Greater Cambridge Local Plan: Proposed Submission

5.1.3 Changes suggested to make the plan sound:
● Remove reference at Bullet 2 to major development being required to deliver a 20% net gain in biodiversity.

5.1.1 Policy BG/BG is an example of a policy within the Local Plan which directly conflicts with the 2026 NPPF, largely as a result of the timing of its publication. Specifically, Bullet 2 of Policy BG/BG, which requires major development to deliver a 20% net gain, which directly conflicts with decision making Policy N2 (3) of the new NPPF which sets out that Decision Makers should not give weight to other development plan policies which require biodiversity gains which go beyond the statutory framework which stands at 10% (unless the policy is site specific, which is not the case with the Local Plan). Furthermore, there is no evidence to justify the position taken in this policy and why it is necessary to depart from the national standard.
5.1.2 Therefore, whilst the Local Plan is not being examined against the new NPPF, TBBD suggest it would be prudent to update policies such as Policy BG/BG where there is a clear conflict with the development management policies of the 2026 NPPF to avoid the Local Plan being immediately in conflict.

6.1.3 To make the Plan sound, the following changes are considered necessary:
● The policy should be amended to clearly distinguish between residential and commercial development, ensuring that requirements for community facilities, engagement, and ongoing management are proportionate, evidence-based, and directly related to demonstrable impacts arising from the development, consistent with national planning policy and the statutory tests for planning obligations.

6.1.1 As set out in our Regulation 18 representations, whilst the need to support the delivery of sustainable communities is acknowledged and supported by TBBD, the need for employment developments over 5,000m² to be informed by detailed community needs assessments, stakeholder engagement strategies, and potentially community development measures are disproportionate and not justified by national policy. Such requirements risk placing unreasonable and unclear obligations on commercial schemes, when the key driver to the need for additional services is the growing residential population which is directly linked to the delivery of housing, not commercial floorspace.
6.1.2 The policy lacks clarity on the nature and scope of services and facilities that are expected to be delivered or funded by commercial development, creating unnecessary uncertainty and viability risk. Commercial developments already make appropriate contributions through the potential for future CIL and or Section 106 obligations, where impacts are identified and clearly evidenced.

7.1.9 To make the Plan sound, the following changes are considered necessary:
● Update the policy to provide clarity that Bullet 8 applies to sites outside the defined limits of development and allocations.
● Update the policy to explicitly reference the relationship with Policies S/DS and S/DE.
● Provide clarity as to how unmet need will be demonstrated and whether this is a quantitative or qualitative assessment (or both).
● Remove reference in the policy to meeting national and regional need, with the policy amended to refer to unmet need generally.

7.1.1 TBBD welcome the change from the Regulation 18 version of the Local Plan with the policy (Bullet 8) now allowing for large scale warehousing and distribution facilities to meet national or regional needs. This is an improvement of the Regulation 18 draft which ruled out any such use to meet national needs. The revised policy helpfully aligns better with Policy S5 of the 2026 NPPF which allows development outside settlements where a need can be justified and will be a material consideration in determining applications alongside the Local Plan.
7.1.2 However, we still consider that a number of changes are required to the policy to provide clarity and ensure it will be effective.
7.1.3 The policy should make it clear that it relates to the provision of facilities over and above those planned for in the Local Plan. This can be assumed by reference to unmet need in the policy, but adding reference to sites being outside planned limits of development and allocated sites on the proposal map would provide clarity on this point. The policy should explicitly cross reference to Policies S/DS and S/DE to clarify the relationship between the policies.
7.1.4 There is a need to clarify how unmet need will be defined, either in the policy or the supporting text because, at the moment, it is unclear what an applicant would be expected to provide to justify a need exists either in quantitative or qualitative terms. We would advocate that beyond any evidence of a lack of delivery or a stalling of committed sites, such as allocations, that a market needs assessment setting out interest and requirements from occupiers would be a sensible starting point, outlining the demand and supply dynamics of the commercial market. Given the importance of Greater Cambridgeshire this should not be limited to a local context, but also a national and regional context.
7.1.5 The Local Plan is clear (as set out at Paragraphs 8.17 and 8.18), that the allocations in the Local Plan are to meet local need only (i.e. not regional or national) but, in reality, there is very little a Local Plan can do to prevent the floorspace built on allocated sites being taken up by regional and national operators. Furthermore, as set out elsewhere, notwithstanding our views on the extent of additional local need that is required, the strategic national importance of the A14 for freight and logistics and Greater Cambridgeshire as an economic centre, should and cannot be ignored. This is outlined in the June 2026 Ministerial Statement by Housing and Planning Minister, Matthew Pennycook, in the announcement on the establishment of the Greater Cambridgeshire 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” and “the focus on the delivery of strategic, nationally significant growth in its boundary” (our own emphasis).
7.1.6 In our view, the recent suppression of the warehousing and industrial sector in the area (due to a lack of land supply and the draw on the Cambridge economy) means that there is significant demand from national operators in the area, as demonstrated by DPD taking a pre-let agreement on the Tritax Park Queens’ Cambridge site (HELAA References 40121 and 40244).
7.1.7 If national or regional operators take up floorspace in allocated sites, this will mean that local demands will not be able to be met. Therefore, TBBD consider that rather than the policy specifically referring to meeting national or regional need, it should simply refer to proposals meeting unmet needs for employment floorspace generally, which would ensure it is effective in supporting the objective of delivering sufficient floorspace to meet the needs of the area.
7.1.8 This is emphasised by the significance and strategic importance of the A14 nationally but also the pull and market interest driven by the proximity to Cambridge.

7.2.5 To make the Plan sound, the following changes are considered necessary:
● The policy should be amended to clearly remove the requirement for affordable workspace for B2/B8 uses and if evidenced, should be applied to site specific allocations, where viability tested.

7.2.1 The justification for this policy seems to suggest that the requirement is due to a shortage of affordable workspace for start-up businesses and small and medium-sized enterprises (SMEs) across Greater Cambridge. Furthermore, this issue is more apparent closer to Cambridge City, as tenants are priced out of the market due to high rents and long waiting lists.
7.2.2 The requirement for this policy to bite on B2/B8 uses to meet this policy is completely non-sensical in the context of the extent of supressed need in this sector (particularly B8), given the policy restriction that has been in place since the last adopted Local Plan. The issue for affordable workspace in the B2/B8 sector is primarily driven by the lack of supply and delivery over a significant period of time.
7.2.3 If this policy can be evidenced for the B2/B8 sector, which we strongly believe it cannot, then it should be attributed to site specific allocations and not a blanket policy which may ultimately conflict with other aims and objectives of the Plan in respect of sustainable development.
7.2.4 Such requirements risk placing unreasonable and unclear obligations on commercial schemes within these use classes, which cannot be sustained, particularly given the limitations being planned for in respect to the amount of floor space and flexibility in sites seeking to be allocated. This policy will place an added burden on development that could impact viability and delivery of development.