Greater Cambridge Local Plan: Proposed Submission

Modification 1 – Site capacity
Amend the indicative capacity for Policy S/C/HGH (and corresponding figures in the supporting text, housing trajectory and site schedules) from 50 dwellings to "at least 95 dwellings".

Reason: it reflects the only site-specific capacity evidence before the examination (Formation Architects study), aligns with the Topic Paper's conclusion that higher capacity is possible, and is consistent with Policy DP/HD and NPPF paragraphs 124, 125 and 130 (positively prepared, justified, consistent with national policy).

Modification 2 – Criterion (g)
Delete criterion (g). Alternatively, replace it with:
"(g) The site is capable of accommodating a significant uplift in density above the indicative capacity. Proposals should follow a design-led approach demonstrating that amenity, outlook, daylight and sunlight and heritage impacts, including along the Chesterton Road frontage, in views down Carlyle Road and on the setting of nearby Grade II listed structures, are assessed and mitigated effectively."

Reason: it retains the heritage and amenity safeguards sought by Historic England and other respondents, but removes the unjustified cap on capacity, so that the appropriate quantum is determined through detailed design and assessment at application stage (justified, effective).

Modification 3 – Positive framing of the policy
Add the following opening text to Policy S/C/HGH (or its supporting text):

"The redevelopment of Henry Giles House is supported as a highly sustainable, previously developed site within walking distance of Cambridge City Centre, with excellent public transport and active travel accessibility. The existing building is identified in the Conservation Area Appraisal as having a negative impact on the Conservation Area. Its replacement with a high-quality residential scheme that makes efficient use of land and optimises density, in accordance with Policy DP/HD, is encouraged."

Reason: it sets out the positive basis for the allocation, consistent with Plan paragraph 2.56 and NPPF paragraph 125, and provides the certainty needed to incentivise comprehensive redevelopment rather than retention of the existing building (positively prepared, effective).

Introduction
This representation is made by Twenty5 Planning Ltd on behalf of Telereal Investment Properties Limited Trillium Ltd (TT Group), owner and promoter of Henry Giles House (HGH), 73-79 Chesterton Road. It should be read alongside our full representation letter dated 18 September 2026 and its appendices (see Section 4). TT Group made representations on draft Policy S/C/HGH at the Regulation 18 stage (December 2025 - January 2026). These supported the principle of allocating the site for residential development, but recommended changes to ensure that the policy optimises the redevelopment of a prime brownfield site in a highly sustainable location, in accordance with Paragraph 124 of the NPPF (December 2024). TT Group continues to support the allocation, but considers that Policy S/C/HGH, and in particular criterion (g), is unsound when assessed against the tests at Paragraph 36 of the NPPF. Changes to Policy S/C/HGH at Regulation 19 The Proposed Submission Plan amends criterion (a) to require building heights reflective of local context and contextual materials, and adds criteria (f) (archaeological assessment, as requested by Historic England) and (g). We have no comment on the amendments to criterion (a) or on criterion (f). Criterion (g) states: "There is potential for a minimal increase in capacity where it can be demonstrated that amenity, outlook, daylight and sunlight and heritage impacts can be assessed and mitigated effectively. Any increase in scale along the Chesterton Road frontage would need to be fully tested from sensitive heritage views including the views down Carlyle Road and the impacts on nearby Grade Il listed structures and their setting." The policy as a whole is negatively worded. It sets out everything development must not do and all the mitigation it must consider, but does not acknowledge the positive basis for redevelopment: a previously developed site in a highly sustainable location within walking distance of the City Centre, with good public transport and active travel accessibility. HGH is identified in the adopted Conservation Area Appraisal as a building that has a negative impact on the Conservation Area, so the emphasis should be on positive redevelopment and on making the most effective use of the land to meet the very significant need for homes in Greater Cambridge. Cambridge is one of the least affordable places to live in the UK, and the Housing Trajectory & Housing Land Supply Addendum (September 2026) identifies that Cambridge City has only a 2.72-year supply of homes. Against this backdrop the Plan should be maximising the potential of sustainable sites such as HGH. The Site Allocations Topic Paper (2026) states that "there is potential for a higher capacity to be accommodated where further evidence can be developed" to ensure impacts on neighbouring buildings and heritage assets are managed. While we accept that further detailed assessment would be required to support a denser scheme, limiting the site to "a minimal increase in capacity" in criterion (g) conflicts with the Council's own evidence and is unsound for the reasons set out below. Positively Prepared

NPPF Paragraph 124 requires strategic policies to accommodate objectively assessed needs in a way that makes as much use as possible of previously developed land. With only a 2.72-year supply in Cambridge City, the Plan clearly cannot currently accommodate its needs. The high-growth scenario requires c.48,069 new homes over the Plan period to 2045 and relies on major strategic allocations to deliver over 37,000 of these, several of which depend on significant infrastructure (e.g. North East Cambridge) or are subject to scrutiny given delivery rates at Cambourne, Northstowe and Waterbeach. This heightens the importance of maximising smaller, deliverable brownfield sites such as HGH. Paragraph 2.56 of the Proposed Submission Plan confirms that the urban area of Cambridge "provides the most significant opportunities for reusing previously developed land and optimising densities in these well connected locations". Criterion (g) contradicts this strategic driver by failing to optimise the density of a brownfield site in a highly sustainable and well-connected location. Criterion (g) also conflicts with Policy DP/HD (Housing Density), which requires efficient use of land through a design-led approach and supports high-density development exceeding prevailing densities where sites are within 800m walking/cycling distance of Cambridge City Centre and/or high-quality active travel provision. HGH meets these locational criteria. It also conflicts with NPPF Paragraph 130(a), which requires plans to optimise the use of land and seek a significant uplift in density in city and town centres unless there are strong reasons why this would be inappropriate. Policy S/C/HGH instead presumes against a significant uplift. The policy, and criterion (g) in particular, has not been positively prepared. Justified TT Group's Regulation 18 representations were accompanied by a scale and massing study by Formation Architects, based on Figure 52 of the Mitcham's Corner Development Framework SPD (a maximum of 5 storeys in the centre of the site, grading down to 2 storeys to the north and east, with stepped 3- and 4-storey forms to the west and north). It demonstrates that up to 95 dwellings (c.151 dph) can be achieved, meeting space standards and cycle parking standards, with private amenity space for each unit and parking for around 50% of units (44 spaces), which is generous in a location where car-free development would be supported. The approved 3-storey + 1 scheme at Carlyle House (20/03843/FUL) demonstrates that deviation from the SPD's 2-storey + 1 approach can be acceptable. This evidence, and the heritage benefit of replacing a building identified as harmful to the Conservation Area, do not appear to have been considered in limiting the site to a "minimal increase". The Topic Paper provides no justification for this limitation. The other Regulation 18 respondents on this policy (Historic England, a local resident and the Green Party) sought for development to reflect local historic context, heights and materiality - matters now addressed in criteria (a) and (f). None suggested that density or the quantum of development should be curtailed. Criterion (g) is therefore not justified. Effective Allocations must be deliverable over the Plan period. HGH is available and deliverable, but underestimating and capping site capacity undermines investor confidence. Formation Architects' work indicates that conversion of the existing building could accommodate a similar number of homes to the 50-dwelling allocation. Given the costs of demolition, construction, affordable housing and biodiversity net gain on brownfield sites, the policy as drafted provides no incentive to pursue comprehensive redevelopment, and effectively encourages retention of the existing building. A policy that deters the redevelopment it seeks to secure is not effective.
We accept that careful consideration of the immediate context, including the Chesterton Road frontage, will be required at application stage, supported by a Heritage Impact Assessment and Landscape and Visual Impact Assessment. That design-led, collaborative process with the LPA is the appropriate means of establishing the optimal capacity; an arbitrary cap in the policy places a barrier on it. Criterion (g) is not effective. Consistent with National Policy NPPF Chapter 11 requires efficient and effective use of land. Paragraph 125 requires policies to support the development of under-utilised brownfield land, and Paragraph 130 requires densities that optimise the use of land. Comparable Cambridge allocations have exceeded their allocated densities significantly: Policy R9 (Devonshire Gardens) allocated 43 homes on 1.23ha (35 dph), while the approved scheme (22/01982/FUL) achieves 184 dph. Restricting HGH to a "minimal increase" above 50 dwellings unduly limits a prime brownfield site and is inconsistent with national policy. Conclusion TT Group supports the allocation of HGH, but Policy S/C/HGH must be amended to be sound. The indicative capacity should be increased to at least 95 dwellings, and criterion (g) should be deleted or modified to remove any limitation on capacity, with the policy recognising the positive opportunity the site presents. Proposed modifications are set out in Section 5.