Draft Greater Cambridge Local Plan for consultation

COMMENT is given to the requirement for development to meet the objectively assessed needs in Greater Cambridge over the period of 2024-2045 with regard to economic development.

These representations are supported by a Technical Note prepared by Volterra which provides the following key considerations:

• A local plan that only meets the minimal “objectively assessed need” could leave no headroom for the extra growth Government and industry partners are actively seeking to stimulate.

• This conservative outlook means the plan could fall short of the Government’s and Combined Authority’s bold ambitions. If Cambridge’s growth even partly approaches the higher national expectations, the currently planned employment land and floorspace would be insufficient to support it.

SUPPORT is given to the inclusion of Policy S/DE which seeks to permit development and redevelopment of unallocated land and buildings within defined development extents as defined within the Draft Policies Map for Greater Cambridge 2025.

Cambridge Science Park is located within the defined development extents as illustrated and as a result, should for any reason Policy S/NEC fall away given the uncertainty regarding the CWWTP, the redevelopment of Cambridge Science Park would still principally be supported under Policy S/DE as the site falls within the defined development extent of Cambridge City. This emerging policy broadly aligns with that currently afforded to Cambridge Science Park through Policy E/1 of the Adopted South Cambridge District Council Local Plan (2018).

SUPPORT is given to the inclusion of a meanwhile uses policy within the emerging Local Plan. Given the long-term, strategic framework established by Policy S/NEC for whole-site outline applications at North East Cambridge, the ability to accommodate meanwhile uses is considered integral to the deliverability of the allocation. Meanwhile uses can provide flexibility during phased development, activate sites ahead of permanent development, and support the effective implementation of the overall masterplan strategy.

The requirement for new developments of 1,000 sqm or more of floorspace within commercial and flexible use classes to submit and implement an Employment and Skills Plan at both the construction and occupation stages is SUPPORTED.

The College is a strong advocate for the provision of education, training and skills development opportunities across Cambridge Science Park, including through facilities such as the Cambridge Science Centre and connections with Cambridge Regional College, and local schools. Cambridge Science Park has a strong commitment to inspiring the next generation of innovators.

In supporting this requirement, it is considered important that Employment and Skills Plans are applied in a flexible and proportionate manner, having regard to the nature, scale and phasing of individual developments, as well as the operational requirements of occupiers. An appropriately tailored approach will ensure that Employment and Skills Plans remain effective, deliverable and aligned with existing initiatives across the Science Park, while continuing to provide meaningful benefits to the local community and workforce.

Although SUPPORT is given to the overarching objective of promoting the provision of affordable workspace within employment developments, the policy as currently drafted lacks clarity regarding the key requirements for delivery. In particular, the policy does not specify the development thresholds at which affordable workspace would be required, nor does it identify the proportion of floorspace that should be provided as affordable workspace within qualifying schemes.

Should the Council intend for affordable workspace to be delivered as part of larger commercial developments, it is considered necessary for the policy to clearly define both the minimum size of development to which the requirement applies and the percentage of floorspace to be allocated. Alternatively, if the Council does not wish to prescribe specific thresholds or figures, the policy should explicitly confirm that affordable workspace provision will be assessed on a case-by-case basis. This approach should be set out within the policy wording itself, rather than relying on supporting text or supplementary information.

Trinity College Cambridge also supports the inclusion of flexibility to allow affordable workspace requirements to be met off-site in exceptional circumstances. These circumstances may include, but are not limited to, developments where an occupier requires exclusive use of a single office building, or where mixed-use sites comprise multiple landownerships that make on-site provision impractical.

Cambridge Science Park already provides a broad and established range of workspace typologies, supporting businesses at all stages of growth, from early-stage start-ups and incubator space, through grow-on and scale-up accommodation, to bespoke headquarters buildings for established companies. In this context, the ability to meet affordable workspace requirements flexibly across the wider Cambridge Science Park estate, rather than within each individual development parcel, is supported. This would allow affordable workspace provision to be aligned more effectively with the operational needs of occupiers and the evolving lifecycle of businesses, while still contributing to the overall supply of affordable workspace across the site.

SUPPORT is given to the inclusion of support for appropriately scaled facilities in business and employment parks. Cambridge Science Park already benefits from a well-established range of services and facilities distributed across the site, including food and drink outlets, meeting and collaboration spaces, amenities for employees, and landscaped areas that support wellbeing. These facilities are widely used and contribute positively to the day-to-functioning and attractiveness of the Park for both occupiers and visitors.

Furthermore, the emerging masterplan for Cambridge Science Park seeks to build upon this strong existing provision through the introduction of additional services and facilities designed to further support the employment function of the site. These include enhanced indoor and outdoor social and collaboration spaces, leisure and wellbeing facilities, and improved green and public realm spaces. Collectively, these measures will help reinforce Cambridge Science Park as a high-quality, sustainable employment location capable of supporting future growth and development.

It is our view that the 20% requirement set out in Policy BG/BG has not been sufficiently justified based on proportionate evidence and as such should be amended to remove the additional requirement for major development to provide a minimum of 20% and that this should only be referenced as an aspirational target.

Despite TCC supporting the overall objectives of Policy BG/BG which control the biodiversity impacts from development, it considers the wording within the policy to be above what is required by legislation, and therefore OBJECT to the policy on that basis.

As mentioned previously, the Environment Act 2021, set a minimum Biodiversity Net Gain of 10% and includes aspirational goals for this to be increased through the local planning system. Additionally, Government PPG states that plan makers should not seek a higher percentage than the statutory objective unless justified through evidenced local need.

Seeking a higher requirement should only be by way of an exception, and in this case, demonstrating that Greater Cambridge is significantly worse than any other part of the country as a whole with regards to the negative impacts on biodiversity seems wholly unrealistic.

It is our view that the 20% requirement set out in Policy BG/BG has not been sufficiently justified based on proportionate evidence and as such should be amended to remove the additional requirement for major development to provide a minimum of 20% and that this should only be referenced as an aspirational target.

Should other employment sites also have the application of policy BG/PO then for Cambridge Science Park an amendment to the draft Polices Map to show the areas of Open Space within Cambridge Science Park is suggested in the attached plan.

TCC recognise the importance that open spaces play across Cambridge Science Park. All of the open spaces and biodiverse areas within the Science Park have been planned and curated over its 55 year history.

However, TCC OBJECT to the inclusion as currently outlined on the draft policies map.

Firstly, the Greater Cambridge Shared Planning Team have not adopted this approach on any other strategic employment site. Having reviewed Cambridge Biomedical Campus, Granta Park and the Wellcome Campus none of these employment sites contain land designated under policy BG/PO.

The designation's green outline is not logical as shown. It includes car parking areas and development sites.

It is considered that the inclusion of numerous other policies within the draft local plan including Policy BG/BG and written elements within Policy S/NEC cover off the retention and reprovision of open space where necessary. For example, Policy S/NEC requires “an extensive high-quality network of multi-functional open spaces”.

Appendix 1 includes an Open Space Assessment of the currently proposed designated open space and demonstrates the inconsistencies within the emerging Local Plan designations across the district.

Should other employment sites also have the application of policy BG/PO then for Cambridge Science Park an amendment to the draft Polices Map to show the areas of Open Space within Cambridge Science Park is suggested, in line with Appendix 1.

These representations recognise the alterations made to the draft Local Plan, which now include reference to Cambridge Science Park as a major employment site within the Greater Cambridge Area. However, there are still concerns regarding specific policy wording proposed as set out within these representations.

Please see attached letter given the length of the representations.

Please find attached representation prepared by Turley on behalf of Trinity College, Cambridge.