Draft Greater Cambridge Local Plan for consultation

Railpen suggest that Figure 19 only shows ‘allocations’ or is made clearer presenting ‘allocations’ and separately ‘designations’ (i.e. PRIAs) so there is no confusion as to how the Local Plan refers to each category.

On behalf of our client, Railpen, we submit the following representation in response to the emerging Local Plan Policy S/LAC wording relating Other Site Allocations in Cambridge. The wording as currently drafted is provided below:

1. The following sites identified on the Policies Map are allocated for housing, employment or mixed uses in the
Cambridge urban area.

3. An indicative dwelling or floorspace capacity is identified for each of the site allocations. The number of homes or amount of floorspace granted planning permission on each site may be higher or lower than the indicative capacity and should be determined through a design-led approach. In the interests of consistency and precision, reference to Cambridge Retail Park as an allocation should be corrected to be a designation, reflecting the sites inclusion as a designated Public Realm Improvement Area (PRIA).

Railpen suggests that the policy requiring 30% tree canopy cover is removed.

On behalf of our client, Railpen, we submit the following representation in response to the emerging Local Plan Policy BG/TC wording relating to improving tree canopy cover and the tree population.

The National Planning Policy Framework (December 2024) requires planning policies to support the protection,
enhancement and integration of green infrastructure, including trees. However, it does not prescribe any quantitative tree canopy cover target—such as a 30% requirement—that local planning authorities must apply. Any such requirement within a Local Plan must therefore be fully justified by robust evidence demonstrating that policies are adequate, proportionate and justified, in line with the NPPF’s approach to plan-making. There is limited evidence to support the imposition of the suggested policy. Evidence does not suggest that recent development schemes have failed to deliver appropriate levels of tree canopy cover. The imposition of such an impactful policy will introduce a prescriptive constraint that could undermine development capacity, density and viability. As such, it is not aligned with national planning policy or with the Government’s stated ambition for growth. It will have a significant impact on the viability and deliverability of schemes.

The statutory requirement to deliver a minimum of 10% Biodiversity Net Gain (BNG) already provides a robust,
outcome-based mechanism for securing ecological enhancement. The BNG framework is evidence-led and capable of responding to site-specific circumstances. The proposed tree canopy cover requirement appears to duplicate, or cut across, the existing BNG regime without sufficient justification, and risks prioritising a single ecological metric over a balanced and holistic planning judgement.

The policy and supporting text state that canopy cover should be calculated using a Council-approved calculator or
metric. However, neither the policy itself nor the Biodiversity and Green Spaces Topic Paper identify what calculator or methodology is intended to be used. In the absence of a defined and agreed approach, the policy lacks clarity and certainty.

In the Cambridge context, where sites are often constrained and development viability is already heavily influenced by multiple policy requirements, the introduction of a substantial and fixed canopy cover threshold risks placing an
additional and unjustified burden on development.

This will compromise scheme deliverability and, in turn, the ability of the Local Plan to be implemented as intended.
Particularly in an authority area which is reliant on large sites to deliver on its stated growth ambitions. The emerging NPPF reform paper (December 2025) seeks to limit the use of quantitative standards in development plans to those specific issues where local variation is clearly justified. A generic tree canopy requirement is precisely the type of rigid, blanket standard that national policy seeks to avoid, as it risks complicating development, constraining design-led solutions and discouraging growth.

A generic “hectares per employee” requirement is precisely the type of rigid, blanket standard that national policy seeks to avoid, as it risks complicating development, constraining design-led solutions and discouraging growth. Railpen suggests that this policy obligation is removed.

On behalf of our client, Railpen, we submit the following representation in response to the emerging Local Plan Policy BG/EO relating to the provision and enhancement of open space. The policy wording as currently drafted is set out below:

3. The Councils will require an Accessible Greenspace standard for commercial development, likely to be applied to development in use classes E(g)(i), E(g)(ii), or E(g)(iii) for 100 employees or more (as calculated using the Councils’ latest jobs density calculations). The Councils are continuing to explore the number of hectares per employee to apply within this requirement. The proposed policy approach is insufficiently flexible and fails to adequately reflect the operational, spatial and viability considerations inherent in employment and commercial development in different parts of Greater Cambridge.

The National Planning Policy Framework (2024), including the direction of travel set out in emerging Policy L2 of the reformed NPPF, is clear that planning policies should support economic growth and make effective use of land in sustainable locations. The application of a generic accessible greenspace requirement to commercial development risks constraining efficient site layouts and reducing development capacity, which would be contrary to national policy and the Government’s stated ambition to support growth in key sectors, including science and technology. This is particularly significant given the acute shortage of laboratory space identified in the Case for Cambridge 2024. If the government does not address the pressure on infrastructure and the demand for research space, there is a ‘real risk’ that science clusters will stop growing or relocate to other competitor cities around the world. Imposing a generic greenspace standard on top of existing constraints risks further reducing the capacity of the very sites intended to solve this shortage.

The Government’s NPPF reform paper published in December 2025 further reinforces the importance of achieving higher densities in appropriate locations and emphasises the need for flexibility in policy application. In this context, the proposed open space requirement risks being misaligned with current and emerging national objectives relating to density and efficient land use and could create barriers to delivery in areas intended to accommodate growth.

In addition, the policy acknowledges that the Councils are continuing to explore how the requirement will be calculated. In the absence of a clearly defined and agreed methodology, the policy lacks clarity and certainty. This is likely to result in delays, inconsistent interpretation and avoidable disputes between applicants and decision-makers, with a risk of disproportionate demands being placed on commercial development. Such uncertainty has the potential to adversely affect scheme viability and deliverability, undermining the effectiveness of the policy.

Finally, the emerging NPPF reform paper (December 2025) seeks to limit the use of quantitative standards in
development plans to those specific issues where local variation is clearly justified. A generic “hectares per employee” requirement is precisely the type of rigid, blanket standard that national policy seeks to avoid, as it risks complicating development, constraining design-led solutions and discouraging growth.

Railpen therefore requests that the policy parts are removed.

On behalf of our client, Railpen, we submit the following representation in response to the emerging Local Plan Policy WS/NC wording relating to Meeting the needs of new and growing communities. The associated wording as currently drafted is provided below:

4. Proposals for residential sites of 200 or more dwellings (or groups of smaller sites which cumulatively exceed this figure) and employment development of over 5000m2 must be informed by detailed assessments of community needs and include strategies that address identified needs. Submitted strategies to meet community needs must demonstrate that the local community and stakeholder groups have been engaged to guide the provision of community, facilities to be introduced as part of the site-wide development strategy. Measures may be required to assist the development of a new community, such as through community development workers.

5. All housing development will contribute towards the provision of indoor community facilities to meet the need
generated by the development. Developments of sufficient scale to generate the need for new on-site facilities will be required to do so, unless it can be demonstrated that there would be advantages in off-site delivery. Other
developments will contribute to off-site provision through planning obligations or through the Community Infrastructure Levy as appropriate. Contributions will be based on a standard of 129m2 of such floorspace per 1,000 additional population.

Response to Part 4: Assessment of Community Needs
Policy 4 introduces a requirement for large-scale employment development to be informed by detailed community
needs assessments and to include strategies addressing those needs, including evidence of engagement with local communities and stakeholder groups. While the principle of supporting sustainable communities is acknowledged, the policy raises significant concerns in relation to certainty around requirements and maintaining the viability of schemes.

The policy creates uncertainty for the developers by failing to clearly define the content and timing of the required
community needs assessments, engagement processes and resulting strategies. It provides no clarity on what level of engagement would be sufficient, how stakeholder views would be balanced, or how engagement outcomes would translate into measurable development requirements. The open-ended reference to additional measures, such as community development workers, further increases uncertainty by introducing potentially ongoing and uncosted obligations. This lack of clarity is inconsistent with the National Planning Policy Framework (December 2024), which requires planning policies to be clear, unambiguous and capable of consistent application, and to provide a predictable framework for decision-making.

The burden of these assessments should fall on the Council as part of their Infrastructure Delivery Plan, and the responsibility should not fall on developers to determine which community needs a development should meet.

Part 5: Obligations
Paragraph 58 of the NPPF requires planning policies to support economic growth and productivity, including by
ensuring that planning obligations and policy requirements are not unnecessarily onerous or duplicative.

The proposed policy risks rendering development schemes unviable by imposing a cumulative requirement for the
provision of indoor community facilities that is not sufficiently justified or flexible. The application of a fixed floorspace standard of 129m² per 1,000 additional population, regardless of site context and constraints, removes the ability to tailor contributions to site-specific circumstances. In particular, the requirement for on-site provision on developments introduces significant long-term management liabilities, which directly impact a schemes viability. The policy also lacks clarity on the interaction between on-site provision, planning obligations and the Community Infrastructure Levy, creating a risk of cumulative financial burden. This approach conflicts with the Planning Practice Guidance (2019), which requires plan policies to be proportionate, to ensure that the cumulative impact of policy requirements does not undermine deliverability of development and in turn the Local Plan itself. The policy risks placing disproportionate demands on development, thereby threatening the deliverability of commercial premises at the scale envisaged by the Local Plan.

The following wording is suggested as a new Point (a):
a. Tall Buildings are defined as those which are significantly taller than the surrounding built form.

The following wording is suggested as a new Point (b):
b. Impact on the historic environment – applicants must demonstrate and quantify the potential harm of proposals to the significance of Cambridge’s heritage assets and their settings assessed on a site-by-site basis. These will include impact on key landmarks and viewpoints (identified in Appendix H: Skyline and tall buildings guidance)

The following wording is suggested as a new Point (c):
c. Scale and massing – applicants must demonstrate using scaled drawings, sections, accurate visual representations and models, how their proposals will deliver a high-quality addition to the skyline. This will include assessment of the cumulative impact of committed development.

The following wording is suggested as a new Point (e):
Amenity and microclimate – applicants must carefully consider impact on neighbouring buildings and open spaces in terms of the diversion of wind, overlooking or overshadowing, and adequate sunlight and daylight within and around the proposals.

On behalf of our client, Railpen, we submit the following representation in response to the emerging Local Plan Policy
GP/ST wording relating to Skyline and tall buildings.

Firstly, it is considered necessary to define ‘tall buildings’ within the policy in order to avoid ambiguity.

With regard to the existing draft wording, it is suggested that point (b) relating to impacts on the historic environment is worded to ensure that it is consistent with the NPPF and allows for future and emerging clusters:

Furthermore, point (c) is suggested to be amended to ensure that the policy remains in line with guidance and good practice by not going above and beyond committed development:

Lastly, it is considered pertinent to allow for judgement and the planning balance to be applied to point (e) which
currently outlines that applicants must demonstrate no impact.

Finally, within all criterion listed for tall buildings, it is considered unsuitable to use the word ‘must’ as this creates a
mandatory requirement leaving little to no discretion for decision makers. The use of the word ‘should’ outlines an
expectation unless justified otherwise, which aids decision makers in reaching a balanced judgement.

Such changes are required to reflect the intentions of Government to make effective use of land and to increase, as a general intent, the density of developments. A policy that acts to stifle reasonable consideration of height does not accord with the drive for increased density.

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

On behalf of our client, Railpen, we object to the emerging Local Plan Policy J/NE relating to new employment
development proposals.

Policy J/NE, is overly prescriptive and risks unduly restricting the delivery of large-scale industrial
and logistics development serving national and regional needs. In particular, Part 7 imposes disproportionate
constraints on warehousing and distribution uses, limiting the Plan’s ability to respond effectively to changing economic and employment requirements. The wording of Part 7 is shown below:

7. Large scale warehousing and distribution centres providing for national or regional needs will not be permitted in
Greater Cambridge.

This approach is inconsistent with the direction of travel in the draft reformed NPPF. Paragraph E1 emphasises that plans supporting long-term economic growth should avoid overly prescriptive requirements on acceptable uses and instead enable flexibility to respond to evolving commercial property demands. Paragraph E3 further recognises the particular physical and locational characteristics of freight and logistics development, including the need for access to strategic transport infrastructure and, in some cases, larger buildings. Policy J/NE does not sufficiently reflect this national policy context.

Recent appeal decisions reinforce the importance of flexibility and choice within employment land markets. In the
Beehive appeal decision (APP/Q0505/V/25/3360616), the Inspector emphasised that maintaining an adequate and
diverse supply of employment land is critical to keeping the market fluid, accelerating delivery, and reducing the risk of investment being lost overseas. The decision makes clear that quantitative targets, including those in the Iceni analysis The Greater Cambridge Growth Sectors Study September 2024), should be treated as reference points rather than caps, and that a diversity of site types, locations and offers is essential to meeting demand and maximising job creation.

The policy creates a disproportionate bar for industrial and logistics development, which typically requires larger plots, specific access arrangements and locations beyond tightly constrained settlement boundaries.

The policy therefore risks excluding sustainable employment proposals that would meet identified economic needs and contribute to a diverse and resilient supply of employment land, contrary to national policy and recent appeal findings. It is not effective, as it may prevent appropriate industrial and logistics schemes from coming forward simply because they cannot satisfy the policy requirements, despite being sustainable in principle.

For these reasons Railpen objects to the inclusion of Policy J/AW in the emerging local plan.

Policy J/AW introduces a new and significant requirement for the provision of affordable workspace within large
employment and mixed-use developments. While the principle of supporting a diverse economy is acknowledged, the policy as drafted raises fundamental concerns regarding certainty, viability and consistency with national policy.

Firstly, the requirement for affordable workspace to be made available for occupation at, or prior to, the first occupation of 50 per cent of the non-affordable economic floorspace introduces a delivery risk. This approach would require developers to deliver discounted floorspace early in the development programme, ahead of the point at which sufficient market floorspace has been occupied to support scheme cashflow. Requiring developers to maintain affordable workspace in perpetuity also creates uncertainty for investors that may not know how market conditions will be in the future, deterring investment. For large and complex commercial developments, this front-loading of non-market floorspace has the potential to undermine development viability and delay delivery, contrary to the National Planning Policy Framework (December 2024), which requires plan policies to be supportive of economic growth.

Secondly, the policy lacks essential detail. It does not define the floorspace thresholds, the percentage of affordable workspace to be delivered and the level or duration of rental discounts. These matters are fundamental to assessing development feasibility. Additionally, the term ‘affordable’ lacks proper definition, affordability might mean different things in different contexts, leading to inconsistencies in how the policy is applied. The absence of this information creates significant uncertainty for applicants and investors, which is inconsistent with the NPPF requirement for planning policies to be clear, unambiguous and supportive of growth (para 16d).

The NPPF is explicit that policies should be underpinned by proportionate, up-to-date evidence (para 32) and that
policy requirements should be tested through plan-wide viability assessment. Introducing a policy of this nature before the completion of the required work (para 8.55 of the supporting text) risks embedding requirements that have not been demonstrated to be viable or deliverable.

Finally, the cumulative effect of uncertainty around thresholds, rental levels, delivery timing and management
requirements risks placing a disproportionate burden on development at a time when viability is already a limiting factor for schemes due to interest rates, inflation and material costs. Developers may need to make realistic judgments about what can be viably accommodated within Section 106 obligations, which may result in reductions to contributions elsewhere. Paragraph 35 of the NPPF makes clear that the cumulative impact of policy requirements should not undermine the deliverability of the Plan. In its current form, Policy J/AW coupled with other obligations fails to meet this test and risks discouraging investment, delaying delivery and reducing the overall quantum of employment floorspace that can be brought forward. This is particularly worrying as Cambridge is reliant on a small number of large sites, which if not brought forward will mean that development will need to be sought from elsewhere.

The policy should therefore be amended to acknowledge that the delivery of certain infrastructure will be dependent on, and led by, third-party infrastructure providers. Without this clarification, the policy risks being ineffective, undeliverable and inconsistent and therefore fails NPPF tests of soundness by lacking effectiveness, deliverability, and alignment with national policy

On behalf of our client, Railpen, we submit the following representation in response to the emerging Local Plan policy I/ID wording relating to Infrastructure and Delivery.

The policy is overly rigid in stating that “planning permission will only be granted for proposals that have made suitable arrangements for the improvement or provision of infrastructure necessary to make the scheme acceptable in planning terms.” This wording implies an absolute requirement on developers to secure all necessary infrastructure provision, irrespective of whether provision is within their control. It fails to recognise that much strategic and utility infrastructure is delivered by statutory undertakers operating under separate regulatory frameworks and investment programmes.

The National Planning Policy Framework (December 2024) is clear that planning policies should be judged to be
unsound, if they are not deliverable, are ineffective, and inconsistent with national policy (para 36). Paragraphs relating to plan-making emphasise the importance of collaboration with infrastructure providers and the need for policies to reflect what can reasonably be expected of developers, having regard to the deliverability of the Plan. Requiring developers to demonstrate “suitable arrangements” as a precondition to planning permission, without acknowledging the role, responsibilities and timescales of utility providers, risks placing obligations on applicants that they are not able to control or guarantee.

Furthermore, national policy makes clear that planning obligations and conditions should only be used where they meet the statutory tests of necessary to the development, related to the development and proportional to the scheme. The blanket nature of the policy wording risks going beyond these tests by effectively requiring developers to deliver infrastructure that should properly be addressed through utility providers’ statutory duties and the public sector. This creates uncertainty for applicants, risks delaying otherwise acceptable development, and conflicts with the NPPF’s objective of supporting timely delivery of sustainable development.