Greater Cambridge Local Plan: Proposed Submission

Suggested Modifications
To ensure the policy is justified and effective, the University requests that:
• Any trigger for the requirement should relate to jobs created, not floorspace to avoid scenarios where new buildings are created for existing employees/departments/companies to relocate to, where floorspace is created by additional jobs are not.
• The application of the 1,000 square metre (or alternative job creation) threshold to existing employment estates and institutional campuses is clarified.
• The 20% local labour requirement is replaced with a more flexible, evidence-based approach.
• Occupation-phase requirements allow for site-specific circumstances and existing workforce profiles.
• Financial contributions are not sought where applicants can demonstrate that reasonable endeavours have been undertaken.
• Specific flexibility is provided for established educational, research and institutional employers.
• Monitoring requirements recognise labour market constraints and factors outside the applicant's control.
These amendments would improve the effectiveness and deliverability of the policy whilst supporting its underlying objectives.

The University of Cambridge is supportive of the principle of the policy and its objective of increasing employment and skills opportunities for local residents. However, the University objects to Policy WS/IO as currently drafted on the basis that it is not sufficiently justified or effective and raises significant concerns regarding implementation, monitoring and deliverability and therefore fails to effectively be in line with National Policy PM15.

The policy requires the preparation and delivery of Employment and Skills Plans for both the construction and occupation phases of qualifying development. These requirements apply to employment-generating development, including educational uses, and are also triggered where a proposal forms part of a wider development which cumulatively exceeds the 1,000 square metre threshold. It is considered that any trigger should relate directly to jobs created, not floorspace to avoid the policy being triggered in instances where existing employees/departments/companies simply relocate elsewhere in Greater Cambridge.

The University is concerned that the operation of these provisions is unclear in relation to large and established employment locations. In particular, it is not evident how the cumulative threshold would apply to extensive institutional estates, such as those operated by the University, where existing floorspace already substantially exceeds the threshold identified within the policy. Further clarification is required to ensure the policy can be applied consistently and proportionately.

The University also has concerns regarding the assumptions underpinning the viability evidence. The Greater Cambridge Local Plan Viability Assessment (2026), prepared by Aspinall Verdi, concludes that the costs associated with preparing and monitoring Employment and Skills Plans are likely to be modest relative to overall scheme costs. However, the University considers that this assessment may underestimate the time, complexity and resources required to prepare, implement and monitor such plans, particularly on large and complex development projects and within established employment clusters. These additional requirements could therefore have implications which are not fully reflected within the supporting evidence base.

Furthermore, the University is concerned by the inclusion of rigid numerical targets within the policy.
Paragraph 4 requires that 20% of all jobs created during the construction phase of development are secured for local residents. Whilst the objective of maximising employment opportunities for local people is supported, the evidence base does not clearly demonstrate that this specific target is appropriate or achievable across all forms of development and throughout the plan period. Labour market conditions will vary over time, and the availability of suitably qualified local labour will differ between sectors and occupations. The policy should therefore provide greater flexibility to respond to changing economic circumstances and labour market conditions.
Similar concerns arise in relation to paragraph 5, which requires qualifying developments to provide a minimum number of supported employment places for local residents during the occupation phase of development. The requirement is based on a formula set out within the supporting text. However, there is limited evidence demonstrating that the resulting targets are realistic and deliverable across the range of employment-generating development expected to come forward during the plan period.

The practical implementation and enforcement of the policy also give rise to concerns. Paragraph 9 requires developers to use reasonable endeavours to implement agreed Employment and Skills Plans and to submit regular monitoring reports to the Councils. The policy further states that where target outputs are not achieved, and the Councils consider that reasonable endeavours have not been exercised, a financial contribution may be sought in respect of any shortfall.

Whilst the University supports appropriate monitoring arrangements, it is unclear how compliance will be assessed where labour shortages, skills gaps or wider economic factors beyond the control of applicants affect the ability to achieve the prescribed targets. In such circumstances, the policy has the potential to create uncertainty for applicants despite genuine efforts having been made to comply with its requirements.

The University is particularly concerned about the implications of the policy for existing employers and institutions operating within Greater Cambridge. Many organisations, including the University, maintain established and highly skilled workforces and may seek to redevelop, modernise or relocate existing accommodation during the plan period. In these circumstances, the occupation phase requirements could create unintended consequences where existing workforce profiles do not align with the ratios generated by the policy's calculator.

The University considers that it would be inappropriate for planning policy to discourage investment in new or improved accommodation by existing businesses, institutions and educational establishments. The policy should recognise that redevelopment proposals involving established employers will often differ from new employment-generating schemes and should therefore allow sufficient flexibility to reflect existing workforce characteristics and operational requirements.

The current wording also raises questions regarding how the policy would operate in practice where prescribed employment outcomes are sought irrespective of the availability, suitability or capability of the local labour force. Greater clarity is required to demonstrate that the policy requirements are realistic, enforceable and capable of being applied in a manner that does not give rise to unintended consequences.

Accordingly, substantial modifications to Policy WS/IO are necessary to comply with National Policy PM15 and to provide greater flexibility, improve the clarity of implementation and monitoring arrangements, and ensure that the policy appropriately reflects labour market realities and the circumstances of existing employers and institutions. Without such amendments, the policy is not considered sufficiently justified or effective and may not be capable of being found sound.

Suggested Modifications
To ensure the policy is justified and effective, the University requests that:
• Any trigger for the requirement should relate to jobs created, not floorspace to avoid scenarios where new buildings are created for existing employees/departments/companies to relocate to, where floorspace is created by additional jobs are not.
• The application of the 1,000 square metre (or alternative job creation) threshold to existing employment estates and institutional campuses is clarified.
• The 20% local labour requirement is replaced with a more flexible, evidence-based approach.
• Occupation-phase requirements allow for site-specific circumstances and existing workforce profiles.
• Financial contributions are not sought where applicants can demonstrate that reasonable endeavours have been undertaken.
• Specific flexibility is provided for established educational, research and institutional employers.
• Monitoring requirements recognise labour market constraints and factors outside the applicant's control.
These amendments would improve the effectiveness and deliverability of the policy whilst supporting its underlying objectives.

Please see attached document which highlights the proposed changes in red.

The University therefore considers that the original criteria should be reinstated alongside the new requirements. Without these provisions, the policy does not fully address key design and amenity considerations and may be less effective in delivering its stated objectives.

The University of Cambridge is supportive of the principle of the policy, to ensure that new development is of the highest design quality. However, to ensure that it is clear and effective in line with National Policy PM15, it is requested that two additional criteria are added to paragraph 2 of the policy as follows:

q. Create safe open spaces and active streets, by providing highway layouts that incorporate well-integrated car parking and landscaping. Proposals should avoid the perception of a car-dominated environment and prioritise safe and convenient pedestrian and cycle movement; and,

r. Protect the amenity of neighbouring uses and provide a high standard of amenity for future occupiers. Design should minimise adverse impacts including loss of privacy, overlooking, overshadowing, poor daylight/sunlight access, microclimate effects, artificial lighting, noise, vibration, fumes, odours, and other forms of pollution.
These criteria were included in the Regulation 18 Consultation (as criteria (d) and (h)) and addressed important place-making and amenity considerations. However, through the re-drafting of the policy wording for the Regulation 19 Consultation, these two requirements have been deleted in favour of two replacement criteria around designing out crime and integration of measures such as Hostile Vehicle Mitigation.

While the University supports the inclusion of these additional design and safety considerations, it considers that they should not have been introduced at the expense of the original criteria. The matters covered by criteria (q) and (r) are fundamental to achieving high-quality development and ensuring that proposals create attractive, functional and healthy environments for both existing and future users.

The University therefore considers that the original criteria should be reinstated alongside the new requirements. Without these provisions, the policy does not fully address key design and amenity considerations and may be less effective in delivering its stated objectives.

Accordingly, a modification to the policy wording is necessary to ensure that the policy is justified, effective and consistent with national policy, and that the Draft Local Plan can be found sound at examination. A tracked change version of these changes can be found attached to this representation.

Suggested Modifications
To improve flexibility and deliverability, the University requests the following amendments:
• Exempt development proposals delivered primarily for educational, research or institutional purposes where affordable workspace would not be operationally appropriate.
• Expand the circumstances in which off-site provision or financial contributions may be accepted, subject to appropriate justification.
• Remove the requirement for affordable workspace to be occupied prior to, or alongside, occupation of 50% of the market floorspace and instead allow delivery through an agreed phasing strategy.
• Permit alternative management arrangements where applicants can demonstrate appropriate expertise, without requiring operation by an approved provider.
• Include a viability review mechanism to ensure that affordable workspace requirements remain proportionate and deliverable.
• Clarify that affordable workspace obligations will be applied flexibly to avoid discouraging investment, redevelopment and expansion by existing employers and institutions.

The University of Cambridge supports the principle of providing affordable workspace to support innovation and business growth within Greater Cambridge. However, it objects to Policy J/AW as currently drafted because several elements of the policy are not sufficiently justified and may not be effective in practice, and therefore fall short of the requirements of National Policy PM15.

The policy requires developments comprising more than 1,000 square metres of office and research and development floorspace to provide a minimum of 10% affordable workspace, with discounted rents secured in perpetuity. Whilst the objective of supporting affordable business space is recognised, the policy does not adequately reflect the diverse nature of employment development within Greater Cambridge. In particular, many developments brought forward by the University are intended to meet its own teaching, research and operational requirements rather than provide accommodation for third-party occupiers. Whilst the University actively seeks to encourage collaboration, in many circumstances on-site affordable workspace may not be appropriate or practicable.

The University is also concerned that the policy places undue emphasis on on-site provision. Whilst paragraph 4 allows for a financial contribution in limited circumstances, this would still impose an additional cost burden on developments that are not intended to accommodate commercial occupiers. A more flexible approach is required to recognise developments delivered by educational and research institutions in pursuit of their core functions.
Further concerns arise from the requirement for affordable workspace to be delivered prior to, or alongside, occupation of 50% of the market workspace. The evidence base does not demonstrate that the viability and cashflow implications of this requirement have been fully assessed. For large or complex developments, a rigid delivery threshold may constrain implementation and reduce flexibility in responding to market demand.

The policy also requires affordable workspace to be managed by an approved provider, together with ongoing monitoring secured through planning obligations. The cumulative impact of these requirements may be more onerous than suggested by the supporting evidence and could create additional operational burdens for applicants.
Accordingly, the University considers that modifications are necessary to ensure that the policy is justified, effective and capable of being found sound.

Suggested Modifications
To improve flexibility and deliverability, the University requests the following amendments:
• Exempt development proposals delivered primarily for educational, research or institutional purposes where affordable workspace would not be operationally appropriate.
• Expand the circumstances in which off-site provision or financial contributions may be accepted, subject to appropriate justification.
• Remove the requirement for affordable workspace to be occupied prior to, or alongside, occupation of 50% of the market floorspace and instead allow delivery through an agreed phasing strategy.
• Permit alternative management arrangements where applicants can demonstrate appropriate expertise, without requiring operation by an approved provider.
• Include a viability review mechanism to ensure that affordable workspace requirements remain proportionate and deliverable.
• Clarify that affordable workspace obligations will be applied flexibly to avoid discouraging investment, redevelopment and expansion by existing employers and institutions.

These modifications would help ensure that the policy supports affordable workspace provision whilst remaining sufficiently flexible to accommodate the diverse range of employment and institutional developments expected to come forward during the plan period.

Please see attached document which highlights the proposed changes in red. This includes amending para 8 to include 'c. Where the change of use to other appropriate uses can contribute to identified needs
within the Plan and/or can deliver viable uses within heritage assets that would secure
their long-term use.'

The University of Cambridge objects to this policy on the basis that it is not effective as set out in National Policy PM15.

Cambridge and the wider plan area benefit from a range of visitor accommodation. The Greater Cambridge Future Hotel Need Study (2025) identifies that by the end of the plan period, between 1,600 and 3,800 additional rooms will be needed, depending on the growth scenario and success of the Destination Management Plan to convert more day visits (currently 90% of visits), to overnight stays.

However, these projections are subject to changing economic conditions and market trends over the plan period. As such, the level of need for additional hotel accommodation may fluctuate and could reduce in the future. In these circumstances, the policy's current requirements for the loss of visitor accommodation are overly restrictive.

In particular, the requirement to demonstrate that the use is no longer economically viable and that the property has been actively marketed for at least 12 months with no interest in continued hotel use places a significant and unnecessary burden on applicants.

This approach is slow, resource-intensive and insufficiently responsive to changing market conditions. It restricts the ability of buildings to adapt to economic signals, prevents the efficient re-use of underperforming assets and can delay the delivery of alternative uses that may provide greater planning benefits. Notably, the City of York Local Plan (2025) and the emerging Bristol Local Plan, both identified in the Hotel Need Study as comparable city authorities, do not impose equivalent requirements on proposals involving the loss of visitor accommodation.

Given Greater Cambridge's sustained growth and pressing need for housing and student accommodation, there is a strong justification for adopting a more proportionate and flexible approach to proposals involving the conversion of visitor accommodation. Rather than relying solely on a stringent viability and marketing test, the policy should allow appropriate redevelopment proposals where they contribute towards identified accommodation needs and deliver sustainable planning outcomes.

Such an approach is consistent with national policy TC1 (our emphasis), which states that local planning authorities should:
‘Be informed by a strategy for town centres in the area, to ensure that the full range of potential needs and opportunities for development is considered. This includes the scope to accommodate additional floorspace, to broaden the mix of uses beyond main town centre uses (including residential development) where this would not undermine the vitality and viability of a centre, to strengthen or re-introduce markets, to bring vacant sites and premises back into use, and to reduce or expand the boundaries of town centres where appropriate’
To ensure that the policy is effective, draft policy J/VA needs to be amended at paragraph 8 as follows:
Loss of visitor accommodation

8. Development will not be permitted which would result in the loss of existing visitor accommodation unless it can be demonstrated that:
a. All reasonable efforts have been made to preserve the facility, but it has been proven that it would not be economically viable to retain the visitor accommodation in its current form; or
b. The property or site has been appropriately marketed for at least 12 months in order to confirm that there is no interest in the property or site for visitor accommodation use; or
c. Where the change of use to other appropriate uses can contribute to identified needs within the Plan and/or can deliver viable uses within heritage assets that would secure their long-term use.

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.

The University acknowledges the alterations made to the draft local plan since the Regulation 18 Consultation. It welcomes these helpful amendments especially in respect of policies H/SA (Student Accommodation) and H/MO (HMO’s).

These policies will enable the Colleges to continue to provide and service high-quality student accommodation to our communities in the core areas where we have operated historically. It will also enable strong and focussed delivery of the associated pastoral care and communal benefits to our communities.
Therefore, the University support the policy in full.

The University acknowledges the alterations made to the draft local plan since the Regulation 18 Consultation. It welcomes these helpful amendments to support the University's move to expand part-time courses and accommodating part-time students in line with Government policy.

This will enable the collegiate University's ability to widen its course offering and offer accommodation to these students, some of which will be on courses that include intensive teaching blocks and benefit from being accommodated in the City.

Therefore, the University support the policy in full.

To ensure that the policy is clear and effective in line with National Policy PM15, it is requested that the policy sets out maximum car parking standards for different use classes, as it does for minimum cycle parking standards.

This would be in accordance with Policy TR2: Local Parking Standards as set out in the National Planning Policy Framework (2026), which requires development plans to set out maximum standards for car parking.

The University of Cambridge is supportive of the principle of the policy and welcomes the more flexible approach to EV charging.

However, to ensure that the policy is clear and effective in line with National Policy PM15, it is requested that the policy sets out maximum car parking standards for different use classes, as it does for minimum cycle parking standards.

This would be in accordance with Policy TR2: Local Parking Standards as set out in the National Planning Policy Framework (2026), which requires development plans to set out maximum standards for car parking.
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.

Please see attached document which highlights the proposed changes in red. This includes amending the following sentence to read 'Harm caused to the Observatory by proposed development will be refused, or where appropriate will be overcome with use of conditions or planning obligations to regulate the installation and use of equipment likely to interfere with the operation of the
observatory.'

The University of Cambridge is supportive of the policy. However, to ensure that it is clear and effective in line with National Policy PM15, it is requested that the supporting text reads as follows:

10.56. The internationally important Mullard Radio Astronomy Observatory at Lord’s Bridge contains unique radio and optical telescopes which are highly susceptible to many forms of interference, specifically electrical interference, light pollution and mechanical vibration. Arrangements are made to consult the University of Cambridge about the technical consequences for the observatory of proposed development. Harm caused to the Observatory by proposed development will be refused, or where appropriate will be overcome with use of conditions or planning obligations to regulate the installation and use of equipment likely to interfere with the operation of the observatory.

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.

Suggested changes are identified on the attached table. These include requiring the masterplan to be co-developed by campus landowners, with input from major occupiers. This would provide all parties with confidence in the deliverability of the masterplan and ensure that the wider vision for the campus can be achieved through a realistic and coordinated framework as well as changes to the quantum of development, clarity on specific policy requirements as well as greater flexibility elsewhere within the policy.

The University of Cambridge (UoC) supports the Councils' recognition of the Campus as a globally significant centre for healthcare, life sciences, and clinical research. However, the UoC objects to this policy in its current form, as a number of modifications to the wording are required. These changes are necessary to ensure that the policy is effective, consistent with National Policy PM15, and that the Draft Local Plan is capable of being found sound.

The UoC is a key partner in the ongoing development and operation of the Cambridge Biomedical Campus (CBC). The wider campus is home to the School of Clinical Medicine and includes significant commercial and research activities that benefit from the campus's unique "bench to bedside" environment, where close partnerships between research institutions and hospitals support collaboration, innovation, and the advancement of patient care and medical science.

The UoC has worked collaboratively with partners across the CBC to ensure a coordinated approach to campus development and to deliver a shared vision for a world-class biomedical campus. This collaboration has included the preparation of these representations, undertaken in close coordination with Cambridge University Hospitals NHS Foundation Trust, Cambridge Biomedical Campus Limited (CBC Limited), and the Landowner Collaboration Group (LCG).

Notwithstanding the above, the UoC considers that aspects of the current drafting of Policy S/CBC would not deliver the coordinated and comprehensive development of the campus that the policy seeks to achieve. The proposed modifications set out in the attached schedule of amendments are therefore critical to securing a coordinated, masterplan-led approach to future development.

In particular, while the masterplan is central to the delivery of the policy, the process for its preparation is not sufficiently defined. As currently drafted, paragraphs 10 and 30 require a whole-campus masterplan to be prepared "with input from" and "engaging" existing campus landowners and major occupiers. The UoC strongly objects to this approach, as it would permit third parties to prepare plans affecting assets that are not within their ownership or control and without the agreement of the relevant landowners. Such an approach risks producing a masterplan that is not deliverable in practice.

The proposed amendments therefore require the masterplan to be co-developed by campus landowners, with input from major occupiers. This would provide all parties with confidence in the deliverability of the masterplan and ensure that the wider vision for the campus can be achieved through a realistic and coordinated framework.
Furthermore, the trigger for the preparation of the campus-wide masterplan should remain as currently drafted, namely the submission of a major planning application relating to Phase 3 or Phase 4 expansion land. The requirement should not be extended to any "strategically significant" development on the existing campus. Such an approach could unnecessarily impede development proposals brought forward by existing occupiers or landowners within the established brownfield areas of the campus, particularly where progress on land released from the Green Belt is delayed.

In this regard, the recently adopted Cambridge Biomedical Campus Supplementary Planning Document (CBC SPD 2025) already provides an up-to-date policy framework to guide development proposals on the existing campus and should continue to fulfil that role.

The co-development and shared ownership of the masterplan are also essential to enable compliance with paragraph 32 of the policy, which requires the masterplan to be reviewed and updated as development progresses. Effective implementation of this requirement will only be possible where all relevant landowners are actively involved in both the preparation and ongoing stewardship of the masterplan.

The attached schedule of amendments sets out the modifications proposed by the UoC, together with the justification for each change. These amendments are necessary to ensure that the policy is sound by being positively prepared, justified, effective, and consistent with national policy.