Draft Greater Cambridge Local Plan for consultation

Tritax support the proposed wording of Policy GP/AR.
Tritax Park, Cambridge is recognised as having the potential to contain archaeological remains. Further assessment and investigation would be undertaken at the appropriate stage to establish the nature, extent and significance of any assets present, in consultation with the relevant archaeological advisors. The emerging approach would seek, where feasible, to preserve archaeological remain in situ through sensitive design.
Where preservation in situ is not possible, appropriate mitigation would be secured though investigation, recording and reporting, proportionate to the significance of the remains in accordance with national and local policy. This approach would ensure the archaeological considerations are satisfactorily embedded within the development, allowing the site to come forward in a manner that appropriately balances heritage protection with the delivery of sustainable development.

3.31.11 It is requested that Policy J/NE is modified to adopt a more proportionate and flexible approach, explicitly recognising the distinct characteristics of industrial and logistics development. This should allow proposals in rural and edge-of-settlement locations to be assessed on their individual merits where they can demonstrate sustainability, suitable access and appropriately managed impacts. Such an approach would better align the policy with national guidance, the Local Plan evidence base, and the clear findings of recent appeal decisions.

3.31.1 Tritax object to the proposed wording of Policy J/NE.
3.31.2 The policy is overly prescriptive and risks unduly restricting the delivery of large-scale industrial and logistics development serving national and regional needs. In particular, Part 7 imposes disproportionate constraints on warehousing and distribution uses, limiting the Plan’s ability to respond effectively to changing economic and employment requirements.
3.31.3 The NPPF 2024 sets out in Chapter 6 how the Government wants to build a strong, competitive economy. Paragraph 85 makes it clear; “planning policies and decisions should help create the conditions in which businesses can invest, expand and adapt. Significant weight should be places on the need to support economic growth and productivity, taking into account both local business needs and wider opportunities for development.” Paragraph 86 (e) highlights planning policies should be; “flexible enough to accommodate needs not anticipated in the plan.... to enable rapid responses to changes in economic circumstances.”
3.31.4 The NPPF 2024 goes further in Paragraph 87 to confirm planning policies and decisions should recognise and address the specific locational requirements of different sectors. Part (b) of the paragraph deals specifically with making provision for “storage and distribution uses at a variety of scales in suitably accessible locations that allow for the efficient and reliable handling of goods.”
3.31.5 As set out in the accompanying ‘Need for B2/B8 in Greater Cambridge note prepared by Bidwells (January 2026); “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.”
3.31.6 This approach is inconsistent with the direction of travel in the NPPF 2026. Paragraph E1 emphasises that plans supporting long-term economic growth should avoid overly prescriptive requirements on acceptable uses and instead enable flexibility to respond to evolving commercial property demands. Paragraph E3 further recognises the particular physical and locational characteristics of freight and logistics development, including the need for access to strategic transport infrastructure and, in some cases, larger buildings. Policy J/NE does not sufficiently reflect this national policy context.
3.31.7 Recent Appeal Decisions reinforce the importance of flexibility and choice within employment land markets. In the Beehive Call In decision (PINS Reference: 3360616), the Inspector emphasised that maintaining an adequate and diverse supply of employment land is critical to keeping the market fluid, accelerating delivery, and reducing the risk of investment being lost overseas. The decision makes clear that quantitative targets, including those in the Iceni analysis The Greater Cambridge Growth Sectors Study (September 2024), should be treated as reference points rather than caps, and that a diversity of site types, locations and offers is essential to meeting demand and maximising job creation.
3.31.8 The policy creates a disproportionate bar for industrial and logistics development, which typically requires larger plots, specific access arrangements and locations beyond tightly constrained settlement boundaries.
3.31.9 The policy therefore risks excluding sustainable employment proposals that would meet identified economic needs and contribute to a diverse and resilient supply of employment land, contrary to national policy and recent appeal findings. It is not fully effective, as it may prevent appropriate industrial and logistics schemes from coming forward simply because they cannot satisfy the policy requirements, despite being sustainable in principle.
3.31.10 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.
3.31.11 It is requested that Policy J/NE is modified to adopt a more proportionate and flexible approach, explicitly recognising the distinct characteristics of industrial and logistics development. This should allow proposals in rural and edge-of-settlement locations to be assessed on their individual merits where they can demonstrate sustainability, suitable access and appropriately managed impacts. Such an approach would better align the policy with national guidance, the Local Plan evidence base, and the clear findings of recent appeal decisions.

3.32.4 As drafted, the policy effectively introduces an agricultural land sequential test, similar to that applied in flood risk policy. This approach is not supported by national guidance and places a disproportionate evidential burden on applicants. The policy should therefore be amended to align with national policy.

3.32.1 Tritax object to the proposed wording of Policy J/AL.
3.32.2 The current wording of criterion (1)(b) places an unduly onerous and potentially unrealistic burden on land promoters and landowners, particularly where sites contain Grade 1, 2 or 3a agricultural land.
3.32.3 While the policy appropriately reflects the principle that the irreversible loss of high-quality agricultural land should be avoided where possible, the requirement to demonstrate that “the development cannot be located on areas of poorer quality land” is overly prescriptive. This goes beyond national policy, which states at Footnote 65 of the NPPF 2024 that, where significant development of agricultural land is necessary, areas of poorer quality land should be preferred, rather than requiring proof that no alternative location exists.
3.32.4 As drafted, the policy effectively introduces an agricultural land sequential test, similar to that applied in flood risk policy. This approach is not supported by national guidance and places a disproportionate evidential burden on applicants. The policy should therefore be amended to align with national policy.
3.32.5 Land in the Greater Cambridge area is subject to significant development pressure, and lower-grade agricultural land may not be available, deliverable or sustainable due to ownership constraints, infrastructure capacity, access limitations, environmental designations or competing development needs. In this context, the policy risks preventing sustainable, plan-led development regardless of wider benefits. This is inconsistent with national policy, which requires impacts on agricultural land to be balanced against wider sustainability and development objectives through the planning balance.

3.33.1 Tritax objects to the proposed wording of Policy J/AW.
3.33.2 In its current form, it is not possible to provide comprehensive comments on the policy wording. The Council acknowledges they are still refining the nature and scale of the employment floorspace the policy will apply to, the affordable workspace percentage and the level of discounts.
3.33.3 The Councils supporting evidence base, Topic Paper 6, uses London as a benchmark for affordable workspace provision. London provides a very contextually different market in respect to both economic conditions / land values and the scale of units that may be delivered.
3.33.4 Tritax Park, Cambridge will comprise large B8 sheds and providing an affordable provision on the Site is not considered to be appropriate or feasible. It will conflict with national priorities for making an effective use of land and Tritax Park is not likely to be seen as an appropriate location for start ups, the focus of an affordable workspace policy.
3.33.5 Further clarity is needed on the types of development which will trigger Policy J/AW. Large strategic logistic developments are not considered suitable to provide smaller, affordable units as part of the overall development.
3.33.6 Large-format employment and logistics developments are typically designed for single occupiers and are not compatible with subdivided, small-scale units. Requiring on-site affordable workspace in such circumstances risks constraining efficient site layout and undermining economic viability.
3.33.7 The need for, and form of, affordable workspace provision should therefore be considered on a case-by-case basis, informed by site characteristics, intended occupiers, operational requirements and local evidence of demand, with flexibility to allow alternative approaches where on-site provision would be impractical or ineffective.

3.33.1 Tritax objects to the proposed wording of Policy J/AW.
3.33.2 In its current form, it is not possible to provide comprehensive comments on the policy wording. The Council acknowledges they are still refining the nature and scale of the employment floorspace the policy will apply to, the affordable workspace percentage and the level of discounts.
3.33.3 The Councils supporting evidence base, Topic Paper 6, uses London as a benchmark for affordable workspace provision. London provides a very contextually different market in respect to both economic conditions / land values and the scale of units that may be delivered.
3.33.4 Tritax Park, Cambridge will comprise large B8 sheds and providing an affordable provision on the Site is not considered to be appropriate or feasible. It will conflict with national priorities for making an effective use of land and Tritax Park is not likely to be seen as an appropriate location for start ups, the focus of an affordable workspace policy.
3.33.5 Further clarity is needed on the types of development which will trigger Policy J/AW. Large strategic logistic developments are not considered suitable to provide smaller, affordable units as part of the overall development.
3.33.6 Large-format employment and logistics developments are typically designed for single occupiers and are not compatible with subdivided, small-scale units. Requiring on-site affordable workspace in such circumstances risks constraining efficient site layout and undermining economic viability.
3.33.7 The need for, and form of, affordable workspace provision should therefore be considered on a case-by-case basis, informed by site characteristics, intended occupiers, operational requirements and local evidence of demand, with flexibility to allow alternative approaches where on-site provision would be impractical or ineffective.

3.34.1 Tritax support policy J/EP.
3.34.2 Tritax recognise the benefits delivered through meaningful facilities on employment parks.
3.34.3 As part of the public consultation, feedback was gathered on the types of facilities the community would like to see. Tritax Park, Cambridge will provide facilities for employees, visitors and local residents, provisionally including sports facilities and circular walking routes to promote recreation and wellbeing.

3.35.1 Tritax object to the proposed wording of Policy I/ST.
3.35.2 The NPPF 2024 Chapter 9 seeks to promote sustainable transports with paragraph 110 stating; “significant development should be focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes.” Further details are set out in Paragraphs 115 – 117 highlighting how authorities should consider development proposals ensuring sustainable transport modes are prioritised taking account of the vision for the site, the type of development and its location. Chapter 6 seeks to build a strong competitive economy with Paragraph 86 (b) highlighting planning policies and decisions should make 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,”
3.35.3 The direction of travel set out in the NPPF 2026 provides important clarity that the Government recognises the specific locational and operational requirements of freight and logistics development. Proposed Policy E3 (Freight and Logistics) confirms that a sector-specific approach is necessary due to the scale of development and the critical importance of access to strategic transport infrastructure.
3.35.4 The direction of travel set out in the NPPF 2026 acknowledges that logistics developments will not always align with traditional urban sustainable travel patterns, and that locational suitability must be assessed in the round, having regard to the functional needs of the sector alongside proportionate sustainability measures.
3.35.5 The accompanying Transport Technical Note (5030488) provides further detail on how Tritax Park, Cambridge benefits from sustainable transport and connectivity. This includes the locational benefits provided through the A14 / B1050 / A1307 road network alongside public transport & active travel opportunities that support the sustainable development of the Site.
3.35.6 Within this context, the application of Policy I/ST must reflect the nature of the proposed development. Tritax Park, Cambridge demonstrates a balanced and policy-compliant approach by combining an appropriate strategic location with a strong package of sustainable transport measures.
3.35.7 Tritax Park, Cambridge adjoins an existing pedestrian and cycle route connecting Longstanton and Northstowe to the north, and Bar Hill to the south, providing direct access to the wider active travel network. Opportunities to enhance public transport accessibility will also be delivered, including potential diversion of existing bus services or the provision of new bus stops, enabling access to half-hourly services between Northstowe and Cambridge City Centre via the Guided Busway.
3.35.8 Vehicular access is proposed from the B1050 via a new signalised junction, providing direct connectivity to the A1307 and the A14 at Junction 25. This strategic location supports efficient freight movement while minimising wider network impacts, consistent with the objectives of Policy I/ST.
3.35.9 Overall, Tritax Park, Cambridge, appropriately balances the locational requirements of freight and logistics development with proportionate and effective sustainable transport measures, as supported by the direction of travel in the NPPF 2026.

3.35.1 Tritax object to the proposed wording of Policy I/ST.
3.35.2 The NPPF 2024 Chapter 9 seeks to promote sustainable transports with paragraph 110 stating; “significant development should be focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes.” Further details are set out in Paragraphs 115 – 117 highlighting how authorities should consider development proposals ensuring sustainable transport modes are prioritised taking account of the vision for the site, the type of development and its location. Chapter 6 seeks to build a strong competitive economy with Paragraph 86 (b) highlighting planning policies and decisions should make 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,”
3.35.3 The direction of travel set out in the NPPF 2026 provides important clarity that the Government recognises the specific locational and operational requirements of freight and logistics development. Proposed Policy E3 (Freight and Logistics) confirms that a sector-specific approach is necessary due to the scale of development and the critical importance of access to strategic transport infrastructure.
3.35.4 The direction of travel set out in the NPPF 2026 acknowledges that logistics developments will not always align with traditional urban sustainable travel patterns, and that locational suitability must be assessed in the round, having regard to the functional needs of the sector alongside proportionate sustainability measures.
3.35.5 The accompanying Transport Technical Note (5030488) provides further detail on how Tritax Park, Cambridge benefits from sustainable transport and connectivity. This includes the locational benefits provided through the A14 / B1050 / A1307 road network alongside public transport & active travel opportunities that support the sustainable development of the Site.
3.35.6 Within this context, the application of Policy I/ST must reflect the nature of the proposed development. Tritax Park, Cambridge demonstrates a balanced and policy-compliant approach by combining an appropriate strategic location with a strong package of sustainable transport measures.
3.35.7 Tritax Park, Cambridge adjoins an existing pedestrian and cycle route connecting Longstanton and Northstowe to the north, and Bar Hill to the south, providing direct access to the wider active travel network. Opportunities to enhance public transport accessibility will also be delivered, including potential diversion of existing bus services or the provision of new bus stops, enabling access to half-hourly services between Northstowe and Cambridge City Centre via the Guided Busway.
3.35.8 Vehicular access is proposed from the B1050 via a new signalised junction, providing direct connectivity to the A1307 and the A14 at Junction 25. This strategic location supports efficient freight movement while minimising wider network impacts, consistent with the objectives of Policy I/ST.
3.35.9 Overall, Tritax Park, Cambridge, appropriately balances the locational requirements of freight and logistics development with proportionate and effective sustainable transport measures, as supported by the direction of travel in the NPPF 2026.

3.36.1 Tritax support policy I/TH.
3.36.2 Tritax recognise its role in supporting the development of new travel hubs and the improvement of existing sustainable transport infrastructure to deliver modal shift away from private car use in line with Local Plan objectives and direction of travel.
3.36.3 Tritax Park, Cambridge, is currently exploring options for sustainable transport enhancements, including the potential for a travel hub facility and the rerouting of bus services to better integrate with wider active travel and public transport networks.

3.37.2 The policy would be more effective if it clearly recognised that car parking and EV charging provision must respond to the specific characteristics of individual sites. Large or complex developments often have distinct operational requirements, travel patterns and accessibility constraints that cannot be addressed through uniform or prescriptive standards.

Tritax objects to the proposed wording of Policy I/EV.
The policy would be more effective if it clearly recognised that car parking and EV charging provision must respond to the specific characteristics of individual sites. Large or complex developments often have distinct operational requirements, travel patterns and accessibility constraints that cannot be addressed through uniform or prescriptive standards.
Tritax supports the objective of ensuring parking provision reflects land use, location, accessibility and EV infrastructure. The policy should therefore adopt a proportionate, evidence-based and site-specific approach, consistent with national policy, to support sustainable transport objectives without undermining development viability or deliverability.

3.38.1 Tritax object to the proposed wording of Policy I/SD.
3.38.2 The supporting text is heavily focused on built-up urban areas and defines micro-consolidation centres as small-scale facilities within or close to town and neighbourhood centres. This approach risks unduly constraining delivery and fails to provide sufficient flexibility for rural and edge-of-settlement employment sites, contrary to national planning policy.
3.38.3 The NPPF (2024) Chapter 6 focuses on building 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. The approach taken should allow each area to build on its strengths, counter any weaknesses and address the challenges of the future.” Further detail is set out in Paragraph 86 (e) which says 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.”
3.38.4 The NPPF 2026 provides a clear direction of travel. Policy E2 confirms that substantial weight should be given to the economic benefits of commercial development, including freight and logistics, while Policy E3 recognises the sector’s specific physical and locational requirements, including the need for access to strategic transport infrastructure and, in some cases, larger-scale buildings. National policy therefore anticipates that logistics and servicing functions may be more appropriately located at accessible rural or edge-of-settlement sites, where impacts can be effectively managed.
3.38.5 Policy I/SD should therefore be amended to explicitly support; (1) consolidation facilities at edge-of-settlement and rural locations serving nearby towns, villages and business areas; and (2) consolidation facilities that exceed “micro” scale where justified, provided they deliver equivalent outcomes in reduced vehicle mileage, lower emissions and improved delivery efficiency.
3.38.6 These changes would ensure Policy I/SD functions as a positive enabler of sustainable logistics development. This approach aligns with proposals such as Tritax Park, Cambridge, which will deliver strategically located logistics infrastructure supporting efficient, lower-emission last-mile distribution in line with national policy objectives.

3.38.1 Tritax object to the proposed wording of Policy I/SD.
3.38.2 The supporting text is heavily focused on built-up urban areas and defines micro-consolidation centres as small-scale facilities within or close to town and neighbourhood centres. This approach risks unduly constraining delivery and fails to provide sufficient flexibility for rural and edge-of-settlement employment sites, contrary to national planning policy.
3.38.3 The NPPF (2024) Chapter 6 focuses on building 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. The approach taken should allow each area to build on its strengths, counter any weaknesses and address the challenges of the future.” Further detail is set out in Paragraph 86 (e) which says 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.”
3.38.4 The NPPF 2026 provides a clear direction of travel. Policy E2 confirms that substantial weight should be given to the economic benefits of commercial development, including freight and logistics, while Policy E3 recognises the sector’s specific physical and locational requirements, including the need for access to strategic transport infrastructure and, in some cases, larger-scale buildings. National policy therefore anticipates that logistics and servicing functions may be more appropriately located at accessible rural or edge-of-settlement sites, where impacts can be effectively managed.
3.38.5 Policy I/SD should therefore be amended to explicitly support; (1) consolidation facilities at edge-of-settlement and rural locations serving nearby towns, villages and business areas; and (2) consolidation facilities that exceed “micro” scale where justified, provided they deliver equivalent outcomes in reduced vehicle mileage, lower emissions and improved delivery efficiency.
3.38.6 These changes would ensure Policy I/SD functions as a positive enabler of sustainable logistics development. This approach aligns with proposals such as Tritax Park, Cambridge, which will deliver strategically located logistics infrastructure supporting efficient, lower-emission last-mile distribution in line with national policy objectives.

3.39.1 Tritax supports of Policy I/EI.
3.39.2 The policy appropriately recognises the need for new development to be underpinned by resilient, future-proofed and low-carbon energy infrastructure, consistent with national and local climate objectives and emerging energy system requirements.
3.39.3 Tritax places sustainability and energy efficiency at the heart of its projects, with new buildings designed to achieve net zero carbon in construction, alongside EPC A ratings and BREEAM Excellent as a minimum target.