Draft Greater Cambridge Local Plan for consultation

3.1.20 For these reasons, the Local Plan should:
● Consider utilising a more optimistic and realistic figure for job numbers.
● Confirm that 73,300 jobs is a baseline minimum, not a maximum. Critical in supporting flexibility and changes in the market, as required under the NPPF 2024 and strengthened in the NPPF 2026.
● Include explicit support for higher-growth scenarios, with corresponding flexibility in employment land allocations.

3.1.1 Tritax object to the proposed wording of Policy S/JH.
3.1.2 The proposed policy wording presents the job figure as an objectively assessed need, however, the figure must be treated as a minimum benchmark rather than a maximum or constraining target.
3.1.3 The Emerging Local Plan identifies the need for 73,300 additional jobs between 2024 and 2045 to support Greater Cambridge’s knowledge-intensive economy and provide a diverse range of local employment opportunities. This is considered as the ‘central growth’ scenario, without accounting for the full objectively assessed need, for reasons set out below.
3.1.4 The policy’s supporting evidence base titled the ‘Greater Cambridge Employment and Housing Needs Update 2024-2045’ (September 2025), prepared by Iceni, concludes in Section 3.55 that the various scenarios modelled indicate a need of between 67,600 and 90,900 additional jobs over the plan period.
3.1.5 This range compares to between 66,600 and 75,800 additional jobs modelled under the previous 2023 results. This significant increase in the upper end of the modelling indicates that economic growth expectations have strengthened exponentially, not diminished.
3.1.6 As set out in the abovementioned Iceni Employment and Housing Needs Update, during the strongest phase of growth (2010–2020), the Greater Cambridge economy expanded by almost 4,000 jobs per year. The evidence identifies a ‘central growth’ scenario of 73,200 jobs across the plan period, representing sustained annual growth of around 3,500 jobs.
3.1.7 Crucially, this scenario already builds in assumptions of slower periods, contractions, and economic shocks, and is therefore inherently conservative rather than reflective of the full growth capacity of the Cambridge economy.
3.1.8 On 23rd August 2024, Matthew Pennycook reaffirmed the Government’s commitment to Cambridge stating; “The economic growth of Cambridge has been a phenomenal success and we should seek to maximise the potential contribution that Greater Cambridge could make to the UK economy.” Pennycook goes on to say; “Greater Cambridge has a vital role to play in this Government’s mission to kickstart economic growth.”
3.1.9 More recently, on 29th January 2025, Rt Hon Rachel Reeves (Chancellor of the Exchequer) reaffirmed the national importance of the Oxford-Cambridge Growth Corridor and in particular the opportunity to harness the potential for growing its reputation for science and technology, research and development in respect of ‘kickstarting economic growth’. This was referenced in the recent Call in Appeal Decision for the Beehive redevelopment (PINS Reference: 3360616, Appendix 6).
3.1.10 As set out in the accompanying ‘Need for B2/B8 in Greater Cambridge’ note prepared by Bidwells (January 2026, Appendix 7), this highlights the market suppression that already exists in Cambridge. Paragraph 16 of the note states; ‘By 2024, Oxford Economics local forecasts (April 2025) showed that only 9.7% to of the total GVA generated by Greater Cambridge was from the Manufacturing and Transport and Storage sectors1 (“the B2/B8 sectors”), compared to 14.7% for the entire Cambridge to Oxford Arc. Clearly there has been an intentional suppression of these industrial sectors in Greater Cambridge through planning policy since at least the 1990s and is now manifesting itself through a notable difference in economic output.” The emerging Local Plan must allow the market to respond accordingly and meet national and local planning objectives.
3.1.11 The Government’s commitment to growth in Cambridge, and specifically economic growth has been further strengthened through the direction of travel set out in the proposed reform version of the NPPF 2026. Policy E2 affords; ‘substantial weight should be given by the decision-maker to the economic benefits of proposals for commercial development’.
3.1.12 The Iceni Report acknowledges a ‘High’ and ‘High Sensitivity’ scenario, whereby growth would meet or exceed the 2010–2020 trajectory. This level of growth is feasible in Cambridge and would support the Government’s direction of travel from a national perspective. Recent comparative analysis of employment projections, including the Homes England study (2023), the Emerging Local Plan, and the Oxford Economics forecast (October 2025), indicates the proposed Local Plan assumptions remain relatively cautious at 1.3% per annum over the period 2024–2045.
3.1.13 These projected growth rates are no higher than those recorded between 2019 and 2024, a period which includes the impacts of the Covid-19 pandemic. By contrast, post-pandemic employment growth between 2021 and 2024 has exceeded forecast projections. Evidence demonstrates that higher-growth outcomes remain credible and should not be ruled out by policy, as is currently the case with the proposed policy wording.
3.1.14 The commitment to growth is evident in the recent Secretary of State Call in for the Beehive redevelopment. The Appeal Decision makes clear that the Secretary of State recognised “benefits in terms of employment and social value arising from employment should be given significant weight” and that “benefits relating to the proposal’s support for economic growth and productivity in the Greater Cambridge area should be given significant weight”.
3.1.15 Importantly, this reinforces the principle that economic growth plays a critical role in maintaining a fluid and competitive employment land market at a strategic scale, ensuring that sufficient choice, flexibility and quality of provision are available to support business expansion, inward investment and productivity gains across the wider area. This was further echoed in the Call in Appeal Decision for the redevelopment of Cambridge North (PINS Reference: 3315611, Appendix 8) which states; “The Inspector states that great weight should be assigned to economic benefits. In accordance with paragraph 85 of the Framework, the Secretary of State assigns significant weight to economic growth and productivity benefits, and driving innovation.”
3.1.16 The justification for the 73,300 figure rests on a ‘central’ forecast which assumes robust growth but explicitly accounts for downturns and unknown shocks. By definition, this embeds caution and therefore should not be treated as a cap on growth. The evidence base itself recommends flexibility in employment land provision to accommodate potential out-performance of the central scenario.
3.1.17 Furthermore, the Local Plan’s employment evidence identifies requirements for over 300,000 sqm of office and R&D space and over 317,000 sqm of industrial and warehousing floorspace, signalling substantial and growing demand across sectors - notably logistics, manufacturing, and support services.
3.1.18 Treating 73,300 jobs as a ceiling, risks misaligning land allocations, constraining business expansion, and undermining the Plan’s ability to respond to economic change. Chapter 6 (Building a strong, competitive economy) of the NPPF 2024 states at Paragraph 86 (e); planning policies should “be flexible enough to accommodate needs not anticipated in the plan, and allow for new and flexible working practices and spaces to enable a rapid response to changes in economic circumstances.” The commitment to economic growth is further strengthened in the direction of travel set out in the NPPF 2026 which states at Chapter 7 (Building a strong, effective economy); “Economic growth is the number one mission of this Government.”
3.1.19 As set out and reaffirmed at Section 7.92 of the Cambridge North Appeal Decision, “The Council is a pro-growth, pro-business authority which actively seeks to assess development needs and plan for them where it is sustainable to do so.” This stance is supported by the adopted Local Plan, which does not impose a cap on job numbers. By contrast, the introduction of a cap on job numbers in the Emerging Local Plan runs counter to the Council’s stated pro-growth agenda and represents a regression from the adopted policy position.
3.1.20 For these reasons, the Local Plan should:
● Consider utilising a more optimistic and realistic figure for job numbers.
● Confirm that 73,300 jobs is a baseline minimum, not a maximum. Critical in supporting flexibility and changes in the market, as required under the NPPF 2024 and strengthened in the NPPF 2026.
● Include explicit support for higher-growth scenarios, with corresponding flexibility in employment land allocations.
3.1.21 The Bidwells B2/B8 Needs note suggests at Paragraph 28 a need for 424,900 sqm net additional B2/B8 floorspace; “we consider the adjustment in GVA to reflect sufficient flexibility if the figure is considered a minimum in accordance with the NPPF”. This figure is above the 317,000 sqm citied in the Iceni Report 2025. Furthermore (Paragraph 3), it highlights the need to engage with industry developers and agents in accordance with the National Planning Practice Guidance (Para 2a-026-20190220), in particular logistics developers and occupiers in order to fully understand the changing nature and requirements in relation to size, type and location of facilities, particularly the emergence of new technologies (PPG Para 2a-031-20190722).
3.1.22 Without these changes set out above, Policy S/JH risks being unsound and inconsistent with current national policy objectives to support sustainable economic growth and productivity. The NPPF 2024, Paragraph 87 states; “Planning policies and decisions should recognise and address the specific locational requirements of different sectors. This includes making provision for: a) clusters or networks of knowledge and data-driven, creative or high technology industries.” Furthermore, by using an objectively assessed figure, the current policy wording is contrary to the Governments number one mission of economic growth, cited in Chapter 7 of the NPPF (2026).

3.2.10 To ensure Policy S/DS is effective, justified and resilient, it should be modified to:
● reduce reliance on a limited number of strategic sites for employment delivery;
● explicitly recognise the need for flexible and responsive provision of industrial and logistics land, including opportunities beyond strategic allocations; and
● ensure the spatial strategy supports the full range of employment uses required to sustain nationally significant growth ambitions.

3.2.1 Tritax object to the proposed wording of Policy S/DS.
3.2.2 Policy S/DS, as currently drafted and supported by its evidence base, places over-reliance on a limited number of large strategic sites to deliver both housing and employment growth.
3.2.3 This approach introduces significant delivery risk and uncertainty, particularly for industrial and logistics development, and risks undermining the Plan’s ability to respond effectively to nationally significant growth pressures in Greater Cambridge.
3.2.4 Policy S/DS directs the majority of growth to strategic sites and existing urban areas. It relies heavily on complex, long-term allocations coming forward as anticipated. Experience demonstrates that such sites are often subject to delays arising from land ownership fragmentation, infrastructure funding, viability constraints and changing market conditions. This creates a particular risk for employment land delivery, where industrial and logistics uses typically have lower value than offices, laboratories or residential development.
3.2.5 The Government has repeatedly reaffirmed the national importance of Greater Cambridge as a driver of economic growth, innovation and productivity, including explicit support for the Oxford- Cambridge Growth Corridor. These ambitions require not only laboratory and office space, but also a full spectrum of supporting industrial, logistics, manufacturing and distribution uses. The ‘UK’s Modern Industrial Strategy’, published by the Government in November 2025, confirms their commitment to Cambridge as they seek to “unleash the economic potential of Life Sciences Clusters”, including Cambridge. The Strategy also provides confirmation of the Government’s intentions specifically for freight and logistics and states they will be; “working closely with industry, we will deliver a new plan for freight and logistics later this year so that the sector can continue to play its part in growing the economy”. Recognition of the Industrial sector is strengthened in the NPPF 2026 which includes a specific policy for freight and logistics (Policy E3). Furthermore, Policy E2 also explicitly references freight and logistics in supporting economic development which is to be awarded substantial weight in the planning balance.
3.2.6 The Local Plan’s own employment evidence identifies structural shortages and delivery uncertainty even for high-value employment uses. Where the supply of laboratory and office floorspace is acknowledged to be constrained and uncertain, this highlights a wider issue: the employment land pipeline as a whole lacks resilience.
3.2.7 If the Local Plan does not provide sufficient spatial flexibility beyond strategic sites, industrial and logistics uses are likely to be further marginalised.
3.2.8 Policy S/DS is not fully effective because it relies on a narrow spatial strategy that lacks contingency should strategic sites fail to deliver employment land at the anticipated pace or scale. This is particularly problematic for industrial and logistics uses, which require a responsive and diversified land supply.
3.2.9 The policy is insufficiently justified in assuming that strategic sites alone can meet the full range of employment needs over the plan period. The supporting evidence demonstrates uncertainty and delivery risk, yet the policy does not translate this into a more flexible spatial strategy.
3.2.10 To ensure Policy S/DS is effective, justified and resilient, it should be modified to:
● reduce reliance on a limited number of strategic sites for employment delivery;
● explicitly recognise the need for flexible and responsive provision of industrial and logistics land, including opportunities beyond strategic allocations; and
● ensure the spatial strategy supports the full range of employment uses required to sustain nationally significant growth ambitions.
3.2.11 Without these changes, Policy S/DS risks constraining industrial and logistics development, undermining supply chains, and limiting the Local Plan’s ability to respond to economic growth over the plan period.

3.3.1 Tritax support the proposed wording of Policy S/SH.
3.3.2 Bar Hill is allocated as a ‘rural minor settlement’. In relation to rural minor settlements, the supporting policy text states they; “have a lower level of services, facilities and employment than rural centres, but a greater level than most other settlements in Greater Cambridge and often perform a role in terms of providing services and facilities for a small rural hinterland.”
3.3.3 When reviewed in the wider context of Greater Cambridge, as set out in the policies supporting text and Figure 14, Bar Hill benefits from a highly strategic location on the A14, which is a clear benefit and locational requirement of the logistics sector. A recent Appeal Decision at Thrapston dated 22nd October 2025 (PINS Reference: 3362393), as appended at Appendix 9, “established that the A14 is a priority route for strategic logistics.” Further to this, vehicular access will be taken from the B1050,
3.3.4 Bar Hill is one of only three ‘minor rural centres’ located on the A14 corridor and is considered the most appropriate location within Greater Cambridge to support growth in the industrial and logistic sector, being outside of the Green Belt, and in close proximity to the city. Histon and Impington is the only settlement above Bar Hill in the settlement hierarchy but given its Green Belt designation and wider context, is not considered a suitable alternative location for strategic industrial and logistics uses. Tritax Park, Cambridge located at Bar Hill is considered a preferable location for industrial and logistics uses and is not constrained by Green Belt. Furthermore, Bar Hill is well located to both Northstowe and Cambourne, both designated as ‘towns’ under Policy S/SH, providing a substantial and growing local workforce and a range of supporting services and infrastructure.
3.3.5 Paragraph 148 of the Appeal Decision identifies that the A14; “was built specifically to link the port of Felixstowe to the national motorway network at the junction with the M1 and M6 and provide access to the Midlands and the North. It is essential for the movement of imported and exported goods across the country with Felixstowe accounting for 5.3% of all freight moved through UK ports in 2023.” The Appeal Decision responds to key Paragraphs 86 (c) and 87 (b) from the NPPF 2024 in addressing barriers to entry and making provision for suitably accessibly locations for the efficient handling of goods. This is consistent with the NPPF 2026 which confirms the unique operational requirements required for the freight and logistics sector at Policy E3.
3.3.6 Paragraph 149 of the Appeal Decision states; “The A14 consequently plays a critical role in enabling the efficient distribution of goods entering and exiting the UK, connecting them to key distribution centres, manufacturing hubs and retail destinations. As such, it is of national importance and ready access to it directly contributes to growth-supporting infrastructure and the networks that support freight and logistics that the Government has identified as a particular priority.” This is further echoed in the direction of travel set out in the NPPF 2026 with economic growth the number one mission of the government, supported by a suite of policies in Chapter 7 to support a strong and effective economy.

3.4.12 Modifications to the policy should be made to support the logistics and freight sector, outside of defined development extents, which are well located to the strategic road network, support the Cambridge ecosystem and national planning policy guidance and the future direction of travel.

3.4.1 Tritax objects to the proposed wording of Policy S/DE.
3.4.2 These representations support the overall role of Policy S/DE; however, modifications are required to the policy wording to ensure it is effective and justified in enabling sustainable employment development on suitable land, including land located outside defined development extents.
3.4.3 The direction of travel set out in the NPPF 2026 includes a policy on the principle of development outside settlements (Policy S5). The policy seeks to prevent unsustainable patterns of growth and conserve rural character. Development that would be acceptable in principle includes development which would meet an unmet need or which “echoes what the current presumption in favour of sustainable development would allow where relevant plan policies are out of date, although it adds the proviso that in such circumstances development should be well-related to an existing settlement (unless the nature of the use would make this inappropriate), to guard against development being badly-located.”
3.4.4 Paragraphs 86 (c) of the NPPF 2024 aims to ensure planning policies address potential barriers to investment. Tritax have a committed occupier and are committed to investment and delivery on the Site. Paragraph 87 highlights that planning policies should address the specific locational requirements of different sectors. Part (b) states that planning policies and decision should make the provision for; “storage and distribution operations at a variety of scales and in suitably accessible locations that allow for the efficient and reliable handling of goods, especially where this is needed to support the supply chain”. Policy E3 (Freight and Logistics) of the NPPF 2026 also recognises the need for a sector specific logistics policy; “because of the particular physical and locational characteristics of logistics developments, which in some cases will involve particularly large structures, and because of the particular importance of having access to the right transport links for the type of operation.” Both adopted and emerging national guidance acknowledges the most suitable location for industrial and logistics must be assessed on merit and may be outside of defined settlement boundaries. This is acknowledged through the Councils currently proposed B8 allocations being outside of a defined settlement boundary.
3.4.5 Policy S/DE establishes a strong presumption against development outside defined development extents unless it falls within a narrow set of exceptions.
3.4.6 While Part 2d provides a mechanism of support for some development outside of defined development extents, as currently drafted, the policy is overly restrictive in its approach to unallocated sites outside defined development extents, which risks placing an undue reliance on larger strategic allocations to meet development needs. Such sites are often subject to longer lead-in times and increased delivery risks, including issues relating to land ownership, infrastructure funding and overall deliverability, which can hinder timely implementation during the plan period.
3.4.7 Tritax’s strong credentials and track record of delivery (particularly large strategic sites), supported by the necessary financial capital to deliver without external funding has been demonstrated by a Phase 1 unit, which is pre let and backed by a leading occupier. The first phase of Tritax Park, Cambridge will establish a new parcel distribution facility for a nationally recognised parcel delivery company, supporting sustainable logistics throughout Greater Cambridgeshire.
3.4.8 The policy does not sufficiently recognise that defined development extents are a plan-making tool rather than a definitive test of sustainability.
3.4.9 Policy S/DE is particularly restrictive for employment development that:
● requires larger plots;
● benefits from separation from sensitive residential uses; and
● is logically located outside of settlements in close proximity to the strategic road network rather than within tightly constrained urban areas.
3.4.10 Policy S/DE does not currently provide sufficient flexibility to allow well-related employment development to come forward where impacts can be acceptably managed, in accordance with the NPPF 2024 Paragraphs 86 (c) and 87 (b). Tritax Park, Cambridge is well located to Bar Hill and the A14 strategic road network, providing an appropriate environment in which a strategically important logistics park can be brought forward.
3.4.11 The policy is insufficiently justified in assuming that land outside defined development extents is inherently unsuitable for development. There is no evidence that all land beyond these boundaries is incapable of supporting sustainable development, particularly where impacts can be addressed through design, access, landscaping and phasing. This issue risks undermining the plan’s ability to respond positively to changing economic needs over the plan period.
3.4.12 Modifications to the policy should be made to support the logistics and freight sector, outside of defined development extents, which are well located to the strategic road network, support the Cambridge ecosystem and national planning policy guidance and the future direction of travel.

3.5.8 It is requested that Policy S/MO is modified to:
● clarify how monitoring outcomes will be used to inform decision-making during the plan period; and
● explicitly acknowledge the need for flexibility where monitoring identifies delivery risks or shortfalls.

3.5.1 Tritax objects to the proposed wording of Policy S/MO.
3.5.2 Modifications are required to ensure the policy is effective, proportionate and capable of responding to changing circumstances over the plan period. The NPPF 2024 Paragraph 86 (e) states planning policies should; “be flexible enough to accommodate needs not anticipated in the plan, and allow for new and flexible working practices and spaces to enable a rapid response to changes in economic circumstances.”
3.5.3 Furthermore, the NPPF 2026, Policy E1 highlights; “plans should avoid overly prescriptive requirements on acceptable uses, enabling flexibility to respond to changing commercial property demands.” As currently drafted, Policy S/MO lacks sufficient clarity on how monitoring outcomes will inform decision-making and plan flexibility, which risks limiting its effectiveness in addressing delivery shortfalls or unforeseen constraints.
3.5.4 A central purpose of monitoring is to ensure that the Local Plan remains effective over time, particularly in relation to development delivery. Policy S/MO does not currently provide sufficient flexibility or commitment to action where:
● delivery falls behind anticipated trajectories;
● certain types of development are not being delivered at the required pace; or
● reliance on a limited number of large or complex sites results in delays.
3.5.5 In the absence of a clear mechanism for responding to such circumstances, the policy does not adequately support the timely delivery of development across the plan period. This is essential to address, especially as the Plan does not currently seek to Plan for its full identified objectively assessed employment land need. This will result in a continued under supply and delivery, and puts the emerging Local Plan at risk of not delivering its objectives and the Government’s number one mission of economic growth.
3.5.6 Policy S/MO is not fully effective as it does not clearly link monitoring outcomes to potential corrective actions. An effective monitoring policy should allow the planning authority to respond positively where evidence demonstrates that delivery assumptions are not being met.
3.5.7 The policy is insufficiently justified in assuming that monitoring alone will ensure plan delivery, without setting out how the results of monitoring will influence future decision-making or trigger appropriate responses.
3.5.8 It is requested that Policy S/MO is modified to:
● clarify how monitoring outcomes will be used to inform decision-making during the plan period; and
● explicitly acknowledge the need for flexibility where monitoring identifies delivery risks or shortfalls.
3.5.9 This would ensure that monitoring plays an active role in supporting delivery rather than simply recording outcomes.

3.6.1 Tritax object to Policy S/SHF.
3.6.2 Policy S/SHF places a significant degree of reliance on a single strategic site to deliver up to 220,000 sqm of B2 and B8 commercial floorspace. This level of reliance presents a material risk to the soundness of the emerging Local Plan if the site is not deliverable in full or within the plan period.
3.6.3 The Bidwells B2/B8 Needs note suggest at Paragraph 28 a need for at least 424,900 sqm net additional B2/B8 floorspace; “we consider the adjustment in GVA to reflect sufficient flexibility if the figure is considered a minimum in accordance with the NPPF”. This figure is above the 317,000 sqm citied in the Iceni Report 2025.
3.6.4 The NPPF 2024 Chapter 6 sets out how the Government intends to build a strong, competitive economy. Paragraph 85 states; “Significant weight should be placed on the need to support economic growth and productivity, taking into account both local business needs and wider opportunities for development.” In addition, subsequent paragraphs provide further support for economic development, Paragraph 86 (e) requires plans to be “flexible enough to accommodate needs not anticipated in the plan, and allow for new and flexible working practices and spaces to enable a rapid response to changes in economic circumstances.”
3.6.5 Policy S/SHF responds positively to the direction of travel set out in the NPPF 2026 by recognising the specific locational requirements of the freight and logistics sector, as supported under Policies E2 and E3, this builds upon Paragraph 87 (b) of the NPPF 2024 However, at a strategic level, Tritax Park, Cambridge benefits from the same locational advantages attributed to Slate Hall Farm, including close proximity to Bar Hill and, critically, A14 Junction 25. These shared characteristics and for reasons set out in these representations (when read as a whole) demonstrate that Tritax Park, Cambridge is better positioned to meet the identified needs of the logistics and industrial market.
3.6.6 This is highlighted in Paragraphs 2.6.1 to 2.6.15 of these representations, and the supporting Transport Technical Note (Appendix 5) it highlights the convoluted route to the Slate Hall Farm access, and the difficulties attributed with the potential access points which are more likely to interfere with the local road network.
3.6.7 Slate Hall Farm (Cambridge 25) is being promoted by a private development entity. While this approach is not uncommon, there is limited publicly available evidence demonstrating a track record in delivering major industrial or logistics developments of a comparable scale elsewhere in the UK. Experience cited in support of the site relates primarily to mixed-use, city-centre schemes, which differ materially in delivery complexity, funding structures, infrastructure requirements and occupier relationships when compared with large-scale, strategic logistics and industrial parks.
3.6.8 By contrast, Tritax Park, Cambridge is promoted by a developer with a long-established and proven track record in the logistics sector. Tritax is a FTSE 250 company and the owner of the UK’s largest logistics development and investment portfolio, valued at £6.82 billion. As a long-term owner and operator, Tritax has consistently demonstrated its ability to deliver complex, large-scale logistics schemes, supported by secure funding structures and established occupier relationships.
3.6.9 The deliverability of Tritax Park, Cambridge is evidenced through part of Phase 1 being partly pre-let to a nationally recognised parcel delivery operator. This will deliver a new parcel distribution facility, supporting sustainable logistics across Greater Cambridgeshire and last mile logistics. Tritax’s occupier base across its portfolio includes DPD, Siemens Healthineers, Ocado, Marks & Spencer, Rolls Royce, GXO, Unilever, Harper Collins and Royal Mail, clearly demonstrating its understanding of occupier requirements and market demand.
3.6.10 In contrast, the proposed allocation at Slate Hall Farm places a disproportionate reliance on a site promoted by a developer without a proven delivery record for this scale and type of development.
3.6.11 As referenced in Paragraphs 2.3.1 to 2.3.6, the Council’s assessment fails to adequately recognise that Slate Hall Farm lies within the setting of the adjoining Green Belt. As such, the decision to change the site’s overall assessment score from red to amber is not fully justified or supported by robust evidence. By contrast, Tritax Park, Cambridge, is not located adjacent to the Green Belt with significant opportunities for enhancement through the proposed mitigation with this being sympathetic to the Landscape Character Area.
3.6.12 The Greater Cambridge Warehouse and Industrial Space Needs Report (Iceni, March 2025) identifies a requirement of around 317,000 sqm (3.4 million sqft) of additional warehouse and industrial floorspace over the next 15 years.
3.6.13 However, even this increased provision falls short of long-term market demand. Section 4.5.8 of the Draft Market Needs Assessment, prepared by Bidwells (and submitted previously, as part of the PPA - Appendix 10) states:
“We believe this still falls short of satisfying the demand from occupiers in the immediate and regional markets, based on long-term average annual take-up figures of 375,000 sq ft (local) and 1.5 million sq ft (regional) respectively, particularly considering that take-up in the immediate market will also have been restrained by lack of supply over the past 10 years.”
3.6.14 This persistent shortfall highlights a structural issue within plan-making: the difficulty of ensuring that allocations are not only policy compliant but also realistically deliverable in line with market demand.
3.6.15 Further concerns regarding deliverability arise from the recently submitted EIA Scoping Opinion at Slate Hall Farm (LPA Reference: 25/03511/SCOP). Policy S/SHF draft allocates 220,000 sqm of commercial floorspace across 113.3 hectares, including substantial areas of green infrastructure, particularly to the south-east (as per Figure 2 of Supporting Document). However, the EIA Scoping boundary covers only 60.32 hectares, limited to a select Central area of the allocation (as shown in Figure 3 of Supporting Document).
3.6.16 The majority of the land required to accommodate the allocated floorspace has been omitted from the EIA Scoping area. This coincides with the fact that the western proportion of the site is earmarked for latter delivery. The EIA Scoping raises questions over challenges to delivery which need to be addressed before development of the site can come forward.
3.6.17 This discrepancy raises serious concerns regarding the site’s capacity to deliver the quantum of development proposed and casts doubt on the robustness of the allocation. There is a clear risk that Slate Hall Farm may not deliver the required floorspace within the plan period, thereby undermining the Local Plan’s ability to meet identified employment needs. Furthermore, the Iceni Report makes it clear that; “a number of the market segments such as warehousing and distribution for the Greater Cambridge market as well as some expanding local manufacturers, will have shorter term requirements, suggesting bringing forward supply in the earlier part of the plan period would be beneficial.” It is therefore imperative that the Local Plan supports the short-term supply of industrial and logistics floorspace to meet an identified need at the earliest opportunity.
3.6.18 In this context, Tritax Park, Cambridge, located adjacent to the preferred allocation, represents a highly deliverable and credible alternative capable of providing essential logistics and advanced manufacturing infrastructure for Greater Cambridgeshire. It is well positioned to support the efficient movement of goods in line with evolving supply chain demands and is demonstrably aligned with the evidence base underpinning Policy S/SHF. As per Paragraph 1.2.4, Tritax Park, Cambridge also can demonstrate their deliverability through an occupier already been in place for Unit 1.
3.6.19 Tritax’s strong credentials and track record of delivery, supported by the necessary financial capital to deliver without external funding has been demonstrated by a Phase 1 which is pre let and backed by a leading occupier. Tritax are committed to bringing the Site forward at speed to meet a known need and address it at the earliest opportunity, in line with the Council’s evidence base.

3.6.1 Tritax object to Policy S/SHF.
3.6.2 Policy S/SHF places a significant degree of reliance on a single strategic site to deliver up to 220,000 sqm of B2 and B8 commercial floorspace. This level of reliance presents a material risk to the soundness of the emerging Local Plan if the site is not deliverable in full or within the plan period.
3.6.3 The Bidwells B2/B8 Needs note suggest at Paragraph 28 a need for at least 424,900 sqm net additional B2/B8 floorspace; “we consider the adjustment in GVA to reflect sufficient flexibility if the figure is considered a minimum in accordance with the NPPF”. This figure is above the 317,000 sqm citied in the Iceni Report 2025.
3.6.4 The NPPF 2024 Chapter 6 sets out how the Government intends to build a strong, competitive economy. Paragraph 85 states; “Significant weight should be placed on the need to support economic growth and productivity, taking into account both local business needs and wider opportunities for development.” In addition, subsequent paragraphs provide further support for economic development, Paragraph 86 (e) requires plans to be “flexible enough to accommodate needs not anticipated in the plan, and allow for new and flexible working practices and spaces to enable a rapid response to changes in economic circumstances.”
3.6.5 Policy S/SHF responds positively to the direction of travel set out in the NPPF 2026 by recognising the specific locational requirements of the freight and logistics sector, as supported under Policies E2 and E3, this builds upon Paragraph 87 (b) of the NPPF 2024 However, at a strategic level, Tritax Park, Cambridge benefits from the same locational advantages attributed to Slate Hall Farm, including close proximity to Bar Hill and, critically, A14 Junction 25. These shared characteristics and for reasons set out in these representations (when read as a whole) demonstrate that Tritax Park, Cambridge is better positioned to meet the identified needs of the logistics and industrial market.
3.6.6 This is highlighted in Paragraphs 2.6.1 to 2.6.15 of these representations, and the supporting Transport Technical Note (Appendix 5) it highlights the convoluted route to the Slate Hall Farm access, and the difficulties attributed with the potential access points which are more likely to interfere with the local road network.
3.6.7 Slate Hall Farm (Cambridge 25) is being promoted by a private development entity. While this approach is not uncommon, there is limited publicly available evidence demonstrating a track record in delivering major industrial or logistics developments of a comparable scale elsewhere in the UK. Experience cited in support of the site relates primarily to mixed-use, city-centre schemes, which differ materially in delivery complexity, funding structures, infrastructure requirements and occupier relationships when compared with large-scale, strategic logistics and industrial parks.
3.6.8 By contrast, Tritax Park, Cambridge is promoted by a developer with a long-established and proven track record in the logistics sector. Tritax is a FTSE 250 company and the owner of the UK’s largest logistics development and investment portfolio, valued at £6.82 billion. As a long-term owner and operator, Tritax has consistently demonstrated its ability to deliver complex, large-scale logistics schemes, supported by secure funding structures and established occupier relationships.
3.6.9 The deliverability of Tritax Park, Cambridge is evidenced through part of Phase 1 being partly pre-let to a nationally recognised parcel delivery operator. This will deliver a new parcel distribution facility, supporting sustainable logistics across Greater Cambridgeshire and last mile logistics. Tritax’s occupier base across its portfolio includes DPD, Siemens Healthineers, Ocado, Marks & Spencer, Rolls Royce, GXO, Unilever, Harper Collins and Royal Mail, clearly demonstrating its understanding of occupier requirements and market demand.
3.6.10 In contrast, the proposed allocation at Slate Hall Farm places a disproportionate reliance on a site promoted by a developer without a proven delivery record for this scale and type of development.
3.6.11 As referenced in Paragraphs 2.3.1 to 2.3.6, the Council’s assessment fails to adequately recognise that Slate Hall Farm lies within the setting of the adjoining Green Belt. As such, the decision to change the site’s overall assessment score from red to amber is not fully justified or supported by robust evidence. By contrast, Tritax Park, Cambridge, is not located adjacent to the Green Belt with significant opportunities for enhancement through the proposed mitigation with this being sympathetic to the Landscape Character Area.
3.6.12 The Greater Cambridge Warehouse and Industrial Space Needs Report (Iceni, March 2025) identifies a requirement of around 317,000 sqm (3.4 million sqft) of additional warehouse and industrial floorspace over the next 15 years.
3.6.13 However, even this increased provision falls short of long-term market demand. Section 4.5.8 of the Draft Market Needs Assessment, prepared by Bidwells (and submitted previously, as part of the PPA - Appendix 10) states:
“We believe this still falls short of satisfying the demand from occupiers in the immediate and regional markets, based on long-term average annual take-up figures of 375,000 sq ft (local) and 1.5 million sq ft (regional) respectively, particularly considering that take-up in the immediate market will also have been restrained by lack of supply over the past 10 years.”
3.6.14 This persistent shortfall highlights a structural issue within plan-making: the difficulty of ensuring that allocations are not only policy compliant but also realistically deliverable in line with market demand.
3.6.15 Further concerns regarding deliverability arise from the recently submitted EIA Scoping Opinion at Slate Hall Farm (LPA Reference: 25/03511/SCOP). Policy S/SHF draft allocates 220,000 sqm of commercial floorspace across 113.3 hectares, including substantial areas of green infrastructure, particularly to the south-east (as per Figure 2 of Supporting Document). However, the EIA Scoping boundary covers only 60.32 hectares, limited to a select Central area of the allocation (as shown in Figure 3 of Supporting Document).
3.6.16 The majority of the land required to accommodate the allocated floorspace has been omitted from the EIA Scoping area. This coincides with the fact that the western proportion of the site is earmarked for latter delivery. The EIA Scoping raises questions over challenges to delivery which need to be addressed before development of the site can come forward.
3.6.17 This discrepancy raises serious concerns regarding the site’s capacity to deliver the quantum of development proposed and casts doubt on the robustness of the allocation. There is a clear risk that Slate Hall Farm may not deliver the required floorspace within the plan period, thereby undermining the Local Plan’s ability to meet identified employment needs. Furthermore, the Iceni Report makes it clear that; “a number of the market segments such as warehousing and distribution for the Greater Cambridge market as well as some expanding local manufacturers, will have shorter term requirements, suggesting bringing forward supply in the earlier part of the plan period would be beneficial.” It is therefore imperative that the Local Plan supports the short-term supply of industrial and logistics floorspace to meet an identified need at the earliest opportunity.
3.6.18 In this context, Tritax Park, Cambridge, located adjacent to the preferred allocation, represents a highly deliverable and credible alternative capable of providing essential logistics and advanced manufacturing infrastructure for Greater Cambridgeshire. It is well positioned to support the efficient movement of goods in line with evolving supply chain demands and is demonstrably aligned with the evidence base underpinning Policy S/SHF. As per Paragraph 1.2.4, Tritax Park, Cambridge also can demonstrate their deliverability through an occupier already been in place for Unit 1.
3.6.19 Tritax’s strong credentials and track record of delivery, supported by the necessary financial capital to deliver without external funding has been demonstrated by a Phase 1 which is pre let and backed by a leading occupier. Tritax are committed to bringing the Site forward at speed to meet a known need and address it at the earliest opportunity, in line with the Council’s evidence base.

3.7.2 Tritax have concerns regarding the proposed allocation under Policy SRRA.2. While the site may offer some localised benefits, its limited scale and constrained capacity mean it is unlikely to make a meaningful contribution to meeting the identified strategic need for B2 and B8 accommodation across Greater Cambridge.
3.7.3 The allocation appears to place emphasis on addressing specific operational or ancillary requirements rather than delivering modern, large-scale industrial and logistics floorspace aligned with market demand. In this context, the site’s size, coupled with the range of policy constraints and mitigation requirements, raises questions regarding its effectiveness and deliverability, particularly when assessed against the scale of need identified in the supporting evidence base.
3.7.4 As currently drafted, the allocation risks diverting focus away from the delivery of larger, more strategic and demonstrably deliverable sites capable of addressing identified employment land requirements. The role of Policy should therefore be clearly framed as making only a limited and complementary contribution, rather than forming a material component of the Local Plan’s strategy for meeting industrial and logistics need.

3.7.6 The Buckingham Business Park allocation is an extension to the adopted South Cambridgeshire Local Plan established employment area allocation under E/15.
3.7.7 Tritax have no objection to the proposed allocation and notes that the site may make a positive, albeit limited, contribution to the overall supply of employment land within the plan area. The policy for the Buckingway Business Park is focused on B8 uses but limited to smaller premises to meet local needs. The Business Park will provide a much smaller scale of unit to meet a different need to what will be delivered at Tritax Park, Cambridge.
3.7.8 However, due to its scale and capacity, the allocation is not of sufficient size to materially address the identified need for strategic B2 and B8 accommodation set out in the supporting evidence base. As such, whilst the site may assist in meeting local or smaller-scale employment requirements, it should not be relied upon to play a significant role in meeting the wider strategic logistics and industrial demand identified for Greater Cambridge.
3.7.9 The allocation should therefore be viewed as complementary to, rather than a substitute for, larger and more deliverable strategic employment sites capable of accommodating modern logistics and industrial uses at scale.

3.8.1 Tritax supports Policy CC/SD and welcomes its clear, outcome-focused approach to sustainable development. There is however the requirement to add in wording “where appropriate” when outlining the range of issues to address to provide flexibility in the requirements for sustainability statement
3.8.2 The policy aligns closely with the ambitions for Tritax Park, Cambridge, which is being promoted as a landscape-led, low-carbon logistics and advanced manufacturing park, incorporating high-performance buildings, extensive green infrastructure, biodiversity enhancement, sustainable drainage and opportunities for renewable energy generation.
3.8.3 With the added flexibility of ‘where appropriate’, Policy CC/SD is supported, enabling site-specific solutions to climate change mitigation and adaptation while ensuring that strategic employment development can be delivered efficiently and, in a manner, consistent with Greater Cambridge’s sustainability objectives.

Tritax supports Policy CC/DC, which sets clear, design-led criteria to ensure high-quality, sustainable, and inclusive places.
The policy aligns with the vision for Tritax Park, Cambridge, where development will be guided by a landscape-led masterplan that prioritises functional site layout, well-designed buildings, active travel, green infrastructure, and connectivity.
The emphasis on good design, adaptability, and placemaking is welcomed, as it will help ensure that new strategic employment sites contribute positively to their setting, enhance user experience, and support long-term resilience. Tritax considers Policy CC/DC’s principles to be both appropriate and capable of guiding development that meets local and regional needs.