Greater Cambridge Local Plan: Proposed Submission

Modifications to the policy to allow for a level of flexibility that is required to enable the policy to be applicable and resilient for the 20+ years over which the project will be implemented, as set out in the full representations.

See attached representations letter for full representations.

Martin Grant Land, Cambourne North Landowners Consortium, Landoak Estates and Davison & Co (POTCO) Ltd very much welcome and support Cambourne North being included as an integral part of the Councils’ spatial strategy for the Local Plan in order to meet its housing, employment and community needs and deliver sustainable development. However, they object to and are seeking changes in relation to the level of prescription in the Proposed Submission Local Plan details which are not justified.

The representations seek modifications to the policy to allow for a level of flexibility that is required to enable the policy to be applicable and resilient for the 20+ years over which the project will be implemented. Subject to these proposed modifications to the detail of the Proposed Submission Local Plan, it is clear that Cambourne North can be delivered as an expansion of ‘One Cambourne’.

To be effective, changes are required to Policy CC/NZ as:
• Greater flexibility is required to ensure that the policy does not compromise development;
• The space heating targets may be challenging in certain circumstances and flexibility is therefore needed;
• EUI targets have not yet been formally confirmed or adopted; and
• If retained, the EUI targets need to be adaptable to ensure they can respond appropriately to differing site contexts and design constraints.

The requirement in Policy CC/NZ that “Proposals must seek to maximise opportunities to generate on-site renewable energy and facilitate flexibility to enable the development, where possible, to achieve all energy demands through onsite energy generation” also does not allow for the necessary planning balance to be assessed between ‘maximise opportunities where possible’ and other planning considerations and needs to be changed.

These comments are made in the context of the delivery of Cambourne North.

To be effective, changes are required to Policy CC/NZ as:
• Greater flexibility is required to ensure that the policy does not compromise development;
• The space heating targets may be challenging in certain circumstances and flexibility is therefore needed;
• EUI targets have not yet been formally confirmed or adopted; and
• If retained, the EUI targets need to be adaptable to ensure they can respond appropriately to differing site contexts and design constraints.

The requirement in Policy CC/NZ that “Proposals must seek to maximise opportunities to generate on-site renewable energy and facilitate flexibility to enable the development, where possible, to achieve all energy demands through onsite energy generation” also does not allow for the necessary planning balance to be assessed between ‘maximise opportunities where possible’ and other planning considerations and needs to be changed.

Policy CC/WE needs to be changed to be more flexible to allow for site specific constraints, including costs / viability, and be flexible enough to respond to the water availability position at the date of the application/detailed stage.

These comments are made in the context of the delivery of Cambourne North.

An inflexible requirement for 80 litres of water per person per day for schemes of 100 or more dwellings as required by Policy CC/WE is stringent compared to the current Building Regulations standard of 110 litres per person per day. Limiting water use to this level will likely require advanced water reuse systems and dual plumbing infrastructure, adding considerable cost and complexity to developments. Furthermore, the requirement for non-residential development to achieve full credits under Wat 02, Wat 03, and Wat 04, and one credit for category Wat 05 of BREEAM goes beyond minimum compliance and typically demands specialist design and technology. Wat 04 is difficult to control because it focuses on unregulated water uses, which rely heavily on end users, operational practices and decisions made after construction, and adds considerable cost and complexity to developments.

Policy CC/WE therefore needs to be changed to be more flexible to allow for site specific constraints, including costs / viability, and be flexible enough to respond to the water availability position at the date of the application/detailed stage. This includes removing the prescription in Policy S/CBN: Cambourne North where it states that it is likely to be necessary to limit first occupations of new dwellings taking place until after the Grafham Transfer water supply intervention becomes operational or when alternative headroom is secured.

The policy approach to integrated water management, sustainable drainage and water quality needs to be more flexible. Designing for no runoff during small rainfall events may be difficult to achieve on constrained or high-density sites, and a performance-based approach that allows equivalent mitigation measures, where strict compliance is not feasible, is required. Mandating green or brown roofs on all flat roofs can present significant challenges, including structural capacity, cost implications, and heritage constraints. Flexibility is required where technical or viability issues arise, supported by alternative biodiversity measures.

These comments are made in the context of the delivery of Cambourne North.

The policy approach to integrated water management, sustainable drainage and water quality needs to be more flexible. Designing for no runoff during small rainfall events may be difficult to achieve on constrained or high-density sites, and a performance-based approach that allows equivalent mitigation measures, where strict compliance is not feasible, is required. Mandating green or brown roofs on all flat roofs can present significant challenges, including structural capacity, cost implications, and heritage constraints. Flexibility is required where technical or viability issues arise, supported by alternative biodiversity measures.

The requirement in Policy BG/BG to provide a minimum 20% biodiversity net gain (BNG) on-site where this is feasible and effective, or off-site where onsite options for BNG have been evidenced to be exhausted as agreed with the Local Planning Authority, is not justified and needs to be changed. The requirement for onsite options to be exhausted does not allow for the necessary planning balance to be assessed having regard to other planning considerations.

These comments are made in the context of the delivery of Cambourne North.

The requirement in Policy BG/BG to provide a minimum 20% biodiversity net gain (BNG) on-site where this is feasible and effective, or off-site where onsite options for BNG have been evidenced to be exhausted as agreed with the Local Planning Authority, is not justified and needs to be changed. The requirement for onsite options to be exhausted does not allow for the necessary planning balance to be assessed having regard to other planning considerations. In the case of Policy S/CBN: Cambourne North, it may be most appropriate to provide (part of the) BNG within the Strategic Enhancement Area rather than within the Site Allocation boundary.

Review / justification of and changes to standards.

These comments are made in the context of the delivery of Cambourne North.

The Proposed Submission Local Plan is the first stage of the Local Plan that includes open space standards for major residential and / or commercial developments. The proposed standard for residential development of 7 hectares per 1,000 of the population in Policy BG/EO is based on current provision across Cambridge City and South Cambridgeshire which is not in itself a sound basis for determining what needs to be delivered as part of new development. In addition, the requirement in Policy BG/EO for all commercial developments of 2,000 square metres or more (Gross Internal Area) to demonstrate open space provision equivalent to 2.0 hectares of open space per 1,000 employees and / or provision off-site via financial contributions is not justified.

These comments are made in the context of the delivery of Cambourne North.

In addition to the contributions for community facilities based on a standard of 129 square metres floorspace per 1,000 additional population set out in the Draft Local Plan Regulation 18 Consultation (2025), the Proposed Submission Local Plan now additionally requires, in Policy WS/NC contributions for cultural facilities of 100 square metres per 1,000 additional population and 1.5% of Net Internal Area commercial space. This would be an additional cost that would need to be considered as part of overall viability at Cambourne North.

Criterion a) needs to be reworded to state “Pay special attention to the desirability of preserving or enhancing the significance of the designated heritage asset(s) and its setting, and the character or appearance of Conservation Areas including views into, within and out of them” as harm can be outweighed by public benefits.

These comments are made in the context of the delivery of Cambourne North.

Whilst Policy GP/HA does now include “Harm to the significance of a designated heritage asset or its setting will be weighed against public benefits” it retains the requirement that “Development proposals that affect designated heritage assets … must a) Preserve or enhance the significance of the designated heritage asset(s) and its setting, and the character or appearance of Conservation Areas”. Criterion a) needs to be reworded to state “Pay special attention to the desirability of preserving or enhancing the significance of the designated heritage asset(s) and its setting, and the character or appearance of Conservation Areas including views into, within and out of them” as harm can be outweighed by public benefits. This revised wording brings the policy in line with the wording of the Planning (Listed Buildings and Conservation Areas) Act 1990 and the NPPF 2024.

These comments are made in the context of the delivery of Cambourne North.

The Proposed Submission Local Plan is the first stage of the Local Plan that requires affordable workspace as part of new office, R&D, Industrial and Storage developments. The requirements are set out in Policy J/AW and require 10% of net additional floorspace (GIA) as affordable workspace which should be a minimum of 20% below prevailing market rents in perpetuity. This would have an impact the viability of commercial development and, whilst the principle of providing affordable workspace may be supported, it would need to be considered as part of overall viability at Cambourne North.

The policy needs to be changed to provide more flexibility in the proposed affordable housing tenure requirements in accordance with Government policy to include, for example, other forms of intermediate housing like discount market housing. The policy also needs to expressly recognise that viability may justify a different percentage and / or mix. Flexibility is required to respond to changing need profile over a very long delivery of a development of the scale of Cambourne North.

These comments are made in the context of the delivery of Cambourne North.

The policy needs to be changed to provide more flexibility in the proposed affordable housing tenure requirements in accordance with Government policy to include, for example, other forms of intermediate housing like discount market housing. The policy also needs to expressly recognise that viability may justify a different percentage and / or mix. It is noted that there is no reference to how the affordable housing policy applies to key worker accommodation. Flexibility is required to respond to changing need profile over a very long delivery of a development of this scale.