Greater Cambridge Local Plan: Proposed Submission

As set out in the National Planning Policy Framework 2026 Local Plan policies should not duplicate, substantively restate or be inconsistent with the content of national decision-making policies, unless directed by other policies in the Framework’

Whilst Girton College recognises that some attempts have been made to clarify the policy. It maintains objections that it is not in line with the new National Planning Policy Framework
In para 2, by suggesting that development must fulfil the requirements of the various strands which follow, the policy lacks the balance provided in the NPPF. For example the presence of National Decision-Making policy HE4 which require that heritage assets ‘should be conserved in a manner appropriate to their significance’ provides the appropriate balance. The presence of national decision-making policies, questions the need for local plan policies such as GP/HA.

Highlight the explanation in H.13 within the policy, or make it clear that any new building taller than the one it replaces does not automatically ‘break the skyline’ as it depends on the context in which it is viewed.

At Regulation 18 Stage, Girton College commented on confusion which the phrase ‘break the skyline’ brings. Whilst the clarification given in Appendix H (H.13) is helpful -

‘Skyline refers to the outline or profile of buildings, structures, and natural features visible against the sky when viewed from a distance or from specific vantage points’

It would avoid confusion to highlight the explanation in H.13 within the policy, or make it clear that any new building taller than the one it replaces does not automatically ‘break the skyline’ as it depends on the context in which it is viewed.

Major development must provide the statutory biodiversity net gain requirement in accordance with Schedule 7A of the Town and Country Planning Act 1990 (unless exempt from those requirements). Biodiversity net gain should be provided on-site where feasible and effective, or off-site where on-site opportunities have been demonstrated to be exhausted and this has been agreed by the Local Planning Authority. Requirements for biodiversity net gain in excess of the statutory minimum shall only apply to specific site allocations where justified and demonstrated to be deliverable.

Plan-Making Policy N1(2) of the National Planning Policy Framework (17 August 2026) states that development plans should only require biodiversity net gain in excess of the statutory requirement where this relates to specific site allocations and is fully justified and deliverable. It also states that local standards should not apply to categories of development that are exempt from the statutory biodiversity net gain regime.

As drafted, Policy BG/BG appears to impose biodiversity net gain requirements beyond the statutory framework without limiting them to specific allocations or providing the justification required by national policy. The policy therefore conflicts with the National Planning Policy Framework and fails the test of soundness that a plan must be consistent with national policy.

The policy should be amended to confirm that any biodiversity net gain requirements exceeding the statutory minimum apply only where justified through a specific site allocation policy. It should also make clear that development exempt from statutory biodiversity net gain requirements is not subject to additional local biodiversity net gain standards. Reference should also be made to the statutory biodiversity net gain framework contained in Schedule 7A of the Town and Country Planning Act 1990.

As a further point, if Policy BG/BG duplicates or materially departs from the national BNG framework, there is also an argument that it is inconsistent with the 2026 NPPF approach to avoiding duplication of national policies within development plans.

The Protected Open Space draft designations POS_1559, POS_1560 and POS_1910 should be reviewed and amended to exclude land benefiting from planning permission and subject to imminent implementation, ensuring that the Policies Map accurately reflects the Council's development strategy and existing planning commitments.

Five parcels of land are proposed for designation as Protected Open Space (POS) within the College grounds. It is acknowledged that the POS policy allows for the designation of land within private ownership.
However, the College question the proposed designations of three parcels given they do not accurately reflect their status as having planning permission.
With regard to the two areas of land below, the College understand the reasons for their proposed designation.
• POS_1558 Playing Fields at Girton College designated as ‘Outdoor Sports Facilities’ – Assumed to the existing sports fields located in the northern part of the College grounds
• POS_1909 Parks and Gardens at Girton College Huntingdon Road designated as ‘Parks and Recreation Space’ – assumed to be Emily Davies Court
However, the justification for the following is questioned. These are not numbered on the Policies Map, nor can a drawing be found which identifies these. However, the assumptions are made as below.
• POS_1559 Tennis Courts at Girton College Outdoor Sports Facilities
• POS_1560 Tennis Courts at Girton College Outdoor Sports Facilities
These are the land adjacent to eastern side of the College buildings and the area within the area also proposed for designation as sports ground
• POS_1910 Sports Ground at Girton College Outdoor Sports Facilities – assumed to be the larger area to the west of the College buildings (Orchard Field).
For clarification tennis courts within the POS 1910 designation are disused. There are no tennis courts on the land to the east of the existing buildings.
POS_1910 is a grassed area with no formal playing pitch.
Outline planning permission was originally granted in October 2016 and renewed in June 2025. This has recently been the subject of a Minor Material Amendment application, so the outline planning permission ref is now : 26/01599/S73. The permission is for:

construction of student residential accommodation together will ancillary meeting, office and social space (maximum 14700sqm ), auditorium (maximum 1300sqm) replacement buildings and grounds maintenance workshops, one new and relocated sports pitch, additional ball-stop fencing, relocated tennis courts, a new vehicular access and replacement car park with some matters reserved except for access)

The planning permission included approval of development plots. The proposed POS 1559,1560 and 1910 sit within two of the development plots.

Reserved matters for the plot northwest of the main college buildings (Orchard Field), sitting between Grange Drive and Orchard Drive have been the subject of extensive pre-application engagement and are due to be submitted by Christmas 2026.
Reserved Matters for the sports pitch and tennis courts on the sports field (as described on the description on the decision notice) were submitted on in September 2026. Following approval, works are due to start in January 2027, thereby implementing the outline planning permission.
To clarify the proposed sports facilities on the sports pitches will relocate and enhance those on Orchard Field as required under the outline planning permission.
Given the above, the Council has determined that development is acceptable on these proposed designations.
The Protected Open Space designation is not justified in its current extent because designated areas POS_1559, POS_1560 and POS_1910 already benefit from planning permission. The Council has already accepted the principle of development on these sites through the development management process. In these circumstances, the continued designation of the same land as Protected Open Space is inconsistent with the established planning position.
Policy HQ/OS is intended to protect areas of environmental and recreational importance from loss or harm. However, where land has already been granted planning permission and is expected to be developed, there should be clear evidence explaining why it continues to warrant designation as Protected Open Space. The inclusion of land with planning permission suggests that the extent of the designation has not been adequately assessed and does not accurately reflect the Council's planned strategy for the area.
The Protected Open Space draft designations POS_1559, POS_1560 and POS_1910 should be reviewed and amended to exclude land benefiting from planning permission and subject to imminent implementation, ensuring that the Policies Map accurately reflects the Council's development strategy and existing planning commitments.