Greater Cambridge Local Plan: Proposed Submission
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Greater Cambridge Local Plan: Proposed Submission
Chapter 2: Development strategy
Respondent: The Crown Estate
Representation Summary:
This representation relates to a site submission (HELAA ref 200814 Cambridge Business Park, Milton Road, Cambridge)
Support, subject to minor amendments.
TCE welcomes the revised approach to the North East Cambridge (NEC) Area of Major Change and the wider development strategy, in particular the recognition that growth and intensification within NEC can continue despite the uncertainty surrounding the relocation of the Cambridge Waste Water Treatment Plant and Hartree development.
Furthermore, Policy S/DS now provides a more realistic and deliverable framework for the continued growth of Greater Cambridge's innovation economy and appropriately recognises the importance of existing employment clusters, including TCE’s Cambridge Business Park site.
Full text:
Support, subject to minor amendments.
TCE welcomes the revised approach to the North East Cambridge (NEC) Area of Major Change and the wider development strategy, in particular the recognition that growth and intensification within NEC can continue despite the uncertainty surrounding the relocation of the Cambridge Waste Water Treatment Plant and Hartree development.
Furthermore, Policy S/DS now provides a more realistic and deliverable framework for the continued growth of Greater Cambridge's innovation economy and appropriately recognises the importance of existing employment clusters, including TCE’s Cambridge Business Park site.
Greater Cambridge Local Plan: Proposed Submission
Policy S/AMC/NEC: North East Cambridge Area of Major Change
Respondent: The Crown Estate
Representation Summary:
Support, subject to minor amendments.
TCE strongly supports the significant evolution of the NEC policy since Regulation 18.
Policy S/AMC/NEC Part 3(e), TCE supports the principle of providing affordable workspace and supporting innovation, start-up businesses and creative industries. The policy clause should be amended to make clear that establishing an appropriate quantum of affordable workspace will need to take account of site-specific viability, market demand, existing occupier requirements and delivery mechanisms and there may be instances where opportunities to deliver equivalent economic benefits through alternative mechanisms and off-site provision could be more appropriate and impactful.
Additionally, concerns remain regarding the continued reliance on the NEC trip budget framework. The policy should expressly allow for future review and adjustment of the trip budget where robust evidence demonstrates this can be achieved without unacceptable transport impacts. The retention of fixed vehicle trip budget limits represents the principal outstanding concern relating to Policy S/AMC/NEC.
Full text:
Support, subject to minor amendments.
TCE strongly supports the significant evolution of the NEC policy since Regulation 18.
In particular, the removal of employment floorspace caps, support for employment-led intensification, recognition of Cambridge Business Park as a location for future growth, and the more flexible approach to building heights are welcomed. These changes improve the effectiveness and deliverability of the policy and better reflect the role of NEC as a nationally significant innovation district.
In respect of Policy S/AMC/NEC Part 3(e), TCE supports the principle of providing affordable workspace and supporting innovation, start-up businesses and creative industries. The policy clause should be amended to make clear that establishing an appropriate quantum of affordable workspace will need to take account of site-specific viability, market demand, existing occupier requirements and delivery mechanisms and there may be instances where opportunities to deliver equivalent economic benefits through alternative mechanisms and off-site provision could be more appropriate and impactful.
Additionally, concerns remain regarding the continued reliance on the NEC trip budget framework. Whilst TCE acknowledges the Council's desire to manage transport impacts, the policy should allow greater flexibility to respond to updated evidence, changing travel behaviours, technological change and site-specific transport mitigation measures. The policy should expressly allow for future review and adjustment of the trip budget where robust evidence demonstrates this can be achieved without unacceptable transport impacts. The retention of fixed vehicle trip budget limits represents the principal outstanding concern relating to Policy S/AMC/NEC.
As such, the policy should be amended to allow for future evidence-led review of the trip budget and associated transport assumptions.
Greater Cambridge Local Plan: Proposed Submission
Respondent: The Crown Estate
Representation Summary:
Support, minor amendments sought.
TCE supports the principle of co-living as an important component of Greater Cambridge's housing offer.
TCE welcomes the removal of the clause from Regulation 18 stage which established a minimum tenancy length requirement.
The draft policy would still benefit from an amendment in respect of the proposed unit thresholds which do not reflect the operational and financial characteristics of the sector. Experience from the market demonstrates that many successful co-living developments require significantly more than 200 units to achieve viability and support the level of shared facilities expected by residents.
Full text:
Support, minor amendments sought.
TCE supports the principle of co-living as an important component of Greater Cambridge's housing offer.
TCE welcomes the removal of the clause from Regulation 18 stage which established a minimum tenancy length requirement which, as commented at Regulation 18 stage, was unnecessarily restrictive required removal to provide operators greater flexibility to respond to market demand whilst continuing to provide stable accommodation.
The latest draft policy would still benefit from an amendment in respect of the proposed unit thresholds which do not reflect the operational and financial characteristics of the sector. Experience from the market demonstrates that many successful co-living developments require significantly more than 200 units to achieve viability and support the level of shared facilities expected by residents. The policy should therefore provide greater flexibility and avoid establishing prescriptive thresholds that could prevent otherwise sustainable and deliverable schemes from coming forward, such as requiring further justification / criteria for co-living schemes of over 200+ units )as set out in part d(i) and (ii) of the draft policy.
Greater Cambridge Local Plan: Proposed Submission
Policy I/CV: Cycle and vehicle parking
Respondent: The Crown Estate
Representation Summary:
Support in principle, amendment sought.
TCE supports the promotion of sustainable travel and reduced car dependency. However, parking provision should be more closely aligned to operational requirements, forecast demand, actual mode share and the characteristics of individual occupiers and locations. A more flexible, evidence-led approach would better reflect changing working patterns, including hybrid working, and avoid over or under-provision of parking. The policy should explicitly allow departures from standard parking requirements where supported by robust transport evidence and travel demand assessments.
Full text:
Support in principle, amendment sought.
TCE supports the promotion of sustainable travel and reduced car dependency. However, parking provision should be more closely aligned to operational requirements, forecast demand, actual mode share and the characteristics of individual occupiers and locations. A more flexible, evidence-led approach would better reflect changing working patterns, including hybrid working, and avoid over or under-provision of parking. The policy should explicitly allow departures from standard parking requirements where supported by robust transport evidence and travel demand assessments.
Greater Cambridge Local Plan: Proposed Submission
Policy J/AW: Affordable workspace and creative industries
Respondent: The Crown Estate
Representation Summary:
Object unless modified.
TCE supports the principle of providing affordable workspace and supporting innovation, start-up businesses and creative industries. However, the policy as drafted currently seeks significant amounts of affordable workspace at prescribed discounts and, critically, in perpetuity across strategic science and business parks, including Cambridge Business Park.
Change suggested by respondent:
The policy should either: a) remove the reference to 10% affordable workspace provision and take a more ‘case-by-case’ approach based on evidence/demand (thereby reducing the need for viability assessments at the decision-making stage); or b) include a more clearly defined viability review mechanism and provide greater flexibility regarding the quantum, tenure, operational model and long-term management of affordable workspace. Furthermore, the policy should more clearly allow for opportunities to deliver equivalent economic benefits through alternative mechanisms and off-site provision where appropriate.
Full text:
Object unless modified.
TCE supports the principle of providing affordable workspace and supporting innovation, start-up businesses and creative industries. However, the policy as drafted currently seeks significant amounts of affordable workspace at prescribed discounts and, critically, in perpetuity across strategic science and business parks, including Cambridge Business Park.
TCE has significant concerns that the policy as drafted does not provide sufficient flexibility to take account of site-specific viability, market demand, existing occupier requirements and delivery mechanisms. Furthermore, the requirement to secure affordable workspace in perpetuity, rather than for a prescribed timescale (which would appear inconsistent with affordable workspace policies in London Boroughs and elsewhere in the UK), would place significant viability constraints on development.
Regard should be had to the new NPPF (August 2026) which makes clear at Policy PM12(3)(b) that “policy requirements should be set at a level that allows for the planned types of development and sites to be deliverable, maximising certainty and reducing the need for viability assessment at the decision-making stage”.
As such, the policy should either: a) remove the reference to 10% affordable workspace provision and take a more ‘case-by-case’ approach based on evidence/demand (thereby reducing the need for viability assessments at the decision-making stage); or b) include a more clearly defined viability review mechanism and provide greater flexibility regarding the quantum, tenure, operational model and long-term management of affordable workspace. Furthermore, the policy should more clearly allow for opportunities to deliver equivalent economic benefits through alternative mechanisms and off-site provision where appropriate.
Greater Cambridge Local Plan: Proposed Submission
Policy S/DS: Development strategy
Respondent: The Crown Estate
Representation Summary:
Policy S/DS now provides a more realistic and deliverable framework for the continued growth of Greater Cambridge's innovation economy and appropriately recognises the importance of existing employment clusters, including TCE’s Cambridge Business Park site.
Full text:
Support, subject to minor amendments.
TCE welcomes the revised approach to the North East Cambridge (NEC) Area of Major Change and the wider development strategy, in particular the recognition that growth and intensification within NEC can continue despite the uncertainty surrounding the relocation of the Cambridge Waste Water Treatment Plant and Hartree development.
Furthermore, Policy S/DS now provides a more realistic and deliverable framework for the continued growth of Greater Cambridge's innovation economy and appropriately recognises the importance of existing employment clusters, including TCE’s Cambridge Business Park site.
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