Greater Cambridge Local Plan: Proposed Submission

We propose changes to the "Uses", "Context", "Built Form", "Movement", and "Lifespan" elements of the policy wording, and the supporting information for the policy.

Please refer to the submission attachment for suggested tracked changes to the wording of Policy S/SHF. Annex 1 at the end of the submission attachment also sets out our recommended (substantive and clarification) changes to Policy S/SHF: Land north of A1307, Bar Hill (Slate Hall Farm).

LDL’s Cambridge 25 site (c.103ha application site) forms the primary part of the proposed 113.3ha site allocation ‘Policy S/SHF: Land north of A1307, Bar Hill (Slate Hall Farm)’ in the draft GCLP “for a major new employment site”. The Indicative Spatial Framework identifying the extent of the Site Allocation is shown at Figure 1.

LDL welcomes and supports the site allocation and most of the draft Policy S/SHF wording, this being a continuation of the site allocation and policy from the Regulation 18 GCLP consultation (December 2025).

Greater Cambridge Evidence Supporting Policy S/SHF Allocation
Planning Practice Guidance (Paragraph: 001 Reference ID: 3-001-20190722) requires plan-making LPAs to undertake “An assessment of land availability [to identify] a future supply of land which is suitable, available and achievable for housing and economic development uses over the plan period.”
The Greater Cambridge Housing and Economic Land Availability Assessment (‘HELAA’), identifies that both the Cambridge 25 site (HELAA Site ID-40248) and the S/SHF site (HELAA Site ID- 05277) are suitable, available and achievable for economic development uses over the plan period.

Informed by the HELAA and the wider GCLP evidence base, SCDC/CCC have identified the S/SHF site as the most suitable site to meet the majority of Greater Cambridge’s strategic B2/B8 development requirements.
The Greater Cambridge Development Strategy Topic Paper (July 2026) explains (at para 5.27) that:
“For industrial and warehousing space, the EHNU 2025 identified a shortfall in space for the plan period that the draft plan needs to meet. As set out in tables 5 and 6 below, sites identified in the Proposed Submission Local Plan provide a flexible supply that more than meet the identified industrial and warehousing floorspace needs for the plan period, noting that precise delivery timing of space at the sites is uncertain. In particular, at the mixed use strategic allocations, delivery typically follows behind that of housing, and as such may come forward beyond the plan period. Land at Slate Hall Farm, Bar Hill, is a very large site that will come forward in phases and may also continue beyond the plan period.”

The Development Strategy, forming policy S/DS, identifies the S/SHF site as one of the “strategic scale allocations…proposed to meet the majority of the development needs to 2045 and beyond” as follows (at 2 e. i.):
“Slate Hall Farm, Junction 25, A14 - an allocation for master-planned employment-led development that responds sensitively to the local landscape and secures access to new green infrastructure for future workers and the local community: including approximately 220,000 square metres employment floorspace for industrial and warehousing uses, with a mix of small-medium units to support the growth of a wide range of different businesses;”

The Greater Cambridge Sustainability Appraisal (LUC, July 2026) (paras 5.714-5.722) assesses the draft allocation against the relevant 13 of the 15 Sustainability Appraisal objectives (at Table 5.71), finding the site to score positively against all criteria, bar the ‘efficient use of land’ objective.

LDL Additional Evidence Supporting Policy S/SHF Allocation
Following pre-application engagement with the GCSP, SCDC and other stakeholders, LDL submitted an Outline Planning Application (OPA) for the Cambridge 25 site (ref.26/02534), validated on 03 July 2026, for the following development:

“Development of up to 230,000 m2 GIA of employment floorspace (within Use Classes E (g)(i), E(g)(ii), E(g)(iii), B2, and B8) together with supporting community and amenity space (within Use Classes F1, F2, E(a), E(b), E(d), and E(f)), nature park and biodiversity zone, service yards and parking areas, formation of primary means of access, associated landscaping, earthworks, drainage and other associated works (outline, all matters reserved except for the principal means of vehicular access to the Site).”

The OPA scheme and the associated plans and assessments (at Appendix 1) serve to demonstrate how the Cambridge 25 site and wider site allocation and policy are proposed to be realised and add to the Councils’ GCLP evidence that this site allocation can successfully and promptly be delivered to meet a significant proportion of the identified employment land requirement. The Cambridge 25 ES and the OPA planning assessments provide detailed assessments of the suitability of major industrial and logistics development on the S/SHF site (also at Appendix 1).

The Planning Statement (Planning Prospects, June 2026) (Appendix 1) draws those Cambridge 25 assessment findings together in its conclusion (at para 8.13) that:
“The Proposed Development is supported by a comprehensive suite of technical documents. These deal with the need for the scheme, the socio-economic benefits, and then aspects of design and sustainability, landscape and visual considerations, transport and highways, noise and vibration, air quality, ecology and trees, the historic environment, ground conditions, soils and agricultural land, water resources and flood risk, and health impacts. Considering this material as a whole, the Proposed Development is shown to be acceptable, subject to mitigation measures and taking account of identified impacts. In a number of cases – for example in terms of landscape and visual considerations, transport and highways, amenity, arboriculture, and ground conditions – particular attention is drawn to the eminent suitability of the Site to accommodate development of this type.”

We have also prepared a HELAA Update for the Cambridge 25 site (HELAA Site ID-40248) (at Appendix 2) to further demonstrate that the site is suitable, available and achievable for major employment park development, drawing on the plans and assessments forming part of the OPA (ref. 26/02534/OUT) submission.

Salhia and LDL are committed to the successful implementation of its Cambridge 25 employment park development on its land and the realisation of the wider allocation site, contributing to the economic vision and growth priorities of the GCLP. Salhia’s development track record and plan for the delivery of Cambridge 25, following planning permission, are explained in its Delivery Statement (at Appendix 3).

Salhia anticipates that construction of the completed development will be phased over several years, guided by market requirements, with the indicative development timetable (ES para 3.4.1) (Appendix 1) currently anticipating that the first buildings being completed in 2029.

Proposed Substantive Modifications to Policy S/SHF
LDL supports the site allocation and most of the draft Policy S/SHF wording. However, we consider it is necessary to seek substantive or clarification modifications to a limited number of elements within the policy, to ensure the policy is more appropriately worded and more consistent with the most up to date available evidence. We also comment on and seek changes to elements of the Supporting Information (text) to the policy.

Annex 1 at the end of this letter / representation sets out our recommended (substantive and clarification) changes to Policy S/SHF: Land north of A1307, Bar Hill (Slate Hall Farm). An explanation of our recommended amendments is provided below:

Uses
The strategic location, size and context of the S/SHF site allocation make it the most suitable and sustainable site for strategic B2/B8 uses in Greater Cambridge. However, we consider it is also appropriate for this to accommodate an element of E(g)(iii) (Light Industrial) use within the site allocation, for reasons including:

1 The Council’s evidence on industrial need (in the Greater Cambridge Employment and Housing Needs Update 2024 - 2045, published in 2025 [‘EHNU 2025’]) does not differentiate between light and general industrial uses.
2 The Development Strategy policy, S/DS, in identifying the strategic scale allocations proposed to meet the majority of the employment development needs, identifies a number of sites suitable for a mix of employment uses including ‘industrial uses’ and ‘industrial processes’ – i.e. without distinguishing between light and general industry.
3 The proposed affordable workspace and creative industries policy, J/AW, treats E(g)(iii) light industry alongside B2 general industry and B8 warehousing in limb 2., separately from E(g)(i & ii) in limb 1.
4 It is important for there to be a choice of locations for all manufacturing businesses who may wish to locate or expand in the Plan area, including those of a more routine, light industrial, nature, for whom there is commercial benefit in clustering alongside a B2/B8 cluster.

Therefore, whilst there are some differences in the specific locational and market requirements of the general industrial and logistics sector from light industry, the two industrial uses should not be defined separately in a Local Plan land use context.

We also consider that, in addition to the appropriateness of identifying some Class E(g)(iii) (Light Industrial) use within the land use mix at this Employment Park site allocation, there is also masterplanning and design merit in doing so because light industrial uses generally require smaller units and so encouraging a wider range of building sizes.

However, we do consider the broadening of the acceptable land uses within this allocation to include Class E(g)(iii) light industry uses should be controlled to comprise a small proportion of the Employment Park development, to ensure that it does not prejudice meeting the primary strategic B2/B8 needs for development on this site.

On this basis, for the policy’s soundness to be more robust, and consistent with LDL’s representation on Policy S/DS: Development Strategy, we consider it is necessary to insert an additional sentence within policy S/SHF 6, as follows:
“Class E(g)(iii) (Light Industrial) uses, where the total amount and Class E(g)(iii) (Light Industrial) floorspace does not exceed 30,000 sq m gross.”

Context
Bullet 9 of policy S/SHF states that the development at Land North of A1307, Bar Hill (Slate Hall Farm) must: “Mitigate the impact of the development on Slate Hall Farm, a potential non designated heritage asset.”

Bullet 16 then states that: “Slate Hall Farm must be retained as a potential non designated heritage asset.”

This is not consistent with the 2026 HELAA for the site (HELAA Site ID: 05277) which confirms that Slate Hall Farm is not a Non- Designated Heritage Asset, stating:

“The additional information has been assessed, and it is agreed that Slate Hall Farm buildings are not considered to be non-designated heritage assets. Therefore, from a built heritage perspective, the RAG score has been updated to green”.

That additional information comprised ‘The Slate Hall Farm Building Heritage Appraisal’, undertaken by RPS Tetra Tech, 26 January 2026, (at Appendix 4) – this originally formed part of our GCLP Reg18 representation, 30 January 2026. For the reasons explained in the statement (pg.2)) it concludes that “We therefore adjudge the Slate Hall Farm building not to be a non-designated heritage asset.”

More recently, the Greater Cambridge’s Conservation Officer has confirmed in their consultation response (dated 04 August 2026) to Outline Planning Application (ref. 26/02534) (at Appendix 5), that:

“It had previously been queried whether Slate Farmhouse constituted a non-designated heritage asset (NDHA), however a heritage assessment provided as part of the Local Plan call for site HELAA showed the site had undergone lot of modern development and changes and it is agreed that the building is not considered a NDHA, so can be excluded from the impact assessment.”

Accordingly, we consider that bullets 9 and 16 should be deleted to be factually accurate and ensure this policy is justified and therefore sound in accordance with Paragraph 36 (b) of the NPPF 2024.

Proposed Clarification Modifications to Policy S/SHF

Introduction
• Bullet 1- Below amendment required to remove closed list of who can prepare the Site Wide Masterplan, as this is not justified. For example, it could also be prepared by a developer or prospective occupier(s).

“A site wide Masterplan will be prepared in conjunction with the Council and in consultation with the local community and other stakeholders. The Masterplan should be broadly aligned with the indicative Spatial Framework shown at Figure 89 and will need to identify the broad distribution of land uses, infrastructure delivery and phasing and will be used as a basis for the consideration of subsequent planning applications. The masterplan should be agreed by the Council prior to the approval of any planning applications (and may be subsequently updated by the landowners and/or promoters and agreed by the Council).”

Built Form
• Bullet 13- Below amendment required to provide a more accurate description of Figure 85- Indicative Spatial Framework for Policy S/SHF: Land north of A1307, Bar Hill (Slate Hall Farm).

“Focus built form on the north-west and central parts of the site, with the area to the south-east providing substantial green infrastructure, and water management features along the Oakington Brook.”

• Bullet 14- Below amendment required to clarify where in the site the building heights need to step down to respond to heritage sensitivity. This would also reflect the Parameter Plan and Design Code for the Outline Planning Application.

“Management of impact on landscape by ensuring heights are scaled down to the sensitive edges on the western corner of the site, the mass is organised to avoid a ‘block’ effect and sufficient screening is installed.”

• Bullet 15- Below amendment to align with NPPF para 215 on the need to balance harm to significant to a designated heritage asset against the public benefits:

“Through the preparation of a Heritage Impact Assessment, protect as far as possible, and where appropriate, enhance the significance of heritage assets and their setting, including the Grade II The Grange, Grade II* Parish Church of All Saints, Lolworth and Grade II 2 and 4 The Green.”

Movement
• Bullet 21a- Replacement of word ‘optimal’ with ‘appropriate and sustainable’, as optimal is undefined and difficult to measure.
“…the development optimal appropriate and sustainable transport outcomes, including maximising site internalisation and high active and public transport mode shares;”

• Bullet 21b- (1) Clarification that trip budget will cover the peak hours of the day for clarity. (2) Removal of requirement that a definitive trip budget needs to be agreed “prior to submission of the outline application”, as a vehicular trip budget is normally agreed during the planning application transport assessment process.

“The quantum and mix of development can be delivered within the agreed vehicular trip budget covering the peak hours of the day. A definitive trip budget based on detailed evidence must be agreed with the Local Highways Authority. A monitor and manage approach will be taken to ensure that the development remains within the agreed trip budget for the site throughout its delivery.”

Lifespan
• Bullet 26- Clarification:
“In addition to the requirements on the validation checklist, the following will be required at the submission of a major planning application:
• Bullet 26 (a, b +g)- Moved to a new bullet (27) detailing requirements for reserved matters and detailed applications:
“Reserved matters and detailed planning applications will also be required to submit:
a A comprehensive environmental management and construction strategy for all phases of development required;
b Strategies for the long-term management and maintenance of landscape, drainage and green infrastructure; and
c The approach to the long-term management, maintenance and stewardship of the site, including its infrastructure, services, facilities and built and natural environment, must be identified at the outset through a Management and Maintenance Plan that sets out a comprehensive approach to the long-term management of the site as it evolves.”

Proposed Amendments to Supporting Information
Small and Medium Scale Commercial Uses
Policy S/SHF requires “a flexible range of appropriate units that can support a wide range of businesses and that can be adapted to accommodate changing business requirements within the following uses classes”.

However, the supporting information to the policy, refers to “…small and medium scale commercial uses…” when referring to a flexible range. This conflicts with policy, is inappropriate and overly prescriptive in relation to the type and size of units, given the employment need and demand and site suitability for a range including larger units on a strategic site allocation.

The prescriptive approach contradicts both the NPPF 2024 (paragraph 87b) and the NPPF 2026 (Policy E1 2.), as well as the property market needs evidenced in the area (relating to both the Council’s evidence, namely the Greater Cambridge Warehouse and Industrial Space Needs Report (2025) and the Market Demand Assessment Chapter of the Cambridge 25 Market Assessment (Savills, May 2026) (at Appendix 6).

This report (at paragraphs 6.3.2 to 6.3.5) demonstrates that, in commercial property market terms, the size of any unit does not directly relate to the market it serves - i.e., local or regional needs. The key points are:
1 There are already a number of both local and national/international companies in Greater Cambridge that occupy industrial units above 100,000 sqft (Appendix 6, Table 6.1), for example:
a Cambridge University Press & Assessment (CUPA);
b Fred Smart Logistics; and
c Hain Daniels.
2 In addition, it is important to highlight that compared to other locations with similar economic dynamics, such as Oxford, Sheffield, Bedford, Bristol, and Norwich (Appendix 6, Section 6.4.3), Greater Cambridge is considerably under-providing larger scale industrial units. These comparable centres have a far higher representation of larger scale units over 100,000 sq. ft. This is evidential of the supply in Greater Cambridge, having been artificially suppressed relative to comparable locations elsewhere; it also highlights the vital role that such units play enabling the proper function of the I&L market.
3 The last eight years of policy restriction, since the adoption of South Cambridgeshire LP Policy E/11, has severely constrained existing businesses from finding suitable accommodation within Greater Cambridge due to a lack of availability of premises of sufficient scale. Examples include Marshalls, Cambridge Aerospace and DHL (Appendix 6, paragraphs 6.4.6- 6.4.12).

Extrapolating these trends, the latent demand for larger-scale units will continue increasing, and the lack of such provision will displace investment further away and jeopardise the retention of existing businesses, if they are unable to accommodate their growth plans within Greater Cambridge.

Furthermore, the Council’s evidence, namely the GCW&ISN 2025, cites the ‘Understanding demand for B8 premises across Greater Cambridge’, authored by WSP in 2021 on behalf of Greater Cambridge Partnership and the Greater Cambridge Shared Planning Service, which presents the findings of the engagement with the industry (19 interviews with stakeholders), and indicates that there is latent demand for larger scale units in the area with emphasis on the need for medium- to large-scale B8 units.

We would finally draw attention to the West Suffolk Local Plan Examination in Public and Inspector’s Report (July 2025) (Appendix 7), where a similar size unit cap for logistics units was removed (see para 250, repeated below):
We concluded under main issue 1 that there is significant demand for large scale strategic logistics development in the wider sub region, and an identified need for 35 hectares in West Suffolk. The restriction on such developments comprising more than 9,000 sqm is not therefore justified or consistent with national policy which recognises the critical role that such development plays in enabling an efficient, sustainable and effective supply of goods for consumers and businesses as well as contributing to local employment opportunities. Policy SP12 therefore needs to be modified to allow large scale logistics development on suitable allocations and employment areas, provided that it is consistent with national policy and does not prevent more localised needs being met. (Lichfields emphasis).
In comparison, the GCSP evidence in the Iceni report (2025 GC Employment and Housing Needs Update) identifies a minimum need in Greater Cambridge for 317,000 sq m of new B2/B8 Employment floorspace to 2045, with an existing critical undersupply of land and premises to meet the needs of the I&L sector and this is particularly severe in relation to large units (Appendix 6, para 5.5.4).

On the above basis, and consistent with LDL’s representation on Policy S/DS: Development strategy, we would also seek an amendment to the supporting text to ensure this accords with para 36(d) of the NPPF 2024, as follows:

“The policy enables a range of commercial uses to come forward and it will be important that there is sufficient variety in their form and floorplate size and flexibility in their design to ensure that they cater for a range of different business types and can be adapted over time to meet changing local business needs. As the focus of the site should be on meeting the identified local Greater Cambridge needs, the site should deliver a range of appropriate unit sizes. Development should come forward in phases.”

In order to be more effective and to accord with paragraph 36(c) of the NPPF 2024, Policy S/JH should be amended as follows:

“Development will meet the objectively assessed needs in Greater Cambridge over the period 2024-2045 for:

1. A minimum of 73,300 additional jobs to support the Greater Cambridge’s knowledge intensive sectors, and also provide a diverse range of local jobs;”

Policy S/JH sets out a target of 73,300 jobs over the 2024-2045 period based on the Greater Cambridge Employment and Housing Evidence Update 2025 (‘EHNU 2025’).

The ENHU 2025 identifies a need for 317,000 sq.m of industrial / warehousing (Use Classes B2/B8) space by 2045, alongside a need for over 302,000 sq.m of office and 600,000 sq.m of R&D space. Building on the jobs forecast, these need figures take into consideration the latest market signals and stakeholder engagement, applying necessary adjustments to inform the employment policy requirements (GCLP paragraph 2.12).

The 317,000 sq.m of industrial / warehousing figure updates the underestimate of floorspace requirements set out in the Council’s previous evidence base work (i.e. ELEDS 2020, which only identified up to 60,000 sq.m of industrial and warehousing need over the 2020 to 2041 time period). The revised figures comprise a more reflective estimate of the market activity across the Greater Cambridge area.

The GCLP (paragraph 2.11) highlights that there is also “a higher growth forecast, placing greater weight on rapid growth in the recent past, particularly in key sectors, and that it recommended providing flexibility in employment land in case the market delivers more jobs than anticipated.” [Lichfields’ emphasis]. Therefore, the Council recognises the potential for further employment growth over and above the identified need position across the plan period.

On a similar basis, the EHNU 2025 discusses suppressed demand matters and suggests that, if an 8% availability rate was assumed, there would be a higher need for industrial and distribution floorspace of 360,000 sq.m (EHNU, paragraph 5.26).

Whilst the GCLP is being prepared to be consistent with the previous National Planning Policy Framework (‘NPPF 2024’), the latest (August 2026) national planning policy framework (‘NPPF 2026’) is also relevant. This is particularly the case in decision-making, as not only do the NPPF DM policies apply from 17 August 2026, but also: “Development plan policies which are materially inconsistent with the national decision-making policies in this Framework should be given very limited weight. The only exception to this is where they have been examined and adopted or made against this Framework.…” (NPPF, 2026, Annex A, paragraph 2).

NPPF 2026 Policy E1 highlights the importance of a clear economic vision aligned with the strategic and local economic development strategies to support business investment and employment locally. Moreover, the national policy gives significant emphasis to ‘market signals’ in both plan-making (Policy E1.2) and decision-making (Policy E2.2a) policies of Chapter 7 ‘Building a strong, effective economy’.

This represents a clear recognition by the Government of the importance of responding to commercial property market activity in plan-making.

Synthesising the above and also considering that the Council’s evidence focuses solely on needs arising within Greater Cambridge and is neutral regarding the wider FEMA strategic requirements ( Greater Cambridge Warehouse and Industrial Space Needs 2025 para 0.23, which is included in the EHNU 2025 needs figure ), there is a need to treat these economic need figures as the minimum employment space requirement and allow for appropriate flexibility and a level of choice for different sectors, as well as to enable the higher growth scenario that reflects recent past trends.

Policy Recommendation

For this reason and in order to be more effective and to accord with paragraph 36(c) of the NPPF 2024, Policy S/JH should be amended as follows:

“Development will meet the objectively assessed needs in Greater Cambridge over the period 2024-2045 for:
1. A minimum of 73,300 additional jobs to support the Greater Cambridge’s knowledge intensive sectors, and also provide a diverse range of local jobs;”

In order to be justified and accord with paragraphs 36(b) and (d) of the NPPF 2024, and therefore be sound in all respects, Policy S/DS 2e(i) should be amended as follows:

“i. Slate Hall Farm, Junction 25, A14 – an allocation for master-planned employment-led development that responds sensitively to the local landscape and secures access to new green infrastructure for future workers and the local community: including approximately 220,000 square metres employment floorspace for industrial and warehousing uses, with a mix of unit sizes to support the growth of a wide range of different businesses;”

Policy S/DS: Development Strategy sets out the proposed spatial distribution of jobs (and housing) growth across the Greater Cambridge area for the period to 2045 and beyond. In terms of the pattern of employment growth, there is a significant focus on the R&D and offices sectors, reflective of Greater Cambridge’s economy.

Provision Quantum
Nonetheless, a total of 350,000 sq.m of industrial and warehousing space is proposed to be allocated (Policy S/DS 2bi, 2cii, 2ei and 2eii) for industrial and warehousing purposes (B2/B8), alongside an additional 183,800 sq.m for office, research and industrial uses (i.e., Eg/B2/B8) (Policy S/DS 2ci1, 2ci2, 2civ and 2cv), to support the local economy and to accommodate the significant demand for such space as indicated by the Council’s evidence. The allocated land purely for office and research & development totals over 1.2m sq.m (i.e. Policy S/DS 2aii, 2bii, 2biv,2ciii,2di and 2dii).

On this basis, the GCLP aims to provide for a higher economic need figure against the 317,000 sq.m minimum requirement for industry and warehousing; however, this is not considered sufficient ‘headroom’ to deal with anything more than the identified indigenous needs which, as indicated in the Council’s evidence, total 360,000 sq.m once the recent trends are considered.

Most of this allocation provision (i.e., 310,000 sq.m or 88.5%) is proposed in the ‘Rest of the rural area’ (Policy S/DS 1e, 2ei and 2eii), with the remaining 40,000 sq.m or 11.5% industrial uses equally divided (20,000 sq.m each) between the edge of Cambridge (Policy S/DS 1b,2bi) and the expanded Cambourne (Policy S/DS 1c,2cii).

The open employment class allocations relate to large residential-led allocations in Cambourne North (Policy S/DS 2ci) of 108,000 sq.m, Cambourne (Policy S/DS 2ci2) of 34,600 sq.m, Waterbeach New Town (Policy S/DS 2civ) of 39,800 sq.m and, finally, in Bourn Airfield new village (Policy S/DS 2cv) of just 1,400 sq.m. None of these is expected to provide a significant amount of industrial and warehousing space.

Most of the industrial and warehousing supply relates to the proposed Slate Hall Farm site allocation (Policy S/DS 2ei) at Junction 25, A14 (for which LDL is the main promoter and stakeholder), where the new allocation for approximately 220,000 sq.m employment floorspace for industrial and warehousing uses (Policy S/SHF) accounts for some 63 % of the total industrial and warehousing provision. The strategic location and size of the allocation site provides flexibility and choice to meet the needs of the historically under-supplied Greater Cambridge market.

This highlights that the Council recognises that the draft site allocation S/SHF is intended to have a key role as the principal strategic location for meeting the future industrial and warehousing growth needs of Greater Cambridge over the next 20 years. It is also important to highlight that the size of the allocation site can provide flexibility and choice to the market, in turn significantly enhancing availability in the Greater Cambridge which has been a very constrained market for a long period.

We therefore consider policy S/DS to be sound, save in respect of prescribing the scale of the unit sizes.

Scale and Flexibility
However, Policy S/DS 2ei appears overly prescriptive in terms of unit sizes, given that there is no justification for excluding a wider unit size range that could be provided on this largest and principal site allocation. This should also be aligned with the updated Policy J/NE (8), to allow flexibility for a wider range of unit sizes subject to supporting evidence demonstrating those needs. Indeed, this is essential to achieve the stated aim of the policy, which itself refers to supporting “the growth of a wide range of different businesses.”

NPPF 2024 paragraph 87b highlights the importance of planning policies to address the specific locational requirements of “storage and distribution operations at a variety of scales and in suitably accessible locations...” [Lichfields’ emphasis]. The national policy gives weight to the sector’s specific requirements and highlights the importance of providing a wide range of scales, in recognition of the sector’s particular characteristics

The importance of providing for flexibility aligned with market requirements is highlighted in NPPF 2026 Policy E1 point 2, which requires local plans to be flexible in response to the changing commercial property requirements and states in particular that “…development plans should not be overly prescriptive about the types of uses or unit sizes that would be acceptable on particular sites (other than where there is a clear and justified rationale for being specific about acceptable uses at the plan-making stage)” [Lichfields’ emphasis].

Moreover, NPPF 2026 Policy E1.1.c.ii states that development plans should “c. Allocate sites to implement the economic vision and strategy and meet existing and anticipated needs over the plan period, paying particular regard to…making provision for: ii. storage and distribution operations at a variety of scales and in suitably accessible locations that allow for the efficient and reliable handling of goods, especially where this is needed to support the supply chain (including ‘last mile’ deliveries), transport innovation and decarbonisation;...” [Lichfields’ emphasis].

The Council’s evidence, namely the Greater Cambridge Warehouse and Industrial Space Needs Report 2025 (‘GCW&ISNR’, paragraphs 5.7, 5.14, 5.18, 6.19, 6.24, 7.21), highlights that there is demand for larger-scale units in Greater Cambridge and gives particular emphasis to the A14 corridor. On this basis, the market signals demonstrate clearly the demand for a variety of scales of industrial and particularly warehousing units across Greater Cambridge generally and the A14 corridor in particular.

The prescriptive approach also contradicts the property market needs evidenced in the Market Demand Assessment Chapter of the Cambridge 25 OPA Market Assessment (Savills, May 2026) (at Appendix 6).

This report (at paragraphs 6.3.2 to 6.3.5) demonstrates that, in commercial property market terms, the size of any unit does not directly relate to the market it serves - i.e., local or regional needs. The key points are:
1 There are already a number of both local and national/international companies in Greater Cambridge that occupy industrial units above 100,000 sqft (Appendix 6, Table 6.1), for example:
a Cambridge University Press & Assessment (CUPA);
b Fred Smart Logistics; and
c Hain Daniels.
2 In addition, it is important to highlight that compared to other locations with similar economic dynamics, such as Oxford, Sheffield, Bedford, Bristol, and Norwich (Appendix 6, Section 6.4.3), Greater Cambridge is considerably under-providing larger scale industrial units. These comparable centres have a far higher representation of larger scale units over 100,000 sq. ft. This is evidential of the supply in Greater Cambridge, having been artificially suppressed relative to comparable locations elsewhere; it also highlights the vital role that such units play enabling the proper function of the I&L market.
3 The last eight years of policy restriction, since the adoption of South Cambridgeshire LP Policy E/11, has prevented existing businesses from finding suitable accommodation within Greater Cambridge due to a lack of availability of premises of sufficient scale. Examples include Marshalls, Cambridge Aerospace and DHL (Appendix 6, paragraphs 6.4.6- 6.4.12).

Extrapolating these trends, the latent demand for larger-scale units will continue increasing, and the lack of such provision will displace investment further away and jeopardise the retention of existing businesses, if they are unable to accommodate their growth plans within Greater Cambridge.

Furthermore, the Council’s evidence, namely the GCW&ISN 2025, cites the ‘Understanding demand for B8 premises across Greater Cambridge’, authored by WSP in 2021 on behalf of Greater Cambridge Partnership and the Greater Cambridge Shared Planning Service, which presents the findings of the engagement with the industry (19 interviews with stakeholders), and indicates that there is latent demand for larger scale units in the area with emphasis on the need for medium- to large-scale B8 units.

We would finally draw attention to the West Suffolk Local Plan Examination in Public and Inspector’s Report (July 2025) (Appendix 7), where a similar size unit cap for logistics units was removed (see para 250, repeated below):

We concluded under main issue 1 that there is significant demand for large scale strategic logistics development in the wider sub region, and an identified need for 35 hectares in West Suffolk. The restriction on such developments comprising more than 9,000 sqm is not therefore justified or consistent with national policy which recognises the critical role that such development plays in enabling an efficient, sustainable and effective supply of goods for consumers and businesses as well as contributing to local employment opportunities. Policy SP12 therefore needs to be modified to allow large scale logistics development on suitable allocations and employment areas, provided that it is consistent with national policy and does not prevent more localised needs being met. (Lichfields emphasis).
In comparison, the GCSP evidence in the Iceni report (2025 GC Employment and Housing Needs Update) identifies a minimum need in Greater Cambridge for 317,000 sq m of new B2/B8 Employment floorspace to 2045 , with an existing critical undersupply of land and premises to meet the needs of the I&L sector and this is particularly severe in relation to large units (Appendix 6, para 5.5.4).

In summary, the fact that national and international providers already have a presence in the area should be taken into consideration as part of the market dynamics locally, alongside the fact that there are local businesses that cannot accommodate their growth plans locally and are forced to move out of the area.

Synthesising this evidence, we consider that the justification for this policy, seeking to limit commercial uses to small- and medium-sized units, is plainly not justifiable, nor aligned with national policy. To the contrary, it will actively constrain local growth, contrary to national policy.

Policy Recommendation

Therefore, in order to be justified and accord with paragraphs 36(b) and (d) of the NPPF 2024, and therefore be sound in all respects, Policy S/DS 2e(i) should be amended as follows:

“i. Slate Hall Farm, Junction 25, A14 – an allocation for master-planned employment-led development that responds sensitively to the local landscape and secures access to new green infrastructure for future workers and the local community: including approximately 220,000 square metres employment floorspace for industrial and warehousing uses, with a mix of units sizes to support the growth of a wide range of different businesses;”

LDL considers that part 8 of Policy J/NE is not justified and therefore not sound in accordance with paragraph 36(b) of the NPPF 2024; it should therefore be deleted.

As a minimum, the wording should be amended as follows to make clear that it does not apply to allocated sites within the Plan:

“8. Proposals for large scale warehousing and distribution facilities on non-allocated sites providing for national or regional needs will not be permitted unless it can be demonstrated that:…
a. there is an unmet need for such facilities that must and can be appropriately met within Greater Cambridge, having regard to other policies and priorities within and arising from this Plan; and
b. the proposal will not impede delivery of warehousing and distribution and industrial space that meets local market needs in market sector priority locations

We note that Policy J/NE point 8 in relation to ‘large-scale warehousing and distribution facilities’ has been altered since Regulation 18 stage so that proposals for strategic scale facilities providing for national or regional needs will not be permitted unless it can be demonstrated that there is an unmet need for such facilities that “must and can be appropriately provided within Greater Cambridge having regard to other policies and priorities within and arising from the Local plan”. The supporting text (paragraph 8.17) specifies that ‘appropriately met’ can mean that the development does not generate traffic movements that impede the delivery of the wider development strategy. It also (paragraph 8.17) specifies units exceeding 9,300 sq.m as the benchmark to be applied for the purposes of interpreting the policy.

From the Council’s response document (Consultation Statement, Appendix 12: Response to Representations - Jobs ) it is understood that the Council considers that strategic scale logistics developments would be addressed in the forthcoming SDS (that commences in late 2026), and their neighbouring authorities and those in the relevant functional economic market area (FEMA), have developed a Statement of Common Ground with the Cambridgeshire & Peterborough Combined Authority, which confirms the need to assess strategic warehousing facilities serving national or regional markets across the FEMA.

In general terms, as noted at Regulation 18, LDL does not consider that any policies that seek to be restrictive or reduce flexibility – or overly prescriptive in terms of unit size thresholds – in relation to addressing market requirements or business needs can be justified or effective in policy. This is not consistent with the NPPF 2024 (paragraph 87b) and NPPF 2026 (E1.2). Furthermore, our view is that the implementation of this Plan cannot rely upon a future SDS, which is yet to be developed and with no confirmed timetable for adoption. This would leave a policy vacuum in relation to large-scale needs across the FEMA.

As phrased, the draft policy limits any warehousing and distribution development above 9,300 sq.m on the basis that this size threshold differentiates between local and regional/national operations. For the reasons discussed below, this is not considered to be an accurate reflection of market realities in Greater Cambridge (or indeed anywhere else), it would potentially result in a distortion to the functioning of the market and is not consistent with the national policy.

There is no evidence that large-scale warehousing units above 9,300 sq.m (100,000 sqft) are solely accommodating national or regional needs. In contrast, there are occupiers serving Greater Cambridge that have such requirements, but they are not reflected in either the net absorption data or in the completions rates economic growth scenario, given that existing policy has not allowed for larger units to be developed in the last 15-20 years. The market signals, reflecting enquiries and activity, as well as stakeholder engagement (through the Council’s evidence, namely the GCW&ISN (Iceni,2025) and the Understanding demand for B8 premises across Greater Cambridge (WSP, 2021), which is also cited within the Council’s evidence – i.e., GCW&ISN 2025) highlight the latent demand for larger-scale units in the area. This was also recognised by the Council in the Jobs Topic Paper 2025, paragraph 3.42 (see pg.5).

In addition, recent market evidence from Savills (Appendix 6 - paragraphs 6.3.2 to 6.3.5) demonstrates that, in commercial property market terms, the size of any unit does not directly relate to the market it serves - i.e., local or regional needs. The key points are:
1 There are already a number of both local and national/international companies in Greater Cambridge that occupy industrial units above 100,000 sqft (Appendix 6, Table 6.1), for example:
a Cambridge University Press & Assessment (CUPA);
b Fred Smart Logistics; and
c Hain Daniels.
2 In addition, it is important to highlight that compared to other locations with similar economic dynamics, such as Oxford, Sheffield, Bedford, Bristol, and Norwich (Appendix 6, Section 6.4.3), Greater Cambridge is considerably under-providing larger scale industrial units. These comparable centres have a far higher representation of larger scale units over 100,000 sq. ft. This is evidential of the supply in Greater Cambridge, having been artificially suppressed relative to comparable locations elsewhere; it also highlights the vital role that such units play enabling the proper function of the I&L market.
3 The last eight years of policy restriction, since the adoption of South Cambridgeshire LP Policy E/11, has prevented existing businesses from finding suitable accommodation within Greater Cambridge due to a lack of availability of premises of sufficient scale. Examples include Marshalls, Cambridge Aerospace and DHL (Appendix 6, paragraphs 6.4.6- 6.4.12).

Extrapolating these trends, the latent demand for larger-scale units will continue increasing, and the lack of such provision will displace investment further away and jeopardise the retention of existing businesses, if they are unable to accommodate their growth plans within Greater Cambridge. Continuing to restrict larger units will therefore continue to constrain economic growth.

A policy choice to limit provision for regional (and national) occupiers is not consistent with the NPPF 2024. In particular, NPPF 2024 paragraphs 86c, 86e and 87b require the necessary levels of flexibility in accommodating specific modern economy - including (inter alia) freight and logistics - needs, recognising the evolving economic circumstances as well as the specific locational requirements for the sector “at a variety of scales”. Moreover, the NPPF 2026 gives additional emphasis to meeting regional economic growth (and weight to the future Spatial Development Strategies in plan-making).

NPPF 2026 Policy E1.1.a also sets out a clear alignment between the economic strategic priorities and the Industrial Strategy with the plan-making. The Industrial Strategy emphasises the role of the freight and logistics sector and its part in growing the economy nationally and has stated that a new plan for the sector will be published in due course. It is on this basis that anticipated regional and national priorities for the sector will be further weighted in the near future, making it even more important to consider those needs now as part of emerging plans.

Moreover, NPPF 2024 paragraph 87b and NPPF 2026 E1.2 aim to allow for flexibility across a variety of scales; NPPF 2026 E1.2 in particular states that development 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 about acceptable uses at the plan-making stage). The rationale of, effectively, carrying over an outdated legacy policy against the identified needs for larger units is not sound, given the evidence of demand for larger-scale industrial and warehousing units in the area. As aforementioned, both Council’s evidence and the latest market evidence (in Appendix 6) highlight the undersupply of larger industrial and warehousing units in Greater Cambridge.

In addition, the potential consequence of Policy J/NE 8 as phrased, would be to give rise to unmet strategic B8 needs. The Planning Practice Guidance (‘PPG’) paragraph 031 advises that, where needs for strategic facilities exist, policy-making authorities should collaborate with infrastructure providers and other parties to identify the scale of need across the relevant market, and the authorities will then need to consider the most appropriate locations for meeting these identified needs.

NPPF 2026 Policy E2.2 goes further in this regard, by stating that, if market signals demonstrate undersupply of specific types of land or premises, considering the relevant catchment area (which could expand beyond Greater Cambridge’s boundaries), or specific locational requirements exist, then, in compliance with the NPPF 2026 S5, the development could be permitted. In other words, if the GCLP limits the supply of units above 9,300 sq.m, given that this is a historically constrained market, there is the risk that such units would be promoted outside the provisions of the GCLP - through the development management process – with locally needed employment being paradoxically contrary to the provisions of the development plan.

By allowing greater flexibility for the proposed allocations to accommodate some strategic larger-scale needs, if required, the GCLP will be more effectively able to demonstrate that it is aligned with the national policy.
Furthermore, the policy as presently drafted provides limitations in terms of any future proposal’s viability, as it constrains market flexibility and future occupiers’ choice by limiting options for larger units which, based on market evidence, are subject to high levels of demand.

In summary, the thresholds that limit the size of units in an effort to constrain regional and national activity need to be removed to ensure alignment with the national policy and, more importantly, to serve efficiently the needs of the local market.

Policy Recommendation
Therefore, LDL considers that part 8 of Policy J/NE is not justified and therefore not sound in accordance with paragraph 36(b) of the NPPF 2024; it should therefore be deleted.

As a minimum, the wording should be amended as follows to make clear that it does not apply to allocated sites within the Plan:
“8. Proposals for large scale warehousing and distribution facilities on non-allocated sites providing for national or regional needs will not be permitted unless it can be demonstrated that:…

a. there is an unmet need for such facilities that must and can be appropriately met within Greater Cambridge, having regard to other policies and priorities within and arising from this Plan; and
b. the proposal will not impede delivery of warehousing and distribution and industrial space that meets local market needs in market sector priority locations

Policy Recommendation:

Delete limb 2 of Policy J/AW.

The draft Policy J/AW limb 2 states: “Proposals for new Industrial and Storage developments (use classes E(g)iii, B2 and B8) over 2,500 square metres will be required to provide a minimum of 10% of net additional floorspace as affordable workspace (GIA) at a minimum of 20% below prevailing market rents in perpetuity.”

Such a ‘universal’ policy jeopardises the deliverability of proposed industrial and storage developments, as we set out below. Lichfields have reviewed the Greater Cambridge Local Plan Viability Report, prepared by Aspinall Verdi and published in July 2026. We find that the Report does not provide a reasonable representation of the viability position for all forms of commercial development across the Greater Cambridge area and that it is not possible to reasonably conclude that the requirement for the provision of affordable workspace would not undermine the viability of commercial development in Greater Cambridge.

Our reasoning is provided in Appendix 7 (below), but we summarise the key arguments below:
1 The assessment of viability is based on the testing of an insufficient number and range of site typologies. Critically, no consideration has been given to the viability implications of large scale industrial and logistics developments such as that envisaged within the proposed ‘Policy S/SHF: Land north of A1307, Bar Hill (Slate Hall Farm)’ site allocation in the draft GCLP – i.e. a major employment site of 220,000sqm of B2/B8 use. Nor has consideration been given to other strategic employment site allocation typologies.
2 The assumptions that have been applied in respect of costs are inadequate as they:
a Under-estimate construction costs;
b Fail to make any provision for external and abnormal costs; and,
c Under-estimate contingency costs.
3 The assumptions that have been made in respect of rental value and yields overestimate the gross development value of industrial development.

The implication of these shortcomings is that it is not possible to reasonably conclude that the requirement for the provision of affordable workspace would not undermine the viability of commercial development in Greater Cambridge. We do not consider that Policy J/AW limb 2 is justified, as it is not based on clear and proportionate evidence; it also fails to have regard to reasonable alternatives. In addition, we consider that the policy is not effective, as it would undermine significantly the deliverability of commercial development.

Iceni’s Greater Cambridge Affordable Workspace Study (June 2026) (‘GCAW 2026’) underpins this policy. The evidence highlights that there is justification for policy intervention, given that there are smaller businesses, scale-ups, creative industries and certain industrial occupiers that need to be accommodated according to the business profile of the area.

GCAW 2026 makes it clear that affordable workspace requirements should be tailored to the different market conditions across Greater Cambridge rather than applying a single approach everywhere (para 9.1.2). The evidence states clearly that those requirements are most acute in the central locations and particularly in the established innovation clusters, with needs for affordable office and R&D workspace as part of major office and R&D and mixed-use developments in those locations.

GCAW also states clearly (para 9.1.5) that, particularly for the industrial market, a distinct policy approach in relation to affordable space will be required to reflect the fact that the market is comprised of a number of sub-sectors with different locational and space need requirements which are not currently appropriately reflected in the supporting viability. With respect to large industrial and logistics developments it is also stated (para 9.1.5):

“…However, large industrial and logistics developments are often located in areas that are less suitable for managed affordable workspace provision.”

It is, therefore, clear that the draft Policy J/AW limb 2 contradicts the GCLP’s evidence base, which highlights that the provision of affordable workspace could not be ‘suitable’ on large industrial and warehouse development sites. There is a clear misinterpretation of the draft Policy J/AW limb 2 that the affordable workplace needs would be accommodated in large industrial and logistics developments, as these are not the locations where the affordable workspace is actually needed, which, according to the evidence (GCAW para 9.1.9) is required within Cambridge City and the city fringe locations. The implication of adopting such a policy on large industrial and logistics sites risks the potential for inefficient use of space if affordable workspace is not taken up.

Synthesising the above, neither the Council’s evidence nor the viability review demonstrates that a universal minimum of 10% of net additional floorspace as affordable workspace (GIA), at a minimum of 20% below prevailing market rents in perpetuity in industrial and storage developments of over 2,500 sq.m is sound.

Policy Recommendation
Delete limb 2 policy J/AW:

LDL request the policy is amended as follows:

“Appropriately scaled facilities including cafes, restaurants, convenience shop, indoor and outdoor social spaces and leisure and sports facilities, changing and childcare facilities, green spaces, and collaboration and networking spaces will be supported in business parks and employment areas where…”

Alternatively, and to ensure such policy is flexible enough to accommodate market changes (like we saw in COVID), the policy wording could be amended to include “for example” after “including” to identify this is not a closed list.

LDL notes Policy J/EP and endorses the principle of appropriately scaled facilities being supported in business parks and employment areas. This would include Cambridge 25.

LDL notes this is a closed list of facilities, and therefore in order for Policy J/EP to be more ‘justified’ in accordance with NPPF para 36(b), it is requested that the list of activities in the policy is aligned with para 8.47 of the supporting text which includes additional activities such as ‘changing and childcare facilities. Accordingly, LDL request the policy is amended as follows:

“Appropriately scaled facilities including cafes, restaurants, convenience shop, indoor and outdoor social spaces and leisure and sports facilities, changing and childcare facilities, green spaces, eating, social and collaboration and networking spaces will be supported in business parks and employment areas where…”

Alternatively, and to ensure such policy is flexible enough to accommodate market changes (like we saw in COVID), the policy wording could be amended to include “for example” after “including” to identify this is not a closed list.

LDL notes Policy I/SD and endorses limb 4 which requires that “Proposals for any new industrial and distribution centres that will generate significant freight traffic must provide sufficient facilities for long-term and overnight lorry parking."

The GCLP also considers the general (non-scheme specific) overnight lorry parking need being met by the expansion of the existing facilities at J24 of the A14, as proposed in allocation ‘S/RRA/SCS Land to the south of Cambridge Services’.

We consider this distinction in the two types of overnight lorry parking to be sound and consistent with paragraph 36 of the NPPF (2024).

In order for Policy CC/NZ to be ‘effective’ in accordance with Para 36 of the NPPF (2024), LDL considers the below amendments to the wording of limb 1. should be introduced to allow flexibility, where it can be justified:

“Where appropriate (with the exception of householder applications) new development must achieve net zero operational emissions by following a hierarchical approach of reducing heat and power demand then supplying all energy demand through onsite energy generation, unless, satisfactorily justified otherwise.”

‘Policy CC/NZ: Net zero carbon new buildings’ states (at 1.) that “New development (with the exception of householder applications) must achieve net zero operational emissions by following a hierarchical approach of reducing heat and power demand then supplying all energy demand through onsite energy generation.” [Lichfields emphasis].

LDL notes the requirement to follow a hierarchical approach of reduction heat and power demand, however, raises concerns with flexibility on the subsequent requirement to supply all energy demand through on site energy generation, as there may be some instances where this is not possible (e.g. energy intensive industries or where sustainable generation may exist nearby) and/or an alternative off-site solution may be preferable.

In order for Policy CC/NZ to be ‘effective’ in accordance with Para 36 of the NPPF (2024), LDL considers the below amendments to the wording of limb 1. should be introduced to allow flexibility, where it can be justified:

“Where appropriate (with the exception of householder applications) new development must achieve net zero operational emissions by following a hierarchical approach of reducing heat and power demand then supplying all energy demand through onsite energy generation, unless, satisfactorily justified otherwise.”

This requested amendment for flexibility was also raised by LDL at Regulation 18 stage. It was identified and recognised by the GCSP as a Main Issue in the ‘Summary of Main Issues’ to Policy CC/NZ (pgs. 49-50) of the ‘Consultation Statement Appendix 8: Response to Representations- Climate Change’ but then the GCSP was silent on this matter in the subsequent ‘Response to the main issues raised in representations’ (pgs. 51-54).

In order to make Policy GP/LC sound, LDL considers the below amendments to Policy GP/LC are required:

All new development proposals must a. conserve the intrinsic character and beauty of the local landscape, as set out in the Greater Cambridge Landscape Character Assessment (2021) Part A and Part B or successor documents;”

Part 1.a. of Policy GP/LC: Protection and enhancement of landscape character states that “1. All new development proposals must a. protect, conserve and enhance the local landscape character as set out in the Greater Cambridge Landscape Character Assessment (2021) Part A and Part B or successor documents;” [Lichfields emphasis]

LDL notes that this is inconsistent with Paragraph 187(a and b) of the NPPF (December 2024) which states that:
“Planning policies and decisions should contribute to and enhance the natural and local environment by:
a Protecting and enhancing valued landscapes, sites of biodiversity or geological value and soils (in a manner commensurate with their statutory status or identified quality in the development plan);
b Recognising the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land, and of trees and woodland;” [Lichfields emphasis]

The NPPF para 187a only requires that ‘valued landscapes’ are protected and enhanced (i.e. not conserved) and that this is not the same as ‘local landscape character’. GCSP acknowledge in the ‘Consultation Statement Appendix 11: Response to Representations- Great Places(pg.87) that “… there are no defined valued landscapes within Greater Cambridge…”.

The NPPF 2026 Policies N1 and N2 do not mandate a particular level of protection but require assessment when identifying opportunities for improving the natural environment and when providing safeguards.

For ‘local landscape character’, NPPF para 187b is most relevant, for which the policy requirement is to “recognise the intrinsic character and beauty of the countryside”.

Instead, GCSP make the case in the ‘Consultation Statement Appendix 11: Response to Representations- Great Places(pg.88) that “the intention of the policy to protect, conserve and enhance local landscape character is in line with NPPF section 12 on achieving well-designed places, which says that planning policies and decisions should ensure that developments ‘are sympathetic to local character and history”

We do not agree that NPPF para 187b has been considered appropriately.

Therefore, Policy GP/LC is not consistent with national policy as required at paragraph 36(d) of the NPPF (2024). In order to make Policy GP/LC sound, LDL considers the below amendments to Policy GP/LC are required:

1.All new development proposals must a. conserve the intrinsic character and beauty of the local landscape, as set out in the Greater Cambridge Landscape Character Assessment (2021) Part A and Part B or successor documents;”

LDL notes Policy I/SD and endorses limb 4 which requires that “Proposals for any new industrial and distribution centres that will generate significant freight traffic must provide sufficient facilities for long-term and overnight lorry parking."

The GCLP also considers the general (non-scheme specific) overnight lorry parking need being met by the expansion of the existing facilities at J24 of the A14, as proposed in allocation ‘S/RRA/SCS Land to the south of Cambridge Services’.

We consider this distinction in the two types of overnight lorry parking to be sound and consistent with paragraph 36 of the NPPF (2024).