Full text:
This representation has been prepared on behalf of Paragon Land & Estates Ltd (hereafter “Paragon”) in relation to their land interests at draft allocation S/RRA/SNR: Land to the North of St Neots Road, Dry Drayton (the “Site”). This also follows on from the representations made to the Regulation 19 consultation earlier this year.
Paragon is supportive of the draft allocation for employment uses in the emerging Local Plan which recognises that the Site is available, achievable and deliverable. Further, it is acknowledged the need to ensure that development across the Site does not prejudice the delivery of the recently approved Cambourne to Cambridge Busway nor East West Rail. The Site remains available for residential uses should the Council wish to discuss that opportunity.
However, Paragon objects to the draft policy wording, in particular the restriction of Use Classes across the Site to office (E(g)(i)), research and development (E(g)(ii)) and light industrial (Class E(g)(iii)) which we believe is unjustified.
Whilst it is acknowledged that the Site has previously been promoted for the proposed allocation uses, the market has materially moved on since this time, and therefore the range of allocated uses should be expanded to include B2 industrial and B8 storage and distribution. The reasons for which are set out below.
Council’s Response to Regulation 18 Consultation
The Council has prepared a document entitled “Consultation Statement - Appendix 7: Response to Representations – Site Allocations, which provides their responses to representations made in relation to sites proposed for allocation, such as Paragon’s site known as “S/RRA/SNR”.
The Council states that they do not propose to include B2 and B8 uses in the draft allocation as:
● The need for uses is met elsewhere, and
● Due to proximity to residential uses, there is potential for noise to have an adverse impact on amenity.
Taking each point in turn:
Need for Warehouse Uses Being Met Elsewhere
It is not considered sufficient to simply state that warehousing is met across other allocations. In fact, paragraph 86 e) of the examining Framework clearly states that policies should “be flexible enough to accommodate needs not anticipated in the plan and allow for new and flexible working practices and spaces to enable a rapid response to changes in economic circumstances.” Clearly, seeking to curtail an employment allocation purely on existing evidence and limiting its flexibility would run contrary to this paragraph.
Whilst we acknowledge that this Plan is not being examined against the plan-making policies of the new NPPF (2026), it is important to consider its changes and why they were made.
New Policy E1 states that “to support business investment and employment, development plans should, at the most appropriate level [….] 2. Given changing commercial property requirements, 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).”
The government’s summary paper published alongside the December 2025 consultation on the Framework provided information as to why changes were proposed . Under Policy E1 the government elaborated that it was redrafting elements of NPPF 2024 paragraphs 86 and 87 to make it “clearer that, in allocating sites, plans should avoid overly prescriptive requirements on acceptable uses, enabling flexibility to respond to changing commercial property demands.”
It would appear, based on the feedback in the Council’s consultation report, that the primary reason the Council is seeking to limit the use is noise. As such, Paragon, has engaged with an Acoustic Consultant to provide evidence to support greater flexibility, the findings of which are set out below.
Noise – B2 and B8
Heyda Acoustics has prepared the appended Noise Impact Assessment (Appendix 1). The findings of which are clear there are no in-principle reasons why the flexibility sought in policy terms that B2 and B8 uses cannot be secured on this Site subject to detailed design and considered mitigation. As such, we propose that the development management process is used to ensure that amenity is protected in the future.
As such, whilst Paragon does not feel it necessary, they would be agreeable to the proposed allocation having an additional limb added requiring the submission of a noise impact assessment with any future application.
Greater Demand and Industrial and Logistics
Since the Site was first promoted for the uses allocated in the draft policy, there has been a greater recognition of the demand for industrial and logistics warehouse space across Greater Cambridge.
The Council has considered this further within its Greater Cambridge Warehouse and Industrial Space Needs Assessment which was prepared by Iceni (March 2025). Table 6.4 of the report identifies indicative land requirements as shown below:
This sets out a significant need for warehouse space to satisfy several different functions (residual need of 197,000 sqm). Table 7.5 of the same report further considers existing supply and the approach to distributing need by warehouse / industrial typologies:
There is clearly significant pent-up demand for warehouse space across the plan period, including across a range of different unit sizes. Whilst the large allocation on the A14 will deliver a large amount of this residual demand, this will likely be larger floor plates, and as identified above there is also demand for smaller scale units which can be accommodated on this Site.
Given the Site’s sustainable location in close proximity to large housing proposals (Cambourne and Bourn Airfield), proximity to Cambridge urban fringe and its strong access to the strategic road network, it could function across the range of uses that may look to take up warehouse space as well as function for the current draft allocated uses.
Proposed Amendments to Policy S/RRA/SNR
As previously outlined, Paragon is supportive of the draft allocation for employment uses in principle on the Site and believe work to date clearly demonstrates it is available, achievable and deliverable. The Site can also be made available for residential uses should the Council wish to discuss this further, we would be happy to do so.
However, based upon the evolving commercial market and the special qualities of the Site, we believe that the allocated uses can be expanded to include B2 and B8. This would also be consistent with paragraph 86 e) of the examining Framework, and the clear direction of travel set out by the new Framework. As such, we do not believe the resistance to include B2 and B8 uses has been justified appropriately. We therefore object to the policy in this regard.
We have set out the proposed changes in bold below to address the use classes matter and to ensure sufficient flexibility should Cambourne to Cambridge (“C2C”) or East West Rail not be delivered. It is acknowledged that C2C has been subject to a public inquiry, however flexibility needs to be retained in policy terms in case the scheme is not delivered.
Further, additional new wording has been added since Regulation 18 without justification regarding a requirement for ‘forest scale’ trees. It is for the development management process to determine an appropriate landscape design; this may include how a site best addresses biodiversity net gain for instance.
The proposed changes are below:
• Site area of 4.6 hectares.
• Capacity for approximately 5,000 square metres of office (Class E(g)(i)), research and development (Class E(g)(ii)), and light industrial (Class E(g)(iii)), industrial (B2) and storage and distribution (B8).
1. Development proposals must demonstrate how they will meet the following requirements:
a) Development proposals should enhance the existing southern hedgerow to provide visual screening . Landscape proposals must take into account landscape enhancements associated with the Cambourne to Cambridge high quality public transport (HQPT) corridor and East West Rail;
b) Implement measures necessary to provide good public transport and active travel access to the site from surrounding existing and planned developments;
c) The form and siting of the development will need to account for and safeguard land for the Cambourne to Cambridge high quality public transport (HQPT) corridor unless it can be evidenced that the scheme will not come forward;
d) Development of the site must not prejudice the preferred East-West Rail route alignment or its delivery unless it can be evidenced that the scheme will not come forward; and
e) Must be accompanied by an appropriate archaeological assessment, including the extent, character and condition of the archaeological resource and the likely impact of the development on the archaeological remains.
f) Any forthcoming application should be accompanied by a Noise Impact Assessment.
