Draft Greater Cambridge Local Plan for consultation

The attached letter sets out Railpen’s suggested amendments in full.

Railpen proposes the following amended wording to replace the existing text in the draft Local Plan:

a. where it will not prejudice the comprehensive and coordinated development of the wider area, having regard to key local strategies and frameworks

b. where the development is based on clearly articulated and justified objectives and an appropriate level of
coordination which may include strategies and/or other overarching coordination documents;

c. in instances where the infrastructure provision is to be phased, the development demonstrates that necessary infrastructure will be delivered in a timely and appropriate manner

This alternative approach retains the Council’s objective of coordinated development while ensuring that the policy
remains flexible, proportionate, and deliverable. It avoids placing unreasonable obligations on individual landowners and better reflects the realities of development delivery in Cambridge and so better support the timely and effective delivery of the Areas of Major Change.

On behalf of our client, Railpen, we submit the following representation in response to the emerging Local Plan policy wording relating to Areas of Major Change. The wording as currently drafted is provided below:

Part 2
“2. Additionally, development will only be permitted:
a. where it is in accordance with a comprehensive implementation plan for the area which has demonstrable support
from all key landowners, or it is supported by evidence to demonstrate that the comprehensive and successful delivery
of the development can still take place without this being secured;
b. where the development is based on clearly articulated and justified objectives and approach through the provision of
a site-wide masterplan, strategies and/or other over-arching coordination documents;
c. in instances where the infrastructure provision is to be phased, an approved phasing strategy is in place.”

Response to part a and b (Comprehensive implementation plan and landowner support)
Railpen supports the principle of coordinated development and recognises the importance of comprehensive planning in appropriate circumstances. However, the additional criteria set out in points (a)–(c) impose unnecessary and disproportionate requirements that risk undermining the deliverability, flexibility, and effectiveness of development-on development sites. The policy does not acknowledge that different sites are at different stages; some yet to come forward through planning and some very advanced. For example, the Beehive Centre has a recent planning permission with extensive coordinating documents within it. There is no need or benefit to now suggest a new requirement on the Beehive Centre to provide documents to directly address parts a of the policy.

Response to part c (mandatory phasing strategy)

The blanket requirement for a site-wide masterplan and associated coordination documents is not proportionate in all circumstances. The policy fails to distinguish between large, complex, multi-landowner regeneration areas and sites where incremental or phased development is entirely appropriate. This approach risks over-prescription, reducing flexibility and responsiveness to market conditions and evolving delivery opportunities.
The requirement for an approved phasing strategy wherever infrastructure provision is phased is unnecessarily
restrictive. Requiring approval of a phasing strategy at an early stage may constrain otherwise viable schemes and introduce avoidable delay. The policy should instead focus on ensuring that infrastructure is delivered in a timely and coordinated manner, rather than mandating a specific mechanism.

The attached letter sets out Railpen’s suggested amendments in full.

To improve clarity and ensure the policy better reflects the site’s strategic role and planned evolution, Railpen proposes the following amended wording to replace the existing text of the policy in the draft Local Plan:

Part 1:
Development proposals across this policy area, will be supported if they
“A. create a positive, balanced and attractive environment, to support the successful regeneration of the site and its integration with the surrounding area
C. support the delivery of public realm improvements, adopting an integrated approach towards public realm and
streetscape design which responds positively to the surrounding context and, where reasonably practicable, has regard to adjacent development proposals.

Part 2:
a. “a clear set of development and environmental objectives to guide the site’s re-configuration over the short, medium and long-term;
b. a material improvement in the quality of the site’s environment and public realm to support the overall regeneration of the area. This should include providing equipment to support outdoor cultural activities”

Part 3:
Where feasible, proposals should:
a. Take opportunities to improve the connectivity with the surrounding neighbourhoods;
c. where feasible and proportionate, having regard to timing and certainty of local infrastructure projects provide a
movement strategy integrating with any proposals in the wider area.

Para 3.1.131
The former Beehive Centre area provides an important edge-of-centre brownfield site for intensification
for a range of uses that complement the adjacent residential and retail park uses. This reconfiguration and
intensification of uses affords the site many opportunities to improve its accessibility within the site and beyond,
including access to Cambridge Retail Park which should be maximised to encourage the use of sustainable forms of transport to access the area and help reduce vehicular congestion. The area’s long-term strategy is also expected to improve the area’s environment and appeal for residents, local workers and visitors from further afield.

In December 2025, the Secretary of State granted planning permission for a comprehensive redevelopment of the site, comprising a commercial R&D-led scheme including a new local centre, significant public realm, a new public park and enhanced connectivity. That consented scheme is supported by approved phasing plans and a coordinated, site-wide approach to future development, which together meet the policy expectations for a Comprehensive Implementation Plan and an overarching development and environmental strategy framework.

Para 3.1.132
“All short-to-medium proposals should have regard for the site’s long-term ambition. Relevant public realm, landscape, movement and servicing strategies should consider how these have regard for these progressive stages and remain consistent with the area’s clear set of development and environmental requirements , to ensure a cohesive approach to the site’s comprehensive redevelopment.”

On behalf of our client, Railpen, we submit the following representation in response to the emerging Local Plan policy wording relating to Policy S/AMC/BC: Beehive Centre.

Railpen suggests amendments to the wording of Policy S/AMC/BC part 1 (a and c). The wording as currently drafted is provided below:

“1. Development proposals across this policy area, will be supported if they:
A. create a positive, balanced and attractive environment, to support the vitality and viability of this area;”
C. support the delivery of public realm improvements, adopting an integrated approach towards public realm and
streetscape design, linked to adjacent development proposals;

Response to part a:
The intention and practical application of this criterion is unclear. The terms “vitality and viability” (part a) are well
established planning concepts, most commonly used in the assessment of town centre and retail uses. As currently
drafted, the criterion risks creating uncertainty and ambiguity for decision-makers and applicants, particularly given the scale and mixed-use nature of the proposed redevelopment. While ‘vitality and viability’ have a strong foundation in retail policy, the policy (and the extant planning permission for the site) is to reduce/remove the amount of retail floorspace. Policies should be sufficiently precise to provide clarity and certainty, particularly where they are intended to guide large-scale, long-term redevelopment.

Response to part c:
Additionally, the requirement to link public realm and streetscape design to “adjacent development proposals” (part c) introduces a level of dependency on third-party land, perhaps separate ownerships, and future proposals over which an individual applicant may have no control. As currently drafted, the policy risks undermining deliverability by implying that development proposals could be required to coordinate with, or be contingent upon, adjacent sites coming forward in a particular form or timeframe. It also risks delaying otherwise acceptable development where adjacent proposals
are uncertain, evolving, or not progressing. Policies must be effective, deliverable and flexible

Part 2.
2. Railpen suggests amendments to the wording of Policy S/AMC/BC part 2 (a and b). The wording as currently drafted
is provided below:
Any proposals to reconfigure the retail park to provide alternative uses must include:
A. “an overarching development and environmental strategy framework to guide the site’s re-configuration over
the short, medium and long-term;
b. a material improvement in the quality of the site’s environment and public realm to support the overall vitality
and viability of the area. This should include providing external plant equipment to support outdoor cultural
activities”

Response to part a:
As drafted, the requirement for an “overarching development and environmental strategy framework” lacks clarity and precision. The term is undefined within the Local Plan and does not correspond to any commonly recognised planning document, which creates uncertainty for applicants and decision-makers as to its scope, content, level of detail, and
status within the decision-making process. This ambiguity risks placing an open-ended and potentially onerous burden on development proposals, contrary to the requirement for planning policies to be clear, justified and effective.

Response to part b:
The terms “vitality and viability” are well-established planning concepts, most commonly used in the assessment of
town centre and retail uses. As currently drafted, the criterion risks creating uncertainty and ambiguity for decision
makers and applicants, particularly given the scale and mixed-use nature of the proposed redevelopment. While
‘vitality and viability’ have a strong foundation in retail policy, the policy (and the extant planning permission for the site) is to reduce/remove the amount of retail floorspace. Policies should be sufficiently precise to provide clarity and certainty, particularly where they are intended to guide large-scale, long-term redevelopment.

Part 3
3. Railpen requests amendments to the wording of Policy S/AMC/BC parts 3 (a and b). The wording as currently
drafted is provided below:
Where feasible, proposals should:
a. create better east-west and north-south connections, improving the area’s links with the surrounding
neighbourhoods;
c. provide a movement strategy integrating with any proposals the Greater Cambridge Partnership may have for the
wider area.

The reference to east–west connections fail to acknowledge the presence of the railway line along the site’s eastern
boundary. In addition, the future role of the Greater Cambridge Partnership is uncertain, and references to it should
therefore be removed.

Supporting text

Para 3.1.131 The former Beehive Centre area provides an important edge-of-centre brownfield site for intensification for a range of uses that complement the adjacent residential and retail park uses. This reconfiguration and intensification of uses affords the site many opportunities to improve its accessibility within the site and beyond, including access to Cambridge Retail Park which should be maximised to encourage the use of sustainable forms of transport to access the area and help reduce vehicular congestion. The area’s long-term strategy is also expected to improve the area’s environment and appeal for residents, local workers and visitors from further afield.

The policy does not adequately reflect the Secretary of State’s December 2025 decision granting planning permission for a comprehensive redevelopment of the site, which included a commercial R&D scheme, a new local centre, significant public realm improvements, a new public park, and enhanced connectivity.

Para 3.1.132
Railpen suggests amendments to the wording of Policy S/AMC/BC para 3.1.132
“All short-to-medium proposals should have regard for the site’s long-term ambition. Relevant public realm, landscape, movement and servicing strategies should consider how these have regard for these progressive stages and remain consistent with the area’s agreed overarching development and environmental strategy framework, to ensure a cohesive approach to the site’s comprehensive redevelopment.”
The reference to an “overarching development and environmental strategy framework” is unclear, as the policy does not define what it is, when it is required, or the purpose it is intended to serve, creating uncertainty for applicants and decision-makers.

The attached letter sets out Railpen’s suggested amendments in full.

On behalf of our client, Railpen, we request that the former Beehive Centre site is excluded from the list of designated
Retail Centres in the Local Plan. Designating the site as a Retail Centre creates a direct policy conflict with the
Council’s ambition to achieve a comprehensive, major redevelopment of the site, which includes a commercial R&D
led scheme, a new local centre, enhanced public realm, and improved connectivity.

On behalf of our client, Railpen, we submit the following representation in response to the emerging Local Plan policy wording relating to Policy J/RC: Retail and other complementary town centre uses.

Railpen objects to the inclusion of Policy J/RC part 5. The wording as currently drafted is provided below:

Across Greater Cambridge’s network of centres (excluding the Primary Shopping Area), proposals that would result in the loss of any retail or other main town centre use or in the reconfiguration of separate planning units through the merging of two or more units or sub-division of a unit will only be supported where:

a. there is no market demand for the existing unit(s) or potential replacement unit(s) of the same size and use, as
demonstrated through an up-to-date marketing exercise for at least 12 months in accordance with the guidance
provided in Appendix G: Marketing, local needs assessments and viability appraisals of this Local Plan demonstrating that the premises are not reasonably capable of being used or redeveloped for a town centre use acceptable in the centre; or

b. evidence is submitted that demonstrates the new use or reconfiguration of planning units (through merger or sub
division) would:
i. meet an identified need for alternative community, retail or leisure facilities;
ii. contribute positively to the vitality, viability and diversity of the centre; and
iii. not result in significant adverse impacts on surrounding uses
the additional criteria set out in policy J/RC impose unnecessary and disproportionate requirements that risk
undermining the deliverability, flexibility, and effectiveness of development on the site. Policies should allow for greater flexibility and not impose unnecessary constrain, which may lead to empty units.

On behalf of our client, Railpen, we request that the former Beehive Centre site is excluded from the list of designated Retail Centres in the Local Plan. Designating the site as a Retail Centre creates a direct policy conflict with the Council’s ambition to achieve a comprehensive, major redevelopment of the site, which includes a commercial R&D led scheme, a new local centre, enhanced public realm, and improved connectivity.

Railpen proposes the following amended wording to replace the existing text in the draft Local Plan:

“Additionally, development will only be permitted:
a. where it will not prejudice the comprehensive and coordinated development of the wider area, having regard to key local strategies and frameworks
b. where the development is based on clearly articulated and justified objectives and an appropriate level of coordination which may include strategies and/or other over-arching coordination documents;
c. in instances where the infrastructure provision is to be phased, the development demonstrates that necessary infrastructure will be delivered in a timely and appropriate manner”

This alternative approach retains the Council’s objective of coordinated development while ensuring that the policy remains flexible, proportionate, and deliverable. It avoids placing unreasonable obligations on individual landowners and better reflects the realities of development delivery in Cambridge and so better support the timely and effective delivery of the Areas of Major Change.”

On behalf of our client, Railpen, we submit the following representation in response to the emerging Local Plan policy wording relating to Areas of Major Change. The wording as currently drafted is provided below:

Part 2

“2. Additionally, development will only be permitted:

a. where it is in accordance with a comprehensive implementation plan for the area which has demonstrable support from all key landowners, or it is supported by evidence to demonstrate that the comprehensive and successful delivery of the development can still take place without this being secured;

b. where the development is based on clearly articulated and justified objectives and approach through the provision of a site-wide masterplan, strategies and/or other over-arching coordination documents;

c. in instances where the infrastructure provision is to be phased, an approved phasing strategy is in place.”

Response to part a and b (Comprehensive implementation plan and landowner support)

Railpen supports the principle of coordinated development and recognises the importance of comprehensive planning in appropriate circumstances. However, the additional criteria set out in points (a)–(c) impose unnecessary and disproportionate requirements that risk undermining the deliverability, flexibility, and effectiveness of development-on-development sites. The policy does not acknowledge that different sites are at different stages; some yet to come forward through planning and some very advanced. For example, the Beehive Centre has a recent planning permission with extensive coordinating documents within it. There is no need or benefit to now suggest a new requirement on the Beehive Centre to provide documents to directly address parts a of the policy.

Response to part c (mandatory phasing strategy)

The blanket requirement for a site-wide masterplan and associated coordination documents is not proportionate in all circumstances. The policy fails to distinguish between large, complex, multi-landowner regeneration areas and sites where incremental or phased development is entirely appropriate. This approach risks over-prescription, reducing flexibility and responsiveness to market conditions and evolving delivery opportunities.

The requirement for an approved phasing strategy wherever infrastructure provision is phased is unnecessarily restrictive. Requiring approval of a phasing strategy at an early stage may constrain otherwise viable schemes and introduce avoidable delay. The policy should instead focus on ensuring that infrastructure is delivered in a timely and coordinated manner, rather than mandating a specific mechanism.

To improve clarity and ensure the policy better reflects the site’s strategic role and planned evolution, Railpen proposes the following amended wording to replace the existing text in the draft Local Plan:

Part 1:
“Development proposals across this policy area, will be supported if they:
a. create a positive, balanced and attractive environment, to support the successful regeneration of the site and its integration with the surrounding area

c. support the delivery of public realm improvements, adopting an integrated approach towards public realm and streetscape design which responds positively to the surrounding context and, where reasonably practicable, has regard to adjacent development proposals.”

Part 2:
To improve clarity and ensure the policy better reflects the site’s strategic role and planned evolution, Railpen proposes the following amended wording to replace the existing text in the draft Local Plan:

a. “a clear set of development and environmental objectives to guide the site’s re-configuration over the short, medium and long-term;

b. a material improvement in the quality of the site’s environment and public realm to support the overall regeneration of the area. This should include providing equipment to support outdoor cultural activities”

Part 3:
Railpen proposes the following amended wording to replace the existing text in the draft Local Plan:

“Where feasible, proposals should:

a. Take opportunities to improve the connectivity with the surrounding neighbourhoods;

c. where feasible and proportionate, having regard to timing and certainty of local infrastructure projects provide a movement strategy integrating with any proposals in the wider area.”

Supporting Information
Para 3.1.131

Para 3.1.131 The former Beehive Centre area provides an important edge-of-centre brownfield site for intensification for a range of uses that complement the adjacent residential and retail park uses. This reconfiguration and intensification of uses affords the site many opportunities to improve its accessibility within the site and beyond, including access to Cambridge Retail Park which should be maximised to encourage the use of sustainable forms of transport to access the area and help reduce vehicular congestion. The area’s long-term strategy is also expected to improve the area’s environment and appeal for residents, local workers and visitors from further afield.

In December 2025, the Secretary of State granted planning permission for a comprehensive redevelopment of the site, comprising a commercial R&D-led scheme including a new local centre, significant public realm, a new public park and enhanced connectivity. That consented scheme is supported by approved phasing plans and a coordinated, site-wide approach to future development, which together meet the policy expectations for a Comprehensive Implementation Plan and an overarching development and environmental strategy framework.

Para 3.1.132
“All short-to-medium proposals should have regard for the site’s long-term ambition. Relevant public realm, landscape, movement and servicing strategies should consider how these have regard for these progressive stages and remain consistent with the area’s clear set of development and environmental requirements to ensure a cohesive approach to the site’s comprehensive redevelopment.”

On behalf of our client, Railpen, we submit the following representation in response to the emerging Local Plan policy wording relating to Policy S/AMC/BC: Beehive Centre.

Railpen suggests amendments to the wording of Policy S/AMC/BC part 1 (a and c). The wording as currently drafted is provided below:
“1. Development proposals across this policy area, will be supported if they:
a. create a positive, balanced and attractive environment, to support the vitality and viability of this area;
c. support the delivery of public realm improvements, adopting an integrated approach towards public realm and streetscape design, linked to adjacent development proposals;”

Response to part a:
The intention and practical application of this criterion is unclear. The terms “vitality and viability” (part a) are well-established planning concepts, most commonly used in the assessment of town centre and retail uses. As currently drafted, the criterion risks creating uncertainty and ambiguity for decision-makers and applicants, particularly given the scale and mixed-use nature of the proposed redevelopment. While ‘vitality and viability’ have a strong foundation in retail policy, the policy (and the extant planning permission for the site) is to reduce/remove the amount of retail floorspace. Policies should be sufficiently precise to provide clarity and certainty, particularly where they are intended to guide large-scale, long-term redevelopment.

Response to part c:
Additionally, the requirement to link public realm and streetscape design to “adjacent development proposals” (part c) introduces a level of dependency on third-party land, perhaps separate ownerships, and future proposals over which an individual applicant may have no control. As currently drafted, the policy risks undermining deliverability by implying that development proposals could be required to coordinate with, or be contingent upon, adjacent sites coming forward in a particular form or timeframe. It also risks delaying otherwise acceptable development where adjacent proposals are uncertain, evolving, or not progressing. Policies must be effective, deliverable and flexible.

Part 2.
2. Railpen suggests amendments to the wording of Policy S/AMC/BC part 2 (a and b). The wording as currently drafted is provided below:
Any proposals to reconfigure the retail park to provide alternative uses must include:
a. “an overarching development and environmental strategy framework to guide the site’s re-configuration over the short, medium and long-term;
b. a material improvement in the quality of the site’s environment and public realm to support the overall vitality and viability of the area. This should include providing external plant equipment to support outdoor cultural activities”

Response to part a:
As drafted, the requirement for an “overarching development and environmental strategy framework” lacks clarity and precision. The term is undefined within the Local Plan and does not correspond to any commonly recognised planning document, which creates uncertainty for applicants and decision-makers as to its scope, content, level of detail, and status within the decision-making process. This ambiguity risks placing an open-ended and potentially onerous burden on development proposals, contrary to the requirement for planning policies to be clear, justified and effective.

Response to part b:
The terms “vitality and viability” are well-established planning concepts, most commonly used in the assessment of town centre and retail uses. As currently drafted, the criterion risks creating uncertainty and ambiguity for decision-makers and applicants, particularly given the scale and mixed-use nature of the proposed redevelopment. While ‘vitality and viability’ have a strong foundation in retail policy, the policy (and the extant planning permission for the site) is to reduce/remove the amount of retail floorspace. Policies should be sufficiently precise to provide clarity and certainty, particularly where they are intended to guide large-scale, long-term redevelopment.

Part 3
3. Railpen requests amendments to the wording of Policy S/AMC/BC parts 3 (a and b). The wording as currently drafted is provided below:
Where feasible, proposals should:
a. create better east-west and north-south connections, improving the area’s links with the surrounding neighbourhoods;
c. provide a movement strategy integrating with any proposals the Greater Cambridge Partnership may have for the wider area.

The reference to east–west connections fails to acknowledge the presence of the railway line along the site’s eastern boundary. In addition, the future role of the Greater Cambridge Partnership is uncertain, and references to it should therefore be removed.

Supporting text
Railpen suggests amendments to the wording of Policy S/AMC/BC para 3.1.131, not least to acknowledge the important fact that the site received consent from the Secretary of State for the comprehensive redevelopment of the site. This is a material matter for the context of the policy and must be recognised that the consent defines that development and what is required from it.

Para 3.1.131 The former Beehive Centre area provides an important edge-of-centre brownfield site for intensification for a range of uses that complement the adjacent residential and retail park uses. This reconfiguration and intensification of uses affords the site many opportunities to improve its accessibility within the site and beyond, including access to Cambridge Retail Park which should be maximised to encourage the use of sustainable forms of transport to access the area and help reduce vehicular congestion. The area’s long-term strategy is also expected to improve the area’s environment and appeal for residents, local workers and visitors from further afield.

The policy does not adequately reflect the Secretary of State’s December 2025 decision granting planning permission for a comprehensive redevelopment of the site, which included a commercial R&D scheme, a new local centre, significant public realm improvements, a new public park, and enhanced connectivity.
Supporting Information

Para 3.1.132
Railpen suggests amendments to the wording of Policy S/AMC/BC para 3.1.132

“All short-to-medium proposals should have regard for the site’s long-term ambition. Relevant public realm, landscape, movement and servicing strategies should consider how these have regard for these progressive stages and remain consistent with the area’s agreed overarching development and environmental strategy framework, to ensure a cohesive approach to the site’s comprehensive redevelopment.”

The reference to an “overarching development and environmental strategy framework” is unclear, as the policy does not define what it is, when it is required, or the purpose it is intended to serve, creating uncertainty for applicants and decision-makers.

A full representation is shown in the attached document.

Railpen request that the former Beehive Centre site is excluded from the list of designated Retail Centres in the Local Plan. Designating the site as a Retail Centre creates a direct policy conflict with the Council’s ambition to achieve a comprehensive, major redevelopment of the site, which includes a commercial R&D-led scheme, a new local centre, enhanced public realm, and improved connectivity.

Railpen objects to the wording of para 8.92 related to Policy J/RC

The supporting text makes reference to certain restrictions that the Council might put in place to reduce the permitted development rights of a scheme in main town centres. Railpen objects to the policy, on the grounds that greater flexibility should be offered to avoid the potential for empty shop locations, enhance deliverability and align with the goals on flexibility within the NPPF.

On behalf of our client, Railpen, we submit the following representation in response to the emerging Local Plan policy wording relating to Policy J/RC: Retail and other complementary town centre uses.

Railpen objects to the inclusion of the Beehive Centre in Policy J/RC part 5. The wording as currently drafted is provided below:

Across Greater Cambridge’s network of centres (excluding the Primary Shopping Area), proposals that would result in the loss of any retail or other main town centre use or in the reconfiguration of separate planning units through the merging of two or more units or sub-division of a unit will only be supported where:

a. there is no market demand for the existing unit(s) or potential replacement unit(s) of the same size and use, as demonstrated through an up-to-date marketing exercise for at least 12 months in accordance with the guidance provided in Appendix G: Marketing, local needs assessments and viability appraisals of this Local Plan demonstrating that the premises are not reasonably capable of being used or redeveloped for a town centre use acceptable in the centre; or

b. evidence is submitted that demonstrates the new use or reconfiguration of planning units (through merger or sub-division) would:
i. meet an identified need for alternative community, retail or leisure facilities;
ii. contribute positively to the vitality, viability and diversity of the centre; and
iii. not result in significant adverse impacts on surrounding uses

The additional criteria set out in policy J/RC impose unnecessary and disproportionate requirements that risk undermining the deliverability, flexibility, and effectiveness of development on the site. Policies should allow for greater flexibility and not impose unnecessary constrain, which may lead to empty units.

On behalf of our client, Railpen, we request that the former Beehive Centre site is excluded from the list of designated Retail Centres in the Local Plan. Designating the site as a Retail Centre creates a direct policy conflict with the Council’s ambition to achieve a comprehensive, major redevelopment of the site, which includes a commercial R&D-led scheme, a new local centre, enhanced public realm, and improved connectivity.

Greater Cambridge’s Hierarchy of Designated Centres

Railpen objects to the wording of para 8.92 related to Policy J/RC
The supporting text makes reference to certain restrictions that the Council might put in place to reduce the permitted development rights of a scheme in main town centres. Railpen objects to the policy, on the grounds that greater flexibility should be offered to avoid the potential for empty shop locations, enhance deliverability and align with the goals on flexibility within the NPPF.

A full representation is shown in the attached document.

it is requested that part 1 is amended as shown below:
c. help sustain or deliver facilities and amenities appropriate to function and character of the area

Railpen’s suggests amends to part 3 and para 3.1.156, suggested wording is provided below:

3. “where proposals provide opportunities and potential challenges, site promoters should develop a
steering document, approved by the planning authority as part of a planning application to promote and guide overall change during the life of the plan for the relevant area”

Para 3.1.156 “it is recognised that while development can improve an area’s attractiveness it can also challenge the area’s character, in such circumstances site promoters are encouraged to develop a steering document to guide the area’s reconfiguration. Site specific policies requirements are also included, to highlight key local characteristics along with short and long-term opportunities and area aspirations that development should take account of as part of any planning application.”

A full representation is shown in the attached document.

On behalf of our client, Railpen, we submit the following representation in response to the emerging Local Plan policy wording relating to Policy S/PRIA: Public Realm Improvement Areas (PRIA) in Cambridge.

Part 1.
Railpen suggests amendments to the wording of part 1(c) of policy S/PRIA worded below:

c. help sustain or deliver local shops and services.

The reference to local shops is not sufficiently clear or defined in planning policy. Each PRIA is different and it is not evident that all PRIAs should ‘help sustain or deliver local shops and services’.

Part 3:
Railpen suggests amendments to the wording of part 3 and para 3.1.156 of policy S/PRIA worded below:

Part 3 “Where proposals provide opportunities and potential challenges, site promoters should develop a policy framework, approved by the planning authority to promote and guide overall change during the life of the plan for the relevant area.”

Para 3.1.156 “it is recognised that while development can improve an area’s attractiveness it can also challenge the area’s character, in such circumstances site promoters are encouraged to develop a policy framework to guide the area’s reconfiguration. Site specific policies requirements are also included, to highlight key local characteristics along with short and long-term opportunities and area aspirations that development should take account of as part of any planning application.”

We recommend that the wording be amended to refer instead to “steering document(s)”. This would achieve the same objective of guiding and coordinating change over the life of the plan, while providing a more practical, flexible and deliverable mechanism aligned with the comprehensive approach already established; such as at Cambridge Retail Park (CRP) and its already formed Framework Document. The content and full intentions of a policy framework is not clear, but infers an unnecessary degree of additional policy layered over the Local Plan.

Railpen suggests the following amendments to the wording of the policy:

Part 1:
Respond positively with both the adjacent Beehive Centre development (Policy Ref. S/AMC/BC:) and the surrounding neighbourhoods;

Part 2:
2a) “Where proposals provide opportunities and potential challenges, site promoters should develop a
steering document approved by the planning authority to promote and guide overall change during the life of the plan for the relevant area.”
2c) An improved design approach that responds positively to the adjacent areas”

Part 3:
“a. Take opportunities to improve the connectivity with the surrounding neighbourhoods;
c. where feasible and proportionate, having regard to timing and certainty of local infrastructure projects provide a movement strategy integrating with any proposals in the wider area.”

Part 4:
"An urban design led approach should be taken to inform the appropriate scale and massing of development proposals in the policy area. Studies will also be required to show that land use proposals will be in accordance with the approved steering document on a proposal-by-proposal basis."

paragraph 3.1.159:
It is, however recognised that the site is subject to many constraints related to the current leaseholders on site that may limit these opportunities, in the short to medium term. However, all short to the medium proposals should have regard for the site’s long term ambition. Relevant public realm, landscape, movement and servicing strategies should consider how these have regard for these progressive stages and remain consistent with the area’s agreed
steering document, to ensure a cohesive approach to the park’s evolution, ensuring it remains ‘open for business’ throughout.

On behalf of our client, Railpen, we submit the following representation in response to the emerging Local Plan policy wording relating to S/PRIA/CRP: Public Realm Improvement Areas (PRIA).

Part 1:
Railpen suggests amendments to the wording of part 1(b) of policy S/PRIA/CRP worded below:

b. integrate positively with both the adjacent Beehive Centre development (Policy Ref. S/AMC/BC:) and the surrounding neighbourhoods;

Reference to sufficient integration between CRP and Beehive is not sufficiently clear or measurable as a policy objective.

Part 2:
2. Railpen suggests amendments to the wording of part 2 (a and c) of policy S/PRIA/CRP worded below:
2a) “Where proposals provide opportunities and potential challenges, site promoters should develop a policy framework, approved by the planning authority to promote and guide overall change during the life of the plan for the relevant area.”
2c) “a better urban relationship with Newmarket Road, the Beehive Centre development and the surrounding neighbourhoods.

We request that the wording be amended to refer instead to “steering document(s)”. This would achieve the same objective of guiding and coordinating change over the life of the plan, while providing a more practical, flexible and deliverable mechanism aligned with the comprehensive approach already established at Cambridge Retail Park (CRP) through is already formed Framework Document.

Railpen recommends that part c of the wording is amended to overcome the uncertainty for what an ‘urban relationship’ is and rather provide a clearer policy direction that any future application that comes forward will respond positively to the adjacent area.

Part 3:

3. Railpen suggests amendments to the wording of part 3 (a and c) of policy S/PRIA/CRP worded below:
“Where feasible, proposals should:
a. create better east-west and north-south connections, improving the area’s links with the surrounding neighbourhoods;
c. provide a movement strategy integrating with any proposals the Greater Cambridge Partnership may have for the wider area.”
The reference to east–west connections fails to acknowledge the presence of the railway line along the site’s eastern boundary. In addition, the future role of the Greater Cambridge Partnership is uncertain, and references to it should therefore be removed.

Part 4:
Railpen suggests amendments to the wording of part 4 of policy S/PRIA/CRP to remove the reference to steering documents.

Supporting Information
3.1.159 Railpen requests amendments to the wording of para 3.1.159 of policy S/PRIA/CRP worded below:
It is, however recognised that the site is subject to many constraints related to the current leaseholders on site that may limit these opportunities, in the short-to-medium term. However, all short-to-medium proposals should have regard for the site’s long-term ambition. Relevant public realm, landscape, movement and servicing strategies should consider how these have regard for these progressive stages and remain consistent with the area’s agreed overarching development and environmental strategy framework, to ensure a cohesive approach to the park's evolution, ensuring it remains 'open for business' throughout.

The requirement for an “overarching development and environmental strategy framework” lacks clarity and precision. The term is undefined within the Local Plan and does not correspond to any commonly recognised planning document, which creates uncertainty for applicants and decision-makers as to its scope, content, level of detail, and status within the decision-making process. This ambiguity risks placing an open-ended and potentially onerous burden on development proposals, contrary to the requirement for planning policies to be clear, justified and effective. This must be replaced with a reference to a ‘steering document’ which would better relate to the already formed ‘Cambridge Retail Park Framework Document’.

Amended wording is provided below for precision and clarity:

f. respond positively with to the adjacent Cambridge Retail Park (Policy Ref. S/PRIA/CRP), Beehive Centre (Policy Ref. S/AMC/BC), Fitzroy/Burleigh Street/Grafton Area (Policy Ref. S/AMC/FBG) and surrounding neighbourhoods.

Railpen supports the policy and its reference in Part 1 to the Beehive Centre and Cambridge Retail Park and how the Eastern Gate area and adjoining or nearby sites can collectively deliver a greater beneficial impact to the local area.

Railpen requests an amendment to Part 1 (f) of policy S/PRIA/EG as currently worded below:

f. integrate positively with the adjacent Cambridge Retail Park (Policy Ref. S/PRIA/CRP), Beehive Centre (Policy Ref. S/AMC/BC), Fitzroy/Burleigh Street/Grafton Area (Policy Ref. S/AMC/FBG) and surrounding neighbourhoods.
References to ‘integration’ is not sufficiently clear or measurable as a policy objective.

the Local Plan should adopt more optimistic yet realistic assumptions for job growth and provide explicit support for higher-growth scenarios; certainly not to act against them. Without such changes, Policy S/JH is unsound and inconsistent with national policy objectives to support sustainable economic growth and improved productivity.

n behalf of our client, Railpen, we submit the following representation in response to policy S/JH part 1 (a and b) of the emerging Local Plan policy wording relating to new jobs and homes.

The provision of 73,300 additional jobs across the plan period should be treated as a minimum requirement rather than a maximum or constraining target. The evidence supporting the policy, set out in the Greater Cambridge Employment and Housing Needs Update 2024–2045 (September 2025), concludes at paragraph 3.55 that the range of scenarios modelled indicates a requirement for between 67,600 and 90,900 additional jobs over the plan period. This represents a notable increase compared with the previous 2023 modelling, which identified a range of between 66,600 and 75,800 jobs. The significant uplift at the upper end of the range demonstrates that economic growth expectations have strengthened markedly rather than diminished.

As set out in the Employment and Housing Needs Update, during the strongest phase of recent growth (2010–2020) the Greater Cambridge economy expanded by almost 4,000 jobs per annum. The Update identifies a ‘Central growth’ scenario of 73,200 jobs over the plan period, equating to sustained annual growth of around 3,500 jobs. Importantly, this scenario incorporates assumptions of slower growth phases, periods of contraction, and economic shocks. As such, it is inherently conservative and does not reflect the full growth potential of the Cambridge economy.

Since the preparation of the evidence base, there have been significant changes in the national and strategic planning policy context that further reinforce the need to plan positively for increased job creation and housing delivery. These changes represent a step-change in the policy framework within which the Draft Local Plan must be assessed. On 23 August 2024, Matthew Pennycook reaffirmed the Government’s commitment to Cambridge, stating: “The economic growth of Cambridge has been a phenomenal success and we should seek to maximise the potential contribution that Greater Cambridge could make to the UK economy.” He further noted that “Greater Cambridge has a vital role to play in this Government’s mission to kickstart economic growth.” In response, the Cambridge Growth Company was established in 2024 to address barriers to growth and help unlock the area’s full economic potential. More recently, in October 2025, the Government announced its intention to consult on the case for a centrally led Development Corporation as a potential delivery mechanism, with statutory consultation planned for 2026.

Greater Cambridge also continues to benefit from strategic infrastructure investment that will further drive demand for employment growth. This includes the proposed East West Rail station, public transport improvements along the Cambourne to Cambridge corridor, and enhancements to the Cambridge Eastern Access corridor. In addition, the Cambridgeshire and Peterborough Local Growth Plan 2025 identifies priority growth sectors and highlights the need for continued investment in skills development, along with the need for agglomerated growth and multiplier affects.

The Employment and Housing Needs Update explicitly acknowledges ‘High’ and ‘High Sensitivity’ scenarios in which growth can meet or exceeds the 2010–2020 trajectory. At 3.62 of the report it says:
‘It is important to acknowledge that the high scenarios could be achieved or exceeded. For this to take place it is considered that a step change in infrastructure investment and development would be needed to facilitate growth, notably in transport to connect in and move labour, as well as in wider services infrastructure and the expansion of both housing and commercial development programmes’.

This is exactly the context Greater Cambridge is in. Never has there been such a focus and commitment to Cambridge from national government. Millions of pounds of investment already taking place and every prospect for much more to come; supported by the Combined Authority and, in short time, a local Development Corporation. The foundations are in place to deliver a high growth scenario set upon a new approach and wave of investment to Greater Cambridge, rather than being led by historic trends within a very different context.

Such levels of growth are demonstrably achievable in Cambridge and align closely with the Government’s stated economic objectives. Higher-growth outcomes therefore remain realistic and should not be excluded by policy. This necessitates a revision to the proposed policy wording.