Greater Cambridge Local Plan: Proposed Submission

REQUESTED CHANGE

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

COMMENT

Policy BG/PO concerns the protection and provision of open space. Of relevance, para 2 stipulates the requirements for open space replacement which should be

a. located within a suitable distance of the original site having regard to the Natural England Accessible Greenspace Accessibility Standards and

b. fully available for use before the area of open space to be lost can be redeveloped.

Hill Residential submitted representations at the Regulation 18 consultation stage that point b of para 2 requiring replacement open space to be in operation prior to the loss of existing space does not accommodate for practicalities regarding site deliverability, construction and access. Whilst this applies to all types of development, it is particularly relevant for previously developed brownfield sites where redevelopment may need to be phased to allow for demolition if relevant, and associated implementation of green and blue infrastructure. Requiring full open space provision prior to construction and completion of building may have implications on cash flow, deliverability, site logistics and thus viability of a site.

GREATER CAMBRIDGE RESPONSE

Whilst house builders sought greater flexibility regarding the requirement for the new space to be provided before the site can be redeveloped, this point has been retained to ensure continuous access to open space for the local community.

No changes have been made to the policy at the Regulation 19 stage, so Hill Residential’s earlier expressed objection remains.

REQUESTED CHANGE

To request that the provision of open space takes full account of other policy requirements and is flexible enough to reflect overall viability costs and individual site constraints on housing delivery, including in relation to the overall developable area of sites.

Policy BG/EO sets out the open space requirements and standards.

Hill Residential in principle supports the provision of open space with new developments. However, in its Regulation 18 representations it highlighted the importance of ensuring such provision is balanced with other policy requirements as set out in the draft GCLP, namely Policy BG/BG, BG/GI, Policy BC/TC, Policy: WS/NC Policy BG/EO and Policy H/SS, which restrict opportunities for density uplift and delivery of housing supply with overall reduction in net developable area. It is equally important that such provision if required to be delivered off site does not result in high financial contributions or risk of delay to development.

The policy has been significantly amended. Section 3 specifies that:

“All major developments that are predominantly residentially led must demonstrate total provision of accessible greenspace equivalent to 7.0 hectares per 1,000 population, and within this total, deliver a minimum on-site accessible greenspace provision that:

a. Is equivalent to 3.0 hectares per 1,000 of the population, unless the calculated on-site quantum falls below a functional minimum parcel size of 0.5 hectares. In such cases, the shortfall must be secured off-site; and

b. Ensures access for all residences within the development to at least one appropriate tier of greenspace within the size-proximity criteria (as defined in Figure 111)”.

Section 5 of the policy now stipulates that all green and/or open space must be designed to be welcoming and accessible meeting the needs of all users, with habitats and infrastructure appropriate to the local character and typology of greenspace. Green and/or open space design and management planning must have regard to best practice guidance as defined by the Green Flag Award criteria.

Hill Residential questions whether it is ever possible to demonstrate that sites would ever be capable of ‘meeting the needs of all users’ (our emphasis).

GREATER CAMBRIDGE RESPONSE

Some developers expressed the view that the policy was too rigid, and did not account for the varied operational and spatial needs of employment and commercial development in Greater Cambridge. It was noted within comments that the quantum of AGS that a proposal can deliver will very much be dictated by site context, constraints and opportunities and will need to be recognised in the policy. Concerns were raised by developers that a generic open space requirement could hinder site layouts and reduce development capacity, conflicting with national policy and the Government's growth ambitions.

The HBF objected to the introduction of a standard for major residential development suggesting that where there are play spaces within close proximity to a development it may be a more effective approach for improvements to be made to those spaces rather than requiring provision on site.

Objections from developers were received on the lack of clarity on the standards, the lack of a defined methodology for calculating greenspace requirements and that the policy aim is not clearly explained to plan users. Concerns were raised about the accuracy of the Green Infrastructure Strategy mapping, the reported 8.7 Ha of accessible greenspace per 1,000 population (and whether this figure is sufficient to meet future needs), and the risk of overlapping and conflicting requirements which may make viability and deliverability challenging. A further comment was received which stated that referenced data used by GCSP is not up to date.

Further responses highlighted the importance of including land acquisition costs in the overall figures for strategic natural greenspace provision.

Sections 8-10 of the policy relate to play and youth space. All major developments that are predominantly residentially-led must demonstrate provision of play and youth space equivalent to 0.6 ha per 1,000 population (it was previously 0.55 ha at the Regulation 18 stage). This should include at least 0.25 ha per 1,000 population of equipped play and at least 0.3 ha per 1,000 population of informal play provision.

Section 11-12 of the policy specifies that all major developments that are predominantly residential led must demonstrate provision of food growing space equivalent to 0.4 ha per 1,000 population. Food growing spaces should be provided on-site by default. The design, approach to on or off-site provision, and management of food growing spaces must be informed by the Food Growing Study or successor document. Any shortfall in the provision of food growing spaces on-site must provide a financial contribution towards the provision of food growing space offsite.

Section 14 of the policy specifies that all green space, open space, play and/or food growing space must have an adopted management plan (GI Operation and Maintenance Plan), outlining how the space will be managed over a 30-year period, and the funding and stewardship arrangement for implementing the management plan, secured via condition.

Whilst Hill Residential is sympathetic to the sentiments that underpin the policy, it is concerned about the potential inflexibility and cost of the aforementioned policy requirements, which will not always be practical to implement on every site.

UPDATED EVIDENCE

Following updated evidence and recommendations from the Greater Cambridge GI and Open Space Standards Framework (2026), the policy now sets out how development proposals will be subject to minimum quantity, quality and accessibility greenspace standards, with the Councils seeking to implement Natural England’s Green Infrastructure Framework as applied to the Greater Cambridge area.

The headline standard is to require Accessible Green Space, which accounts for a range of green space typologies listed in the supporting text.

The Aspinall Verdi (AV) Greater Cambridge Local Plan Viability Main Viability Report (July 2026) states that on p.19 that the costs for delivering on-site open space included external works and could have a positive impact on value. Additional enhancements for open space have been included in the IDP costs

REQUESTED CHANGE

To ensure that the viability costs of this policy are properly considered.

To delete para 2 in its entirety, so as to avoid repetition with other draft policies.

To request that the threshold of a full HIA submission is increased to 500 dwellings, a rapid HIA for schemes of 200-500 dwellings; and no requirement for an HIA for schemes of 200 or less dwellings.

COMMENT

Policy WS/HD details how new development can support the promotion of everyday health wellbeing and lifestyles of residents. Para 2 sets out principles new developments should incorporate to facilitate the delivery of healthy lifestyles in accordance with other policies within the Local Plan. Para 4 sets out the thresholds for when HIAs will be needed, with full HIAs required for proposals of 100 dwellings or more or 5,000m2 of gross internal floorspace (GIA).

Hill Residential supports the principle of new developments promoting healthy and active lifestyles. However, para 2 of Policy WS/HD relists principles that are addressed in other policies in draft GCLP linked to housing, biodiversity and green spaces.

For consistency and avoidance of replication, it is preferred that the wording in para 2 is deleted to avoid unnecessary repetition and principles which are addressed under other draft policies.

Hill Residential does not object to the principle of HIAs as part of major developments as required by para 4. However, it is requested that the threshold for full HIAs is increased to 500 dwellings rather than 100 dwellings (to be more proportionate with the HIA requirements), with a rapid HIA for schemes of 200-500 dwellings and no requirement for a HIA for schemes of 200 or less dwellings.

GREATER CAMBRIDGE RESPONSE

The policy seeks to highlight the importance of place in the health and wellbeing of individuals and communities and to outline how Local Plan policies seek to help to create healthy places. It is recognised that clarity is required that the policies listed in part 1 (now part 2) are not standalone policies and amplify rather than duplicate policies elsewhere in the plan. As such, many of the issues raised, including in respect of active travel, are addressed in policies in other themes such as Great Places and Infrastructure. Evidence behind each element of the policy can be found in the Health and Wellbeing Topic Papers at each stage of the Plan as well as in the Consultation Statement. Including the policy requirements in an overarching policy prevents duplication and ensures consistency.

The Health Impact Assessment Supplementary Planning Document was consulted on in November 2024 to January 2025 and adopted in April 2025, this confirmed the thresholds for HIAs in Greater Cambridge. It is considered appropriate by the Councils that the Plan requires their application across Greater Cambridge. The SPD HIA checklist includes a number of areas raised by respondents including Access to Healthy Food and older people as a protected group. The HIA process ensures that impacts on all groups are considered in the HIA process including residents, workers and visitors. It is expected that the application of Healthy New Town Principles will be proportionate to the nature of the site.

UPDATED EVIDENCE

The Aspinall Verdi (AV) Greater Cambridge Local Plan Viability Main Viability Report (July 2026) fails to mention or provide any indicative costs relating to the implementation of this policy.

REQUESTED CHANGES

To ensure that the viability costs of this policy are properly considered.

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

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

To remove the requirement for groups of smaller sites to undertake a detailed assessment of community need.

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

Clarification is requested over future management of such facilities and assurance that it is not the responsibility of the developer to undergo the task to identify the local need and deficiency for potential future facilities.
Appropriate wording should also be included to reflect for circumstances where improvements or expansions to existing facilities within the immediate area would be more efficient than new onsite deliver,

COMMENT

Policy WS/NC of draft GCLP seeks to ensure that new development contributes towards the delivery of new services and facilities to meet the needs of residents. The supporting text to Policy WS/NC identifies the types of services and facilities that the policy applies to, including education, libraries, health, indoor and outdoor sports facilities, and community development. Reference is included to identified and addressing needs, the provision of indoor community facilities and implementation.

Of relevance, para 3 of Policy WS/NC requires that “developments of sufficient scale to generate the need for new on-site facilities will be required to do so, unless it can be demonstrated that there would be advantages in delivering the facilities off site. Acceptable provision and arrangements will be determined in consultation with service providers”.

Part 4 requires residential developments of 200 dwellings or more, or collections of smaller sites that together exceed this threshold, to be informed by a detailed assessment of community needs and to incorporate strategies to address those needs.

Part 5 concerns the delivery of indoor and outdoor community facilities, requiring that “all residential development will contribute towards the provision of indoor and outdoor community and cultural facilities to meet the needs generated by the development. Development of sufficient scale to generate the need for new on-site facilities will be required to do so, unless it can be demonstrated that there would be advantages in off-site delivery. Other developments will contribute to off-site provision through planning obligations or through a Community Infrastructure Levy (CIL) as appropriate”.

Hill Residential supports the principles behind Policy WS/NC in delivering appropriate community facilities, which are important contributors to community cohesion and place.

The wording, however, as drafted under paras 3 and 5 of Policy WS/NC concerning the delivery of onsite facilities is considered as vague and unclear when the policy requirements will be triggered. The threshold for “Developments of sufficient scale” should be defined and specified. There is also general overlap in the requirements of para 3 and 5 and for purposes of conciseness, it is requested that these are combined.

Regarding para 4, there is a lack of clarity around how the councils intend to define the geographic area within which smaller developments would be required to consider cumulative impacts, or the methodology by which such assessments would be carried out. In practice, it is unlikely that all sites within an area will be brought forward simultaneously, raising the prospect that an early scheme could be expected to assess and address infrastructure impacts in advance of later developments. This would be neither practical nor reasonable and risks conflicting with the tests for planning obligations set out in paragraph 58 of the NPPF. On this basis, Hill considers that the requirement for groups of smaller sites to undertake such assessments should be deleted.

The requirement also to provide onsite indoor and outdoor community and cultural facilities as required under para 5 of Policy WS/NC when balancing against other policy requirements as set out in the draft GCLP, namely Policy BG/BG, BG/GI, Policy BC/TC, Policy BG/EO and Policy H/SS, restrict opportunities for density uplift and delivery of housing supply with a reduction in developable residential area. There are also risks for site viability to accommodate for these considerations, essential in delivering affordable housing requirements (draft policy H/AH) and infrastructure delivery (draft policy I/ID).

It is considered that para 5 of draft policy WS/NC needs to better align with other draft GCLP policies and housing requirements, in order to ensure that such provisions are actually deliverable.

It is important that smaller or medium sized sites are not required to contribute to or deliver facilities beyond their own demand, and that the requirement to provide community facilities does not compromise the speed of site delivery, for example through protracted S106/third party negotiations.

It is also noted that no clarity is provided on who adopts and funds the long-term operation of such onsite community facilities. Clarification is requested.

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

GREATER CAMBRIDGE RESPONSE

The Policy has been written in accordance with the then current NPPF and informed by a number of studies including the Community Infrastructure Study and Cultural Infrastructure Strategy which will also inform the Infrastructure Delivery Plan to support the Local Plan. These studies recommend Community and Cultural Plans be developed, respectively to inform the type of infrastructure that should be provided and whether this should be on site or off site, or a combination of both. This will provide a flexible approach that takes into account local considerations and opportunities nearby to maximise investment in these facilities and make the best use of development land. The policy has been amended to clarify how indoor and outdoor community and cultural facilities should be provided and secured.

The provision and location of healthcare facilities should aim to meet the need of existing and new residents, which may include the need for community-based, out-of-hospital facilities. The Local Planning Authorities have engaged with the relevant health organisations in developing the Infrastructure Delivery Plan that accompanies this Local Plan. Developers of large-scale sites and new communities will also need to engage with health providers to understand and respond to healthcare needs.

UPDATED EVIDENCE

The Aspinall Verdi (AV) Greater Cambridge Local Plan Viability Main Viability Report (July 2026) states that “costs assumed within surplus for s106 contributions based on standard approach to infrastructure planning”.

REQUESTED CHANGES

The policy be substantially rewritten in order to remove overly rigid target figures and incorporate much greater flexibility so that it is capable of actual implementation across the Greater Cambridge area so as to ensure that construction can commence, or not be halted, should there be difficulties concerning the implementation of an Employment and Skills Plan.

COMMENT

Policy WS/IO sets out how new development will provide training, employment and supply chain opportunities to local residents and businesses through the creation and implementation of an Employment and Skills Plan. For new developments of 10 or more dwellings, schemes will be required to submit and implement an Employment and Skills Plan for the construction stage with the policy then stipulating the associated criteria of what this should include.

The policy requires that new developments of 1,000 square metres or more gross floorspace that fall within Use Classes E (commercial, business and service); B2 (general Industrial), B8 (storage and distribution); C1 (Hotel); F1 (learning and non-residential); F2 (local community) and Sui generis will be required to submit and implement an Employment and Skills Plan for both the construction and occupation stages of the development. A development that forms part of a larger development which would cumulatively exceed the 1,000 square metres threshold would also be required to deliver a Skills and Employment Plan.

It is stated that whilst Employment and Skills Plans will be agreed on a site-by-site basis, they will be expected to include:

a. How and when the developer will, as a minimum, deliver the benchmarks for the development use and gross development value set out in the latest version of the Construction Industry Training Board (CITB) National Skills Academy for Construction (NSAfC) Project Based Approach guidance and benchmarks;

b. Where required by this policy, how and when the developer will, as a minimum, deliver the employment and training targets in the occupation stage of the development;

c. How these opportunities will be made available to local residents who have difficulty accessing the labour market and/or who would not have traditionally accessed the career paths available through the development; and

d. How procurement opportunities associated with the construction and occupation phases will be promoted to local businesses and what support will be available to them to understand the tendering process.

Section 4.requires that development proposals must secure 20% of all jobs created by the construction phase of the development for local residents. Whilst the aspiration to ensure job creation for local people is supported, it is not clear what evidence is available to demonstrate that this rigid requirement figure is either appropriate or achievable throughout the Greater Cambridge area taking into account the existing and likely labour market this policy would be drawing upon.

Additionally, Section 5 specifies that applicable development proposals must provide a minimum number of supported employment places to local residents during the occupation phase of the development, calculated using the formula set out in the supporting text to this policy.

Section 9 goes on to state that developers will be expected to use reasonable endeavours to implement the agreed Employment and Skills Plan. The developer will be required to provide monitoring reports for review by the councils on the implementation of their Plan at agreed regular intervals. Should instances occur where the target outputs in Employment and Skills Plans are not met or are partially met and the councils consider that reasonable endeavours have not been made an equivalent contribution for the shortfall in outputs will be sought by the councils.

Hill Residential are fully supportive of the overall aims of the policy to provide jobs for local residents, which is highly laudable. However, it has serious concerns regarding the operation and practical application and enforceability of this policy, including the implications where insufficient capacity or capability exists in the labour-force to service the policy demands. It also raises practical questions as to the implications for organisations already operating within the area who may be seeking to relocate to new premises and the potential impact upon their existing labour force which may not comprise the ratios being sought through the occupation phase calculator. It would be perverse to discourage existing businesses and institutions from improving their accommodation through fear of otherwise being challenged by planning policy, whilst the strict wording also raises questions of compatibility with employment law centred around discrimination.

Furthermore, it must be recognised that the Greater Cambridge Authorities are also intending to introduce a Community Infrastructure Levy (CIL) in addition to S.106 policy contributions.[MO1.1][PC1.2] Consequently, we are concerned that the overall viability of employment provision could be threatened by any overly onerous policy requirements.

GREATER CAMBRIDGE RESPONSE

The policy approach is justified by national and local policy considerations that address local inequalities and skills shortages. Further information on both areas was set out in the Wellbeing and Social Inclusion Topic Paper in 2025. There are a range of examples of similar policies being operated in other areas where these issues are also present. Evidence for the need for a policy has been clearly established. Further details have been added to the Proposed Submission Local Plan to clarify elements of its implementation.

Some comments highlight opportunities regarding how the policy could be delivered, and linkages to other schemes. The policy is flexible enough that specific opportunities can be responded to during implementation. The policy also includes a mechanism for in lieu payments where measures cannot be delivered on site. Some comments raised issues regarding site specific implementation, but the policy has sufficient flexibility to respond to site specific circumstances.

UPDATED EVIDENCE

Hill Residential note that p.140 of the Aspinall Verdi Greater Cambridge Local Plan Viability Main Viability Report (Regulation 19 Stage) (July 2026) states that the cost of preparing and monitoring Employment and Skills plans is expected to be modest relative to scheme size. We believe that this underestimates the likely time and complexity of completing the Employment and Skills Plans. Furthermore, it fails to factor in the 'in lieu' financial contributions that could become payable at a later stage if/when the targets of the Employment & Skills Plan are not met.

Further to this, Hill Residential are particularly concerned regarding the incorporation of rigid and inflexible targets within the policy.

REQUESTED CHANGE

To amend the policy wording to include affordable viability adjustment mechanisms and flexibility to depart from the specified tenure split in appropriate site-specific circumstances where an alternative mix can be robustly evidenced and justified.

To allow for policy consideration for clustering of affordable dwellings from a management and maintenance perspective.

COMMENT

Policy H/AH sets out the minimum affordable housing delivery requirements as well as specifying the tenures of affordable housing required to address identified needs.

Hill Residential recognise the importance of affordable housing delivery; however, it is considered that the policy does not include broad viability adjustment mechanisms, except for very narrow exemptions (vacant building credit, Build to Rent, C2 uses). It is requested that further flexibility is provided in the policy wording to allow for considerations of market volatility, build cost inflation or local constraints.

Further, the proposed affordable housing policy has evolved to introduce more prescriptive requirements, particularly in relation to tenure mix on developments. For 10-14 dwellings it requires 75% social and affordable rent homes and 25% shared ownership homes, or other homes providing a route to home ownership.

For developments of more than 15 dwellings. The policy now requires such schemes to deliver 65% affordable rent, 10% social rent and 25% shared ownership (or other affordable tenures that provide a route to home ownership).

In its Regulation 18 representations, Hill Residential stated that as drafted, the policy provides no flexibility to depart from the specified tenure split where an alternative mix could be robustly evidenced and justified. In hill
practice, it is common for tenure mixes on larger, more complex/strategic sites to evolve as proposals are refined, often through the preparation of a bespoke, site-wide affordable housing strategy submitted alongside a planning application. Such an approach provides a more effective and responsive mechanism for determining an appropriate affordable housing mix, reflecting site-specific circumstances and identified needs.

Hill Residential's Reg 18 representations also asked that the criteria for assessing the suitability of clustering was altered to include consideration of cost-effective management, reduced service charge burdens and the preferences of the Registered Providers responsible for their ongoing management and maintenance.

These concerns remain given the Regulation 19 version of the policy has failed to incorporate these necessary amendments.

GREATER CAMBRIDGE RESPONSE

National planning policy requires local authorities to assess the size, type and tenure of housing needed for different groups in the community, including those who require affordable housing, and reflect the results of this assessment in their planning policies. The Councils state that they have evidence that there is high level of need for affordable housing in Greater Cambridge, and it is important we seek a significant contribution from developments to respond to this need. Seeking high levels of affordable housing by securing at least 40% affordable homes on major development sites and at least 50% affordable homes on land within the Green Belt, and by enabling the provision of affordable housing on rural exception sites (see Policy H/ES), will make a significant contribution towards responding to their identified affordable housing needs. The Councils state that their viability assessment demonstrates it is viable to seek 40% affordable homes on major development sites and 50% affordable homes on land within the Green Belt, but that a higher percentage will impact on the viability and delivery of sites.

All major developments for housing must provide on-site affordable housing or in specific circumstances either a financial contribution to enable delivery of affordable housing elsewhere or linked off-site provision. National planning guidance states that 20% is generally a suitable benchmark for the level of Affordable Private Rent homes to be provided in any Build to Rent scheme, but that local authorities can set a different requirement if justified by evidence.. The Councils maintain that their Viability Assessment shows that it is viable for any major developments for housing (irrespective of their use class of C2, C3, C4 or sui generis) to provide affordable housing or a financial contribution.

UPDATED EVIDENCE

Hill Residential note that p.33 of the Aspinall Verdi (AV) Greater Cambridge Local Plan Viability Main Viability Report (Regulation 19 Stage) (July 2026) acknowledges that this policy will have direct cost implication as the provision of onsite affordable housing has a significant downward effect on the GDV.

For the purposes of viability testing, AV have applied a blended affordable housing tenure across the Greater Cambridge area. Rather than testing each authority’s requirements separately, it has combined the different policy percentage targets that apply in Cambridge City and South Cambridgeshire into a single, averaged rate. It states that this provides a pragmatic and representative assumption that reflects the overall direction of policy across the two districts and allows them to assess cumulative viability impacts on a consistent basis across the plan area.

In accordance with the PPG, AV acknowledges that policy requirements, particularly for affordable housing, should be set at a level that takes account of affordable housing and infrastructure needs and allows for the planned types of sites and development to be deliverable, without the need for further viability assessment at the decision-making stage (Paragraph: 002 Reference ID: 10-002-20190509, Revision date: 09 05 2019).

To request that the minimum external amenity space requirements are more aligned with other policy requirements and consideration is given to site feasibility and viability in the application of the policy. It is requested that additional policy wording to allow for viability adjustment mechanisms and flexibility in the application of the policy is included in Part 6 of Policy H/SS to depart from the specified standards in appropriate site specific circumstances where such deviations can be robustly evidenced and justified.

It is requested that a maximum cap is included on the total number of affordable M4(3) units on schemes which deliver more than 40% affordable housing, with the M4(3) requirement based on the policy compliant affordable housing position of 40%.

It is requested that a maximum cap is included on the total number of M4(3) market units to be delivered. It is requested that this maximum cap introduced for schemes of 200 or more dwellings, with the M4(3) market requirement only applying to the first 200 dwellings.

COMMENT

Policy H/SS sets out the required standards for internal spaces within new homes, the proportion of accessible and adaptable dwellings to be provided, and the required standards for external private and shared amenity space.

Paras 1 and 2 concern internal residential space standards. Paras 3 and 4 stipulate external residential space standards that should be met or exceeded. This includes for new build, conversions and change of use with houses (irrespective of the number of bedrooms) to provide a minimum of 10 sqm private amenity space; and upper floor apartments to have a minimum of 5 sqm, with an additional 1 sqm for each additional bedspace.

Para 5 outlines exemptions for provision of private external amenity space. Paras 6-8 relate tp accessible and adaptable homes. They require all new residential buildings to be built to M4(2) standard and for development proposals providing 20 or more new build dwellings to deliver10% of the affordable units and 5% of the market units as M4(3).

Hill Residential supports in principle the need to deliver high standards of amenity and accessibility in new homes.

Paras 1 and 2 reference and replicate the NDSS. This replication and repetition in Policy H/SS is unnecessary and should be removed.

The requirements under paras 3 and 4 for the stipulated minimum external residential space standards may constrain site opportunities when balanced against other policy requirements as set out in the draft GCLP, namely Policy BG/BG, BG/GI, Policy BC/TC, Policy BG/EO, and Policy WS/NC. This is particularly relevant for density uplift and delivery of housing. Variably sized balconies depending on the quantum of bedrooms will add to design complexities including stacking and incur further costs in construction. To accommodate the required size and width of balcony, it may be necessary to increase unit width, which may then reduce the number of units per floor; increase circulation area; add extra cores to meet access distances; and increase building footprint or height.

Similarly, paras 6-8 regarding the delivery of M4(3) units may give rise to viability constraints when coupled with the overall requirement to deliver affordable housing draft Policy H/AM and infrastructure (draft Policy I/ID).

It is considered that draft Policy H/SS needs to better align with other draft GCLP policies and housing requirements to ensure that such housing space standards are feasible and deliverable. It is requested that additional policy wording is included to address the external standards stipulated by H/SS to include for viability adjustment mechanisms and flexibility to depart from the specified standards in appropriate site-specific circumstances where such deviations can be robustly evidenced and justified.

It is also requested that wording is added to Policy H/SS to allow for a maximum cap on the total number of M4(3) affordable units to be delivered. The draft Policy requires 10% of all affordable units be provided as M4(3). This is to accommodate developments which may be providing 100% affordable housing and/or where a need for such quantity of M4(3) units would be unnecessary (e.g due to RP preferences/demand). It is suggested that if schemes deliver more than 40% affordable housing, the M4(3) requirement is capped and the number based on the policy compliant affordable housing position.

It is also requested that a maximum cap is included on the total number of M4(3) market units to be delivered. The draft Policy requires that 5% of all market units be provided as M4(3) units. Such M4(3) market provision is considered unnecessary. The Housing Needs of Specific Groups report shows that the overall need for M4(3) homes is quite low, with 968 units needed across Greater Cambridge. The proposed 5% requirement would result in an excess requirement and a risk that developments have specialist housing which would be difficult to sell. It is suggested therefore that a maximum cap is introduced for schemes of 200 or more dwellings with the M4(3) market requirement only applying to the first 200 dwellings.

GREATER CAMBRIDGE RESPONSE

The Councils' evidence, as set out in the Housing Needs of Specific Groups study (2025), highlights that the Councils should require all new homes to meet the M4(2) standards on the basis of its increasing ageing population and the projected increase in the number of people with disabilities. It is important that new homes across Greater Cambridge provide high-quality internal and external spaces, so they are inclusive, accessible, adaptable and flexible to meet the needs of existing and future users, and therefore enable and support healthy lives. There may be specific developments where meeting the required internal space standards, amenity space requirements, and / or accessible and adaptable homes standards, would not be appropriate for the identified occupants, however, any exceptions would need to be clearly justified with evidence provided to demonstrate that the proposed development still delivers suitable and appropriate homes for the anticipated occupants. The evidence set out in Appendix 1 of the Homes Topic Paper (2025) supports requiring all homes to meet the M4(2) standard by showing that the majority of developments for new residential dwellings in recent years are meeting the requirements, and any exceptions are generally developments for specialist accommodation meeting a specific need.

Having considered the representations received regarding the fixed minimum private external amenity space of 30sqm and concern around its application in certain development contexts, the Councils have decided to remove the set external amenity space standard and implement a more design-led, qualitative approach to securing appropriate external amenity space. The implementation of this approach will ensure that schemes provide sufficient amenity space that is appropriate to the typology and size of the units provided. Applicants will be required to evidence in their Design and Access Statement how the size of the amenity space provided is sufficient for the intended occupants. The Councils have continued to include a specific requirement for apartments to provide direct private amenity space as well as set width and depth requirements as these have been more standardly applied across all contexts in Greater Cambridge and align with national guidance. As set out in the supporting information, where these set balcony standards are not appropriate for the identified occupants and justification can be provided that alternative standards are more appropriate, then exceptions can apply. The policy has been amended to provide clarification that in exceptional circumstances the provision of shared external amenity space will be allowed on schemes delivering aspects of communal living such as specialist housing, purpose-built student accommodation, co-living or co-housing. The amount of external amenity space required will be determined on a design and context led basis and this does not mean that private amenity space will also not be required as part of the scheme.

UPDATED EVIDENCE

Hill Residential note that p.22 of the Aspinall Verdi Greater Cambridge Local Plan Viability Main Viability Report (Regulation 19 Stage) (July 2026) states that M4(2) increases costs by £1,164 per flat and £657 per house. AV have assumed worst case scenario costs of M4(3)(b) on the higher level M4(3) Category 3 2b Accessible units add costs of £9,875 per flat and £28,619 per house.

Evidence has been taken from the Equality & Human Rights Commission and Habinteg, A Toolkit for Local Authorities in England: Planning for Accessible Homes (indexed by BCIS), and all figures assume that dwellings also comply with the Nationally Described Space Standards, ensuring sufficient internal space alongside the accessibility requirements.

REQUESTED CHANGE

To request that the minimum threshold trigger for delivery of self/custom build plots is increased and greater flexibility added to allow a lower proportion of self and custom build homes where there is evidence that there is limited demand or it would not support good placemaking. It is proposed that the 5% threshold trigger should only be applied to schemes containing a minimum of 100 dwellings and should be capped so that it would only apply to the first 500 dwellings. The minimum 12-month marketing period before unused plots can revert to developer delivery should be reduced to six months.

COMMENT

Policy H/CB concerns self and custom build home delivery in Greater Cambridge. Para 1 requires that developments of 20 or more dwellings must provide at least 5% of the new homes as serviced plots for custom and self-build houses and/or serviced custom-build flats. Unless specified all custom and self-build plots will be classified as market housing as stated under para 2. Para 3 sets out the marketing criteria for custom and self-build plots.

Hill Residential requests that there is more flexibility in this provision where it can be demonstrated that there is limited demand and/or it would not support good placemaking. Hill Residential also considers that there is scope for the 5% threshold trigger of 20 dwellings to be increased.

Self/custom buildings reduce the ability to design optimised layouts with standardised unit widths, depths and typologies, resulting in lower densities and reduced overall yield; the servicing of irregular plot shapes or standalone plots incurs further costs. When balanced against other policy requirements as set out in the draft GCLP, (namely Policy BG/BG, BG/GI, Policy BC/TC, Policy BG/EO, and Policy WS/NC) the policy requirement may constrain site opportunities. This is relevant for density uplift and delivery of housing, especially on larger schemes where such levels would result in the requirement to plan for a significant number of self-build/custom homes (for example 150 on a 3000 home scheme), leading to the wrong design and density outcomes. There is also no evidence of demand for this level of custom/self-build homes on a single scheme. Our experience shows that there is no demand for self/custom build plots on large housebuilder led schemes.

Paragraph 61 of the NPPF (2024) is clear in its wording that while the needs of groups with specific housing requirements should be addressed, the overall aim is to meet an area’s identified housing need.
Paragraph 129 of the NPPF (2024) notes that planning policies should support development that makes efficient use of land. As outlined above, there are concerns that an oversupply of self-build/custom builds would , affect overall site densities and design/placemaking, leading to issues with overall housing supply.

The NPPF (2026) further states in national decision-making 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;

The requirement for minimum self-build plot provision would affect the ability for sites to maximise efficient use and density of land, contrary to Policy L3’s requirements.

Moreover, self/custom build plots typically deliver more slowly than developer built units, causing delays in build out rates, sales receipts and s106/CIL trigger points. They also create difficulties around logistics, with self-builders developing alongside main contractors. The minimum 12 month marketing period before unused plots can revert to developer delivery is a significant delay on build programmes for sites needing timely delivery. This includes the need for bespoke legal agreements, plot passports, boundary definitions and management arrangements for self/custom build plots, causing higher legal and administrative overheads.

GREATER CAMBRIDGE RESPONSE

The recent fall in the number of applicants joining the Greater Cambridge Self and Custom Build Register is recognised. However, there remains a significant deficit in the number of permissions: 440 plots at the end of base period 7 allowing for permissions up to 30 October 2025. The supporting text to the policy states that “the 5% requirement may be reduced where at least a 1-year oversupply of custom and self-build housing permissions exists and subject to agreement with the local planning authority”. The scale of the deficit could reduce quite quickly if the number of new applicants to the register remains low. However, proposals for self and custom build developments continue to be allowed on appeal outside of defined development extents because South Cambridgeshire District Council cannot demonstrate that it is meeting its statutory requirement to match demand (as measured by the register) with permissions. The proposed policy approach of requiring 5% custom or self-build plots on developments of 20 dwellings or more offers the best chance of reducing the deficit as quickly as possible, whilst taking a more flexible approach to the 5% requirement later in the plan period once there is no longer a deficit.

The requirement that custom or self-build plots which do not sell to continue to be marketed as such for a further period or transferred to a Registered Provider is considered to be an important control to ensure potential custom and self-build dwellings are not lost to mainstream market housing.


UPDATED EVIDENCE

Hill Residential note that p.23 of the Aspinall Verdi (AV) Greater Cambridge Local Plan Viability Main Viability Report (Regulation 19 Stage) (July 2026) states that in terms of self-build, there is no additional cost, given plots can be sold at full value and any plots not sold after 12 months will revert to developer.

AV have not appraised any self-build schemes explicitly. All the residential typologies are on the basis that land can be acquired and developed into a new unit (including appropriate allowance for profit). Where self-building involves plot sales and/or part completed units (e.g. foundations, or ‘wind and watertight’) the working assumption is that the developers’ profit is commensurate with the development work undertaken and therefore there is sufficient development surplus to incentivise the self-builder to complete the unit.

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

To clarify the type of non-standard cycle parking provision to be provided in developments as required under Para 3 of Policy I/CV. To also include a development quantum threshold for such provision and specify a fixed percentage provision for the overall non-standard cycle parking provision.

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

COMMENT

Policy I/CV details the requirements for cycle and vehicle parking. Amongst other things, para 2 concerns cycle parking and sets out associated design principles listed in paras 2a-i. Para 2h states that cycle parking for residential development is to be integrated within the front of the house, located in a purpose-built lockable area with easy access to the front of the house or within a garage, avoiding basement parking.

Para 3 sets out cycle parking standards. Para 8 requires the submission of a site-wide Electric Vehicle charging strategy for large-scale major sites , whilst Para 9 confirms the disabled parking provision and associated design principles.

The wording as currently stated in para 2h does not accommodate provision in different types of residential dwellings, for example flats or maisonettes, where cycle parking will not be able to be provided in a garage or to the front of a house. It is therefore requested that this is updated to reflect requirements for alternative housing typologies.

The requirement under Para 3 to provide at least 5% of non-standard cycle parking is non-specific and does not provide sufficient flexibility for minor developments where such provision is unlikely to be required, nor necessarily feasible to deliver. The wording should be updated to include a threshold for the requirement to non-standard cycle parking provision. Further, non-standard cycle parking should be defined to specifically reference the alternative cycle parking to be accommodated, such as cargo or electric bike provision.

Para 8 does not specify the threshold for large scale major sites, and it is unclear what the threshold requirement for the submission of a site wide electric vehicle charging strategy is. A defined threshold should be specified.

GREATER CAMBRIDGE RESPONSE

The proposed cycle standards are a minimum requirement, and higher levels may be appropriate as determined on a site-by site basis using a vision-led and design-led approach. Further clarification has been added to the policy wording and supporting text to ensure cycle parking is at least as convenient as car parking, accessible and suitable for people of all abilities and designed appropriately, particularly in sensitive locations. This includes limiting the use of two-tiers stands, how parking should consider the different needs of users including clarification of non-standard cycles, and how it should be sympathetically integrated into the streetscene and residential developments. Larger developments are required to ensure appropriate space for micromobility modes such as dockless cycles.

The policy requires electric charging provision in accordance with Building Regulations. Further guidance has been added to the supporting text to guide the type and power output of chargers, and to ensure their design avoids street clutter and conflict with other highway users.

Further clarification has been added to the policy on the interpretation of policy elements, including guidance around the design of car parking and provision for drop-off/pick-up and car clubs. In response to comments received, a new requirement has been added to the policy requiring appropriate storage space for micromobility modes such as dockless cycles and escooters to be provided where the proposal leads to increased demand.

UPDATED EVIDENCE

Hill Residential note that p.35 of the Aspinall Verdi (AV) Greater Cambridge Local Plan Viability Main Viability Report (Regulation 19 Stage) (July 2026) states that it has assumed that the cost of providing EV charging infrastructure is now baked into BCIS costs, given that it has been mandatory since 2022.

The cost of parking in accordance with policy standards is included within the external works allowance.
For the purposes of viability assessments, the cost of professional design teams needed to deliver high-quality, well-placed design is assumed to be covered within the standard professional fee budget. It is also in developers’ own interests to deliver high-quality design, as supported by the Building Better, Building Beautiful Commission (January 2020), since well-designed places can increase sales values and improve viability overall.

REQUESTED CHANGE

The wording as proposed under para 3 of Policy I/ID places full responsibility on the developer to demonstrate sufficient capacity rather than the relevant provider. Consequently, it is inappropriate to ask developers to evidence and/or provide sufficient infrastructure capacity that they are not legally responsible for.

For these reasons, the draft wording of para 3 of Policy I/ID should be deleted.

COMMENT

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

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

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

It is requested that the wording under para 3 of Policy I/ID is amended to ensure liability is not solely placed on a developer to address all infrastructure deficiencies in an area created by historic failures to deliver. Hill Residential are strongly of the view that this would be unreasonable. Any infrastructure requirements should be directly related to the impact of the proposed development. This reflects concerns raised under draft Policy CC/WE.

GREATER CAMBRIDGE RESPONSE

There are detailed policies in the Local Plan that address the various forms of infrastructure that need to be considered depending on the nature, scale and location of a proposal. These policies establish how the need is to be assessed, the standards to be applied, as well as the preferred approach to provision. It is therefore not necessary or appropriate to try to list in this one policy all forms of infrastructure that may be sought from development or particular standards that should be met, when the plan is intended to be read as a whole.

The wording of the policy has been amended to further strengthen the requirement for infrastructure to be provided in a timely manner to support occupation of the development, including where development is to be phased and built out over a longer period of time.

The updated IDP will, where information exists, seek to address the shortcomings identified by respondents. However, much of the certainty sought is reliant on whether the relevant service provider has detailed proposals for provision. Where such detail is currently unavailable, broad estimates will need to be used, and the IDP further updated and refined as each of the infrastructure projects are worked up in more detail.

UPDATED EVIDENCE

Hill Residential note that p.24 of the Aspinall Verdi (AV) Greater Cambridge Local Plan Viability Main Viability Report (Regulation 19 Stage) (July 2026) states that at this point its appraisals do not incorporate any infrastructure costs over and above standard development costs. These would be paid for via either S106 contributions from the site surplus and/or through a reduction in land price if these are ‘abnormal’ development costs. Site-specific constraints may affect costs on a case-by-case basis.