Greater Cambridge Local Plan: Proposed Submission

We think the policy should be changed to enable sufficient flexibility to accommodate changes in climate change policy and good practice over the lifetime of the Plan. The Local Plan will therefore need to build in suitable flexibility to accommodate these changes within the lifetime of the Plan.

The reference at part 2, (a), (iii), prioritising passive design solutions to minimise internal heat generation through ‘Energy efficient design to minimise internal heat generation with a focus on building services’, should be altered as the policy is too loosely worded and does not clearly define what is expected.

Barratt David Wilson Homes and the North West Cambridge Consortium of Landowners object to Policy CC/DC. The policy is unsound as it is not effective.
It will be important to ensure the policy enables sufficient flexibility to accommodate changes in climate change policy and good practice over the lifetime of the Plan. Climate change scenarios predict extensive changes by 2050, much of which is dependent on government and human action so there is substantial uncertainty over outcomes. The Local Plan will therefore need to build in suitable flexibility to accommodate these changes within the lifetime of the Plan.
Furthermore, with regards to the reference at part 2, (a), (iii), to prioritising passive design solutions to minimise internal heat generation through ‘Energy efficient design to minimise internal heat generation with a focus on building services’, the policy is too loosely worded and does not clearly define what is expected.

Information requirements must be specific and the policy must allow for a planning judgement and balanced decision to allow for site and development specific issues to be taken into account.

Clarification is sought on the details required by a ‘Green Infrastructure Plan’ and ‘Green Infrastructure (GI) Statement’ and whether or not this would or could form part of a Design and Access Statement (DAS). As currently worded the requirement is too vague and it is not clear what these deliverables would achieve that is not already secured through the submission of a DAS.

Barratt David Wilson Homes and the North West Cambridge Consortium of Landowners object to Policy BG/GI. The policy is unsound as it is not effective.
Information requirements must be specific and the policy must allow for a planning judgement and balanced decision to allow for site and development specific issues to be taken into account. Furthermore, clarification is sought on the details required by a ‘Green Infrastructure Plan’ and ‘Green Infrastructure (GI) Statement’ and whether or not this would or could form part of a Design and Access Statement (DAS). As currently worded the requirement is too vague and it is not clear what these deliverables would achieve that is not already secured through the submission of a DAS.

Part 4 of the policy should be changed so that the responsibility should not fall on developers to determine which community needs a development should meet, rather these assessments should be prepared by Councils as part of their infrastructure Delivery Plan. This also repeats requirements set out in Policy BG/EO so it should be removed. In Part 6, the reference to contributions towards the provision of community facilities based on a standard of 129 m2 of floorspace per 1,000 additional population should be clarified as it is not clear whether any corresponding study has been undertaken for Cambridge city. As such, the inclusion of the standard of 129 m2 of floorspace per 1,000 additional population towards the provision of indoor community facilities is currently not fully justified.

Barratt David Wilson Homes and the North West Cambridge Consortium of Landowners object to Policy WS/NC. The policy is unsound as it is not effective.
With regards to part 4 of the policy and the requirement for proposals for residential sites of 200 or more dwellings to be informed by detailed assessments of both sports, recreation, culture and community needs and include strategies that address identified needs, these assessments should be prepared by the Councils as part of their Infrastructure Delivery Plan, and the responsibility should not fall on developers to determine which community needs a development should meet. Furthermore, this repeats requirements set out in Policy BG/EO so it should be removed.
With regards to part 6 and the reference to contributions towards the provision of community facilities based on a standard of 129 m2 of floorspace per 1,000 additional population, whilst it is acknowledged that this has been informed by the South Cambridgeshire Community Facilities Study (2025), it is not clear whether any corresponding study has been undertaken for Cambridge city. As such, the inclusion of the standard of 129 m2 of floorspace per 1,000 additional population towards the provision of indoor community facilities is currently not fully justified.

The policy needs to ensure it is sufficiently flexible in order to respond to changing needs and opportunities. Furthermore, the ability to include cascade mechanisms is requested to be included in the policy.

Barratt David Wilson Homes and the North West Cambridge Consortium of Landowners object to Policy H/AH. The policy is unsound as it is not effective.
The policy needs to ensure it is sufficiently flexible in order to respond to changing needs and opportunities. Furthermore, the ability to include cascade mechanisms is requested to be included in the policy.

In terms of Part 2 (h), the requirement for cycle parking for residential development to be integrated “within the front of the house” is overly prescriptive and should be deleted. For example, there are many ways in which cycle parking can be designed and it may not always be the case that providing cycle parking at the front of a property is convenient or appropriate

Barratt David Wilson Homes and the North West Cambridge Consortium of Landowners object to Policy I/CV. The policy is unsound as it is not effective.
In terms of Part 2 (h), the requirement for cycle parking for residential development to be integrated “within the front of the house” is overly prescriptive and should be deleted. For example, there are many ways in which cycle parking can be designed and it may not always be the case that providing cycle parking at the front of a property is convenient or appropriate

Reference to the wording ‘harmful concentration’ within the policy is not deemed appropriate. The below sentence within the policy should therefore be deleted;
“Schemes will not be supported where they result in a harmful concentration of this type of development within the local area”

Barratt David Wilson Homes and the North West Cambridge Consortium of Landowners object to Policy H/BR. The policy is unsound as it is not effective.
Reference to the wording ‘harmful concentration’ within the policy is not deemed appropriate. Not only is this inherently subjective and open to inconsistent interpretation, but it has not been proven that build to rent has any impact on the character of a wider area in which it is located. The below sentence within the policy should therefore be deleted;
“Schemes will not be supported where they result in a harmful concentration of this type of development within the local area”

Changes should include a flexible approach. That is, where appropriate, the Council will work with developers, registered providers, landowners and relevant individuals or groups to address identified local requirements for self and custom-build homes as identified in the Greater Cambridgeshire self and custom-build register.

Barratt David Wilson Homes and the North West Cambridge Consortium of Landowners object to Policy H/CB. The policy is unsound as it is not effective.
Barratt David Wilson Homes and the North West Cambridge Consortium of Landowners raise concern regarding the mandatory requirement for 5% self-build homes as part of all development proposals including 20 or more dwellings. This would be inconsistent with the Self-build and Custom Housebuilding Act, which focuses on demand registers, not quotas. Such a blanket approach across all developments is unjustified and self-build provision should only be sought on sites where there is a demonstrable need.
A flexible approach should instead be taken. That is, where appropriate, the Council will work with developers, registered providers, landowners and relevant individuals or groups to address identified local requirements for self and custom-build homes as identified in the Greater Cambridgeshire self and custom-build register.

Policy needs to be revised to read as follows:
The words “where appropriate” should be added to Part 1 (a) (i) of the Policy, as per below (see capitals):
“1. Development proposals are required to deliver high quality landscape and public realm by:
a. Enabling local communities:
i. Create a range of open spaces that provide comfortable formal and informal places to rest, socialise and play, provide drinking water fountains, shade and shelter, bicycle parking, street lighting, signage and public art WHERE APPROPRIATE, designed in a coordinated and needs-led approach that is accessible and age appropriate for its user;

Barratt David Wilson Homes and the North West Cambridge Consortium of Landowners object to Policy GP/QP. The policy is unsound as it is not effective.
Whilst Barratt David Wilson Homes and the North West Cambridge Consortium of Landowners broadly support Policy GP/QP, consideration of individual site circumstances and the circumstances of a local area should also be taken into account. Introducing an inflexible and prescriptive constraint could undermine development capacity, density and viability and is not aligned with national planning policy or with the Government’s stated ambition for growth. As such, the words “where appropriate” should be added to Part 1 (a) (i) of the Policy, as per below (see capitals):
“1. Development proposals are required to deliver high quality landscape and public realm by:
a. Enabling local communities:
i. Create a range of open spaces that provide comfortable formal and informal places to rest, socialise and play, provide drinking water fountains, shade and shelter, bicycle parking, street lighting, signage and public art WHERE APPROPRIATE, designed in a coordinated and needs-led approach that is accessible and age appropriate for its user;

Policy should be revised to avoid unnecessary duplication and ambiguity. For example, Part 2 (h) requires the successful integration of safety and security such as Hostile Vehicle Mitigation but there is no guidance within the Policy on which development proposals this will be required and as currently worded appears to be a blanket approach across all forms of development. This does not take into account the site-specific circumstances, setting and contexts of individual development sites. To be effective and justified the policy should be reworded to state that such design measures will be required “where appropriate” and should provide further guidance on what measures are envisioned.

Barratt David Wilson Homes and the North West Cambridge Consortium of Landowners object to Policy GP/QD. The policy is unsound as it is not effective.
This policy repeats sections of policies GP/PP and GP/QP and as such is inconsistent with paragraph 16 of the NPPF (2024) which states that plans should serve a clear purpose and avoid unnecessary duplication of policies that apply to a particular area (including policies in the Framework, where relevant). There are numerous cases where these policies could be written more clearly and/or consolidated to avoid ambiguity and repetition.
For example, Part 2 (h) requires the successful integration of safety and security such as Hostile Vehicle Mitigation but there is no guidance within the Policy on which development proposals this will be required and as currently worded appears to be a blanket approach across all forms of development. This does not take into account the site-specific circumstances, setting and contexts of individual development sites. To be effective and justified the policy should be reworded to state that such design measures will be required “where appropriate” and should provide further guidance on what measures are envisioned.

Policy GP/PP repeats sections of policies GP/QD and as such is inconsistent with paragraph 16 of the NPPF (2024) which states that plans should serve a clear purpose and avoid unnecessary duplication of policies that apply to a particular area (including policies in the Framework, where relevant). We therefore request to remove duplication from GP/PP as per document attached.

Barratt David Wilson Homes and the North West Cambridge Consortium of Landowners object to Policy GP/PP. The policy is unsound as it is not effective.
This policy repeats sections of policies GP/QD and as such is inconsistent with paragraph 16 of the NPPF (2024) which states that plans should serve a clear purpose and avoid unnecessary duplication of policies that apply to a particular area (including policies in the Framework, where relevant).
There are numerous cases where these policies could be written more clearly and/or consolidated to avoid ambiguity and repetition. For example, Policy GP/QD states, at Part 1 (a) (iii) that development proposals will be supported that respond to Greater Cambridge’s communities by “Designing streets, places and public realm to remove the threat or perceived threat of crime and improve community safety, especially for those with protected characteristics under the Equality Act”. Policy GP/QD then states, at part 2 (d) that development proposals will be expected to demonstrate how they have addressed the following design principles and requirements including “Create safe open spaces and active streets that design out crime and consider counter-terrorism protective security measures that are proportionate to the building, street or place, particularly places with higher crowd densities” and again at (h) to “Provide a comprehensive and accessible design approach that ensures the successful integration of safety and security such as Hostile Vehicle Mitigation”.