The proposed Policy S/RRA: Site allocations in the rest of the rural area “allocates sites for homes or employment that support the overall development strategy within the rural area, excluding the rural southern cluster”.

The supporting text adds that:
“For employment, we considered the evidence from our Greater Cambridge Employment Land Review & Economic Development Evidence Base (2020) to understand the locational demand of different sectors. We then reviewed site opportunities to identify the preferred list of sites. The site selection was informed by the Housing & Employment Land Availability Assessment, and taking into account sustainable travel opportunities alongside the likely travel requirements of the proposed uses. We identified land that could respond to the need for local warehousing and distribution with good access to the highway network. We also identified some small-scale opportunities in accessible locations which could add the mix and types of land available.”

The J25 Bar Hill site is not allocated for development. Instead, the GCLP makes two allocations within the rest of the rural area that include an element of light industrial, warehousing and/or distribution uses (Use Classes B2 and B8). This list does not include Classes E(g)(i) Offices to carry out any operational or administrative functions, E(g) (ii) Research and development of products or processes; and E(g) (iii) Light Industrial processes. It also does not include allocations for replacement of existing floorspace (e.g. S/RRA/OHD Old Highways Depot, Twenty Pence Lane, Cottenham).
• S/RRA/SAS Land to the south of the A14 Services: 18.2ha suitable for Class B2 (General Industrial) and Class B8 (Storage or Distribution) providing a range of small and medium sized units.
• S/RRA/CR Land at Buckingway Business Park, Swavesey: 2.1ha for Class B2 (General Industrial) or Class B8 (Storage or Distribution). B8 use would be limited to small to medium sized premises.

Based on the above, the GCLP would be providing up to 20.3ha (based on our assessment in Appendix 1, the developable area is much less) of Class B2/B8 floorspace within the Rest of the Rural Area. There are no further allocations for Class B2/B8 floorspace in the emerging GCLP1.

Moreover, and as detailed in our response to Policy S/JH (New jobs and homes), the ELEDES’s storage and distribution uses floorspace need projections are a significant underestimate. Instead, we have identified a requirement for allocating additional land of 69.0 ha to 85.5 ha for storage and distribution uses which is suitable, available and deliverable across the Plan period to 2041. Considering the developable supply position in Greater Cambridge, this results in a shortfall of strategic logistics land of 55.0 ha to 71.5 ha.

J25 Bar Hill has capacity to deliver around 60 ha of developable floorspace and as evidenced by Appendices 3 and 4 of this Representation, is suitable, available and achievable, contrary to the conclusions of the Greater Cambridge’s HELAA Site Assessment ref.40248 (Appendix 2).

The site’s assessment is summarised at Appendix 3. As evidenced, the site is suitable, available and achievable and would help to meet Greater Cambridge’s employment need over the plan period to 2041, in accordance with the requirements of the NPPF.

The allocation of J25 Bar Hill for a sustainable leading-edge employment park development with business and logistics capability and capacity of around 60ha to meet the identified shortfall of employment land across the Plan period would fully align with emerging Policy S/DS and NPPF Paragraphs 11 and 83. Further and as recognised on pg. 36 of the supporting text of the GCLP “providing a healthy supply of land for business use should also help ensure land is affordable for all business sectors, including those which cannot afford higher cost space.”

Some of the clear planning benefits of allocating this site, over any others, include:

1 Strategic highways access: J25 Bar Hill is located just off Junction 25 of the recently upgraded A14, a key nodal point on the strategic road network, connecting the site with the Midlands ‘Golden Triangle’, London, the Freeports of Felixstowe and Harwich International and the existing employment provision in Greater Cambridge. The locational opportunity provided by the converging of many strategic roads around Cambridge for accommodating such strategic development on large sites would help meet local, regional and national employment need.

2 Minimal impact on the local highway network: given the location just off the strategic road network, it would not be necessary for larger delivery vehicles to use the local highway network, which would be required for comparable allocations on the edge of large settlements like Cambridge, contributing towards decreasing congestion, improving air quality and, overall, tackling the climate crisis.

3 Site size: the site has the capacity to deliver around 60 ha of developable space, contributing to meeting the identified employment shortfall of 55.0 ha to 71.5 ha across the Plan period. A single and large allocation is sustainable and offers the capability and flexibility of a range of unit sizes to respond to the spatial needs of different sectors, including the fast-growing and rapidly innovating logistics sector. This may not be possible for a series of smaller allocations. Further the site size offers the opportunity for extensive landscaping and greening with FPCR’s Biodiversity and Geodiversity Technical Appraisal (Appendix 4(iii)) identifying capability of achieving a c.12-20% biodiversity net gain.

4 Proximity to existing and new settlements: the site is close to new and proposed settlements of Northstowe (6,345 new homes across the Plan period), Cambourne West (2,590 homes), Cambourne (1,950 homes), Bourn Airfield (2,460 homes), Darwin Green (478 homes) and Eddington (3,142 homes). It is also in close proximity to the Waterbeach New Town. On this basis, the site will contribute to minimising workforce travel distances and maximise accessibility by sustainable transport opportunities such as bus or more active modes of transport such as cycling and/or walking. In addition, providing logistics facilities close to urban centres enables the use of electric fleet (which currently have specific distance limitations) and cargo bikes for last mile deliveries. These contribute towards decreasing congestion, improving air quality and, overall, tackling the climate crisis and contributes to the recently introduced Net Zero Strategy: Build Back Greener.

5 Opportunity for economic cluster on A14: there are a number of comparable existing businesses along the A14 including Bar Hill and Trafalgar Way which is identified as an important advance manufacturing cluster in the north of Greater Cambridge. In addition, the two emerging employment allocations ‘S/RRA/SAS Land to the south of the A14 Services’ and ‘S/RRA/CR Land at Buckingway Business Park, Swavesey’ prove that Greater Cambridge recognise the dynamics of this location along the A14. The allocation of J25 Bar Hill would help to exploit agglomeration benefits and complement the employment and business space offer along the A14 Corridor.

6 No major environmental and heritage constraints: the site is outside of the Green Belt and as detailed at Table 2 above there are no major environmental or heritage constraints that we would anticipate preventing the delivery of this site. Critically, at FPCR’s Landscape and Townscape Appraisal (Appendix 4(ii)), the site has been assessed as ‘Green’ in Landscape and Townscape terms instead of ‘Red’ in the HELAA.

We would therefore recommend that Policy S/RRA (Allocations in the Rest of the Rural Area) is amended to include a new allocation for the J25 Bar Hill site for a major leading-edge employment park development with business and logistics capability and capacity.