Greater Cambridge Local Plan: Proposed Submission

REQUESTED CHANGE

To ensure sustainability requirements are reflective of, and are not inconsistent with, national standards and guidance.

COMMENT

Policy CC/SD sets out the need for climate change mitigation and adaptation principles to be incorporated into developments.

Hill Residential in principle supports Policy CC/SD, but are concerned that several requirements exceed national standards, creating inconsistency with the sector agreed pathway set out in the Future Homes Hub One Plan and the Net Zero Transition Plan. Local variation should only be applied where clearly evidence based and viability tested to avoid supply chain fragmentation, increased costs, and risks to deliverability.

These concerns were previously set out in Hill’s Regulation 18 representations.

GREATER CAMBRIDGE RESPONSE

Comments, including those offering general support for the policy approaches, were noted. No changes have been made to the policy or supporting text.
UPDATED EVIDENCE

The Aspinall Verdi (AV) Greater Cambridge Local Plan Viability Main Viability Report (July 2026) acknowledges on p.16 that the cost of preparing Sustainability Statements and demonstrating compliance is included in the professional fee allowance within the viability appraisal. Specific additional design costs are covered under related climate and energy policies (e.g. CC/NZ). No further separate viability allowance is required for this overarching policy.

REQUESTED CHANGE

To ensure sustainability requirements are reflective of, and are not inconsistent, with national standards and guidance. Hill Residential still considers that draft Policy CC/DC should be combined with draft Policy CC/NZ regarding the overlap between the set-out principles and requirements.

COMMENT

Policy CC/DC sets out how developments in terms of design and placemaking should mitigate against the challenge of climate change, including overheating.

Hill acknowledges the importance of new developments being as climate efficient as possible. In its Regulation 18 representations, Hill highlighted that the principles set out under Policy CC/DC largely replicated the principles listed under draft Policy CC/NZ. Accordingly, it was suggested that the two policies be combined to avoid unnecessary repetition.

GREATER CAMBRIDGE RESPONSE

With regards to the calls to combine policies CC/NZ and CC/DC, this is not considered appropriate as policy CC/NZ specifically deals with climate mitigation and metrics to deliver net zero carbon development, while policy CC/DC relates to climate change adaptation. Buildings of a unique nature are capable of being considered as a material consideration.

UPDATED EVIDENCE

The Aspinall Verdi (AV) Greater Cambridge Local Plan Viability Main Viability Report (July 2026) acknowledges on p.17 that it is assumed that the relevant design responses (such as improved shading, glazing, orientation or landscape design) will be included in the professional design process and external works costs. For viability purposes, no additional cost allowance is made beyond professional fees and standard construction allowances, as the uplift in design quality is expected to support values.

REQUESTED CHANGE

Draft Policy CC/DC to be combined with draft Policy CC/NZ regarding the overlap between the set-out principles and requirements.

Notwithstanding our comments on draft Policy CC/DC suggesting its amalgamation with draft Policy CC/NZ, it is requested that draft Policy CC/NZ is reconsidered and rewritten. Hill Residential proposes that the requirement thresholds are amended to reflect adequate consideration of developer viability to avoid unintended impacts on design quality, deliverability and overall housing supply.

COMMENT

Policy CC/NZ stipulates the levels of energy use that will be allowed for new development, how renewable energy should be used to meet that energy need, and how whole life carbon emissions (emissions associated with constructing buildings) should be considered.

Hill supports the principles set out under Policy CC/NZ, but the proposed standards significantly exceed the Future Homes Standard and effectively mandate Passivhaus level performance. There are concerns that the imposition of such high standards carries risks for design including the potential for a homogenised architectural form and vernacular, particularly in relation to elevational design and fenestration, as schemes are optimised to meet stringent performance criteria.

In addition, there are practical concerns relating to procurement, buildability, and the capacity of the construction supply chain. At present, there is a risk that materials availability and access to suitably skilled labour are insufficient to support the mainstream delivery of homes to this standard at scale. Viability is also a key consideration, as the Future Homes Hub in their report “Ready for Zero”, identifies cost uplifts in the order of 10–20%.

GREATER CAMBRIDGE RESPONSE

In some cases, schemes being delivered to specific construction standards will be deemed to comply with the requirements of policy CC/NZ. Clarification on this point has been added to the supporting text of the policy alongside details of the evidence that would need to be submitted for this approach to be taken.

The policy has been amended, introducing a threshold at which a Whole Life Carbon Assessment should be undertaken, which for homes is set at 100 units and 10,000 square metres of non-residential floorspace (it was previously proposed to cover all major development).

UPDATED EVIDENCE

The Aspinall Verdi (AV) Greater Cambridge Local Plan Viability Main Viability Report (July 2026) acknowledges on p.121 that meeting Net Zero carbon on new buildings will have a direct cost impact. This relates to the cost to deliver higher construction standards. over and above the existing Part L 2021 compliance requirements.

Costs have been provided by Bioregional / Currie & Brown, who have assessed the percentage uplift on current costs in order to meet these standards, differentiated by houses and flats.

AV expect that as these measures include improved heating and insulation measures which would reduce energy use, this would be reflected in sales values.

For non-domestic properties, AV have referred to the ‘Essex Net Zero Policy – Technical Evidence Base’ (updated Sep 2025) to inform costs, which applied a 4% uplift to office and 13% for industrial to meet Net Zero.

Consequently, there is no clear or transparent evidence set out to demonstrate that the policy would be viable or capable of widespread implementation.

Further viability testing is required alongside evidence around the potential impact on affordability and whether the development industry will be able to meet these standards if the plan is adopted. In any event, inflated costs are likely to lead to delayed delivery or, in some cases, discounted or reduced housing output or reduced levels of affordable housing delivery.

REQUESTED CHANGE

The water‑stress challenges facing Cambridgeshire are acknowledged, but the proposed requirements exceed what can be delivered sustainably in the near term, given current supply‑chain capacity, cost implications and operational burdens associated with widespread on‑site recycling systems. A phased, evidence‑led approach aligned with the Future Homes Hub Water Ready pathway, using transitional measures and targeted offsetting through water utilities, would provide a more deliverable, lower‑risk route to achieving genuine water efficiency improvements. The policy also needs to provide for some flexibility where achieving the requirement is not possible for practical, viability or legal reasons.

The water efficiency threshold should be updated to be consistent for developments containing both less than and more than 100 dwellings, with water usage between 90 to 100 litres/person/day. There is no justification for differing standards. While the water stresses are acknowledged, there has been a failure of statutory authorities and water and sewerage companies to deliver appropriate infrastructure, and inconsistency with national policy will have viability and deliverability implications for all scales of development.

Proposed updated policy wording as follows:

Delete paragraphs a& b:

a. For residential development of 100 or more dwellings, water usage of no more than than 80 litres/person/day. To achieve this level, some form of water reuse or recycling will be necessary. Proposals that seek to deliver levels of water usage below this level are encouraged;

b. For residential development of less than 100 dwellings, water usage of 90 litres/person/day. Proposals that seek to deliver levels of water usage below this level are encouraged;

Replace with:

For residential development, all development must demonstrate highly water efficient design, with a target water usage of no more than 90-100 litres/person/day.

COMMENT

Policy CC/WE sets the levels of water efficiency that new developments must comply with, responding to the water supply pressures facing Greater Cambridge and the need to protect the water environment.

Para 1 requires new development to demonstrate that there will be an adequate water supply available to serve the development. It sets out the water efficiency thresholds to be adhered to. Of relevance, for residential development of 100 or more dwellings, water usage is expected to be no more than 80 litres/person/day and for residential development of less than 100 dwellings, water usage of between 90 to 100 litres/person/day.

The remaining parts discuss water efficiency measures to be included.

Hill Residential recognises the issues around water stress and supports in principle the importance of new developments to include water efficiency measures. However, a significant part of the problem faced is down to a failure by the water companies and statutory authorities to plan and deliver appropriate infrastructure.

The water efficiency requirements proposed under para 1 (a), which requires all major residential developments of 100 or more dwellings to restrict water usage to 80 litres/person/day is considered too onerous and will be difficult to achieve and implement in practice.

Part G of the Building Regulations sets a mandatory baseline of 125 l/p/d for new homes, but includes an optional, stricter requirement of 110 l/p/d. The proposed thresholds are therefore not consistent with national requirements, and it is requested that the proposed thresholds are amended to align with this. Notwithstanding the fact that the GCLP will be examined against the 2024 NPPF, we consider that it is important to note the direction of the new NPPF regarding standards in Local Plans and reliance on existing regimes, as referenced within Policy DM7: Relationship with other regulatory regimes

It is acknowledged that the recent consultation on Approved Document Part G “Sanitation, hot water safety and water efficiency” is unlikely to respond adequately to the acute and regionally specific water-stress risks facing Cambridgeshire. In light of this, it is proposed that the Future Homes Hub – Water Ready: A report to inform HM Government’s roadmap for water-efficient new homes (April 2024) is adopted as the more appropriate framework.

The Water Ready report sets out a phased and evidence-led pathway whereby:

• Water-stressed areas adopt a 90 litres per person per day (lpppd) standard from 2030 (to be confirmed in 2027), and a 80 lpppd standard from 2035 (to be confirmed in 2032).

• Seriously water-stressed areas adopt 90 lpppd from 2025, with any further reductions for 2030 and 2035 to be confirmed following sector collaboration and consultation in 2027 and 2032 respectively.

During these transitional periods, the report allows for enabling measures such as “water-reuse-ready” dual supply pipework and developer contributions, which may be more appropriate than mandating on-site water recycling systems prematurely. While there are examples of successful dwelling-level and communal recycling systems, widespread adoption in the near term presents significant risks, including limited supply-chain capacity, increased capital costs, and ongoing operational and maintenance burdens for occupants.

By contrast, upgrading existing local housing stock water related fixtures & fittings, through the incumbent water utility companies, using water-offsetting funds, offers a more equitable and lower-risk route to achieving water efficiency gains up to 2035.Accordingly, it is requested that a more balanced, phased approach which aligns with the Water Ready report is recognised with some flexibility around targets which exceed building regulation requirements (which is contrary to the WMS ), rather than pursuing higher specifications within compressed timeframes that may undermine deliverability and affordability. Such flexibility would allow for unusual viability pressures or legal implications to be considered.

GREATER CAMBRIDGE RESPONSE

Comments, including those offering general support for the policy approach and phasing of growth in the plan to align with new strategic water supply are noted. Concerns that the policy is setting unreasonable requirements on developers to produce evidence have been addressed by removing paragraph 1 of the policy so that the policy is focused on achieving high water efficiency design levels in new development.

We welcome the fact that the aforementioned change has addressed one element of our Regulation 18 representations.

UPDATED EVIDENCE

The Aspinall Verdi (AV) Greater Cambridge Local Plan Viability Main Viability Report (July 2026) acknowledges on p.127-128 that for schemes of 100 units or more, a requirement of less than 80 litres per person per day has been assumed at a cost of £6,000 per unit. For schemes of fewer than 100 units, a requirement of 90 litres per person per day has been assumed at a cost of £750 per unit, based on ‘Future Homes Hub – Water Ready: A Report to inform HM Government’s Roadmap for Water Efficient New Homes (April 2024)’.

Hill believes that the assumed costings underestimate the true costs of such provision.

For reasons above, it is requested that the draft wording of Para 6a of Policy CC/IW is deleted.

6a.There is capacity for wastewater treatment and 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 prior to the occupation of the development (where development is being phased, this must be demonstrated for each phase before first occupation);

OBJECT

Policy CC/IW establishes the principles for water management including ensuring proposals provide appropriate sustainable drainage systems alongside protecting and enhancing water quality.

Para 6 of Policy CC/IW concerns water quality. Specifically, part a of para 6 states that all development proposals must demonstrate there is capacity for wastewater treatment and adequate wastewater conveyancing infrastructure to serve the whole development.

Hill Residential supports in principle the importance of forthcoming proposals to ensure and deliver appropriate water management. However, the wording as proposed under Para 6a places full responsibility on the developer to demonstrate sufficient capacity rather than the relevant provider. Water and sewerage companies have a legal duty under sections 37 and 94 of the Water Industry Act 1991 to "maintain, improve, and extend" their networks to meet future development needs and to effectively deal with sewage. Consequently, it is inappropriate to ask developers to evidence something that they are not legally responsible for. The legal responsibility here is on the water companies. We consider this to be contrary to Paragraph 201 of the NPPF (2024) and Policy DM7: Relationship with other regulatory regimes in the NPPF (2026), which in the case of the latter, sets out the direction of travel regarding standards and regimes.

For these reasons, the draft wording of Para 6 of Policy CC/IW is requested to be deleted.

GREATER CAMBRIDGE RESPONSE

The policy seeks to ensure that development proposals would not cause detriment to water quality by ensuring that there is adequate wastewater treatment and conveyancing infrastructure to serve the development prior to occupation which would relate to each phase and as explained in the supporting text would be conditioned. Anglian Water’s next Drainage and Wastewater Management Plan (DWMP28) will look at the growth proposed in the Local Plan and what infrastructure will be needed to protect water quality. The Councils will continue to work collaboratively with Anglian Water during the development of this plan which will look at requirements at Cambridge Water Recycling Centre (WRC), Uttons Drove WRC and the other WRCs in Greater Cambridge. The strategic sites are planned for later in the plan period which will give a longer lead in time for investment in wastewater treatment infrastructure.

No changes have been made to the policy in relation to Hill Residential’s earlier Regulation 18 representations.

REQUESTED CHANGE

It is requested that the overall principles set out under Policy CC/CE are amended to have less emphasis on the presumption of retention, with less justification required for demolition and further flexibility included to allow for demolition when appropriate.

This includes amending the draft wording under Para 2 of Policy CC/CE to include the word ‘reasonable’:

“…Demolition will only be acceptable where it is demonstrated to the reasonable satisfaction of the Local Planning Authority that…”

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

If the policy is retained, additional justification criteria should be included in Para 2 of Policy CC/CE to allow for site viability and modern building requirements, including indoor and outdoor space standards, to be considered when demolition is proposed for redevelopments, alongside allowing for higher densities. We would also propose that strategic sites are excluded from the requirements of this policy.

Further, the threshold for the requirement of circular economy statements should be amended to be consistent to those applied to energy and water strategies and underpinned by a future Part Z of the Building Regulations methodology.

COMMENT

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.

Hill acknowledges the importance of waste minimisation. However, it is requested that in the drafting of para 2d, the word ‘exceptional’ is removed to accommodate 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).

The conversion of non-residential buildings to residential use requires careful consideration, as such typologies often do not lend themselves to successful conversion or other material considerations such as constraints of listed building and conservation area protections.

Constraints relating to storey heights, layouts, space standards, structural systems, daylight provision, and thermal performance frequently limit viability and/or quality, with demolition therefore often representing the only feasible outcome. This is acknowledged alongside the recognised value of circularity assessments and whole life carbon assessments.

Para 2 of the policy places undue emphasis on the retention and refurbishment of existing buildings, which risks delivery of optimal development outcomes. Prioritising retention in this way can limit opportunities for effective densification and the efficient use of land, running counter to the 2024 NPPF’s objectives to optimise development potential in well-located and sustainable locations and to support the effective reuse of previously developed land, specifically paragraphs 124, 129 and 130.

It is also contrary to the new NPPF (August 2026), which states within Policy L3: Achieving Appropriate Densities that “within settlements, development proposals for residential and mixed-use development should contribute to an increase in the density of the area in which they are situated. The only exception is where there is a clear justification that this is either inappropriate or not possible (for example, where the prevailing density is already very high, the nature of the accommodation required precludes higher densities, or where it would conflict with other policies in this Framework). In considering the potential to increase densities, the existing character of an area should be taken into account, in accordance with policy DP3, but should not preclude development which makes the most of an area's potential”.

A presumption in favour of retention also risks introducing significant viability and deliverability challenges. Experience in London where similar policies exist, demonstrates that the evidential burden required to justify demolition can be disproportionate, increasing time, cost and risk for applicants and, in turn, reducing appetite for investment. This can result in compromised schemes that are designed around existing structures rather than delivering high-quality, policy-compliant development.

As drafted, the policy and associated exceptions do not adequately acknowledge the wider design and delivery implications of retention-led approaches. These include constraints on achieving efficient layouts, meeting internal and external space standards, delivering private outdoor amenity space, securing dual-aspect dwellings, and providing fully accessible homes. There is also uncertainty as to the willingness of Registered Providers to acquire affordable housing delivered through non-standard construction methods or with compromised layouts arising from retention.

These considerations highlight the need for a more balanced approach. While the retention and refurbishment of existing buildings clearly have a place, this should not be at the expense of proposals involving demolition and redevelopment where these would better meet the objectives of the NPPF, including optimisation of land, delivery of sustainable growth, and the provision of high-quality homes.

In relation to circularity assessments, the proposed 150-dwelling threshold appears inconsistent with other policy triggers, such as those applied to energy and water strategies. Greater alignment across policy thresholds for major schemes would be beneficial.

We also look forward to further clarity on the scope, methodology, and targets for circularity assessments, together with their relationship to whole life carbon assessment. In our view, these objectives would be most effectively delivered through the introduction of a new Part Z to the Building Regulations.

We 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.

GREATER CAMBRIDGE RESPONSE

In response to concerns about point 5 of the policy and the timing of the Circular Economy Statement requirement, similarly to the GLA approach to Circular Economy used successfully in London, a circular economy statement will now be required at submission stage to demonstrate how the development has utilised the principles to consider the approach to the site and the re-use of buildings, building elements and details. It is stated that this is being asked for at this stage as these considerations will feed into the operational energy and whole life carbon calculations completed at this stage. An Outline scheme will require less detail than a Reserved Matters application and this will be set out in the supporting technical notes and sustainability checklist.

An amendment has been made to specify that the threshold for requiring Pre- Demolition Audits will be proposals of 500sqm or more of floorspace.

A new section 8 has been added to the policy that refers to when excavated materials recovered on a site via a treatment operation can be reused on site.

REQUESTED CHANGE

It is considered that draft Policy BG/BG needs to better align with other draft GCLP policies and housing requirements, with a requirement to achieve 10% BNG uplift consistent with national legislation. A 20% BNG uplift should be an aspirational target and only be required where sites can reasonably accommodate this, having regard to viability and other policy requirements. Developers should not be expected to address existing biodiversity deficits that are totally unrelated to their proposed developments.

OBJECT

Draft policy BG/BG concerns biodiversity uplift and enhancement. Para 1 requires all development to provide a minimum of 10% BNG (biodiversity net gain) against the baseline BNG value. Para 2 requires all major development to provide a minimum of 20% uplift. Para 3 relates to the submission of Biodiversity Gain Plans and Para 4 highlights opportunities to align with the Cambridgeshire and Peterborough Local Nature Recovery Strategy. Para 5 outlines the requirements for offsite BNG provision where required, with the remaining parts then setting out the principles for ensuring the adequate protection of biodiversity and geodiversity

Hill recognises the importance of biodiversity protection and associated enhancement around the Greater Cambridge Area.

However, the 20% uplift required for major developments as set out under para 2 of draft policy BG/BG does not align with the direction of travel in the new draft NPPF which states local planning authorities should not be going above 10% uplift, the mandatory national requirement as set out in the Environmental Act 2021. If adopted as per the consultation draft, the 20% uplift would be inconsistent with legislation and national planning policy. Further para 74-006-20240214 of the PPG states that “… plan-makers should not seek a higher percentage than the statutory objective of 10% biodiversity net gain, either on an area-wide basis or for specific allocations for development unless justified.

Policy N1: Identifying Environmental Opportunities and Safeguards in the NPPF (2026) states that development plans should only set local standards for biodiversity net gain which are in excess of the statutory net gain requirement where this is for specific site allocations and is fully justified and deliverable. Local standards should not extend to categories of development which are exempt from statutory biodiversity net gain. This clearly shows the Government’s direction of travel and recognition of the importance of ensuring that development is viable.

Policy N2: Improving the Natural Environment (a national decision-making policy) specifies in section 3 that development proposals may incorporate biodiversity enhancements which exceed the statutory objective for biodiversity net gain, but this should only be a requirement where it is set out in up-to-date development plan policies for specific site allocations. Decision-makers should not give weight to other development plan policies which require biodiversity gains which go beyond the statutory framework, including where a policy requires gains for development proposals which are exempt.

To justify such policies, they will need to be evidenced including as to local need for a higher percentage, local opportunities for a higher percentage and any impacts on viability for development. Consideration will also need to be given to how the policy will be implemented”. It is considered that there is no justification in the evidence base as to why the plan should seek to deliver more than 10% or around the impact on viability, especially where offsite delivery and credits are required.

A proportionate approach could involve adopting the 10% national baseline, with an aspirational target towards 20%, where a site can reasonably accommodate this having regard to viability and other policy considerations. In such cases, flexibility across other planning requirements (for example, reduced operational and/or embodied carbon standards and/or urban greening factors (see below) could be considered to help maintain viability. Alternatively, an offsetting mechanism above the 10% threshold could be used to support local nature assets; however, it should be recognised that this additional cost would inevitably have implications for development viability.

In tandem with other policy considerations set out within the draft GCLP (Policies BG/TC, BG/GI, Policy BG/EO, Policy WS/NC, and Policy H/SS), these policies in conjunction restrict opportunities for density uplift and achieving housing delivery. 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).

To maintain an appropriate balance between new homes delivery and the implementation of Biodiversity Net Gain (BNG), any local policy exceeding the national 10% requirement must carefully consider its impacts on land values, affordable housing delivery, Section 106 obligations, Community Infrastructure Levy (CIL) contributions, and overall scheme viability.

GREATER CAMBRIDGE RESPONSE

The Authorities state that in response to concerns about the policy exceeding 10% national mandatory BNG specifically citing the draft NPPF (which sets out that LPAs should not be going above 10% BNG), the Councils have not made any changes to the Plan to respond to comments recommending alignment with the consultation on revised National Planning Policy Framework (NPPF) and other changes to the planning system held between December 2025 and March 2026. National Planning Practice Guidance on BNG sets out that plan makers may seek a higher percentage than the statutory objective of 10% BNG either on an area-wide basis or for specific allocations for development unless justified, and where this is supported by local evidence, including local need, local opportunities; and impacts on viability for development. It is stated that in the Biodiversity and Green Spaces Topic Paper the Councils have provided robust justification for the policy approach for 20% BNG for major development and 10% for minor development in Greater Cambridge, through evidence, analysis of local data and reasoned justification of the implementation of the policy in practice.

UPDATED EVIDENCE

The Biodiversity and Green Spaces Topic Paper states that the Cambridge City Biodiversity Strategy 2022-30 and (March 2026) and the South Cambridgeshire Climate and Nature Strategy 2026-2030 (March 2026) highlight that Cambridgeshire is one of the most nature-depleted areas within the country. It is therefore vital to create quality, species-rich habitats, and in doing so increase residents’ access to nature and green spaces in Greater Cambridge. In summary, it says that Greater Cambridge can justify its higher percentage due to its local biodiversity deficit.

The Aspinall Verdi (AV) Greater Cambridge Local Plan Viability Main Viability Report (July 2026) states on p.131 that it has included biodiversity net gain costs of £1,793 per unit for greenfield sites and £392 per unit for brownfield sites. This is based upon the DEFRA ‘Impact Assessment Biodiversity net gain and local nature recovery strategies IA No: RPC Reference No: RPC-4277(1)-DEFRA-EA’ (dated 15/10/2019) to establish the cost of the 10% increase, with the further increase to 20% based on the SQW report ‘Viability Assessment of Biodiversity Net Gain in Essex’ (August 2024).

On p.132 it states that “We note that the cost of implementing biodiversity net gain is an emerging cost, and we are monitoring this and seeking up-to-date evidence that can be relied upon”.

Given the above, Hill strongly question where the viability evidence is to justify the 20% BNG policy requirement.

REQUESTED CHANGE

To ensure green infrastructure requirements are reflective of, and are not inconsistent, with national standards and guidance and adequately reflect and address viability concerns.

COMMENT

Policy BG/GI of draft GCLP seeks to protect and enhance green infrastructure, and identifies a number of strategic green infrastructure initiatives.

Hill Residential’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 this particular policy and now form a separate new policy (BG/UGF: Urban Greening Factor).

We note that there have been a few other changes to the policy text.

Section 2 of the policy now states that planning applications for major development must submit a Green 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.

The Authorities will need to be mindful of the content of the NPPF (2026) regarding information requirements to ensuring that they are both appropriate and proportionate.

GREATER CAMBRIDGE RESPONSE

In response to Natural England’s request for a GI design code, the policy now requires submission of a GI Statement or GI Plan to be submitted with every application for major development helps to ensure that GI is integrated into development from the outset and ensures its long-term management and maintenance. This is supported by the Greater Cambridge GI and Open Space Standards Framework (2026) (see Chapter 4) which provides guidance which outlines the various requirements needed for GI Statements / GI Plans at various stages of the planning application process.

The requirement for a minimum UGF factor has been added to the plan as a standalone policy, informed by the Greater Cambridge Green Infrastructure and Open Spaces Standards Framework Final Report (June 2026). The report considered the inter-play between all the proposed GI standards to ensure the policy approach was proportionate and robust and concluded that no significant conflicts were found that would impact the final framework.

UPDATED EVIDENCE

The Aspinall Verdi (AV) Greater Cambridge Local Plan Viability Main Viability Report (July 2026) states on p.19 that “costs for design work are included in professional fees; delivery costs are included in external works. Accreditation is optional, so no additional cost included. High-quality green infrastructure may support sales values”.

Hill would highlight that the production and implementation of GI Operation and Maintenance Plans over the lifetime of developments will clearly have associated costs.

REQUESTED CHANGE

To request that the requirements to achieve greening factors of 0.4 or 0.5 are more aligned with other policy requirements and reflect the feasibility of achieving green infrastructure initiatives. Specifically for the factor to be aligned with 10% Biodiversity Net Gain (BNG) requirements and introducing UGF at a lower initial target of 0.2, with scope for aspirational targets of 0.4 and 0.5 where a site can reasonably accommodate this having regard to viability and other policy considerations.

This is a new policy that previously formed part of Policy BG/GI: Green Infrastructure. Hill Residential’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.

Hill Residential supports in principle initiatives to improve the green infrastructure network around the Greater Cambridge Area. However, it is considered that achieving greening factors of 0.4 or 0.5 compromises the ability to deliver viable developments when balanced against other policy requirements as set out in the draft GCLP ,namely Policy BG/BG, Policy BC/TC Policy BG/EO, Policy WS/NC, and Policy H/SS. These restrict opportunities for density uplift and delivery of housing supply.

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). No assessment around the cost or impact on developable area and viability of the proposed policy seems to have been provided in the evidence base and therefore it cannot be justified at this time.

Further, 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.

Clarification is also requested towards the definition of urban greening and whether this refers directly to the Urban Greening Factor (UGF) as set out in the London Plan.

In this context, we respectfully request that any approach to urban greening is proportionate and balanced. Specifically, we suggest aligning Urban Greening Factor (UGF) requirements with a 10% Biodiversity Net Gain (BNG) ceiling and introducing UGF at a lower initial target, such as 0.2. A proportionate approach could involve adopting a factor of 0.2 with an aspirational target of 0.4 or 0.5 where a site can reasonably accommodate this having regard to viability and other policy considerations.

GREATER CAMBRIDGE RESPONSE

The Authorities state that the London Plan successfully applies the urban greening factor of 0.4 and 0.3 and renewable energy requirements to meet both objectives. Requirements for rooftop solar alongside greening policies will be addressed on a case-by-case basis. The Viability assessment of the Plan demonstrates that the Plan as a whole is viable, considering the impact of the greening policies. Therefore, the requirement for the UGF in planning policy is justified and officers have worked with Natural England and LUC to ensure that the policy requirements for UGF as set out BG/UGF are feasible and aligned with national policy and guidance.

UPDATED EVIDENCE

The Aspinall Verdi (AV) Greater Cambridge Local Plan Viability Main Viability Report (July 2026) does not include any reference to Policy BG/UGF or its viability.

REQUESTED CHANGE

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.

COMMENT

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 aboricultural 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.

In its earlier representations, Hill Residential 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, Hill 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).

Given that Greater Cambridge currently has an estimated baseline tree canopy cover of approximately 13.5%, it would be more appropriate to adopt a phased “staircase” approach, with incremental increases every 3–5 years. This would support improved climate resilience while avoiding unintended consequences for dwelling densities and the design and adaptation of public highways, footpaths, and public realm. In addition, higher canopy targets may necessitate alternative construction approaches, such as piled foundations in place of traditional strip foundations, with associated cost and viability implications.

GREATER CAMBRIDGE RESPONSE

The Urban Forest Strategy 2026-2036 reaffirms Cambridge City Council’s promise to restore, protect and grow Cambridge’s tree canopy cover to 20% by 2050, within the context of a changing climate and the rising threat of pests and diseases. South Cambridgeshire District Council’s Corporate Plan 2025-2030 strengthens the Council’s commitment to ‘Being Green to our Core’ by reducing carbon emissions within its own operations, enabling the rest of the district to reduce emissions, increasing tree canopy and ‘nature rich’ areas in the district. This policy supports these priorities by seeking to conserve and protect existing trees, and by requiring and encouraging new or replacement planting to enhance this resource now and in the future.

UPDATED EVIDENCE

The Aspinall Verdi (AV) Greater Cambridge Local Plan Viability Main Viability Report (July 2026) states that on p.19 that the cost of preparing the assessment would be included in professional fees; planting and landscaping costs included in external works.

It is not evident that the wider financial costs associated with the tree canopy cover policy have been adequately considered in the Viability Assessment.