Greater Cambridge Local Plan: Proposed Submission

The University acknowledges the alterations made to the draft local plan since the Regulation 18 Consultation. It welcomes these helpful amendments, which support the University's current and future site aspirations. Therefore, the University support the policy in full.

See attached table of changes which relate to the factual amendments, the recent planning permission and clarification on the spatial framework diagram.

The University are supportive of this policy, which will deliver the quantum's and uses of development set out in paragraph 3 of the policy. These have been secured in September 2026, through a resolution by Joint Development Management Committee to grant planning approval, subject to completion of the S106 Agreement by 16 December 2026.

However, the University do object to this policy on the basis that there are several modifications needed to the wording of the policy. This will ensure that it is effective in line with National Policy PM15 and that the Draft Local Plan is capable of being found sound.

The modifications are focused on ensuring the policy requirements align with the current application, that has been granted a resolution for planning approval, subject to completion of the S106 Agreement, and the adopted North West Cambridge Area Action Plan.

Given the synergies between Eddington and Cambridge West, the policy also makes reference to West Cambridge, which we have suggested is amended to Cambridge West to avoid any confusion in the future.
The proposed changes are set out in the accompanying table and are necessary to ensure that the policy is justified and that the DLP can be found sound at examination.

See attached table of changes which relate to the factual amendments, recent planning permissions and clarification on the spatial framework diagram.

The University are supportive of this policy, which will deliver the quantum's and uses of development set out in paragraph 3 of the policy and are secured through the Outline Planning Approval – 16/1134/OUT.

However, the University do object to this policy on the basis that there are several modifications needed to the wording of the policy. This will ensure that it is effective in line with National Policy PM15 and that the Draft Local Plan is capable of being found sound.

The modifications are focused on ensuring the policy requirements are only relevant, where any future redevelopment or densification of the site, not consented under the extant Outline Planning Permission (or any variation to that permission), comes forward.

Furthermore, there are corrections to the site name, which has been renamed from West Cambridge to Cambridge West, to avoid any confusion in the future.

The proposed changes are set out in the accompanying table and are necessary to ensure that the policy is justified and that the DLP can be found sound at examination.

The University agree with the representations made by Carter Jonas, on behalf of Jaynic, in collaboration with the Pearson Family and the University, as landowners of the site and changes to the policy are set out in that document. These are:

1. The Site Area outlined within the first Bullet Point of the Policy to be amended and increased from 24.58ha to 26.82ha. This is shown on updated Site Location Plan (DR-A-0100 RevP02).

2. Criterion 1a be amended to “Site boundaries to provide landscape buffers of a minimum 25m to the most sensitive boundaries, 20m to moderately sensitive boundaries and 5m to lower sensitivity boundaries, as identified in the LVIA, to mitigate adverse landscape impacts of built form and light pollution, with open space and tree planting provided throughout the site as part of a landscape-led masterplan”.

3. Criterion 1b to be amended to remove reference to existing “balancing ponds to be reprofiled”.

4. Criterion 1c be amended to “Building heights shall respond sensitively to the local rural context and the landscape sensitivity of the site as identified in the LVIA, with taller buildings located away from the most sensitive boundaries and appropriately integrated within the landscape-led masterplan”.

5. Criterion 1h(i) to be amended to remove reference to connections to “Boxworth”.

6. Criterion 1h(ii) be amended to “Bus service improvements to serve the site, including associated infrastructure enhancements and on-demand services to cover shift patterns, with connections to the guided busway, which offers onward links to railway stations, Cambridge, Cambourne (including the planned allocation at Cambourne North), Northstowe, St Ives and other nearby villages”.

7. Criterion 1h(iii) be amended to “Provision of appropriate on plot facilities for those arriving by walking, wheeling, cycling and public transport”.

8. Criterion 1i(v) be amended to “Financial contributions will be sought to address the provision of transport infrastructure necessary to make the development of the site acceptable in transport terms., where this will not be funded via CIL payments.

9. The Plan at Figure 92 (Site Plan of S/RRA/SCS Land to the south of Cambridge Services, A14) to be updated to reflect revised site allocation red line boundary.

10. Within the Supporting Information to the Policy, the site area outlined within Para. 3.5.13 to be amended to 26.82ha.

In collaboration with the Pearson family, the University are the landowner of land to the southern side of the draft site allocation. On behalf of both landowners, Jaynic have been promoting the site through the planning system for high-quality employment floorspace, to complement the existing uses to the north of the allocation, within the Motorway Services Area.

The key benefits of the proposed scheme are:

• Around 90,000m² of Classes B2 or B8 use floorspace, contributing to the identified employment need in support of the local economic area. This would meet just over 31% of the need identified for Greater Cambridge.

• Approximately 150 new HGV parking spaces, including provision for active and passive e-HGV charging and direct access to existing amenity and welfare facilities.

• Extensive landscape buffering along the Site boundaries to mitigate visual impact arising from development as well as tree planting and open space within the development for occupiers and employees.

• The expanded HGV provision at Extra Services will allow a redesign of traffic flows around the Services, reducing potential conflicts between cars and HGVs, which can at times lead to traffic backing-up on the roundabout.

• Provision of jobs in a range of sectors for local residents. In addition, the scheme will support indirect employment opportunities beyond end-users, including ancillary and service-sector roles.

• Preserving the Site’s existing habitats, flora and fauna to ensure biodiversity net gain, improving the biodiversity and habitat value through native species planting.

• Opportunity to improve pedestrian and cycle linkages between the development and the local area, encouraging the use of sustainable transport options.

The site is achievable, available and deliverable and the University agree that development of the Site will have begun on site within the next five years, in accordance with the requirements of the NPPF (2026).

On land in the ownership of the University, the illustrative masterplan intends to deliver a 25 m landscape buffer to ensure that key benefits of the scheme can be realised in full, including mitigating any visual impact and improving the biodiversity of the site. The land will also assist in delivering the identified quantum of B2 and B8 floorspace.

As such, the University agree with the representations made by Carter Jonas, on behalf of Jaynic, in collaboration with the Pearson Family and the University, as landowners of the site.

It is noted that since the Regulation 18 Consultation the wording of the policy has expanded and that this is in line with best practice for sustainable design. The University continue to fully support this policy.

Please see attached document which highlights the proposed changes in red, setting out greater flexibility in the policy wording.

The University of Cambridge is supportive of the principle of the policy, given that Cambridgeshire is a highly water stressed area. However, to ensure that it is effective in line with National Policy PM15, it is requested that the wording of the policy is modified to read as follows:

1a) For residential development of 100 or more dwellings, water usage of no more than 80 litres/person/day, unless demonstrated not practicable. To achieve this level, some form of water reuse or recycling will be necessary. Proposals that seek to deliver levels of water usage below this level are encouraged; and

1e) Proposals for data centres should avoid water-based cooling, unless demonstrated not practical, use closed-loop cooling systems and use additional water resources such as rainwater and grey water.

The 80 litres/person/day standard is based on the Shared Standards in Water Efficiency for Local Plans Guidance (April 2025), which identifies a range of variables that may influence the ability of development to achieve this target. In recognition of these circumstances, the policy should include flexibility to allow alternative approaches where robust evidence demonstrates that the standard is not practicable to achieve. Subject to appropriate justification, this will ensure the policy remains both effective and deliverable while supporting the efficient use of water resources.

Accordingly, modifications to the policy are necessary to ensure that it is justified, effective and capable of being found sound through examination. A tracked change version of these changes can be found attached to this representation.

To ensure consistency with national policy, draft Policy BG/BG should either:

1. Be amended to require the statutory minimum of 10% Biodiversity Net Gain; or

2. Apply a higher BNG requirement only to specific site allocations where the Council can demonstrate, through robust evidence, that such a requirement is justified, viable and deliverable without compromising development capacity, including housing delivery and commercial floorspace provision.

The University of Cambridge objects to this policy on the basis that it is inconsistent with national policy as set out in National Policy PM15.
The University of Cambridge is committed to delivering Biodiversity Net Gain (BNG) and, where feasible, achieving outcomes that exceed the statutory 10% requirement in order to support wider efforts to reverse biodiversity decline. However, any additional requirements imposed through local policy must be justified, deliverable and consistent with national policy and guidance.

Paragraph 2 of National Policy N2 states that:
“Development proposals may incorporate biodiversity enhancements which exceed the statutory objective for biodiversity net gain, but this should only be a requirement where it is set out in up-to-date development plan policies for specific site allocations.”

National policy therefore recognises that requirements exceeding the statutory 10% BNG target should not be applied as a blanket policy across an entire local plan area. Instead, any higher requirement should be limited to specific site allocations where it can be demonstrated that the requirement is justified, deliverable and supported by appropriate evidence.

In the Greater Cambridge context, the ability for developments to consistently achieve a 20% BNG target is particularly challenging in highly constrained urban locations, such as Cambridge City Centre. A blanket 20% requirement is likely to result in a greater reliance on off-site BNG provision and associated credits. This would increase development costs and could adversely affect the viability and deliverability of schemes. It is unclear whether the Greater Cambridge Local Plan Viability Assessment (2026), prepared by Aspinall Verdi, has adequately assessed the implications of a universal 20% BNG requirement and the associated off-site delivery costs.
Furthermore, paragraph 2 of Annex 1 of the NPPF (2026) states that:

“Development plan policies which are materially inconsistent with national decision-making policies in this Framework should be given very limited weight.”

Whilst the Council's objective of supporting the recovery of biodiversity is acknowledged and supported, the need to reverse biodiversity decline is a national issue rather than one unique to Greater Cambridge. Consequently, the evidence presented does not demonstrate why a blanket increase from the statutory 10% requirement to 20% across all qualifying development sites is necessary, justified or consistent with national policy.

To ensure consistency with national policy, draft Policy BG/BG should either:
1. Be amended to require the statutory minimum of 10% Biodiversity Net Gain; or
2. Apply a higher BNG requirement only to specific site allocations where the Council can demonstrate, through robust evidence, that such a requirement is justified, viable and deliverable without compromising development capacity, including housing delivery and commercial floorspace provision.

Accordingly, the policy in its current form is not considered justified, effective or consistent with national policy and should be amended.

To ensure that the policy is justified and effective, the Council should provide further evidence to support the proposed approach, including:
• the justification for applying UGF requirements across the entire Local Plan area, rather than focusing on predominantly urban locations;
• the evidence supporting the proposed target levels, including the increased requirement in certain areas of South Cambridgeshire;
• whether local circumstances justify variations to the target for particular development types, including non-residential institutions; and
• clarification of the relationship between UGF, BNG and Accessible Greenspace Standards, including how potential overlap between qualifying measures will be treated in development proposals.

The University of Cambridge supports the principle of protecting, enhancing and increasing green infrastructure and green spaces across the Local Plan area. However, the University objects to this policy on the basis that it is not currently justified or effective, as required by national policy and the tests of soundness.

The policy relies on the application of the Urban Greening Factor (UGF) to major development proposals across the Local Plan area. However, Natural England's Urban Greening Factor for England User Guide (January 2023) makes clear at paragraph 3.2 that the UGF is principally a planning tool intended to support the greening of predominantly urban and suburban environments. The policy, as currently drafted, does not distinguish between urban and rural locations and instead applies the requirement to all major development, subject only to the exceptions identified in paragraph 1.

Furthermore, paragraph 4.5 of the User Guide recognises that UGF is often most appropriately applied in specific locations, such as city centres, growth areas and areas of opportunity. The evidence supporting the policy does not explain why a uniform approach is justified across the entire Local Plan area, including rural parts of South Cambridgeshire where the proposed UGF requirement increases to a factor of 0.5. In such locations, the rationale for applying an urban-focused metric, and for applying a higher target than elsewhere, has not been adequately evidenced.

The User Guide also recognises that local authorities may apply different UGF targets to different forms of development, including non-residential institutions. Given the significant presence of educational institutions within the Local Plan area, it is not clear whether the Council has considered the appropriateness of varying UGF requirements for such development types. The Council's evidence base and topic paper do not appear to provide justification for the approach that has been adopted.

The User Guide identifies UGF, Biodiversity Net Gain (BNG) and Accessible Greenspace Standards as complementary planning tools, each serving a different purpose whilst contributing towards wider environmental objectives. The supporting text should therefore confirm that the Council will recognise the complementary relationship between UGF, BNG and Accessible Greenspace Standards and clarify the circumstances in which the same intervention may contribute towards multiple policy objectives, provided that all relevant requirements are independently satisfied. This would provide greater certainty for applicants and assist in the consistent implementation of the policy.

To ensure that the policy is justified and effective, the Council should provide further evidence to support the proposed approach, including:
• the justification for applying UGF requirements across the entire Local Plan area, rather than focusing on predominantly urban locations;
• the evidence supporting the proposed target levels, including the increased requirement in certain areas of South Cambridgeshire;
• whether local circumstances justify variations to the target for particular development types, including non-residential institutions; and
• clarification of the relationship between UGF, BNG and Accessible Greenspace Standards, including how potential overlap between qualifying measures will be treated in development proposals.
In the absence of such evidence and clarification, the policy is not currently justified and its effectiveness in decision-making is uncertain. Consideration should therefore be given to amending the policy wording and supporting text to better reflect the approach advocated in Natural England's guidance and the specific characteristics of different parts of the Local Plan area.

To ensure that the policy is justified and effective, further evidence is required to demonstrate the basis for the proposed standards and to assess their cumulative impact when considered alongside other policy requirements within the Draft Local Plan. In particular, the Council should demonstrate how these requirements can be delivered on strategic allocations and other major development sites without materially reducing housing capacity and/or employment floorspace.

The University of Cambridge are committed to delivering high-quality open spaces within its schemes. However, in order to find the Plan sound, the policy requirement needs to be fully justified as set out in National Policy PM15. For this reason, the University of Cambridge object to this policy.

The Green Infrastructure and Open Spaces Standards Framework (2026) by LUC identifies that the existing baseline for Accessible Greenspace within the Local Plan area equates to 7 ha per 1,000 people. Therefore, this has informed the policy, to ensure that growth within Greater Cambridge leads to no net loss in per capita access to publicly accessible green space.

However, the University has concerns regarding the robustness of the evidence used to establish the 7 hectares per 1,000 population requirement (as set out in Appendix A of the LUC report). The methodology underpinning this calculation is unclear and the evidence does not adequately demonstrate how this benchmark has been derived. Furthermore, there is insufficient justification for the requirement that at least 3 hectares of accessible greenspace should be provided on-site.

In addition, the evidence base (Table A.2 of LUC report) indicates that a number of existing strategic developments fall significantly short of achieving these standards. This raises concerns regarding the practical deliverability of the proposed requirements and whether they can be accommodated alongside the wider objectives of the Draft Local Plan, particularly the need to provide sufficient homes and employment floorspace to support future growth.

Furthermore, there is no clear evidence to support the requirement for 2 hectares per 1,000 employees on qualifying commercial developments. The LUC report states at paragraph 3.34 'drawing on available evidence and through the robust weighing up of judgements, a standard of 2 ha of accessible open space per 1,000 employees is recommended.' The 'available evidence' and 'weighing up of judgements' are not presented in the report. The use of Census data from 2011 to provide data on the number of employees travelling in Cambridge is unreliable in light of changes in work pattens over the past 15 years and should be treated cautiously.

To ensure that the policy is justified and effective, further evidence is required to demonstrate the basis for the proposed standards and to assess their cumulative impact when considered alongside other policy requirements within the Draft Local Plan. In particular, the Council should demonstrate how these requirements can be delivered on strategic allocations and other major development sites without materially reducing housing capacity and/or employment floorspace.

On this basis, some modification to the wording of the policy is necessary to ensure that the policy is justified and that the DLP can be found sound at examination.

The policy is fundamentally important to the delivery of a sound plan and therefore the University of Cambridge needs to ensure that the points made in the representations can be articulated directly to the Inspector.

The reference to “1.5% of Net Internal Area commercial space” should be removed, as the policy is not intended to apply community facility contributions to commercial development. In addition, “large employment developments” should be clearly defined and any requirement for on-site sports provision should apply only where justified.

The University of Cambridge is supportive of the principle of the policy, to ensure that new development supports the needs of new and growing communities. However, to ensure that it is clear and effective in line with National Policy PM15, it is requested that the wording of the policy is modified to read as follows:

6. Contributions for community facilities will be based on a standard of 129 square metres of such floorspace per 1,000 additional population. Contributions for cultural facilities will be 100 square metres per 1,000 additional population.

As currently drafted, it is not the intention for the policy to apply these requirements to commercial development, and its inclusion creates uncertainty regarding implementation. Removing this wording would provide greater clarity and ensure the policy is applied as intended.

In addition, a definition of "large employment developments" should be included within the policy. Where justified, this definition should be incorporated into the wording of paragraph 8, rather than applying the requirement for on-site sports provision to all commercial developments regardless of scale.

This amendment is necessary because, as acknowledged in paragraph 6.30 of the supporting text, only one of the three supporting sports strategies, namely the Indoor Sports Facility Strategy (2026), specifically identifies impacts arising from employment development, and specifically 'large employment developments'. The current approach therefore does not provide sufficient justification for imposing on-site sports provision requirements across all employment schemes.

On this basis, some modification to the wording of the policy is necessary to ensure that the policy is justified and that the DLP can be found sound at examination. A tracked change version of these changes can be found attached to this representation.