Greater Cambridge Local Plan: Proposed Submission

This objection cuts across the Plan and goes to the heart of Policy I/ID. Depending upon the outcome of the further work on viability which WGCL suggests is necessary to
be confident in delivery, multiple policies that impact upon viability or require specification of contributions may need to be amended to acknowledge that all policy ambitions cannot be met on all sites. WGCL has not objected to every Policy where this might apply. Instead, WGCL presents an overarching concern here in relation to the
primary delivery policy. It may be that a more informed position in relation to delivery can be addressed under this Policy alone, as long as other policies make suitable cross
reference.

WGCL requests that careful consideration is given to the cumulative impact of policies across the Plan on development costs and the infrastructure need in relation to specific allocations. WGCL fail to see how this Policy can be regarded as sound without either:

• Having a definitive and detailed plan for infrastructure delivery, including
transport, based upon firm evidence; or
• being directly and explicitly honest about the competing priorities for funding and
investment, and the need to balance those priorities, setting parameters for what
can and should be delivered through CIL and Section 106.

As a general point, while WGCL recognises the time constraints upon production of this version of the Plan, the lack of cross reference from the Policies to the supporting
specific evidence base (the totality of which is overwhelming in scale, has made it extremely difficult to identify and establish on what basis individual Policies are justified. Determining that Policies are reasonable and effective now and going forward is greatly compromised. In making modification this essential information should be added to the supporting text to all policies.

These representations are made on behalf of Wellcome Genome Campus Limited (WGCL). WGCL is the Wellcome owner-developer-operator charged with leading the Wellcome Genome Campus and delivering its ongoing transformation and expansion as a globally significant science ecosystem and community. This ambition is intrinsic to both the substantial scale of development now underway on the ‘expansion land’, to the east of the A1301, and in priority WGCL is now directing towards modernising the existing Campus, west of the A1301. WGCL’s vision is to bring these areas together as
an open, diverse and connected place that puts people first, supports collaboration and innovation using digital technology and delivers a shift to active travel. WGCL is evolving the Campus from a closed, gated workplace into a place and destination. Increasingly, the Campus will have the characteristics of a small town, one with a clear purpose derived from its science mission. The Local Plan represents an opportunity to guide this change and secure wide benefits.

WGCL want to assert the important role of the expanding Campus and the part it can play in the growth and success of Cambridge, as a location for life sciences of national and global significance. Realising this potential is dependent upon achieving an effective and sustainable movement network across the communities and investment locations within the Southern Cluster, and integrated back into the City.

WGCL is working hard to:

• externalise and promote the activity which underpins the work undertaken
at the Campus and ensure this vital activity can be sustained;
• accelerate the benefits arising amongst common interests within the Southern Cluster; and
• open up the Campus to the wider community.

With Policy support, the enormous investment that has underpinned the operation of the Campus to date, and that which is planned, could yield far greater economic and social benefit while furthering the science mission.

WGCL is greatly encouraged by the recent response of officers and members to its ambitious proposals, and efforts to evolve the Local Plan Policy to facilitate next steps and embody flexibility to allow the Campus to change and adapt over the period ahead. Good progress has been made between the Regulation 18 and Regulation 19 versions of the Plan in this regard. There was insufficient progress at Regulation 18 to fully
engage with and consider the implications of the wider Plan Policies, in terms of cumulative demands, infrastructure needs, viability and delivery. These are now central to the question of soundness and this further representation on behalf of WGCL.

There are three principal elements to this Regulation 19 submission:

1. The Wellcome Genome Campus Policies are now, for the most part, well formed to provide the basis for decision making in relation to both continued implementation of the extant planning permissions for expansion and to evolve the existing Campus over time. There are a number of
relatively minor modifications that would ensure the Policy is as clear and effective as it needs to be. WGCL is hopeful that these can be resolved through further engagement with officers in advance of Examination.

2. Creating the conditions necessary to realise the investment potential enshrined in the Wellcome Genome Campus Policies requires that the Local Plan is aspirational but is also deliverable. For WGCL, focused upon delivery at Wellcome Genome Campus, the Local Plan is more than a development management tool. The Plan needs to be a positive signal to investors, underpinning, not detracting from the competitive advantage of the location. As it stands, the forward plan for infrastructure delivery that underpins the Plan is uncertain and incomplete. Certainty around strategic
transport infrastructure is WGCL’s greatest concern. Without commitment on this front, the Local Plan signals a high level of risk to investors.

3. The challenges around infrastructure investment layer into a multitude of onerous and costly policy obligations across the Plan, the cumulative impact of which in any specific location (especially where the transport
infrastructure deficit is considerable) is not tested, or is masked by a broad, whole plan viability assessment. WGCL is not convinced that the deliverability of the Plan is sufficiently secure.

In these representations, ‘The Wellcome Genome Campus’ or ‘Campus’ refers to the full extent of the WGCL interest, including both the existing Campus, associated
parkland and wetlands, and the expansion land to the east of the A1301.

The Greater Cambridge Local Plan succeeds in articulating a positive vision and ambition for a substantial scale of growth. It also identifies the significant infrastructure challenges that already exist across the City and South Cambridgeshire, and the degree which those challenges multiply with any additional plans for development, over and above that already committed, but not yet implemented.

The principal issue is not whether growth should occur, but whether the infrastructure, funding mechanisms and delivery arrangements necessary to support that growth have been demonstrated with sufficient certainty to satisfy the tests of soundness.

The Plan also demands that every development proposal meets high expectation and stretched targets for sustainability, design, greening, BNG, community infrastructure and a wide range of community and housing needs, including affordable housing and affordable employment space. It is not apparent in the evidence base that the full cumulative burden of these policy demands, and infrastructure requirements has been
fully assessed, either broadly or in relation to policy areas and allocations. Where there is sensitivity testing through site appraisals within the viability evidence, there is no
evidence of regard for the site-specific constraints or testing of the assumed capacity of the sites. The Urban Greening requirement appears not to have been factored into the viability testing at all, in terms of potential impact upon developable area across larger, mixed-use sites, in combination with other land use budget considerations.

Cumulatively, the cost burden of these Policy demands upon development is unprecedented in this locality and adds to spiralling build costs. There has been significant build cost inflation over the last couple of years, and more is expected over the period ahead. Meanwhile, rents and values have remained largely static or are now subject to downward pressure.

A ‘whole plan’ approach to viability (and a simple per unit apportionment of anticipated Section 106 costs) is potentially a valid approach across a plan area reliant on many smaller and medium sized allocations and where any individual proposal is unlikely to be critical to the Development Strategy, or greatly dependent upon shared, strategic infrastructure. That is not the case in Greater Cambridge. Large sites and new communities are critical to the Development Strategy and to unlocking (majority funding) the infrastructure upon which there is wide dependency, especially where interconnected priority and opportunity exist, as across the Southern Cluster.

The absence of clarity on transport infrastructure is the principal concern. Furthermore, the reliance upon large sites, many of which are already subject to Outline Planning Permission, involving phased development and a monitor and manage approach to delivery, requires a level of further site-specific scrutiny. They remain a priority for
infrastructure investment. A simple assumption that permission assures delivery and the infrastructure commitment is fully understood and funded, is not the case.

CIL presents opportunity to better address strategic transport needs, but the approach to assigning CIL, forward funding in anticipation of CIL collection and how it combines with Section 106 Contributions and other funding streams, is not yet clear or even explored in
the Infrastructure Delivery Plan.

Sustainable accessibility and connectivity across the Southern Cluster is the single biggest priority and concern for WGCL. Securing an effective, integrated transport
network requires more than a shopping list of potential interventions in a broad Transport Strategy (which at present is not even in final form). It needs to be translated into a meaningful delivery programme, bedded into the Local Plan, with scope, costs, funding, timing and actions understood. The transport position presented in the IDP provides no evidence to demonstrate the transport interventions needed can and will be secured. Identified schemes are not scoped or costed or even directly related to the policy proposals. The NPPF (2024) paragraph 35 is clear ‘Plans should set out the contributions expected from development’ and policies that demand contributions
‘should not undermine the deliverability of the plan. This is only possible if the full infrastructure costs are understood; the cumulative impact of policy demands is properly accounted for a site level.

WGCL are looking to the Local Plan and Transport Strategy to direct effective, collaborative and urgent action to set priorities and assemble credible, fundable
transport solutions. WGCL is engaging directly with the Combined Authority on the emerging Greater Cambridge Transport Strategy in respect of the transport commitments necessary to realise investment plans at the Wellcome Genome Campus. Should this engagement not yield a positive outcome in the final version of the
emerging Transport Strategy, WGCL will seek opportunity to expand upon these representations in relation to transport, in anticipation of the Examination.
The viability position presented does not acknowledge the limitations of the Infrastructure Delivery Plan or work that is incomplete. And yet it is concluded that the
Plan, as a whole, is deliverable. This seems a very premature conclusion given the absence of essential information.

Only at page 761 of the Local Plan does the delivery challenge surface. It is implicit in all the preceding pages that the Local Plan allocations are deliverable, meeting all, full policy expectations and fully cognisant of infrastructure requirements and build costs. This is misleading; it is not founded upon the evidence as it stands or indeed real
experience of delivering large, complex development schemes across Cambridgeshire.

Only under Policy I/ID is the scope for site specific viability acknowledged and this is without recognition that the infrastructure burden alone will virtually always necessitate
negotiation of priorities on large schemes, very often because of the transport mitigation ask. The Policy places the burden of proof entirely upon the developer, when it is
entirely appropriate that the developer should be satisfied that major Local Plan Allocations are intrinsically viable and deliverable. If this approach succeeds, the need
to balance and prioritise will only be revealed when a planning application is made. This means the developer bears to the full brunt of objection, having ‘failed’ against policy expectation. Communities have unrealistic expectations and are likely to be disappointed. This does nothing to build confidence, trust and support for the Plan or subsequent allocations. It may well deter beneficial investment.

The longer term opportunity at the Wellcome Genome Campus is to be the subject of a new master planning exercise and WGCL hope that can provide the forum in which to resolve priorities and shape an unencumbered, deliverable set of proposals. Investment will be frustrated if every stage of the planning process is embroiled in protracted negotiation over viability.

A good deal more work needs to be done to properly understand the cumulative impact of infrastructure and policy requirements and then forward plan for delivery, most particularly in relation to infrastructure.

WGCL request that the Wellcome Genome Campus is removed from the list of locations to which this policy applies.

In addition, as a general point, the Policy is not entirely clear in terms of distinguishing between different needs. Part 3 appears to relate to any provision (either 1 or 2 above), so blurs ‘need’ across different uses and might be interpreted as providing opportunity for proposals for R&D to provide space for creative industries or for R&D space needs to be integrated into a creative/cultural offer. This is, evidently, not practical in most locations. Further clarity and distinction would be helpful.

These representations are made on behalf of Wellcome Genome Campus Limited (WGCL). WGCL is the Wellcome owner-developer-operator charged with leading the Wellcome Genome Campus and delivering its ongoing transformation and expansion as a globally significant science ecosystem and community. This ambition is intrinsic to both the substantial scale of development now underway on the ‘expansion land’, to the east of the A1301, and in priority WGCL is now directing towards modernising the existing Campus, west of the A1301. WGCL’s vision is to bring these areas together as
an open, diverse and connected place that puts people first, supports collaboration and innovation using digital technology and delivers a shift to active travel. WGCL is evolving the Campus from a closed, gated workplace into a place and destination. Increasingly, the Campus will have the characteristics of a small town, one with a clear purpose derived from its science mission. The Local Plan represents an opportunity to guide this
change and secure wide benefits.

WGCL want to assert the important role of the expanding Campus and the part it can play in the growth and success of Cambridge, as a location for life sciences of national and global significance. Realising this potential is dependent upon achieving an effective and sustainable movement network across the communities and investment locations within the Southern Cluster, and integrated back into the City.

WGCL is working hard to:

• externalise and promote the activity which underpins the work undertaken at the Campus and ensure this vital activity can be sustained;
• accelerate the benefits arising amongst common interests within the Southern Cluster; and
• open up the Campus to the wider community.

With Policy support, the enormous investment that has underpinned the operation of the Campus to date, and that which is planned, could yield far greater economic and social benefit while furthering the science mission.

WGCL is greatly encouraged by the recent response of officers and members to its ambitious proposals, and efforts to evolve the Local Plan Policy to facilitate next steps and embody flexibility to allow the Campus to change and adapt over the period ahead. Good progress has been made between the Regulation 18 and Regulation 19 versions of the Plan in this regard. There was insufficient progress at Regulation 18 to fully
engage with and consider the implications of the wider Plan Policies, in terms of cumulative demands, infrastructure needs, viability and delivery. These are now central to the question of soundness and this further representation on behalf of WGCL.

There are three principal elements to this Regulation 19 submission:
1. The Wellcome Genome Campus Policies are now, for the most part, well formed to provide the basis for decision making in relation to both continued implementation of the extant planning permissions for expansion and to evolve the existing Campus over time. There are a number of
relatively minor modifications that would ensure the Policy is as clear and effective as it needs to be. WGCL is hopeful that these can be resolved through further engagement with officers in advance of Examination.

2. Creating the conditions necessary to realise the investment potential enshrined in the Wellcome Genome Campus Policies requires that the Local Plan is aspirational but is also deliverable. For WGCL, focused upon delivery at Wellcome Genome Campus, the Local Plan is more than a development management tool. The Plan needs to be a positive signal to investors, underpinning, not detracting from the competitive advantage of the location. As it stands, the forward plan for infrastructure delivery that underpins the Plan is uncertain and incomplete. Certainty around strategic
transport infrastructure is WGCL’s greatest concern. Without commitment on this front, the Local Plan signals a high level of risk to investors.

3. The challenges around infrastructure investment layer into a multitude of onerous and costly policy obligations across the Plan, the cumulative impact of which in any specific location (especially where the transport
infrastructure deficit is considerable) is not tested, or is masked by a broad, whole plan viability assessment. WGCL is not convinced that the deliverability of the Plan is sufficiently secure.

In these representations, ‘The Wellcome Genome Campus’ or ‘Campus’ refers to the full extent of the WGCL interest, including both the existing Campus, associated
parkland and wetlands, and the expansion land to the east of the A1301. WGCL has not elected to make individual representations on all the policies of the Plan which individually, and cumulatively, reflect a significant challenge to the viability of new development. WGCL’s position on the cumulative burden of these policies is set out in the representation in respect of Policy I/ID. The exception to this approach (an overarching representation) is in relation to this policy.

As one of a handful of developers currently tackling the challenges of delivering new R&D floorspace on one of the Cambridge Science Parks, WGCL is compelled to input on this Policy. It may seem relatively innocuous on the face of it, and in isolation, but it is burdensome in the extreme given the specific circumstances on the Wellcome
Genome Campus and the potential, cumulative position highlighted in the representation on Policy I/ID. WGCL underline a lack of faith in the high-level appraisal of viability across the Plan and CIL.

Nowhere in the evidence supporting the Plan is the case made for significant market failure in the science sector necessitating this burden upon those owning, providing and managing R&D employment space. To consider applying this Policy to the science parks, evidence needs to be assembled that points to the need for "cheap" space being a primary issue frustrating innovation and growth. WGCL are unaware of any such evidence.

There is plenty of competitive provision in and around Cambridge for newer/smaller companies in the sector, including the new BioLabs offer being delivered by WGCL. Downward pressure on rents is opening up lots of opportunity for good value space and incentivised deals. In WGCL’s recent experience, it is the wrap-around
support and services, much more than rental levels, which is the more likely determinant of occupier interest. Start-ups and scale-ups will expect to share the cost of the things they need, for example lab/science operations, access to expensive equipment they can share (but could not afford themselves), access to low-volume consumables, finance and commercial support. They want access to fundraising advice, mentoring, venture
capitalists, angel investors and potential non-executive directors and advisors. These services and networks tend to come from full-service incubator and accelerator models, not discounted rental space where providers are then constrained to invest. Such a simplistic view of how best to facilitate investment in the science sector is potentially harmful; such a significant discount on rental across a sizable proportion of the offer may result in the more important wrap-around provision being diminished.

It is also unclear how the discounts have been arrived at and what the assumptions are underpinning the approach broadly, or in relation to individual and established
locations. There is no indication that any regard has been had to wider site context, not least where there is already a lot of space occupied on a ‘non-commercial’ basis,
supporting innovation and research. At the Wellcome Genome Campus there is 850,000 sq ft of space already owned by charitable and public institutions, on long
leases. New space now being brought forward is to help commercial entities cluster and partner with these 'host' institutions and establish a sustainable business model for the Campus as a whole. The Campus cannot sustain any further subsidy to occupiers.

If a Policy of this sort is to be entertained, it needs to be far more sophisticated in terms of application, informed by full engagement with space providers in the relevant sectors to which it is applied. Baking-in discount and placing time limits on the discount is essential. In the science sector ‘in perpetuity’ provisions are likely to discourage progression into more 'mature' floorspace and may disadvantage the owner/investor, while the occupier flourishes. The burden then falls upon the owner to manage and direct occupation to avoid subsidising those who no longer need it. Occupiers in this sector are not easily relocated without significant fit-out cost, giving rise to further cost burden on the owner. The Policy will hinder the dynamism within the sector.

More widely, there is no necessity for the Council to operate and manage space, the market should be allowed to respond and innovate to meet the need for space at
different price points, acknowledging that so often repurposed space, not new build space, unlocks far greater potential for affordable workspace. The risk here is stifling innovation in business models and creating a closed shop of providers, counter to the wider interests of owner and providers, harming viability and reducing income being channelled into provision of new space and meeting occupier needs.

WGCL acknowledge that there is some recognition in the supporting text to the Policy that fit-out costs associated with R&D may justify a reduced discount on grounds of viability, but in circumstances where there is clearly no reasonable basis to demand a discount in the first place, given the site specific considerations, the burden of costly and convoluted viability discussions, should not fall upon the developer, simply because the Policy fails to appropriately address the circumstances when it may be reasonable to apply it.

WGCL’s suggested amendment to the wording of Policy S/AMC is as followis (these are outlined in the attachment with additions in black, bold type; explanations and comments in square brackets)

These representations are made on behalf of Wellcome Genome Campus Limited (WGCL). WGCL is the Wellcome owner-developer-operator charged with leading the Wellcome Genome Campus and delivering its ongoing transformation and expansion as a globally significant science ecosystem and community. This ambition is intrinsic to both the substantial scale of development now underway on the ‘expansion land’, to the east of the A1301, and in priority WGCL is now directing towards modernising the existing Campus, west of the A1301. WGCL’s vision is to bring these areas together as an open, diverse and connected place that puts people first, supports collaboration and innovation using digital technology and delivers a shift to active travel. WGCL is evolving the Campus from a closed, gated workplace into a place and destination. Increasingly, the Campus will have the characteristics of a small town, one with a clear purpose derived from its science mission. The Local Plan represents an opportunity to guide this change and secure wide benefits.

WGCL want to assert the important role of the expanding Campus and the part it can play in the growth and success of Cambridge, as a location for life sciences of national and global significance. Realising this potential is dependent upon achieving an effective and sustainable movement network across the communities and investment locations within the Southern Cluster, and integrated back into the City.

WGCL is working hard to:

• externalise and promote the activity which underpins the work undertaken at the Campus and ensure this vital activity can be sustained;
• accelerate the benefits arising amongst common interests within the Southern Cluster; and
• open up the Campus to the wider community.

With Policy support, the enormous investment that has underpinned the operation of the Campus to date, and that which is planned, could yield far greater economic and social benefit while furthering the science mission.

WGCL is greatly encouraged by the recent response of officers and members to its ambitious proposals, and efforts to evolve the Local Plan Policy to facilitate next steps and embody flexibility to allow the Campus to change and adapt over the period ahead. Good progress has been made between the Regulation 18 and Regulation 19 versions of the Plan in this regard. There was insufficient progress at Regulation 18 to fully engage with and consider the implications of the wider Plan Policies, in terms of cumulative demands, infrastructure needs, viability and delivery. These are now central
to the question of soundness and this further representation on behalf of WGCL.

There are three principal elements to this Regulation 19 submission:

1. The Wellcome Genome Campus Policies are now, for the most part, well formed to provide the basis for decision making in relation to both continued implementation of the extant planning permissions for expansion and to evolve the existing Campus over time. There are a number of
relatively minor modifications that would ensure the Policy is as clear and effective as it needs to be. WGCL is hopeful that these can be resolved through further engagement with officers in advance of Examination.

2. Creating the conditions necessary to realise the investment potential enshrined in the Wellcome Genome Campus Policies requires that the Local Plan is aspirational but is also deliverable. For WGCL, focused upon delivery at Wellcome Genome Campus, the Local Plan is more than a development management tool. The Plan needs to be a positive signal to investors, underpinning, not detracting from the competitive advantage of the location. As it stands, the forward plan for infrastructure delivery that underpins the Plan is uncertain and incomplete. Certainty around strategic
transport infrastructure is WGCL’s greatest concern. Without commitment on this front, the Local Plan signals a high level of risk to investors.

3. The challenges around infrastructure investment layer into a multitude of onerous and costly policy obligations across the Plan, the cumulative impact of which in any specific location (especially where the transport
infrastructure deficit is considerable) is not tested, or is masked by a broad, whole plan viability assessment. WGCL is not convinced that the deliverability of the Plan is sufficiently secure.

In these representations, ‘The Wellcome Genome Campus’ or ‘Campus’ refers to the full extent of the WGCL interest, including both the existing Campus, associated
parkland and wetlands, and the expansion land to the east of the A1301.

WGCL recognises that there is merit in two policies to address the potential at the Wellcome Genome Campus. This responds positively to representations made by
WGCL on the Regulation 18 consultation plan, seeking distinction and clarity with regard to what is already consented and being delivered and what is in prospect, but less well defined. It does however present some challenges in navigating between the policies and the related Plans. Some further modifications are necessary to remove inconsistencies, achieve clarity and ensure policies are effective. Additional modifications are also necessary to correct minor omissions and some drafting that is not as clear as it could be. The rationale for these changes should be self-explanatory. WGCL has approached these representations on the basis that Policy S/AMC/WGC layers additional potential onto the baseline position established by extant planning permissions (as reflected in Policy S/WGC) to recognise further potential for intensification and renewal, including on those parts of the existing Campus which are not within the area covered by the S/WGC Site Allocation (which corresponds with the
limits of extant planning permissions for expansion).

WGCL supports the ambition of this Policy to realise the full potential of the Wellcome Genome Campus and ensure it is sustained over the decades ahead. The principle of replacement, intensification and expansion being guided through a Masterplan (as identified at Policy Point 1) represents a pragmatic approach to forward planning: it provides an appropriate basis for facilitating and considering future development in circumstances when opportunity is not yet fully crystallised and linked to the success of committed development. Minor amendment to Policy Point 1c is suggested to reflect the fact that provision of a substantial amount of new, modern R&T floorspace will mean some of the older buildings will be remodelled and repurposed or replaced, and there
may well be loss of floorspace or inter-mixing of uses in some areas, more than compensated for by gain in others. As drafted the Policy is over simplistic and not
reflective of the objectives of the Policy overall.

The requirement for a Masterplan to be agreed prior to approval of "any planning applications" is unnecessarily onerous and should be amended to ensure that it does not
frustrate ‘business as usual’ operations across the Campus. As the Council are aware, the existing Campus has always, and will continue to adapt to progress maintenance and upgrades and make adaptations for occupiers, requiring regular interventions, which
very often constitute development. The expansion progresses under a separate regime so needs no new masterplan. These must not be hindered by processes that need relate only to major change. A new masterplan is required to guide significant development beyond that encompassed by Policy S/WGC and should be tied into
accordingly.

The preparation of a Master Plan, Place Book and Design Code is supported, in principle. However, Wellcome caution against overly prescriptive, detailed or drawn-out
processes that risk unnecessarily slow, complex, repetitive or costly commitments. The approach needs to be proportionate and reflective of gradual, incremental evolution across the Campus. It is also suggested that Development Briefs might offer a useful alternative to coding, especially where change might arise in the context of one single building.

WGCL welcomes the revised wording relating to the Conference Centre.

WGCL supports the approach that residential homes are for Campus workers "as a first priority’. This is welcome improvement on previous drafting. It better reflects the
existing controls on occupation and leaves some scope for adaptation to underpin delivery of homes on site.

Policy Points 1(m) and 1(o) should be reworded to support strategic public transport and active travel improvements, with contributions secured where necessary and
proportionate to the scale and impact of development proposed.

While the scope of the Master planning exercise is not disputed. The Policy needs to start with clear articulation of how a process which starts with a masterplan will be
carried forward into ‘projects’ that can be defined as commitments and an essential component of the Infrastructure Delivery Plan. At this point, insufficient engagement and scoping have been undertaken to indicate in Policy (backed up by the IDP) what the
purpose and objective of the Policy is and what is required from those that will be engaged in taking this exercise forward. WGCL is not, therefore, in a position to suggest
improved drafting.

Reflecting on the work that has been undertaken already, there is also merit in extending the Study Area across the A505 so that the potential to overcome the barrier to
connectivity that the road represents, as well as development opportunities in close proximity to the station, can be considered as part of the exercise.

WGCL is willing to engage with landowners and stakeholders to scope this exercise, so a more effective Policy can be put before the Inspector.

These representations are made on behalf of Wellcome Genome Campus Limited (WGCL). WGCL is the Wellcome owner-developer-operator charged with leading the Wellcome Genome Campus and delivering its ongoing transformation and expansion as a globally significant science ecosystem and community. This ambition is intrinsic to both the substantial scale of development now underway on the ‘expansion land’, to the east of the A1301, and in priority WGCL is now directing towards modernising the existing Campus, west of the A1301. WGCL’s vision is to bring these areas together as
an open, diverse and connected place that puts people first, supports collaboration and innovation using digital technology and delivers a shift to active travel. WGCL is evolving the Campus from a closed, gated workplace into a place and destination. Increasingly, the Campus will have the characteristics of a small town, one with a clear purpose derived from its science mission. The Local Plan represents an opportunity to guide this change and secure wide benefits.

WGCL want to assert the important role of the expanding Campus and the part it can play in the growth and success of Cambridge, as a location for life sciences of national and global significance. Realising this potential is dependent upon achieving an effective and sustainable movement network across the communities and investment locations within the Southern Cluster, and integrated back into the City.

WGCL is working hard to:

• externalise and promote the activity which underpins the work undertaken at the Campus and ensure this vital activity can be sustained;
• accelerate the benefits arising amongst common interests within the Southern Cluster; and
• open up the Campus to the wider community.

With Policy support, the enormous investment that has underpinned the operation of the Campus to date, and that which is planned, could yield far greater economic and social benefit while furthering the science mission.

WGCL is greatly encouraged by the recent response of officers and members to its ambitious proposals, and efforts to evolve the Local Plan Policy to facilitate next steps and embody flexibility to allow the Campus to change and adapt over the period ahead.

Good progress has been made between the Regulation 18 and Regulation 19 versions of the Plan in this regard. There was insufficient progress at Regulation 18 to fully
engage with and consider the implications of the wider Plan Policies, in terms of cumulative demands, infrastructure needs, viability and delivery. These are now central to the question of soundness and this further representation on behalf of WGCL.

There are three principal elements to this Regulation 19 submission:

1. The Wellcome Genome Campus Policies are now, for the most part, well formed to provide the basis for decision making in relation to both continued implementation of the extant planning permissions for expansion and to evolve the existing Campus over time. There are a number of
relatively minor modifications that would ensure the Policy is as clear and effective as it needs to be. WGCL is hopeful that these can be resolved through further engagement with officers in advance of Examination.

2. Creating the conditions necessary to realise the investment potential enshrined in the Wellcome Genome Campus Policies requires that the Local Plan is aspirational but is also deliverable. For WGCL, focused upon delivery at Wellcome Genome Campus, the Local Plan is more than a development management tool. The Plan needs to be a positive signal to investors, underpinning, not detracting from the competitive advantage of the location. As it stands, the forward plan for infrastructure delivery that underpins the Plan is uncertain and incomplete. Certainty around strategic
transport infrastructure is WGCL’s greatest concern. Without commitment on this front, the Local Plan signals a high level of risk to investors.

3. The challenges around infrastructure investment layer into a multitude of onerous and costly policy obligations across the Plan, the cumulative impact of which in any specific location (especially where the transport
infrastructure deficit is considerable) is not tested, or is masked by a broad, whole plan viability assessment. WGCL is not convinced that the deliverability of the Plan is sufficiently secure.

In these representations, ‘The Wellcome Genome Campus’ or ‘Campus’ refers to the full extent of the WGCL interest, including both the existing Campus, associated
parkland and wetlands, and the expansion land to the east of the A1301.

WGCL attach great priority to the redevelopment of Parkway Station area to deliver a functional transport interchange that can better support investment and development across the Southern Cluster including at Wellcome Genome Campus. Realising opportunity around stations has long been an important priority in support of sustainable development, now given new impetus by the latest NPPF.

The Policy is not, however, the firm commitment that is necessary to lead and progress a master exercise towards deliverable outcomes. A programme is needed that aligns
with delivery of immediate and committed development and anticipates emerging development proposals including those in the Local Plan.

Vague support for a masterplan does not represent an effective Policy to achieve delivery. Through the Policy, the relevant stakeholders need to confirm commitment to a timeframe for the master planning and then articulate the further steps to progress to implementation. It is not the role of the Local Plan to simply record the Council’s support for an exercise that is essential to the Development Strategy. The role of Local Plan is
to make Policy that is effective in delivering outcomes.

Completed studies on the future of the Whittlesford Parkway Station have already languished on shelves since 2018 and 2020, demonstrating very well the potential risk of not being positive and proactive in gearing towards implementation of solutions.

Failure to tackle transport interchange at Whittlesford puts substantial investment at risk, including the raft of Local Plan Policies across the Southern Cluster and at Wellcome Genome Campus.

WGCL are one of the critical stakeholders in this process and stand ready to participate in a master planning exercise. WGCL are already part-funding a study, in progress to examine the potential of Autonomous Vehicle connections between Wellcome Genome Campus and Whittlesford Parkway Station. WGCL also has Section 106 commitments to investment in transport improvements that need to be finalised in the context of comprehensive, coordinated proposals for the Parkway Station and the A505 Corridor.

The ability to interchange effectively at the Station will very soon become a critical question to answer in taking committed development forward. This further underlines the importance of this exercise and the potential for the Policy to unlock Wellcome investment.

Modification of the Policy is also suggested to widen the study area (or, if preferred, allow the stakeholders scope to expand the study area), recognising that the opportunity
the station presents will not be realised unless connection from south of the A505 is addressed.

For the Policy to be effective, sufficient certainty on the commitment to deliverability and implementation of the Whittlesford Parkway Station masterplan is needed.

These representations are made on behalf of Wellcome Genome Campus Limited (WGCL). WGCL is the Wellcome owner-developer-operator charged with leading the Wellcome Genome Campus and delivering its ongoing transformation and expansion as a globally significant science ecosystem and community. This ambition is intrinsic to both the substantial scale of development now underway on the ‘expansion land’, to the east of the A1301, and in priority WGCL is now directing towards modernising the existing Campus, west of the A1301. WGCL’s vision is to bring these areas together as
an open, diverse and connected place that puts people first, supports collaboration and innovation using digital technology and delivers a shift to active travel. WGCL is evolving the Campus from a closed, gated workplace into a place and destination. Increasingly, the Campus will have the characteristics of a small town, one with a clear purpose derived from its science mission. The Local Plan represents an opportunity to guide this change and secure wide benefits.

WGCL want to assert the important role of the expanding Campus and the part it can play in the growth and success of Cambridge, as a location for life sciences of national and global significance. Realising this potential is dependent upon achieving an effective and sustainable movement network across the communities and investment locations within the Southern Cluster, and integrated back into the City.

WGCL is working hard to:

• externalise and promote the activity which underpins the work undertaken at the Campus and ensure this vital activity can be sustained;
• accelerate the benefits arising amongst common interests within the Southern Cluster; and
• open up the Campus to the wider community.

With Policy support, the enormous investment that has underpinned the operation of the Campus to date, and that which is planned, could yield far greater economic and social benefit while furthering the science mission.

WGCL is greatly encouraged by the recent response of officers and members to its ambitious proposals, and efforts to evolve the Local Plan Policy to facilitate next steps and embody flexibility to allow the Campus to change and adapt over the period ahead.

Good progress has been made between the Regulation 18 and Regulation 19 versions of the Plan in this regard. There was insufficient progress at Regulation 18 to fully
engage with and consider the implications of the wider Plan Policies, in terms of cumulative demands, infrastructure needs, viability and delivery. These are now central to the question of soundness and this further representation on behalf of WGCL.

There are three principal elements to this Regulation 19 submission:

1. The Wellcome Genome Campus Policies are now, for the most part, well formed to provide the basis for decision making in relation to both continued implementation of the extant planning permissions for expansion and to evolve the existing Campus over time. There are a number of
relatively minor modifications that would ensure the Policy is as clear and effective as it needs to be. WGCL is hopeful that these can be resolved through further engagement with officers in advance of Examination.

2. Creating the conditions necessary to realise the investment potential enshrined in the Wellcome Genome Campus Policies requires that the Local Plan is aspirational but is also deliverable. For WGCL, focused upon delivery at Wellcome Genome Campus, the Local Plan is more than a development management tool. The Plan needs to be a positive signal to investors, underpinning, not detracting from the competitive advantage of the location. As it stands, the forward plan for infrastructure delivery that underpins the Plan is uncertain and incomplete. Certainty around strategic
transport infrastructure is WGCL’s greatest concern. Without commitment on this front, the Local Plan signals a high level of risk to investors.

3. The challenges around infrastructure investment layer into a multitude of onerous and costly policy obligations across the Plan, the cumulative impact of which in any specific location (especially where the transport
infrastructure deficit is considerable) is not tested, or is masked by a broad, whole plan viability assessment. WGCL is not convinced that the deliverability of the Plan is sufficiently secure.

In these representations, ‘The Wellcome Genome Campus’ or ‘Campus’ refers to the full extent of the WGCL interest, including both the existing Campus, associated
parkland and wetlands, and the expansion land to the east of the A1301.

WGCL supports Policy S/DS and the overarching development strategy for Greater Cambridge.

Recognition of the need for substantial employment growth and the role of knowledge intensive sectors, life sciences and innovation-led industries in underpinning the future economy of Greater Cambridge is welcome. The Policy appropriately recognises the Southern Cluster as a key location for employment, research, innovation and
investment. Distinguishing a broad Policy area will drive collaborative effort to realise the potential of the science ecosystem and new communities.

WGCL also welcomes the specific recognition given to the Wellcome Genome Campus within the Development Strategy Policy and its identification as a strategic-scale
allocation within the Rural Southern Cluster. The Policy positively acknowledges the mixed-use expansion of the Campus, together with the renewal of the existing site. It
supports the creation of an exceptional environment for integrated working and living as articulated by the supporting text associated with the settlement hierarchy Policy. It recognises that the Campus is evolving into a place with homes, jobs and services and will continue to develop in its role as a settlement over the plan period. This reflects the scale of investment and planned growth already commenced and acknowledges the changing role of the Campus within the Southern Cluster.

These representations are made on behalf of Wellcome Genome Campus Limited (WGCL). WGCL is the Wellcome owner-developer-operator charged with leading the Wellcome Genome Campus and delivering its ongoing transformation and expansion as a globally significant science ecosystem and community. This ambition is intrinsic to both the substantial scale of development now underway on the ‘expansion land’, to the east of the A1301, and in priority WGCL is now directing towards modernising the existing Campus, west of the A1301. WGCL’s vision is to bring these areas together as
an open, diverse and connected place that puts people first, supports collaboration and innovation using digital technology and delivers a shift to active travel. WGCL is evolving the Campus from a closed, gated workplace into a place and destination. Increasingly, the Campus will have the characteristics of a small town, one with a clear purpose derived from its science mission. The Local Plan represents an opportunity to guide this change and secure wide benefits.

WGCL want to assert the important role of the expanding Campus and the part it can play in the growth and success of Cambridge, as a location for life sciences of national and global significance. Realising this potential is dependent upon achieving an effective and sustainable movement network across the communities and investment locations within the Southern Cluster, and integrated back into the City.

WGCL is working hard to:

• externalise and promote the activity which underpins the work undertaken at the Campus and ensure this vital activity can be sustained;
• accelerate the benefits arising amongst common interests within the Southern Cluster; and
• open up the Campus to the wider community.

With Policy support, the enormous investment that has underpinned the operation of the Campus to date, and that which is planned, could yield far greater economic and social benefit while furthering the science mission.

WGCL is greatly encouraged by the recent response of officers and members to its ambitious proposals, and efforts to evolve the Local Plan Policy to facilitate next steps and embody flexibility to allow the Campus to change and adapt over the period ahead.

Good progress has been made between the Regulation 18 and Regulation 19 versions of the Plan in this regard. There was insufficient progress at Regulation 18 to fully
engage with and consider the implications of the wider Plan Policies, in terms of cumulative demands, infrastructure needs, viability and delivery. These are now central to the question of soundness and this further representation on behalf of WGCL.

There are three principal elements to this Regulation 19 submission:

1. The Wellcome Genome Campus Policies are now, for the most part, well formed to provide the basis for decision making in relation to both continued implementation of the extant planning permissions for expansion and to evolve the existing Campus over time. There are a number of
relatively minor modifications that would ensure the Policy is as clear and effective as it needs to be. WGCL is hopeful that these can be resolved through further engagement with officers in advance of Examination.

2. Creating the conditions necessary to realise the investment potential enshrined in the Wellcome Genome Campus Policies requires that the Local Plan is aspirational but is also deliverable. For WGCL, focused upon delivery at Wellcome Genome Campus, the Local Plan is more than a development management tool. The Plan needs to be a positive signal to investors, underpinning, not detracting from the competitive advantage of the location. As it stands, the forward plan for infrastructure delivery that underpins the Plan is uncertain and incomplete. Certainty around strategic
transport infrastructure is WGCL’s greatest concern. Without commitment on this front, the Local Plan signals a high level of risk to investors.

3. The challenges around infrastructure investment layer into a multitude of onerous and costly policy obligations across the Plan, the cumulative impact of which in any specific location (especially where the transport
infrastructure deficit is considerable) is not tested, or is masked by a broad, whole plan viability assessment. WGCL is not convinced that the deliverability of the Plan is sufficiently secure.

In these representations, ‘The Wellcome Genome Campus’ or ‘Campus’ refers to the full extent of the WGCL interest, including both the existing Campus, associated parkland and wetlands, and the expansion land to the east of the A1301.

WGCL supports Policy S/SH and the proposed settlement hierarchy.

The policy provides an appropriate framework for directing growth to the most sustainable locations whilst recognising the different roles and functions of settlements
across Greater Cambridge.

In particular, WGCL welcomes paragraph 2.123, which recognises that the Wellcome Genome Campus is evolving into a place with homes, jobs and services and will continue to develop in its role as a settlement over the plan period.

This is a positive recognition of the growing role of the Campus within the Southern Cluster and reflects the scale of investment and planned growth already taking place.

The supporting text appropriately acknowledges that the Wellcome Genome Campus is evolving into a more complete science community with a wider mix of uses and services.

WGCL's provides in attached amendments to to the wording of Policy S/WGC is as follows (deletions are shown crossed through with additions in black, bold type; explanations and
comments in square brackets)

These representations are made on behalf of Wellcome Genome Campus Limited (WGCL). WGCL is the Wellcome owner-developer-operator charged with leading the Wellcome Genome Campus and delivering its ongoing transformation and expansion as a globally significant science ecosystem and community. This ambition is intrinsic to both the substantial scale of development now underway on the ‘expansion land’, to the east of the A1301, and in priority WGCL is now directing towards modernising the existing Campus, west of the A1301. WGCL’s vision is to bring these areas together as
an open, diverse and connected place that puts people first, supports collaboration and innovation using digital technology and delivers a shift to active travel. WGCL is evolving the Campus from a closed, gated workplace into a place and destination. Increasingly, the Campus will have the characteristics of a small town, one with a clear purpose derived from its science mission. The Local Plan represents an opportunity to guide this change and secure wide benefits.

WGCL want to assert the important role of the expanding Campus and the part it can play in the growth and success of Cambridge, as a location for life sciences of national and global significance. Realising this potential is dependent upon achieving an effective and sustainable movement network across the communities and investment locations within the Southern Cluster, and integrated back into the City.

WGCL is working hard to:

• externalise and promote the activity which underpins the work undertaken at the Campus and ensure this vital activity can be sustained;
• accelerate the benefits arising amongst common interests within the Southern Cluster; and
• open up the Campus to the wider community.

With Policy support, the enormous investment that has underpinned the operation of the Campus to date, and that which is planned, could yield far greater economic and social benefit while furthering the science mission.

WGCL is greatly encouraged by the recent response of officers and members to its ambitious proposals, and efforts to evolve the Local Plan Policy to facilitate next steps and embody flexibility to allow the Campus to change and adapt over the period ahead.

Good progress has been made between the Regulation 18 and Regulation 19 versions of the Plan in this regard. There was insufficient progress at Regulation 18 to fully
engage with and consider the implications of the wider Plan Policies, in terms of cumulative demands, infrastructure needs, viability and delivery. These are now central to the question of soundness and this further representation on behalf of WGCL.

There are three principal elements to this Regulation 19 submission:

1. The Wellcome Genome Campus Policies are now, for the most part, well formed to provide the basis for decision making in relation to both continued implementation of the extant planning permissions for expansion and to evolve the existing Campus over time. There are a number of
relatively minor modifications that would ensure the Policy is as clear and effective as it needs to be. WGCL is hopeful that these can be resolved through further engagement with officers in advance of Examination.

2. Creating the conditions necessary to realise the investment potential enshrined in the Wellcome Genome Campus Policies requires that the Local Plan is aspirational but is also deliverable. For WGCL, focused upon delivery at Wellcome Genome Campus, the Local Plan is more than a development management tool. The Plan needs to be a positive signal to investors, underpinning, not detracting from the competitive advantage of the location. As it stands, the forward plan for infrastructure delivery that underpins the Plan is uncertain and incomplete. Certainty around strategic
transport infrastructure is WGCL’s greatest concern. Without commitment on this front, the Local Plan signals a high level of risk to investors.

3. The challenges around infrastructure investment layer into a multitude of onerous and costly policy obligations across the Plan, the cumulative impact of which in any specific location (especially where the transport
infrastructure deficit is considerable) is not tested, or is masked by a broad, whole plan viability assessment. WGCL is not convinced that the deliverability of the Plan is sufficiently secure.

In these representations, ‘The Wellcome Genome Campus’ or ‘Campus’ refers to the full extent of the WGCL interest, including both the existing Campus, associated parkland and wetlands, and the expansion land to the east of the A1301.

WGCL recognises that there is merit in two policies to address the potential at the Wellcome Genome Campus. This responds positively to representations made by
WGCL on the Regulation 18 consultation plan, seeking distinction and clarity with regard to what is already consented and being delivered and what is in prospect, but less well defined. It does, however, present some challenges in navigating between the policies and the related Plans. Some further modifications are necessary to remove inconsistencies, achieve clarity and ensure polices can be applied to the appropriate
areas.

WGCL has approached these representations on the basis that Policy S/AMC/WGC layers additional potential onto the baseline position established by extant planning
permissions, (reflected in Policy S/WGC), to recognise further potential for intensification and renewal, including on those parts of the existing Campus which are not within the area covered by the S/WGC Site Allocation (which corresponds with the limits of extant planning permissions for expansion).

Additional modifications are also necessary to correct minor omissions and some drafting that is not as clear as it could be. The rationale for these changes should be
self-explanatory.

Objectives and Place Identity
WGCL is generally supportive of this section insofar as it supports the continued growth of the Wellcome Genome Campus as a nationally significant research and innovation cluster.

Uses
The precise quantum of floorspace is derived only from what is already permitted, some of which has already been delivered. Some clarification is suggested to explain this (acknowledging that comes later in the supporting text). WGCL welcomes the removal of the Regulation 18 blanket restriction on employment uses solely to genomics and bioinformatics. This did not reflect the breadth of opportunity or the permitted development, the permissions for which carefully clarify the scope of uses.

WGCL also welcomes the removal of the Regulation 18 requirement restricting residential occupation exclusively to Campus workers. The wording imposed an overly restrictive limit beyond that secured through the extant planning permission. Defining instead a first priority for residential dwellings to be targeted at Campus workers recognises that there is flexibility to cascade to other occupiers when there is no immediate demand from the
Campus.

Context
This section should be retitled to reflect its content, which is not ‘context’ but important Policy for the wider Policy Areas.

WGCL supports the objective of maintaining separation between Hinxton, Ickleton and new built development. The drafting is however a bit confusing and unclear as to the difference between ‘strategic gap’ and ‘open buffer’ requirements. For clarity and effectiveness, a simpler approach is suggested.

Policy point 7(b) refers to the "Hinxton Conservation Area within and to the west of the site east". This is a rather confused presentation of the geography – the Conversation Area sits partly across the Policy Area and extends into Hinxton Village. Alternative clearer wording is suggested.

Built Form
WGCL supports the recognition of opportunities and intensification and providing flexibility where necessary.

The wording of the Policy should clarify that the ‘built area’ is to be contained within the Site Allocation boundary.

Policy Point 10 requires a Masterplan for the ‘whole Campus where significant changes are proposed within the Existing Campus’ and follows with reference to the existing form of ‘master plan’ (The Design Guide) for the Site Allocation area. It is suggested the order is reversed as the latter is more relevant to the Site Allocation and the Masterplan relates more directly to S/AMC/WGC. Cross reference to S/AMC/WGC would help understanding of these two elements. Similar to Policy Point 11, while WGCL supports the intensification of built form this should be expressed as a general point. This Policy does not deal with much of the existing Campus.

Some clarification in relation to the location of the central green is suggested to ensure it is not interpreted as the only location retail and community facilities are or will be
delivered.

Public Space
The ‘Public Space’ requirements adopt the consented scheme, in detail. There is no basis for Policy to require exactly what has been consented (down to minor detail such as a decorative ‘water feature’ on the Green). A different scheme, for example one without a water feature, could be equally appropriate in planning terms. More
significantly, additional development beyond the extant OPP or a changed approach may necessitate different provision or introduce different design ideas. The critical
requirement is that the impact of any/all proposals are tested and associated policy requirements for open space, sports provision, habitats etc are tested and defined at the
planning application stage. Some minor amendments are proposed to avoid unjustified over-prescription of design detail.

Nature
WGCL supports the objective of protecting and enhancing biodiversity and landscape features associated with the Campus.

Minor amendments are proposed to address that public access is not appropriate in all locations (especially where the existence of protected species require limitation on
access) and while trees and buffer planting are part of the GI strategy there is no proposal for a woodland to the northwest of the site.

Movement
WGCL are generally supportive of the approach to movement with some minor clarifications to acknowledge the degree of uncertainty over strategic transport
commitments. If greater certainty in respect of transport investment emerges, it would be beneficial that this is reflected more firmly in this Policy (see WGCL’s representations on Infrastructure Delivery).

Resources
WGCL supports Policy Point 25 and recognises the need for an energy centre and data centre to support the operation and future growth of the Campus.

Life Span
WGCL suggest minor drafting changes to better reflect a more familiar definition of transport mitigation in the context of planning applications. WGCL is fully committed to engaging in collaborative efforts to develop strategic transport mitigation for the Southern Cluster, but in the context of any specific planning application, the ability for a single applicant to formulate effective strategic transport mitigation is limited. The Local Plan and Greater Cambridge Transport Strategy must set the context for these solutions.