Draft Greater Cambridge Local Plan for consultation

Search representations

Results for Tritax Big Box Developments search

New search New search

Object

Draft Greater Cambridge Local Plan for consultation

Policy CC/NZ: Net zero carbon new buildings

Representation ID: 204314

Received: 30/01/2026

Respondent: Tritax Big Box Developments

Agent: Bidwells LLP

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Representation Summary:

The respondent objects to the wording of Policy CC/NZ, arguing that requiring net zero operational emissions at the shell and core stage is impractical without knowledge of future end users and operational profiles.

The respondent believes that such requirements could deter occupier delivery or investment due to the impractical obligations imposed.

Concerns are raised regarding the reliance on CIBSE TM54 modelling, which overlaps with existing energy performance assessments in BREEAM requirements, potentially reducing certainty without providing significant environmental benefits.

The respondent advocates for a proportionate, evidence-based approach that considers realistic delivery stages and aligns with existing standards.

Change suggested by respondent:

3.10.1 Tritax object to the proposed wording of Policy CC/NZ.
3.10.2 Although Tritax Park, Cambridge has a named occupier for Phase 1, requiring net zero operational emissions at the shell and core stage is not appropriate where the future end user and operational profile are not yet known. Such a requirement risks imposing impractical obligations and may deter occupier delivery or investment.
3.10.3 Likewise, the reliance on CIBSE TM54 modelling, which is MEP-led, overlaps with energy performance assessments already embedded within Excellent/Outstanding BREEAM requirements under Ene 01. This duplication may reduce certainty without adding meaningful environmental benefit. Tritax encourages a proportionate, evidence-based approach that reflects realistic delivery stages and aligns with existing standards.

Full text:

Tritax object to the proposed wording of Policy CC/NZ.
Although Tritax Park, Cambridge has a named occupier for Phase 1, requiring net zero operational emissions at the shell and core stage is not appropriate where the future end user and operational profile are not yet known. Such a requirement risks imposing impractical obligations and may deter occupier delivery or investment.
Likewise, the reliance on CIBSE TM54 modelling, which is MEP-led, overlaps with energy performance assessments already embedded within Excellent/Outstanding BREEAM requirements under Ene 01. This duplication may reduce certainty without adding meaningful environmental benefit. Tritax encourages a proportionate, evidence-based approach that reflects realistic delivery stages and aligns with existing standards.

Object

Draft Greater Cambridge Local Plan for consultation

Policy CC/WE: Water efficiency in new developments

Representation ID: 204327

Received: 30/01/2026

Respondent: Tritax Big Box Developments

Agent: Bidwells LLP

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Representation Summary:

The respondent objects to the wording of Policy CC/WE, stating it exceeds national and industry guidance.

They reference recent case law indicating that local planning authorities should not deviate from national policy without robust evidence.

The respondent argues that mandating rainwater or greywater harvesting on all major developments does not consider site-specific operational requirements and viability.

They highlight that national policy advocates for context-led approaches to water efficiency, suggesting the need for flexibility in Policy CC/WE.

The respondent recommends amending Policy CC/WE to include achievable performance standards and alternative measures where necessary.

Change suggested by respondent:

Tritax therefore urges that Policy CC/WE be amended to allow flexibility, achievable performance standards, and alternative measures where such systems are unsuitable.

Full text:

3.11.1 Tritax objects to the proposed wording of Policy CC/WE.
3.11.2 The policy goes beyond national and industry guidance. Recent case law confirms that, while local planning authorities may depart from national policy or guidance where this is justified by local circumstances, such departure is not expected as a matter of course and cannot be assumed to be appropriate in the absence of robust evidence. In R (Rights: Community: Action Ltd) v Secretary of State 2025, the Court of Appeal confirmed that the NPPF 2024 and Written Ministerial Statements constitute guidance rather than binding law, but made clear that any policy divergence must be underpinned by a clear and proportionate rationale, supported by demonstrable evidence of viability. Where this threshold is not met, the imposition of requirements exceeding national policy risks inconsistency, reduced policy certainty and adverse impacts on deliverability.
3.11.3 By effectively mandating rainwater or greywater harvesting on all major developments, the policy does not consider what may be appropriate or deliverable. This is particularly the case for strategic logistics and industrial sites, where such systems may conflict with operational requirements, site constraints, or viability. National policy promotes proportionate, context-led approaches to water efficiency.
3.11.4 Tritax therefore urges that Policy CC/WE be amended to allow flexibility, achievable performance standards, and alternative measures where such systems are unsuitable.

Object

Draft Greater Cambridge Local Plan for consultation

Policy CC/IW: Integrated water management, sustainable drainage and water quality

Representation ID: 204333

Received: 30/01/2026

Respondent: Tritax Big Box Developments

Agent: Bidwells LLP

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Representation Summary:

Tritax objects to the proposed wording of Policy CC/IW.
The policy places unduly prescriptive requirements on strategic employment sites, including expectations for rainwater and greywater harvesting that may not be appropriate or deliverable in all circumstances.
For large-scale logistics and industrial developments such as Tritax Park, Cambridge, the feasibility of integrated water reuse technologies should be assessed on a site-specific basis, having regard to operational requirements, building use, viability, and infrastructure constraints.
The policy should adopt a flexible, performance-led approach, allowing alternative or equivalent measures to achieve water efficiency and resilience without mandating specific technologies where these are unsuitable.

Change suggested by respondent:

The policy should adopt a flexible, performance-led approach, allowing alternative or equivalent measures to achieve water efficiency and resilience without mandating specific technologies where these are unsuitable.

Full text:

Tritax objects to the proposed wording of Policy CC/IW.
The policy places unduly prescriptive requirements on strategic employment sites, including expectations for rainwater and greywater harvesting that may not be appropriate or deliverable in all circumstances.
For large-scale logistics and industrial developments such as Tritax Park, Cambridge, the feasibility of integrated water reuse technologies should be assessed on a site-specific basis, having regard to operational requirements, building use, viability, and infrastructure constraints.
The policy should adopt a flexible, performance-led approach, allowing alternative or equivalent measures to achieve water efficiency and resilience without mandating specific technologies where these are unsuitable.

Support

Draft Greater Cambridge Local Plan for consultation

Policy CC/FM: Managing flood risk

Representation ID: 204335

Received: 30/01/2026

Respondent: Tritax Big Box Developments

Agent: Bidwells LLP

Representation Summary:

3.13.1 Tritax supports Policy CC/FM.
3.13.2 Tritax Park, Cambridge will be designed to manage surface water and fluvial flood risk through integrated Sustainable Drainage Systems (SuDS), appropriate modelling, and mitigation measures.
3.13.3 We welcome the policy’s emphasis on demonstrating that flood risk can be safely managed throughout the lifetime of development. A Flood Risk Assessment will be developed in line with national policy.

Full text:

3.13.1 Tritax supports Policy CC/FM.
3.13.2 Tritax Park, Cambridge will be designed to manage surface water and fluvial flood risk through integrated Sustainable Drainage Systems (SuDS), appropriate modelling, and mitigation measures.
3.13.3 We welcome the policy’s emphasis on demonstrating that flood risk can be safely managed throughout the lifetime of development. A Flood Risk Assessment will be developed in line with national policy.

Object

Draft Greater Cambridge Local Plan for consultation

Policy CC/CE: Supporting a circular economy and sustainable resource use

Representation ID: 204344

Received: 30/01/2026

Respondent: Tritax Big Box Developments

Agent: Bidwells LLP

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Representation Summary:

3.14.1 Tritax objects to the proposed wording of Policy CC/CE.
3.14.2 While Tritax supports the policy’s objectives and the promotion of circular economy principles, these are already embedded within Tritax’s standard development approach, with embodied carbon routinely assessed through scheme design and delivery.
3.14.3 The requirement for a standalone Circular Economy Statement goes beyond current industry guidance and best practice, risking unnecessary duplication with existing assessments and reporting frameworks. A more proportionate and flexible approach is required, allowing applicants to demonstrate compliance through established sustainability and carbon reporting processes.

Change suggested by respondent:

3.14.1 Tritax objects to the proposed wording of Policy CC/CE.
3.14.2 While Tritax supports the policy’s objectives and the promotion of circular economy principles, these are already embedded within Tritax’s standard development approach, with embodied carbon routinely assessed through scheme design and delivery.
3.14.3 The requirement for a standalone Circular Economy Statement goes beyond current industry guidance and best practice, risking unnecessary duplication with existing assessments and reporting frameworks. A more proportionate and flexible approach is required, allowing applicants to demonstrate compliance through established sustainability and carbon reporting processes.

Full text:

3.14.1 Tritax objects to the proposed wording of Policy CC/CE.
3.14.2 While Tritax supports the policy’s objectives and the promotion of circular economy principles, these are already embedded within Tritax’s standard development approach, with embodied carbon routinely assessed through scheme design and delivery.
3.14.3 The requirement for a standalone Circular Economy Statement goes beyond current industry guidance and best practice, risking unnecessary duplication with existing assessments and reporting frameworks. A more proportionate and flexible approach is required, allowing applicants to demonstrate compliance through established sustainability and carbon reporting processes.

Object

Draft Greater Cambridge Local Plan for consultation

Policy CC/CS: Supporting land-based carbon sequestration and carbon sinks

Representation ID: 204357

Received: 30/01/2026

Respondent: Tritax Big Box Developments

Agent: Bidwells LLP

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Representation Summary:

The respondent supports the principle of enhancing land-based carbon sequestration and green infrastructure but raises concerns that Policy CC/CS exceeds industry guidance and established practice.

The policy reads as an extension to the Biodiversity Net Gain process rather than clearly defining requirements for carbon sequestration.

The respondent suggests that opportunities for carbon sequestration should be proportionate, evidence-based, and appropriate to the site's scale and nature, considering landscape and ecological practices.

There is uncertainty regarding how schemes will demonstrate a 'meaningful' level of carbon sequestration alongside significant BNG.

Policy CC/CS should allow flexibility for outcomes to align with established guidance rather than imposing prescriptive expectations that exceed standards.

Change suggested by respondent:

3.15.1 Tritax raise concern over the proposed wording of Policy CC/CS.
3.15.2 While the principle of enhancing land-based carbon sequestration and green infrastructure is supported, aspects go above and beyond industry guidance and established practice. The policy reads as an extension of the Biodiversity Net Gain (hereafter referred to as ‘BNG’) process, rather than a clearly defined requirement.
3.15.3 Opportunities for land-based carbon sequestration should be proportionate, evidence based and appropriate to the scale and nature of the site, reflecting landscape, ecological and design practice. It is unclear how schemes would be expected to demonstrate a ‘meaningful’ level of carbon sequestration alongside significant BNG.
3.15.4 Policy CC/CS should provide sufficient flexibility to allow outcomes to be delivered through measures aligned with established guidance, rather than imposing prescriptive expectations that exceed standards.

Full text:

Tritax raise concern over the proposed wording of Policy CC/CS.
While the principle of enhancing land-based carbon sequestration and green infrastructure is supported, aspects go above and beyond industry guidance and established practice. The policy reads as an extension of the Biodiversity Net Gain (hereafter referred to as ‘BNG’) process, rather than a clearly defined requirement.
Opportunities for land-based carbon sequestration should be proportionate, evidence based and appropriate to the scale and nature of the site, reflecting landscape, ecological and design practice. It is unclear how schemes would be expected to demonstrate a ‘meaningful’ level of carbon sequestration alongside significant BNG.
Policy CC/CS should provide sufficient flexibility to allow outcomes to be delivered through measures aligned with established guidance, rather than imposing prescriptive expectations that exceed standards.

Object

Draft Greater Cambridge Local Plan for consultation

Policy BG/BG: Biodiversity and geodiversity

Representation ID: 204374

Received: 30/01/2026

Respondent: Tritax Big Box Developments

Agent: Bidwells LLP

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Representation Summary:

The respondent objects to the proposed wording of Policy BG/BG.

The requirement to uplift the mandatory minimum to 20% BNG for major development is deemed unsound, lacking adequate justification and consistency with national policy.

Recent case law indicates that local planning authorities must provide robust evidence for any departure from national policy, which is not met by the proposed BNG uplift.

The national BNG framework requires that any local requirement exceeding the statutory minimum be justified, flexible, and based on site-specific ecological capacity and viability.

The respondent's development at Tritax Park, Cambridge, aims for at least 25% BNG and should be viewed as a significant planning benefit rather than a strict policy requirement.

Policy BG/BG may undermine policy certainty by imposing a fixed uplift beyond the national framework without sufficient justification, suggesting that any BNG above the 10% requirement should be considered a material benefit.

Change suggested by respondent:

3.16.1 Tritax object to the proposed wording of Policy BG/BG.
3.16.2 The proposed requirement to uplift the mandatory minimum to 20% BNG for major development is considered unsound, as it is not adequately justified and is inconsistent with national policy.
3.16.3 Recent case law confirms that, while local planning authorities may depart from national policy or guidance where this is justified by local circumstances, such departure is not expected as a matter of course and cannot be assumed to be appropriate in the absence of robust evidence. In R (Rights: Community: Action Ltd) v Secretary of State [2025], the Court of Appeal confirmed that the NPPF and Written Ministerial Statements constitute guidance rather than binding law, but made clear that any policy divergence must be underpinned by a clear and proportionate rationale, supported by demonstrable evidence of viability. Where this threshold is not met, the imposition of requirements exceeding national policy risks inconsistency, reduced policy certainty and adverse impacts on deliverability. The BNG uplift is not supported by a robust evidence base and does not sufficiently demonstrate that it is proportionate or deliverable across all sites.
3.16.4 The national BNG framework provides clarity and certainty for plan-making and decision-taking. Any local requirement exceeding the statutory minimum must therefore be clearly justified, flexible, and grounded in site-specific ecological capacity and viability.
3.16.5 Tritax Park, Cambridge will be delivered through a landscape-led masterplan, with at least 40% of the site retained as green and open space and a target of no less than 25% BNG, demonstrating a strong commitment to biodiversity enhancement. This should be considered as a substantial planning benefit in the balance, rather than a fixed policy requirement.
3.16.6 Policy BG/BG risks undermining policy certainty by imposing a fixed uplift beyond the national framework without adequate justification. Any BNG delivered above the mandatory 10% requirement should be treated as a material benefit in the planning balance, rather than a fixed policy requirement.

Full text:

3.16.1 Tritax object to the proposed wording of Policy BG/BG.
3.16.2 The proposed requirement to uplift the mandatory minimum to 20% BNG for major development is considered unsound, as it is not adequately justified and is inconsistent with national policy.
3.16.3 Recent case law confirms that, while local planning authorities may depart from national policy or guidance where this is justified by local circumstances, such departure is not expected as a matter of course and cannot be assumed to be appropriate in the absence of robust evidence. In R (Rights: Community: Action Ltd) v Secretary of State [2025], the Court of Appeal confirmed that the NPPF and Written Ministerial Statements constitute guidance rather than binding law, but made clear that any policy divergence must be underpinned by a clear and proportionate rationale, supported by demonstrable evidence of viability. Where this threshold is not met, the imposition of requirements exceeding national policy risks inconsistency, reduced policy certainty and adverse impacts on deliverability. The BNG uplift is not supported by a robust evidence base and does not sufficiently demonstrate that it is proportionate or deliverable across all sites.
3.16.4 The national BNG framework provides clarity and certainty for plan-making and decision-taking. Any local requirement exceeding the statutory minimum must therefore be clearly justified, flexible, and grounded in site-specific ecological capacity and viability.
3.16.5 Tritax Park, Cambridge will be delivered through a landscape-led masterplan, with at least 40% of the site retained as green and open space and a target of no less than 25% BNG, demonstrating a strong commitment to biodiversity enhancement. This should be considered as a substantial planning benefit in the balance, rather than a fixed policy requirement.
3.16.6 Policy BG/BG risks undermining policy certainty by imposing a fixed uplift beyond the national framework without adequate justification. Any BNG delivered above the mandatory 10% requirement should be treated as a material benefit in the planning balance, rather than a fixed policy requirement.

Support

Draft Greater Cambridge Local Plan for consultation

Policy BG/GI: Green and blue infrastructure

Representation ID: 204382

Received: 30/01/2026

Respondent: Tritax Big Box Developments

Agent: Bidwells LLP

Representation Summary:

3.17.1 Tritax support Policy BG/GI.
3.17.2 The policy appropriately recognises the importance of protecting, enhancing and integrating green and blue infrastructure networks within new development. The policy’s requirement for development to protect and enhance existing green infrastructure and provide multifunctional, connected and resilient green and blue spaces is consistent with evidence that green infrastructure delivers significant environmental, social and ecological benefits, including biodiversity enhancement, climate adaptation, water management and access to nature for local communities.

Full text:

3.17.1 Tritax support Policy BG/GI.
3.17.2 The policy appropriately recognises the importance of protecting, enhancing and integrating green and blue infrastructure networks within new development. The policy’s requirement for development to protect and enhance existing green infrastructure and provide multifunctional, connected and resilient green and blue spaces is consistent with evidence that green infrastructure delivers significant environmental, social and ecological benefits, including biodiversity enhancement, climate adaptation, water management and access to nature for local communities.

Object

Draft Greater Cambridge Local Plan for consultation

Policy BG/TC: Improving tree canopy cover and the tree population

Representation ID: 204392

Received: 30/01/2026

Respondent: Tritax Big Box Developments

Agent: Bidwells LLP

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Representation Summary:

The respondent strongly objects to the wording of Policy BG/TC, arguing it duplicates the existing 10% BNG requirement without justification.

They assert that the proposed tree canopy requirement could undermine planning flexibility and contradicts national policies promoting effective land use and densification.

The lack of clarity regarding the Council-approved calculator or methodology for calculating canopy cover is highlighted as a significant issue.

The respondent believes the policy imposes an unreasonable burden on developments, conflicting with local plans and government growth ambitions.

Change suggested by respondent:

3.18.1 Tritax strongly objects to the proposed wording of Policy BG/TC.
3.18.2 The statutory requirement to deliver a minimum 10% BNG already provides a robust, outcome-based mechanism for securing ecological enhancement. This framework is flexible, evidence-led and capable of responding to site-specific circumstances. The proposed tree canopy requirement appears to duplicate or cut across the BNG regime, without sufficient justification, and risks prioritising a single ecological metric over a balanced planning judgement.
3.18.3 Chapter 11 of the NPPF 2024 is clear that planning policies should promote the effective use of land in meeting the need for homes and other uses, particularly in sustainable locations. The need for making an effective use of land is further strengthened through the direction of travel set out in L2 of the NPPF 2026, supporting densification. The requirement for major development to demonstrate a minimum of 30% tree canopy cover on site risks introducing an inflexible and prescriptive constraint that could undermine development capacity, density and viability. As such, it is not aligned with national planning policy or with the Government’s stated ambition for growth.
3.18.4 The policy and supporting text state that canopy cover should be calculated using a Council-approved calculator or metric. However, neither the policy itself nor the Biodiversity and Green Spaces Topic Paper identifies what calculator or methodology is intended to be used. In the absence of a defined and agreed approach, the policy lacks clarity and certainty.
3.18.5 The policy places an unreasonable and unevidenced burden of developments and will act contrary to the Local Plans and Governments growth ambitions.

Full text:

3.18.1 Tritax strongly objects to the proposed wording of Policy BG/TC.
3.18.2 The statutory requirement to deliver a minimum 10% BNG already provides a robust, outcome-based mechanism for securing ecological enhancement. This framework is flexible, evidence-led and capable of responding to site-specific circumstances. The proposed tree canopy requirement appears to duplicate or cut across the BNG regime, without sufficient justification, and risks prioritising a single ecological metric over a balanced planning judgement.
3.18.3 Chapter 11 of the NPPF 2024 is clear that planning policies should promote the effective use of land in meeting the need for homes and other uses, particularly in sustainable locations. The need for making an effective use of land is further strengthened through the direction of travel set out in L2 of the NPPF 2026, supporting densification. The requirement for major development to demonstrate a minimum of 30% tree canopy cover on site risks introducing an inflexible and prescriptive constraint that could undermine development capacity, density and viability. As such, it is not aligned with national planning policy or with the Government’s stated ambition for growth.
3.18.4 The policy and supporting text state that canopy cover should be calculated using a Council-approved calculator or metric. However, neither the policy itself nor the Biodiversity and Green Spaces Topic Paper identifies what calculator or methodology is intended to be used. In the absence of a defined and agreed approach, the policy lacks clarity and certainty.
3.18.5 The policy places an unreasonable and unevidenced burden of developments and will act contrary to the Local Plans and Governments growth ambitions.

Object

Draft Greater Cambridge Local Plan for consultation

Policy BG/RC: River corridors

Representation ID: 204405

Received: 30/01/2026

Respondent: Tritax Big Box Developments

Agent: Bidwells LLP

Legally compliant? No

Sound? No

Duty to co-operate? Yes

Representation Summary:

The respondent objects to the proposed wording of Policy BG/RC, stating it adopts a restrictive approach that undermines effective land use, contrary to NPPF 2024 Chapter 11 and NPPF 2026 L2.

The blanket requirement for riparian buffer zones of 15m from riverbanks and 10m from ditch bank tops could sterilise significant areas of land, especially in rural and edge-of-settlement sites.

Relying on definitions from the BNG framework risks equating minor or engineered land drains with natural watercourses, imposing fixed buffer requirements regardless of ecological function.

This approach lacks proportionality and may reduce developable area, constrain site layouts, and undermine development capacity, conflicting with national policy objectives.

The respondent recommends amending Policy BG/RC to adopt a more flexible, site-specific approach that differentiates between natural watercourses and engineered land drains.

Change suggested by respondent:

3.19.6 Policy BG/RC should therefore be amended to adopt a more flexible, allowing for a site specific approach that distinguishes between natural watercourses and engineered land drains.

Full text:

Tritax object to proposed wording of Policy BG/RC.
The policy adopts a restrictive approach that risks undermining the effective use of land, contrary to the NPPF 2024 Chapter 11 and the direction of travel in the NPPF 2026 L2 towards efficient land use of land in sustainable locations.
The blanket requirement to retain or reinstate riparian buffer zones of at least 15m from riverbanks and 10m from ditch bank tops risks sterilising significant areas of land, particularly on rural and edge-of-settlement sites where land drains and engineered drainage features are common.
By relying on River/Ditch definitions derived from the BNG framework, the policy risks treating minor or engineered land drains as equivalent to natural watercourses, triggering fixed buffer requirements regardless of ecological function or sensitivity.
This approach lacks proportionality and could significantly reduce developable area, constrain site layouts and undermine development capacity, contrary to national policy objectives on effective land use.
Policy BG/RC should therefore be amended to adopt a more flexible, allowing for a site-specific approach that distinguishes between natural watercourses and engineered land drains.

For instructions on how to use the system and make comments, please see our help guide.