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Object

Draft Greater Cambridge Local Plan for consultation

Policy S/AMC/GP: Granta Park

Representation ID: 203348

Received: 29/01/2026

Respondent: BMR GRANTA PARK PROPCO LIMITED

Agent: Carter Jonas

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Figure 103: Site Plan of Policy S/AMC/GP: Granta Park defines the site area. The Site Plan should be updated (Extended) to reflect the demise of the Phase 2 scheme approved under application – with the decked car park and land to the rear in accordance with planning consent S/1110/15/OL (as varied by S/1110/15/NMA1 & 22/04467/S73 (the revised RMA)).

Change suggested by respondent:

The Site Plan should be updated (Extended) to reflect the demise of the Granta Park Phase 2 scheme approved under application – with the decked car park and land to the rear in accordance with planning consent S/1110/15/OL (as varied by S/1110/15/NMA1 & 22/04467/S73 (the revised RMA)).

Full text:

BIOMED REALTY (BMR GRANTA PARK PROPCO LIMITED)

Figure 103: Site Plan of Policy S/AMC/GP: Granta Park defines the site area. The Site Plan should be updated (Extended) to reflect the demise of the Phase 2 scheme approved under application – with the decked car park and land to the rear in accordance with planning consent S/1110/15/OL (as varied by S/1110/15/NMA1 & 22/04467/S73 (the revised RMA)).

Attachments:

Object

Draft Greater Cambridge Local Plan for consultation

Policy S/AMC/GP: Granta Park

Representation ID: 203350

Received: 29/01/2026

Respondent: BMR GRANTA PARK PROPCO LIMITED

Agent: Carter Jonas

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Granta Park’s allocation as an Area of Major Change is supported, but several refinements to Policy S/AMC/GP are needed. R&D floorspace should remain the dominant use, with flexibility for enabling facilities that strengthen the life‑science ecosystem. Open‑space policy should recognise usability, function and operational needs, not just visual or ecological value. The SSSI clause is unnecessary due to existing legal protections. A new criterion should support essential infrastructure such as key worker accommodation, which is vital given immediate workforce pressures and delays to new settlement delivery. Overall, the policy must better reflect the operational realities of a modern life‑science campus.

Change suggested by respondent:

Updated Proposed Amendments to Policy S/AMC/GP (Granta Park)
Submitted on behalf of BioMed Realty

BioMed Realty is supportive of Granta Park being identified as an Area of Major Change within the Rural Southern Cluster, recognising the campus’ strategic importance to the Greater Cambridge life science economy. However, several refinements are required to ensure the policy reflects the operational realities of a modern research campus and provides an effective, flexible framework for the continued evolution of Granta Park.

The policy rightly requires applicants to demonstrate that reuse of existing buildings has been considered before new development is brought forward. Criterion (c) should, however, be updated to reflect how the campus operates as an integrated R&D ecosystem. To do this, the wording should confirm that there should be no loss of Class E(g)(ii) research and development floorspace unless a proposal demonstrably supports the overall functioning or competitiveness of Granta Park as a strategic R&D location, or where there is a sufficiently justified community benefit. This ensures that R&D remains the dominant land use while acknowledging that certain enabling uses—such as support facilities essential for the life science cluster—are required to keep the campus functioning efficiently.

Similarly, Criterion (e) would benefit from a broader and clearer definition of what it means to “enhance” open space. While open spaces that contribute to parkland character, visual quality, biodiversity value, or the setting of heritage assets should be protected and improved, enhancement should also include improvements to usability, accessibility and the functional performance of spaces. This may involve creating areas for staff wellbeing, informal meetings or outdoor collaboration; providing better surface treatments, seating or shade; improving microclimate conditions; enhancing connectivity across the campus; or providing inclusive movement routes and wayfinding. In this way, open space is recognised not only for its aesthetic value but also for its practical contribution to the daily operation of a high performing life science campus. At the same time, incidental or lower value open spaces that provide little landscape, amenity, or ecological function may appropriately be considered for development where this supports the efficient operation of the campus.

With regards to Criterion (f), the requirement to demonstrate no adverse impacts on Alder Carr SSSI is unnecessary and duplicative. The Wildlife and Countryside Act 1981 already makes it a legal offence to damage or disturb an SSSI or undertake harmful activities without Natural England’s consent, meaning these protections apply automatically regardless of Local Plan wording. In addition, Alder Carr is private land with no public access, significantly reducing risk pathways such as visitor pressure. Given these safeguards, retaining Criterion (f) adds no additional value and could be removed without weakening environmental protection.
To ensure the policy responds effectively to the needs of an internationally competitive science campus, a new criterion (i) should be introduced. This would explicitly recognise that essential supporting infrastructure is fundamental to the continued success of Granta Park as a strategic R&D destination. New development may therefore include key worker accommodation or other critical facilities where these are demonstrably linked to the functioning of the site. Such provision may be appropriately delivered on land within the ownership of Granta Park where it would reduce commuting demand and pressure on the transport network, support staff retention in key scientific and technical roles, and strengthen the overall resilience and competitiveness of the campus. While Policy S/GF references worker housing at Grange Farm, the scale and phasing of that proposal mean homes may not be delivered until the late 2030s or beyond, creating a significant mismatch with the immediate workforce needs of the science campus. Granta Park has previously promoted key worker accommodation at Bancroft Park, and the policy should create space for such solutions to be properly considered.

Together, these amendments ensure that Policy S/AMC/GP supports the continued delivery of high quality R&D space while enabling the critical supporting facilities and infrastructure required for the campus to thrive. They also ensure that environmental considerations—such as open space and biodiversity—are addressed in a practical, proportionate way consistent with the realities of a high performing life sciences environment.

Full text:

Granta Park’s allocation as an Area of Major Change is supported, but several refinements to Policy S/AMC/GP are needed. R&D floorspace should remain the dominant use, with flexibility for enabling facilities that strengthen the life‑science ecosystem. Open‑space policy should recognise usability, function and operational needs, not just visual or ecological value. The SSSI clause is unnecessary due to existing legal protections. A new criterion should support essential infrastructure such as key worker accommodation, which is vital given immediate workforce pressures and delays to new settlement delivery. Overall, the policy must better reflect the operational realities of a modern life‑science campus.

Object

Draft Greater Cambridge Local Plan for consultation

Policy CC/NZ: Net zero carbon new buildings

Representation ID: 203352

Received: 29/01/2026

Respondent: BMR GRANTA PARK PROPCO LIMITED

Agent: Carter Jonas

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

BioMed Realty supports the ambition for low‑carbon, high‑performance buildings but objects to Policy CC/NZ because the proposed energy targets are not technically feasible for life science laboratories, which require high ventilation, extraction and safety systems that inherently increase energy use. The policy assumes onsite renewables that are typically unachievable on laboratory buildings and provides no clarity on the offsetting mechanism. CC/NZ duplicates other climate policies and lacks viability and technical evidence, making it unsound. Amendments are requested to acknowledge R&D energy demands, ensure policy flexibility, clarify interactions with other policies, provide a defined offsetting mechanism and complete full viability testing.

Change suggested by respondent:

CLIMATE CHANGE

Policy CC/NZ: Net zero carbon new buildings
Submitted on behalf of BioMed Realty (Granta Park)

Objection
BioMed Realty (Granta Park) supports the overarching ambition of delivering low carbon, high performance buildings and acknowledges the important role of the construction sector in addressing the climate emergency.

BioMed Realty, as the long term investor, owner and operator of Granta Park, fully supports the Council’s ambition to deliver a low carbon future and recognises the significant contribution that the built environment must make in responding to the climate emergency. We are committed to providing high performance, energy efficient laboratories across our life science portfolio and to supporting global decarbonisation efforts through the work carried out within these facilities. However, Policy CC/NZ, as currently drafted, is neither technically feasible nor proportionate for life science R&D buildings and therefore cannot be considered sound.

The draft policy sets extremely low energy performance thresholds, including space heating demands of 15–20 kWh/m²/yr and EUI levels aligned with the UK Net Zero Carbon Buildings Standard 2030. These standards significantly exceed Building Regulations but are not supported by any evidence showing that they can be achieved in laboratory settings. Life science buildings operate fundamentally differently from standard commercial offices. They require high, continuous ventilation rates; 24/7 mechanical extraction; and extensive HVAC and safety systems to meet strict regulatory and operational requirements. These systems cannot be reduced without compromising safety or scientific integrity and inevitably result in higher baseline energy use. As a result, the targets proposed in CC/NZ are simply incompatible with the operational realities of modern R&D facilities.

The policy also expects buildings to meet their energy demand through onsite renewable generation “where possible,” yet laboratory buildings typically have little available roofspace because essential plant occupies most of the area. Taller buildings and air handling zones further reduce opportunities for onsite renewables, making large scale onsite generation unachievable on many science campuses. Although the policy provides for an offsetting mechanism, it offers no clarity on governance, cost, or delivery, meaning applicants cannot understand how this route would operate in practice.

In addition, CC/NZ duplicates requirements already contained in CC/SD, CC/IW, CC/CE and CC/DC, creating overlapping obligations, multiple evidence requirements, and uncertainty about how policies interact. Without clear alignment, this adds unnecessary complexity to the planning process and risks inconsistency in decision making. Combined with the absence of technical feasibility testing and whole plan viability assessment, these issues mean that CC/NZ is not justified, not effective, and not aligned with national policy.

For these reasons, BioMed Realty requests targeted amendments to CC/NZ. The policy must explicitly recognise the unique ventilation, safety and energy demands of R&D buildings and allow flexibility where net zero thresholds cannot be met for technical reasons. It should also clarify its relationship to other climate related policies so that applicants can prepare a single, coordinated climate and energy strategy. Before the policy progresses, the Council should undertake full viability and technical modelling—specifically including laboratory typologies. Ensuring flexibility within the policy is essential for Cambridge to continue attracting world class science and innovation facilities that contribute positively to both the local economy and global decarbonisation.

BioMed Realty remains committed to working collaboratively with the Council to develop an evidence based, deliverable, and science appropriate framework for achieving net zero development.

Policy CC/NZ should be amended as follows:

1. Avoid duplication and ensure clarity
Clarify how CC/NZ interacts with CC/SD, CC/IW, CC/DC and CC/CE so that applicants only need to submit one coordinated climate related evidence package, avoiding overlapping or conflicting requirements.
2. Undertake whole plan viability testing and technical modelling
Complete full viability testing—including laboratory specific feasibility assessments—before the next iteration of the Local Plan to ensure that the requirements in CC/NZ do not compromise the deliverability of new development, particularly R&D floorspace.
3. Ensure adaptability for the unique demands of R&D development
Explicitly recognise that life science laboratories have unavoidable ventilation, safety and operational requirements that make some Net Zero thresholds technically unachievable. The policy must include sufficient flexibility to accommodate these constraints.
4. Ensure policy flexibility enables continued science sector growth (additional enhancement)
Amend the policy to ensure that Net Zero requirements do not inadvertently limit the delivery of essential scientific infrastructure or undermine Cambridge’s role as a globally competitive R&D centre.

Full text:

BioMed Realty supports the ambition for low‑carbon, high‑performance buildings but objects to Policy CC/NZ because the proposed energy targets are not technically feasible for life science laboratories, which require high ventilation, extraction and safety systems that inherently increase energy use. The policy assumes onsite renewables that are typically unachievable on laboratory buildings and provides no clarity on the offsetting mechanism. CC/NZ duplicates other climate policies and lacks viability and technical evidence, making it unsound. Amendments are requested to acknowledge R&D energy demands, ensure policy flexibility, clarify interactions with other policies, provide a defined offsetting mechanism and complete full viability testing.

Support

Draft Greater Cambridge Local Plan for consultation

Policy WS/MU: Meanwhile uses during long term redevelopments

Representation ID: 203354

Received: 29/01/2026

Respondent: BMR GRANTA PARK PROPCO LIMITED

Agent: Carter Jonas

Representation Summary:

BioMed Realty (Granta Park) We support the policy’s encouragement of meanwhile uses on large development sites, vacant land, and underused buildings awaiting permanent redevelopment. Such uses play an important role in maintaining activity, meeting community needs, and enhancing the vibrancy of sites during phased delivery. However, the policy should allow flexibility in the duration of meanwhile uses to reflect differing site circumstances, development phasing, and market conditions. Meanwhile uses must remain compatible with surrounding uses and should not impede the long‑term development objectives for the site. A flexible, supportive approach will ensure sites contribute positively throughout the redevelopment period.

Full text:

BioMed Realty (Granta Park) We support the policy’s encouragement of meanwhile uses on large development sites, vacant land, and underused buildings awaiting permanent redevelopment. Such uses play an important role in maintaining activity, meeting community needs, and enhancing the vibrancy of sites during phased delivery. However, the policy should allow flexibility in the duration of meanwhile uses to reflect differing site circumstances, development phasing, and market conditions. Meanwhile uses must remain compatible with surrounding uses and should not impede the long‑term development objectives for the site. A flexible, supportive approach will ensure sites contribute positively throughout the redevelopment period.

Object

Draft Greater Cambridge Local Plan for consultation

Policy BG/BG: Biodiversity and geodiversity

Representation ID: 203356

Received: 29/01/2026

Respondent: BMR GRANTA PARK PROPCO LIMITED

Agent: Carter Jonas

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

BioMed Realty supports biodiversity enhancement but objects to Policy BG/BG’s proposed 20% Biodiversity Net Gain requirement, which exceeds the statutory 10% set by the Environment Act and conflicts with emerging national policy. Combined with other green infrastructure policies, the 20% uplift would significantly constrain life science campuses, where laboratory buildings require larger footprints and extensive servicing. The threshold has not been viability‑tested and risks delaying essential R&D development. Life science parks can deliver greater ecological value through strategic, site‑wide habitat creation and BNG banking. The policy should align with the 10% requirement, allow estate‑wide delivery, and avoid restricting research floorspace.

Change suggested by respondent:

BG/BG – Biodiversity
Objection
Submitted on behalf of BioMed Realty (Granta Park)
BioMed Realty supports the principle of protecting and enhancing biodiversity and fully recognises the importance of delivering meaningful Biodiversity Net Gain (BNG) across Greater Cambridge. We are committed to managing Granta Park as a high quality landscape and ecological environment and have a strong track record of investing in long term habitat creation and enhancement. However, Criterion 2 of Policy BG/BG, which requires all major developments to deliver a minimum 20% BNG, goes significantly beyond the mandatory 10% statutory requirement set by the Environment Act 2021 and does not align with the direction of emerging national policy. The draft NPPF is explicit that local planning authorities should not exceed the national minimum requirement, raising serious concerns about the soundness of the proposed 20% threshold.

The requirement must also be considered in the context of the combined burdens placed on development by other draft policies, including BG/TC (tree canopy), BG/GI (green infrastructure), and BG/EO (habitat and ecology requirements). Each of these policies materially reduces the land available for development, limits density potential, and increases delivery costs. When taken together, these expectations disproportionately affect life science sites, where development footprints often need to accommodate technically complex laboratory buildings, extensive plant zones, and enhanced servicing requirements. For constrained or brownfield life science campuses, a mandatory 20% BNG uplift could significantly restrict the ability to deliver new research floorspace and risk undermining the economic role of Greater Cambridge’s science parks.

In addition, the viability implications of the 20% requirement—whether achieved onsite, offsite or through habitat banking—have not been tested at a whole plan level. This introduces uncertainty for developers and occupiers and raises the risk that the policy could delay or prevent the delivery of essential science sector infrastructure and employment space.

Importantly, life science campuses such as Granta Park already present unique opportunities to deliver biodiversity at a site wide scale, rather than solely on a building by building basis. These campuses typically include large areas of managed parkland, naturalised drainage, woodland belts, and habitat networks that can be strategically enhanced. A site wide BNG strategy enables the creation of larger, better connected, and longer term ecological benefits that go beyond the fragmented uplift achievable on individual plots. Such an approach also allows BNG credits to be generated, banked, and drawn down, enabling future phases of laboratory development to proceed while still delivering meaningful biodiversity gains across the wider campus.

For these reasons, a rigid 20% requirement applied to every individual development parcel does not reflect how life science parks function in practice and could unintentionally undermine their ability to contribute both to biodiversity enhancement and to the region’s globally significant research economy.

Requested Change
Policy BG/BG should be revised as follows:
1. Align the Local Plan with the statutory 10% BNG requirement, unless robust, site specific justification is provided for a higher uplift and whole plan viability testing has been completed.
2. Recognise the role of life science campuses in delivering strategic, site wide biodiversity enhancements, allowing BNG to be delivered across the wider estate rather than at plot level.
3. Enable site wide habitat creation to generate and “bank” BNG credits, which can be used to support and mitigate future phases of development within science parks and speed up delivery.
4. Ensure that BNG policy does not unintentionally constrain the delivery of essential life science floorspace, acknowledging the operational and spatial demands of R&D buildings.

Full text:

BioMed Realty supports biodiversity enhancement but objects to Policy BG/BG’s proposed 20% Biodiversity Net Gain requirement, which exceeds the statutory 10% set by the Environment Act and conflicts with emerging national policy. Combined with other green infrastructure policies, the 20% uplift would significantly constrain life science campuses, where laboratory buildings require larger footprints and extensive servicing. The threshold has not been viability‑tested and risks delaying essential R&D development. Life science parks can deliver greater ecological value through strategic, site‑wide habitat creation and BNG banking. The policy should align with the 10% requirement, allow estate‑wide delivery, and avoid restricting research floorspace.

Object

Draft Greater Cambridge Local Plan for consultation

Policy BG/GI: Green and blue infrastructure

Representation ID: 203358

Received: 29/01/2026

Respondent: BMR GRANTA PARK PROPCO LIMITED

Agent: Carter Jonas

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

BioMed Realty supports strengthening green and blue infrastructure but objects to Policy BG/GI’s mandatory Greening Factor of 0.3 for non‑residential development. The basis for this threshold is unclear, and its relationship with other requirements—such as rooftop solar, BNG, tree canopy and ecology policies—is undefined. Combined, these policies could constrain viable development, particularly on brownfield or higher‑density life science sites. The Greening Factor has not been tested for viability or supported by completed technical evidence, creating risks for deliverability. A more flexible, evidence‑led approach is requested, allowing greening levels to reflect site context, viability and other policy obligations.

Change suggested by respondent:

Policy BG/GI: Green and Blue Infrastructure
Submitted on behalf of BioMed Realty (Granta Park)
Objection
BioMed Realty supports the overarching principle of protecting and enhancing green and blue infrastructure (GBI) and agrees that GBI should be considered at an early stage. Part 4 of the policy however requires that all major non residential developments should aim to meet a Greening Factor of 0.3.
It is unclear why a Greening Factor of 0.3 has been settled on, and how this will interface with other considerations e.g. rooftop solar panels and biodiversity net gain.
It is considered that achieving a greening factor of 0.3 may compromise the ability to deliver viable developments when balancing against other policy requirements as set out in the draft GCLP, namely Policy BG/BG, Policy BC/TC Policy BG/EO, Policy WS/NC. These restrict opportunities for density uplift and achieving the development aspirations of the draft plan.
The Mandatory Greening Factors are also not evidently backed by viability testing or completed technical evidence, especially as GI standards are still being developed. This risks undermining deliverability—particularly on brownfield or higher density sites. The policy introduces multiple GI obligations in addition to statutory BNG, creating overlaps or conflicts. On constrained sites, delivering multifunctional GI and 10% BNG on site may be physically unrealistic.
Requested Change

It is requested that the Greening Factor requirement is reviewed and amended as follows:

1. Replace the mandatory Greening Factor of 0.3 (non residential) with a flexible, evidence based standard, such as:

“Major development should seek to achieve a Greening Factor that is appropriate to site context, viability and other policy requirements, and should demonstrate how green and blue infrastructure has been maximised through a design led approach.”

Full text:

BioMed Realty supports strengthening green and blue infrastructure but objects to Policy BG/GI’s mandatory Greening Factor of 0.3 for non‑residential development. The basis for this threshold is unclear, and its relationship with other requirements—such as rooftop solar, BNG, tree canopy and ecology policies—is undefined. Combined, these policies could constrain viable development, particularly on brownfield or higher‑density life science sites. The Greening Factor has not been tested for viability or supported by completed technical evidence, creating risks for deliverability. A more flexible, evidence‑led approach is requested, allowing greening levels to reflect site context, viability and other policy obligations.

Object

Draft Greater Cambridge Local Plan for consultation

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

Representation ID: 203364

Received: 29/01/2026

Respondent: BMR GRANTA PARK PROPCO LIMITED

Agent: Carter Jonas

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

BioMed Realty supports tree protection and landscape enhancement but objects to Policy BG/TC’s fixed requirement for 30% future canopy cover. This rigid threshold does not reflect varied site conditions, higher‑density development, or the operational needs of life science campuses, where laboratory buildings and essential plant significantly limit available land. The requirement also overlaps with other green infrastructure and biodiversity policies, increasing cumulative constraints on developable area. Granta Park already provides substantial estate‑wide canopy, which should be recognised. A more flexible, context‑led approach is requested, requiring developments to maximise canopy opportunities without imposing a uniform numerical target.

Change suggested by respondent:

Representation on Policy BG/TC – Tree Canopy
Submitted on behalf of BioMed Realty (Granta Park)

BioMed Realty supports the principle of protecting existing trees and enhancing landscape quality across Greater Cambridge. However, Policy BG/TC’s requirement for all major developments to provide a minimum 30% future tree canopy cover is overly rigid and does not reflect the wide variation in site conditions, development typologies or operational needs—particularly on life science campuses. While the policy indicates that lower percentages may be accepted where justified, the imposition of a fixed 30% baseline still places significant constraints on viable development and does not strike the appropriate balance between landscape enhancement and the delivery of strategic growth.

This challenge is especially acute on previously developed or brownfield sites, as well as in more urbanised locations where higher development densities are expected. For life science environments such as Granta Park, development footprints must often accommodate complex laboratory buildings, extensive plant areas, service routes and specialised infrastructure. These operational requirements reduce the land available to deliver new canopy cover and mean that a rigid numerical target can conflict with the practical delivery of R&D floorspace. In addition, the 30% canopy requirement sits alongside other policies—including BG/BG (Biodiversity Net Gain), BG/GI (Green Infrastructure), BG/EO (Ecology and On site Habitat) and WS/NC (Natural Capital)—that collectively place substantial pressure on developable land. The cumulative effect of these policies risks reducing capacity, limiting density, and undermining the deliverability of developments supported by the draft Local Plan.

Granta Park itself provides an excellent example of why a more flexible approach is required. The campus already contains approximately 30 acres of woodland, representing a significant and mature canopy resource that contributes meaningfully to biodiversity, landscape character and the overall environmental quality of the site. Any assessment of additional canopy provision should therefore be able to take proper account of this existing estate wide tree cover rather than applying a uniform 30% requirement to individual development plots in isolation. A more proportionate, context based approach would allow the planning system to recognise the wider landscape contribution already provided across the science park.

Requested Change
Draft Policy BG/TC should be amended so that developments are required to demonstrate that they have maximised opportunities to deliver new canopy cover, without imposing a fixed percentage requirement. This would ensure a balanced and realistic policy approach that acknowledges existing woodland assets—such as those at Granta Park—and supports the continued delivery of high quality life science R&D floorspace while still promoting strong landscape and ecological outcomes.

Full text:

BioMed Realty supports tree protection and landscape enhancement but objects to Policy BG/TC’s fixed requirement for 30% future canopy cover. This rigid threshold does not reflect varied site conditions, higher‑density development, or the operational needs of life science campuses, where laboratory buildings and essential plant significantly limit available land. The requirement also overlaps with other green infrastructure and biodiversity policies, increasing cumulative constraints on developable area. Granta Park already provides substantial estate‑wide canopy, which should be recognised. A more flexible, context‑led approach is requested, requiring developments to maximise canopy opportunities without imposing a uniform numerical target.

Object

Draft Greater Cambridge Local Plan for consultation

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

Representation ID: 203366

Received: 29/01/2026

Respondent: BMR GRANTA PARK PROPCO LIMITED

Agent: Carter Jonas

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

BioMed Realty supports circular economy principles, including reducing waste and reusing materials, but objects to Policy CC/CE because Criterion 2 does not reflect the specialist needs of life science R&D facilities. The policy creates a presumption for retaining existing buildings, with demolition only allowed “on an exceptional basis,” which is unrealistic for laboratories requiring advanced vibration control, ventilation, containment and adaptable layouts. Retrofitting older structures is often unsafe, unfeasible or inefficient. A more balanced approach is needed. BioMed Realty requests removing “on an exceptional basis” to allow proportionate assessments that consider the unique technical and scientific requirements of R&D buildings.

Change suggested by respondent:

CC/CE – Circular economy
Representation on Policy CC/CE – Circular Economy

Objection
BioMed Realty supports the principle of embedding circular economy thinking into development, including reducing waste, encouraging material reuse, and improving whole life resource efficiency. We recognise the importance of minimising demolition waste and maximising the retention of existing building structures wherever possible. However, Policy CC/CE, and in particular Criterion 2, does not take account of the specialist and rapidly evolving needs of life science R&D facilities, which frequently require high specification, technically complex environments that cannot always be accommodated within existing buildings.

Criterion 2 currently creates a presumption in favour of retaining and reusing existing buildings, with demolition only permitted where strict criteria are met. The wording in Criterion 2(d)—that demolition may only be justified “on an exceptional basis”—is overly restrictive and does not provide a realistic framework for scientific campuses, where advances in research, safety standards, and laboratory technology can necessitate purpose built facilities rather than the adaptation of legacy structures. Life science buildings often require specific vibration control, floor loading, ventilation and containment systems, along with highly adaptable internal layouts to support evolving research. These operational requirements mean that retrofitting older buildings is not always feasible, safe or cost effective, nor does it always support long term circular economy outcomes when extensive structural interventions or partial rebuilds are needed.

The pace of scientific and technological change also means that facilities must evolve regularly to remain suitable for cutting edge research. A rigid presumption against demolition risks constraining the ability of life science occupiers to maintain scientific excellence, respond to emerging technologies, and continue contributing to the region’s international competitiveness. Adopting a more balanced and proportionate approach would still prioritise waste minimisation, but without creating a barrier to delivering modern, efficient and sustainable laboratory buildings that cannot be accommodated within existing structures.

For these reasons, the policy should allow demolition where a proportionate assessment demonstrates that retention is not practical, safe, or compatible with delivering high quality scientific space—not only in “exceptional” circumstances. This will ensure that circular economy principles are applied appropriately while still supporting the viability and operational needs of the life science sector.

Requested Change

Remove the phrase “on an exceptional basis” from Criterion 2(d) of Policy CC/CE, so that demolition can be considered through a proportionate and balanced assessment that takes full account of the unique technical, operational and scientific requirements of life science R&D facilities.

Full text:

BioMed Realty supports circular economy principles, including reducing waste and reusing materials, but objects to Policy CC/CE because Criterion 2 does not reflect the specialist needs of life science R&D facilities. The policy creates a presumption for retaining existing buildings, with demolition only allowed “on an exceptional basis,” which is unrealistic for laboratories requiring advanced vibration control, ventilation, containment and adaptable layouts. Retrofitting older structures is often unsafe, unfeasible or inefficient. A more balanced approach is needed. BioMed Realty requests removing “on an exceptional basis” to allow proportionate assessments that consider the unique technical and scientific requirements of R&D buildings.

Object

Draft Greater Cambridge Local Plan for consultation

Policy S/GF: Land adjacent to A11 and A1307 at Grange Farm

Representation ID: 203371

Received: 29/01/2026

Respondent: BMR GRANTA PARK PROPCO LIMITED

Agent: Carter Jonas

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

BioMed Realty supports the allocation of Grange Farm as a new settlement and welcomes the inclusion of key worker housing to serve the surrounding life‑science cluster. However, the long lead‑in time means homes may not be delivered until the late 2030s, creating a mismatch with the immediate workforce needs of Granta Park. Clear delivery mechanisms, early phasing and safeguards are required to ensure key worker housing is provided promptly, tied directly to major R&D campuses, and protected over time. Alternative nearby sites, such as Bancroft Park, should also be considered to meet urgent accommodation needs.

Change suggested by respondent:

NEW SETTLEMENTS
Suggested Reg 18 Representation – Policy S/GF (Grange Farm)
Submitted on behalf of BioMed Realty (Granta Park)
Object

Overall Position
Biomed Realty welcomes the allocation of Grange Farm as a strategic new settlement within the Rural Southern Cluster and supports the policy’s recognition of the need for key worker housing to serve surrounding employment centres, including Granta Park. As a major long term investor in Granta Park and a key stakeholder in the life sciences ecosystem, Biomed Realty is committed to ensuring that new residential development supports the economic success and global competitiveness of the cluster.
However, while the principle of key worker housing at Grange Farm is supported, we have significant concerns regarding delivery lead in time, certainty of supply, and the mechanisms to ensure that the needs of Granta Park-based employers are met.

Requested Change

1. Support for Key Worker Housing (Policy S/GF(7)(f)(i))
Biomed Realty strongly supports explicit reference to “key worker housing to support surrounding employment sites”. This is an essential component of maintaining the functioning of the life sciences cluster, which is experiencing acute recruitment challenges linked to housing affordability.
To strengthen the policy, we recommend:

Requested Amendment
Add to S/GF(7)(f)(i):
“Provision for key worker housing should be secured through a defined delivery strategy, with early phases prioritising accommodation that meets the needs of employers at Granta Park, Babraham Research Campus and other strategic R&D facilities within the Rural Southern Cluster.”

2. Concern: Long Lead In Time and Misalignment With Employment Needs
The planning, infrastructure delivery, and phasing requirements for a new settlement of this scale mean that homes may not come forward until the late 2030s or beyond. This creates a significant temporal mismatch with the immediate and growing workforce accommodation needs at Granta Park.
Without early delivery mechanisms, the policy risks failing to address the structural housing shortages affecting life sciences recruitment across Cambridge’s southern cluster.

An alternative approach to key worker housing to service Granta Park should be considered with the opportunity to promote nearby sites within a shorter timescale. The applicant has previously promoted a site within their ownership called land at Bancroft Park immediately to the north of the Granta Park site, which would be suitable for limited key worker housing development, which we would welcome further discussions.

Requested Amendment
Introduce text under Lifespan / Phasing (paras 22–24):

“The phasing plan must demonstrate how key worker housing can be delivered in the early phases of the development to address existing needs within the Rural Southern Cluster, including Granta Park, and should consider temporary and meanwhile housing solutions where appropriate.”

This ensures the Local Plan acknowledges the importance of timely delivery and avoids reliance on slow, late-stage phases.

3. Deliverability and Certainty of Provision
Policy S/GF is currently silent on the quantum, delivery vehicle, tenure, and control mechanisms for key worker housing. Without these, provision risks dilution through viability negotiation or competing priorities.
Biomed Realty suggests the inclusion of clear safeguards.

Requested Amendment
Insert a new clause under the Uses section:
“A Key Worker Housing Delivery Strategy will be required at outline planning stage, setting out the quantum, tenure mix, nomination arrangements, and delivery programme for key worker accommodation linked to major employment sites including Granta Park.”
This provides transparency and long term certainty for employers.

4. Relationship With Employment Clusters
The policy acknowledges the settlement’s location within the Rural Southern Cluster but does not explicitly tie key worker housing supply to strategic sites of national importance, especially Granta Park.
Biomed Realty supports stronger alignment between housing and employment delivery.

Suggested Strengthening of Para. 2
“Given its location at the heart of the Rural Southern Cluster—a globally significant life sciences hub—the development must prioritise early delivery of key worker housing to support the operational needs of Granta Park and surrounding R&D campuses.”

5. Mechanisms to Safeguard Key Worker Supply Over Time
Experience across Cambridge shows that without safeguards, “key worker housing” often becomes general housing stock over time.

Requested Policy Addition
Add a requirement under Lifespan / Management (para 24):
“The Stewardship and Management Plan must include measures to safeguard the long term availability of key worker housing for eligible employees at local science and research institutions.”
This ensures continuity across the life of the new settlement.

Summary of Key Representation Points

Biomed Realty supports the inclusion of key worker housing and recognises the strategic importance of Grange Farm to the southern R&D cluster

BUT requests policy changes to:
• ensure early delivery of key worker homes
• provide certainty and enforceability via a delivery strategy
• tie provision explicitly to Granta Park and other science campuses
• prevent dilution over time through stewardship requirements

Full text:

BioMed Realty supports the allocation of Grange Farm as a new settlement and welcomes the inclusion of key worker housing to serve the surrounding life‑science cluster. However, the long lead‑in time means homes may not be delivered until the late 2030s, creating a mismatch with the immediate workforce needs of Granta Park. Clear delivery mechanisms, early phasing and safeguards are required to ensure key worker housing is provided promptly, tied directly to major R&D campuses, and protected over time. Alternative nearby sites, such as Bancroft Park, should also be considered to meet urgent accommodation needs.

Object

Draft Greater Cambridge Local Plan for consultation

Policy S/AMC/GP: Granta Park

Representation ID: 203553

Received: 29/01/2026

Respondent: BMR GRANTA PARK PROPCO LIMITED

Agent: Carter Jonas

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

BioMed Realty is concerned that relying on key worker housing at Grange Farm will not meet the urgent accommodation needs of Granta Park, as delivery is unlikely before the late 2030s. This creates a major timing mismatch for the life sciences workforce. A more flexible approach is required, allowing earlier delivery through nearby sites such as Bancroft Park (HELAA ID 115250), which is within the applicant’s control and suitable for limited key worker housing. This approach parallels established exception‑site principles, enabling development to meet demonstrable local need. The policy should support such employment‑linked exception‑style schemes adjoining Granta Park.

Change suggested by respondent:

Policy S/AMC/GP: Granta Park (Supporting Infrastructure)

BioMed Realty is concerned about the long lead in time and misalignment between the timing of key worker housing at Grange Farm and the immediate accommodation needs of the Granta Park workforce. Given the scale, infrastructure requirements and phasing of the new settlement, key worker homes are unlikely to be delivered until the late 2030s or later, creating a significant temporal gap for an employment cluster experiencing acute recruitment pressures.

To address this, the Local Plan should support alternative mechanisms capable of delivering key worker housing within a shorter timeframe. Land within BioMed Realty’s control—such as the Bancroft Park site (HELAA ID: 115250), immediately north of Granta Park—offers a realistic and deliverable opportunity. The site could accommodate a modest, well designed key worker housing scheme that directly responds to operational needs at the campus.

This approach has clear parallels with established ‘exception site’ principles, where development is enabled outside settlement boundaries to meet demonstrable local needs that cannot otherwise be met through the plan led supply. A targeted employment linked exception style scheme would provide an appropriate, policy responsive route to deliver essential housing for Granta Park in advance of the significantly longer term delivery horizon at Grange Farm.

BioMed Realty therefore requests that the Council re assesses the strategy for key worker provision and incorporates a flexible policy framework that recognises the importance of early delivery on well located sites adjoining Granta Park, where proposals accord with wider emerging Local Plan policies.

Full text:

BioMed Realty is concerned that relying on key worker housing at Grange Farm will not meet the urgent accommodation needs of Granta Park, as delivery is unlikely before the late 2030s. This creates a major timing mismatch for the life sciences workforce. A more flexible approach is required, allowing earlier delivery through nearby sites such as Bancroft Park (HELAA ID 115250), which is within the applicant’s control and suitable for limited key worker housing. This approach parallels established exception‑site principles, enabling development to meet demonstrable local need. The policy should support such employment‑linked exception‑style schemes adjoining Granta Park.

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