Greater Cambridge Local Plan: Proposed Submission

CIP welcomes the removal of former paragraph 1 which has addressed our previous Regulation 18 representations.

Policy H/AH sets out the requirements for affordable housing delivery on new housing developments,
including specifying the size of developments on which affordable homes will be provided and the proportion of affordable homes required, and setting out the tenures of affordable housing required to address identified needs
Part 5 of the policy stipulates affordable housing tenures for schemes of 10-14 dwellings and then 15 dwellings or more.
CIP welcomes that the policy wording has been amended to allow for 25% shared ownership homes “or other affordable homes providing a route to homeownership” in part 2 of Policy H/AH as requested under the Reg 18 reps.

CIP are in support of the policy change including to part b which address our reg 18 comments.

As stated in our previous reg 18 comments, we would request that the policy includes “and/or” is including in the wording of part 1a given this western boundary does not fall within CIP ownership and is highways land.

CIP welcome the updates that have been made to allocation following our previous reg 18 comments. However as stated in our previous reg 18 comments, we would request that the policy includes “and/or” is including in the wording of part 1a given this western boundary does not fall within CIP ownership and is highways land.

CIP request that part (a) be amended to allow for justified tree removals through an Arboricultural Impact Assessment.
CIP also request that the site allocation capacity is amended to 77 homes to reflect the latest site proposals and associated site capacity analysis.

CIP welcome the updates that have been made to allocation following our previous reg 18 comments. However as stated in our previous reg 18 comments, we would request that part (a) be amended to allow for justified tree removals through an Arboricultural Impact Assessment.
We would also request that the site allocation capacity is amended to 77 homes to reflect the latest site proposals and associated site capacity analysis.

CIP request part (b) of the allocation be reworded as follows:
“Development must retain the existing mature trees Mature trees on the site should be retained. Any tree removals must be justified through the submission of an Arboricultural Impact Assessment with appropriate replacement planting thereafter secured.”

CIP request that part (c) of the policy be deleted.

CIP request part (d) should read as follows:

“Archaeological investigation and potential mitigation will be required to identify the presence and significance of possible archaeological remains across the site. In the first instance archaeological investigation will be required via Desk Based Assessment.”

CIP welcome the update to the allocation wording following the previous reg 18 comments.
However not all of the previous reg 18 comments were included and it is requested these are included as reinserted below.

• Part (b) seeks the retention of existing mature trees. CIP supports the aspiration to retain mature trees that are worthy of retention. There are however instances where some mature trees do need to be removed to facilitate redevelopment. This applies on this site where the three London Plane trees in the centre of the site need to be removed to facilitate development. The many other mature trees around the perimeter can be retained.
Such proposals need to be considered on their own merits. We would therefore suggest that part (b) of the allocation be reworded as follows:
“Development must retain the existing mature trees Mature trees on the site should be retained. Any tree removals must be justified through the submission of an Arboricultural Impact Assessment with appropriate replacement planting thereafter secured.”
• Part (c) requires development proposal to mitigate the impacts of the existing electricity substation on residential amenity and outlook. CIP is not aware of any existing amenity concerns arising from the substation. Notwithstanding this, CIP accepts the need to positively design for essential apparatus such as substations within the development. It is however not considered that this needs to be stipulated within the policy. This is a matter that should be picked up through the consideration of the planning application as will be the case for all other allocations in the plan. CIP would therefore suggest that part (c) of the policy be deleted.

• Part (d) requires archaeological investigation. CIP supports this. It is however noted that other allocations, such as that at Davy Road (S/C/DR) make it clear that in the first instance this will require a desk based assessment. We would request that similar wording be applied here, especially given the difficulty of undertaking any form of intrusive investigations around existing buildings and trees. Part (d) should therefore read as follows:

“Archaeological investigation and potential mitigation will be required to identify the presence and significance of possible archaeological remains across the site. In the first instance archaeological investigation will be required via Desk Based Assessment.”

CIP request the existing site capacity is amended to 32.

CIP request the wording of part b is amended to be similar to allocation S/C/BRN: Land at Barnwell Road and Newmarket Road, as proposed below:

Design of buildings, in regard to height, style and materials, must respond positively to the local character and setting to ensure no unacceptable adverse impacts on the Kite Conservation Area and the setting of designated assets. Tested and refined through a design led approach, development should broadly reflect the local prevailing building heights

CIP welcome the updates from the previously submitted reg 18 comments. However, the existing quantum, of homes is incorrect and should be 32 homes plus a formers warden’s house rather than 34 homes. Therefore, the loss difference would be 4 units.

We also note the inclusion of part b. We would request the wording is amended to accommodate for the variation in surrounding building heights (i.e the Grafton Centre to the south) and any final design solution to be led by the planning application process.

We would suggest the wording of part b is similar to wording included in allocation S/C/BRN: Land at Barnwell Road and Newmarket Road, as proposed below:

Design of buildings, in regard to height, style and materials, must respond positively to the local character and setting to ensure no unacceptable adverse impacts on the Kite Conservation Area and the setting of designated assets. Tested and refined through a design led approach, development should broadly reflect the local prevailing building heights

To reword part B as follows:
“The mature street trees on Newmarket Road & Peverel Road frontages should must be retained and incorporated into development proposals for the site. Any tree removals must be justified through the submission of an Arboricultural Impact Assessment with appropriate replacement planting thereafter secured.”

CIP also note the addition of text to part c which references prevailing character and heights of 2 or 3 storeys. CIP request this reference to 2 and 3 storeys is removed given an application for taller building heights has been approved.

As per the reg 18 comments, Part (b) - Seeks to retain mature trees on Newmarket Road and Peverel Road frontages. CIP supports the aspiration to retain landscape features that are worthy of retention. There are however instances where some features may need to be removed to facilitate redevelopment. CIP suggests the policy be reworded as follows:
“The mature street trees on Newmarket Road & Peverel Road frontages should must be retained and incorporated into development proposals for the site. Any tree removals must be justified through the submission of an Arboricultural Impact Assessment with appropriate replacement planting thereafter secured.”
CIP also note the addition of text to part c which references prevailing character and heights of 2 or 3 storeys.
As the Council is aware, CIP controls part of the draft allocation (land parcels either side of Barnwell Road) and has already submitted a planning application for the land, application 23/04687/FUL. The application has been approved and the development is now being constructed. The approved development for these two land parcels includes 120 new homes and 495 sq m of commercial floorspace. Given the heights have been agreed as part of this application and which are higher than the surrounding heights, we would suggest the reference to 2 and 3 storeys is removed.

Proposed updated policy wording as follows:
To protect and enhance water quality, all development proposals must demonstrate that:

6a.there is adequate wastewater conveyancing infrastructure to serve the whole development, or an agreement is in place with the relevant service provider to ensure the provision of the necessary infrastructure to support the capacity for wastewater treatment prior to the occupation of the development (where development is being phased, this must be demonstrated for each phase before first occupation);

Policy CC/IW establishes the principles for water management including ensuring proposals provide appropriate sustainable drainage systems alongside protecting and enhancing water quality.
Criteria 6 of Policy CC/IW concerns water quality. Specifically, part a of paragraph 6 states that all development proposals must demonstrate there is capacity for wastewater treatment and adequate wastewater conveyancing infrastructure to serve the whole development.
CIP supports in principle the importance of forthcoming proposals to ensure and deliver appropriate water management but request that the wording as drafted in part a of paragraph 6 is updated to ensure it is not the sole responsibility of the developer to demonstrate sufficient capacity.
While this comment was made at the Regulation 18 consultation, CIP’s requested changes have not been made to the policy.

It is further requested that the word ‘exceptional’ is removed in the wording of para 2d Policy CC/CE. [

Policy CC/CE sets out how development proposals should incorporate circular economy principles into schemes including for demolition and construction, and operational waste management.
Para 1 states the importance of opportunities to reduce embodied carbon. Para 2 states there will be a presumption of retention and reuse of existing buildings over demolition. Justification for demolition will only be accepted if proposals can accord with set criteria listed out under paras 2 a-c (e.g. disrepair / energy efficiency) or compliance with para 2d in terms of benefits of demolition outweighing carbon savings.
Paras 3 concerns operational waste management with paras 4-5 requiring the provision of circular economy statements for residential development of 150 dwellings or more.
CIP in principle supports the importance of waste minimisation. However, it is requested that in the wording of part 2d that the word ‘exceptional’ is removed to accommodate for other site considerations and viability (e.g. delivery of affordable housing and infrastructure, compliance with modern building standards or minimum amenity spaces as set out under draft policy Policy H/SS).
While this comment was made at the Regulation 18 consultation, CIP’s requested changes have not been made to the policy.
We support the principle of prioritising refurbishment and circularity, but greater clarity is needed to recognise that refurbishment opportunities are often constrained by tenure, heritage protections and the practical limitations of converting many non residential buildings, where viability and building form frequently make demolition the only realistic option. We therefore consider that circularity requirements should be aligned with existing policy thresholds and underpinned by clear, nationally consistent methodologies—ideally through a future Part Z of the Building Regulations—to ensure assessments are deliverable, proportionate and integrated with whole life carbon policy.
While this comment was made at the Regulation 18 consultation, CIP’s requested changes have not been made to the policy.