Greater Cambridge Local Plan: Proposed Submission

1) The number of rooms should be changed to 'approximately 250'.
2) All Class E uses should be considered acceptable on the site.
3) The extensive listing of heritage assets should be in the supporting text (if needed) not in the policy itself.
4) The word 'must' should be relaced with 'should take reasonable steps to...' or similar in terms of the desire to enhance existing routes and permeability.
5) Points 1b, 1c, 1d and 1e need to be deleted as they have no relevance to this site.

Whilst King’s College are pleased to see that comments about the site boundary, made at Regulation 18 stage have been taken on board and remain pleased to see the support for a student residential led scheme, we object to the specification of ‘approximately 243 student rooms’. This number is 13 less than at Regulation 18 stage with no explanation provided as to why. If the intention is that the number is determined by demonstration of the site capacity, it would be more sensible to say ‘approximately 250 rooms’. This would be more sensible when the 2018 Local Plan (Policy 26) refers to 350 rooms across the Mill Lane South and Mill Lane north sites, and when the former only delivered 94 rooms (leaving the balance of 256 rooms as suggested in the Regulation 18 version of the policy).
We continue to object to the specifying of subclasses within Class E which is unnecessarily prescriptive for no clear purpose. Again, the phrase ‘university related uses’ is meaningless without definition. The assumption is that this must include Collegiate use.
In 1a, we continue to question the need to list a range of nearby heritage assets when a Heritage Impact Assessment (HIA) is required. All relevant assets would have to be scoped in as part of that document anyway. The need for a HIA is in any case a requirement of policy GP/HE, without needing to be specified here. If considered necessary, assets could simply be listed in the ‘Supporting Information’ section only rather than being repeated. Then the policy can benefit from greater brevity and clarity.
We object to the inclusion on 1b, 1c, 1d and 1e which have clearly been copied in error from another policy. There are no ‘school facilities’ on the site and no space to provide a range of pitches, courts etc.
As with our Regulation 18 comments, we continue to object to the requirement that development ‘must ensure that accessibility and permeability of the site is improved and safer streets are created’. It is not reasonable to suggest that new routes are created through private land whilst the enhancement to existing routes will be subject to the control of the Highway Authority and so may be outside the developer’s gift.
King’s College do not object to the aspiration of this policy but as before, we would request that ‘must’ is replaced by ‘should take reasonable steps to…’ or ‘should seek to…’.

Strands b) and c) of the policy should be deleted as they are not relevant to a policy seeking public realm improvements.
Strand d) should be re-worded to require exploration of opportunities for enhancing public enjoyment of the river rather than specifically requiring a public space.
Strand g) should be reworded to 'should seek to' (or similar) rather than 'must' to reflect that enhancement to public routes and accessibility are not entirely within the developer's gift and may conflict with other site aspirations.

King's College are pleased that this policy is now better coordinated with Policy S/C/OPM and that references to the 2018 Masterplan have been removed.
However, we continue to object to the inclusion of b) and c) which relate better to the site-specific redevelopment policy (S/C/OPM) and are not relevant to a policy aiming to improve the public realm.
We object to strand d) which requires the creation of a public space fronting the river. Whilst we note the inclusion of the word ‘potentially’, this should be one of a range of options considered as it may conflict with, for example, townscape and other heritage aspirations. Again, whilst King’s College have no issue with the aspiration to improve public access to the waterfront this might be through a publicly-accessible building rather than a space. The policy should support exploration of feasible approaches, based on supporting studies, not advocate one approach without any technical assessment.
As with the redevelopment policy (S/C/OPM), we object to the blanket requirement to improve accessibility and permeability through the site and create safer streets (strand g). This should be an aspiration not a requirement as it is not purely within the gift of the owner of the site.

The policy needs to refer specifically to the clarification in Appendix H (esp H.13) or make it clear that any building taller than the one it replaces does not automatically 'break the skyline'.

King’s College previously commented on confusion which the phrase ‘break the skyline’ brings. Whilst the clarification given in Appendix H (specifically H.13) is helpful in clarifying that this is judged 'when viewed from a distance or from specific vantage points’ that is not our experience of how members of the public interpret the phrase. It would avoid confusion to highlight the explanation provided in H.13 within the policy, or to make it clear that any new building taller than the one it replaces does not automatically ‘break the skyline’. It depends on the context in which it is viewed.

The policy should be deleted (given the presence of the ne National Decision Making policies) or reworded to require that assets should be conserved as appropriate to their heritage significance.

Whilst King’s College recognises attempts to clarify the policy, we maintain our objection that it is not in line with the NPPF (as revised in August 2026).
Indeed, the presence of the new national decision-making policies, questions the need for local policies such as GP/HA at all.
Regardless, in para 2, by suggesting that development 'must' fulfil the requirements of the various strands which follow, the policy lacks the necessary balance in the new NPPF. National Decision-Making policy HE4 which requires that heritage assets ‘should be conserved in a manner appropriate to their significance’ is to be preferred.

The general wording of the policy is too rigid. The word 'must' should be replaced with 'should seek to' or similar.
In 1. b i) there is no recognition that re-naturalisation may be incompatible with the heritage significance of parts of the River Cam corridor which stems from built form and in places a surviving industrial character. More balanced wording is needed.
In 1 e i) the promotion of a continuous Cam Valley trail does not recognise that The Backs - one of the most recognisably characteristic parts of the river corridor - is in private ownership. This needs to be acknowledged and the need for flexibility to protect heritage significance not just biodiversity built in to the policy.
In 1f, it is not clear what is meant by 'the other roles of the river'. Clarity is required both as to what this means and how conflicting values are to be balanced.
With regard to the riparian buffer zones:-
Again the policy wording needs to allow flexibility where heritage significance derives from built form not openness.
There needs to be greater clarity as to what constitutes essential infrastructure with recognition that this may include sustainable energy infrastructure and that this may serve groups of buildings (eg courts of College buildings) set away from the river and the infrastructure itself.

The College objects to this policy for the following reasons:-

1. The policy in general lacks flexibility, requiring that developments ‘must’ demonstrate compliance with all the various policy strands.
2. The historic significance of some parts of the River Cam stem from its built form and even former industrial character, which may not be compatible with the aims of re-naturalisation. Similarly, whilst there is recognition of the tourism and recreational function of the river, the phrase in strand f. of the policy that this is supported ‘whilst ensuring that this does not impact negatively on the other roles of the river’ is too vague to provide any meaningful guidance on how the different amenity values and characteristics of the river corridor are to be balanced in different situations.
3. In strand i) which requires support for a continuous ‘Cam Valley Trail’ there is no recognition that one of the most characterful parts of the River Cam are the private grounds of the Colleges. Whilst the supporting information in 5.74 recognises flexibility to protect biodiversity, it does not do the same to protect the historic Collegiate character.
The College also objects to the Riparian Buffer Zones’ policy.
This part of the policy is too rigid and does not adequately recognise that some parts of the Cam in particular derive their character from the juxtaposition of built form immediately adjacent or close to the riverbank.
The term ‘essential infrastructure’ is also vague, despite the clarification in 5.75. The river provides a significant opportunity to provide sustainable energy through river source heat pumps etc which would need some infrastructure to be built within the buffer zone. In the case of the Colleges, this could be a highly sustainable way to help meet energy demand for the entire College, not just a specific development. At the very least, this should be recognised in the policy.