Greater Cambridge Local Plan: Proposed Submission

Draft policy BG/BG concerns biodiversity uplift and enhancement. Part 1 requires all development to provide a minimum of 10% BNG (biodiversity net gain) against the baseline BNG value. Part 2 requires all major development to provide a minimum of 20% uplift. Part 3 outlines the requirements for offsite BNG provision where required, with the remaining criteria then setting out the principles for ensuring the adequate protection of biodiversity and geodiversity
CIP supports in principle the importance of biodiversity protection and associated enhancement around the Greater Cambridge Area.
The 20% uplift required for major developments as set out under part 2 of draft policy BG/BG reflects the guidance contained in the SPD and is the uplift that current CIP schemes adhere to. .
In tandem with other policy considerations set out draft GCLP policies, namely Policy BG/TC, BG/GI, Policy BG/EO, Policy WS/NC, Policy H/SS, these policies in conjunction restrict opportunities for density uplift and achieving the housing numbers as set out under the draft site allocations listed in draft policy S/LAC: Other site allocations in Cambridge and draft policy S/AMC/EB: East Barnwell.
There are also risks for site viability to accommodate for these considerations, essential in delivering affordable housing requirements (draft policy H/AH) and infrastructure delivery (draft policy I/ID).
It is considered that draft Policy BG/BG needs to better align with other draft GCLP policies and housing requirements.

Policy BG/GI of draft GCLP seeks to protect and enhance green infrastructure, and identifies a number of strategic green infrastructure initiatives.
CIP’s Regulation 18 representations to this policy primarily focussed on the Urban Greening Factor (UGF) elements of the policy. These have now been removed from draft Policy BG/GI and now form a separate new policy (BG/UGF: Urban Greening Factor).
We note that there have been several other changes to the policy text.
Section 2 of the policy now states that planning applications for major development must submit a Infrastructure Plan, and that at the outline planning stage must also provide a Green Infrastructure Statement, that demonstrates how green infrastructure has been integrated into the design approach at an early stage.
Section 3 of the policy previously stated that strategic development will be encouraged to seek accreditation under the Building and Nature Standards. It now encourages developments of 100 dwellings or more than 5,000 sqm or more, to apply for accreditation.
A new Section 6 of the policy requires that a GI Operation and Maintenance Plan must be submitted to and approved in writing before any development is occupied, and that the approved plan shall thereafter be implemented for the lifetime of the development.[EG4.1]
Policy DM2: Information Requirements in the updated NPPF (2026) notes that where local validation lists proposed additional information requirements, any such requirement “should be proportionate to the scale of development and its potential impact. Where appropriate, the requirements should clearly distinguish between what is required for major, medium and other types of development proposals”.
Policy PM13: Setting standards of the NPPF (2026) further notes that when setting quantitative standards through development plan policies, such standards “should provide clarity and a high degree of certainty about the requirements that relevant development proposals are expected to meet”.

To request that the requirement to achieve a greening factor of 0.4 is more aligned with other policy requirements in order to accommodate for feasibility in achieving green infrastructure initiatives having regard to viability and other policy considerations including the green infrastructure provisions as set out under Policy BG/GI.

This is a new policy that previously formed part of Policy BG/GI: Green Infrastructure.
CIP’s Regulation 18 representations to that policy primarily focussed upon its Urban Greening Factor (UGF) requirements.
Section 1 of the policy states that all major development proposals must include the latest version of Natural England's Urban Greening Factor User Guide and User Guide Spreadsheet, demonstrating how the development will achieve Urban Greening Factor scores of at least:
• 0.3 for predominantly commercial development;
• 0.4 for predominantly residential development within Cambridge Defined Development Extent; or
• 0.5 for predominantly residential development outside Cambridge Defined Development Extent, except where it can be demonstrated that more than 50% of the site area equates to accessible greenspace.
The latter 0.5 requirement was not previously included within the earlier Regulation 18 policy.
CIP supports in principle initiatives to improve the green infrastructure network around the Greater Cambridge Area. However, it is considered that achieving a greening factor of 0.4 for residential development within Cambridge may compromise the ability to deliver viable developments when balancing against other policy requirements as set out in the draft GCLP, namely Policy BG/BG, Policy BC/TC Policy BG/EO, Policy WS/NC, Policy H/SS. These restrict opportunities for density uplift and achieving the housing numbers as set out under the draft site allocations listed in draft policy S/LAC: Other site allocations in Cambridge and draft policy S/AMC/EB: East Barnwell.
There are also risks for site viability to accommodate for these considerations, essential in delivering affordable housing requirements (draft policy H/AH) and infrastructure delivery (draft policy I/ID).
It is considered that draft Policy BG/UGF needs to better align with other draft GCLP policies and housing requirements, in order to ensure that the initiatives are implemented.

It is considered that draft Policy BG/TC needs to better align with other draft GCLP policies and housing requirements, in order to ensure that the initiatives are implemented. Due consideration must be given to the potential impact that a high level of tree cover could have on density and housing quantum, viability and balancing for blue/grey infrastructure delivery.

Policy BG/TC of the draft GCLP seeks to improve tree canopy cover and afford protection for existing trees with criteria set out for proposals to refer to for arboricultural considerations.
The Regulation 18 version of the policy required that major developments achieve a future tree canopy cover of at least 30%, demonstrated through a Tree Canopy Cover Assessment.
CIP supported in principle the protection of existing trees and initiatives to promote further planting. However, it was considered that the requirement to provide a minimum of 30% tree canopy cover was too onerous and was based on a recommendation by the Woodland Trust rather than a statutory target. It pointed out that such a requirement would be difficult to deliver when balancing other site-specific constraints and considerations.
Consequently, CIP welcomes the fact that the 30% requirement figure has now been removed from the draft policy.
Section 1 of the Regulation 19 version of the policy states that all applications for development where there are trees on, or immediately adjacent to the development site, should be made in accordance with the recommendations set out in BS5837 2012 Trees in relation to design, demolition and construction – Recommendations and accompanied by an Arboricultural Impact Assessment and a tree protection plan and/or a Hedgerow Survey.
Section 7 of the policy specifies that development proposals, including through the construction phase, must maintain at least a 15 metre buffer zone from the boundary of any ancient woodland, and should aim for at least 50 metres. The latter 50m target figure being a new addition to the policy.
Neither the policy nor the supporting evidence clearly explains how tree canopy cover is to be measured. Specifically, it is not clear whether it refers solely to future tree canopy or whether it also includes other landscape or green infrastructure elements such as hedgerows, scrub, structural planting, green walls or green roofs. This distinction is important and requires clarification.
In tandem with other policy considerations set out within draft GCLP (Policies BG/BG, BG/GI, Policy BG/EO, Policy WS/NC, and Policy H/SS), this restricts opportunities for density uplift and delivery of housing supply. There are also risks for site viability to accommodate these considerations; essential in delivering affordable housing requirements (draft policy H/AH) and infrastructure delivery (draft policy I/ID).

To request that replacement open space does not need to be in operation prior to any loss and an interim period can be allowed for to accommodate for any associated replacement, and such flexibility is introduced in the policy wording of BG/PO.

Policy BG/PO concerns the protection and provision of open space. Of relevance, part 2 stipulates the requirements for open space replacement which should be
a. located within a suitable distance of the original site having regard to the Natural England Accessible Greenspace Accessibility Standards and
b. fully available for use before the area of open space to be lost can be redeveloped.
CIP supports in principle the protection of existing open space and mechanisms to achieve this. However, there are concerns that point b of part 2 requiring replacement open space to be in operation prior to the loss of existing space does not accommodate for practicalities regarding site deliverability, construction and access. This is particular for previously developed brownfield sites where redevelopment may need to be phased to allow for demolition if relevant, and associated implementation of green and blue infrastructure.

For part 2 to be amended to include explicit reference to the relevant policies which expand upon the principles listed under Part 1 of WS/HD.
To request the threshold of a full HIA submission is increased to 500 dwellings, a rapid HIA for schemes of 200-500 dwellings and for schemes of 200 or less dwellings there is no requirement for a HIA.
If the thresholds are not amended, we would request that the reference to 5000 sqm gross internal floorspace (GIA) for residential development in relation to full HIAs is removed. This threshold should be applied to non-residential development only. Applying this threshold for residential development, may result in scenarios where developments seeking lower quantum of dwellings, may only propose limited housing mixes (i.e. 1 bed 2 person only) to avoid the 5000 sqm trigger.

Policy WS/HD concerns how new development can support the promotion of everyday health wellbeing and lifestyles of residents. Para 2 sets out principles new developments should incorporate to facilitate the delivery of healthy lifestyles in accordance with other policies within the Local Plan. Para 4 sets out the thresholds for when HIAs will be needed, with full HIAs required for proposals of 100 dwellings or more or 5,000m2 of gross internal floorspace (GIA).
CIP supports in principle the importance of new developments in promoting healthy and active lifestyles. Part 2 of Policy WS/HD relists principles that are addressed in other policies in draft GCLP linked to housing, biodiversity and green spaces.
CIP support the requirement of submission of HIAs as part of major developments as required by Part 4 (previously part 2). However, it is requested that the threshold for full HIAs is increased to 500 dwellings rather than 100 dwellings; a rapid HIA for schemes of 200-500 dwellings and for schemes of 200 or less dwellings there is no requirement for a HIA.
The Aspinall Verdi (AV) Greater Cambridge Local Plan Viability Main Viability Report (July 2026) fails to mention or provide any indicative costs relating to the implementation of this policy.
While this comment was made at the Regulation 18 consultation, CIP’s requested changes have not been made to the policy.

To clarify the threshold for “Developments of sufficient scale” as listed under paras 3 and 5 of Policy WS/NC.

To request paras 3 and 5 of Policy WS/NC are merged for conciseness and avoidance of replication.

To request the requirement to provide onsite indoor community facilities as required under para 5 of Policy WS/NC is more aligned with other policy requirements to accommodate for the feasibility in achieving housing requirements and infrastructure delivery.

Appropriate wording should also be included to reflect for circumstances where improvements or expansions to existing facilities within the immediate area would be more efficient than new onsite delivery.

Policy WS/NC of draft GCLP seeks to ensure that new development contributes towards the delivery of new services and facilities to meet the needs of residents. The supporting text to Policy WS/NC identifies the types of services and facilities that the policy applies to, including education, libraries, health, indoor and outdoor sports facilities, and community development. Reference is included to identified and addressing needs, the provision of indoor community facilities and implementation.
Of relevance, part 3 of Policy WS/NC requires that Developments of sufficient scale to generate the need for new on-site facilities will be required to do so, unless it can be demonstrated that there would be advantages in delivering the facilities off site.
Part 5 concerns the delivery of indoor community facilities, requiring that all housing developments will contribute towards the provision of indoor community facilities to meet the need generated by the development. Developments of sufficient scale to generate the need for new on-site facilities will be required to do so, unless it can be demonstrated that there would be advantages in off-site delivery.
CIP supports Policy WS/NC in principle and delivering appropriate community facilities.
The wording however as drafted under Parts 3 and 5 of Policy WS/NC concerning the delivery of onsite facilities is considered as vague and unclear as to when the policy requirements will be triggered. The threshold for “Developments of sufficient scale” should be defined and specified. There is also general overlap in the requirements of part 3 and 5 and for purposes of conciseness, it is requested that these are combined.
The requirement also to provide onsite indoor and outdoor community and cultural facilities as required under para 5 of Policy WS/NC when balancing against other policy requirements as set out in the draft GCLP, namely Policy BG/BG, BG/GI, Policy BC/TC, Policy BG/EO and Policy H/SS, restrict opportunities for density uplift and delivery of housing supply with a reduction in developable residential area. There are also risks for site viability to accommodate for these considerations, essential in delivering affordable housing requirements (draft policy H/AH) and infrastructure delivery (draft policy I/ID).
It is considered that para 5 of draft policy WS/NC needs to better align with other draft GCLP policies and housing requirements, in order to ensure that such provisions are actually deliverable.
While this comment was made at the Regulation 18 consultation, CIP’s requested changes have not been made to the policy.

To request the 80% affordable housing exemption of self and custom home plot delivery listed under part 1 a ii of Policy H/CB is decreased to 50%.

Policy H/CB concerns self and custom build home delivery in Greater Cambridge. Part 1 requires that developments of 20 or more dwellings must provide at least 5% of the new homes as serviced plots for custom and self build houses and/or serviced custom-build flats. Exemptions from this requirement, which amongst other things, include schemes where a minimum of 80% homes are delivered as affordable. Unless specified all custom and self build plots will be classified as market housing as stated under part 2. Part 3 sets out the marketing criteria for custom and self build plots.
CIP in principle support the delivery of self and custom build home delivery in Greater Cambridge.
However, it is requested that the currently proposed threshold of 80% affordable homes listed under part 1 a ii allowing for the exemption of delivery of custom and self build plots is decreased to 50%.
Cambridge City Council’s ten-year development programme seeks to deliver 1000 net additional council rented homes between 2022 and 2032, of which CIP is the main delivery vehicle to achieve this target. CIP has already delivered residential redevelopments across the city which provide in excess of the minimum policy requirement of 40% affordable housing. To achieve the above affordable housing target however, site viability is key and it is considered that the proposed 80% threshold would affect this delivery and feasibility to meet the 2022-2032 council rented home target. This includes now the securing of funding from the Homes England Local Authority Strategic Partnership.
Self/custom buildings reduce the ability to design optimised layouts with standardised unit widths, depths and typologies, resulting in lower densities and reduced overall yield; the servicing of irregular plot shapes or standalone plots incurs further costs. When balanced against other policy requirements as set out in the draft GCLP, (namely Policy BG/BG, BG/GI, Policy BC/TC, Policy BG/EO, and Policy WS/NC) the policy requirement may constrain site opportunities. This is relevant for density uplift and delivery of housing, leading to the wrong design and density outcomes. There is also no evidence of demand for this level of custom/self-build homes on a single scheme.
The NPPF (2026) is clear in its wording that while the needs of groups with specific housing requirements should be addressed, the overall aim is to meet an area’s identified housing need. The requirement for minimum self-build plot provision would affect the ability for sites to maximise efficient use and density of land, contrary to Policy L3 of the NPPF (2026) which promotes densities.
We note the Council’s response who to adding supporting information to allow for the lowering or waiving of custom and self build requirements subject to viability evidence and where schemes are delivering affordable housing numbers that are at least 10% above policy requirements. While we support this inclusion, we would request this allowance is included in the policy wording and reflects for the 50% threshold we had previously requested and the potential impact on affordable housing delivery.

To update the wording of para 2h of Policy I/CV to accommodate cycle parking design requirements for alternative residential typologies.

To clarify the threshold for large scale Major sites and associated requirement for a site wide electric vehicle charging strategy as requested by para 8 of Policy I/CV (i.e. in paragraph 10.35).

CIP welcome the updates that have been undertaken to Policy I/CV including clarification on a fixed percentage provision for the overall non-standard cycle parking provision and further information included on non-standard cycle parking provision as summarised in paragraph 10.23.
However, the wording of 2h does not offer flexibility for alternative residential typologies and where cycle parking design requirements may be more appropriate to be within areas not located to a front of a dwellinghouse. It is therefore requested further wording is included to accommodate for this or to allow for scenarios of split parking provision (i.e. both to the front and rear of a house if needed).
Part 8 (previously part 6) deals with site wide electric charging matters. We request that the thresholds for provision of a site EV charging strategy in relation to “large-scale major sites” is clarified in the supporting information of Policy I/CV as it is not clear what the quantitative triggers would be.

The draft wording of para 3 of Policy I/ID is requested to be deleted.

Policy I/ID seeks to ensure there is sufficient infrastructure capacity to support and meet all the requirements arising from the new development, and its associated phasing. Para 1 outlines that proposals will need to make appropriate arrangements for physical and social infrastructure improvement and provision. Para 2 outlines infrastructure phasing requirements. Para 3 states the need for proposals to demonstrate adequate capacity with parts 4 and 5 expanding upon this further. Para 6 and 7 confirm the requirements for the submission of a utilities statement. Paragraphs 8-10 relate to viability.

CIP recognises the importance of infrastructure delivery where this is necessary to support development. The wording under para 3 of Policy I/ID as inserted below:

Proposals for new development will be required to demonstrate adequate capacity exists or is capable of being secured both on and off site to serve the development.

However, the comments raised by CIP previously have not been taken into account.