Greater Cambridge Local Plan: Proposed Submission

2.1.25 To make the Plan sound, the following changes are considered necessary:
● Undertake a proper assessment of the sustainability effects of higher rate of employment growth to ensure the strategy is justified.
● Increase in the level of job growth proposed to align with the high growth scenario, which would be reflective of a more optimistic market approach based on the economic prominence of Greater Cambridge – 90,900 jobs.
● At Paragraph 2.12, increase in the need for industrial and warehousing floorspace over the plan period from 317,000m² to at least 429,900m².

2.1.1 TBBD objected to Policy S/JH in their Regulation 18 representations on the basis that the Local Plan does not plan for sufficient employment land to support the significant economic potential that exists in the Greater Cambridgeshire area.

Economic Growth as an Imperative
2.1.2 Greater Cambridge has been recognised by successive governments as one of the UK’s most important economic growth opportunities, particularly as a global leader in life sciences, technology and research sectors.

2.1.3 Furthermore, Greater Cambridge forms part of the Oxford Cambridge Arc (referred to as the UK’s Silicon Valley in March 2026 by the Oxford-Cambridge corridor to be UK’s “Silicon Valley” - GOV.UK ) which has long been recognised as one of the central planks of the Government’s plans for economic growth.

2.1.4 Matthew Pennycook MP, Minister of State for Housing and Planning, identified that sustained economic growth is the only route to improving the prosperity of the country and living standards of working people. Identifying economic growth as the government’s number one mission.

2.1.5 His statement on realising the full potential of Greater Cambridge identifies that whilst the economic growth of Cambridge has been a phenomenal success, it has even greater potential beyond to contribute to an even greater extent to the national economy.

2.1.6 In this context, the government established the Cambridge Growth Company in 2024 to address barriers to growth and help unlock Greater Cambridge’s full potential. More recently, the government established the Greater Cambridge Development Corporation in June 2026 with the express purposes of building upon the work of the Growth Company to achieve transformational economic growth. The Ministerial Statement states clearly “Greater Cambridge Development Corporation”, to promote ambitious, high quality, sustainable growth and unlock the full potential of Greater Cambridge, for the benefit of its communities and the country as a whole”. (Written statements - Written questions, answers and statements - UK Parliament).

2.1.7 The Cambridgeshire and Peterborough Combined Authority (hereafter referred to as “CPCA”) adopted its Local Growth Plan in 2025 with an ambition to ensure the local economy grows faster than any other region in the UK. This includes setting a mayoral target across the CPCA area of tripling the economy by 2050.

2.1.8 In the Chancelors Growth Speech of September this year outlined a strategy to transform the country into a "Growth Britain" ahead of the October Autumn Budget with an approach for fiscal discipline and to drive growth in every postcode.

Employment Growth
2.1.9 The Local Plan has been prepared on the basis that it supports the delivery of 73,200 new jobs – this figure is presented by the Council as a ceiling rather than a target. In parallel, the amount of land allocated to support delivery of this job growth (discussed further in response to Policy S/DS) includes enough land to deliver only 317,000m² of industrial and warehousing floorspace. TBBD consider that both figures are far too low and lack vision given the significant economic potential of the area and specifically the extensive and previously suppressed need for industrial and warehousing floorspace in the Greater Cambridgeshire area.

2.1.10 The Local Plan does however recognise the national importance of the Cambridge economy, stating at Paragraph 2.8 that ‘The continuing strength of the nationally important Greater Cambridge economy provides justification for exploring higher employment and related housing figure’.

2.1.11 Despite this, the Local Plan targets only 73,200 jobs based on a ‘central’ forecast, which includes an assumption that there will be downturns and unknown shocks in the economy. This effectively embeds excessive caution into the target leading to an unjustified limit on the economic growth potential of the area rather than seeking to present any sort of positive ambition in line with Paragraph 2.8. This is confirmed in the conclusion set out in the Employment and Housing Needs Evidence Update (EHNU) (2025), Paragraph 3.60). As such, TBBD do not consider that Policy S/JH has been positively prepared.

2.1.12 The updated EHNU (2025) reiterates that a ‘higher’ rate forecast was considered which aligned with the faster 10-year growth rate for the first 5 years of the plan period, before return to a balanced 20-year growth rate. However, the analysis appears to suggest that a more optimistic forward looking forecast is not justified due to recent under performance against previous forecasts, despite recognising that this covers the period of the Covid-19 pandemic and the post-Covid recovery period, and that the alternative Centre for Business Research (CBR) data indicating a more positive economic outlook which would ‘lean towards a conclusion of planning for a high level of employment growth’ (Development Strategy Topic Paper, Paragraph 3.2).

2.1.13 Table 3.7 of the EHNU (2025) is clear that the preferred strategy of delivering 73,200 jobs during the plan period represents a compound annual growth rate (CAGR) of 1.34% over the plan period, significantly below the 2010-2020 comparison (2.07%), indicating the lack of ambition in the forecast. Additionally, as is recognised in the Topic Paper (Paragraph 3.25) CBR’s analysis indicates recent growth rates of 6.7% in 2021/22, 6.3% on 2022/23 and 5.3% in 2023/24. It is, therefore, clear that the level of job growth that is planned for in the development strategy is significantly below that which could be delivered in the area. This is important, as it has a direct impact on both the level of housing and employment land allocated in the Local Plan.

2.1.14 Building on the analysis above, it is noted that the Development Strategy Topic Paper makes numerous references to 73,200 being the ‘most likely’ forecast of job creation over the plan period and an effective ceiling, dismissing the need for a more optimistic target or any positive flexibility. In an area which is ‘championed’ as one of the leading economies in the country, TBBD do not consider that this approach to be justified, nor does it align with national policy, which seeks to support investment and economic growth as is reflected by the Government’s continued recognition of the Oxford-Cambridge Growth corridor. Further, this approach does not align with our evidence regarding quantum of need supplied at Regulation 18 stage and would therefore be contrary to the objectives of the 2026 NPPF (Building a strong, effective economy) and the Governments ambitions for growth, as such a strategy would likely result in under provision and actively restrict economic growth and job creation.

2.1.15 Although not referred to specifically in Policy S/JH, the supporting text notes the need for just 317,000m² of industrial and warehousing floorspace. The allocations to meet this requirement are discussed further in our representation on Policy S/DS. However, in relation to Policy S/JH, TBBD would note that this is a significant underestimation of the requirements of the area and as outlined above, an increased figure would not result in any ‘harm’ but would simply provide the flexibility and contingency to enable sustainable growth unincumbered by unnecessary pr ambiguous planning restrictions.

2.1.16 As such the level of job growth proposed should align with the high growth scenario, which would be reflective of a more optimistic market approach based on the economic prominence of Greater Cambridge – 90,900 jobs.

Logistic, Warehouse and Mid-Tech Space
2.1.17 Our Regulation 18 representation (Appendix 1) identified a need for a minimum of 429,900m² of net additional B2/B8 floorspace based on an approach of utilising forecast growth in GVA by job type and converting this into the necessary increase in floorspace, which includes forecasting and is an accepted approach. This is significantly above – 36% - the 317,000m² of additional floorspace identified in the Local Plan. This evidence remains robust and valid and should be fully considered by the Inspector.

2.1.18 Notwithstanding the above, the EHNU notes that a 5% availability rate corresponds with the recommended 317,000m² requirement, whereas an 8% rate would increase this to around 360,000m². We question therefore, why this lower end of the range has been replied upon. Within the Councils own (Iceni report) evidence they state, “It is widely recognised that 5-10% (with a 7.5% mid-point) availability or vacancy is needed in commercial markets for functionality and enabling business to grow into new space or facilitate inward investment”.

2.1.19 Whilst there are methodological differences that account for the different forecast of the floorspace required over the plan period, we consider that the previous market suppression in Greater Cambridgeshire, as well as a need to factor in regional/national need into the figure are key issues, which are being underplayed in the Councils evidence base.

2.1.20 The later point is specifically addressed in the supporting Iceni report, ‘Review of economic data, context and representations (June 2026)’, where it states that ‘whilst wider area large scale warehouse requirements are acknowledged, it is not clear that they are Plan area specific, with historic patterns focussing delivery in other parts of the Cambridgeshire and Peterborough area such as Peterborough and Huntingdonshire’. However, there does not appear to be any specific evidence that would support this position, either in respect to wider sub-regional requirements or any analysis on the needs arising from neighbouring authorities and the position taken within their emerging Local Plans.

2.1.21 As we pointed out at Regulation 18 stage, this is a naïve position to take as there will be significant overlap between the needs of local occupiers versus others and indeed, even once allocated, planning policy has no direct control over who occupies units. As is touched on further in our representations on Policy J/NE, the approach of the Local Plan appears to be to specifically constrain the number of large floorplates units, which generally have greater building heights, by manipulating and constraining the objectively assessed need for floorspace in a way which is contrary to national planning policy and guidance. Our view is that constraining the supply in this way will only result in the continued chronic undersupply of industrial and warehousing floorspace which has impacted economic growth in the past, particularly if national and regional occupiers are able to out-bid smaller local occupiers for the same floorspace. Therefore, it is illogical for the need for such floorspace to be excluded from the assessment of need, particularly given the Governments ongoing support for economic growth in Greater Cambridgeshire.

2.1.22 As such, the supporting text (Paragraph 2.12) should be modified to increase the need for industrial and warehousing floorspace over the plan period from 317,000m² to at least 429,900m² to properly reflect the full assessed need.

Sustainability Appraisal
2.1.23 It is also noted that the Sustainability Appraisal process does not appear to have assessed a higher, employment led growth scenario after 2021 (SA report Paragraph 2.20). The report states that ‘Planning for the higher jobs forecast and level of homes associated with it (maximum growth option) was rejected as while this higher job forecast could be possible, it is not the most likely future scenario. As such the Councils did not consider that it represents Greater Cambridge’s objectively assessed need and would therefore not be a reasonable alternative’.

2.1.24 In light of the Chancellors direction for growth and given the level of evidence that indicates that higher levels of job growth could be possible and in recognition that the Cambridge economy is of national importance, we do not consider that it would have been unreasonable to test such a growth scenario as a reasonable alternative and the failure to do this is a weakness of the Sustainability Appraisal process. Failure to plan for such a scenario would likely lead to little prospect in delivering on the governments growth agenda and would miss a fundamental opportunity to provide the necessary conditions for long-term economic growth, contrary to Chapter 7 of the 2026 NPPF. As such, the strategy is not justified as it has not properly tested the alternative scenarios for higher rates of growth to understand the sustainability implications.

2.2.13 To make the Plan sound, the following changes are considered necessary:
● Update the policy to make clear the strategy for the delivery of industrial and warehouse facilities, specifically the role of the A14 corridor, as a strategic freight corridor of national and regional importance.
● Allocate additional land in the A14 corridor to meet the significant additional demand for industrial and warehousing floorspace identified in representations on Policy S/JH.
● Link to Policy J/NE to provide clarity as to how they will be expected to operate as part of the same development strategy.

2.2.1 Policy S/DS sets out the order of preference for where the need for new jobs and homes will be met. In overall terms, this logically focuses on the urban area of Cambridge, before moving to locations beyond the city boundary, including within the urban area.
2.2.2 However, in our view, the strategy fails to adequately separate the strategy for delivering homes and jobs which, whilst interlinked, have different locational characteristics which justify greater clarity in the policy.
2.2.3 As an example, the delivery of industrial and warehousing is primarily focused on two sites in the A14 corridor. However, the strategy identifies the sites under the ‘in the rest of the Rural Area’ sub-heading. This suggests rural scale growth when in reality, the ‘strategy’, which TBBD support and is in accordance with the 2024 NPPF Paragraph 86 c), is to focus strategic scale warehouse and distribution floorspace in the key A14 corridor. The policy would benefit from this point being made clear which would add to the justification for the overall strategy and ensure its effectiveness, when the plan is read as a whole. This is further emphasised in plan-making Policy E1,1c,ii) of the 2026 NPPF with a clearer focus on freight and logistics.
2.2.4 As set out in our representations on Policy S/JH, TBBD consider that requirements for additional employment land, specifically industrial and warehousing land, are significantly below identified need, and should be increased by at least a third. TBBD, therefore, reasonably conclude that more land needs to be identified in the Local Plan to ensure that the true level of demand for such floorspace can be met over the plan period. TBBD consider that the inclusion of their site at Tritax Park Queens’ Cambridge would be a logical addition to the Local Plan, lying within the A14 corridor which has rightly been identified as the key location for such uses specifically to serve the Greater Cambridgeshire area. This is evidenced by DPD already being a named occupier for the proposed Tritax Park Queens’ Cambridge development.
2.2.5 The A14 represents a priority national route for the strategic movement of freight and logistics linking the port of Felixstowe to the national motorway network. This route and its connections allow logistics and freight to integrate with rail freight and supply chains enabling the efficient movement across the UK (Accounting for 5.3% of all freight moved through UK ports in 2023- Appeal Reference: APP/M2840/W/25/3362393).
2.2.6 The A14 consequently plays a critical role in enabling the efficient distribution of goods entering and exiting the UK, connecting them to key distribution centres, manufacturing hubs and retail destinations, such as Cambridge City. As such, it is of national importance and ready access to it directly contributes to growth-supporting infrastructure and the networks that support freight and logistics that the Government has identified as a particular priority.
2.2.7 In respect to localised demand within the Greater Cambridgeshire area, the diversity and type of occupier who have a registered requirements in the market since Covid, remains unsatisfied due to the historic suppression of this type of development under current adopted planning policy. This active local demand is drawn to an area of unmet provision to establish themselves within close proximity to the city of Cambridge to support the continued growth of Greater Cambridge, such as the life sciences and technology clusters.
2.2.8 Even if the Inspector(s) were to conclude that the Council’s approach to calculating the need for industrial and warehousing land is justified, TBBD still consider that additional land needs to be identified in the Local Plan to ensure the Plan can be effective in meeting the requirement.
2.2.9 As drafted, the Local Plan effectively allocates only one site (Slate Hall Farm) that is suitable to meet the needs of strategic scale industrial and warehousing floorspace over the plan period, noting the scale and nature of the A14 services allocation means it is more suited to smaller units. There is no contingency in supply should the site (Slate Hall Farm) not come forward as expected, nor is there any flexibility to respond to changes in the market.
2.2.10 The approach to industrial and warehouse land in the Development Strategy is therefore ineffective, as well as being contrary to national policy, with the 2024 NPPF (Paragraph 86e) requiring policies to be flexible enough to meet needs not expected in the plan period and to allow rapid response to changes in economic circumstances. Allocating only sufficient land (320,000 m² across three sites) to meet what the Council considers to be the minimum need for such floorspace cannot be considered to meet this requirement, or to be indicative of a positively prepared plan (Emphasised in plan making Policy E1,1cii) of the 2026 NPPF).
2.2.11 The inclusion of an additional criterion in Policy J/NE that would allow some additional warehousing and distribution facilities outside settlement boundaries adds an element of flexibility to the overall strategy and is welcomed (although we have made specific comments on the detail of the policy). Policy J/NE better aligns with the intention of the development management policies of the new NPPF, which will be in operation alongside the policies of the new Local Plan, if adopted, and should be mentioned in Policy S/DS to set out how the two policies are expected to operate alongside each other. However, such a policy should not be at the expense of planning positively to meet the underlying needs of the area, which should be properly accounted for within the development strategy and should therefore only be effective in additionality to the increased need that should be met by way of the allocation of additional land.
2.2.12 In relation to the deliverability of the sites identified in Policy S/DS, we would note that there are numerous policy requirements of the Local Plan which could have an impact. The introduction of CIL cannot be ignored, as in parallel this adds a significant risk to stalling development viability and delaying growth in this sector, if not introduced in an appropriate and evidenced based manner. Such requirements, risk stalling development viability and delaying growth, specifically, in relation to the delivery of sites, as is noted in relation to other policies, there is a significant burden on major developments which could have an impact on viability and meeting the site-specific expectations set out in the Local Plan. Policy requirements, introducing CC/NZ (Net Zero operational requirements beyond national policy), CC/WE (Water leak detection beyond national policy), BG/TC (with no loss of canopy cover), WS/NC (with the requirement to assess sports, recreation, culture and community needs, and include strategies that address identified needs) and J/AW (with the requirement to include affordable workspace), plus the introduction of CIL, will all place a burden on development that could impact viability, making it vital that flexibility is built into the supply of land.

2.3.5 To make the Plan sound, the following changes are considered necessary:
● Either update the policy to reflect the location of development or update the supporting text to provide clarity on the relationship with employment land policies.

2.3.1 Policy S/SH sets out the settlement hierarchy and the expectations for the nature of development that will be accommodated in each location/area. However, it is not clear what role the settlement hierarchy plays in consideration of employment-led development.
2.3.2 As noted in relation of Policy S/DS, major employment growth is proposed in the ‘rural area’. However, this is not reflected in the settlement hierarchy, which appears to focus solely on residential development, and omits any reference to employment related growth. This could be somewhat misleading for the reader and needs further justification/explanation within the policy.
2.3.3 It is suggested that clarity needs to be provided in the policy wording, or the supporting text, to make clear the role and purpose of the policy. If the settlement hierarchy is not to be updated to refer to employment locations, including the A14 corridor, the settlement hierarchy needs to set out which policies are relevant to the consideration of employment related developments.
2.3.4 Given the importance of Greater Cambridge to the national economic growth agenda, this Local Plan has to co-exist with the national objectives and conditions to enable long-term economic growth in accordance with Chapter 7 of the 2026 NPPF. As such, consideration needs to be given as to how the policy will operate alongside the new 2026 NPPF, which set out a number of opportunities for development to be justified outside defined settlement boundaries. Again, this could be a matter that is addressed through an update to the supporting text.

2.4.6 To make the Plan sound, the following changes are considered necessary:
● Update the policy wording to link to Policy J/NE to make it clear that the need for employment floorspace can be the trigger for justifying development outside defined extents of development.

2.4.1 Linked to our comments on the settlement hierarchy, although not a direct consideration for the examination of the Local Pan, there is a need to consider how the policy will operate alongside the new NPPF which includes policies, including those that allow for development outside defined development extents.
2.4.2 In relation to freight and logistics development, any application will be considered against Policies S5 (J) (i) and E3 of the 2026 NPPF which allow development outside settlement boundaries. The wording of Policy S/DE is contrary to these policies and should be given limited weight in decision making in accordance with the new NPPF Annex A2. We therefore suggest that the Council consider how this conflict is addressed in the Local Plan. This is of significant importance given the role Greater Cambridge is to play in the national economic growth agenda, the Local Plan has to therefore co-exist with the national objectives and conditions to enable long-term economic growth in accordance with Chapter 7 of the 2026 NPPF.
2.4.3 In relation to soundness, TBBD note that Paragraph 86 e) of the 2024 NPPF sets out that policies should be flexible enough to accommodate needs not anticipated in the plan and to enable a rapid response to changes in economic circumstances.
2.4.4 Whilst Policy J/NE provides an element of flexibility to meet unexpected needs outside defined settlement extents, this policy is not explicitly linked to Policy S/DE. Whilst there is reference at bullet 2d) to development that is supported by other polices in the plan, it is not clear that this refers to employment floorspace. In the same way as rural exception sites and development for other specific uses in referred to in bullets 2 a-d), we consider that the effectiveness of the plan would benefit from reference to when employment floorspace will be allowed outside defined boundaries – and this would logically be by providing a link to Policy J/NE, which we have commented on separately.
2.4.5 Such a change would provide clarity to the reader and be justified by the requirements of Paragraph 86 e) of the 2024 NPPF.

2.5.7 To make the Plan sound, the following changes are considered necessary:
● Update Policy S/MO to include additional detail as to the actions that will be undertaken to bring forward sites in circumstances where the monitoring identifies a lack of progress.
● Update the monitoring framework to allow regular and timely progress against job creation and employment floorspace completion to be monitored, including the addition of specific trigger points for intervention measures to be actioned.

2.5.1 TBBD welcome the commitment of Policy S/MO to monitor the implementation of the performance of the Local Plan against the monitoring framework, which includes indicators around job creation and the delivery of new employment floorspace. However, there are issues with the policy as drafted, along with the monitoring framework, set out at Appendix E of the Local Plan, which mean the policy is likely to be ineffective.
2.5.2 The wording of Policy S/MO refers to mechanisms being triggered to ‘review’ allocations, taking ‘action’ to bring forward sites, without any detail as to how this would work in practice, rendering the policy ineffective. We suggest it would be more effective if more specific mechanisms were identified which make it clear what the implication will be if monitoring shows that the Local Plan is not delivering as expected. It is suggested that this could include identifying where there could be policy flexibility and/or setting out timescales within which action will be taken.
2.5.3 Additionally, the monitoring framework at Appendix E lacks sufficient detail to understand when the interventions proposed in Policy S/MO would be triggered. For example, in relation to Policy S/JH (Monitoring Indicator Code M1A), the only trigger is the inability to meet the 73,000 new jobs by the end of the plan period. There are no annualised indicators or intervening targets which would suggest that ongoing monitoring would lead to the need for any intervention.
2.5.4 Equally, for Monitoring Indicator M1B (related to the amount of new employment floorspace created), there is no target set and no trigger for any intervention. It is, therefore, unclear how any underperformance will be identified and when the need for any action to be taken by the Council to address the failings of the Local Plan.
2.5.5 As set out in our representations on the Spatial Strategy, the importance of the monitoring framework would not be as great if the Council had proposed the allocation of additional land to ensure flexibility and contingency in the supply of employment land. However, as drafted, TBBD consider that it is imperative that the monitoring framework is robust to manage the significant risk that the employment market and economic growth potential of the area will be restricted by the under delivery on new employment floorspace.
2.5.6 We therefore suggest that both Policy S/MO and the Monitoring Framework on which it relies, need to be updated to ensure they are effective in supporting the delivery of the Local Plan objectives.

3.1.11 To make the Plan sound, the following changes are considered necessary:
● Update the evidence base to accurately reflect the opportunities and constraints offered by all sites.
● Update the evidence based to provide a clear and comparable assessment of the site options to justify decisions made by the Council.
● Allocate additional land in the A14 corridor to meet the significant additional demand for industrial and warehousing floorspace identified in representations on Policy S/JH.

3.1.1 Chapter 3 of the Local Plan sets out policies for specific site allocations which have been identified to deliver the overall spatial strategy for the area.
3.1.2 TBBD support a number of the conclusions drawn when identifying sites for allocations, as set out in the appendices to the Development Strategy Topic Paper. In relation to sites for industrial and warehousing space, key areas of support include:
● The identification of generally preferred locations for different employment typologies, including the A14 corridor for industrial and warehousing space.
● The conclusion that there is no need to look inside the Green Belt given the availability of suitable sites outside the Green Belt capable of meeting the needs of the area.
● The approach of narrowing sites down from the initial long list based on the suitability (including scale) to meet identified needs and on the basis of not wanting to affect the delivery of new Settlements (specifically Cambourne).
3.1.3 However, we have a number of issues with the conclusions set out in the justification to the selection of sites set out in the Development Strategy Topic Paper (Appendix 7: Review of sites for industrial and warehousing space) and do not believe the selection of sites has been properly justified. The specific concerns relate to the assessment of Land North of A14, J25, Bar Hill (Tritax Park Queens’ Cambridge) (HELAA References 40121 and 40244).
3.1.4 A key determining factor for the Council discounting the Site appears to be that the Site is considered to be a ‘dry island’ with the conclusion that all points of access would require crossing Flood Zones 2 and 3 (Topic Paper Appendix 7, Paragraph 1.11). This conclusion is inaccurate. Whilst the proposed scheme does include an access from the B1050 which does cross Flood Zones 2 and 3, this has been proposed due to this being the optimum access point in highway safety terms. Access could have been taken from the south from the A1307, the same road from which access will be taken for the proposed allocation at Slate Hall Farm and indeed is used as the proposed emergency access point.
3.1.5 Irrespective of this point, the flood risk identified to the east of the Site is ‘in channel’ and can easily be bridged without affecting Flood Zone 2 or 3 in any way. The conclusion on flood risk is, therefore, not justified.
3.1.6 The Topic Paper also indicates that the development of Tritax Park Queens’ Cambridge (HELAA References 40121 and 40244) will have significant negative impacts on the landscape, with a very simple conclusion that large scale buildings will have significant impact on the landscape. We can see no evidence which justifies this conclusion. The Landscape Sensitivity Study (Page 315) assessed the Tritax Park Queens’ Cambridge site in the same study area as Slate Hall Farm, concluding that the area is of medium/low sensitivity to development. Whilst the Slate Hall Farm site includes additional trees and hedgerows which would offer some mitigation to landscape impact if retained, these are not of such significance to logically conclude that they make the site suitable for development whilst considering Tritax Park Queens’ Cambridge would have significant impacts.
3.1.7 We also note that the latest HELAA summaries only have landscape comments on Tritax Park Queens’ Cambridge from 2021, with other sites, including Slate Hall Farm, having additional comments for in 2025 and 2026, suggesting an inconsistent, non-evidential, approach has been taken to drawing the conclusions on landscape.
3.1.8 The Topic Paper conclusions appear to use accessibility by active travel routes as justification for proposing Slate Hall Farm for allocation, despite Tritax Park Queens’ Cambridge having almost exactly the same accessibility characteristics. Indeed, Tritax Park Queens’ Cambridge arguably has more straight forward access arrangements, which would have less impact on the local highway network, but this does not appear to have been considered. This is further contrived by the fact that the land to the south of Cambridge Services, A14 does not benefit from the same level of active travel connections to potential workforces, such as those provided by the proximity of Bar Hill and Northstowe, as it is located further away from the City of Cambridge.
3.1.9 Finally, notwithstanding the concerns raised above, there does not appear to have been any proper comparable, evidence based, assessment of the merits of four potential sites identified as potential allocations. This makes it difficult to understand the overall justification for site selection
3.1.10 Overall, TBBD do not consider that there has been a sufficiently robust assessment of the alternative site assessments, and more evidence is needed to justify the conclusions made.

3.2.4 To make the Plan sound, the following changes are considered necessary:
● Update the evidence base to accurately reflect the opportunities and constraints offered by all sites.
● Allocate additional land in the A14 corridor to meet the significant additional demand for industrial and warehousing floorspace identified in representations on Policy S/JH.
● Allocate Tritax Park Queens’ Cambridge (Land North of A14, J25, Bar Hill) as an alternative or addition to Slate Hall Farm (noting separate representations have been made on the need for an increased supply of employment land).

3.2.1 A noted in our general comments on the site allocations, TBBD support the approach to recognising a need for industrial and warehousing floorspace in the key A14 corridor. However, in terms of the specific site allocations proposed, we have a number of concerns. In relation to Slate Hall Farm, these are:The focus on a single site with the potential to deliver strategic scale footprint buildings.
● The relatively convoluted access arrangements, compared to Tritax Park Queens’ Cambridge, which can deliver direct access to the A14 J25, despite the Council’s conclusions regarding the site being a dry island.
● The promotion arrangements, which cast doubt on delivery (specifically in the short term)
● The location on the edge of the Green Belt, meaning it is potentially more harmful to the purposes of the Green Belt than other alternative sites.
3.2.2 As noted in our comments on the Site Allocations generally we do not consider that a robust, logical and comparable assessment of the alternative sites has been undertaken to justify the selection of the site over other alternatives.
3.2.3 TBBD do not disagree that the site is suitable for development per se, but that insufficient justification and detailed assessment has been undertaken to enable justification for the selection of the site over Tritax Park Queens’ Cambridge (HELAA References 40121 and 40244).

3.3.3 To make the Plan sound, the following changes are considered necessary:
● Update the evidence base to accurately reflect the opportunities and constraints offered by all sites.
● Allocate additional land in the A14 corridor to meet the significant additional demand for industrial and warehousing floorspace identified in representations on policy S/JH.
● Allocate Tritax Park Queens’ Cambridge (Land North of A14, J25, Bar Hill) as an alternative or addition to Land to the south of Cambridge Services, A14 (noting separate representations have been made on the need for an increased supply of employment land).

3.3.1 As noted in our general comments on the site allocations, TBBD support the approach to recognising a need for industrial and warehousing floorspace in the key A14 corridor. However, in terms of the specific site allocations proposed, we have a number of concerns. In relation to Land South of Cambridge Services, these are:No comparable assessment has been undertaken to compare the merits of the site to Tritax Park Queens’ Cambridge (HELAA References 40121 and 40244).
● The site has been selected despite being in a less accessible location than Tritax Park Queens’ Cambridge. The site is more remote to the city, limiting scope for access via active travel routes and limiting the potential for sustainable last mile deliveries (noted as a reason for selecting Slate Hall Farm (Development Strategy Topic Paper, Appendix 7, Paragraph 3.3)).
● The site seems to have only been compared to Brickyard Farm and not Tritax Park Queens’ Cambridge. It is unclear why this approach has been taken.
● The extent of surface water flooding applicable to this site, in addition to the localised requirement for betterment to the Swavesey Internal Drainage Board and historic flood events downstream would likely be a constraint to the extent of development that could be achieved upon this site.
3.3.2 Overall, whilst the site has some site-specific benefits in terms of access to services and facilities, there is no proper justification as to why the site has been selected against the reasonable alternatives.

4.1.8 To make the Plan sound, the following changes are considered necessary:
● TBBD are concerned that there is little to no or evidence as to why these requirements are necessary beyond the national requirements under the relevant regimes or how viable these are across such a range of uses. It is therefore felt that they are not justified as currently worded and should be modified accordingly.

4.1.1 As alluded to elsewhere within our representations, there are several development management policies within the Plan which seek to exceed other consenting regime requirements, thereby adding onerous requirements onto development which is unsound and unjustified.
4.1.2 The NPPF 2026 whilst not the examining plan at Annex A, Paragraph 2 effectively requires a consistency check between Local Plan policies and the National Development Management Policies of the Framework. Where materially inconsistent, Local Plan policies will carry very limited weight, and weight applied to the Framework instead.
4.1.3 Furthermore, Policy PM13 of the 2026 NPPF goes further in respect to Setting Standards, where it is clear that quantitative standards set through development plan policies for design should provide clarity and a high degree of certainty about the requirements that development proposals are expected to meet.
4.1.4 In respect to such standards these policies should be justified, drawing upon relevant evidence of local characteristics and needs and that evidence in support of standards should be proportionate, especially where relevant national standards already exist. More importantly such policies should not cover matters that are already addressed by Building Regulations.
4.1.5 In respect to energy efficiency, standards that go beyond the current or proposed Building Regulations (UK NSCBS & 2020 Energy Use Intensity limits) should have a clear and robustly costed rationale which shows that there will not be an adverse impact on the viability and deliverability of development.
4.1.6 The Council needs to ensure that development management policies are consistent at this stage, and we have found no record of such an exercise being carried out as part of this process, and the transitional arrangement of Annex A, Paragraph 2 would seemingly not apply to these policies as they have not been examined and adopted against the 2026 Framework. Therefore, Policy DM7 of the 2026 Framework would apply where the Council is seeking to exceed matters controlled by other statutory regimes.
4.1.7 Whilst supportive of the premise of many of these conditions, ensuring consistency with other consenting regimes is important for investor confidence; or where standards are exceeded it is clearly evidenced as to why and its viability. This follows on from the concerns we have with the Local Plan evidence base as discussed under the affordable workspace policy (Policy J/AW).

4.1.8 To make the Plan sound, the following changes are considered necessary:
● TBBD are concerned that there is little to no or evidence as to why these requirements are necessary beyond the national requirements under the relevant regimes or how viable these are across such a range of uses. It is therefore felt that they are not justified as currently worded and should be modified accordingly.

4.2.1 As alluded to elsewhere within our representations there are several development management policies within the Plan which seek to exceed other consenting regime requirements, thereby adding onerous requirements onto development which is unsound and unjustified.
4.2.2 The NPPF 2026 whilst not the examining plan at Annex A, Paragraph 2 effectively requires a consistency check between Local Plan policies and the National Development Management Policies of the Framework. Where materially inconsistent, Local Plan policies will carry very limited weight, and weight applied to the Framework instead.
4.2.3 Furthermore, Policy PM13 of the 2026 NPPF goes further in respect to Setting Standards, where it is clear that quantitative standards set through development plan policies for design should provide clarity and a high degree of certainty about the requirements that development proposals are expected to meet.
4.2.4 In respect to such standards these policies should be justified, drawing upon relevant evidence of local characteristics and needs and that evidence in support of standards should be proportionate, especially where relevant national standards already exist. More importantly such policies should not cover matters that are already addressed by Building Regulations.
4.2.5 In respect to energy efficiency, standards that go beyond the current or proposed Building Regulations (UK NSCBS & 2020 Energy Use Intensity limits) should have a clear and robustly costed rationale which shows that there will not be an adverse impact on the viability and deliverability of development.
4.2.6 The Council needs to ensure that development management policies are consistent at this stage, and we have found no record of such an exercise being carried out as part of this process, and the transitional arrangement of Annex A, Paragraph 2 would seemingly not apply to these policies as they have not been examined and adopted against the 2026 Framework. Therefore, Policy DM7 of the 2026 Framework would apply where the Council is seeking to exceed matters controlled by other statutory regimes.
4.2.7 Whilst supportive of the premise of many of these conditions, ensuring consistency with other consenting regimes is important for investor confidence; or where standards are exceeded it is clearly evidenced as to why and its viability. This follows on from the concerns we have with the Local Plan evidence base as discussed under the affordable workspace policy (Policy J/AW).