This post represents my views. It does not necessarily represent the views of Huntingdon Town Council or any other organisation with which I’m associated.
“A local plan sets out planning policies and identifies how land is used determining what will be built where. Adopted local plans provide the framework for development across England and the government has repeatedly emphasised the importance of universal plan coverage.”
Report to Huntingdonshire District Council Overview and Scrutiny Panel (Performance and Growth) on the Pre-Submission Local Plan, para 2(1)
Introduction
This post is my summary of what the Pre-Submission Local Plan does that affects Huntingdon or responds to asks from Huntingdon Town Council. The bulk of the useful content is in the ask tracker. I have done my best to be thorough but I have written this quickly because of the timings mentioned above so it is more likely than usual that there will be mistakes. I’ve tried to learn as much as I can about local plans and the plan making process over the past couple of years, but I am very much not an expert.
The local plan is available to download and read here.
There is going to be growth in Huntingdonshire. Huntingdon is going to grow. The question is how that growth is managed – or whether it’s going to be managed at all.
“Multiple phases of public engagement have been carried out to meet the requirements of Regulation 18 of the Town and Country Planning (Local Planning) (England) Regulations 2012 to ensure that the Pre-Submission Local Plan to 2046 has been strongly shaped by inputs from local communities, businesses and organisations.” [emphasis added] Report to Huntingdonshire District Council Overview and Scrutiny Panel (Performance and Growth) on the Pre-Submission Local Plan, para 3
I agree.
Of the 70 things that Huntingdon Town Council said it wanted in the local plan, forty are entirely there and a further ten are partially there. Others will have been asking for the same things, but it’s still a 75% win rate and some of those are big wins. The proposal for Lodge Farm envisions 1km of open space between it and anything that happens at Wyton. The Sapley Park Garden Village additional site has gone because it is not sustainable. There are tools in the local plan to make sure infrastructure comes before and with development, not after it.
The alternative to this local plan to wait for whichever new unitary we end up in to draw up a local plan. That will be for the whole of the new unitary, not Huntingdonshire. Except under option E, it will be a local plan that includes the city of Peterborough. The new process for drawing up a local plan takes thirty months. The earliest that can start is 1st April 2028, vesting day, when the new unitary becomes a planning authority. That means we would be without a local plan until at least October 2030 even if the new unitary authority starts on day one and goes through the process as quickly as possible. That seems unlikely. That means it would be harder, for instance, to stop the current Sapley Park Garden Village proposal that would see Huntingdon reach up to Abbots Ripton.
However, my support for the local plan is not because of that. I support the local plan because I think it’s a good plan.
Ask tracker
The table below is based on my notes of Huntingdon Town Council’s submissions to the various rounds of consultation. There are 70 asks in total. 40 were achieved, 10 were partially achieved, 16 were not achieved, and 4 have not been rated for various reasons. I think that means three quarters of the things Huntingdon Town Council wanted ended up in the pre-submission local plan.
Some of our asks were very ambitious, and some, in retrospect, asked for the impossible. That the Lodge Farm site will, under this document, have a kilometre of open space between it and Wyton; and developer contributions to active travel will include access to key sites, improving infrastructure away from the development itself; and that the need for early engagement with town and parish councils; and that town and parish councils will be given first refusal on open space and community facilities feel like substantial wins.
| Stage | RAG |
|---|---|
| FIO – Further Issues and Options | 🟢 Meets, very close to, or exceeds our ask |
| AS – Additional Sites Land Availability Assessment | 🟨 Partially meets our ask |
| APS – Additional Preferred Sites | ♦️ Does not meet our ask |
| PO – Preferred Options Draft Local Plan | ✖ No longer applicable |
| Ask | Stage | Pre-Submission Local Plan | RAG |
|---|---|---|---|
| End date of 2043 | FIO | Plan runs to 2046 | 🟢 |
| Vision built on Huntingdonshire Futures (Option A) | FIO | Adopted. Vision now stated directly in terms of the five journeys | 🟢 |
| Growth strategy: a new community plus growth at existing settlements; oppose dispersed growth and the strategic road network | FIO | Substantially adopted. Strategy built on market towns and service centres; three new communities | 🟢 |
| Huntingdon and St Neots in their own higher tier (Option E) | FIO | Not adopted. All four market towns share the top tier | ♦️ |
| Review the Huntingdon Spatial Planning Area boundary | FIO; PO | Overtaken. Spatial Planning Areas are abolished. | ✖ |
| Identifiable boundaries so Huntingdon does not merge into neighbouring settlements | FIO; PO | Partly. Lodge Farm requires integration with Huntingdon while maintaining separation from other settlements, with an approximately 1km gap to Wyton Airfield at 9.93. Prestley Country Park separates from Alconbury Weald. No general policy | 🟨 |
| Alconbury Weald to remain its own settlement, not a suburb of Huntingdon | FIO; PO | Prestley Country Park separates from Alconbury Weald | 🟢 |
| A shorter name for the North Huntingdon Growth Cluster Opportunity Zone | PO | No. “North Huntingdon opportunity zone” and “North Huntingdon growth cluster” are also used. However, language comes from CPCA. | ✖ |
| Cumulative impacts of the Zone extend beyond its boundary | PO | Addressed in LP 3, which requires proposals to show how they manage the cumulative impacts of growth | 🟢 |
| An uplift above the standard method figure | FIO | Adopted, then reduced. 10% in the Draft, just over 5% here | 🟢 |
| More housing is needed in Huntingdonshire | FIO; PO | Reflected throughout | 🟢 |
| A clear affordable housing target (Option B) | FIO | Adopted. 30% in LP 18. See note above. | 🟢 |
| Affordable housing not confined to service-rich locations (Option B) | FIO | Adopted | 🟢 |
| Address the shortage of smaller units through a required mix (Option C) | FIO | LP 45 says have regard to evidence but sets no numerical mix; this allows for changing need | 🟨 |
| A mix including studios, flats and bungalows for single people, couples and retirees | FIO | Not adopted as a requirement. Draft LP 41 also says that “[n]ew social and affordable rented homes must be designed to at least meet whichever is the more generous of the Nationally Described Space Standards or the M4(2)/ M4(3) standards or successor standards at the time the planning application is submitted.” This has gone from LP 18, and 4.72 only references the Nationally Described Space Standards. | 🟨 |
| A floor on affordable housing that viability assessments cannot breach | PO | Not an absolute floor, but very substantial improvement at LP 18 | 🟢 |
| Housing mix policy to use up-to-date evidence, matching the affordable housing wording | PO | Partly. “Aligns with” becomes “has regard to”, but LP 45(d) now refers to local assessments of need “within the relevant town or parish” | 🟨 |
| Older people’s and retirement housing to take account of existing provision nearby | FIO; PO | Not adopted. LP 48 has nothing on existing provision or over-concentration | ♦️ |
| Supported and specialist housing not concentrated only where services exist | FIO | Not adopted | ♦️ |
| HMO policy to cover amenity as well as character, plus parking assessment and communal space | PO | Not adopted. LP 49(d) covers character only | ♦️ |
| Infrastructure delivered early in the development process, not at the end | FIO; PO | Adopted and strengthened. LP 12 carried over; new strategic LP 14; infrastructure delivery plans for large strategic sites at 4.9; stepped trajectory; A141 and water recycling capacity as monitoring indicators | 🟢 |
| Stronger wording so there is no under-provision of schools and healthcare at any stage | PO | LP 14 and Appendix 3 | 🟢 |
| Consultation with bus providers for substantial developments | FIO; PO | Not specifically mentioned but implied | 🟨 |
| Connections and improvements to existing active travel infrastructure, not just within sites | FIO; PO | Adopted. LP 30 requires connection to and extension of existing routes, now extended to “key destinations” | 🟢 |
| Support for East West Rail | FIO | Adopted. Named in LP 14 | 🟢 |
| Reduce reliance on private cars (Option A) | FIO | Adopted | 🟢 |
| EV charging required, or its practicability considered | FIO | Adopted. LP 32 | 🟢 |
| EV charging retrofitted in existing developments and where only on-street parking exists | PO | Not adopted. LP 32 applies to new development only | ♦️ |
| Cycle changing and showering facilities where an alteration takes a building over 2,500m² | FIO; PO | Not adopted at either stage. LP 31(j) still applies to new buildings only | ♦️ |
| Cycle spaces for town centre changes of use over 600m² | FIO; PO | Not adopted at either stage. LP 31(i) still applies to new uses only | ♦️ |
| Car parking numbers plus unassigned spaces for visitors and deliveries | FIO | Partly. LP 31 sets criteria but no unassigned space requirement | 🟨 |
| Alternative access to Hinchingbrooke; two points of access | PO | Partially. Views Common Road access, but no second access via Parkway, but I don’t think this is something the Local Plan can actually do. | 🟨 |
| HGVs kept out of Huntingdon from the A141 employment site | FIO | Not adopted. I don’t think this is something the Local Plan can actually do. | ✖ |
| Water efficiency at 100 l/p/d, with support at 80 | FIO | Exceeded. LP 24 sets 90 l/p/d. I don’t think our extra support at 80 is actually possible | 🟢 |
| Non-household water efficiency at “excellent” or “outstanding” | FIO | Not adopted, and weakened since the Draft | ♦️ |
| An alternative decarbonisation scenario, maximising reductions by 2040 and keeping the target under review | FIO | Not adopted. The balanced pathway is retained | ♦️ |
| Ambitious renewable energy (Option B) | FIO | Adopted. On-site generation, preferably on plot, sized to total annual demand, is retained in LP 28 | 🟢 |
| Support for retrofitting existing buildings and microgeneration | FIO; PO | Adopted. LP 29, now anchored to the Environmentally Sustainable Design and Construction Technical Advice Note (November 2025) | 🟢 |
| Clarify how the heritage and energy efficiency balance works in practice | PO | Not adopted. The caveat is unchanged | ♦️ |
| Stronger language than “considering” climate resilience | PO | Adopted. LP 26(f) now reads “incorporates climate resilience measures” | 🟢 |
| Streetscene improvement recognised as a public benefit in the demolition policy | PO | Not adopted. The entire justification schedule has been deleted from LP 28 | ♦️ |
| Green and blue infrastructure Option B, plus additional Huntingdon sites in the Recovery Network | FIO | Partly. Priority Areas are now a strategic policy, but no additional Huntingdon sites are identified | 🟨 |
| Protection for informal, undesignated green space against cumulative loss | PO | Not adopted | ♦️ |
| Not all remaining green space in Huntingdon treated as suitable for infill | PO | Not adopted. Windfall remains a numerical allowance. However, other means of protecting via neighbourhood plans. | ♦️ |
| Refuse and recycling futureproofing | PO | Not adopted as a distinct requirement. LP 26(d) covers integration only | 🟨 |
| Disabled access and energy retrofit named as public benefits for heritage assets | FIO; PO | Not adopted at either stage. LP 56 | ♦️ |
| Economic and environmental sustainability of heritage assets | FIO; PO | In text of LP 56 | 🟢 |
| Flexibility for non-main town centre uses at ground floor in a primary shopping frontage | FIO | Adopted, and further. LP 42 supports class E and class C1 of any scale, plus residential on upper floors | 🟢 |
| Additional markets supported only where they would not damage existing markets | FIO | Not adopted. LP 42(f) still supports an additional market that “adds diversity” with no test of harm | ♦️ |
| Mayfield Road shops designated as a local centre | PO | Not adopted. Huntingdon’s local centres remain Huntingdon Retail Park, Tesco and Tower Fields, Stukeley Road Retail Park and Oak Drive | ♦️ |
| Recognition of the importance of market town centres | PO | Retained and strengthened | 🟢 |
| Careful masterplanning for large sites | FIO | Adopted. LP 11 has thresholds of 50 homes, 2,500m² or 2ha | 🟢 |
| Early and meaningful engagement with town and parish councils in masterplanning | PO | Adopted, in supporting text. 3.113 says masterplanning for all large scale major development should engage the local community “including relevant Town and Parish Councils”, with early engagement to inform option development and consultation on the draft masterplan. It sits in supporting text rather than the policy box | 🟢 |
| Limit follow-on developments from well-related land outside the built-up area | PO | New NPPF | ✖ |
| Health and wellbeing as a strategic policy | PO | Adopted. LP 17 is strategic, and the threshold falls from 100 homes to 50, with tiered rapid and full HIAs | 🟢 |
| Nine of ten active design principles | FIO | Reflected through LP 17 and the design policies | 🟢 |
| Huntingdon Racecourse unsuitable because of flood risk and the SSSI | FIO; PO | Substantially adopted. Employment use dropped; racecourse retained; sequential flood strategy, drainage betterment and SSSI protection required | 🟢 |
| Lodge Farm supported, subject to A141 certainty, integration, active travel, early infrastructure and a definite edge | FIO; PO | Largely adopted. 317.7ha for about 4,900 homes, innovation quarter, A141 realignment, at least one mobility hub, integration with Huntingdon with separation from other settlements, 1km gap to Wyton retained. No dependency on the A141 route being settled first. NB that numbers for education and care have been replaced with assessment phase by phase. | 🟢 |
| Land North of A141 suitable subject to mitigation | FIO | Adopted as an employment allocation. New reference to a possible bus depot | 🟢 |
| Land south and north east of Ermine Street appropriate | FIO | Adopted. Now a single allocation to allow joint provision of a two form entry primary school | 🟢 |
| Amber Centre: community use preferred, otherwise around 12 homes, suited to bungalows | FIO; PO | Partly. Allocated for about 12 homes. No community use; nothing on bungalows or on the cumulative Suffolk House point | 🟨 |
| Land off Huntingdon Road, Brampton, as a benefit to the country park | PO | Adopted. Allocated for green infrastructure, biodiversity net gain, open space and parking | 🟢 |
| Sapley Park Garden Village: “unsure” about allocation as a reserve site, on the basis of the cumulative impact of development in and around Huntingdon. Opposed to proposal, comments on what could make it more acceptable. | APS | Not allocated | 🟢 |
| Nook Farm, Wyton Airfield and Hungry Hall: clear boundaries, no sprawl | FIO | Wyton Airfield is allocated as a new community with separation from Houghton and Wyton required. Nook Farm and Hungary Hall do not appear | 🟢 |
| Nook Farm: no building in flood zone 3, flood zone 2 for parkland, allotments and sports pitches; no flooding caused within the Huntingdon parish boundary; bus provision and cycle access all the way into Huntingdon | FIO | Not allocated | 🟢 |
| Land West of Scholars Avenue undevelopable because of flooding, loss of green space and traffic | FIO | Not allocated | 🟢 |
| Land off Old Houghton Road suitable only for moorings and a single supporting building, tightly constrained for parking, with junction improvements at the A1123 and Main Street | FIO | Not allocated | 🟢 |
| Land north of 6 Old Houghton Road unsuitable on flood risk and access; the sustainability appraisal’s finding of good accessibility contested; unlikely to pass the sequential test | FIO | Not allocated | 🟢 |
| Former WATA site, Hartford (Huntingdon 5) unsuitable for residential development: flood risk, cumulative risk with the Old Houghton Road sites, scepticism that the sequential test could be met, low density if approved, non-residential uses to be considered | AS | Not allocated. | 🟢 |
| Hinchingbrooke Hospital site (Huntingdon 4) unsuitable for residential development; low density if approved; consideration to be given to non-residential uses | AS | Partly. The site is allocated as Huntingdon 1 for mixed use, but healthcare-led: replacement hospital, ambulance station reprovision, related healthcare in class E(e), parking, and residential limited to affordable key worker and medical or care student accommodation. The objection to general residential development is met in substance; the objection to any residential element is not. However, our ask should have made clear that we didn’t include accommodation on the hospital site, but only accommodation on the legacy space. Community provision implied. | 🟢 |
Strategic Policies
As I understand it, a strategic policy is one that is essential to delivering the local plan as a whole. The term comes from the NPPF. Making a policy strategic entrenches it. The text might be exactly the same, but becoming a strategic policy substantially increases their importance.
Strategic policies are called out at 1.11 as all the policies in 3 and 4 and the site allocations in 9, 10, 11, 12, and 13.
In short, infrastructure, transport, renewable energy, health, affordable housing, heritage, green and blue infrastructure, carbon capture, and water have all been given much greater weight as policies.
Infrastructure
Pause the Plan have been campaigning to, well, pause the plan. I agree with a lot of their concerns but do not believe that pausing the local plan process would do anything to address those concerns and might make things worse. My own view is that some of what the Pause the Plan campaign is asking for cannot be done by the local plan, and that the iterative way the local plan comes together means evidence is pulled together throughout the process. Nevertheless, I am glad that concerns raised by Pause the Plan and others, including Huntingdon Town Council, have been recognised, listened to, and acted upon. The provisions for making sure infrastructure comes with development show this. The stepped housing trajectory makes this easier to achieve. The use of viability assessments, which often have the effect of reducing social and affordable housing, has been tightened up.
The infrastructure process is considerably stronger, largely because of the completely new, strategic Policy LP 14 Supporting and Enabling Strategic Infrastructure. This does three things.
Firstly, it commits the council to supporting strategic infrastructure including but not limited to the A141 upgrade, the St Ives Transport Improvement Scheme, East West Rail, reservoirs and their associated infrastructure, waste water treatment plants, and rural accessibility.
Secondly, where proposals for strategic infrastructure are still being worked up, new developments can’t get in the way.
Thirdly, planning obligations can be used for mitigation, phasing, or design measures to stop developments getting in the way of strategic infrastructure. It also includes an explicit refusal power to make sure strategic infrastructure can be safeguarded.
The effect is that development proposals cannot get in the way of the delivery, operation, or future expansion of strategic infrastructure, and must safeguard land for them, and ways of making sure that happens are set out. This seems to me to be a very significant strengthening indeed over the effective equivalent in the draft of a few words at Draft LP 18.
All mentions of interim water treatment solutions have been removed between the preferred options draft local plan and the pre-submission local plan. Policy LP 22 includes “If acceptable permanent [waste water] solutions are not possible, proposals will not be supported.”
For the North Huntingdon Growth Cluster Opportunity Zone, there are further guarantees at Policy LP 3 that are worth quoting in full:
“Proposals in this growth cluster will be expected [to] demonstrate how they are working collaboratively to support delivery of the infrastructure necessary to deliver development and to manage the cumulative impacts of growth. Other proposals within this growth cluster may be supported where evidence indicates that they can be successfully delivered without giving rise to significant detrimental impacts on local communities, infrastructure capacity and the natural and historic environments.”
Huntingdonshire District Council Pre-Submission Local Plan
Appendix 3 sets out developer contributions. I think it is significant that this is part of the local plan and not a supplementary planning document. I think that viability assessments have become harder to initiate and harder to achieve.
Housing delivery
The overall target remains 32,200 new homes between 2021 and 2046. For jobs, it has risen from 14,400 to 15,400. The uplift over the (revised) standard method figure for housing has been cut to “just over 5%” (Policy LP 1). Huntingdon Town Council previously argued at the Further Issues and Options Paper for 10% because of our concerns about tilted balance. The plans for Sapley Park Garden Village suggest to me that we are right to be very concerned about uncontrolled development under tilted balance, given what has been proposed. However, the new NPPF does not include an equivalent of the old paragraph 11(d) that gave rise to tilted balance.
The really big change is that, instead of a flat, yearly target, delivery is back-loaded. From 25/26 to 29/30, it’s an average of 1,050 homes a year; then 1,250 a year from 30/31 to 34/35; then 1,482 a year from 35/36 to 45/46 (Policy LP 1 and Appendix 7). At 3.21, this is mentioned as being specifically permitted in planning policy and is to allow infrastructure to be front-loaded. Taken together, I read this to mean that most housing will come after the A141. This does make it important to get on with delivering that infrastructure as it becomes part of the critical path. Large sites have to set out how infrastructure will be delivered. Policy LP 14 names pieces of infrastructure that will be supported.
Policy LP 12 specifically says that infrastructure should be provided such that there is no short-term adverse impact on existing residents.
Policy LP 3 includes
“Sufficient site allocations are included within this Local Plan to meet the district’s housing and employment needs in full. A proposal for additional development may be supported where it is in a sustainable location in accordance with other policies of this plan and of a scale that can be successfully integrated into the local community.”
Huntingdonshire District Council Pre-Submission Local Plan
I take this provision to be in case some sites become unavailable or take longer to develop than expected, affecting the five year housing land supply, as Sapley Park Garden Village reserve site has been struck. This language was not in the preferred options draft local plan
The Preferred Options Draft Local Plan, at Draft LP 41, asked for 30% affordable housing within sites of 10 or more houses, of which 20% would be social rent, 50% affordable rent, and 30% affordable ownership. The Pre-Submission Local Plan, at Policy LP 18 retains 30% affordable housing, of which 30% would be affordable ownership, but 70% affordable rent and social rent. It is therefore theoretically possible to build a development with zero properties for social rent. Policy LP18 also now allows off-site provision and commuted payments in exceptional circumstances, which the draft did not, constituting a second route by which social rent could fall out of a scheme. If I could make one change, it would be to go back to a percentage requirement for social housing.
The environment
It is notable that language has moved from aiming for net zero to achieving climate resilience. However, the commitment to follow the ‘balanced pathway’ to reach net zero carbon emissions in Huntingdonshire by 2050 remains.
Biodiversity net gain is set at 10%, where it had previously been 20%; Huntingdon Town Council has previously favoured 20%.
The East Inshore and East Offshore Marine Plans are specifically referenced at 1.17 and standards for open space are in Appendix 3 rather than a separate document.
Draft LP 12(d) required proposals to assist in achieving Natural England’s Accessible Natural Green Space Standards (ANGSt). LP 19(d) now says only that proposals should improve “the accessibility, naturalness and connectivity of green spaces for all potential users”.
Draft LP 23’s presumption against demolition came with a justification schedule: percentage of envelope and structure retained, a structural engineer’s report, an architectural and building services report, the importance of the architecture in the streetscene, and whether significant public benefits would be delivered. All of that is deleted, leaving a one-sentence presumption in Policy LP 28. The Future Homes Standard and BREEAM “Very Good” are replaced by “national standards at the point an application is made”, and the design principles move from “must consider” to “should demonstrate that it has considered”.
Policy LP 24 keeps 90 l/p/d for residential water use from Draft LP 16. The current Local Plan has 110 l/p/d. Huntingdon Town Council had asked for 100 l/p/d with a desire for 80 l/p/d. Given that we live in a water-stressed area, this seems very sensible. A new paragraph asks public buildings such as schools and hospitals to take opportunities for higher standards “where practical and viable”.
Towns and parishes generally
As mentioned above, there is a clear, consistent expectation for developers to engage early with stakeholders, including town and parish councils.
The new NPPF makes housing requirements and allocations a live issue for neighbourhood plans. Per the NPPF, a neighbourhood plan cannot have the effect of there being less development than there otherwise would be. The local plan specifies housing development rather than development.
Appendix 3 includes a section (17.39 to 17.41) on maintenance costs that gives town and parish councils first refusal on ‘infrastructure, such as community halls and open space’ with maintenance costs for fifteen years. Where a town or parish council refuses, it is offered to the district council; if the district doesn’t take it on, the developer has to submit proposals for a Trust (not a trust) to handle maintenance. This seems to be the ending of management companies. I would have liked town and parish councils to have also been given first refusal on sporting facilities, but that might only be appropriate for some sporting facilities.
Final thoughts
I recognise that many are uncomfortable with lots of new houses, and some are explicitly opposed. I believe that we do not have enough houses and need to build more because we haven’t been building enough for decades. However, the choice is not ours to make; the number of houses we will see built is set out through the government-set standard method. It is more sustainable economically, environmentally, and socially for those houses to go where there are the facilities to support them. They have the potential to benefit existing residents, not least through more people to use the town centre and support the night time economy. It will do a lot to prevent Huntingdon sprawling into neighbouring settlements, and it will see investment to connect new developments with the rest of the town. I think the economic development offered by Project Fairfax could make life better for people who already live in Huntingdon; not just jobs, but education, training, apprenticeships leadings to skilled jobs that will allow people to take pride in contributing to the defence of the realm.
There is much more to do to make this happen; the local plan, should it go into force, is not the end of the story. Two particular areas come to mind. In order to make sure infrastructure provided meets then-current needs, quite a lot of specific numbers have been replaced with a requirement to assess against needs when development takes place. This makes sense but is somewhere to be vigilant as the security of fixed numbers has been lost and there is the potential for backsliding. The other is protecting open space in Huntingdon where development would not be appropriate.
Given that housing targets are set nationally, given the planning system that exists, and given the way local government works, I believe this is a good local plan for Huntingdon.