Draft Greater Cambridge Local Plan for consultation

Comment

Representation ID: 211262

Received: 30/01/2026

Respondent: Terra Strategic

The strategy is heavily reliant on carrying forward previous allocations from the adopted Plans. New strategic scale allocations are
proposed (a) within the Cambridge urban area; (b) on the edge of Cambridge; (c) at New Settlements; (d) In the Rural Southern
Cluster and (e) In the Rest of the Rural Area.
The remainder of the development needs are to be met at smaller sites within; a. Cambridge urban area; and b. the rural area,
where further development is to be limited with allocations for jobs and housing focused on Rural Centres and Minor Rural
Centres, and the settlement hierarchy policy providing for windfall development for different categories of village consistent with
the level of local service provision and quality of public transport access to Cambridge or a market town.
National Policy sets out a requirement for small and medium sized sites to be identiifed to accommodate at least 10% of the
overall housing requirment on sites no larger than one hectare, unless it can be shown that there are strong reasons why the 10%
target cannot be achieved.

Comment

Representation ID: 211263

Received: 30/01/2026

Respondent: Terra Strategic

This policy groups settlements into categories to reflect their scale, characteristics and sustinability and is used to guide
development to the most sustainable locations. The policy also sets the scale of development for unallocated (windfall) sites that
would be potentially be suitable in each category of settlement.
There are 6 Settlement Tiers proposed with Willingham is identiifed as a Minor Rural Centre, this is consistent with its current
status in the adopted Local Plan.
The Consultation Document sets out that within Minor Rural Centres, residential development and redevelopment up to an
indicative maximum size of 30 dwellings will be permitted within the defined development extents. There is no justification for
the arbitrary figure of a maximum of 30 dwellings.
This limits the level of growth that the Minor Rural Centre could achieve and may also lead to less efficient use of land which
would be contrary to national planning policy which requires proposals to make the most effcient use of land

Comment

Representation ID: 211264

Received: 30/01/2026

Respondent: Terra Strategic

The proposed restriction on water use to 80 litres per person per day (LPPPD) in developments of 100+ dwellings, and 90-100
litres per person per day in developments of less than 100 dwellings is unduly onerous and is not consistent with national policy
requirements.
By Building Regulation standards, the current restriction is 125 litres per person per day (LPPPD) with an optional uplift / reduction
to 110 litres per person per day.
The 'Water Ready’ report published earlier this year by the Future Homes Hub outlines a framework for new homes to achieve
90 LPPPD by 2035.
Draft Policy CC/IW should be amended to reflect National Building Regulations Standards of 125 LPPPD

Comment

Representation ID: 211265

Received: 30/01/2026

Respondent: Terra Strategic

Terra are concerned that this Policy does not reflect the updated Planning Practice Guidance (“PPG”) (updated 17 09 2025)
relating to sequential testing. Policy CC/FM states that development proposals will be supported where the sequential test has
been passed. However, this is not in line with the updated PPG, which states that a proportionate approach should be taken,
applying NPPF Paragraph 175.
The PPG makes clear that where a site-specific flood risk assessment demonstrates clearly that the proposal would ensure that
occupiers and users would remain safe from surface water flood risk for the lifetime of the development (without increasing flood
risk elsewhere) a sequential test is not required. Terra therefore request that this Policy be amended to reflect the updated PPG.

Comment

Representation ID: 211266

Received: 30/01/2026

Respondent: Terra Strategic

Terra supports the contention that for housing density to be appropriate it should reflect the local character and context.
Making the efficient use of land through increasing densities is an existing national planning policy requirment. The draft NPPF
issued on the 16th December 2025 emphasises the need for intensification in appropriate sustainable locations through building
on infill plots, building higher and at a greater density on corner plots and in the more sustainable locations. The emerging Local
Plan should align with national policy in order to assist Greater Cambridgeshire in meeting their housing requirement.
Terra note that no density figures have been provided within the draft policy. Whilst it is acknowledged that character and local
context should inform appropriate density levels, the absence of any minimum figures creates uncertainty at the early planning,
feasibility and land valuation stages. The inclusion of broad density guidance as part of the policy’s design-led and context-led
approach, would improve consistency in decision-making, ensure that sites come forward with proposals which make efficient use
of land in line with national planning policy.
Therefore, it is recommended that draft Policy GP/HD is amended to include indicative density ranges that provide clarity for
developers and decision-makers

Comment

Representation ID: 211268

Received: 30/01/2026

Respondent: Terra Strategic

Policy H/SS is in line with paragraph 135 (f) of the NPPF 2024, which states that developments should create places that are safe,
inclusive and accessible and which promote health and well-being, with a high standard of amenity for existing and future users.
The requirement for all new residential developments to meet and wherever possible exceed, the residential standards set out in
the Governments Technical Housing Standards – Nationally Described Space Standard (NDSS) is not supported by Terra. The
requirement for NDSS compliance on all new dwellings is overly prescriptive and does not comply with National Guidance. In
addition, this requirement is not supported by local evidence and would place additional financial burdens on developments which
could affect viability of developments.The policy also sets out requirements for accessible and adaptable homes requiring all new build houses to be designed in
accordance with Building Regulations M4(2) standard, this is noted and in line with the separate legislation contained in Building
Regulations.

Comment

Representation ID: 211269

Received: 30/01/2026

Respondent: Terra Strategic

Terra support the inclusion within the Local Plan of a specific policy relating to providing specialist housing (within both Use
Classes C2 and C3) to support a variety of groups such as older people, disabled people and those that need specilaist supported
housing. The policy could go further and allocate suitable sites for specialist housing as set out below.
There is a need for the Plan to take a proactive approach given the pressing need for housing for older people. The PPG, Planning
Policy Guidance: Housing for Older and Disabled People, emphasises that the need to provide housing for older people is
‘critical’. People are living longer lives and the proportion of older people in the population is increasing.

Comment

Representation ID: 211584

Received: 30/01/2026

Respondent: Terra Strategic

National Policy sets out a requirement for small and medium sized sites to be identified to accommodate at least 10% of the overall housing requirement on sites no larger than one hectare, unless it can be shown that there are strong reasons why the 10% target cannot be achieved.

The proposed Development Strategy should include an allowance for small and medium size sites in line with Paragraph 73 of the NPPF to ensure a mix of sites are provided for in the Plan. This sentiment is continued by draft Policy HO6 of the draft NPPF consulted on in December 2025.

There are no strong reasons why the 10% target for allocating small and medium size sites cannot be achieved in Greater Cambridgeshire. This is a serious flaw of the current Consultation Plan.

By not including a diverse range and mix of sites the Development Strategy conflicts with the NPPF and
leaves the future supply of sites vulnerable. This will be based on existing commitments which have not delivered in the current Plan as anticipated, new allocations, which may face similar issues with delivery, and a windfall allowance which provides no certainty of sites coming forward.

Comment

Representation ID: 211585

Received: 30/01/2026

Respondent: Terra Strategic

The Draft Plan’s failure to include the allocation of small sites will also impact significantly on the vitality of rural communities preventing them to grow, thrive and support existing local services, which is a key objective of the NPPF and the emerging NPPF.

The Draft Plan sets out that villages should play only a limited role in meeting future development needs, as such only a limited number of smaller new sites are proposed to be allocated in what the Councils consider to be the more sustainable villages.

Terra consider that a higher level of growth should be attributed to the rural villages to maintain their vitality, to support existing services and to ensure a suitable supply of homes, including specialist housing, is provided to meet the needs of the existing residents and future generations.

Object

Representation ID: 211586

Received: 30/01/2026

Respondent: Terra Strategic

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

There is no justification given within the policy wording or the supporting text to justify the figure of a maximum of 30 dwellings. This unduly limits the level of growth that these settlements could provide and would also conflict with national planning policy, in particular Paragraph 83.

Terra consider that rather than having an arbitrary figure written in policy, the level of development should be of an appropriate scale to the size of the settlement and should relate to the character of the area, with any judgements made through the planning application process.