Greater Cambridge Local Plan: Proposed Submission
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Greater Cambridge Local Plan: Proposed Submission
Chapter 1: About the Plan
Respondent: Woolsington One Ltd
Agent: Claremont Planning Consultancy
Legally compliant? Not specified
Representation Summary:
The 2026 Housing and Economic Land Availability Assessment (HELAA) does not provide an accurate assessment of Woolsington One Ltd’s promoted site’s (115329) suitability for development. The site’s ‘red’ landscape score relies on outdated comments and fails to reflect earlier conclusions that development could be accommodated with appropriate mitigation. The Important Countryside Frontage designation is not an absolute constraint and should result in an ‘amber’ rather than ‘red’ rating. Additionally, several criteria including flood risk, ecology, site access, noise, vibration, odour and contamination land are scored ‘amber’ despite the assessment confirming that impacts can be mitigated. The HELAA should be revised to provide a more balanced and evidence based assessment of the site.
Change suggested by respondent:
The HELAA should be revised to provide a more balanced assessment of Woolsington One Ltd’s promoted site at Boxworth End, Swavesey (Site ref. 115329). The site’s
landscape score should be amended from ‘red’ to ‘amber’ as previous Landscape Officer comments confirmed that development could be accommodated on the site with
appropriate mitigation and retention of the Important Countryside Frontage. In addition, the ‘amber’ ratings for other development plan matters should be reviewed since the assessment confirms that these issues can be adequately mitigated. These changes are considered necessary to ensure that the evidence base is justified and accurately reflects the site’s development potential, as is required in order for the Local Plan to be found sound at examination in relation to the provisions of Paragraph 36 of the Framework.
Full text:
Please see the accompanying representations report.
As outlined in Section 5.9 of the attached supporting Representations Report, the overall aim of Policy GP/QD to secure development that is distinctive, contextually appropriate and of a high design quality is supported. Notwithstanding this, the policy is considered to largely repeat the objectives and requirements which are already addressed within Policies GP/QS and GP/PP. Paragraph 132 of the National Planning Policy Framework emphasises that local plans should provide a clear design vision and set out expectations with sufficient certainty so that applicants understand what is likely to be acceptable. The current approach does not achieve this given the duplication of design requirements across several policies. Therefore the Plan should be amended to consolidate Policies GP/QD, GP/QS, GP/PP and GP/QP into a single overarching design policy that establishes a comprehensive framework for achieving high quality development.
Greater Cambridge Local Plan: Proposed Submission
Policy I/ST: Sustainable transport and connectivity
Respondent: Woolsington One Ltd
Agent: Claremont Planning Consultancy
Legally compliant? Not specified
Representation Summary:
Policy I/ST’s support for sustainable transport and connectivity is welcomed but Part 3 must be amended to ensure consistency with national policy as the current wording conflicts with Paragraph 116 of the Framework by suggesting that development should be refused where transport impacts are unacceptable, without reference to severity. The policy should instead reflect that development should only be prevented or refused where there would be an unacceptable impact on highway safety or severe cumulative impacts on the road network.
Change suggested by respondent:
Policy I/ST should be amended to ensure consistency with Paragraph 116 of the National Planning Policy Framework and to ensure that the Plan is sound. The current
wording of the policy is not aligned with national policy which is clear that development should only be prevented or refused on highways grounds where there would be an
unacceptable impact on highway safety, or where the residual cumulative impacts on the road network would be severe.
Full text:
Please see the accompanying representations report.
As outlined in Section 5.9 of the attached supporting Representations Report, the overall aim of Policy GP/QD to secure development that is distinctive, contextually appropriate and of a high design quality is supported. Notwithstanding this, the policy is considered to largely repeat the objectives and requirements which are already addressed within Policies GP/QS and GP/PP. Paragraph 132 of the National Planning Policy Framework emphasises that local plans should provide a clear design vision and set out expectations with sufficient certainty so that applicants understand what is likely to be acceptable. The current approach does not achieve this given the duplication of design requirements across several policies. Therefore the Plan should be amended to consolidate Policies GP/QD, GP/QS, GP/PP and GP/QP into a single overarching design policy that establishes a comprehensive framework for achieving high quality development.
Greater Cambridge Local Plan: Proposed Submission
Policy H/CB: Self and Custom Build Homes
Respondent: Woolsington One Ltd
Agent: Claremont Planning Consultancy
Representation Summary:
Policy H/CB’s requirement for 5% self or custom build provision on developments of 20 or more dwellings is considered excessive and may affect the viability and delivery of small and medium sized schemes. Applying the requirement across all qualifying developments could significantly exceed the identified demand for 700 plots in Greater Cambridge. A more appropriate approach would be to require self build provision only on larger sites of 100 or more dwellings, helping to create sustainable mixed communities whilst providing greater certainty for developers.
Change suggested by respondent:
Policy H/CB should be modified so that the requirement to provide self and custom build housing applies only to larger residential developments of 100 or more dwellings rather than all schemes of 20 or more dwellings. The proposed 5% requirement is considered excessive for small and medium sized sites and could adversely affect their viability and deliverability. Focusing provision on larger sites would better align supply with the identified need to support the delivery of sustainable and mixed communities, ad provide a greater deal of certainty for developers. Accordingly, Policy H/CB should be amended to require an appropriate proportion of self and custom build plots only on developments of 100 or more dwellings.
Full text:
Please see the accompanying representations report.
As outlined in Section 5.9 of the attached supporting Representations Report, the overall aim of Policy GP/QD to secure development that is distinctive, contextually appropriate and of a high design quality is supported. Notwithstanding this, the policy is considered to largely repeat the objectives and requirements which are already addressed within Policies GP/QS and GP/PP. Paragraph 132 of the National Planning Policy Framework emphasises that local plans should provide a clear design vision and set out expectations with sufficient certainty so that applicants understand what is likely to be acceptable. The current approach does not achieve this given the duplication of design requirements across several policies. Therefore the Plan should be amended to consolidate Policies GP/QD, GP/QS, GP/PP and GP/QP into a single overarching design policy that establishes a comprehensive framework for achieving high quality development.
Greater Cambridge Local Plan: Proposed Submission
Policy H/SS: Residential Space Standards and accessible homes
Respondent: Woolsington One Ltd
Agent: Claremont Planning Consultancy
Legally compliant? Not specified
Representation Summary:
The requirement that all new homes comply with the Nationally Described Space Standards is supported. However, Part 2 of Policy H/SS unnecessarily repeats requirements already established within the Government’s Technical Housing Standards and should be deleted to avoid duplication and ensure consistency with Paragraph 16 of the Framework.
Change suggested by respondent:
Policy H/SS should be amended by deleting Part 2 which duplicates requirements already contained within the Government’s Technical Housing Standards. This
modification is necessary to avoid unnecessary repetition and ensure consistency with Paragraph 16 of the Framework. Compliance with the Nationally Described Space Standards should remain but the detailed national requirements should not be repeated within the Local Plan.
Full text:
Please see the accompanying representations report.
As outlined in Section 5.9 of the attached supporting Representations Report, the overall aim of Policy GP/QD to secure development that is distinctive, contextually appropriate and of a high design quality is supported. Notwithstanding this, the policy is considered to largely repeat the objectives and requirements which are already addressed within Policies GP/QS and GP/PP. Paragraph 132 of the National Planning Policy Framework emphasises that local plans should provide a clear design vision and set out expectations with sufficient certainty so that applicants understand what is likely to be acceptable. The current approach does not achieve this given the duplication of design requirements across several policies. Therefore the Plan should be amended to consolidate Policies GP/QD, GP/QS, GP/PP and GP/QP into a single overarching design policy that establishes a comprehensive framework for achieving high quality development.
Greater Cambridge Local Plan: Proposed Submission
Policy H/ES: Exception Sites for Affordable Housing
Respondent: Woolsington One Ltd
Agent: Claremont Planning Consultancy
Legally compliant? Not specified
Representation Summary:
Policy H/ES is supported in principle but the requirement to demonstrate that affordable housing need will persist in the long term is not justified as this goes beyond national
policy. The policy should be amended so that is it consistent with the requirements of Paragraph 82 of the Framework, which requires demonstration of the need for the development at the time of the application’s submission.
Change suggested by respondent:
The requirement in Part (a) should be removed which states that the identified affordable housing need must be expected to persist in the long term to ensure that the policy is consistent with national policy and supports the effective delivery of rural exception sites.
Paragraph 82 of the Framework requires rural exception sites to address identified local housing needs but does not require applicants to demonstrate that such needs will
continue indefinitely.
Full text:
Please see the accompanying representations report.
As outlined in Section 5.9 of the attached supporting Representations Report, the overall aim of Policy GP/QD to secure development that is distinctive, contextually appropriate and of a high design quality is supported. Notwithstanding this, the policy is considered to largely repeat the objectives and requirements which are already addressed within Policies GP/QS and GP/PP. Paragraph 132 of the National Planning Policy Framework emphasises that local plans should provide a clear design vision and set out expectations with sufficient certainty so that applicants understand what is likely to be acceptable. The current approach does not achieve this given the duplication of design requirements across several policies. Therefore the Plan should be amended to consolidate Policies GP/QD, GP/QS, GP/PP and GP/QP into a single overarching design policy that establishes a comprehensive framework for achieving high quality development.
Greater Cambridge Local Plan: Proposed Submission
Policy H/AH: Affordable Housing
Respondent: Woolsington One Ltd
Agent: Claremont Planning Consultancy
Representation Summary:
Policy H/AH is supported in principle but is considered overly restrictive in requiring all affordable housing to be provided on site and in prescribing a fixed tenure mix. Greater flexibility should be incorporated to allow off site provision where justified and to enable the delivery of alternative tenure mixes where this supported by up to date evidence of llocal housing needs.
Change suggested by respondent:
Policy H/AH should be modified to provide greater flexibility in the delivery of affordable housing. The requirement for all affordable housing to be delivered on site should be amended to state that on site provision would be the preferred approach, but that off site provision or commuted sums may be accepted where robust justification demonstrates that an alternative approach would better meet affordable housing needs or result in a more effective development outcome. The prescribed affordable housing tenure mix should also be amended to allow deviation from this where supported by up to date evidence of local housing need, including subsequent Housing and Economic Development Needs Assessments that are published by the Councils or equivalent
evidence. These modifications would be necessary to ensure that the policy is capable of supporting the delivery of affordable housing throughout the Plan period.
Full text:
Please see the accompanying representations report.
As outlined in Section 5.9 of the attached supporting Representations Report, the overall aim of Policy GP/QD to secure development that is distinctive, contextually appropriate and of a high design quality is supported. Notwithstanding this, the policy is considered to largely repeat the objectives and requirements which are already addressed within Policies GP/QS and GP/PP. Paragraph 132 of the National Planning Policy Framework emphasises that local plans should provide a clear design vision and set out expectations with sufficient certainty so that applicants understand what is likely to be acceptable. The current approach does not achieve this given the duplication of design requirements across several policies. Therefore the Plan should be amended to consolidate Policies GP/QD, GP/QS, GP/PP and GP/QP into a single overarching design policy that establishes a comprehensive framework for achieving high quality development.
Greater Cambridge Local Plan: Proposed Submission
Chapter 2: Development strategy
Respondent: Woolsington One Ltd
Agent: Claremont Planning Consultancy
Representation Summary:
This representation relates to a site submission (HELAA ref [40506]: [Land at Dairy Farm (Site 1), Boxworth End, Swavesey])
The promoted site east of Boxworth End represents a suitable, available and deliverable site for new development. The site has capacity to deliver approximately 50 new residential dwellings, based upon a density of 21dph. It is envisaged that 40% of units would be delivered as affordable units of accommodation in accordance with the emerging affordable housing requirement set out within Policy H/AH of the Draft Local Plan. The identified capacity of 50 dwellings can be accommodated alongside a generous open space provision that could include the provision of a village green and orchard at the site’s frontage which, along with the lower density of development, will assist in ensuring that the site’s development will provide an appropriate transition to the adjacent countryside that respects the Important Countryside Frontage designation. Critically, the site is immediately available for development and therefore be delivered within a five year period so as to make an important contribution towards housing land supply in the early years of the emerging Plan period.
The identification of the western boundary of the promoted site as an Important Countryside Frontage is objected to as it is not considered that the promoted site provides the significant connection between the built environment and rural area, or provides an important rural break that is referred to by the policy. The promoted site is enclosed by established development at three elevations which provide an urbanising influence to the site, whereby the site is appreciated in the context of surrounding built development. Additionally, it cannot be considered that the site provides a rural break between two nearby but detached parts of the development Framework for Swavesey, given that established development is continuous along Boxworth End and therefore the development framework is not detached in this part of the settlement.
Change suggested by respondent:
Allocate the site 40506 Land at Dairy Farm (Site 1), Boxworth End, Swavesey.
Full text:
Please see the accompanying representations report.
As outlined in Section 5.9 of the attached supporting Representations Report, the overall aim of Policy GP/QD to secure development that is distinctive, contextually appropriate and of a high design quality is supported. Notwithstanding this, the policy is considered to largely repeat the objectives and requirements which are already addressed within Policies GP/QS and GP/PP. Paragraph 132 of the National Planning Policy Framework emphasises that local plans should provide a clear design vision and set out expectations with sufficient certainty so that applicants understand what is likely to be acceptable. The current approach does not achieve this given the duplication of design requirements across several policies. Therefore the Plan should be amended to consolidate Policies GP/QD, GP/QS, GP/PP and GP/QP into a single overarching design policy that establishes a comprehensive framework for achieving high quality development.
Greater Cambridge Local Plan: Proposed Submission
Policy GP/LC: Protection, conservation and enhancement of landscape character
Respondent: Woolsington One Ltd
Agent: Claremont Planning Consultancy
Legally compliant? Not specified
Representation Summary:
Woolsington One Ltd objects to the designation of the western boundary of their promoted site at Boxworth End, Swavesey as an Important Countryside Frontage. The
site does not perform the role identified by the policy as it is enclosed by existing development on three sides and does not provide a significant rural break within the
settlement. The designation therefore fails to reflect the site’s actual relationship with the surrounding built form and should be amended to remove the designation.
Change suggested by respondent:
Policy GP/LC should be modified to remove the Important Countryside frontage designation from the western boundary of Woolsington One Ltd’s promoted site at Boxworth End, Swavesey, as the site does not fulfil the purposes identified for such designation. This modification will be necessary to ensure that the policy is based on an accurate assessment of the site’s characteristics and contribution to landscape character. Part 2 of the policy should also be amended to provide greater flexibility where development proposals can demonstrate that the key functions of an Important Countryside Frontage can be maintained through sensitive design measures.
Full text:
Please see the accompanying representations report.
As outlined in Section 5.9 of the attached supporting Representations Report, the overall aim of Policy GP/QD to secure development that is distinctive, contextually appropriate and of a high design quality is supported. Notwithstanding this, the policy is considered to largely repeat the objectives and requirements which are already addressed within Policies GP/QS and GP/PP. Paragraph 132 of the National Planning Policy Framework emphasises that local plans should provide a clear design vision and set out expectations with sufficient certainty so that applicants understand what is likely to be acceptable. The current approach does not achieve this given the duplication of design requirements across several policies. Therefore the Plan should be amended to consolidate Policies GP/QD, GP/QS, GP/PP and GP/QP into a single overarching design policy that establishes a comprehensive framework for achieving high quality development.
Greater Cambridge Local Plan: Proposed Submission
Policy GP/QP: Establishing high quality landscape and public realm
Respondent: Woolsington One Ltd
Agent: Claremont Planning Consultancy
Legally compliant? Not specified
Representation Summary:
Concerns are raised that the policy overlaps significantly with Policies GP/QP, GP/QD and GP/PP of the Local Plan which address many of the same design principles and objectives. In order to achieve compliance with national planning policy, and remove the unnecessary duplication of policy throughout the emerging Local Plan, it is recommended that the design policies proposed by the Local Plan are consolidated into a single overarching design policy.
Change suggested by respondent:
Policy GP/QP should be modified to remove duplication with Policies GP/QS, GP/PP and GP/QD and consolidate the various design related requirements into a single
comprehensive design policy. In accordance with Paragraph 132 of the Framework, the Local Plan should establish a clear design vision and expectations for development. The Plan should therefore be amended by merging Policies GP/QD, GP/QS, GP/PP and GP/QP into a single overarching policy addressing design quality.
Full text:
Please see the accompanying representations report.
As outlined in Section 5.9 of the attached supporting Representations Report, the overall aim of Policy GP/QD to secure development that is distinctive, contextually appropriate and of a high design quality is supported. Notwithstanding this, the policy is considered to largely repeat the objectives and requirements which are already addressed within Policies GP/QS and GP/PP. Paragraph 132 of the National Planning Policy Framework emphasises that local plans should provide a clear design vision and set out expectations with sufficient certainty so that applicants understand what is likely to be acceptable. The current approach does not achieve this given the duplication of design requirements across several policies. Therefore the Plan should be amended to consolidate Policies GP/QD, GP/QS, GP/PP and GP/QP into a single overarching design policy that establishes a comprehensive framework for achieving high quality development.
Greater Cambridge Local Plan: Proposed Submission
Policy GP/QD: Achieving high quality development
Respondent: Woolsington One Ltd
Agent: Claremont Planning Consultancy
Representation Summary:
Policy GP/QD of the eLP continues on to establish design requirements for new developments, and restates the expectation for developments to deliver a design that is responsive to the local context. It is recommended that consideration is given to consolidating Policies GP/QS and GP/PP as both policies seek to achieve the same objective of delivering a high quality and locally responsive design. It is considered that consolidating both policies into a single, overarching design policy would assist in providing certainty to developers as to the design requirements that are required to be met by their developments. Paragraph 132 of the Framework confirms that this would represent the most appropriate approach, whereby it recommends that Local Plans should set out a clear design vision and expectations so that applicants have as much certainty as possible about what is likely to be acceptable. Separating design requirements over multiple policies, as is currently proposed by the eLP, is not considered to achieve this. Preparing a single design policy would also assist in removing any unnecessary duplication of policy throughout the eLP, as required by Paragraph 16 of the Framework.
Full text:
Please see the accompanying representations report.
As outlined in Section 5.9 of the attached supporting Representations Report, the overall aim of Policy GP/QD to secure development that is distinctive, contextually appropriate and of a high design quality is supported. Notwithstanding this, the policy is considered to largely repeat the objectives and requirements which are already addressed within Policies GP/QS and GP/PP. Paragraph 132 of the National Planning Policy Framework emphasises that local plans should provide a clear design vision and set out expectations with sufficient certainty so that applicants understand what is likely to be acceptable. The current approach does not achieve this given the duplication of design requirements across several policies. Therefore the Plan should be amended to consolidate Policies GP/QD, GP/QS, GP/PP and GP/QP into a single overarching design policy that establishes a comprehensive framework for achieving high quality development.
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