Draft Greater Cambridge Local Plan for consultation

There is support for the recognition of the SEA's role in delivering a well-vegetated landscape buffer but we must stress the need for the final policy wording to ensure development potential is optimised in accordance with Section 11 of the National Planning Policy Framework.

In Part 18, we object to the policy requirements for the LIA. The policy should allow for flexibility in design and not limit the use of the entire area for linear or drainage features.

It is suggested that there is an addition of a new section 18a for the SEA, proposing specific requirements for landscape buffers, green infrastructure protection, flood risk mitigation, and the use of Green Belt land to enhance biodiversity. Various documents and assessments have been outlined to support recommendations which emphasise adherence to the National Planning Policy Framework regarding the release of Green Belt land and the provision of accessible green spaces.

The submitted paper forms a representation to the Regulation 18 January 2026 consultation to the emerging Greater Cambridge Local Plan (GCLP) on behalf of the Pemberton Family and Pemberton Family Trusts (“the Pemberton Family”). It is a submission focussed on the proposed allocation (ref: S/CBC) ‘Cambridge Biomedical Campus (including Addenbrooke’s Hospital)’. The Pemberton Family is the landowner of a major part of the allocation area and remains a committed member of the ‘Cambridge Biomedical Campus Landowners Collaboration Group (LCG)’ and to continuing to work together as group to achieve a deliverable development.
Attached to the submitted representation is a copy of the representation to the plan prepared by Cambridgeshire County Council (as landowner) and Prologis. The Pemberton Family support the overall approach to the policy set out by the attached representation. There are, however, two matters at part 7 and Part 17d of the policy where the Pemberton Family requires a detailed amendment to the policy to ensure the effective use of land and to ensure a sound allocation that involves the release of Green Belt land. The representations made in this document are matters only related to these two key planning matters. The Pemberton Family has been a long-term stakeholder in the successful development of Phases 1 and 2 of the campus and as owners of land and interests required for its further expansion, they offer strong support to the overall policy and the continued recognition by the emerging Local Plan of the important role of the Cambridge Biomedical Campus and its future growth. This representation refers to some detailed policy points that are requested to be changed and in the context of a Local Plan representation they have been lodged as ‘objections’, notwithstanding the overarching support to the policy. The submission is structured to address only those parts of Policy S/CBC upon which a comment is made.

Part 1 - Cambridge Biomedical Campus (including Addenbrooke’s Hospital) - OBJECT
Part 1 references the Policies Map and the land to be allocated. The Policy, Spatial Framework and the Proposals Map all need to align and be consistent and accurate in how they represent the land and allocation.
The Spatial Framework is clear that part of the site is ‘Strategic Enhancement Area (SEA)’ and another part of the site is ‘Landscape Improvement Area (LIA)’. The policy refers to these areas separately and places different policy expectations on these different parts of the site. It is important that all Local Plan plans or diagrams that present the site graphically show and designate these two areas (LIA and SEA) separately.

Part 17.d – Nature - SUPPORT
Support is given to the recognition of the role that the Strategic Enhancement Area can offer to the overall delivery of the site, including a well vegetated landscape buffer. If an amendment is made to this clear and appropriate policy position it would attract an objection. It is important that planning policy strives for the effective use of land in accordance with Section 11 of the National Planning Policy Framework; the policy must ensure the development potential of the allocation area is optimised and so ensure the SEA is effectively used to provide for mitigation features that would be better placed in the SEA, such as recreation, significant tree belts and landscape enhancement.

Part 18 – Proposals in the Landscape Improvement Area - OBJECT
The Landscape Improvement Area (LIA) is a large swathe of land on the Figure 63 Spatial Framework, but the Part 18 policy requirements for it are linear features or drainage features. Such items will not require the full extent of the LIA and will be a matter for detailed design at the appropriate time. As such, for the policy to include:
The LIA provides an extensive swathe of land to allow space and flexibility for how the required features will sit within the LIA

Part 18 – Proposals in the Landscape Improvement Area - OBJECT
There should be a section 18a to cover proposals in the Strategic Enhancement Area.
It is helpful that the policy has a section dedicated to the Landscape Improvement Area to give precision and clarity for how this particular land parcel is to perform as part of the wider allocation. Separately the Strategic Enhancement Area (SEA) has various requirements set through the policy and so a comparable section in the Policy would bring appropriate precision and clarity to this particular land parcel. Additional wording to the policy to include:

Proposals in the Strategic Enhancement Area should come forward in conjunction with the site allocation and must:
a. Provide a landscape buffer to the south of the campus that responds positively and sensitively to the existing topography and landscape character, establishing a soft-green edge to the City.
b. Protect and enhance green infrastructure including hedgerows, woodlands, waterbodies and protected species. Measures that support restoration, improve ecological connectivity and benefit nature recovery, including conservation farming, will be supported.
c. Contribute, where appropriate, to protect or enhance Strategic Views and integrate built form into the landscape.
d. Demonstrate how it will contribute to flood risk mitigation through site-specific multifunctional sustainable drainage and nature-based solutions.
e. Utilise Green Belt Land to create a multi-functional landscape that further supports biodiversity, with recreation as an important secondary function.

The matters a-e are informed by the Council’s Habitat Regulations Assessment (2025) and the Site Allocations Topic Paper (2025) alongside the evidence submitted that forms the ‘Third Party Comments’ for Cambridge Biomedical Campus (CBC Landowner Collaboration Group and CBC Ltd). In particular the evidence presented in the ‘Emerging Spatial Framework: Visual Commentary, October 30th 2023’, ‘CBC Preliminary Ecological Appraisal – Part 1, December 2022’, ‘CBC Case for Expansion, December 2022’ and ‘Cambridge Biomedical Campus Vision 2050: Creating a life sciences quarter for Cambridge’.
To support the allocation and the exceptional reasons for releasing land from the Green Belt it is important that the National Planning Policy Framework (NPPF 2024) is adhered to:

Paragraph 151
Once Green Belts have been defined, local planning authorities should plan positively to enhance their beneficial use, such as looking for opportunities to provide access; to provide opportunities for outdoor sport and recreation; to retain and enhance landscapes, visual amenity and biodiversity; or to improve damaged and derelict land. Where Green Belt land is released for development through plan preparation or review, the ‘Golden Rules’ in paragraph 156 below should apply.

Paragraph 156
Where major development involving the provision of housing is proposed on land released from the Green Belt through plan preparation or review, or on sites in the Green Belt subject to a planning application, the following contributions (‘Golden Rules’) should be made:
a. affordable housing which reflects either: (i) development plan policies produced in accordance with paragraphs 67-68 of this Framework; or (ii) until such policies are in place, the policy set out in paragraph 157 below;
b. necessary improvements to local or national infrastructure; and
c. the provision of new, or improvements to existing, green spaces that are accessible to the public. New residents should be able to access good quality green spaces within a short walk of their home, whether through onsite provision or through access to offsite spaces.

The NPPF sets a requirement for the provision of new or improved green spaces that are accessible to the public where major development is to be delivered on land released from the Green Belt. This relates to development that includes housing, which the S/CBC allows for. To ensure a robust and sound allocation it requires appropriate new or improved green spaces. Due to the extent of land to be released from the Green Belt, the SEA is required to contribute to the provision of green spaces and ensure there is a sound and NPPF compliant allocation beyond any space which could be accommodated within the existing campus or built-up area of the campus expansion land.
The SEA has an integral and coordinated role to contribute to the delivery of the allocation, especially to underpin a sound release of land from the Green Belt.

The submitted paper forms a representation to the Regulation 18 January 2026 consultation to the emerging Greater Cambridge Local Plan (GCLP) on behalf of the Pemberton Family and Pemberton Family Trusts (“the Pemberton Family”). It is a submission focussed on the proposed allocation (ref: S/CBC) ‘Cambridge Biomedical Campus (including Addenbrooke’s Hospital)’. The Pemberton Family is the landowner of a major part of the allocation area and remains a committed member of the ‘Cambridge Biomedical Campus Landowners Collaboration Group (LCG)’ and to continuing to work together as group to achieve a deliverable development.
Attached to the submitted representation is a copy of the representation to the plan prepared by Cambridgeshire County Council (as landowner) and Prologis. The Pemberton Family support the overall approach to the policy set out by the attached representation. There are, however, two matters at part 7 and Part 17d of the policy where the Pemberton Family requires a detailed amendment to the policy to ensure the effective use of land and to ensure a sound allocation that involves the release of Green Belt land. The representations made in this document are matters only related to these two key planning matters. The Pemberton Family has been a long-term stakeholder in the successful development of Phases 1 and 2 of the campus and as owners of land and interests required for its further expansion, they offer strong support to the overall policy and the continued recognition by the emerging Local Plan of the important role of the Cambridge Biomedical Campus and its future growth. This representation refers to some detailed policy points that are requested to be changed and in the context of a Local Plan representation they have been lodged as ‘objections’, notwithstanding the overarching support to the policy. The submission is structured to address only those parts of Policy S/CBC upon which a comment is made.

Part 1 - Cambridge Biomedical Campus (including Addenbrooke’s Hospital) - OBJECT
Part 1 references the Policies Map and the land to be allocated. The Policy, Spatial Framework and the Proposals Map all need to align and be consistent and accurate in how they represent the land and allocation.
The Spatial Framework is clear that part of the site is ‘Strategic Enhancement Area (SEA)’ and another part of the site is ‘Landscape Improvement Area (LIA)’. The policy refers to these areas separately and places different policy expectations on these different parts of the site. It is important that all Local Plan plans or diagrams that present the site graphically show and designate these two areas (LIA and SEA) separately.

Part 17.d – Nature - SUPPORT
Support is given to the recognition of the role that the Strategic Enhancement Area can offer to the overall delivery of the site, including a well vegetated landscape buffer. If an amendment is made to this clear and appropriate policy position it would attract an objection. It is important that planning policy strives for the effective use of land in accordance with Section 11 of the National Planning Policy Framework; the policy must ensure the development potential of the allocation area is optimised and so ensure the SEA is effectively used to provide for mitigation features that would be better placed in the SEA, such as recreation, significant tree belts and landscape enhancement.

Part 18 – Proposals in the Landscape Improvement Area - OBJECT
The Landscape Improvement Area (LIA) is a large swathe of land on the Figure 63 Spatial Framework, but the Part 18 policy requirements for it are linear features or drainage features. Such items will not require the full extent of the LIA and will be a matter for detailed design at the appropriate time. As such, for the policy to include:
The LIA provides an extensive swathe of land to allow space and flexibility for how the required features will sit within the LIA

Part 18 – Proposals in the Landscape Improvement Area - OBJECT
There should be a section 18a to cover proposals in the Strategic Enhancement Area.
It is helpful that the policy has a section dedicated to the Landscape Improvement Area to give precision and clarity for how this particular land parcel is to perform as part of the wider allocation. Separately the Strategic Enhancement Area (SEA) has various requirements set through the policy and so a comparable section in the Policy would bring appropriate precision and clarity to this particular land parcel. Additional wording to the policy to include:

Proposals in the Strategic Enhancement Area should come forward in conjunction with the site allocation and must:
a. Provide a landscape buffer to the south of the campus that responds positively and sensitively to the existing topography and landscape character, establishing a soft-green edge to the City.
b. Protect and enhance green infrastructure including hedgerows, woodlands, waterbodies and protected species. Measures that support restoration, improve ecological connectivity and benefit nature recovery, including conservation farming, will be supported.
c. Contribute, where appropriate, to protect or enhance Strategic Views and integrate built form into the landscape.
d. Demonstrate how it will contribute to flood risk mitigation through site-specific multifunctional sustainable drainage and nature-based solutions.
e. Utilise Green Belt Land to create a multi-functional landscape that further supports biodiversity, with recreation as an important secondary function.

The matters a-e are informed by the Council’s Habitat Regulations Assessment (2025) and the Site Allocations Topic Paper (2025) alongside the evidence submitted that forms the ‘Third Party Comments’ for Cambridge Biomedical Campus (CBC Landowner Collaboration Group and CBC Ltd). In particular the evidence presented in the ‘Emerging Spatial Framework: Visual Commentary, October 30th 2023’, ‘CBC Preliminary Ecological Appraisal – Part 1, December 2022’, ‘CBC Case for Expansion, December 2022’ and ‘Cambridge Biomedical Campus Vision 2050: Creating a life sciences quarter for Cambridge’.
To support the allocation and the exceptional reasons for releasing land from the Green Belt it is important that the National Planning Policy Framework (NPPF 2024) is adhered to:

Paragraph 151
Once Green Belts have been defined, local planning authorities should plan positively to enhance their beneficial use, such as looking for opportunities to provide access; to provide opportunities for outdoor sport and recreation; to retain and enhance landscapes, visual amenity and biodiversity; or to improve damaged and derelict land. Where Green Belt land is released for development through plan preparation or review, the ‘Golden Rules’ in paragraph 156 below should apply.

Paragraph 156
Where major development involving the provision of housing is proposed on land released from the Green Belt through plan preparation or review, or on sites in the Green Belt subject to a planning application, the following contributions (‘Golden Rules’) should be made:
a. affordable housing which reflects either: (i) development plan policies produced in accordance with paragraphs 67-68 of this Framework; or (ii) until such policies are in place, the policy set out in paragraph 157 below;
b. necessary improvements to local or national infrastructure; and
c. the provision of new, or improvements to existing, green spaces that are accessible to the public. New residents should be able to access good quality green spaces within a short walk of their home, whether through onsite provision or through access to offsite spaces.

The NPPF sets a requirement for the provision of new or improved green spaces that are accessible to the public where major development is to be delivered on land released from the Green Belt. This relates to development that includes housing, which the S/CBC allows for. To ensure a robust and sound allocation it requires appropriate new or improved green spaces. Due to the extent of land to be released from the Green Belt, the SEA is required to contribute to the provision of green spaces and ensure there is a sound and NPPF compliant allocation beyond any space which could be accommodated within the existing campus or built-up area of the campus expansion land.
The SEA has an integral and coordinated role to contribute to the delivery of the allocation, especially to underpin a sound release of land from the Green Belt.

The submitted paper forms a representation to the Regulation 18 January 2026 consultation to the emerging Greater Cambridge Local Plan (GCLP) on behalf of the Pemberton Family and Pemberton Family Trusts (“the Pemberton Family”). It is a submission focussed on the proposed allocation (ref: S/CBC) ‘Cambridge Biomedical Campus (including Addenbrooke’s Hospital)’. The Pemberton Family is the landowner of a major part of the allocation area and remains a committed member of the ‘Cambridge Biomedical Campus Landowners Collaboration Group (LCG)’ and to continuing to work together as group to achieve a deliverable development.
Attached to the submitted representation is a copy of the representation to the plan prepared by Cambridgeshire County Council (as landowner) and Prologis. The Pemberton Family support the overall approach to the policy set out by the attached representation. There are, however, two matters at part 7 and Part 17d of the policy where the Pemberton Family requires a detailed amendment to the policy to ensure the effective use of land and to ensure a sound allocation that involves the release of Green Belt land. The representations made in this document are matters only related to these two key planning matters. The Pemberton Family has been a long-term stakeholder in the successful development of Phases 1 and 2 of the campus and as owners of land and interests required for its further expansion, they offer strong support to the overall policy and the continued recognition by the emerging Local Plan of the important role of the Cambridge Biomedical Campus and its future growth. This representation refers to some detailed policy points that are requested to be changed and in the context of a Local Plan representation they have been lodged as ‘objections’, notwithstanding the overarching support to the policy. The submission is structured to address only those parts of Policy S/CBC upon which a comment is made.

Part 1 - Cambridge Biomedical Campus (including Addenbrooke’s Hospital) - OBJECT
Part 1 references the Policies Map and the land to be allocated. The Policy, Spatial Framework and the Proposals Map all need to align and be consistent and accurate in how they represent the land and allocation.
The Spatial Framework is clear that part of the site is ‘Strategic Enhancement Area (SEA)’ and another part of the site is ‘Landscape Improvement Area (LIA)’. The policy refers to these areas separately and places different policy expectations on these different parts of the site. It is important that all Local Plan plans or diagrams that present the site graphically show and designate these two areas (LIA and SEA) separately.

Part 17.d – Nature - SUPPORT
Support is given to the recognition of the role that the Strategic Enhancement Area can offer to the overall delivery of the site, including a well vegetated landscape buffer. If an amendment is made to this clear and appropriate policy position it would attract an objection. It is important that planning policy strives for the effective use of land in accordance with Section 11 of the National Planning Policy Framework; the policy must ensure the development potential of the allocation area is optimised and so ensure the SEA is effectively used to provide for mitigation features that would be better placed in the SEA, such as recreation, significant tree belts and landscape enhancement.

Part 18 – Proposals in the Landscape Improvement Area - OBJECT
The Landscape Improvement Area (LIA) is a large swathe of land on the Figure 63 Spatial Framework, but the Part 18 policy requirements for it are linear features or drainage features. Such items will not require the full extent of the LIA and will be a matter for detailed design at the appropriate time. As such, for the policy to include:
The LIA provides an extensive swathe of land to allow space and flexibility for how the required features will sit within the LIA

Part 18 – Proposals in the Landscape Improvement Area - OBJECT
There should be a section 18a to cover proposals in the Strategic Enhancement Area.
It is helpful that the policy has a section dedicated to the Landscape Improvement Area to give precision and clarity for how this particular land parcel is to perform as part of the wider allocation. Separately the Strategic Enhancement Area (SEA) has various requirements set through the policy and so a comparable section in the Policy would bring appropriate precision and clarity to this particular land parcel. Additional wording to the policy to include:

Proposals in the Strategic Enhancement Area should come forward in conjunction with the site allocation and must:
a. Provide a landscape buffer to the south of the campus that responds positively and sensitively to the existing topography and landscape character, establishing a soft-green edge to the City.
b. Protect and enhance green infrastructure including hedgerows, woodlands, waterbodies and protected species. Measures that support restoration, improve ecological connectivity and benefit nature recovery, including conservation farming, will be supported.
c. Contribute, where appropriate, to protect or enhance Strategic Views and integrate built form into the landscape.
d. Demonstrate how it will contribute to flood risk mitigation through site-specific multifunctional sustainable drainage and nature-based solutions.
e. Utilise Green Belt Land to create a multi-functional landscape that further supports biodiversity, with recreation as an important secondary function.

The matters a-e are informed by the Council’s Habitat Regulations Assessment (2025) and the Site Allocations Topic Paper (2025) alongside the evidence submitted that forms the ‘Third Party Comments’ for Cambridge Biomedical Campus (CBC Landowner Collaboration Group and CBC Ltd). In particular the evidence presented in the ‘Emerging Spatial Framework: Visual Commentary, October 30th 2023’, ‘CBC Preliminary Ecological Appraisal – Part 1, December 2022’, ‘CBC Case for Expansion, December 2022’ and ‘Cambridge Biomedical Campus Vision 2050: Creating a life sciences quarter for Cambridge’.
To support the allocation and the exceptional reasons for releasing land from the Green Belt it is important that the National Planning Policy Framework (NPPF 2024) is adhered to:

Paragraph 151
Once Green Belts have been defined, local planning authorities should plan positively to enhance their beneficial use, such as looking for opportunities to provide access; to provide opportunities for outdoor sport and recreation; to retain and enhance landscapes, visual amenity and biodiversity; or to improve damaged and derelict land. Where Green Belt land is released for development through plan preparation or review, the ‘Golden Rules’ in paragraph 156 below should apply.

Paragraph 156
Where major development involving the provision of housing is proposed on land released from the Green Belt through plan preparation or review, or on sites in the Green Belt subject to a planning application, the following contributions (‘Golden Rules’) should be made:
a. affordable housing which reflects either: (i) development plan policies produced in accordance with paragraphs 67-68 of this Framework; or (ii) until such policies are in place, the policy set out in paragraph 157 below;
b. necessary improvements to local or national infrastructure; and
c. the provision of new, or improvements to existing, green spaces that are accessible to the public. New residents should be able to access good quality green spaces within a short walk of their home, whether through onsite provision or through access to offsite spaces.

The NPPF sets a requirement for the provision of new or improved green spaces that are accessible to the public where major development is to be delivered on land released from the Green Belt. This relates to development that includes housing, which the S/CBC allows for. To ensure a robust and sound allocation it requires appropriate new or improved green spaces. Due to the extent of land to be released from the Green Belt, the SEA is required to contribute to the provision of green spaces and ensure there is a sound and NPPF compliant allocation beyond any space which could be accommodated within the existing campus or built-up area of the campus expansion land.
The SEA has an integral and coordinated role to contribute to the delivery of the allocation, especially to underpin a sound release of land from the Green Belt.

The submitted paper forms a representation to the Regulation 18 January 2026 consultation to the emerging Greater Cambridge Local Plan (GCLP) on behalf of the Pemberton Family and Pemberton Family Trusts (“the Pemberton Family”). It is a submission focussed on the proposed allocation (ref: S/CBC) ‘Cambridge Biomedical Campus (including Addenbrooke’s Hospital)’. The Pemberton Family is the landowner of a major part of the allocation area and remains a committed member of the ‘Cambridge Biomedical Campus Landowners Collaboration Group (LCG)’ and to continuing to work together as group to achieve a deliverable development.
Attached to the submitted representation is a copy of the representation to the plan prepared by Cambridgeshire County Council (as landowner) and Prologis. The Pemberton Family support the overall approach to the policy set out by the attached representation. There are, however, two matters at part 7 and Part 17d of the policy where the Pemberton Family requires a detailed amendment to the policy to ensure the effective use of land and to ensure a sound allocation that involves the release of Green Belt land. The representations made in this document are matters only related to these two key planning matters. The Pemberton Family has been a long-term stakeholder in the successful development of Phases 1 and 2 of the campus and as owners of land and interests required for its further expansion, they offer strong support to the overall policy and the continued recognition by the emerging Local Plan of the important role of the Cambridge Biomedical Campus and its future growth. This representation refers to some detailed policy points that are requested to be changed and in the context of a Local Plan representation they have been lodged as ‘objections’, notwithstanding the overarching support to the policy. The submission is structured to address only those parts of Policy S/CBC upon which a comment is made.

Part 1 - Cambridge Biomedical Campus (including Addenbrooke’s Hospital) - OBJECT
Part 1 references the Policies Map and the land to be allocated. The Policy, Spatial Framework and the Proposals Map all need to align and be consistent and accurate in how they represent the land and allocation.
The Spatial Framework is clear that part of the site is ‘Strategic Enhancement Area (SEA)’ and another part of the site is ‘Landscape Improvement Area (LIA)’. The policy refers to these areas separately and places different policy expectations on these different parts of the site. It is important that all Local Plan plans or diagrams that present the site graphically show and designate these two areas (LIA and SEA) separately.

Part 17.d – Nature - SUPPORT
Support is given to the recognition of the role that the Strategic Enhancement Area can offer to the overall delivery of the site, including a well vegetated landscape buffer. If an amendment is made to this clear and appropriate policy position it would attract an objection. It is important that planning policy strives for the effective use of land in accordance with Section 11 of the National Planning Policy Framework; the policy must ensure the development potential of the allocation area is optimised and so ensure the SEA is effectively used to provide for mitigation features that would be better placed in the SEA, such as recreation, significant tree belts and landscape enhancement.

Part 18 – Proposals in the Landscape Improvement Area - OBJECT
The Landscape Improvement Area (LIA) is a large swathe of land on the Figure 63 Spatial Framework, but the Part 18 policy requirements for it are linear features or drainage features. Such items will not require the full extent of the LIA and will be a matter for detailed design at the appropriate time. As such, for the policy to include:
The LIA provides an extensive swathe of land to allow space and flexibility for how the required features will sit within the LIA

Part 18 – Proposals in the Landscape Improvement Area - OBJECT
There should be a section 18a to cover proposals in the Strategic Enhancement Area.
It is helpful that the policy has a section dedicated to the Landscape Improvement Area to give precision and clarity for how this particular land parcel is to perform as part of the wider allocation. Separately the Strategic Enhancement Area (SEA) has various requirements set through the policy and so a comparable section in the Policy would bring appropriate precision and clarity to this particular land parcel. Additional wording to the policy to include:

Proposals in the Strategic Enhancement Area should come forward in conjunction with the site allocation and must:
a. Provide a landscape buffer to the south of the campus that responds positively and sensitively to the existing topography and landscape character, establishing a soft-green edge to the City.
b. Protect and enhance green infrastructure including hedgerows, woodlands, waterbodies and protected species. Measures that support restoration, improve ecological connectivity and benefit nature recovery, including conservation farming, will be supported.
c. Contribute, where appropriate, to protect or enhance Strategic Views and integrate built form into the landscape.
d. Demonstrate how it will contribute to flood risk mitigation through site-specific multifunctional sustainable drainage and nature-based solutions.
e. Utilise Green Belt Land to create a multi-functional landscape that further supports biodiversity, with recreation as an important secondary function.

The matters a-e are informed by the Council’s Habitat Regulations Assessment (2025) and the Site Allocations Topic Paper (2025) alongside the evidence submitted that forms the ‘Third Party Comments’ for Cambridge Biomedical Campus (CBC Landowner Collaboration Group and CBC Ltd). In particular the evidence presented in the ‘Emerging Spatial Framework: Visual Commentary, October 30th 2023’, ‘CBC Preliminary Ecological Appraisal – Part 1, December 2022’, ‘CBC Case for Expansion, December 2022’ and ‘Cambridge Biomedical Campus Vision 2050: Creating a life sciences quarter for Cambridge’.
To support the allocation and the exceptional reasons for releasing land from the Green Belt it is important that the National Planning Policy Framework (NPPF 2024) is adhered to:

Paragraph 151
Once Green Belts have been defined, local planning authorities should plan positively to enhance their beneficial use, such as looking for opportunities to provide access; to provide opportunities for outdoor sport and recreation; to retain and enhance landscapes, visual amenity and biodiversity; or to improve damaged and derelict land. Where Green Belt land is released for development through plan preparation or review, the ‘Golden Rules’ in paragraph 156 below should apply.

Paragraph 156
Where major development involving the provision of housing is proposed on land released from the Green Belt through plan preparation or review, or on sites in the Green Belt subject to a planning application, the following contributions (‘Golden Rules’) should be made:
a. affordable housing which reflects either: (i) development plan policies produced in accordance with paragraphs 67-68 of this Framework; or (ii) until such policies are in place, the policy set out in paragraph 157 below;
b. necessary improvements to local or national infrastructure; and
c. the provision of new, or improvements to existing, green spaces that are accessible to the public. New residents should be able to access good quality green spaces within a short walk of their home, whether through onsite provision or through access to offsite spaces.

The NPPF sets a requirement for the provision of new or improved green spaces that are accessible to the public where major development is to be delivered on land released from the Green Belt. This relates to development that includes housing, which the S/CBC allows for. To ensure a robust and sound allocation it requires appropriate new or improved green spaces. Due to the extent of land to be released from the Green Belt, the SEA is required to contribute to the provision of green spaces and ensure there is a sound and NPPF compliant allocation beyond any space which could be accommodated within the existing campus or built-up area of the campus expansion land.
The SEA has an integral and coordinated role to contribute to the delivery of the allocation, especially to underpin a sound release of land from the Green Belt.

The submitted paper forms a representation to the Regulation 18 January 2026 consultation to the emerging Greater Cambridge Local Plan (GCLP) on behalf of the Pemberton Family and Pemberton Family Trusts (“the Pemberton Family”). It is a submission focussed on the proposed allocation (ref: S/CBC) ‘Cambridge Biomedical Campus (including Addenbrooke’s Hospital)’. The Pemberton Family is the landowner of a major part of the allocation area and remains a committed member of the ‘Cambridge Biomedical Campus Landowners Collaboration Group (LCG)’ and to continuing to work together as group to achieve a deliverable development.
Attached to the submitted representation is a copy of the representation to the plan prepared by Cambridgeshire County Council (as landowner) and Prologis. The Pemberton Family support the overall approach to the policy set out by the attached representation. There are, however, two matters at part 7 and Part 17d of the policy where the Pemberton Family requires a detailed amendment to the policy to ensure the effective use of land and to ensure a sound allocation that involves the release of Green Belt land. The representations made in this document are matters only related to these two key planning matters. The Pemberton Family has been a long-term stakeholder in the successful development of Phases 1 and 2 of the campus and as owners of land and interests required for its further expansion, they offer strong support to the overall policy and the continued recognition by the emerging Local Plan of the important role of the Cambridge Biomedical Campus and its future growth. This representation refers to some detailed policy points that are requested to be changed and in the context of a Local Plan representation they have been lodged as ‘objections’, notwithstanding the overarching support to the policy. The submission is structured to address only those parts of Policy S/CBC upon which a comment is made.

Part 1 - Cambridge Biomedical Campus (including Addenbrooke’s Hospital) - OBJECT
Part 1 references the Policies Map and the land to be allocated. The Policy, Spatial Framework and the Proposals Map all need to align and be consistent and accurate in how they represent the land and allocation.
The Spatial Framework is clear that part of the site is ‘Strategic Enhancement Area (SEA)’ and another part of the site is ‘Landscape Improvement Area (LIA)’. The policy refers to these areas separately and places different policy expectations on these different parts of the site. It is important that all Local Plan plans or diagrams that present the site graphically show and designate these two areas (LIA and SEA) separately.

Part 17.d – Nature - SUPPORT
Support is given to the recognition of the role that the Strategic Enhancement Area can offer to the overall delivery of the site, including a well vegetated landscape buffer. If an amendment is made to this clear and appropriate policy position it would attract an objection. It is important that planning policy strives for the effective use of land in accordance with Section 11 of the National Planning Policy Framework; the policy must ensure the development potential of the allocation area is optimised and so ensure the SEA is effectively used to provide for mitigation features that would be better placed in the SEA, such as recreation, significant tree belts and landscape enhancement.

Part 18 – Proposals in the Landscape Improvement Area - OBJECT
The Landscape Improvement Area (LIA) is a large swathe of land on the Figure 63 Spatial Framework, but the Part 18 policy requirements for it are linear features or drainage features. Such items will not require the full extent of the LIA and will be a matter for detailed design at the appropriate time. As such, for the policy to include:
The LIA provides an extensive swathe of land to allow space and flexibility for how the required features will sit within the LIA

Part 18 – Proposals in the Landscape Improvement Area - OBJECT
There should be a section 18a to cover proposals in the Strategic Enhancement Area.
It is helpful that the policy has a section dedicated to the Landscape Improvement Area to give precision and clarity for how this particular land parcel is to perform as part of the wider allocation. Separately the Strategic Enhancement Area (SEA) has various requirements set through the policy and so a comparable section in the Policy would bring appropriate precision and clarity to this particular land parcel. Additional wording to the policy to include:

Proposals in the Strategic Enhancement Area should come forward in conjunction with the site allocation and must:
a. Provide a landscape buffer to the south of the campus that responds positively and sensitively to the existing topography and landscape character, establishing a soft-green edge to the City.
b. Protect and enhance green infrastructure including hedgerows, woodlands, waterbodies and protected species. Measures that support restoration, improve ecological connectivity and benefit nature recovery, including conservation farming, will be supported.
c. Contribute, where appropriate, to protect or enhance Strategic Views and integrate built form into the landscape.
d. Demonstrate how it will contribute to flood risk mitigation through site-specific multifunctional sustainable drainage and nature-based solutions.
e. Utilise Green Belt Land to create a multi-functional landscape that further supports biodiversity, with recreation as an important secondary function.

The matters a-e are informed by the Council’s Habitat Regulations Assessment (2025) and the Site Allocations Topic Paper (2025) alongside the evidence submitted that forms the ‘Third Party Comments’ for Cambridge Biomedical Campus (CBC Landowner Collaboration Group and CBC Ltd). In particular the evidence presented in the ‘Emerging Spatial Framework: Visual Commentary, October 30th 2023’, ‘CBC Preliminary Ecological Appraisal – Part 1, December 2022’, ‘CBC Case for Expansion, December 2022’ and ‘Cambridge Biomedical Campus Vision 2050: Creating a life sciences quarter for Cambridge’.
To support the allocation and the exceptional reasons for releasing land from the Green Belt it is important that the National Planning Policy Framework (NPPF 2024) is adhered to:

Paragraph 151
Once Green Belts have been defined, local planning authorities should plan positively to enhance their beneficial use, such as looking for opportunities to provide access; to provide opportunities for outdoor sport and recreation; to retain and enhance landscapes, visual amenity and biodiversity; or to improve damaged and derelict land. Where Green Belt land is released for development through plan preparation or review, the ‘Golden Rules’ in paragraph 156 below should apply.

Paragraph 156
Where major development involving the provision of housing is proposed on land released from the Green Belt through plan preparation or review, or on sites in the Green Belt subject to a planning application, the following contributions (‘Golden Rules’) should be made:
a. affordable housing which reflects either: (i) development plan policies produced in accordance with paragraphs 67-68 of this Framework; or (ii) until such policies are in place, the policy set out in paragraph 157 below;
b. necessary improvements to local or national infrastructure; and
c. the provision of new, or improvements to existing, green spaces that are accessible to the public. New residents should be able to access good quality green spaces within a short walk of their home, whether through onsite provision or through access to offsite spaces.

The NPPF sets a requirement for the provision of new or improved green spaces that are accessible to the public where major development is to be delivered on land released from the Green Belt. This relates to development that includes housing, which the S/CBC allows for. To ensure a robust and sound allocation it requires appropriate new or improved green spaces. Due to the extent of land to be released from the Green Belt, the SEA is required to contribute to the provision of green spaces and ensure there is a sound and NPPF compliant allocation beyond any space which could be accommodated within the existing campus or built-up area of the campus expansion land.
The SEA has an integral and coordinated role to contribute to the delivery of the allocation, especially to underpin a sound release of land from the Green Belt.

The submitted paper forms a representation to the Regulation 18 January 2026 consultation to the emerging Greater Cambridge Local Plan (GCLP) on behalf of the Pemberton Family and Pemberton Family Trusts (“the Pemberton Family”). It is a submission focussed on the proposed allocation (ref: S/CBC) ‘Cambridge Biomedical Campus (including Addenbrooke’s Hospital)’. The Pemberton Family is the landowner of a major part of the allocation area and remains a committed member of the ‘Cambridge Biomedical Campus Landowners Collaboration Group (LCG)’ and to continuing to work together as group to achieve a deliverable development.
Attached to the submitted representation is a copy of the representation to the plan prepared by Cambridgeshire County Council (as landowner) and Prologis. The Pemberton Family support the overall approach to the policy set out by the attached representation. There are, however, two matters at part 7 and Part 17d of the policy where the Pemberton Family requires a detailed amendment to the policy to ensure the effective use of land and to ensure a sound allocation that involves the release of Green Belt land. The representations made in this document are matters only related to these two key planning matters. The Pemberton Family has been a long-term stakeholder in the successful development of Phases 1 and 2 of the campus and as owners of land and interests required for its further expansion, they offer strong support to the overall policy and the continued recognition by the emerging Local Plan of the important role of the Cambridge Biomedical Campus and its future growth. This representation refers to some detailed policy points that are requested to be changed and in the context of a Local Plan representation they have been lodged as ‘objections’, notwithstanding the overarching support to the policy. The submission is structured to address only those parts of Policy S/CBC upon which a comment is made.

Part 1 - Cambridge Biomedical Campus (including Addenbrooke’s Hospital) - OBJECT
Part 1 references the Policies Map and the land to be allocated. The Policy, Spatial Framework and the Proposals Map all need to align and be consistent and accurate in how they represent the land and allocation.
The Spatial Framework is clear that part of the site is ‘Strategic Enhancement Area (SEA)’ and another part of the site is ‘Landscape Improvement Area (LIA)’. The policy refers to these areas separately and places different policy expectations on these different parts of the site. It is important that all Local Plan plans or diagrams that present the site graphically show and designate these two areas (LIA and SEA) separately.

Part 17.d – Nature - SUPPORT
Support is given to the recognition of the role that the Strategic Enhancement Area can offer to the overall delivery of the site, including a well vegetated landscape buffer. If an amendment is made to this clear and appropriate policy position it would attract an objection. It is important that planning policy strives for the effective use of land in accordance with Section 11 of the National Planning Policy Framework; the policy must ensure the development potential of the allocation area is optimised and so ensure the SEA is effectively used to provide for mitigation features that would be better placed in the SEA, such as recreation, significant tree belts and landscape enhancement.

Part 18 – Proposals in the Landscape Improvement Area - OBJECT
The Landscape Improvement Area (LIA) is a large swathe of land on the Figure 63 Spatial Framework, but the Part 18 policy requirements for it are linear features or drainage features. Such items will not require the full extent of the LIA and will be a matter for detailed design at the appropriate time. As such, for the policy to include:
The LIA provides an extensive swathe of land to allow space and flexibility for how the required features will sit within the LIA

Part 18 – Proposals in the Landscape Improvement Area - OBJECT
There should be a section 18a to cover proposals in the Strategic Enhancement Area.
It is helpful that the policy has a section dedicated to the Landscape Improvement Area to give precision and clarity for how this particular land parcel is to perform as part of the wider allocation. Separately the Strategic Enhancement Area (SEA) has various requirements set through the policy and so a comparable section in the Policy would bring appropriate precision and clarity to this particular land parcel. Additional wording to the policy to include:

Proposals in the Strategic Enhancement Area should come forward in conjunction with the site allocation and must:
a. Provide a landscape buffer to the south of the campus that responds positively and sensitively to the existing topography and landscape character, establishing a soft-green edge to the City.
b. Protect and enhance green infrastructure including hedgerows, woodlands, waterbodies and protected species. Measures that support restoration, improve ecological connectivity and benefit nature recovery, including conservation farming, will be supported.
c. Contribute, where appropriate, to protect or enhance Strategic Views and integrate built form into the landscape.
d. Demonstrate how it will contribute to flood risk mitigation through site-specific multifunctional sustainable drainage and nature-based solutions.
e. Utilise Green Belt Land to create a multi-functional landscape that further supports biodiversity, with recreation as an important secondary function.

The matters a-e are informed by the Council’s Habitat Regulations Assessment (2025) and the Site Allocations Topic Paper (2025) alongside the evidence submitted that forms the ‘Third Party Comments’ for Cambridge Biomedical Campus (CBC Landowner Collaboration Group and CBC Ltd). In particular the evidence presented in the ‘Emerging Spatial Framework: Visual Commentary, October 30th 2023’, ‘CBC Preliminary Ecological Appraisal – Part 1, December 2022’, ‘CBC Case for Expansion, December 2022’ and ‘Cambridge Biomedical Campus Vision 2050: Creating a life sciences quarter for Cambridge’.
To support the allocation and the exceptional reasons for releasing land from the Green Belt it is important that the National Planning Policy Framework (NPPF 2024) is adhered to:

Paragraph 151
Once Green Belts have been defined, local planning authorities should plan positively to enhance their beneficial use, such as looking for opportunities to provide access; to provide opportunities for outdoor sport and recreation; to retain and enhance landscapes, visual amenity and biodiversity; or to improve damaged and derelict land. Where Green Belt land is released for development through plan preparation or review, the ‘Golden Rules’ in paragraph 156 below should apply.

Paragraph 156
Where major development involving the provision of housing is proposed on land released from the Green Belt through plan preparation or review, or on sites in the Green Belt subject to a planning application, the following contributions (‘Golden Rules’) should be made:
a. affordable housing which reflects either: (i) development plan policies produced in accordance with paragraphs 67-68 of this Framework; or (ii) until such policies are in place, the policy set out in paragraph 157 below;
b. necessary improvements to local or national infrastructure; and
c. the provision of new, or improvements to existing, green spaces that are accessible to the public. New residents should be able to access good quality green spaces within a short walk of their home, whether through onsite provision or through access to offsite spaces.

The NPPF sets a requirement for the provision of new or improved green spaces that are accessible to the public where major development is to be delivered on land released from the Green Belt. This relates to development that includes housing, which the S/CBC allows for. To ensure a robust and sound allocation it requires appropriate new or improved green spaces. Due to the extent of land to be released from the Green Belt, the SEA is required to contribute to the provision of green spaces and ensure there is a sound and NPPF compliant allocation beyond any space which could be accommodated within the existing campus or built-up area of the campus expansion land.
The SEA has an integral and coordinated role to contribute to the delivery of the allocation, especially to underpin a sound release of land from the Green Belt.

The submitted paper forms a representation to the Regulation 18 January 2026 consultation to the emerging Greater Cambridge Local Plan (GCLP) on behalf of the Pemberton Family and Pemberton Family Trusts (“the Pemberton Family”). It is a submission focussed on the proposed allocation (ref: S/CBC) ‘Cambridge Biomedical Campus (including Addenbrooke’s Hospital)’. The Pemberton Family is the landowner of a major part of the allocation area and remains a committed member of the ‘Cambridge Biomedical Campus Landowners Collaboration Group (LCG)’ and to continuing to work together as group to achieve a deliverable development.
Attached to the submitted representation is a copy of the representation to the plan prepared by Cambridgeshire County Council (as landowner) and Prologis. The Pemberton Family support the overall approach to the policy set out by the attached representation. There are, however, two matters at part 7 and Part 17d of the policy where the Pemberton Family requires a detailed amendment to the policy to ensure the effective use of land and to ensure a sound allocation that involves the release of Green Belt land. The representations made in this document are matters only related to these two key planning matters. The Pemberton Family has been a long-term stakeholder in the successful development of Phases 1 and 2 of the campus and as owners of land and interests required for its further expansion, they offer strong support to the overall policy and the continued recognition by the emerging Local Plan of the important role of the Cambridge Biomedical Campus and its future growth. This representation refers to some detailed policy points that are requested to be changed and in the context of a Local Plan representation they have been lodged as ‘objections’, notwithstanding the overarching support to the policy. The submission is structured to address only those parts of Policy S/CBC upon which a comment is made.

Part 1 - Cambridge Biomedical Campus (including Addenbrooke’s Hospital) - OBJECT
Part 1 references the Policies Map and the land to be allocated. The Policy, Spatial Framework and the Proposals Map all need to align and be consistent and accurate in how they represent the land and allocation.
The Spatial Framework is clear that part of the site is ‘Strategic Enhancement Area (SEA)’ and another part of the site is ‘Landscape Improvement Area (LIA)’. The policy refers to these areas separately and places different policy expectations on these different parts of the site. It is important that all Local Plan plans or diagrams that present the site graphically show and designate these two areas (LIA and SEA) separately.

Part 17.d – Nature - SUPPORT
Support is given to the recognition of the role that the Strategic Enhancement Area can offer to the overall delivery of the site, including a well vegetated landscape buffer. If an amendment is made to this clear and appropriate policy position it would attract an objection. It is important that planning policy strives for the effective use of land in accordance with Section 11 of the National Planning Policy Framework; the policy must ensure the development potential of the allocation area is optimised and so ensure the SEA is effectively used to provide for mitigation features that would be better placed in the SEA, such as recreation, significant tree belts and landscape enhancement.

Part 18 – Proposals in the Landscape Improvement Area - OBJECT
The Landscape Improvement Area (LIA) is a large swathe of land on the Figure 63 Spatial Framework, but the Part 18 policy requirements for it are linear features or drainage features. Such items will not require the full extent of the LIA and will be a matter for detailed design at the appropriate time. As such, for the policy to include:
The LIA provides an extensive swathe of land to allow space and flexibility for how the required features will sit within the LIA

Part 18 – Proposals in the Landscape Improvement Area - OBJECT
There should be a section 18a to cover proposals in the Strategic Enhancement Area.
It is helpful that the policy has a section dedicated to the Landscape Improvement Area to give precision and clarity for how this particular land parcel is to perform as part of the wider allocation. Separately the Strategic Enhancement Area (SEA) has various requirements set through the policy and so a comparable section in the Policy would bring appropriate precision and clarity to this particular land parcel. Additional wording to the policy to include:

Proposals in the Strategic Enhancement Area should come forward in conjunction with the site allocation and must:
a. Provide a landscape buffer to the south of the campus that responds positively and sensitively to the existing topography and landscape character, establishing a soft-green edge to the City.
b. Protect and enhance green infrastructure including hedgerows, woodlands, waterbodies and protected species. Measures that support restoration, improve ecological connectivity and benefit nature recovery, including conservation farming, will be supported.
c. Contribute, where appropriate, to protect or enhance Strategic Views and integrate built form into the landscape.
d. Demonstrate how it will contribute to flood risk mitigation through site-specific multifunctional sustainable drainage and nature-based solutions.
e. Utilise Green Belt Land to create a multi-functional landscape that further supports biodiversity, with recreation as an important secondary function.

The matters a-e are informed by the Council’s Habitat Regulations Assessment (2025) and the Site Allocations Topic Paper (2025) alongside the evidence submitted that forms the ‘Third Party Comments’ for Cambridge Biomedical Campus (CBC Landowner Collaboration Group and CBC Ltd). In particular the evidence presented in the ‘Emerging Spatial Framework: Visual Commentary, October 30th 2023’, ‘CBC Preliminary Ecological Appraisal – Part 1, December 2022’, ‘CBC Case for Expansion, December 2022’ and ‘Cambridge Biomedical Campus Vision 2050: Creating a life sciences quarter for Cambridge’.
To support the allocation and the exceptional reasons for releasing land from the Green Belt it is important that the National Planning Policy Framework (NPPF 2024) is adhered to:

Paragraph 151
Once Green Belts have been defined, local planning authorities should plan positively to enhance their beneficial use, such as looking for opportunities to provide access; to provide opportunities for outdoor sport and recreation; to retain and enhance landscapes, visual amenity and biodiversity; or to improve damaged and derelict land. Where Green Belt land is released for development through plan preparation or review, the ‘Golden Rules’ in paragraph 156 below should apply.

Paragraph 156
Where major development involving the provision of housing is proposed on land released from the Green Belt through plan preparation or review, or on sites in the Green Belt subject to a planning application, the following contributions (‘Golden Rules’) should be made:
a. affordable housing which reflects either: (i) development plan policies produced in accordance with paragraphs 67-68 of this Framework; or (ii) until such policies are in place, the policy set out in paragraph 157 below;
b. necessary improvements to local or national infrastructure; and
c. the provision of new, or improvements to existing, green spaces that are accessible to the public. New residents should be able to access good quality green spaces within a short walk of their home, whether through onsite provision or through access to offsite spaces.

The NPPF sets a requirement for the provision of new or improved green spaces that are accessible to the public where major development is to be delivered on land released from the Green Belt. This relates to development that includes housing, which the S/CBC allows for. To ensure a robust and sound allocation it requires appropriate new or improved green spaces. Due to the extent of land to be released from the Green Belt, the SEA is required to contribute to the provision of green spaces and ensure there is a sound and NPPF compliant allocation beyond any space which could be accommodated within the existing campus or built-up area of the campus expansion land.
The SEA has an integral and coordinated role to contribute to the delivery of the allocation, especially to underpin a sound release of land from the Green Belt.

The submitted paper forms a representation to the Regulation 18 January 2026 consultation to the emerging Greater Cambridge Local Plan (GCLP) on behalf of the Pemberton Family and Pemberton Family Trusts (“the Pemberton Family”). It is a submission focussed on the proposed allocation (ref: S/CBC) ‘Cambridge Biomedical Campus (including Addenbrooke’s Hospital)’. The Pemberton Family is the landowner of a major part of the allocation area and remains a committed member of the ‘Cambridge Biomedical Campus Landowners Collaboration Group (LCG)’ and to continuing to work together as group to achieve a deliverable development.
Attached to the submitted representation is a copy of the representation to the plan prepared by Cambridgeshire County Council (as landowner) and Prologis. The Pemberton Family support the overall approach to the policy set out by the attached representation. There are, however, two matters at part 7 and Part 17d of the policy where the Pemberton Family requires a detailed amendment to the policy to ensure the effective use of land and to ensure a sound allocation that involves the release of Green Belt land. The representations made in this document are matters only related to these two key planning matters. The Pemberton Family has been a long-term stakeholder in the successful development of Phases 1 and 2 of the campus and as owners of land and interests required for its further expansion, they offer strong support to the overall policy and the continued recognition by the emerging Local Plan of the important role of the Cambridge Biomedical Campus and its future growth. This representation refers to some detailed policy points that are requested to be changed and in the context of a Local Plan representation they have been lodged as ‘objections’, notwithstanding the overarching support to the policy. The submission is structured to address only those parts of Policy S/CBC upon which a comment is made.

Part 1 - Cambridge Biomedical Campus (including Addenbrooke’s Hospital) - OBJECT
Part 1 references the Policies Map and the land to be allocated. The Policy, Spatial Framework and the Proposals Map all need to align and be consistent and accurate in how they represent the land and allocation.
The Spatial Framework is clear that part of the site is ‘Strategic Enhancement Area (SEA)’ and another part of the site is ‘Landscape Improvement Area (LIA)’. The policy refers to these areas separately and places different policy expectations on these different parts of the site. It is important that all Local Plan plans or diagrams that present the site graphically show and designate these two areas (LIA and SEA) separately.

Part 17.d – Nature - SUPPORT
Support is given to the recognition of the role that the Strategic Enhancement Area can offer to the overall delivery of the site, including a well vegetated landscape buffer. If an amendment is made to this clear and appropriate policy position it would attract an objection. It is important that planning policy strives for the effective use of land in accordance with Section 11 of the National Planning Policy Framework; the policy must ensure the development potential of the allocation area is optimised and so ensure the SEA is effectively used to provide for mitigation features that would be better placed in the SEA, such as recreation, significant tree belts and landscape enhancement.

Part 18 – Proposals in the Landscape Improvement Area - OBJECT
The Landscape Improvement Area (LIA) is a large swathe of land on the Figure 63 Spatial Framework, but the Part 18 policy requirements for it are linear features or drainage features. Such items will not require the full extent of the LIA and will be a matter for detailed design at the appropriate time. As such, for the policy to include:
The LIA provides an extensive swathe of land to allow space and flexibility for how the required features will sit within the LIA

Part 18 – Proposals in the Landscape Improvement Area - OBJECT
There should be a section 18a to cover proposals in the Strategic Enhancement Area.
It is helpful that the policy has a section dedicated to the Landscape Improvement Area to give precision and clarity for how this particular land parcel is to perform as part of the wider allocation. Separately the Strategic Enhancement Area (SEA) has various requirements set through the policy and so a comparable section in the Policy would bring appropriate precision and clarity to this particular land parcel. Additional wording to the policy to include:

Proposals in the Strategic Enhancement Area should come forward in conjunction with the site allocation and must:
a. Provide a landscape buffer to the south of the campus that responds positively and sensitively to the existing topography and landscape character, establishing a soft-green edge to the City.
b. Protect and enhance green infrastructure including hedgerows, woodlands, waterbodies and protected species. Measures that support restoration, improve ecological connectivity and benefit nature recovery, including conservation farming, will be supported.
c. Contribute, where appropriate, to protect or enhance Strategic Views and integrate built form into the landscape.
d. Demonstrate how it will contribute to flood risk mitigation through site-specific multifunctional sustainable drainage and nature-based solutions.
e. Utilise Green Belt Land to create a multi-functional landscape that further supports biodiversity, with recreation as an important secondary function.

The matters a-e are informed by the Council’s Habitat Regulations Assessment (2025) and the Site Allocations Topic Paper (2025) alongside the evidence submitted that forms the ‘Third Party Comments’ for Cambridge Biomedical Campus (CBC Landowner Collaboration Group and CBC Ltd). In particular the evidence presented in the ‘Emerging Spatial Framework: Visual Commentary, October 30th 2023’, ‘CBC Preliminary Ecological Appraisal – Part 1, December 2022’, ‘CBC Case for Expansion, December 2022’ and ‘Cambridge Biomedical Campus Vision 2050: Creating a life sciences quarter for Cambridge’.
To support the allocation and the exceptional reasons for releasing land from the Green Belt it is important that the National Planning Policy Framework (NPPF 2024) is adhered to:

Paragraph 151
Once Green Belts have been defined, local planning authorities should plan positively to enhance their beneficial use, such as looking for opportunities to provide access; to provide opportunities for outdoor sport and recreation; to retain and enhance landscapes, visual amenity and biodiversity; or to improve damaged and derelict land. Where Green Belt land is released for development through plan preparation or review, the ‘Golden Rules’ in paragraph 156 below should apply.

Paragraph 156
Where major development involving the provision of housing is proposed on land released from the Green Belt through plan preparation or review, or on sites in the Green Belt subject to a planning application, the following contributions (‘Golden Rules’) should be made:
a. affordable housing which reflects either: (i) development plan policies produced in accordance with paragraphs 67-68 of this Framework; or (ii) until such policies are in place, the policy set out in paragraph 157 below;
b. necessary improvements to local or national infrastructure; and
c. the provision of new, or improvements to existing, green spaces that are accessible to the public. New residents should be able to access good quality green spaces within a short walk of their home, whether through onsite provision or through access to offsite spaces.

The NPPF sets a requirement for the provision of new or improved green spaces that are accessible to the public where major development is to be delivered on land released from the Green Belt. This relates to development that includes housing, which the S/CBC allows for. To ensure a robust and sound allocation it requires appropriate new or improved green spaces. Due to the extent of land to be released from the Green Belt, the SEA is required to contribute to the provision of green spaces and ensure there is a sound and NPPF compliant allocation beyond any space which could be accommodated within the existing campus or built-up area of the campus expansion land.
The SEA has an integral and coordinated role to contribute to the delivery of the allocation, especially to underpin a sound release of land from the Green Belt.

The submitted paper forms a representation to the Regulation 18 January 2026 consultation to the emerging Greater Cambridge Local Plan (GCLP) on behalf of the Pemberton Family and Pemberton Family Trusts (“the Pemberton Family”). It is a submission focussed on the proposed allocation (ref: S/CBC) ‘Cambridge Biomedical Campus (including Addenbrooke’s Hospital)’. The Pemberton Family is the landowner of a major part of the allocation area and remains a committed member of the ‘Cambridge Biomedical Campus Landowners Collaboration Group (LCG)’ and to continuing to work together as group to achieve a deliverable development.
Attached to the submitted representation is a copy of the representation to the plan prepared by Cambridgeshire County Council (as landowner) and Prologis. The Pemberton Family support the overall approach to the policy set out by the attached representation. There are, however, two matters at part 7 and Part 17d of the policy where the Pemberton Family requires a detailed amendment to the policy to ensure the effective use of land and to ensure a sound allocation that involves the release of Green Belt land. The representations made in this document are matters only related to these two key planning matters. The Pemberton Family has been a long-term stakeholder in the successful development of Phases 1 and 2 of the campus and as owners of land and interests required for its further expansion, they offer strong support to the overall policy and the continued recognition by the emerging Local Plan of the important role of the Cambridge Biomedical Campus and its future growth. This representation refers to some detailed policy points that are requested to be changed and in the context of a Local Plan representation they have been lodged as ‘objections’, notwithstanding the overarching support to the policy. The submission is structured to address only those parts of Policy S/CBC upon which a comment is made.

Part 1 - Cambridge Biomedical Campus (including Addenbrooke’s Hospital) - OBJECT
Part 1 references the Policies Map and the land to be allocated. The Policy, Spatial Framework and the Proposals Map all need to align and be consistent and accurate in how they represent the land and allocation.
The Spatial Framework is clear that part of the site is ‘Strategic Enhancement Area (SEA)’ and another part of the site is ‘Landscape Improvement Area (LIA)’. The policy refers to these areas separately and places different policy expectations on these different parts of the site. It is important that all Local Plan plans or diagrams that present the site graphically show and designate these two areas (LIA and SEA) separately.

Part 17.d – Nature - SUPPORT
Support is given to the recognition of the role that the Strategic Enhancement Area can offer to the overall delivery of the site, including a well vegetated landscape buffer. If an amendment is made to this clear and appropriate policy position it would attract an objection. It is important that planning policy strives for the effective use of land in accordance with Section 11 of the National Planning Policy Framework; the policy must ensure the development potential of the allocation area is optimised and so ensure the SEA is effectively used to provide for mitigation features that would be better placed in the SEA, such as recreation, significant tree belts and landscape enhancement.

Part 18 – Proposals in the Landscape Improvement Area - OBJECT
The Landscape Improvement Area (LIA) is a large swathe of land on the Figure 63 Spatial Framework, but the Part 18 policy requirements for it are linear features or drainage features. Such items will not require the full extent of the LIA and will be a matter for detailed design at the appropriate time. As such, for the policy to include:
The LIA provides an extensive swathe of land to allow space and flexibility for how the required features will sit within the LIA

Part 18 – Proposals in the Landscape Improvement Area - OBJECT
There should be a section 18a to cover proposals in the Strategic Enhancement Area.
It is helpful that the policy has a section dedicated to the Landscape Improvement Area to give precision and clarity for how this particular land parcel is to perform as part of the wider allocation. Separately the Strategic Enhancement Area (SEA) has various requirements set through the policy and so a comparable section in the Policy would bring appropriate precision and clarity to this particular land parcel. Additional wording to the policy to include:

Proposals in the Strategic Enhancement Area should come forward in conjunction with the site allocation and must:
a. Provide a landscape buffer to the south of the campus that responds positively and sensitively to the existing topography and landscape character, establishing a soft-green edge to the City.
b. Protect and enhance green infrastructure including hedgerows, woodlands, waterbodies and protected species. Measures that support restoration, improve ecological connectivity and benefit nature recovery, including conservation farming, will be supported.
c. Contribute, where appropriate, to protect or enhance Strategic Views and integrate built form into the landscape.
d. Demonstrate how it will contribute to flood risk mitigation through site-specific multifunctional sustainable drainage and nature-based solutions.
e. Utilise Green Belt Land to create a multi-functional landscape that further supports biodiversity, with recreation as an important secondary function.

The matters a-e are informed by the Council’s Habitat Regulations Assessment (2025) and the Site Allocations Topic Paper (2025) alongside the evidence submitted that forms the ‘Third Party Comments’ for Cambridge Biomedical Campus (CBC Landowner Collaboration Group and CBC Ltd). In particular the evidence presented in the ‘Emerging Spatial Framework: Visual Commentary, October 30th 2023’, ‘CBC Preliminary Ecological Appraisal – Part 1, December 2022’, ‘CBC Case for Expansion, December 2022’ and ‘Cambridge Biomedical Campus Vision 2050: Creating a life sciences quarter for Cambridge’.
To support the allocation and the exceptional reasons for releasing land from the Green Belt it is important that the National Planning Policy Framework (NPPF 2024) is adhered to:

Paragraph 151
Once Green Belts have been defined, local planning authorities should plan positively to enhance their beneficial use, such as looking for opportunities to provide access; to provide opportunities for outdoor sport and recreation; to retain and enhance landscapes, visual amenity and biodiversity; or to improve damaged and derelict land. Where Green Belt land is released for development through plan preparation or review, the ‘Golden Rules’ in paragraph 156 below should apply.

Paragraph 156
Where major development involving the provision of housing is proposed on land released from the Green Belt through plan preparation or review, or on sites in the Green Belt subject to a planning application, the following contributions (‘Golden Rules’) should be made:
a. affordable housing which reflects either: (i) development plan policies produced in accordance with paragraphs 67-68 of this Framework; or (ii) until such policies are in place, the policy set out in paragraph 157 below;
b. necessary improvements to local or national infrastructure; and
c. the provision of new, or improvements to existing, green spaces that are accessible to the public. New residents should be able to access good quality green spaces within a short walk of their home, whether through onsite provision or through access to offsite spaces.

The NPPF sets a requirement for the provision of new or improved green spaces that are accessible to the public where major development is to be delivered on land released from the Green Belt. This relates to development that includes housing, which the S/CBC allows for. To ensure a robust and sound allocation it requires appropriate new or improved green spaces. Due to the extent of land to be released from the Green Belt, the SEA is required to contribute to the provision of green spaces and ensure there is a sound and NPPF compliant allocation beyond any space which could be accommodated within the existing campus or built-up area of the campus expansion land.
The SEA has an integral and coordinated role to contribute to the delivery of the allocation, especially to underpin a sound release of land from the Green Belt.

The submitted paper forms a representation to the Regulation 18 January 2026 consultation to the emerging Greater Cambridge Local Plan (GCLP) on behalf of the Pemberton Family and Pemberton Family Trusts (“the Pemberton Family”). It is a submission focussed on the proposed allocation (ref: S/CBC) ‘Cambridge Biomedical Campus (including Addenbrooke’s Hospital)’. The Pemberton Family is the landowner of a major part of the allocation area and remains a committed member of the ‘Cambridge Biomedical Campus Landowners Collaboration Group (LCG)’ and to continuing to work together as group to achieve a deliverable development.
Attached to the submitted representation is a copy of the representation to the plan prepared by Cambridgeshire County Council (as landowner) and Prologis. The Pemberton Family support the overall approach to the policy set out by the attached representation. There are, however, two matters at part 7 and Part 17d of the policy where the Pemberton Family requires a detailed amendment to the policy to ensure the effective use of land and to ensure a sound allocation that involves the release of Green Belt land. The representations made in this document are matters only related to these two key planning matters. The Pemberton Family has been a long-term stakeholder in the successful development of Phases 1 and 2 of the campus and as owners of land and interests required for its further expansion, they offer strong support to the overall policy and the continued recognition by the emerging Local Plan of the important role of the Cambridge Biomedical Campus and its future growth. This representation refers to some detailed policy points that are requested to be changed and in the context of a Local Plan representation they have been lodged as ‘objections’, notwithstanding the overarching support to the policy. The submission is structured to address only those parts of Policy S/CBC upon which a comment is made.

Part 1 - Cambridge Biomedical Campus (including Addenbrooke’s Hospital) - OBJECT
Part 1 references the Policies Map and the land to be allocated. The Policy, Spatial Framework and the Proposals Map all need to align and be consistent and accurate in how they represent the land and allocation.
The Spatial Framework is clear that part of the site is ‘Strategic Enhancement Area (SEA)’ and another part of the site is ‘Landscape Improvement Area (LIA)’. The policy refers to these areas separately and places different policy expectations on these different parts of the site. It is important that all Local Plan plans or diagrams that present the site graphically show and designate these two areas (LIA and SEA) separately.

Part 17.d – Nature - SUPPORT
Support is given to the recognition of the role that the Strategic Enhancement Area can offer to the overall delivery of the site, including a well vegetated landscape buffer. If an amendment is made to this clear and appropriate policy position it would attract an objection. It is important that planning policy strives for the effective use of land in accordance with Section 11 of the National Planning Policy Framework; the policy must ensure the development potential of the allocation area is optimised and so ensure the SEA is effectively used to provide for mitigation features that would be better placed in the SEA, such as recreation, significant tree belts and landscape enhancement.

Part 18 – Proposals in the Landscape Improvement Area - OBJECT
The Landscape Improvement Area (LIA) is a large swathe of land on the Figure 63 Spatial Framework, but the Part 18 policy requirements for it are linear features or drainage features. Such items will not require the full extent of the LIA and will be a matter for detailed design at the appropriate time. As such, for the policy to include:
The LIA provides an extensive swathe of land to allow space and flexibility for how the required features will sit within the LIA

Part 18 – Proposals in the Landscape Improvement Area - OBJECT
There should be a section 18a to cover proposals in the Strategic Enhancement Area.
It is helpful that the policy has a section dedicated to the Landscape Improvement Area to give precision and clarity for how this particular land parcel is to perform as part of the wider allocation. Separately the Strategic Enhancement Area (SEA) has various requirements set through the policy and so a comparable section in the Policy would bring appropriate precision and clarity to this particular land parcel. Additional wording to the policy to include:

Proposals in the Strategic Enhancement Area should come forward in conjunction with the site allocation and must:
a. Provide a landscape buffer to the south of the campus that responds positively and sensitively to the existing topography and landscape character, establishing a soft-green edge to the City.
b. Protect and enhance green infrastructure including hedgerows, woodlands, waterbodies and protected species. Measures that support restoration, improve ecological connectivity and benefit nature recovery, including conservation farming, will be supported.
c. Contribute, where appropriate, to protect or enhance Strategic Views and integrate built form into the landscape.
d. Demonstrate how it will contribute to flood risk mitigation through site-specific multifunctional sustainable drainage and nature-based solutions.
e. Utilise Green Belt Land to create a multi-functional landscape that further supports biodiversity, with recreation as an important secondary function.

The matters a-e are informed by the Council’s Habitat Regulations Assessment (2025) and the Site Allocations Topic Paper (2025) alongside the evidence submitted that forms the ‘Third Party Comments’ for Cambridge Biomedical Campus (CBC Landowner Collaboration Group and CBC Ltd). In particular the evidence presented in the ‘Emerging Spatial Framework: Visual Commentary, October 30th 2023’, ‘CBC Preliminary Ecological Appraisal – Part 1, December 2022’, ‘CBC Case for Expansion, December 2022’ and ‘Cambridge Biomedical Campus Vision 2050: Creating a life sciences quarter for Cambridge’.
To support the allocation and the exceptional reasons for releasing land from the Green Belt it is important that the National Planning Policy Framework (NPPF 2024) is adhered to:

Paragraph 151
Once Green Belts have been defined, local planning authorities should plan positively to enhance their beneficial use, such as looking for opportunities to provide access; to provide opportunities for outdoor sport and recreation; to retain and enhance landscapes, visual amenity and biodiversity; or to improve damaged and derelict land. Where Green Belt land is released for development through plan preparation or review, the ‘Golden Rules’ in paragraph 156 below should apply.

Paragraph 156
Where major development involving the provision of housing is proposed on land released from the Green Belt through plan preparation or review, or on sites in the Green Belt subject to a planning application, the following contributions (‘Golden Rules’) should be made:
a. affordable housing which reflects either: (i) development plan policies produced in accordance with paragraphs 67-68 of this Framework; or (ii) until such policies are in place, the policy set out in paragraph 157 below;
b. necessary improvements to local or national infrastructure; and
c. the provision of new, or improvements to existing, green spaces that are accessible to the public. New residents should be able to access good quality green spaces within a short walk of their home, whether through onsite provision or through access to offsite spaces.

The NPPF sets a requirement for the provision of new or improved green spaces that are accessible to the public where major development is to be delivered on land released from the Green Belt. This relates to development that includes housing, which the S/CBC allows for. To ensure a robust and sound allocation it requires appropriate new or improved green spaces. Due to the extent of land to be released from the Green Belt, the SEA is required to contribute to the provision of green spaces and ensure there is a sound and NPPF compliant allocation beyond any space which could be accommodated within the existing campus or built-up area of the campus expansion land.
The SEA has an integral and coordinated role to contribute to the delivery of the allocation, especially to underpin a sound release of land from the Green Belt.