Draft Greater Cambridge Local Plan for consultation
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Draft Greater Cambridge Local Plan for consultation
Policy CC/DC: Designing for a changing climate
Representation ID: 203353
Received: 29/01/2026
Respondent: Babraham Research Campus Ltd
Agent: Bidwells
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Object. It is important to ensure the policy enables sufficient flexibility to accommodate changes in climate change policy and good practice over the plan period. Climate change scenarios predict extensive changes by 2050, much of which is dependent on government and human action so there is substantial uncertainty over outcomes. The Local Plan will therefore need to build in suitable flexibility to accommodate these changes over the plan period.
The Plan will also need to be informed by a viability assessment to ensure policies are achievable, and the cumulative cost of policies will not undermine deliverability of the Plan.
It will be important to ensure the policy enables sufficient flexibility to accommodate changes in climate change policy and good practice over the lifetime of the Plan.
The Plan will also need to be informed by a viability assessment to ensure that policies are achievable, and that the total cumulative cost of all relevant policies will not undermine deliverability of the Plan.
Babraham Research Campus Ltd objects to Policy CC/DC.
It will be important to ensure the policy enables sufficient flexibility to accommodate changes in climate change policy and good practice over the lifetime of the Plan. Climate change scenarios predict extensive changes by 2050, much of which is dependent on government and human action so there is substantial uncertainty over outcomes. The Local Plan will therefore need to build in suitable flexibility to accommodate these changes within the lifetime of the Plan.
The Plan will also need to be informed by a viability assessment to ensure that policies are achievable, and that the total cumulative cost of all relevant policies will not undermine deliverability of the Plan.
Object
Draft Greater Cambridge Local Plan for consultation
Policy CC/NZ: Net zero carbon new buildings
Representation ID: 203381
Received: 29/01/2026
Respondent: Babraham Research Campus Ltd
Agent: Bidwells
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
BRC object. The policy exceeds existing sustainability benchmarks without considering viability and deliverability. BRC welcome ambition to ensure that all buildings help to meet zero-carbon targets, there needs to be greater
flexibility.
The requirement for net zero operational emissions at the shell and core stage is deemed inappropriate due to the uncertainty of future end users and operational profiles.
Part A's expectation for new dwellings and non-domestic buildings to achieve a space heating demand of 15-20 kWh per meter squared per year is seen as unrealistic and higher than national standards.
Part B's EUI targets for residential dwellings set at 35 kWh per meter squared per year are also viewed as exceeding national standards.
BRC suggests removing EUI/space heating targets from the draft policy to comply with NPPF 2026 draft policy PM13 and avoid duplication with upcoming Building Regulations Part L 2025.
Remove specific EUI and space heating requirements from the policy as this duplicates building regulations.
Remove requirement for net zero operational emissions for shell and core.
Babraham Research Campus Ltd object to Policy CC/NZ.
The policy goes above and beyond existing sustainability benchmarks without consideration for impacts on viability and deliverability. Whilst Babraham Research Campus Ltd welcomes the ambition to ensure that all buildings help to meet zero-carbon targets, there needs to be greater flexibility within the policy wording.
Firstly, requiring net zero operational emissions at the shell and core stage is not appropriate where the future end user and operational profile are not yet known. Such a requirement risks imposing impractical obligations and may deter occupier delivery or investment.
With regard to Part A, all new dwellings and non-domestic buildings are expected to achieve a space heating demand of 15-20 kwH per meter squared per year. This figure is in line with Climate Change Committee, LETI Net Zero definition and Passivhaus standard, which are higher than other national standards and therefore placing unrealistic expectations on developers.
With regard to Part B, the EUI targets are split between uses. For residential dwellings, the targets are set at 35 kWh per meter squared per year which is aligned with LETI Net Zero definition and the National Grid Future Energy Scenarios. The policy once again goes above and beyond national standards.
It is also understood that the Building Regulations Part L 2025 update/Future Homes Standard is due to include specific EUI targets once published. As EUI targets will be published in this legislation, it is suggested they are removed to ensure that the draft policy complies with NPPF 2026 draft policy PM13 (Setting Standards) and the now withdrawn PPG 1, which states that planning policies should not replicate matters already addressed by Building Regulations.
Object
Draft Greater Cambridge Local Plan for consultation
Policy CC/WE: Water efficiency in new developments
Representation ID: 203394
Received: 29/01/2026
Respondent: Babraham Research Campus Ltd
Agent: Bidwells
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Please see supporting statement.
BRC object as the policy mandates rainwater or greywater harvesting on all major developments, which may not be appropriate or deliverable, especially for commercial-led developments.
The policy requirement for commercial units to achieve all five BREEAM water credits (WAT 01–05) is considered challenging and often unfeasible, with flexibility only applied to WAT 01. The draft Plan is largely silent on BREEAM, and the policy's requirements would necessitate all commercial developments to engage a qualified BREEAM assessor, leading to additional costs and concerns about proportionality for smaller or less complex schemes.
Remove requirement for rainwater or greywater harvesting being mandated in all major developments. This should only be delivered where viable or feasible.
Remove requirement to comply with all 5 BREEAM water credits.
Babraham Research Campus Ltd object to the proposed wording of Policy CC/WE.
The policy goes beyond national and industry guidance by effectively mandating rainwater or greywater harvesting on all major developments, which will not always be appropriate or deliverable. This is particularly the case for commercial led development, where such systems may conflict with operational requirements, site constraints, or viability. National policy promotes proportionate, context-led approaches to water efficiency.
The policy requires commercial units to achieve all five BREEAM water credits (WAT 01–05), with flexibility applied only to WAT 01. In practice, achieving all BREEAM credits is often challenging and may not be feasible in all circumstances. It is also noted that the remainder of the draft Plan is largely silent on BREEAM. As drafted, the policy would therefore require all commercial developments engage with a qualified BREEAM assessor to demonstrate the credits have been achieved, irrespective of scale or complexity, resulting in additional cost. This raises concerns regarding proportionality, particularly for smaller or less complex commercial schemes.
Object
Draft Greater Cambridge Local Plan for consultation
Policy CC/CE: Supporting a circular economy and sustainable resource use
Representation ID: 203400
Received: 29/01/2026
Respondent: Babraham Research Campus Ltd
Agent: Bidwells
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Please see supporting statement.
BRC objects to the proposed wording of Policy CC/CE and requests further clarity on what constitutes 'a significant part' of a building in the context of demolition.
While the emphasis on retrofit is supported, BRC suggests that the policy should acknowledge circumstances where demolition may be justified by wider planning benefits such as fit for purpose R&D facilities. It is recommended that the policy include flexibility to allow for demolition and redevelopment if the viability of refurbishment or reuse is significantly in doubt.
Clarity on the definition of 'significant part'.
Policy worded flexibly to allow for other material benefits to outweigh this presumption and when viability and deliverability is placed in doubt.
Babraham Research Campus Ltd object to the proposed wording of Policy CC/CE.
Further clarity is requested on the policy wording. The policy states that proposals involving the demolition of a building, in whole or a significant part, should be accompanied by a full justification. Clarification is needed on what constitutes ‘a significant part’ to avoid ambiguity.
While the emphasis on retrofit is supported, the policy does not appear to allow for other material benefits that may outweigh the presumption in favour of repairing, refurbishing, and re-using. It is recommended that the policy acknowledges that, in certain circumstances, demolition may be acceptable where justified by wider planning benefits. For example, there are sometimes instances where buildings cannot deliver a flexible/adaptable, compliant and fit for purpose R&D facility and demolition and replacement is the only option.
Flexibility should also be added to the policy to make it clear that if the viability and deliverability of refurbishment, retrofit or reuse places considerable is place in such doubt, then demolition and redevelopment is the only realistic option for the Site.
Object
Draft Greater Cambridge Local Plan for consultation
Policy BG/TC: Improving tree canopy cover and the tree population
Representation ID: 203409
Received: 29/01/2026
Respondent: Babraham Research Campus Ltd
Agent: Bidwells
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Please see supporting statement.
BRC object to Policy BG/TC, arguing that the existing 10% Biodiversity Net Gain requirement already ensures ecological enhancement through an outcome based mechanism. Concerned that the tree canopy requirement duplicates the BNG regime and may prioritise one ecological metric over a balanced planning approach.
The 30% tree canopy cover requirement for major developments is seen as overly prescriptive, potentially undermining development capacity, density, and viability, and misaligned with national planning policy and ambitions for growth. It is also unclear whether other practicalities have been considered, i.e off-set from street lights, SUDS roads and/or foundations.
Furthermore, there has been no published calculator or methodology for measuring canopy cover, which means the policy lacks clarity and certainty.
Remove 30% tree canopy requirement.
Provide calculator to understand how this will be measured.
Should the policy remain, provide flexibility in the policy wording to account for capacity, density and viability, alongside other factors such as SUDs, off-set from streetlights, foundations etc.
Babraham Research Campus Ltd object to Policy BG/TC.
The statutory requirement to deliver a minimum 10% Biodiversity Net Gain already provides a robust, outcome-based mechanism for securing ecological enhancement. This framework is flexible, evidence-led and capable of responding to site-specific circumstances. The proposed tree canopy requirement appears to duplicate or cut across the BNG regime, without sufficient justification, and risks prioritising a single ecological metric over a balanced planning judgement.
The requirement for major development to demonstrate a minimum of 30% tree canopy cover on site risks introducing an inflexible and 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 is overly prescriptive and there is insufficient evidence for its justification. It is also unclear whether other practicalities have been considered, i.e off-set from street lights, SUDS roads and/or foundations.
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 identifies what calculator or methodology is intended to be used. In the absence of a defined and agreed approach, the policy lacks clarity and certainty. On this basis, it does not meet the tests and is not justified.
Object
Draft Greater Cambridge Local Plan for consultation
Policy BG/EO: Providing and enhancing open spaces
Representation ID: 203424
Received: 29/01/2026
Respondent: Babraham Research Campus Ltd
Agent: Bidwells
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Please see supporting statement.
BRC objects to the wording of Policy BG/EO, due to a lack of clarity on the required quantum of open space for commercial developments. The policy is insufficiently flexible, not reflecting the operational and spatial needs of commercial development.
The National Planning Policy Framework (2024) and draft NPPF Policy L2, emphasise that planning policies should support economic growth and effective land use. The application of a generic open space requirement constrains site layouts and reduces development capacity, conflicting with wider growth ambitions.
Policy BG/EO should be revised to allow for case-by-case assessment of open space provision, promoting a flexible approach aligned with national policy on effective land use, economic growth and plan deliverability.
Clarity required on the quantum of open space expected for commercial developments.
Policy BG/EO should be revised to allow for case-by-case assessment of open space provision, promoting a flexible approach aligned with national policy on effective land use, economic growth and plan deliverability.
Babraham Research Campus Ltd object to the proposed wording of Policy BG/EO.
The policy introduces a requirement for open space associated for commercial developments without clarity on the quantum required. The policy is insufficiently flexible and does not reflect the operational and spatial requirements of employment and commercial development.
The National Planning Policy Framework (2024), including the direction of travel set out in Policy L2 of the reformed NPPF, is clear that planning policies should support economic growth and make effective use of land in sustainable locations. Applying a generic open space expectation to commercial development risks constraining efficient site layouts and reducing development capacity, contrary to national policy and the Government’s stated ambition to support growth in the commercial sectors, as set out in Policies E1–E3 of the reformed NPPF.
Policy BG/EO should therefore be reconsidered to allow open space provision to be assessed on a case-by-case basis, adopting a flexible and proportionate approach that recognises the functional requirements of employment uses and aligns with national policy on effective land use, economic growth and plan deliverability.
Object
Draft Greater Cambridge Local Plan for consultation
Policy J/AW: Affordable workspace and creative industries
Representation ID: 203449
Received: 29/01/2026
Respondent: Babraham Research Campus Ltd
Agent: Bidwells
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Please see supporting statement.
BRC objects to the wording of Policy J/AW, as the requirement for affordable workspace could negatively impact scheme viability, especially for projects already facing constraints. The policy lacks clarity on the scale and nature of employment floorspace it applies to, making it difficult to assess impacts.
Adding a viability clause to the policy is important to allow for negotiated contributions and alternative delivery mechanisms when on-site affordable workspace is not feasible.
Point 2b of the policy allows owners to manage affordable workspace if they demonstrate necessary skills and experience, but given the lack of existing policy, it is questioned how this can be demonstrated. It is also important to note the BRC 'Live Labs' scheme, which offers flexible rental agreements or renting of bench/desk space, demonstrating affordability can take various forms.
Addition of a viability clause.
Recognition that affordable workspace takes many different forms.
Lack of clarity on scale and nature of the affordable workspace makes it difficult to assess impact.
Further clarity as to how businesses can demonstrate skills to manage affordable workspace when this has never been a requirement before.
Babraham Research Campus Ltd object to the proposed wording of Policy J/AW.
The requirement for affordable workspace would significantly affect scheme viability for schemes that are already facing viability constraints. In light of the requirement for thousands of new jobs in Greater Cambridge, this would severely impact the number of schemes coming forward to deliver this level of growth.
In its current format, the policy is unclear on the scale and nature of the employment floorspace this would apply to which makes it difficult to comment on the impacts. It is acknowledged that a number of affordable workspace policies exist in London where land values and construction costs are high making the delivery more feasible. However, even in these circumstances, scheme viability is greatly compromised.
It is suggested that if the policy were to be carried forward, then a viability clause should be added in. This could allow for negotiated contributions and provide justification for the alternative delivery mechanisms outlined in the policy such as off-site provision, or financial payments where on-site affordable workspace is not feasible.
It is also noted that at point 2b, the policy allows affordable workspace to be managed and operated by the owner where they can demonstrate the necessary skills and experience. Given the absence of existing guidance, it should be clarified how an owner would demonstrate competence to deliver affordable workspace effectively. Affordability also comes in many forms. For example, at Babraham Research Campus they have a ‘Live Labs’ scheme whereby new start-ups rent bench space and desk space underpinned by the support services running that facility. The company/individual enters into a facility agreement to use the space. For start-ups in other buildings, they benefit from more flexible lease terms (shorter leases and break terms).
Object
Draft Greater Cambridge Local Plan for consultation
Policy S/DS: Development strategy
Representation ID: 203462
Received: 29/01/2026
Respondent: Babraham Research Campus Ltd
Agent: Bidwells
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Please see supporting statement.
BRC object to the policy and request that point ii is reworded as below:
Babraham Research Campus – a new employment-led mixed use allocation to support further growth of this existing world leading bioscience research and innovation campus and improve the health and wellbeing of future employees, residents and the local community through targeted environmental enhancements: including approximately 48,000m2 employment floorspace for office and research & development and approximately 83 additional homes, supported by focused additional facilities that complement existing local services;
Please see comments above regarding rewording of the policy to reflect approximately 83 additional homes.
Babraham Research Campus Ltd object to Policy S/DS: Development Strategy.
Whilst Babraham Research Campus Ltd broadly support Policy S/DS in terms of the identification of Babraham Research Campus as a new employment-led mixed use allocation in the Rural Southern Cluster, they do have a minor observation on the policy wording at part d (ii), as outlined below. The policy should be reworded as follows:
Babraham Research Campus – a new employment-led mixed use allocation to support further growth of this existing world leading bioscience research and innovation campus and improve the health and wellbeing of future employees, residents and the local community through targeted environmental enhancements: including approximately 48,000m2 employment floorspace for office and research & development and approximately 83 additional homes, supported by focused additional facilities that complement existing local services.
The above changes to the wording of the policy are proposed in order to ensure the Plan is clearly written, as per requirements in paragraph 16 (d) of the NPPF (2024) and reflects the approach agreed with officers at Greater Cambridge Shared Planning (GCSP) service in respect of the outline planning application which is currently pending determination (under reference 25/04634/OUT).
Comment
Draft Greater Cambridge Local Plan for consultation
Policy S/JH: New jobs and homes
Representation ID: 203904
Received: 30/01/2026
Respondent: Babraham Research Campus Ltd
Agent: Bidwells
Policy S/JH should be viewed as a minimum requirement for jobs and homes, with 73,300 jobs and 48,195 homes being the baseline rather than a maximum target. The supporting evidence indicates a need for between 67,600 and 90,900 additional jobs, reflecting a significant increase in economic growth expectations. The Central growth scenario of 73,200 jobs is considered conservative and does not fully capture the growth potential of the Cambridge economy. Recent infrastructure investments justify the adoption of a higher growth scenario for job creation and housing supply. The anticipated evidence base from the Cambridge Growth Company is expected to propose ambitious growth targets that exceed current council projections. Strategic infrastructure projects, such as the East West rail station and public transport improvements, will drive the need for new jobs and homes. The Local Plan should adopt more optimistic job and housing figures and support higher-growth scenarios to align with national policy objectives.
Babraham Research Campus Ltd have the following comment on Policy S/JH: New Jobs and Homes.
Policy S/JH sets out the level of objectively assessed needs in Greater Cambridge over the period 2024-2045 for jobs and homes. It states that 73,300 additional jobs and a minimum of 48,195 new homes are required to meet the needs for the total population.
The provision of 73,300 additional jobs and 48,195 new homes across the plan period should be regarded as the very minimum rather than a maximum or constraining target. Supporting evidence to the policy titled the ‘Greater Cambridge Employment and Housing Needs Update 2024-2045’ (September 2025) (EHN), states at 3.55 that the various scenarios modelled indicate a need of between 67,600 and 90,900 additional jobs over the plan period. This compares to between 66,600 and 75,800 additional jobs modelled under the previous 2023 results. This significant increase in the upper end of the modelling indicates that economic growth expectations have strengthened exponentially, not diminished.
As set out in the EHN, during the strongest phase of growth (2010–2020), the Greater Cambridge economy expanded by almost 4,000 jobs per year. The conclusion of the EHN is then based on the ‘Central growth’ scenario of 73,200 jobs across the plan period, representing sustained annual growth of around 3,500 jobs. Crucially, the Central growth scenario builds in assumptions of slower periods, contractions, and economic shocks, and is therefore inherently conservative rather than reflective of the full growth capacity of the Cambridge economy. It is also worth noting, at paragraph 3.62 of the EHN, it is acknowledged that the ‘high’ scenarios could be achieved or exceeded if there is a step change in infrastructure investment.
Greater Cambridge is one such location where there has indeed been a step change in infrastructure investment which heightens the urgency in increasing job creation and housing supply and justifies adopting a higher growth scenario. On 23rd 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.” Pennycook goes on to say; “Greater Cambridge has a vital role to play in this Government’s mission to kickstart economic growth.” Furthermore, the Cambridge Growth Company was established in 2024 to address barriers to growth and help unlock Greater Cambridge’s full potential. In terms of approach, in October 2025, the Government announced its intention to consult on the case for a centrally led Development Corporation as one potential route for delivery (backed by £400m funding). This is to be the subject of statutory consultation in 2026. It is anticipated that Cambridge Growth Company (CGC) will publish its own evidence base ahead of the formation of the Development Corporation, which whilst yet unknown it is expected that an ambitious growth target will be identified; likely to exceed that currently envisioned by the Councils for the Greater Cambridge Local Plan.
Furthermore, Greater Cambridgeshire has been, and continues to be, the location of strategic infrastructure investment that will continue to drive upwards increases in the need for new jobs and homes. This includes the proposed East West rail station as well as the proposed public transport improvements for the Cambourne to Cambridge corridor and the Cambridge Eastern Access corridor. The Cambridgeshire and Peterborough Local Growth Plan 2025 also identify priority growth sectors, and the need for further skills development.
The Employment and Housing Needs Update acknowledges a ‘High’ and ‘High Sensitivity’ scenario, whereby growth would meet or exceed the 2010–2020 trajectory. This high level of growth is feasible in Cambridge and would support the Government’s direction of travel. It is therefore important to recognise to the proposed policy wording.
For these reasons, the Local Plan should consider utilising a more optimistic and realistic figure for job and housing numbers and include explicit support for higher-growth scenarios. Without these changes, Policy S/JH risks being unsound and inconsistent with national policy objectives to support sustainable economic growth and productivity.
Object
Draft Greater Cambridge Local Plan for consultation
Policy S/BRC: Babraham Research Campus
Representation ID: 203943
Received: 30/01/2026
Respondent: Babraham Research Campus Ltd
Agent: Bidwells
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
Please see supporting statement.
The following updates are required to the policy:
2bi. 83 additional Campus worker homes
2bii. appropriate supporting ancillary uses and infrastructure, including approximately 850 square metres nursery space (class (E(f)), and 500 square metres of flexible amenity space (Class F2 (a), (b), Class E (a), (b), (d))
3. Addition of under paragraph 156.
4. Introduction of 'inform specific mitigations' and 'Babraham Conservation Area'
Removal of point 5.
6. Addition of retained as open space, as indicated on the Spatial Framework
7. addition of 'as indicated on the Spatial Framework'
7a. replacement of development with buildings and tree canopy
removal of 7b and d
8. Introduction of landscape buffers and including forest scale trees and under storey planting where appropriate,
Removal of 9.
12. Replace settlement with Campus
13b. site wide design codes removal of each phase
14. Addition of within the campus
16c. contributing to rather than providing
18. addition of together with a strategic and local transport mitigation plan.
Removal of 19.
20. introduction of 'the Babraham Institute'
21. Replace employment with commercial
22. addition of including communal space within the centre of the Campus designed for meeting, socialising and holding events
23. remove all text and suggested new text.
remove 24.
27. addition of new, expanded Nursery and a new amenity building capable of accommodating flexible space to address Campus and local needs, e.g
Removal of 29.
Changes to spatial framework including updated site allocation boundary, updates title, removal of landscape buffer, commercial led development blocks, local nature reserve labelling. Correctly show CSET route and show SEA on plan.
Changes to figure 95 included updated site boundary and updates to title.
Changes to 96 include changes to map and site boundary.
Please see supporting statement.
The following updates are required to the policy:
2bi. 83 additional Campus worker homes
2bii. appropriate supporting ancillary uses and infrastructure, including approximately 850 square metres nursery space (class (E(f)), and 500 square metres of flexible amenity space (Class F2 (a), (b), Class E (a), (b), (d))
3. Addition of under paragraph 156.
4. Introduction of 'inform specific mitigations' and 'Babraham Conservation Area'
Removal of point 5.
6. Addition of retained as open space, as indicated on the Spatial Framework
7. addition of 'as indicated on the Spatial Framework'
7a. replacement of development with buildings and tree canopy
removal of 7b and d
8. Introduction of landscape buffers and including forest scale trees and under storey planting where appropriate,
Removal of 9.
12. Replace settlement with Campus
13b. site wide design codes removal of each phase
14. Addition of within the campus
16c. contributing to rather than providing
18. addition of together with a strategic and local transport mitigation plan.
Removal of 19.
20. introduction of 'the Babraham Institute'
21. Replace employment with commercial
22. addition of including communal space within the centre of the Campus designed for meeting, socialising and holding events
23. remove all text and suggested new text.
remove 24.
27. addition of new, expanded Nursery and a new amenity building capable of accommodating flexible space to address Campus and local needs, e.g
Removal of 29.
Changes to spatial framework including updated site allocation boundary, updates title, removal of landscape buffer, commercial led development blocks, local nature reserve labelling. Correctly show CSET route and show SEA on plan.
Changes to figure 95 included updated site boundary and updates to title.
Changes to 96 include changes to map and site boundary.
Whilst Babraham Research Campus Ltd support the principle of the allocation of Babraham Research Campus for mixed-use development to support the future needs of the Campus, they object to the current wording and supporting Spatial Framework.
Requested changes to the wording of Policy S/BRC and the supporting Spatial Framework is detailed below with clean new policy wording.
Policy S/BRC: Babraham Research Campus
Vision and identity
1. Babraham Research Campus will continue to be a world leading bioscience research and innovation campus, co-locating start up, growing and established bioscience companies. Located at the heart of the Cambridge Southern Cluster life-science ecosystem, the campus will continue to play a key role in bringing together academia and commercial bioscience. It will continue to develop into a place where people can live and work, set within an extensive network of green and blue infrastructure which supports both biodiversity and the health and wellbeing of employees and the wider community.
Uses
2. Babraham Research Campus, including land removed from the Green Belt, is allocated for mixed use development comprising:
a. Within the employment-led development area, approximately 48,000 square metres gross internal area (GIA) additional research and development (Class (E(g)(ii)) floorspace;
b. Within the residential-led development area:
i. approximately 83 additional Campus worker and affordable homes to support the needs of the Campus; and
ii. appropriate supporting ancillary uses and infrastructure, including approximately 850 square metres nursery space (class (E(f)), and 500 square metres of flexible amenity space (Class F2 (a), (b), Class E (a), (b), (d))
3. Development will be required to meet the National Planning Policy Framework (2024) ‘Golden Rules’ for land released from Green Belt under paragraph 156.
Justification for proposed amendments to wording of Policy
The above changes to the wording of the policy are proposed in order to ensure the Plan is clearly written and unambiguous, as per requirements in paragraph 16 (d) of the NPPF (2024).
The change from 450 to 850 sqm for the nursery space reflects the most recent assessment work undertaken to support application 25/04634/OUT which includes for a purpose-built, modern and expanded facility to meet the growing needs of the Institute, Campus Staff and the local community. It is anticipated that the new Nursery will provide pre-school care for up to 100 children.
The changes to the wording regarding the retail/amenity space is proposed in order to provide clarity as to the range of uses that could be accommodated and to reflect the most recent assessment work undertaken to support application 25/04634/OUT. It is envisaged that the facility will be a flexible and multi-functional space, providing opportunities for a variety of different
activities to take place. This may include for a small retail element and/or gym for use by the Campus and the wider community.
The changes to the wording at part 3 are to ensure the policy simply refers to the ‘Golden Rules’ requirements set out under paragraph 156 of the NPPF (2024) (which expands beyond affordable housing).
The development of Babraham Research Campus must do the following (in accordance with the Spatial Framework):
Context
4. Through the preparation of a Landscape Visual Impact Assessment and Heritage Impact Assessment, inform specific mitigations and , protect, and where appropriate, enhance the significance of heritage assets and their setting, including the Grade I Listed St Peter’s Church, Grade II* Listed Babraham Hall, Babraham Conservation Area and nearby heritage assets.
6. Limit development of new buildings to areas of existing development, undeveloped areas of land in the far north of the site, and The Close residential area. Gardens surrounding the Grade I Church and Grade II* Babraham Hall should be retained as open space, as indicated on the Spatial Framework.
7. Retain, preserve and enhance key close-up short and long-range views from, into and within the site, as indicated on the Spatial Framework
a. Ensuring buildings sits below the tree canopy; and existing tree-line
c. Responding sensitively to the setting of heritage assets within the site when redeveloping existing buildings;
8. Retain or, where possible, supplement the existing tree coverage and landscape buffers across the site, including forest scale trees and under storey planting where appropriate, to limit the visual impact of development on heritage assets, views and landscape setting.
10. Apply the sequential approach to flood risk within the site, ensuring any development is subject to appropriate mitigation and does not increase flood risk elsewhere.
11. Given the known significant potential for archaeological remains in this area, development proposals must be accompanied by an appropriate archaeological assessment, which includes information on the significance of the heritage asset, including the extent, character and condition of the archaeological resource and the likely impact of the development on the archaeological remains.
Justification for proposed amendments to wording of Policy
The above changes to the wording of the policy are proposed in order to ensure the Plan is clearly written and unambiguous and has a clear purpose, as per requirements in paragraph 16 (d) and (f) of the NPPF (2024).
There are many instances where there is unnecessary duplication and where parts of the policy could be consolidated. In particular, in terms of assessment and mitigation of impacts upon the significance of heritage assets. This is especially important given that the policy currently extends to 30 parts across 5 pages, plus the Spatial Framework. There is also reference to the Lodge Building’ but it is not clear which Lodge (there are two – Babraham Lodge and Linton Lodge). The suggested wording seeks to provide clearer wording and avoid duplication.
The reference, at part 9, to a requirement for a ‘…wide landscape buffer (minimum 20 metres) in/adjacent to any development in the north-west of site…’ is not considered to be justified or based on evidence. Indeed, the Cambridge Green Belt Study (2021) identifies that the Campus makes a relatively limited contribution to Green Belt purposes, and the harm of its release would be low. The policy also does not acknowledge the existing, established perimeter woodland belt that runs to the west and north of the proposed commercial development in the north of the Campus. This woodland belt is within the wider Campus estate and therefore within the ownership of the Campus and is proposed to be retained. The Campus would be willing for the perimeter woodland to form part of the Strategic Enhancement Area (S/SEA/BRC) as referenced at part 15 of the policy (see plan at Appendix 2 of the submitted representations). Therefore, in summary, the requirement for an additional landscape buffer of a minimum of 20 metres to the existing perimeter woodland belt is overly prescriptive and not justified by evidence. It should not be included on the Spatial Framework. Ultimately, this is a matter to be dealt with via detailed assessment (including a Landscape and Visual Impact Assessment) relating to a site-specific proposal as part of any planning application process.
Built form
12.Ensure the built area of the Campus is contained within the site allocation boundary shown on the policies map and the Spatial Framework Diagram. Context
13.Be comprehensively planned and delivered to ensure development proposals are fully integrated with the wider Campus and to preserve and enhance the setting of identified heritage assets. This must involve:
a. Preparing a site-wide Masterplan, which must be submitted for approval by the Local Planning Authority as part of the first application for planning permission;
b. Preparing a site-wide Design Codes for the development to ensure a high quality of development, which must be submitted and approved before the first reserved matters planning application is determined.
Justification for proposed amendments to wording of Policy
The above changes to the wording of the policy are proposed in order to ensure the Plan is clearly written and unambiguous, as per requirements in paragraph 16 (d) of the NPPF (2024).
With reference to part 13 (b) of the Policy, reference should be made to a Site-Wide Design Code as opposed to Design Codes for each phase of development. This is to ensure the Policy is not overly prescriptive and reflects the approach agreed with officers at Greater Cambridge Shared Planning (GCSP) service in respect of application 25/04634/OUT. The approach was to prepare a Site-Wide Design Code but which includes for site-wide coding as well as coding for the three character areas (residential, central and expansion area within north-west of campus). The Code also includes a section on phasing.
Part 14 of the policy is proposed as it is duplicated within both the employment-led development section (at part 23) and the residential-led section (at part 29).
Nature
14.Maintain and enhance the wider landscape within the Campus, including the corridor of the River Granta.
15.Deliver compensatory improvements to the environmental quality and accessibility of remaining Green Belt land in the Strategic Enhancement Area (S/SEA/BRC), in line with a Green Belt Enhancement Strategy for the area prepared by the applicant. This should:
a. include measures such as walking loops, new wetlands, restoration of ponds, and other associated green infrastructure projects;
b. incorporate the enhancement of existing hedgerows and woodland that form the boundaries of the site, particularly to the east and west;
c. ensure measures integrate with the green and blue infrastructure network across the site and in the wider area.
Justification for proposed amendments to wording of Policy
The above changes to the wording of the policy are proposed in order to ensure the Plan is clearly written and unambiguous, as per requirements in paragraph 16 (d) of the NPPF (2024).
Movement
16.Ensure proposals improve movement within the Campus and deliver connections to highquality sustainable transport, by:
a. securing improvements to pedestrian and cycle routes;
b. supporting the provision of high-quality routes to existing forms of public transport, including nearby bus-stops;
c. contributing to high quality local non-motorised routes linking to Cambridge South East Transport schemes.
17.Where required, contribute financially to strategic public transport and active travel schemes in the south-east corridor, appropriate to the scale and nature of the development.
18.A trip budget based on detailed evidence must be agreed with the Local Highways Authority prior to submission of the outline application, together with a strategic and local transport mitigation plan. A monitor and manage approach will be taken to ensure that the development remains within the agreed trip budget for the site throughout its delivery.
Justification for proposed amendments to wording of Policy
The above changes to the wording of the policy are proposed in order to ensure the Plan is clearly written and unambiguous, as per requirements in paragraph 16 (d) of the NPPF (2024).
The suggested wording seeks to provide clearer wording and avoid duplication.
The employment-led development must, additionally, do the following (in accordance with the Spatial Framework):
Uses
20.Support research and development (Class E(g)ii)) floorspace and supporting uses. Future development proposals will need to deliver spaces for start-ups and the Babraham Institute, and these units should be located close to the centre of the site.
Built form
21.Be limited to the t commercial-led development area identified in the Spatial Framework.
22.Encourage opportunities for collaboration between future occupants, including communal space within the centre of the Campus designed for meeting, socialising and holding events
23. Be of high quality and innovative design which reflect the cutting-edge science which takes place within them whilst enhancing the heritage assets, preserving the rural character and sense of openness of the sites’ context.
Justification for proposed amendments to wording of Policy
The above changes to the wording of the policy are proposed in order to ensure the Plan is clearly written and unambiguous, as per requirements in paragraph 16 (d) of the NPPF (2024).
The suggested wording above more clearly and accurately reflect up to date assessment work undertaken by the Campus to inform their future masterplan. This has been subject to discussion with officers at Greater Cambridge Shared Planning Service and has formed part of the proposals of application 25/04634/OUT. The suggested changes also avoid unnecessary duplication within the policy wording.
The requirement under part 23 to deliver active ground floor uses and frontages wherever possible is overly prescriptive. Ultimately, this is a matter to be dealt with via detailed assessment relating to a site-specific proposal as part of any planning application process. Furthermore, R&D buildings at the Campus cannot have an open door policy.
Public space
25.Include enhanced meeting places as part of the public realm and open spaces.
The residential-led development must, additionally, do the following (in accordance with the Spatial Framework):
Uses
26.Be limited to addressing the needs for campus worker housing, with the mix of typologies and tenures (including affordable housing) informed by an accommodation needs assessment for the campus, the Greater Cambridge Housing Strategy, and discussions with the Local Planning Authority.
27.Provide ancillary uses to meet the daily needs of residents, including a new, expanded Nursery and a new amenity building capable of accommodating flexible space to address Campus and local needs, e.g small shop and gym, both of which must be open to the wider public and not undermine the viability of existing services in the village.
Justification for proposed amendments to wording of Policy
The above changes to the wording of the policy are proposed in order to ensure the Plan is clearly written and unambiguous, as per requirements in paragraph 16 (d) of the NPPF (2024).
The suggested wording more clearly and accurately reflects up to date assessment work undertaken by the Campus to inform their future masterplan. This has been subject to discussion with officers at Greater Cambridge Shared Planning Service and has formed part of the proposals of application 25/04634/OUT.
Built form
28.Be located in the residential-led development area identified in the Spatial Framework.
30.Take a comprehensive, landscape-led approach to the design through the preparation of a Masterplan, which must be prepared by the applicant and submitted as part of the planning application for this part of the site. This must ensure development:
a. maintains the low-density character of the site;
b. secures building design which is sympathetic to the sensitive village-edge location; and
c. focuses development as near to the Babraham High Street as possible.
Justification for proposed amendments to wording of Policy
The above changes to the wording of the policy are proposed in order to ensure the Plan is clearly written and unambiguous and has a clear purpose, as per requirements in paragraph 16 (d) and (f) of the NPPF (2024).
The requirement under part 29 to deliver active ground floor uses and frontages wherever possible is overly prescriptive. Ultimately, this is a matter to be dealt with via detailed assessment relating to a site-specific proposal as part of any planning application process. Furthermore, R&D buildings at the Campus cannot have an open door policy.
Spatial Framework (Figure 94)
The following changes are proposed to the Spatial Framework for Policy S/RSC/BRC: Babraham Research Campus (Figure 94);
● Updates to the proposed site allocation boundary to accurately reflect the Campus masterplan (see Appendix 1 for updated site allocation boundary plan)
● Update to title of Figure 94 as per below: ‘Figure 94: Spatial Framework for Policy S/RSC/BRC: Babraham Research Campus’
● Removal of ‘Landscape Buffer’ in north-west side of site (as referenced at Part 9 of Policy S/BRC)
● Removal of ‘Commercial Led Development’ blocks and simply refer to whole of this part of the Campus as ‘Commercial Led Development’ (as referenced at Part 21 of Policy S/BRC).
● Remove ‘local nature reserve’ labelling. This is incorrect and there is existing built development in these locations which should be acknowledged and shown on the plan and legend.
● Correctly show the alignment of the CSET Route. It is much further south than currently shown.
● Show the entirety of the Strategic Enhancement Area on the Plan and include additional land as per plan at Appendix 2.
Site Plan of Policy S/BRC: Babraham Research Campus (Figure 95)
The following changes are proposed to the Site Plan for Policy S/BRC: Babraham Research Campus (Figure 95);
● Updates to the site allocation boundary to accurately reflect the Campus masterplan (see Appendix 1 for updated site allocation boundary plan)
● Update to title of Figure 95 as per below: ‘Figure 95: Site Plan of Policy S/BRC: Babraham Research Campus’
Map of Green Belt release to enable delivery of Babraham Research Campus (Figure 96)
The following changes are proposed to the Map of Green Belt release to enable delivery of Babraham Research Campus (Figure 96);
Updates to the site allocation boundary to accurately reflect the Campus masterplan (see Appendix 1 for updated site allocation boundary plan)