compliance statement lacks detail on whether neighbouring areas can meet their own housing needs, and there is concern that the focus has been on capacity rather than actual needs.
The removal of the Duty to Co-operate does not eliminate the need for effective cooperation or consideration of unmet needs from neighbouring areas, as outlined in the NPPF.
The assessment of housing needs should consider the potential for higher growth scenarios, especially in light of recent government investment aimed at overcoming barriers to growth.
Concerns were raised regarding reliance on larger household sizes and increased commuting as sustainable solutions for housing needs, suggesting these may not adequately support economic growth.
A higher growth scenario is recommended to better align housing supply with economic growth projections in Greater Cambridge.

Object

Draft Greater Cambridge Local Plan for consultation

Policy CC/NZ: Net zero carbon new buildings

Representation ID: 205174

Received: 30/01/2026

Respondent: Home Builders Federation

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Need for careful consideration of the outcomes from the current consultation and the final NPPF document, particularly regarding carbon emission and energy efficiency standards as outlined in PM13. If PM13 remains, policies would inconsistent with national policy.

The approach based on energy use is inconsistent with the Written Ministerial Statement (WMS) and the Planning and Energy Act, stating that local authorities should not set wholly new standards but can go beyond existing regulations.

Any local standards exceeding building regulations should be expressed as a percentage uplift of the Target Emissions Rate (TER) to avoid fragmentation of standards across different areas.

Concerns are raised about the viability of proposed standards, with evidence suggesting costs for meeting higher standards could significantly exceed current building regulations, necessitating further sensitivity testing in the viability study.

Important to assess the potential impact on housing affordability and the delivery rates of new homes, noting that higher standards may slow down development due to increased requirements for skills and materials.

The need for phased transitional arrangements is highlighted to ensure a steady build-up of skills for delivering higher standards, with concerns that a short transition could lead to quality issues and stalled programmes.

Any local requirements for sustainability must align with national technical standards, as stated in paragraph 159b of the NPPF, to maintain consistency in building performance assessment.

Concerns are raised regarding the requirement for whole life carbon assessments, citing potential inconsistencies and difficulties in achieving consistent assessments across developments, suggesting that this requirement should be deleted.

Object

Draft Greater Cambridge Local Plan for consultation

Policy CC/WE: Water efficiency in new developments

Representation ID: 205195

Received: 30/01/2026

Respondent: Home Builders Federation

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

HBF asserts that water companies are legally responsible for ensuring water supply for new developments, and developers should not be tasked with addressing infrastructure shortcomings.

HBF argues that it is inappropriate for the local plan to require developers to assess water supply capacity, as this falls under the statutory duties of water companies.

HBF recommends deleting paragraph 1 of the policy, stating that if the council cannot demonstrate sufficient water supply, the development level in the local plan is not deliverable.

HBF does not support 80 lppd noting the potential legal implications and risks of cross-contamination associated with water recycling systems, suggesting the council should not mandate given that there are no national standards.

HBF suggests that if a lower water standard is implemented, it should be averaged across the site to allow flexibility for homes with varying water usage.

Object

Draft Greater Cambridge Local Plan for consultation

Policy CC/CE: Supporting a circular economy and sustainable resource use

Representation ID: 205200

Received: 30/01/2026

Respondent: Home Builders Federation

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Part 1 of the policy is deemed unnecessary as the issue is already addressed in part 8 of CC/NZ.

There is no support in the NPPF for a presumption in favour of repairing or refurbishing existing buildings over demolition, which could deter developers and reduce windfall development on previously developed land.

The current policy could lead to lower densities and hinder developers' ability to meet standards for outdoor space, biodiversity net gain, and accessible units.

The proposed presumptions against demolition should be removed as they are not supported by national policy and contradict the aim to maximise development on previously developed land.

The requirement for a circular economy statement for developments of 150 or more dwellings is considered unnecessary; a brief statement in the Sustainability Statement would suffice.

Part 4's requirement for compliance with the RECAP Waste Management Design Guide is problematic as local plans cannot enforce compliance with documents not part of the development plan.

Object

Draft Greater Cambridge Local Plan for consultation

Policy CC/IW: Integrated water management, sustainable drainage and water quality

Representation ID: 205236

Received: 30/01/2026

Respondent: Home Builders Federation

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Part 6a of the policy incorrectly places the responsibility for demonstrating wastewater treatment capacity on developers, which should be the responsibility of the water provider.

Section 106 of the WIA 1991 grants an absolute right to connect to public sewers, and the respondent cites a Supreme Court case to support that sewerage undertakers cannot refuse connections based on potential overload.

The respondent believes it is inappropriate for local plans to require developers to assess water company local authorities and water companies should collaboratively plan for future wastewater demands, and if infrastructure is insufficient, the local plan cannot be deemed deliverable.

Object

Draft Greater Cambridge Local Plan for consultation

Policy BG/BG: Biodiversity and geodiversity

Representation ID: 205250

Received: 30/01/2026

Respondent: Home Builders Federation

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Do not support 20% Biodiversity Net Gain (BNG), stating that the draft NPPF suggests a maximum of 10% unless justified by evidence. No robust justification in the current evidence base for Greater Cambridge.

Residential development has not been a significant driver of biodiversity decline, citing agricultural practices as the primary cause.

Concerns are raised about the viability of achieving a 20% BNG, particularly if offsite delivery is required, which could significantly increase costs.

Policy's encouragement for offsite BNG delivery is unnecessary due to existing financial incentives and the spatial risk multiplier.

If the 20% requirement is retained, the policy should include flexibility to revert to the statutory minimum if it impacts development viability.

Object

Draft Greater Cambridge Local Plan for consultation

Policy BG/GI: Green and blue infrastructure

Representation ID: 205257

Received: 30/01/2026

Respondent: Home Builders Federation

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

HBF do not support the use of a specific greening factor metric of 0.4 for major developments, arguing that green infrastructure can be enhanced without such targets.

Concerns about the lack of assessment regarding the costs of the policy and its potential impact on the net developable area of sites, questioning the justification of the policy.

Need for clarification on how the urban greening factor requirement interacts with the 10% biodiversity net gain (BNG) requirement, noting potential overlaps.

Object

Draft Greater Cambridge Local Plan for consultation

Policy BG/TC: Improving tree canopy cover and the tree population

Representation ID: 205264

Received: 30/01/2026

Respondent: Home Builders Federation

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Concerns were raised regarding the urban green factor's impact on the developable area and its consideration of habitat types necessary for delivering Biodiversity Net Gain (BNG) on site.

Acknowledge the importance of maintaining existing trees and promoting street trees but argues against the arbitrary 30% canopy cover target, suggesting its deletion as it is not a statutory requirement.

In Part 3a, there is a need for flexibility in preserving trees, recommending the addition of 'where possible' to acknowledge situations where tree removal may be necessary due to development needs or health issues.

Object

Draft Greater Cambridge Local Plan for consultation

Policy BG/PO: Protecting open spaces

Representation ID: 205283

Received: 30/01/2026

Respondent: Home Builders Federation

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

This policy requires any replacement open space to be fully available before the area of open space being replaced can be redeveloped. This is not an effective policy as in many cases it will not be practical or possible to replace an open space being redeveloped in the first instance. The timing of any replacement will need to take into account the delivery and phasing of a development and given that the replacement will be a condition of the permission granted there is sufficient certainty that replacement open space will be provided as part of the development.

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