Draft Greater Cambridge Local Plan for consultation

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Object

Draft Greater Cambridge Local Plan for consultation

Policy S/LAC: Other site allocations in Cambridge

Representation ID: 204121

Received: 30/01/2026

Respondent: Railpen

Agent: Bidwells

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

The respondent represents Railpen and provides feedback on Local Plan Policy S/LAC regarding Other Site Allocations in Cambridge.

The respondent notes that the current wording of the policy should be amended to correct the reference to Cambridge Retail Park from an allocation to a designation, as it is included as a designated Public Realm Improvement Area (PRIA).

The respondent highlights that the indicative dwelling or floorspace capacity for site allocations may vary and should be determined through a design-led approach.

Object

Draft Greater Cambridge Local Plan for consultation

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

Representation ID: 204135

Received: 30/01/2026

Respondent: Railpen

Agent: Bidwells

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

The proposed Local Plan Policy BG/TC on tree canopy cover lacks justification and robust evidence, as the National Planning Policy Framework does not mandate a specific canopy cover target.

Imposing a quantitative tree canopy cover requirement could undermine development capacity, density, and viability, conflicting with national planning policy and growth ambitions.

The existing statutory requirement for a minimum of 10% Biodiversity Net Gain already provides a suitable mechanism for ecological enhancement, making the proposed tree canopy cover requirement redundant.

The policy lacks clarity as it does not specify the approved calculator or methodology for calculating canopy cover, leading to uncertainty.

In the context of Cambridge, a fixed canopy cover threshold could impose an unjustified burden on development, compromising scheme deliverability and the Local Plan's implementation.

The emerging NPPF reform paper indicates that generic quantitative standards should be avoided, as they complicate development and discourage growth.

Object

Draft Greater Cambridge Local Plan for consultation

Policy BG/EO: Providing and enhancing open spaces

Representation ID: 204148

Received: 30/01/2026

Respondent: Railpen

Agent: Bidwells

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

The respondent argues that the Accessible Greenspace standard in Policy BG/EO is too rigid and does not account for the varied operational and spatial needs of commercial development in Greater Cambridge.

They highlight that applying a generic greenspace requirement could hinder efficient site layouts and reduce development capacity, contradicting national policies aimed at supporting economic growth.

The respondent expresses concern that without addressing infrastructure pressures, the demand for research space may lead to science clusters relocating, exacerbating the shortage of laboratory space.

They note that the lack of a defined methodology for calculating greenspace requirements could lead to delays and inconsistencies, negatively impacting the viability and deliverability of commercial projects.

The respondent points out that the proposed generic standard contradicts the emerging NPPF reform, which aims to limit rigid quantitative standards and promote flexibility in development policies.

Object

Draft Greater Cambridge Local Plan for consultation

Policy WS/NC: Meeting the needs of new and growing Communities

Representation ID: 204158

Received: 30/01/2026

Respondent: Railpen

Agent: Bidwells

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

Policy WS/NC requires large residential and employment developments to conduct community needs assessments and engage local stakeholders, but lacks clarity on the specifics of these requirements, creating uncertainty for developers.

The respondent argues that the burden of community needs assessments should be on the Council, not developers, to ensure clarity and consistency in planning.

The proposed requirement for indoor community facilities may threaten the viability of development schemes due to its inflexible application of a fixed floorspace standard of 129m² per 1,000 additional population.

The policy's lack of clarity regarding on-site provision and its interaction with planning obligations and the Community Infrastructure Levy may lead to a cumulative financial burden on developers.

The respondent highlights that the policy conflicts with the National Planning Policy Framework and Planning Practice Guidance by imposing potentially onerous and duplicative requirements that could undermine the deliverability of the Local Plan.

Object

Draft Greater Cambridge Local Plan for consultation

Policy GP/ST: Skyline and tall buildings

Representation ID: 204192

Received: 30/01/2026

Respondent: Railpen

Agent: Bidwells

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

It is necessary to define 'tall buildings' within Policy GP/ST to avoid ambiguity.

Point (b) should be revised to align with the NPPF and accommodate future clusters regarding impacts on the historic environment.

Point (c) needs amendment to ensure the policy does not exceed committed development and remains consistent with guidance.

Point (e) should allow for judgement and planning balance, rather than requiring applicants to demonstrate no impact.

The term 'must' in the criteria for tall buildings should be replaced with 'should' to provide discretion for decision makers.

Changes are needed to reflect Government intentions for effective land use and increased development density.

Object

Draft Greater Cambridge Local Plan for consultation

Policy J/NE: New employment development proposals

Representation ID: 204218

Received: 30/01/2026

Respondent: Railpen

Agent: Bidwells

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

The respondent objects to Policy J/NE, stating it is overly prescriptive and restricts large-scale industrial and logistics development needed for national and regional demands.

Part 7 of Policy J/NE imposes significant constraints on warehousing and distribution, hindering the Plan's adaptability to economic and employment changes.

The respondent argues that Policy J/NE is inconsistent with the draft reformed NPPF, which advocates for flexibility in planning to support long-term economic growth.

Recent appeal decisions highlight the necessity for flexibility in employment land markets, emphasizing that quantitative targets should serve as references rather than strict limits.

The policy's restrictions may prevent sustainable employment proposals from being developed, contradicting national policy and the need for a diverse supply of employment land.

Object

Draft Greater Cambridge Local Plan for consultation

Policy J/AW: Affordable workspace and creative industries

Representation ID: 204230

Received: 30/01/2026

Respondent: Railpen

Agent: Bidwells

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

The requirement for affordable workspace to be available at or prior to the first occupation of 50% of non-affordable floorspace introduces delivery risks, potentially undermining development viability and contradicting the National Planning Policy Framework (NPPF) which supports economic growth.

The policy lacks essential details such as floorspace thresholds, percentage of affordable workspace, and rental discounts, leading to uncertainty for applicants and investors, which is inconsistent with NPPF requirements for clarity and support for growth.

The NPPF stipulates that policies should be based on up-to-date evidence and tested through viability assessments; introducing this policy before completing necessary work risks embedding unproven requirements.

The cumulative uncertainty regarding thresholds, rental levels, and delivery timing may impose excessive burdens on development, potentially leading to reduced contributions in Section 106 obligations and undermining the deliverability of the Plan as per NPPF guidance.

The current form of Policy J/AW, alongside other obligations, risks discouraging investment and delaying delivery, which is concerning given Cambridge's reliance on a limited number of large sites for employment floorspace.

Object

Draft Greater Cambridge Local Plan for consultation

Policy I/ID: Infrastructure and delivery

Representation ID: 204250

Received: 30/01/2026

Respondent: Railpen

Agent: Bidwells

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

The policy I/ID is deemed overly rigid, requiring developers to secure all necessary infrastructure, which may not be within their control.

The respondent highlights that strategic and utility infrastructure is often delivered by statutory undertakers under separate frameworks.

The National Planning Policy Framework states that policies should be deliverable and reflect reasonable expectations of developers.

Requiring developers to demonstrate arrangements for infrastructure risks placing unmanageable obligations on them.

The policy wording may exceed statutory tests for planning obligations, potentially delaying development and conflicting with national objectives.

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