Greater Cambridge Local Plan: Proposed Submission

REQUESTED CHANGE

The wording as proposed under para 6 of Policy I/DT 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 6 of Policy I/DT should be deleted.

COMMENT

Policy I/DT sets out how developments should contribute to Greater Cambridge’s access to broadband, telecommunication infrastructure and smart infrastructure.

For telecommunications infrastructure, para 6 requires for schemes of 30 or more dwellings to include suitable infrastructure that would support any future rollout of appropriate telecommunications equipment such as small cell mobile communications technology or mobile masts and towers.

Hill Residential do not object to the principle of the policy but request the wording is updated to ensure full responsibility is not placed on the developer to provide the infrastructure that should reasonably be expected to be delivered by a third party or statutory undertaker and/or would be out of the developer’s control.

GREATER CAMBRIDGE RESPONSE

Reflecting on the range of views put forward on the approach to securing the right telecommunications infrastructure to support development, the Councils believe that the proposed policy strikes an appropriate balance, establishing reasonable thresholds for the provision of necessary infrastructure and the assessment of existing infrastructure deficiencies. The policy is already clear that responsibility for delivering upgrades to mobile telecommunications infrastructure does not lie with applicants. However, noting emerging evidence that developments are increasingly being completed with inadequate outdoor mobile coverage (as cited in a recent government consultation), the Councils view is it is not unreasonable for applicants to assess the potential impacts of their proposals on mobile coverage and enter into early engagement with network operators with a view towards securing necessary upgrades, as required by the policy.

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 for the purposes of its viability assessment, AV have assumed that the relevant cost of professional fees for the required connectivity documents is included in the professional fee budget.

For Local Plan viability purposes, it is considered the cost of delivering broadband infrastructure / street furniture is included in external works costs and would be recouped in the value of the property which will be more marketable – therefore, no specific assumptions have been made.

AV have included for ‘normal’ services connections within the external works allowance. Where connectivity is very remote and/or is abnormal infrastructure, this will need to be negotiated with the provider and/or the planning authority on a site-specific level.

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.