Draft Greater Cambridge Local Plan for consultation

Add a definition of tall buildings
Reword other points as follows:
Impact on the historic environment – applicants must demonstrate and quantify the potential harm of proposals to the significance of Cambridges 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)
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
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.

Brookgate Land Ltd and Network Rail Infrastructure Ltd object to the proposed wording of Policy GP/ST.
Firstly, it is considered necessary to define ‘tall buildings’ within the policy in order to avoid ambiguity. Therefore, 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.
With regard to the existing draft wording, it is suggested that point (b) relating to impacts on the historic environment is worded as follows to ensure that it is consistent with the NPPF and allows for future and emerging clusters:
Impact on the historic environment – applicants must demonstrate and quantify the potential harm of proposals to the significance of Cambridges 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)
Furthermore, point (c) is suggested to be amended as follows to ensure that the policy remains in line with guidance and good practice by not going above and beyond committed development:
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
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. The following updates to the wording are suggested to allow for proportionality rather than an absolute requirement for no impact:
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.
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.

The Local Plan should adopt a more optimistic job figure and explicitly support higher-growth scenarios, ensuring alignment with national policy objectives for sustainable economic growth.

Policy S/JH: New Jobs and Homes
The proposed wording implies that the job figure included in Policy S/JH represents an objectively assessed need. However, this figure should be regarded as a minimum benchmark, not a maximum or constraining target.
Supporting evidence to the policy titled the ‘Greater Cambridge Employment and Housing Needs Update 2024-2045 (September 2025), concludes 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 Employment and Housing Needs Update, during the strongest phase of growth (2010–2020), the Greater Cambridge economy expanded by almost 4,000 jobs per year. The evidence identifies a ‘Central growth’ scenario of 73,200 jobs across the plan period, representing sustained annual growth of around 3,500 jobs.
The advancements are not just in the scientific arena. Life science research and application has seen a technological transformation over recent years. The majority (83%) of the life sciences community is now using some level of automation across their R&D processes (Bidwells & YouGov, 2023). This has innovated the drug development process and clinical trials, but is extending well beyond these areas. Cloud-connected medical devices, artificial intelligence, machine learning, and gene sequencing and editing are evolving rapidly and will deliver new products and transform processes. This will present challenges to companies across the sector to keep pace with the evolution underway. Restricting employment growth to historical trends fails to embrace the advancement technology brings. Over the life-time of a plan restricting employment floorspace in one of the most innovative clusters in the world fails to meet one of the Government’s key priorities of growing the economy
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.
However recent Government announcements highlight the Government’s continued commitment to growth in Cambridge. This has been further strengthened through the direction of travel set out in the proposed reforms to the NPPF (Draft, 2025). Policy E2 states: ‘substantial weight should be given by the decision-maker to the economic benefits of proposals for commercial 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 that higher-growth outcomes remain credible and should not be ruled out by policy. This requires revision to the proposed policy wording.
For these reasons, the Local Plan should consider utilising a more optimistic and realistic figure for job numbers and include explicit support for higher-growth scenarios, with corresponding flexibility in employment land allocations. Without these changes, Policy S/JH risks being unsound and inconsistent with national policy objectives to support sustainable economic growth and productivity.

There is overall support for the continued allocation of Station Road West as the final undeveloped parcel of the wider CB1 development. The area is known as the Devonshire Quarter and comprises land both within Brookgate Land Ltd and Network Rail Infrastructure Ltd and Network Rail ownership, with the latter comprising the existing car park.
It is noted that planning permission granted on the Site (LPA Ref. 21/00264/FUL and 18/1678/FUL) has now lapsed, however, in line with the commentary provided on the allocation within Site Allocations Topic Paper (2025), it is pertinent to consider this within the draft allocation.
Uses
Firstly, while it is acknowledged that the previous planning permission would have delivered up to 11,300 sqm of Class E (g)(i) and (ii) floorspace, this should not be relied upon as a fixed benchmark, as it would unduly constrain flexibility and would not respond appropriately to changing economic, market or site-specific circumstances over the plan period.
It is therefore considered inappropriate for the Local Plan to specify a fixed quantum of Class E (g)(i) and (ii) floorspace. Instead, the amount of development should be determined through a context-led approach, informed by site characteristics, surrounding uses, accessibility, design considerations and compliance with the rest of the allocation. This would allow future proposals to respond positively to evolving needs while still ensuring high-quality, sustainable development.
It is noted that the land-uses within the allocation fail to acknowledge that a hotel use has previously been accepted in principle on the Site, as evidenced by the grant of planning permission under LPA Ref. 18/1678/FUL. This demonstrates that the Site has previously been considered suitable for town-centre use.
Furthermore, the Site occupies a highly sustainable location for residential development including Build to Rent and Co-living, being situated within an 200 metres walking distance of Cambridge Station and benefitting from excellent access to public transport, employment opportunities, and local services. Having regard to the future direction of national planning policy, as set out in the draft 2025 NPPF consultation, there is a clear and strengthened presumption in favour of residential development in such sustainable, well-connected locations.
To provide flexibility and better reflect the Site’s potential, it is therefore proposed that the land-uses are not narrowly specified, but instead the site is allocated for ‘mixed-use development’. For the avoidance of doubt, mixed-use can include a mixture of uses within Class E.
Height and Massing
Brookgate Land Ltd and Network Rail Infrastructure Ltd consider that the allocation contains conflicting requirements in relation to height and massing.
Point (a) indicates that massing should be context-led, suggesting flexibility to respond to the surrounding environment, whereas point (b) prescribes that building height should be less than, or similar to, contemporary development to the west of the station. This creates tension between a flexible, context-driven approach and a rigid height limitation, potentially restricting the ability to respond appropriately to the site’s specific characteristics. It is therefore requested that prescriptions of building heights at point (b) are removed from the allocation. Point (a) however, is supported and should be retained as a positive, context-led approach would allow for appropriate flexibility in an area of the City whereby height is greatly affected by viability.
Point (b) also states that new development should not ‘negatively impact’ Strategic Viewpoint E from Limekiln Road. It is considered that the term ‘negatively impact’ is highly subjective and open to varying interpretation, with limited clarity regarding which elements of the skyline are indeed considered to positively contribute at present.
To provide certainty for applicants and decision-makers, it is recommended that the policy is reworded so that proposals are required to ‘have regard to Strategic Viewpoint E’, rather than relying on a subjective standard of negative impact. This approach would support high-quality development that respects the strategic view while allowing for proportionate interpretation.
Redline Boundary
Furthermore, it must be noted that the inclusion of the railway tracks within the allocation reflects land-ownership boundaries but does not reflect the correct developable area. It is therefore requested that the redline of the allocation is amended to reflect the plan shown in the supporting statement.

Need to consider 21/00264/FUL and 18/1678/FUL for development that has previously been considered acceptable on site. Inappropriate to outline a fixed quantum of floorspace. This should be context-led and be capable of responding to changing economic circumstances. Failure to acknowledge that a hotel was previously considered acceptable. Need to recognise the highly sustainable location for build to rent and co-living Overall, the Site should be allocated for mixed use development Conflicting requirements on height and massing. Point (b) prescribed height, whereas point (a) states it should be context-led. Therefore, suggest removing point (b) Subjectivity around 'negatively impact on strategic viewpoint E' should be amended to 'have regard for Strategic Viewpoint E' Redline boundary should be amended to remove railway tracks.

There is overall support for the continued allocation of Station Road West as the final undeveloped parcel of the wider CB1 development. The area is known as the Devonshire Quarter and comprises land both within Brookgate Land Ltd and Network Rail Infrastructure Ltd and Network Rail ownership, with the latter comprising the existing car park. It is noted that planning permission granted on the Site (LPA Ref. 21/00264/FUL and 18/1678/FUL) has now lapsed, however, in line with the commentary provided on the allocation within Site Allocations Topic Paper (2025), it is pertinent to consider this within the draft allocation. Uses Firstly, while it is acknowledged that the previous planning permission would have delivered up to 11,300 sqm of Class E (g)(i) and (ii) floorspace, this should not be relied upon as a fixed benchmark, as it would unduly constrain flexibility and would not respond appropriately to changing economic, market or site-specific circumstances over the plan period. It is therefore considered inappropriate for the Local Plan to specify a fixed quantum of Class E (g)(i) and (ii) floorspace. Instead, the amount of development should be determined through a context-led approach, informed by site characteristics, surrounding uses, accessibility, design considerations and compliance with the rest of the allocation. This would allow future proposals to respond positively to evolving needs while still ensuring high-quality, sustainable development. It is noted that the land-uses within the allocation fail to acknowledge that a hotel use has previously been accepted in principle on the Site, as evidenced by the grant of planning permission under LPA Ref. 18/1678/FUL. This demonstrates that the Site has previously been considered suitable for town-centre use. Furthermore, the Site occupies a highly sustainable location for residential development including Build to Rent and Co-living, being situated within an 200 metres walking distance of Cambridge Station and benefitting from excellent access to public transport, employment opportunities, and local services. Having regard to the future direction of national planning policy, as set out in the draft 2025 NPPF consultation, there is a clear and strengthened presumption in favour of residential development in such sustainable, well-connected locations. To provide flexibility and better reflect the Site’s potential, it is therefore proposed that the land-uses are not narrowly specified, but instead the site is allocated for ‘mixed-use development’. For the avoidance of doubt, mixed-use can include a mixture of uses within Class E. Height and Massing Brookgate Land Ltd and Network Rail Infrastructure Ltd consider that the allocation contains conflicting requirements in relation to height and massing. Point (a) indicates that massing should be context-led, suggesting flexibility to respond to the surrounding environment, whereas point (b) prescribes that building height should be less than, or similar to, contemporary development to the west of the station. This creates tension between a flexible, context-driven approach and a rigid height limitation, potentially restricting the ability to respond appropriately to the site’s specific characteristics. It is therefore requested that prescriptions of building heights at point (b) are removed from the allocation. Point (a) however, is supported and should be retained as a positive, context-led approach would allow for appropriate flexibility in an area of the City whereby height is greatly affected by viability. Point (b) also states that new development should not ‘negatively impact’ Strategic Viewpoint E from Limekiln Road. It is considered that the term ‘negatively impact’ is highly subjective and open to varying interpretation, with limited clarity regarding which elements of the skyline are indeed considered to positively contribute at present. To provide certainty for applicants and decision-makers, it is recommended that the policy is reworded so that proposals are required to ‘have regard to Strategic Viewpoint E’, rather than relying on a subjective standard of negative impact. This approach would support high-quality development that respects the strategic view while allowing for proportionate interpretation. Redline Boundary Furthermore, it must be noted that the inclusion of the railway tracks within the allocation reflects land-ownership boundaries but does not reflect the correct developable area. It is therefore requested that the redline of the allocation is amended to reflect the plan shown in the supporting statement.

Overall, Policy S/NEC and the policy direction is supported.
As outlined in previous representations, Brookgate Land Ltd is the development partner of Network Rail and D B Cargo UK who own Land at Cambridge North, formerly known as the Chesterton Sidings, and who collectively form The Chesterton Partnership. Brookgate Land Limited has been working as promoter for The Chesterton Partnership in order to secure the rationalisation and redevelopment of the former Chesterton Sidings site.
For clarity, the Chesterton Sidings site forms part of the wider North East Cambridge allocation adjacent to Cambridge North Station, with site ownership boundaries included in Appendix 1 for information.
Brookgate Land Ltd and Network Rail Infrastructure Ltd consider that North East Cambridge remains one of the largest brownfield sites in Cambridge, located in a highly-sustainable location and served by excellent public transport infrastructure. It therefore continues to present a significant opportunity to transform the area into a high-quality gateway to the city and act as a catalyst for the regeneration of the wider area, following delivery of the station in 2017.
The vision for a mixed-use commercial and residential quarter that supports growth in office, laboratory and R&D space, while also delivering new homes, particularly within the private rented sector, to meet the needs of Greater Cambridge’s growing workforce, is therefore supported. Proposals within North East Cambridge should therefore make optimal and efficient use of the site, to deliver a transformative new district that builds on its legacy of innovation.
Since the Greater Cambridge Local Plan – First Proposals Consultation in 2021, hybrid planning permission on the area known as Chesterton Sidings has been approved (LPA Ref. 22/02771/OUT), in addition to the existing 217 bed hotel (LPA ref. S/2372/17/FL) and a 90,000 sq.ft office (LPA ref. S/4478/17/FL) which have now been completed. Due to the changing planning context, Brookgate Land Ltd and Network Rail Infrastructure Ltd wish to ensure that the draft allocation accurately reflects the extant planning permission.
Generally, it must also be considered that the draft allocation focusses on the opportunity provided by the relocation of the existing Cambridge Waste Water Treatment Plant (‘CWWTP’). Despite the Government’s announcement in 2025 confirming withdrawal of funding for the relocation of the CWWTP, the policy remains largely silent on this scenario. It is therefore considered that the policy should provide sufficient flexibility to ensure that retaining the CWWTP does not prejudice the delivery of the remaining parcels and planning applications are considered on their individual merits.
With the above in mind, the following clarifications and/or amendments are requested.
Uses
Draft Policy S/NEC is worded with an appropriate degree of flexibility to support the delivery of a significant mixed-use development. In particular, the use of the term ‘approximately’ provides necessary flexibility in respect of the quantum of homes to be delivered, reflecting the scale, complexity and long-term nature of the regeneration of North East Cambridge.
Notwithstanding this, North East Cambridge represents a highly sustainable location, with excellent public transport accessibility and proximity to employment, services and infrastructure. It is in these locations that Housing Secretary Steve Reed outlined that there would be a ‘default yes’ to housing proposals within the Written Ministerial Statement published on November 18 2025. As such, North East Cambridge is particularly well suited to a range of residential tenures and typologies, including Build to Rent and co-living.
It is therefore requested that Draft Policy S/NEC includes explicit reference to the acceptability of Build to Rent and co-living, subject to compliance with other relevant policy requirements. To support delivery, it is also suggested that the quantum of Build to Rent and Co-living tenures not be specified but rather be market-led. This would ensure the policy remains responsive to evolving housing needs and market conditions over the lifetime of the plan.
Brookgate Land Ltd and Network Rail Infrastructure Ltd do not support the inclusion of specified quantum of floorspace within the draft policy. Based on experience of delivery at North East Cambridge, there has been a historic underestimation of employment densities in and around the station and the currently proposed 320,000 sqm of employment floorspace does not achieve sufficient density for adequate place making. Additionally, a limit on floorspace does not recognise the advances in technology and will in turn hinder the growth of employment in Cambridge. Rather than provide a specified quantum, the policy should be worded to recognise that employment floorspace should be led by market demand above all.
Furthermore, point 3(b) sets a maximum quantum of business floorspace, defined within the policy as Class E(g) uses. However, point 3(c) identifies an additional quantum of floorspace for mid-tech, light industrial and creative industries, which we understand would also fall within Class E(g)(iii). As a result, a number of future consented uses are likely to fall within the scope of both points (b) and (c).
To avoid the potential double counting of proposed uses, it is recommended that the restriction to Class E(g) uses be removed from point 3(b). The provision of business or employment floorspace should instead defer to the definition of employment floorspace set out in draft Policy J/NE .
Furthermore, the removal of specified use classes follows draft NPPF Policy E1. Limb 2 of the emerging policy recognises that commercial property markets can change rapidly, and as a result, plans should not be overly prescriptive about the types of uses that would be acceptable on particular sites (other than where there is a clear and justified rationale for being specific).
In terms of the Site itself, it does not have any spatial qualities or constraints that mean it must be restricted to E(g)(i), (ii) or (iii) uses only. Rather, it has qualities that mean it should be considered for a wider range of uses
Whilst the NPPF consultation document carries limited weight and is subject to change, it does set a clear direction of travel for national policy, particularly a clear set of rules for plan-making.
The need to consider this draft NPPF for plan-making purposes is reaffirmed by the Secretary of State in his letter to Local Authority Leaders and Metro Mayors in December 2025, however, we acknowledge the Council’s intention to prepare this Plan under the old plan-making system and therefore the December 2024 NPPF.
Public Space
Point 8 of Policy S/NEC requires hubs and centres to be car-free. This requirement is fundamentally incompatible with the functional and operational needs of the commercial uses that such centres provide, many of which rely on vehicular access for deliveries and the provision of car parking to remain viable. As a result, the creation of genuinely car-free areas in and around hubs and centres is not achievable in practice.
The Local Centre identified on the spatial framework document (addressed in more detail on page 5) is shown to be located on the main vehicle connection to Cambridge North Station and the guided busway. Therefore, the policy requirement for this area to be car-fee is once again incompatible with the planning permission and wider vision for the Site allocation.
The draft policy therefore imposes an unrealistic requirement that risks undermining the deliverability of these centres. It is accordingly requested that the requirement for car-free zones in proximity to hubs and centres is removed from Policy S/NEC.
Movement
At point 14 of policy S/NEC, it is stated that cycle parking must exceed minimum standards. Brookgate Land Ltd and Network Rail Infrastructure Ltd do not feel that it is reasonable to enforce exceedance of the adopted minimum standards. The requirement for strict cycle parking standards is seen as limiting the density of developments with knock-on consequences for viability.
It is therefore suggested that the policy is worded to state that ‘cycle parking should, where feasible, meet minimum standards’
The removal of the mandatory ‘must’ and replacement with the phrase ‘should, where feasible’ outlines an expectation unless justified otherwise, which aids decision makers in reaching a balanced judgement. This additional flexibility will allow greater choice in how cycle storage is provided, helping to avoid costly requirements such as additional basement levels or the loss of housing units.
At point 22, it is also noted that the draft policy states that proposals must align with the North East Cambridge High Level Transport Strategy (2021) which sets out trip budgets for individual development sites. It is noted that the Site Allocation Topic Paper (2025) references a North East Cambridge Transport Position Statement from 2025. From a review of the 2025 strategy, it was found to provide a more up to date position regarding the trip budgets and takes into account the approved hybrid planning permission for Chesterton Sidings. For this reason, it is important that the most up to date document should be referenced in the policy.
Point 25 of the draft policy sets out the car parking strategy for the allocation. The requirements make no reference to the approved hybrid planning application at the Site, which secured car parking spaces for the commercial elements at Chesterton Sidings. Instead, the policy only references a quantum of parking for employment uses at Milton Road. It is therefore requested that the following is included at Point 25 to reflect the planning permission:
● Approximately 650 spaces (Chesterton Sidings)
Additionally, it is noted that there is a presumption in favour of car-free development but it is considered pertinent to ensure that the policy accounts for the Network Rail car parking spaces which have been retained under the hybrid permission as part of the franchise agreement. It is therefore requested that under ‘Ancillary Uses’ of point 25, the following is added:
● Parking for Network Rail is re-provided as a minimum of 425, with capacity for additional provision as requested.
It is also requested that the requirement for 100% EV charging is removed from the allocation with regard to residential parking. This requirement will be enforced within Part S of the Building Regulations 2010 (as amended). As per the NPPF 2025 draft policy PM13 (Setting Standards) and the now withdrawn PPG 1, planning policies should not replicate matters already addressed by Building Regulations.
Finally, at point 27 of Policy S/NEC it states ‘parking displacement within 2km will be monitored and development will be paused until mitigation is implemented’. This is deemed to be unnecessarily punitive. Potential impacts on car parking should not, in themselves, justify pausing development, especially where the proposal delivers significant public benefits. It is therefore requested that development will be paused until mitigation is implemented be removed from point 27.
Lifespan
Point 31 stipulates that any future planning applications for the wider allocation must be submitted as an Outline planning application. This requirement is unnecessarily restrictive. There is clear evidence of a hybrid planning application for the Chesterton Sidings site being successfully approved, demonstrating that alternative application routes can be both appropriate and effective for complex sites. Mandating a specific form of application removes flexibility, risks delaying the planning process, and may increase the time to first completions of much needed housing. This, in turn, could unduly impact scheme viability and the timely delivery of development, contrary to the objective of boosting housing supply.
Furthermore, point 31 of S/NEC requires a number of complex and unnecessary documents to accompany any future submission within policy area S/NEC.
A design code was not submitted in support of the outline elements for the Chesterton Siding site, yet the approved scheme is considered to constitute high-quality and cohesive design. It is therefore requested that this is removed from the policy and should a design code be required, this be conditioned rather than being required up-front.
Furthermore, the requirement for a Stewardship Strategy is not considered proportionate to the scale and form of developments that are likely to come forward. The wider allocation comprises a number of smaller sites rather than requiring a comprehensive application for the entire site. Stewardship Strategies such as those used at Poundbury in Dorset rely on unified land ownership and long-term estate control, meaning that this approach would be difficult to implement on an allocation comprising multiple independent landowners. The effectiveness of a stewardship strategy depends on consistent design standards, a single management structure, and clear funding mechanisms secured in perpetuity. The additional complexity, cost, and governance requirements are therefore disproportionate to the scale or nature of the allocation. If required, individual conditions can be imposed on planning permission for a Stewardship Strategy rather than be required upfront.
Figure 17: Spatial Framework for S/NEC: North East Cambridge
Figure 17 is largely consistent with the approved hybrid planning permission for the area comprising Chesterton Sidings. However, it should be made clear that figure 17 is intended as an illustrative masterplan and is not a prescriptive tool.
Furthermore, it is noted that a heritage asset is identified within the Chesterton Siding site. There are no heritage assets on Site and therefore it is requested that this is removed from the spatial framework in this location.
Additionally, it is noted that a new local centre is identified within the Chesterton Siding site. Despite there being a small, approved quantum of retail, cafe and food/beverage floorspace at ground floor level of the approved buildings in this location, it is not deemed that the circa 650 sqm quantum would be enough to be considered a ‘Local Centre’ in the retail hierarchy. This would place unnecessary restrictions on the use of this floorspace should it be considered that Town Centre uses were not viable in future.
Additionally, it must be noted that the proposed new local centre is not identified under draft Policy J/RC (Retail and other complementary town centre uses) as an emerging Local Centre. Should the new Local Centre at Chesterton Sidings not have been designated for retail planning purposes, this should be made clear within the policy so as to not place undue constraints on uses in this area in future.

Please refer to submitted supporting statement. Reflect hybrid planning permission 22/02771/OUT Retaining CWWTP should not prejudice other parcels. Should make explicit reference to build to rent and co-living tenures being acceptable. Removal of specified quantum of employment floorspace. Remove restriction to Class E(g) and defer to definition in policy J/NE. Remove requirement for car-free zones near to hubs or centres as this is incompatible with the allocation. Remove requirement to exceed minimum cycle parking standards. Replace existing trip budgets with information included within the North East Cambridge Transport Position Statement 2025 Add 650 parking spaces at Chesterton Sidings Allow for the reprovision of 425 Network Rail Spaces Remove EVCP requirement as this doubles up on building regulations. Allow for development to progress without being halted by parking displacement. Remove requirement for outline planning applications. Condition design codes and Stewardship strategies. Spatial framework- should be clear this is not a prescriptive tool, remove heritage asset at Chesterton Sidings, remove local centres as this is not referred to in other retail policies.

Overall, Policy S/NEC and the policy direction is supported.
As outlined in previous representations, Brookgate Land Ltd is the development partner of Network Rail and D B Cargo UK who own Land at Cambridge North, formerly known as the Chesterton Sidings, and who collectively form The Chesterton Partnership. Brookgate Land Limited has been working as promoter for The Chesterton Partnership in order to secure the rationalisation and redevelopment of the former Chesterton Sidings site.
For clarity, the Chesterton Sidings site forms part of the wider North East Cambridge allocation adjacent to Cambridge North Station, with site ownership boundaries included in Appendix 1 for information.
Brookgate Land Ltd and Network Rail Infrastructure Ltd consider that North East Cambridge remains one of the largest brownfield sites in Cambridge, located in a highly-sustainable location and served by excellent public transport infrastructure. It therefore continues to present a significant opportunity to transform the area into a high-quality gateway to the city and act as a catalyst for the regeneration of the wider area, following delivery of the station in 2017.
The vision for a mixed-use commercial and residential quarter that supports growth in office, laboratory and R&D space, while also delivering new homes, particularly within the private rented sector, to meet the needs of Greater Cambridge’s growing workforce, is therefore supported. Proposals within North East Cambridge should therefore make optimal and efficient use of the site, to deliver a transformative new district that builds on its legacy of innovation.
Since the Greater Cambridge Local Plan – First Proposals Consultation in 2021, hybrid planning permission on the area known as Chesterton Sidings has been approved (LPA Ref. 22/02771/OUT), in addition to the existing 217 bed hotel (LPA ref. S/2372/17/FL) and a 90,000 sq.ft office (LPA ref. S/4478/17/FL) which have now been completed. Due to the changing planning context, Brookgate Land Ltd and Network Rail Infrastructure Ltd wish to ensure that the draft allocation accurately reflects the extant planning permission.
Generally, it must also be considered that the draft allocation focusses on the opportunity provided by the relocation of the existing Cambridge Waste Water Treatment Plant (‘CWWTP’). Despite the Government’s announcement in 2025 confirming withdrawal of funding for the relocation of the CWWTP, the policy remains largely silent on this scenario. It is therefore considered that the policy should provide sufficient flexibility to ensure that retaining the CWWTP does not prejudice the delivery of the remaining parcels and planning applications are considered on their individual merits.
With the above in mind, the following clarifications and/or amendments are requested.
Uses
Draft Policy S/NEC is worded with an appropriate degree of flexibility to support the delivery of a significant mixed-use development. In particular, the use of the term ‘approximately’ provides necessary flexibility in respect of the quantum of homes to be delivered, reflecting the scale, complexity and long-term nature of the regeneration of North East Cambridge.
Notwithstanding this, North East Cambridge represents a highly sustainable location, with excellent public transport accessibility and proximity to employment, services and infrastructure. It is in these locations that Housing Secretary Steve Reed outlined that there would be a ‘default yes’ to housing proposals within the Written Ministerial Statement published on November 18 2025. As such, North East Cambridge is particularly well suited to a range of residential tenures and typologies, including Build to Rent and co-living.
It is therefore requested that Draft Policy S/NEC includes explicit reference to the acceptability of Build to Rent and co-living, subject to compliance with other relevant policy requirements. To support delivery, it is also suggested that the quantum of Build to Rent and Co-living tenures not be specified but rather be market-led. This would ensure the policy remains responsive to evolving housing needs and market conditions over the lifetime of the plan.
Brookgate Land Ltd and Network Rail Infrastructure Ltd do not support the inclusion of specified quantum of floorspace within the draft policy. Based on experience of delivery at North East Cambridge, there has been a historic underestimation of employment densities in and around the station and the currently proposed 320,000 sqm of employment floorspace does not achieve sufficient density for adequate place making. Additionally, a limit on floorspace does not recognise the advances in technology and will in turn hinder the growth of employment in Cambridge. Rather than provide a specified quantum, the policy should be worded to recognise that employment floorspace should be led by market demand above all.
Furthermore, point 3(b) sets a maximum quantum of business floorspace, defined within the policy as Class E(g) uses. However, point 3(c) identifies an additional quantum of floorspace for mid-tech, light industrial and creative industries, which we understand would also fall within Class E(g)(iii). As a result, a number of future consented uses are likely to fall within the scope of both points (b) and (c).
To avoid the potential double counting of proposed uses, it is recommended that the restriction to Class E(g) uses be removed from point 3(b). The provision of business or employment floorspace should instead defer to the definition of employment floorspace set out in draft Policy J/NE .
Furthermore, the removal of specified use classes follows draft NPPF Policy E1. Limb 2 of the emerging policy recognises that commercial property markets can change rapidly, and as a result, plans should not be overly prescriptive about the types of uses that would be acceptable on particular sites (other than where there is a clear and justified rationale for being specific).
In terms of the Site itself, it does not have any spatial qualities or constraints that mean it must be restricted to E(g)(i), (ii) or (iii) uses only. Rather, it has qualities that mean it should be considered for a wider range of uses
Whilst the NPPF consultation document carries limited weight and is subject to change, it does set a clear direction of travel for national policy, particularly a clear set of rules for plan-making.
The need to consider this draft NPPF for plan-making purposes is reaffirmed by the Secretary of State in his letter to Local Authority Leaders and Metro Mayors in December 2025, however, we acknowledge the Council’s intention to prepare this Plan under the old plan-making system and therefore the December 2024 NPPF.
Public Space
Point 8 of Policy S/NEC requires hubs and centres to be car-free. This requirement is fundamentally incompatible with the functional and operational needs of the commercial uses that such centres provide, many of which rely on vehicular access for deliveries and the provision of car parking to remain viable. As a result, the creation of genuinely car-free areas in and around hubs and centres is not achievable in practice.
The Local Centre identified on the spatial framework document (addressed in more detail on page 5) is shown to be located on the main vehicle connection to Cambridge North Station and the guided busway. Therefore, the policy requirement for this area to be car-fee is once again incompatible with the planning permission and wider vision for the Site allocation.
The draft policy therefore imposes an unrealistic requirement that risks undermining the deliverability of these centres. It is accordingly requested that the requirement for car-free zones in proximity to hubs and centres is removed from Policy S/NEC.
Movement
At point 14 of policy S/NEC, it is stated that cycle parking must exceed minimum standards. Brookgate Land Ltd and Network Rail Infrastructure Ltd do not feel that it is reasonable to enforce exceedance of the adopted minimum standards. The requirement for strict cycle parking standards is seen as limiting the density of developments with knock-on consequences for viability.
It is therefore suggested that the policy is worded to state that ‘cycle parking should, where feasible, meet minimum standards’
The removal of the mandatory ‘must’ and replacement with the phrase ‘should, where feasible’ outlines an expectation unless justified otherwise, which aids decision makers in reaching a balanced judgement. This additional flexibility will allow greater choice in how cycle storage is provided, helping to avoid costly requirements such as additional basement levels or the loss of housing units.
At point 22, it is also noted that the draft policy states that proposals must align with the North East Cambridge High Level Transport Strategy (2021) which sets out trip budgets for individual development sites. It is noted that the Site Allocation Topic Paper (2025) references a North East Cambridge Transport Position Statement from 2025. From a review of the 2025 strategy, it was found to provide a more up to date position regarding the trip budgets and takes into account the approved hybrid planning permission for Chesterton Sidings. For this reason, it is important that the most up to date document should be referenced in the policy.
Point 25 of the draft policy sets out the car parking strategy for the allocation. The requirements make no reference to the approved hybrid planning application at the Site, which secured car parking spaces for the commercial elements at Chesterton Sidings. Instead, the policy only references a quantum of parking for employment uses at Milton Road. It is therefore requested that the following is included at Point 25 to reflect the planning permission:
● Approximately 650 spaces (Chesterton Sidings)
Additionally, it is noted that there is a presumption in favour of car-free development but it is considered pertinent to ensure that the policy accounts for the Network Rail car parking spaces which have been retained under the hybrid permission as part of the franchise agreement. It is therefore requested that under ‘Ancillary Uses’ of point 25, the following is added:
● Parking for Network Rail is re-provided as a minimum of 425, with capacity for additional provision as requested.
It is also requested that the requirement for 100% EV charging is removed from the allocation with regard to residential parking. This requirement will be enforced within Part S of the Building Regulations 2010 (as amended). As per the NPPF 2025 draft policy PM13 (Setting Standards) and the now withdrawn PPG 1, planning policies should not replicate matters already addressed by Building Regulations.
Finally, at point 27 of Policy S/NEC it states ‘parking displacement within 2km will be monitored and development will be paused until mitigation is implemented’. This is deemed to be unnecessarily punitive. Potential impacts on car parking should not, in themselves, justify pausing development, especially where the proposal delivers significant public benefits. It is therefore requested that development will be paused until mitigation is implemented be removed from point 27.
Lifespan
Point 31 stipulates that any future planning applications for the wider allocation must be submitted as an Outline planning application. This requirement is unnecessarily restrictive. There is clear evidence of a hybrid planning application for the Chesterton Sidings site being successfully approved, demonstrating that alternative application routes can be both appropriate and effective for complex sites. Mandating a specific form of application removes flexibility, risks delaying the planning process, and may increase the time to first completions of much needed housing. This, in turn, could unduly impact scheme viability and the timely delivery of development, contrary to the objective of boosting housing supply.
Furthermore, point 31 of S/NEC requires a number of complex and unnecessary documents to accompany any future submission within policy area S/NEC.
A design code was not submitted in support of the outline elements for the Chesterton Siding site, yet the approved scheme is considered to constitute high-quality and cohesive design. It is therefore requested that this is removed from the policy and should a design code be required, this be conditioned rather than being required up-front.
Furthermore, the requirement for a Stewardship Strategy is not considered proportionate to the scale and form of developments that are likely to come forward. The wider allocation comprises a number of smaller sites rather than requiring a comprehensive application for the entire site. Stewardship Strategies such as those used at Poundbury in Dorset rely on unified land ownership and long-term estate control, meaning that this approach would be difficult to implement on an allocation comprising multiple independent landowners. The effectiveness of a stewardship strategy depends on consistent design standards, a single management structure, and clear funding mechanisms secured in perpetuity. The additional complexity, cost, and governance requirements are therefore disproportionate to the scale or nature of the allocation. If required, individual conditions can be imposed on planning permission for a Stewardship Strategy rather than be required upfront.
Figure 17: Spatial Framework for S/NEC: North East Cambridge
Figure 17 is largely consistent with the approved hybrid planning permission for the area comprising Chesterton Sidings. However, it should be made clear that figure 17 is intended as an illustrative masterplan and is not a prescriptive tool.
Furthermore, it is noted that a heritage asset is identified within the Chesterton Siding site. There are no heritage assets on Site and therefore it is requested that this is removed from the spatial framework in this location.
Additionally, it is noted that a new local centre is identified within the Chesterton Siding site. Despite there being a small, approved quantum of retail, cafe and food/beverage floorspace at ground floor level of the approved buildings in this location, it is not deemed that the circa 650 sqm quantum would be enough to be considered a ‘Local Centre’ in the retail hierarchy. This would place unnecessary restrictions on the use of this floorspace should it be considered that Town Centre uses were not viable in future.
Additionally, it must be noted that the proposed new local centre is not identified under draft Policy J/RC (Retail and other complementary town centre uses) as an emerging Local Centre. Should the new Local Centre at Chesterton Sidings not have been designated for retail planning purposes, this should be made clear within the policy so as to not place undue constraints on uses in this area in future.