Draft Greater Cambridge Local Plan for consultation

3.20.5 Policy BG/EO should therefore be reconsidered to allow open space provision to be assessed on a case-by-case basis, adopting a flexible and proportionate approach that recognises the functional requirements of employment uses and aligns with national policy on effective land use, economic growth and plan deliverability.

3.20.1 Tritax object to the proposed wording of Policy BG/EO.
3.20.2 The policy is insufficiently flexible and does not reflect the operational and spatial requirements of employment and commercial development, including industrial and logistics uses. Such development relies on efficient building footprints, servicing yards, circulation and security arrangements, which significantly limit the scope for meaningful on-site open space provision.
3.20.3 The NPPF 2024, including the direction of travel set out in Policy L2 of the NPPF 2026, is clear that planning policies should support economic growth and make effective use of land in sustainable locations. Applying a generic open space expectation to commercial development risks constraining efficient site layouts and reducing development capacity, contrary to national policy and the Government’s stated ambition to support growth in the commercial and logistics sectors, as set out in Policies E1–E3 of the NPPF 2026.
3.20.4 Notwithstanding this objection, Tritax recognises the value of well-designed green infrastructure within employment environments. At Tritax Park, Cambridge, green infrastructure is delivered as an integral component of a successful employment park, informed by engagement highlighting the importance of wellbeing and recreation alongside employment uses. This includes the exploration of sports facilities, circular walking routes and informal recreational spaces, alongside positive integration with the Bar Hill community through shared amenities and local initiatives.
3.20.5 Policy BG/EO should therefore be reconsidered to allow open space provision to be assessed on a case-by-case basis, adopting a flexible and proportionate approach that recognises the functional requirements of employment uses and aligns with national policy on effective land use, economic growth and plan deliverability.

3.21.5 The policy should be amended to clearly distinguish between residential and commercial development, ensuring that requirements for community facilities, engagement, and ongoing management are proportionate, evidence-based, and directly related to demonstrable impacts arising from the development, consistent with national planning policy and the statutory tests for planning obligations.

3.21.1 Tritax objects to the proposed wording of Policy WS/NC.
3.21.2 While the principle of supporting sustainable communities is acknowledged, the policy is primarily framed around residential-led growth and is not suitably calibrated for large-scale commercial development.
3.21.3 In particular, the requirement for employment development over 5,000 sqm to be informed by detailed community needs assessments, stakeholder engagement strategies, and potentially community development measures are disproportionate and not justified by national policy. Such requirements risk placing unreasonable and unclear obligations on commercial schemes, whose workforce characteristics, patterns of occupation, and impacts differ fundamentally from residential development.
3.21.4 The policy also lacks clarity on the nature and scope of services and facilities expected to be delivered or funded by commercial development, creating uncertainty and viability risk. Commercial developments already make appropriate contributions through CIL and Section 106 obligations where impacts are clearly evidenced.
3.21.5 The policy should be amended to clearly distinguish between residential and commercial development, ensuring that requirements for community facilities, engagement, and ongoing management are proportionate, evidence-based, and directly related to demonstrable impacts arising from the development, consistent with national planning policy and the statutory tests for planning obligations.

3.22.1 Tritax support Policy SW/MU.
3.22.2 The policy appropriately recognises that some large-scale development proposals may remain temporarily undeveloped for extended periods of time. The application of the policy must be considered on a site-specific basis to ensure that the most appropriate strategy is pursued, which in some circumstances may be to leave land unused.

3.23.1 Tritax supports Policy WS/IO.
3.23.2 The policy appropriately recognises that successful places are shaped not only by physical development but by inclusive, healthy and socially connected environments. The policy’s emphasis on social inclusion, health and wellbeing, through accessible services, community facilities, inclusive design and connectivity, aligns with national planning policy and the Local Plan’s placemaking objectives.
3.23.3 Tritax recognises inclusive design and community wellbeing as integral to sustainable development. Tritax Park, Cambridge will seek to incorporate measures that support social interaction, accessibility and active lifestyles, helping to create healthy, resilient and socially inclusive places.

3.24.1 Tritax supports Policy WS/HS.
3.24.2 The policy recognises the importance of ensuring that new development does not result in unacceptable impacts on health, amenity or safety arising from pollution, including noise, vibration, odour, light and air emissions. The policy provides a clear and proportionate framework for addressing these matters through appropriate design, mitigation and assessment, consistent with the Local Plan’s wellbeing and social inclusion objectives.
3.24.3 By embedding protections against adverse environmental effects, Policy WS/HS helps to ensure that development supports healthy, safe and inclusive places where people can live, work and visit without exposure to harmful impacts.

3.25.1 Tritax object to the proposed wording of Policy GP/ST.
3.25.2 The NPPF 2024 does not have a policy dedicated to ‘tall buildings’. Chapter 11 focuses on making an effective use of land. Paragraph 129 considers densities and allowing planning policies and decisions support development that makes effective use of land including identified needs and market conditions. Chapter 12 considers achieving well designed places with paragraph 135 requiring planning policies and decision to ensure developments ‘will function well’. By its very nature, industrial and logistics development therefore needs to provide appropriate heights to meet the needs of a modern occupier.
3.25.3 The NPPF 2026 explicitly recognise the strategic importance of the freight and logistics sector and acknowledge that such development may require large-scale buildings due to its operational and locational characteristics (Policy E3). National policy, therefore, signals that local planning authorities must be prepared to accommodate larger structures where justified.
3.25.4 However, Policy GP/ST and its supporting evidence, including Appendix H, fail to recognise the specific requirements of freight and logistics development or the existence of established employment areas with buildings exceeding domestic scale, such as at Bar Hill. The policy is primarily focused on Cambridge’s urban skyline and applies a largely uniform, urban-led approach to all development that breaks the skyline, regardless of context. This is evident in the absence of any requirement for Landscape and Visual Impact Assessment and in the policy’s limited engagement with the diverse character of the wider Greater Cambridge area, including South Cambridgeshire. The policy recognises that:
“development in South Cambridgeshire is typically lower in density and domestic in scale, with church towers and spires rising above mature tree canopies to create visual connections between settlements”,
3.25.5 It does not adequately acknowledge that some locations, such as Bar Hill, already contain established employment areas with buildings reaching heights well beyond ‘domestic’ scale. In this context, Appendix H should consider higher thresholds for defining tall or large-scale buildings in areas adjacent to, or outside, defined development extents and within established employment locations.
3.25.6 As drafted, the policy risks unduly constraining appropriate industrial and logistics development by applying assessment criteria designed for urban landmark buildings to rural and employment locations where such an approach is disproportionate. Appendix H should, therefore, adopt higher thresholds and a more context-sensitive approach in established employment areas and locations beyond defined development extents.

3.25.1 Tritax object to the proposed wording of Policy GP/ST.
3.25.2 The NPPF 2024 does not have a policy dedicated to ‘tall buildings’. Chapter 11 focuses on making an effective use of land. Paragraph 129 considers densities and allowing planning policies and decisions support development that makes effective use of land including identified needs and market conditions. Chapter 12 considers achieving well designed places with paragraph 135 requiring planning policies and decision to ensure developments ‘will function well’. By its very nature, industrial and logistics development therefore needs to provide appropriate heights to meet the needs of a modern occupier.
3.25.3 The NPPF 2026 explicitly recognise the strategic importance of the freight and logistics sector and acknowledge that such development may require large-scale buildings due to its operational and locational characteristics (Policy E3). National policy, therefore, signals that local planning authorities must be prepared to accommodate larger structures where justified.
3.25.4 However, Policy GP/ST and its supporting evidence, including Appendix H, fail to recognise the specific requirements of freight and logistics development or the existence of established employment areas with buildings exceeding domestic scale, such as at Bar Hill. The policy is primarily focused on Cambridge’s urban skyline and applies a largely uniform, urban-led approach to all development that breaks the skyline, regardless of context. This is evident in the absence of any requirement for Landscape and Visual Impact Assessment and in the policy’s limited engagement with the diverse character of the wider Greater Cambridge area, including South Cambridgeshire. The policy recognises that:
“development in South Cambridgeshire is typically lower in density and domestic in scale, with church towers and spires rising above mature tree canopies to create visual connections between settlements”,
3.25.5 It does not adequately acknowledge that some locations, such as Bar Hill, already contain established employment areas with buildings reaching heights well beyond ‘domestic’ scale. In this context, Appendix H should consider higher thresholds for defining tall or large-scale buildings in areas adjacent to, or outside, defined development extents and within established employment locations.
3.25.6 As drafted, the policy risks unduly constraining appropriate industrial and logistics development by applying assessment criteria designed for urban landmark buildings to rural and employment locations where such an approach is disproportionate. Appendix H should, therefore, adopt higher thresholds and a more context-sensitive approach in established employment areas and locations beyond defined development extents.

3.26.1 Tritax supports Policy GP/LC.
3.26.2 The policy appropriately recognises the importance of safeguarding and enhancing landscape character and green corridors across the Greater Cambridge area. The policy’s requirement for development to respond positively to its landscape context is consistent with national planning policy objectives relating to environmental protection and landscape quality.
3.26.3 In this context, Tritax Park, Cambridge demonstrates how development can respond positively to landscape character and environmental sensitivities. The scheme integrates high-quality buildings with a strong green infrastructure framework, with at least 40% of the site retained as open green space and a minimum of 25% BNG, ensuring that landscape character and ecological value are meaningfully enhanced.
3.26.4 Slate Hall Farm lies adjacent to the Green Belt; however, the Local Plan does not currently acknowledge this relationship, nor does it provide evidence demonstrating how this sensitive boundary will be protected and enhanced in accordance with Policy GP/LC.

3.27.5 Policy GP/HE should be amended to adopt more proportionate wording that reflects this balanced approach, consistent with the NPPF 2024 and statutory duties.

3.27.1 Tritax objects to the proposed wording of Policy GP/HE.
3.27.2 Part 2(b) is overly prescriptive and not fully consistent with national policy or the statutory framework for decision-making in the historic environment. The use of the word “must” risks precluding high-quality, sustainable development by implying an absolute requirement to conserve or enhance heritage assets in all circumstances, rather than allowing for a balanced planning judgement.
3.27.3 National policy and legislation require decision-makers to have special regard to the desirability of preserving heritage assets, while weighing this against the scale of harm, site context and public benefits.
3.27.4 The direction of travel set in the NPPF 2026, Policy H1 “retains the expectation that local planning authorities prepare a positive strategy for the historic environment, while providing clearer guidance on the factors that should inform this strategy and how these can align with wider planning objectives”.
3.27.5 Policy GP/HE should be amended to adopt more proportionate wording that reflects this balanced approach, consistent with the NPPF 2024 and statutory duties.

3.28.7 Policy GP/HA should therefore be amended to adopt more proportionate wording that reflects the statutory duties and the NPPF 2024’s balanced approach, allowing impacts on heritage significance to be assessed in the round, taking account of scale, context and public benefits.

3.28.1 Tritax objects to the proposed wording of Policy GP/HA.
3.28.2 As drafted, the policy does not allow for any harm to designated heritage assets and fails to reflect the balancing exercise required by both national policy and legislation.
3.28.3 Sections 66 and 72 of the Planning (Listed Buildings and Conservation Areas) Act 1990 require decision-makers to have special regard to the desirability of preserving the setting of listed buildings and to pay special attention to preserving or enhancing the character or appearance of conservation areas. These statutory duties do not impose an absolute prohibition on harm but instead require any harm to be clearly identified and weighed in the planning balance.
3.28.4 The NPPF 2024 allows for harm to designated heritage assets where this is justified and outweighed by public benefits, following a structured assessment of heritage significance, the extent of harm and the justification for the proposal. Policy GP/HA does not reflect this approach and is therefore inconsistent with national policy and the statutory framework.
3.28.5 Policy HE5 of the NPPF 2026 also highlights the governments direction of travel and acknowledges there may be harm to assets; “it introduces clearer guidance on the full range of potential impacts on these assets - from positive effects to total loss of significance - recognising that development can improve heritage outcomes”
3.28.6 The use of mandatory language in Part 2 of the policy, particularly the requirement that proposals “must” meet the stated criteria, overstates the statutory and policy tests and removes necessary scope for professional judgement and balanced decision-making. Furthermore, criteria 2(b) to 2(d) adopt a highly restrictive approach by requiring development to be of an “appropriate” scale, form, height and massing. When applied to development of a different typology or scale, such as strategic or employment development, these criteria risk precluding otherwise acceptable schemes regardless of wider public benefits. This conflicts with the NPPF 2026, including Policy E3, which recognises that logistics development may involve particularly large structures.
3.28.7 Policy GP/HA should therefore be amended to adopt more proportionate wording that reflects the statutory duties and the NPPF 2024’s balanced approach, allowing impacts on heritage significance to be assessed in the round, taking account of scale, context and public benefits.

3.29.4 Policy GP/ND should be amended to reflect the NPPF 2024’s proportionate approach and allow impacts to be assessed through balanced decision-making.

Tritax objects to the proposed wording of Policy GP/NP.
The policy goes beyond national planning policy by seeking to “ensure the retention and enhancement” of non-designated heritage assets. The NPPF 2024 does not require retention in all circumstances, but instead requires a balanced judgement, having regard to the significance of the asset and the scale of any harm or loss. The proposed wording removes this necessary flexibility and risks precluding appropriate development regardless of context or public benefits.
The NPPF 2026 Policy HE7 considers decisions on non-designated heritage assets and aims to clarify how proposals affecting non-designated heritage assets should be assessed.
Policy GP/ND should be amended to reflect the NPPF 2024’s proportionate approach and allow impacts to be assessed through balanced decision-making.