Greater Cambridge Local Plan: Proposed Submission

Remove part 5 of the policy.
Remove the word 'finely' from paragraph 4.49.

Part 5 of the policy is not capable of operation as the decommissioning will mark the end of the planning permission - the ecological enhancements and biodiversity net gain are not therefore capable of being controlled under the planning permission as it will have expired and the reason for them being provided will have been removed. It is noted also that statutory biodiversity net gain is required for 30 years only: this is akin with the current typical duration of a renewable energy generating planning development.
Part 5 of the policy is not effective.
Paragraph 4.48 includes the words 'finely balanced' in considering the benefits of renewable energy generation relative to the loss of agricultural land in food production. The term 'finely balanced' is unnecessary and contrary to national policy which does not advocate such an approach.

Remove part 2 of the policy.

Part 2 of the policy requires a 20% net gain on major developments. The justification within paragraph 5.8 of the draft Local Plan fails in my view to meet the requirement of Planning Practice Guidance (PPG) Paragraph: 006 Reference ID: 74-006-20240214. The Government has been clear (as confirmed in Paragraph: 020 Reference ID: 74-020-20240214) that the statutory framework represents the appropriate national approach towards, and benchmark for, biodiversity gains in planning.
The policy as drafted is therefore not consistent with national policy nor is it justified.

The policy requires re-writing to confirm that such obligations will only be sought where there is a deficit in service provision which would be made worse as a result of the proposed development.

The policy as drafted would lead to Section 106 contributions being required for single dwelling proposals as the Council's approach is tariff based with contributions being required whether or not there is a deficit of the relevant service in the local area. For example a single dwelling with a village which has an underused community facility will still need to contribute financially to improve that facility despite it not being necessary. This approach is contrary to 2024 NPPF paragraph 58 in relation to the legal tests for planning obligations. It is not therefore currently consistent with national policy.

It may be logical to merge policies GP/HE and GP/HA together?

Amend the policy wording to state: suitable, available and viable as opposed to just suitable in part 4 a and just available in part 4 b.

Parts 4a and 4b should refer to no suitable, available and viable alternatives. Suitability is not a sufficient test.

Amend the policy map to allocate the Land to the East of Oakington Road, Girton.

Whilst we have no comments on the policy itself the need for Green Belt release is, in our view, clearly required in order to deliver new housing development. As such our comments relate to the need to release Green Belt land for development. One such opportunity is the land to the north of Girton (land to the east of Oakington Road). In light of the requirements within Appendix C for housing growth within neighbourhood plan areas Green Belt release will be essential in Girton. The land to the east of Oakington Road is suitable for release. The land is shown via the attached plan.

The policies map should be made clearer to differentiate between the East West Rail and the A428 scheme.

See attachment which includes a plan showing the area which should be included within Allocation S/CB.

Amend the site allocation boundary of S/CB to include the land owned by Abbey.

Figure 67 is ambiguous at the western side of the site where the site allocation adjoins the A1198 and the A428. The red line boundary includes a straight line whereas the actual allocation is kinked to exclude land owned by Abbey Developments Cambridgeshire Limited. To the north of that area a wildlife corridor/noise buffer is suggested. This is inconsistent with the position on the ground and in any event it is not clear how the two uses are able to operate together. Please see the plan and further representations attached.