Greater Cambridge Local Plan: Proposed Submission

Heritage Policy to better reflect national policies to ensure they do not carry very limited weight upon adoption.

There are several development management policies within the Plan which seek to exceed other consenting regimes requirements, thereby adding onerous requirements onto development which is unsound and unjustified.
The NPPF 2026 whilst not the examining plan at Annex A, paragraph 2 effectively requires a consistency check between Local Plan policies and the National Development Management Policies of the Framework. Where materially inconsistent, Local Plan policies will carry very limited weight, and weight applied to the Framework instead.
The Council needs to ensure that development management policies are consistent at this stage, and we have found no record of such an exercise being carried out as part of this process, and the transitional arrangement of Annex A, paragraph 2 would seemingly not apply to these policies as they have not been examined and adopted against the 2026 Framework. Therefore, Policy DM7 of the 2026 Framework would apply where the Council is seeking to exceed matters controlled by other statutory regimes.
Whilst supportive of the premise of many of these conditions, ensuring consistency with other consenting regimes is important for investor confidence; or where standards are exceeded it is clearly evidenced as to why and its viability. This follows on from the concerns we have with the Local Plan evidence base as discussed under the affordable workspace policy.
We are concerned that this is the case for the following policies:
● Policy BG/BG: Biodiversity and geodiversity;
● Policy CC/DC: Designing for a changing climate;
● Policy CC/NZ: Net zero carbon new buildings;
● Policy CC/WE: Water efficiency in new developments;
● Heritage related policies.

The requirement for a threshold should be removed and each site assessed on a site-by-site basis.

The requirement for commercial development over 5,000sqm to provide a detailed assessment of sport, recreation, culture and community needs, and strategies to address those needs is not considered to be appropriate, particularly at the scale the Council sets out. Jobs and employment in general do not add significant burden to these matters in the same way residential proposals may do. Whilst it is accepted much larger employment sites or areas can comprehensively masterplan these in, the threshold set cannot achieve that and just creates further financial burden upon developments.

The policy as drafted is too prescriptive and does not have sufficient flexibility as set out in representation.

Creating inclusive employment and business opportunities through new developments – the premise of supporting skills and training is acceptable. However, as drafted the policy is too restrictive. For example, limb 4. Saying 20% of all construction jobs ‘must’ be for local residents. That lacks sufficient flexibility to be sound and is not justified. If such a work force is not available then it automatically means a policy conflict, where a developer, through no fault of their own, not be able to secure local employment.

Greater flexibility is required.

As drafted the policy lacks sufficient flexibility requiring development to comply with the scores as set out in paragraph 1. This fails to recognise different typologies of commercial development, ie: industrial and logistics where service yards necessarily have to be free of landscaping. We suggest, similarly to the London Plan, there needs to be sufficient flexibility to say ‘should’ meet certain scores unless justified through evidence.

Requirement for a threshold on warehouse developments to be removed and reviewed on a case-by-case basis.

still requires commercial development of 2,000sqm and above to provide public open space on site. This is a significant requirement and again fails to fully understand different typologies ie: E(g)(ii) may be in a warehouse development for a mid-tech user. Large areas of open space on warehouse schemes will result in a significant land take which will run contrary to the government’s requirement for efficient use of land. For commercial schemes this should just be judged on a case-by-case basis.