Greater Cambridge Local Plan: Proposed Submission

U&C suggests that the policy wording is amended to refer to a ‘target of 20% biodiversity net gain’ rather than a ‘minimum’ and to acknowledge circumstances when exceeding nationally set requirements may not be possible.

These representations are submitted by David Lock Associates on behalf of Urban&Civic (U&C). U&C now own the Barracks and Airfield site at Waterbeach, which
forms a major part of the Waterbeach New Town allocation. Prior to the purchase of the site, U&C were development partners to the previous owners, the Defence Infrastructure Organisation.

As master developer, U&C are delivering the redevelopment of the Barracks and Airfield,
primarily under Outline Planning Permission S/0559/17/OL (The OPP) (dated 25 September 2019). Outline Planning Permission for redevelopment is also in place on
the remaining part of the allocation, in separate ownership.

U&C is proud of the progress made in delivering Waterbeach New Town and remains fully committed to realising its long-term vision.

The emerging Local Plan still has a very important role to play in this endeavour. The new Plan provides a vital driver. While the principle of the development is established and embedded in extant outline planning permissions across the whole site, there remain some significant challenges to accelerating delivery and achieving full build-out.

U&C objects to the requirement for all major development to provide a minimum of 20% biodiversity net gain, unless exempt under the Environment Act 2021. As drafted, the
policy is inconsistent with UK Government legislation (which requires a minimum of 10%) and introduces a blanket constraint that may well frustrate necessary
development. Particularly in circumstances when standalone applications are brought forward as a component part, or to support wider proposals, this is likely to have unintended consequences. For example, it may impede U&C’s ability to secure permissions for enabling infrastructure other than through reserved matters or where the narrow limits of the current exemptions in the Environment Act 2021 cannot be met.

U&C suggest that the criteria which states ‘All dwellings must achieve an EUI of no more than 35 kWh per meter squared per year’ should be amended to set a target for
regulated energy use only.

U&C suggest that the policy is amended so that it is specific about the types of development where this is required, and flexibility should be added to indicate how this will be applied in relation to phased development and phased sustainability strategies.

Bullet Point 10 should be removed from the Policy or replaced with a simple commitment to ensure new development provides occupiers with the equipment to monitor energy usage.

These representations are submitted by David Lock Associates on behalf of Urban&Civic (U&C). U&C now own the Barracks and Airfield site at Waterbeach, which
forms the major part of the Waterbeach New Town allocation. Prior to the purchase of the site, U&C were a development partner to the previous owners, the Defence
Infrastructure Organisation.

As master developer, U&C are delivering the redevelopment of the Barracks and Airfield, primarily under Outline Planning Permission S/0559/17/OL (The OPP) (dated 25 September 2019). Outline Planning Permission for redevelopment is also in place on
the remaining part of the allocation, in separate ownership.

U&C is proud of the progress made in delivering Waterbeach New Town and remains fully committed to realising its long-term vision.

The emerging Local Plan still has a very important role to play in this endeavour. The new Plan provides a vital driver. While the principle of the development is established and embedded in extant outline planning permissions across the whole site, there remain some significant challenges to accelerating delivery and achieving full build-out.

U&C is extremely concerned that the net zero targets proposed (Paragraph 1 and Part B,5) relate to Total Energy Use (regulated and unregulated) for homes. Requirements relating to unregulated energy use are outside the reasonable control of the developer
and therefore cannot form a robust development management requirement.

Mechanisms to achieve this at scale do not exist at the present time. This target is not universally achievable.

U&C seek clarification on the use of ‘maximise’ for the draft Policy wording which relates to generating on-site renewable energy (Part C). This should be quantified.

In relation to energy offsetting (Part D), U&C seek clarity on the offsetting payments referred to in the draft Policy – the Authority should establish an appropriate calculation
methodology and define the costs to be paid.

U&C is extremely concerned in relation to the assured performance aspect of the draft Policy (Part D). U&C suggest that the policy is amended to refer to specific development types where the use of an assured performance method should apply. It is prohibitive
and particularly onerous to require this for all development types.

U&C is also extremely concerned that the policy as drafted will require all large-scale development to undertake a whole life carbon emission assessment.

An addition has been made to the Policy from the Regulation 18 version (Bullet Point 10) imposing a requirement on all development over 50 homes and 5,000 sq m GIA of employment floorspace to complete in-use energy monitoring. There is no further explanation as to what is required in response to this Policy and whether this is a direction to ensure occupiers have energy usage meters, or whether there is an expectation that an applicant/developer might somehow acquire usage information and report that to the LPA. If it is the latter, the LPA need to address directly how an applicant maintains rights/remit to impose such a demand upon occupiers, once buildings are delivered and occupied by third parties. Furthermore, such an approach would be entirely unjustified as an obligation, as it would serve no practical purpose with regard to making development that is otherwise unacceptable, acceptable: once development is constructed and occupied (and given that in most circumstances the developer is no longer directly engaged in operational development), there is no scope for planning to impose new obligations or restrictions on energy usage. Reporting would therefore serve no legitimate planning purpose. The Policy is not implementable on this basis.

U&C suggest that the draft Policy is amended so that the flexibility applied to minor applications is extended to major applications where matters are dealt with in phases
and, in addition, a conformity statement may be more appropriate than a repeat Sustainability Statement.

The supporting text should be expanded to make clear what is required (would be an appropriate, ‘proportionate’ response) in relation to Circular Economy, at each stage of
the planning process.

These representations are submitted by David Lock Associates on behalf of Urban&Civic (U&C). U&C now own the Barracks and Airfield site at Waterbeach, which
forms the major part of the Waterbeach New Town allocation. Prior to the purchase of the site, U&C were a development partner to the previous owners, the Defence
Infrastructure Organisation.

As master developer, U&C are delivering the redevelopment of the Barracks and Airfield,
primarily under Outline Planning Permission S/0559/17/OL (The OPP) (dated 25 September 2019). Outline Planning Permission for redevelopment is also in place on
the remaining part of the allocation, in separate ownership.

U&C is proud of the progress made in delivering Waterbeach New Town and remains fully committed to realising its long-term vision. The emerging Local Plan still has a very important role to play in this endeavour. The
new Plan provides a vital driver. While the principle of the development is established and embedded in extant outline planning permissions across the whole site, there
remain some significant challenges to accelerating delivery and achieving full build-out.

U&C question whether it is appropriate that all applications will be required to submit a sustainability statement without any consideration of the type of development or the context, such as where large-scale development is delivered in phases, and sustainability is addressed strategically. Many elements listed in the Policy would be
intrinsic to detailed proposals, complying with site-wide requirements, or simply irrelevant.

In this circumstance, the policy approach is likely to impose unnecessary burden on the preparation of planning applications and upon planning officers, might impact supporting infrastructure or enabling works and in turn might impact delivery.

U&C have also found that establishing sitewide and key phase level strategies are an effective mechanism for establishing appropriate sustainability targets (including those related to climate) - subsequent detailed applications are required to demonstrate conformity with such strategies, and U&C is able to steer housebuilders and developers to achieve the targets. Therefore, U&C suggest that the policy is amended to acknowledge that where sitewide or phased sustainability strategies are in place already, a conformity statement may be appropriate rather than a standalone sustainability statement.

The draft Policy also requires Circular Economy reporting. Devising an effective approach at outline stage is very challenging in relation to the economy; it is far more
relevant to detailed proposals. The Policy should be expanded to define what is required in relation to different scales and forms of development in this respect,
particularly if the expectation is that it will apply to outline proposals and strategic scale development. There is otherwise a risk that information adds little value to the early stages of planning.

U&C suggest that the policy is amended to refer to a more achievable requirement for ‘no more than 95 litres/person/day for residential development of 100 or more homes’.

These representations are submitted by David Lock Associates on behalf of Urban&Civic (U&C). U&C now own the Barracks and Airfield site at Waterbeach, which
forms the major part of the Waterbeach New Town allocation. Prior to the purchase of the site, U&C were development partners to the previous owners, the Defence
Infrastructure Organisation.

As master developer, U&C are delivering the redevelopment of the Barracks and Airfield,
primarily under Outline Planning Permission S/0559/17/OL (The OPP) (dated 25 September 2019). Outline Planning Permission for redevelopment is also in place on
the remaining part of the allocation, in separate ownership.

U&C is proud of the progress made in delivering Waterbeach New Town and remains
fully committed to realising its long-term vision.

The emerging Local Plan still has a very important role to play in this endeavour. The new Plan provides a vital driver. While the principle of the development is established and embedded in extant outline planning permissions across the whole site, there remain some significant challenges to accelerating delivery and achieving full build-out.

U&C are very concerned about the water usage targets in the Policy. Water usage of ‘no more than 80litres/person/day for residential development of 100 or more homes’ is a very ambitious target that is not achievable without grey water recycling and rainwater
harvesting systems in place. This raises significant technical, management, maintenance and cost challenges and is proving, through even small demonstration
projects, to be extremely difficult to deliver and secure longer term. The evidence base does not demonstrate that the proposed standard is deliverable at scale across strategic allocations without significant cost and management implications.

To address the concern expressed in the representation, U&C are not able to simply offer amendments to the wording of this Policy or the many other policies across the Plan which establish requirements that go to development costs and value and, therefore, viability and deliverability. Providing assurance that the Plan and each major policy proposal within it is deliverable requires completion and augmentation of the evidence base. The appropriate clarification of the priorities and parameters for
considering and establishing commitments as opposed to aspirations, to inform the redrafting of this Policy and potentially those that relate directly to it must follow.

These representations are submitted by David Lock Associates on behalf of Urban&Civic (U&C). U&C now own the Barracks and Airfield site at Waterbeach, which
forms the major part of the Waterbeach New Town allocation. Prior to the purchase of the site U&C were development partner to the previous owners, the Defence
Infrastructure Organisation.

As master developer, U&C are delivering the redevelopment of the Barracks and Airfield,
primarily under Outline Planning Permission S/0559/17/OL (The OPP) (dated 25 September 2019). Outline Planning Permission for redevelopment is also in place on the remaining part of the allocation, in separate ownership.

U&C is proud of the progress made in delivering Waterbeach New Town and remains fully committed to realising its long-term vision.

The emerging Local Plan still has a very important role to play in this endeavour. The new Plan provides a vital driver. While the principle of the development is established and embedded in extant outline planning permissions across the whole site, there remain some significant challenges to accelerating delivery and achieving full build-out.

The Greater Cambridge Local Plan succeeds in articulating a positive vision and ambition for a substantial scale of growth. The Development Strategy is heavily
dependent upon maintaining delivery across existing, large site commitments and introduces several new allocations of significant scale. The Plan acknowledges the substantial infrastructure challenges that already exist across the Plan area and the degree to which they multiply with additional proposals, over and above that already
committed.

U&C is fully invested in sustaining the success of Greater Cambridge and playing its part in this success, by delivering Waterbeach New Town, under the extant outline planning permission. Committed sites, in delivery, are still very much part of the considerations relevant to whole plan viability. Waterbeach, like others, is a phased development reliant upon a monitor and manage approach to infrastructure delivery. This means that the scope and cost of infrastructure requirements continue to evolve and will compete for investment across the Plan period. A simple assumption that permission assures delivery and the infrastructure commitment is defined and funded is not the case.

U&C has no direct interest in the new, major allocations that are promoted within the Plan. U&C can nevertheless offer significant knowledge and experience in delivering
strategic scale development across Cambridgeshire and in other locations. Delivery of strategic sites is materially different and more complex than smaller scale development. This is now recognised in national planning policy through the inclusion of a definition of Strategic Sites in the recently published National Planning Policy Framework (NPPF). The Framework also tailors policy approaches to reflect the need for flexibility in the consenting and delivery of such developments, recognising the significant infrastructure requirements they support and the extended timescales over which they are brought forward. While the new NPPF is not material to this Local Plan, it underlines the relevant
and unequivocal point.

Despite good intent, U&C remains concerned that the evidence base supporting the emerging Local Plan has not adequately distinguished or appraised the potential
cumulative impact of the Policy demands within the Plan and the infrastructure burden on very large sites. South Cambridgeshire District Council and U&C have extensive
experience, over many years, of delivering new communities. It is not easy. The Local Plan, at present, seems to suggest otherwise. Deliverability is invariably secured from pragmatic and careful consideration of viability and priority. It involves flexibility and
compromise by all stakeholders. The Plan seems to suggest there is no need for this. It is implicit in virtually all the policies that precede Policy I/ID that all policy expectations and infrastructure requirements can be met. This is misleading; it is not founded upon the evidence as it stands or recent, shared experience of delivering large, complex development proposals across Cambridgeshire.

The Plan demands that every development proposal meets very high expectations across sustainability, design, urban greening, Biodiversity Net Gain (BNG), community
infrastructure and a wide range of community and housing needs, including affordable housing and affordable employment space. Cumulatively, the cost burden of these Policies is significant. There is very little comfort that the impact of these demands has been fully tested and translated into robust capacity assumptions for floorspace and homes, or considered in terms of the consequences for character and form. Where expectations go beyond national standards, guidance or current good practice (such as 20% BNG or a 0.5% urban greening factor and tree cover), the implication is potentially significant in terms of developable area, on large sites. This requires detailed sensitively testing, large site by large site, to be confident of deliverability.

Securing effective, integrated transport solutions for Cambridgeshire is a priority for virtually every component of the Development Strategy. The Transport Strategy (which at present is not even in final form) lacks detail and commitment. Firm proposals need to be added to the Local Plan, with scope, costs, funding, timing and actions understood.

The transport position presented in the IDP provides no evidence to demonstrate the transport interventions needed can and will be secured. Identified schemes are not scoped or costed or even directly related to the policy proposals. The NPPF (2024) paragraph 35 is clear, stating that ‘Plans should set out the contributions expected from development’ and policies that demand contributions ‘should not undermine the deliverability of the plan. This is only possible if the full infrastructure costs are understood and the cumulative impact of policy demands is properly accounted for a site level.

CIL presents an opportunity to better address strategic transport needs, but the approach to assigning CIL, forward funding in anticipation of CIL collection and how it
combines with Section 106 Contributions and other funding streams, is not clearly explored in the Infrastructure Delivery Plan.

A ‘whole plan’ approach to viability (and a simple per unit apportionment of anticipated Section 106 costs) is potentially a valid approach across a plan area reliant on many smaller and medium-sized allocations and where any individual proposal is unlikely to be critical to the Development Strategy or greatly dependent upon shared, strategic infrastructure. That is not the case in Greater Cambridge. Large sites and new communities are critical to the Development Strategy.

The viability position presented does not acknowledge the limitations of the Infrastructure Delivery Plan nor the work that is incomplete. Yet it is concluded that the Plan as a whole is deliverable. This seems a very premature conclusion given the absence of essential information and site-by-site appraisal.

Only under Policy I/ID is the scope for site-specific viability acknowledged, and this is without recognition that the infrastructure burden alone will virtually always necessitate
negotiation of priorities on large schemes, very often because of the transport mitigation ask. The Policy places the burden of proof entirely upon the developer, when it is
entirely appropriate that the developer should be satisfied that major Local Plan Allocations are intrinsically viable and deliverable. If this approach succeeds, the need
to balance and prioritise will only be revealed when a planning application is made. This means the developer bears the full brunt of objection, having ‘failed’ against policy expectation. Communities then have unrealistic expectations and are likely to be disappointed. This does nothing to build confidence, trust and support for the Plan or subsequent allocations or indeed the many benefits of large-scale, rather than piecemeal development.

See attached Response form for suggested amendments to Policy S/WNT

These representations are submitted by David Lock Associates on behalf of Urban&Civic (U&C). U&C now own the Barracks and Airfield site at Waterbeach, which
forms the major part of the Waterbeach New Town allocation. Prior to the purchase of the site U&C were development partner to the previous owners, the Defence
Infrastructure Organisation.

As master developer, U&C are delivering the redevelopment of the Barracks and Airfield,
primarily under Outline Planning Permission S/0559/17/OL (The OPP) (dated 25 September 2019). Outline Planning Permission for redevelopment is also in place on
the remaining part of the allocation, in separate ownership.

U&C is proud of the progress made in delivering Waterbeach New Town and remains fully committed to realising its long-term vision.

The emerging Local Plan still has a very important role to play in this endeavour. The new Plan provides a vital driver. While the principle of the development is established and embedded in extant outline planning permissions across the whole site, there remain some significant challenges to accelerating delivery and achieving full build-out.

U&C very much appreciate the further evolution of the Waterbeach Policy since Regulation 18 and the proactive engagement of officers to clarify and update the Policy.

U&C does broadly support the Policy, but submits objections on a number of detailed points, where the Policy is not clear in relation to what is expected, or inaccurate, or risks ambiguity to the extent of misinforming those less familiar with the details of the planning position.

U&C remain hopeful that many, if not all, of these issues can be resolved through further engagement with officers in advance of Examination.

The Policy and supporting text do not acknowledge that the entirety of the Waterbeach New Town Allocation is now subject to Outline Planning Permissions for development, under which implementation is progressing.

In the case of other allocations in the Local Plan, where comparable permissions are already in place, such as Hinxton Genome Campus, this important context is very clearly set out in the text accompanying the Policy. The drafting of this Policy rather implies that an outline planning permission is still to be granted or that permissions are partial. For example, paragraph 3.382 includes reference to matters that are ‘to be secured under
S106 Agreement’ in circumstances where those matters are very much already secured under the existing permissions.

This context is especially important because the extant planning permissions are not entirely consistent with the emerging Policy and cannot be retrospectively amended to be so. The Policy will be relevant to future reserved matters applications or, should it ever be necessary, different outline planning applications. However, for now,
development is progressing under the extant outline planning permissions. Accordingly, matters such as viability, infrastructure funding, Section 106 obligations, subsequent planning requirements and practical delivery considerations are governed by those
permissions.

Either the Policy needs to reflect what is permitted, or there needs to be a clear explanation that the development is progressing under extant outline planning
permissions.

Part 8a of the policy indicates that Waterbeach is ‘allocated for’ a range of uses. In principle, this is acceptable: a site can be allocated for a wide range of uses, and subsequent Planning Applications then address what is to be delivered, which may be some or all of what the Policy permits.

The issue with the drafting as it stands is that the Policy expresses key land use requirements (homes, employment and retail) as ‘approximate’ amounts and, in the case of homes, includes precise details, which, as explained in the supporting text, are now defined as requirements; specifically, 24 Gypsy and Traveller Pitches and 1050 units of specialist accommodation.

The current relevant Outline Planning Permissions express land use requirements as maxima and set ‘up to’ limits. Some uses are defined and required (not least those that are subject to obligations, such as schools); others represent ‘opportunity’ that may or may not be delivered in full or may fall short of the ceiling figures. The amount of employment or retail floorspace will, for example, depend entirely upon demand. The degree to which priority is afforded to housing delivery is also important.

Policy Part 9 states that ‘the above use will need to be delivered in a timely way’, which establishes an expectation that the uses will all be delivered, give or take a margin that is reflective of an ‘approximate’ figure. This is not the case and not the basis on which the OPPs have been granted. U&C are strongly of the opinion that clarification is needed to ensure that this does not create false expectations or misunderstandings.


U&C and its partners have delivered specialist key worker accommodation for nurses on site and affordable homes, alongside market homes. The precise composition of the
residential provision is not defined. However, in the relevant Outline Planning Permission, it is for determination phase by phase, in response to the Applicant’s proposal and the Policy in the Adopted Local Plan. The only Outline Planning Permission obligations are to deliver affordable housing and a minimum quantity (5%) of accessible homes: these requirements are fully factored into viability and the U&C delivery plans.

A precise quantity of Gypsy & Traveller and a precise quantity of specialist accommodation is not an obligation under the Outline Planning Permission, and was not
a requirement under the extant South Cambridgeshire Local Plan Policy or the Waterbeach SPD in place at the time the Outline Planning Permission was granted.
Gypsy & Traveller pitches are not expressly permitted under the OPP. Neither, for that matter, are other uses now included in this Policy, such as burial space. The Local Plan does not demonstrate that these requirements are now deliverable.

U&C can bring forward a range of dwelling types and tenures under the Outline Planning Permission and are working with the local planning authority to achieve a broad mix including specialist housing where delivery partners can be identified, and viability permits; U&C are not obligated or working towards a target number of specialist units, delivery of all types of housing or Gypsy & Traveller pitches. The SPD did not address how or where Gypsy & Traveller pitches might be accommodated on site, and the use has not been factored into parameter plans or subsequent more detailed plans. It is not easy to incorporate this need now, especially given the ‘edge’ location requirement. As the supporting text to the proposed Policy H/GT states: ‘New communities that
accommodate Gypsies and Travellers and the settled community from their conception allows for the different land uses to be considered in a co-ordinated and integrated manner through the masterplanning and design process.’ This did not happen as the Waterbeach proposals were shaped, as there was no requirement for it to happen.
Waterbeach is now significantly beyond the point of ‘conception’, and it is not possible to revert to reshape development that is in progress.

Directing any residential (Use Class C3) housing land to Gypsy and Traveller use will reduce the number of dwellings delivered against the 6,500 dwelling allocation. To maintain viability and the current Affordable Housing commitment, which remains below policy target, development land could only now be reassigned to uses not currently permitted, at greater than market residential land value, to redress the loss of land for market and affordable homes. This is not an approach which U&C is willing to support.

Policy Part 10 is generally supported, subject to two further proposed amendments:

Policy Part 10d -
Runway Park is not a historic feature – it is a linear area of grass, alongside the former runway that is proposed for amenity, as a green corridor: it is a feature of the proposals coming forward, not an asset to be protected.

Policy Part 10g -
Reference to ‘village’ does not make sense – the SEA is related directly to, and north of, the Town; it is not related to the existing village, so it is not protecting ‘village character’.

Policy Part 12 -
It is not entirely clear what is meant by ‘built form’ being in accordance with the indicative Spatial Framework diagram. The diagram does not show built form. We assume the intention is to limit the built development area and suggest drafting that would correspond to this, as long as it can be suitably keyed on the Spatial Framework Plan.

Policy Part 17 -
A minor addition to this section has been suggested to reflect the fact that not all features on the site can be retained or make a positive contribution. Recent practical
experience of seeking to maintain plantation trees on site is a good example of where maintaining older, lower-quality stock is not successful, and new planting is preferable.

Policy Part 22 -
It would be helpful to have greater consistency between the text and Spatial Framework Plan with regard to the location of park and ride, mobility hubs and a full multi-modal interchange at the proposed new Station. The Plan uses a symbol that combines all these elements together.

Policy Part 22a -
This is related to design on site, so (i) should refer to ‘town’, not ‘village’.

Policy Part 23 -
Refers to an ‘agreed master plan’ and the need for a ‘transport mitigation plan’. It is not clear if either of these things exist at present. The Waterbeach SPD provides an
overarching form of master plan – is this what is being referred to?

With regard to transport, the OPP establishes a bespoke ‘monitor and manage’ based mechanism for transport mitigation. It is not clear whether this is still aligned with the ‘strategic and local transport mitigation plan’ referred to in the emerging Policy. If the policy is signalling something new/different in relation to a master plan and transport mitigation plan, it should be clear in what circumstances these are required and how they differ to that which is already in place and guiding delivery. It should only apply in circumstances where the mitigation approach is not already settled. Otherwise, it is
unclear how and when an applicant should respond to this Policy requirement.

Policy Part 26 -
A minor correction is suggested to reflect that not all development is subject to design code requirements and that Reserved Matters Approvals (RMAs) are the primary
determinant of delivery.

Indicative Spatial Framework Plan for Waterbeach New Town

The status of this Plan remains somewhat unclear, but U&C welcome the fact that it is now more closely aligned with the existing SPD and Outline Planning Permissions. To better align with the drafting of the Built Development, it would be beneficial if the yellow area was labelled as the ‘Area for Built Development’. Simplification means that
important distinctions are lost, such as the difference between a small mobility hub at the northern entrance and a major interchange at the station (both have the same labelling). It is important that there is clarification somewhere in the Plan that these Diagrams are high-level and indicative or the plan needs a further level of granularity to be accurate.