Greater Cambridge Local Plan: Proposed Submission

Amend CC/RE to give explicit positive weight to dual-use schemes that demonstrably deliver agricultural yield, animal welfare, and biodiversity outcomes. Stop treating agricultural land retention solely as a mitigating condition against the presumed loss of farming capacity.

Point 1(d) and paragraph 4.48 inaccurately treat renewable development on agricultural land as an inherent negative trade-off requiring "significant sustainability benefits" to outweigh the loss. This understates real-world evidence: dual-use schemes can actively improve crop yields in hot/dry conditions, enhance livestock welfare through shading, and deliver genuine biodiversity gains (e.g., 41% increases in Suffolk Wildlife Trust studies). Dr Jonathan Scurlock, the NFU's Chief Adviser for Renewable Energy, has stated in his professional capacity that the NFU encourages multi-purpose land use.

Amend Policy CC/FM to generally exempt change of use applications from the sequential test, ensuring consistency with NPPF (2024) paragraph 176 and Footnote 62. Retain targeted restrictions specifically for changes of use in Flood Zones 3a/3b and areas of high surface water risk, matching the Environment Agency's recommendations.

Point 1 is not consistent with national policy because it universally applies the sequential test to "change of use" applications. NPPF (2024) paragraph 176 and Footnote 62 explicitly exempt most changes of use and householder extensions from this test. While some changes (e.g., basement care homes) do increase flood risk, the Regulation 19 text fails to reflect the targeted approach recommended by the Environment Agency, resulting in sweeping inconsistency.

Clarify point 6(a) to state explicitly that an agreement to connect is not sufficient evidence of infrastructure capacity. Require confirmed wastewater treatment capacity—or a binding commitment and funded programme to provide it—to be submitted and independently verified by the planning authority before development relying on that capacity can proceed.

Point 6(a) is not positively prepared or effective because it conflates securing a water connection with demonstrating actual wastewater treatment capacity. Paragraph 4.36 states applicants need only "secure a connection" with Anglian Water. Since water companies have heavily restricted legal grounds to refuse connections, a connection agreement does not establish that treatment capacity exists when required. Given the Plan's scale of growth and acknowledged infrastructure constraints, relying on connection paperwork risks allocating and approving development without demonstrating that necessary wastewater infrastructure will be available to support sustainable development.

Add a fallback mechanism for point 1(a) modelled on CC/NZ Part D. Where on-site water reuse or recycling is blocked by absolute regulatory or technical constraints, require a financial contribution to equivalent off-site water savings. This ensures the net ambition survives even when the on-site route is unlawful.

This policy is not effective because point 1(a) mandates water reuse or recycling to achieve 80 l/p/d without any practicability fallback. The Drinking Water Inspectorate has actively blocked greywater recycling models locally at Eddington. While non-residential targets have an "unless demonstrated not practicable" test, residential schemes facing absolute regulatory roadblocks have no lawful route to compliance, making the policy undeliverable.

Retain Cambridge's robust TM54/PHPP-based approach, but add specific text explaining why these models qualify as an "other approved calculation methodology" under PM13. Explicitly linking this to NPPF paragraphs 7 and 8(c) will ensure the Plan's compliance with national policy is robust and explicit.

The policy is not explicitly consistent with national policy. PM13 requires stricter local energy standards to be expressed as a percentage improvement on SAP "or other approved calculation methodology.". While we support the Plan's ambitious use of TM54/PHPP modelling over SAP (which only checks legal minimums), the Plan fails to explicitly categorize this modelling as an approved alternative. This leaves its compliance with PM13 implicit rather than explicit.

Add a maintenance mechanism (via condition or obligation) for CC/DC's overheating-mitigation green infrastructure. This should apply to all development since CC/DC has no major-development threshold, but must apply at least for major development per national precedent (NPPF 182(c)). Include a mandatory 12–36 month aftercare and watering period with species guidance for heat resilience.

This policy is not effective because it lacks a maintenance mechanism for green infrastructure intended as overheating mitigation (e.g., green roofs, tree canopy). Mitigation delivered at construction often fails to persist; national data shows ~22% of saplings are lost to heat scorch and drought stress, meaning watering-only maintenance is insufficient. Furthermore, national policy (NPPF 182(c)) already acknowledges this gap by requiring maintenance arrangements for SuDS.

Strengthen paragraph 6 by explicitly specifying monitoring frequency and assigning clear responsibility for oversight. The policy must explicitly reference the 30-year management duration mentioned in paragraph 5.15. Finally, set out exactly what enforcement action will follow a breach of these requirements, together with confirmation of the local authority resourcing currently in place to effectively carry out this enforcement.

We strongly support this policy's ambition for a 20% biodiversity net gain for major development, which is well justified. However, this policy is not effective because paragraph 6 fails to specify how habitat enhancement measures will be monitored in practice, how frequently, by whom, or what enforcement action follows non-compliance. The Councils' reliance on after-the-fact reporting (such as the Biodiversity Duty report) does not address how non-delivery will be proactively caught or corrected, creating significant compliance risks.

The Councils must confirm what formal mechanisms exist to ensure Policy BG/GI's strategic priorities carry real weight in external decisions. This could include securing statutory consultee status, establishing a memorandum of understanding with the Greater Cambridge Partnership, or requiring that the environmental assessments for projects like CSET and East West Rail explicitly demonstrate consistency with this policy's priorities before proceeding.

This policy is not effective because major infrastructure progressed outside the Local Plan can bypass and undermine its priorities. The Gog Magog Hills are a strategic green infrastructure priority, yet the proposed CSET busway threatens this area. The Councils assert CSET is outside Local Plan processes, reflecting a structural gap also seen with East West Rail. A policy cannot be effective if major infrastructure capable of undermining the Plan's own green priorities is completely outside its control.

Any strengthening of the Operation and Maintenance Plan's monitoring and enforcement provisions—as requested in our representations regarding Policy BG/GI—must be extended equally to apply to all green infrastructure secured under this policy.

We support this policy, but it cannot be effective because green infrastructure delivered through the Urban Greening Factor relies entirely on the Operation and Maintenance Plan under paragraph 3. As raised regarding Policy BG/GI, this mechanism includes no provision for checking compliance and states no consequence for a failure to maintain the infrastructure. Without functional enforcement, the policy's aims are undermined

Confirm exactly how the Councils intend to apply Schedule 14's anti-degradation provision in practice. This must include establishing a proactive baseline dataset—such as routine aerial imagery comparisons—so that prior habitat conditions can be accurately evidenced. This will ensure the existing statutory protection is practically enforceable against pre-emptive clearance, rather than merely theoretical.

This policy is not effective as it fails to prevent pre-application clearance. Trees and hedgerows can be removed with no planning oversight simply by acting before an application is submitted. We are aware of local mature orchards pre-emptively felled prior to sale unrecorded. While Schedule 14 of the Environment Act 2021 allows setting the baseline at pre-degradation value, neither this policy nor BG/BG references how such evidence will be captured or applied locally.