Draft Greater Cambridge Local Plan for consultation

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.

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.

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

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.