Greater Cambridge Local Plan: Proposed Submission

To address these concerns and improve NPPF compliance, the following modifications are required:
● remove the requirement for affordable workspace to be secured in perpetuity and replace it with a time-limited or viability-informed approach;
● make affordable workspace provision subject to viability assessment in all circumstances;
● review and increase the proposed 1,000sqm office and R&D threshold;
● introduce greater locational flexibility to reflect differing commercial market conditions across Greater Cambridge;
● undertake further viability testing using realistic market assumptions and testing the policy as drafted;
● undertake a comprehensive cumulative-impact assessment covering all Local Plan obligations and the emerging CIL regime; and
● incorporate review mechanisms so requirements can adapt to changing market conditions over the Plan period.

BRC Ltd object to Policy J/AW. It is not sound as it is not justified.
While the objective of increasing affordable workspace in Greater Cambridge is supported in principle, draft Policy J/AW does not meet the soundness tests in paragraph 36 of the NPPF. It has not been shown to be positively prepared, justified, effective or consistent with national policy and should therefore be substantially revised or deleted.
Although the evidence identifies a need for affordable workspace, it does not justify the policy’s most onerous requirements, including:
● 10% affordable workspace across a broad range of commercial development types;
● rental discounts of up to 30% below market rents;
● affordable provision secured in perpetuity;
● the reduction in the office and R&D threshold from circa 2,500sqm to 1,000sqm; and
● a largely uniform approach across materially different commercial markets.
Furthermore, the Iceni Affordable Workspace Study (2026), which forms part of the Evidence Base, acknowledges that comparable policies vary widely in thresholds, discounts and affordability periods, but does not explain why the Councils have selected one of the most onerous combinations. Reasonable alternatives, including higher thresholds, lower discounts, fixed-term affordability or more flexible viability-led mechanisms, do not appear to have been robustly assessed or discounted.
With regard to Babraham Research Campus, the Policy must recognise that established innovation campuses can already perform the function sought by the affordable workspace requirement as an integral part of their business model. At Babraham, the provision of incubator, start-up and scale-up accommodation is fundamental to the operation of the Campus including the current endeavours associated with Accelerate@Babraham.
The Campus provides an established ecosystem through which early-stage life science businesses can access flexible laboratory and office accommodation, shared facilities, specialist infrastructure and wider business support. The Campus provides a wide range of accommodation, enabling businesses to establish, grow and ultimately ‘graduate’ from incubator and start-up space into larger scale-up and conventional R&D accommodation within the wider Campus.
There is therefore a clear disconnect between the evidence base and the application of the Policy. Despite Babraham already delivering an established affordable workspace model which directly supports the objectives of the Policy, its categorisation as an established science and business park would subject new development to the more onerous 30% discount to market rents. This fails to recognise or give any credit to the significant affordable, incubator and scale-up provision already embedded within the Campus and risks imposing an additional requirement where the intended policy outcomes are already being successfully delivered. Such an approach places undue emphasis on a prescribed rental discount rather than the overall affordability and business support offer, including flexible accommodation, shared infrastructure and specialist support, which enables businesses to establish, grow and graduate onto larger premises.
The evidence does not demonstrate that the affordable workspace obligations can be delivered without prejudicing the viability and delivery of employment development central to the Greater Cambridge economy. The Policy should therefore provide sufficient flexibility for established science and innovation campuses to demonstrate compliance through an existing or proposed campus-wide incubation, start-up and scale-up model where this delivers equivalent or greater benefits for SMEs and early-stage businesses. The focus should be on the outcomes achieved rather than requiring an additional prescribed affordable workspace product where a successful mechanism for supporting business formation and growth is already embedded within the operation of the site.

The Babraham Inset map incorrectly as the annotation for the Strategic Enhancement Area as ‘S/AMC/BRC’. This should be corrected to ‘S/SEA/BRC’. The Strategic Enhancement Area at BRC is a Policy Area not an Area of Major Change

BRC Ltd object to the Greater Cambridge Policies Map (2026) : Babraham Inset Map. It is unsound as it not effective. The Inset map incorrectly as the annotation for the Strategic Enhancement Area as ‘S/AMC/BRC’. This should be corrected to ‘S/SEA/BRC’. The Strategic Enhancement Area at BRC is a Policy Area not an Area of Major Change

The Policy should clarify that the requirement of 3.0 hectares per 1,000 population is intended to be applied on a pro-rata basis to developments accommodating fewer than 1,000 residents. Whilst this appears to be the intention, particularly given the reference to a functional minimum parcel size of 0.5 hectares, this is not expressly stated and should be clarified to ensure consistent application of the Policy.
Furthermore, the policy should be amended to clarify whether the stated open space standards represent a requirement for new/additional open space arising from development, or whether existing accessible open space may contribute towards the required provision. As currently drafted, references to ‘total provision’ and ‘open space provision’ do not distinguish between existing and new provision. This creates uncertainty as to how the standards would be applied, particularly to development within established sites or campuses where significant existing open space may already be available and accessible.
The policy should expressly confirm that existing accessible open space within a development site may count towards the relevant quantitative standards where it is retained and remains available to serve the development. Requiring the standards to be met solely through new provision would risk generating an unjustified additional requirement irrespective of the quantity, quality and accessibility of existing open space already available within a site.
With the above in mind, it must be reiterated that the clear direction of national policy is to support economic growth whilst making effective and efficient use of land. The NPPF (2026) places significant emphasis on building a strong, effective economy and ensuring that planning policies facilitate, rather than unnecessarily constrain, investment and development, alongside the effective use of land. Against this context, the application of a generic quantitative open space standard to commercial development risks losing sight of the fundamental purpose of such development: to deliver employment floorspace, support business growth, create jobs and facilitate innovation.
Policy BG/EO should therefore be reconsidered to allow open space provision to be assessed on a case-by-case basis, adopting a flexible and proportionate approach that recognises the functional requirements of employment uses and aligns with national policy on effective land use, economic growth and plan deliverability.

BRC Ltd object to Policy BG/EO. The Policy is unsound as it is not effective.
The Policy introduces an open space requirement for commercial development. Commercial developments of 2,000 sqm or more Gross Internal Area within Use Classes E(g)(i) and E(g)(ii), together with sui generis research, innovation or institutional campuses, are required to demonstrate open space provision equivalent to 2.0 hectares per 1,000 employees.
As a preliminary point, the Policy does not clarify whether the calculation is intended to be based upon the gross number of employees accommodated by the development or the net increase in employees arising from it. This distinction is important, particularly in the context of development and intensification of an established employment campus. For example assuming that the requirement is intended to apply to gross employment, the outline proposals at Babraham Research Campus provide for approximately 3,000 FTE employees, which would generate a requirement for approximately 6 hectares of open space just for employees.
Whilst Babraham Research Campus benefits from extensive historic parkland and the proposals incorporate generous areas of green open space, a requirement of this scale must be considered in the context of the wider spatial requirements of a mixed-use development. Land must also be accommodated for food growing, children's play, private and communal residential amenity space, sustainable drainage infrastructure, structural and dense planting, access and movement infrastructure, amongst other requirements. Importantly, not all of these areas would necessarily fall within the definition of open space for the purposes of the Policy. This requirement would be combined also with the accessible green space requirements for residential developments.
The Policy should clarify that the requirement of 3.0 hectares per 1,000 population is intended to be applied on a pro-rata basis to developments accommodating fewer than 1,000 residents. Whilst this appears to be the intention, particularly given the reference to a functional minimum parcel size of 0.5 hectares, this is not expressly stated and should be clarified to ensure consistent application of the Policy.
Furthermore, the policy should be amended to clarify whether the stated open space standards represent a requirement for new/additional open space arising from development, or whether existing accessible open space may contribute towards the required provision. As currently drafted, references to ‘total provision’ and ‘open space provision’ do not distinguish between existing and new provision. This creates uncertainty as to how the standards would be applied, particularly to development within established sites or campuses where significant existing open space may already be available and accessible.
The policy should expressly confirm that existing accessible open space within a development site may count towards the relevant quantitative standards where it is retained and remains available to serve the development. Requiring the standards to be met solely through new provision would risk generating an unjustified additional requirement irrespective of the quantity, quality and accessibility of existing open space already available within a site.
With the above in mind, it must be reiterated that the clear direction of national policy is to support economic growth whilst making effective and efficient use of land. The NPPF (2026) places significant emphasis on building a strong, effective economy and ensuring that planning policies facilitate, rather than unnecessarily constrain, investment and development, alongside the effective use of land. Against this context, the application of a generic quantitative open space standard to commercial development risks losing sight of the fundamental purpose of such development: to deliver employment floorspace, support business growth, create jobs and facilitate innovation.
Policy BG/EO should therefore be reconsidered to allow open space provision to be assessed on a case-by-case basis, adopting a flexible and proportionate approach that recognises the functional requirements of employment uses and aligns with national policy on effective land use, economic growth and plan deliverability.

For the reasons provided above, Policy BG/UGF should be substantially revised or deleted from the Plan.

BRC Ltd object to Policy BG/UGF: Urban Greening Factor. The Policy is unsound as it is not effective.
BRC Ltd consider the achievement of 10% BNG secured via the Environment Act (2021) to be an appropriate mechanism by which developments can deliver an appropriate amount of environmental and ecological enhancements. However, BRC Ltd query whether the urban greening factor has been taken into account within the Viability Assessment, with the concern that establishing a new mandatory requirement for a factor of 0.3 for predominantly commercial development and 0.4 for residential development may be both inappropriate and render development unviable (particularly when this is in addition to the other extensive environmental and sustainability requirements set out within the emerging Local Plan).
There are plentiful example Urban Greening policies adopted nationwide which apply the same UGF scores of 0.3 for commercial developments and 0.4 for residential developments as those proposed within Policy BG/UGF. However, importantly, these are expressed as targets, recognising that their achievement will be dependent upon the circumstances and constraints of individual sites. By contrast, the Regulation 19 wording requires the relevant UGF score to ‘at least’ achieve, effectively converting these targets into mandatory minimum requirements and removing flexibility to respond to site-specific considerations.
This concern is compounded by the requirement to demonstrate compliance using the ‘latest version’ of Natural England’s UGF User Guide. This introduces considerable uncertainty, as the methodology against which proposals are assessed could change during the lifetime of the Plan and potentially after development proposals have been formulated. Applicants would therefore have no certainty as to the standard against which future applications will be assessed. At present this additional requirement risks rendering both commercial and residential development unviable and hence we consider the draft policy to be unjustified and inconsistent with national policy.
BRC Ltd also objects to the requirement for outline applications to be supported by a phasing strategy demonstrating that key recreational green spaces and green infrastructure will be delivered ‘early in the programme’ and in advance of, or alongside, the occupation of new homes. This is overly prescriptive and fails to recognise the practical delivery and sequencing requirements of large-scale, mixed-use development.
As with many complex outline schemes, the proposals at Babraham Research Campus comprise an integrated mix of commercial and residential development, with elements of the recreational green space and permanent green infrastructure appropriately delivered as part of the later phases of the wider development. Requiring such provision to be delivered ‘early’, a term which is itself undefined, or in advance of or alongside the occupation of the residential element, could conflict with the logical sequencing of the development and unnecessarily constrain its delivery. The timing of green infrastructure should instead be capable of responding to the agreed phasing and practical delivery of the development as a whole.

Part 6 (a) should be deleted from the policy.

BRC Ltd object to Policy CC/IW. The policy is unsound as it is not justified.
Part 6a of the policy states development must demonstrate that there is capacity for waste water treatment and adequate wastewater conveyancing infrastructure to support the whole development. BRC Ltd does not consider this approach to be sound on the basis that water infrastructure providers have a legal requirement to provide the necessary infrastructure to meet the needs of Greater Cambridge’s current and future population and that it should not be for house builders and other developers to address the failings of water companies to upgrade infrastructure.
When considering water and wastewater capacity it must be recognised that water companies are subject to statutory duties under S37 and 94 of the Water Industry Act 1991 (WIA 1991). Section 37 of the Act, set out below, imposes a statutory duty on all water companies to provide and maintain adequate infrastructure and potable water supplies.
“S37 General duty to maintain water supply system etc. (1) It shall be the duty of every water undertaker to develop and maintain an efficient and economical system of water supply within its area and to ensure that all such arrangements have been made— (a) for providing supplies of water to premises in that area and for making such supplies available to persons who demand them; and (b) for maintaining, improving, and extending the water undertaker’s water mains and other pipes, as are necessary for securing that the undertaker is and continues to be able to meet its obligations under this Part. (2) The duty of a water undertaker under this section shall be enforceable under section 18 above— (a) by the Secretary of State; or (b) with the consent of or in accordance with a general authorisation given by the Secretary of State, by the Director.”
Section 106 of the WIA 1991 confers the power to connect to a public sewer. Section 106(1) states that the owner of any premises or the owner of any private sewer which drains premises, shall be entitled to have its drains or sewer communicate with the public sewer of any sewerage undertaker and therefore discharge foul water and surface water from those premises or that private sewer. Specifically, in relation to wastewater, the Supreme Court considered this matter in 2009 – see Barratt versus Welsh Water [2009] UKSC 13. Paragraph 23 of the decision is salient. Given its importance in the context of wastewater it is recited in full below:
“The right to connect to a public sewer afforded by section 106 of the 1991 Act and its predecessors has been described as an “absolute right”. The sewerage undertaker cannot refuse to permit the connection on the ground that the additional discharge into the system will overload it. The burden of dealing with the consequences of this additional discharge falls directly upon the undertaker and the consequent expense is shared by all who pay sewerage charges to the undertaker. Thus, in Ainley v Kirkheaton Local Board (1891) 60 LJ (Ch) 734 Stirling J held that the exercise of the right of an owner of property to discharge into a public sewer conferred by section 21 of the 1875 Act could not be prevented by the local authority on the ground that the discharge was creating a nuisance. It was for the local authority to ensure that what was discharged into their sewer was freed from all foul matter before it flowed out into any natural watercourse.”
Consequently, it is inappropriate to include a policy in the local plan requiring all development proposals to demonstrate that there is capacity for wastewater treatment and adequate wastewater conveyancing infrastructure to serve the whole development. It is agreed that there must be sufficient water capacity and wastewater infrastructure to serve new development but it is the responsibility of water companies, working with local authorities and the Environment Agency, to plan for the future demand for water services relating to the development requirements proposed in local plans, not applicants. If the water company is unable to support the development needed in Greater Cambridgeshire, this needs to be disclosed in the Water Resource Management Plan.
In terms of wastewater treatment, Paragraph 201 of the National Planning Policy Framework (NPPF) (2024) states that the focus of planning policies and decisions should be on whether proposed development is an acceptable use of land, rather than the control of processes or emissions (where these are subject to separate pollution control regimes). Therefore, whilst the Plan should contain policies aimed at ensuring that wastewater capacity is not put under undue pressure, planning decisions should assume that these regimes will operate effectively. As such, Part 6 (a) should be deleted from the policy.

Part 2 of the Policy should be reworded to promote the retention, reuse and renovation of existing buildings where possible, but remove the detailed justification requirements set out in sub points a-d, allowing development proposals to come forward and demolition justified on their own merit. This would allow embodied carbon to be taken into the planning balance in the same manner in which other material considerations are.

BRC Ltd wish to object to policy CC/CE for the reasons set out below.
Part 1 of the draft policy requires all development proposals to ‘proportionately’ take opportunities to reduce the development’s embodied carbon content. As currently worded the policy is considered too vague and does not set any clear defined parameters or boundaries for schemes to meet. Without clear boundaries, it is unclear if this policy requirement will threaten the viability of development.
Part 2 of the policy requires any proposals that involve demolition to be accompanied by full justification for demolition. This requirement does not reflect the provisions made under The Town and Country Planning (General Permitted Development (England) Order 2015 which under Class B sets out the Permitted Development rights for demolition of a building. Requiring full justification for demolition of a building to be provided would hence be inconsistent with the legislative procedure for building demolition set out within Class B. As currently worded, the draft policy is hence considered unjustified and inconsistent with national policy. Furthermore, the policy fails to adequately recognise the wider benefits that demolition and redevelopment can deliver including regeneration, improved building performance, economic growth, and enhanced sustainability outcomes. As drafted, the policy risks preventing otherwise sustainable and beneficial redevelopment proposals to come forward. The presumption in favour of retention and reuse should therefore be amended to allow greater consideration of site-specific circumstances and the wider benefits of redevelopment.
Furthermore, Part 2(d) requires proposals involving demolition to demonstrate, on an ‘exceptional basis’, significant benefits which outweigh the carbon savings that would arise from the repair or reuse of the existing building. In isolation, this requirement is considered unduly onerous and elevates embodied carbon above other material planning considerations. Whilst the objective of reducing embodied carbon is supported, carbon savings should form part of the wider planning balance rather than operate as a determinative test of whether demolition is acceptable. Existing buildings may remain technically capable of repair or refurbishment whilst nevertheless being functionally obsolete, incapable of meeting modern operational requirements, or materially constraining the efficient use, intensification and future development of a site. Redevelopment may therefore represent the more appropriate planning outcome for a range of legitimate reasons, including the efficient use of land, changing operational requirements, economic growth and the provision of modern R&D floorspace.
The approach is also considered to go beyond the requirements of the NPPF (2026). For the purposes of determining application proposals Policy CC2 (Mitigation of climate change) states substantial weight should be given to the benefits of improving the energy efficiency of existing buildings and the use of renewable carbon sources. CC2 does not, nor does it anywhere else in the NPPF (2026) require that development only be approved where benefits would outweigh the carbon savings. It is hence considered the policy as currently worded is materially inconsistent with NPPF (2026) and would hence only be afforded limited weight in the determination of future applications.

Whilst it is acknowledged the GCLP will be examined against the NPPF (2024), the introduction of PM13 within the NPPF (2026) establishes a clear direction from national government that standards within local plans should not exceed national expectations unless fully evidenced. To ensure the GCLP continues to be consistent with national policy and is positively prepared, it is requested therefore that parts A and B of the Policy are deleted and replaced with a policy that is consistent with the NPPF (2026). BRC Ltd encourages a proportionate, evidence-based approach that reflects realistic delivery stages and aligns with existing standards. Any policies exceeding Building Regulation standards would need to be based on robust and credible evidence including demonstrating their viability in the local development market.

BRC Ltd object to Policy CC/NZ as currently drafted. The Policy is unsound as it is inconsistent with national policy.
Whilst BRC Ltd welcome the ambition to ensure that all buildings help to meet net-zero carbon targets, there needs to be greater flexibility within the policy wording.
The requirement for new development to achieve net zero operational emissions is considered onerous and goes beyond the requirements of the Building Regulations. In addition, the requirement of achieving net zero in all new development has not been given due consideration in terms of viability within the Viability Report and hence threatens to challenge the deliverability of residential development across the Authority Area.
Further, with regards to Part A (Space Heating) the requirement for dwellings to achieve a space heating demand of 15-20kwH per meter squared per year accords with the Climate Change Committees, LETI Net Zero definition and Passivhaus standard, which are higher than other national standards and hence place unrealistic and onerous expectations on developers.
With regard to Part B of the Policy (Total Energy Use Intensity, EUI), the EUI targets are split between uses. For residential dwellings, the targets are set at 35 kWh per meter squared per year which is aligned with LETI Net Zero definition and the National Grid Future Energy Scenarios. The policy once again goes above and beyond national standards.
Reliance on CIBSE TM54 modelling, which is MEP-led, overlaps with energy performance assessments already embedded within Excellent/Outstanding BREEAM requirements under Ene 01. This duplication may reduce certainty without adding meaningful environmental benefit.
Whilst it is acknowledged the GCLP will be examined against the NPPF (2024), the introduction of PM13 within the NPPF (2026) establishes a clear direction from national government that standards within local plans should not exceed national expectations unless fully evidenced.
To ensure the GCLP continues to be consistent with national policy and is positively prepared, it is requested therefore that parts A and B of the Policy are deleted and replaced with a policy that is consistent with the NPPF (2026). BRC Ltd encourages a proportionate, evidence-based approach that reflects realistic delivery stages and aligns with existing standards. Any policies exceeding Building Regulation standards would need to be based on robust and credible evidence including demonstrating their viability in the local development market.

The requirement at Part (d) for full-building mechanical ventilation and cooling to be considered only after ‘all other elements of the hierarchy have been utilised’ is therefore considered unnecessarily prescriptive and could constrain the appropriate design and operation of specialist R&D development. The policy should recognise that the cooling hierarchy is not capable of being applied uniformly across all development types and should instead allow measures higher within the hierarchy to be considered and incorporated where compatible with the operational requirements of the proposed use. Point (d) should therefore be amended to provide this flexibility, ensuring that the policy continues to secure climate-responsive development without compromising the functionality or delivery of specialist R&D and laboratory floorspace.
With regards to the inclusion of ‘albedo’ (2(a)[i]), it is requested this must be quantified to avoid ambiguity and inconsistency when preparing applications for development proposals. Without quantification the inclusion of ‘albedo’ should be removed from the policy to avoid introducing an unnecessary and undefined requirement for applicants to adhere to.
Furthermore, point 2(a)[iii] is considered too loosely worded with no clear definition of the requirements to ‘minimise internal heat generation’. Without quantifying a requirement, the draft policy risks being redundant and not providing clear guidance on the expectations of the Council with regards to internal heat generation. As currently worded the draft policy is not considered to be effective or justified and risks being ambiguous and ineffective.

BRC Ltd object to Policy CC/DC: Designing for a changing climate. The policy is unsound as it not effective.
Whilst the principle of minimising overheating and reducing reliance on energy-intensive cooling is supported, concern is raised that the policy does not adequately recognise the specialist operational requirements associated with R&D and laboratory uses such as those existing and proposed at Babraham Research Campus.
Such buildings can have fundamentally different requirements to conventional office or residential development, including controlled internal environments, specialist ventilation and air-handling requirements, significant internal heat loads arising from equipment, and particular security and contamination-control requirements. As a result, measures identified within the cooling hierarchy, including natural ventilation, night-time purge ventilation and particular glazing arrangements, may not always be technically appropriate or compatible with the intended operation of an R&D building. Equally, mechanical ventilation and cooling may be an integral operational requirement rather than simply a design choice, which under CC/DC can only be considered once passive alternatives have been exhausted.
The requirement at Part (d) for full-building mechanical ventilation and cooling to be considered only after ‘all other elements of the hierarchy have been utilised’ is therefore considered unnecessarily prescriptive and could constrain the appropriate design and operation of specialist R&D development. The policy should recognise that the cooling hierarchy is not capable of being applied uniformly across all development types and should instead allow measures higher within the hierarchy to be considered and incorporated where compatible with the operational requirements of the proposed use. Point (d) should therefore be amended to provide this flexibility, ensuring that the policy continues to secure climate-responsive development without compromising the functionality or delivery of specialist R&D and laboratory floorspace.
With regards to the inclusion of ‘albedo’ (2(a)[i]), it is requested this must be quantified to avoid ambiguity and inconsistency when preparing applications for development proposals. Without quantification the inclusion of ‘albedo’ should be removed from the policy to avoid introducing an unnecessary and undefined requirement for applicants to adhere to.
Furthermore, point 2(a)[iii] is considered too loosely worded with no clear definition of the requirements to ‘minimise internal heat generation’. Without quantifying a requirement, the draft policy risks being redundant and not providing clear guidance on the expectations of the Council with regards to internal heat generation. As currently worded the draft policy is not considered to be effective or justified and risks being ambiguous and ineffective.

In order to overcome the issues highlighted in this representation and progress a sound Local Plan, it will be necessary to utilise more optimistic and realistic figures for job and housing numbers and include explicit support for higher-growth scenarios. Without these changes, Policy S/JH risks being unsound and inconsistent with national policy objectives to support sustainable economic growth and productivity.

BRC Ltd object to Policy S/JH: New Jobs and Homes. The policy is unsound as it is not positively prepared, not justified, not effective and inconsistent with national policy.
In terms of the policy context, paragraph 69 of the NPPF (2024) is clear that Authorities need to plan for higher levels of growth than the Standard Method requirement to reflect growth ambitions linked to economic development and infrastructure investment. Furthermore, paragraph 86(d) of the NPPF (2024) confirms that planning policies should seek to address potential barriers to investment, such as inadequate infrastructure, services or housing, or a poor environment. The draft Plan does not do this.
This need for growth is evidenced by national, regional and authority level investment in infrastructure including the new Cambridge South Railway Station providing direct connectivity between Cambridge Biomedical Campus (CBC) and London, the granting of the Cambourne to Cambridge busway and progression of Cambridge South East Transport (CSET) to inquiry later this year. In a national context, the commitment to East West Rail establishes the area as one benefiting from continued investment in major transport infrastructure. Growth envisioned by Government is set to be realised and delivered by the Greater Cambridge Development Corporation set to deliver infrastructure first growth. We contend in order to ensure the Plan is found sound the unique nature of Cambridge and its projected capacity for growth must be realised within the emerging Local Plan.
The fact that the GCLP is not planning for the level of growth necessary to support the economic ambitions of the Local Growth Plan, which align with the economic objectives of the government is underlined by the fact that the Employment and Housing Needs Update (EHNU) (2026) does not even consider the Oxford Cambridge Arc or the Local Growth Plan. Instead, it has been developed on the basis of standard economic forecasts which are inevitably trend-based and so do not account for economic potential of the area as is necessary to align with local and national economic ambitions. The EHNU draws its conclusions and jobs and housing needs from the ‘central growth’ scenario with the ‘higher growth scenario’ dismissed. However, it is noted the EHNU notes that the higher scenario could be achieved with step change in investment.
Rightly the EHNU draws a relationship between job growth and housing need, on the basis that greater job growth in the region will generate a derived demand for housing, creating an interdependency between the two. The ‘central growth scenario,’ as outlined within the EHNU, builds in assumptions of slower periods of growth, contractions, and economic shocks. Inherently both the number of jobs and homes proposed within the Proposed Submission Plan are conservative rather than reflective of the full growth potential of the Greater Cambridge economy.
With the advent of the Greater Cambridge Development Corporation (backed by £400 million of central government funding) and renewed commitment to delivery of growth in the Oxford – Cambridge Growth Corridor there is clear rationale for the Authority to reasonably adopt the high growth scenario. Furthermore whilst the Authority have met their identified needs for housing via the Standard Method it is acknowledged the Standard Method does not take into account the specific growth agenda and focus on Cambridge as an area of ‘supercharged growth’.
It is evident that committed and future infrastructure projects in Greater Cambridge continue to confirm Cambridge’s position as an area capable of supporting and delivering high growth. Within this context Cambridge remains a priority of the incumbent Labour government to deliver ‘supercharged growth’. The Employment and Housing Needs Update acknowledges a ‘High’ and ‘High Sensitivity’ scenario, whereby growth would meet or exceed the 2010–2020 trajectory. This high level of growth is feasible in Cambridge and would support the Government’s direction of travel. It is therefore important to recognise that higher-growth outcomes remain credible and should not be ruled out by policy. This requires revision to the proposed policy wording.
We also note the Regulation 18 version of the emerging Local Plan required 2,463 dwellings per annum to deliver employment growth of 66,000 jobs compared to the Regulation 19 version which required delivery of 2,292 dwellings per annum to deliver 73,200 jobs across the plan period; representing a decrease in housing delivery whilst reflecting an increase in job creation. The EHNU reasons this in stating the fact that average household sizes are now larger, leading to an increase in people of working age and more in-commuting which reduces the number of local people required to fill jobs created. We raise concern this is an unsustainable approach to development strategy and reflects a local housing market where many young people are unable to move out of their family homes and move closer to or within Cambridge where jobs are located at key existing and development employment centres such as CB1, Cambridge Biomedical Campus and Cambridge Science Park. We advocate the Plan needs to address the affordability of housing within Greater Cambridge by planning for increased growth and supply to reflect growing demand rather than embed the issue of increasing household size.
In doing so and making provision for increased housing stock in Greater Cambridge in sustainable locations would ensure the Local Plan promotes more suitable patterns of travel as required by paragraph 111 of the NPPF (2024) using planning polices to minimise the length of and journeys required for employment.
In order to overcome the issues highlighted in this representation and progress a sound Local Plan, it will be necessary to utilise more optimistic and realistic figures for job and housing numbers and include explicit support for higher-growth scenarios. Without these changes, Policy S/JH risks being unsound and inconsistent with national policy objectives to support sustainable economic growth and productivity.

Point ii should be amended as per the wording below:
ii. Babraham Research Campus - an employment-led mixed use allocation to support further growth of this existing world leading bioscience research and innovation campus and improve the health and wellbeing of future employees, residents and the local community through targeted environmental enhancements: including approximately 48,000 square metres employment floorspace for office and research & development 83 additional homes supported by focused additional facilities that complement existing local services;

BRC Ltd object to policy S/DS: Development Strategy. The policy is unsound as it is not justified.
Whilst BRC Ltd broadly support Policy S/DS in terms of the identification of Babraham Research Campus as a new employment, mixed-use allocation in the Rural Southern Cluster, they do have minor observations on the policy wording at part d (ii) as outlined below.
ii. Babraham Research Campus - an employment-led mixed use allocation to support further growth of this existing world leading bioscience research and innovation campus and improve the health and wellbeing of future employees, residents and the local community through targeted environmental enhancements: including approximately 48,000 square metres employment floorspace for office and research & development 83 additional homes supported by focused additional facilities that complement existing local services;
The above changes are once more required to ensure the Plan is clearly written as per the requirements in NPPF Paragraph 16 (d) (2024) and to reflect the agreed approach with officers at Greater Cambridge Shared Planning Service (‘GCSPS’) in respect of the current outline planning application pending determination (LPA Ref. 26/04634/OUT) and the numbers included in the site-specific policy S/BRC.
BRC Ltd also objects to the new wording requiring the additional homes to be ‘all to be delivered within the plan period’ and proposed that this requirement should be deleted. It is unnecessary and inconsistent with the structure of Policy S/DS, which already establishes the appropriate mechanism for considering the timing of housing delivery. Paragraph 4 of Policy S/DS states that ‘Delivery across the plan period is set out in the housing trajectory included in Appendix D.’ The Plan therefore draws a clear distinction between identifying land as suitable for allocation and determining, through the trajectory, the expected timing and quantum of delivery over the plan period.
Including an additional policy requirement that all additional homes must be completed within the plan period cuts across that approach. The housing trajectory is the evidence-based tool identified by the Plan itself for assessing delivery, taking account of relevant matters such as lead-in times, planning status, infrastructure requirements, reserved matters or subsequent approvals and anticipated build-out rates. Those matters may change over time and are properly assessed through the trajectory and monitoring process, not fixed as an inflexible requirement within the site allocation wording.
The requirement is also not applied consistently. Other site allocations within the ‘Rest of the Rural Area’ are not subject to an equivalent requirement that their housing component must be delivered in full within the plan period. No justification is provided for imposing this additional constraint on Babraham Research Campus.