Greater Cambridge Local Plan: Proposed Submission

add new text to end of part 2(d): Where mechanical cooling is necessary to meet the evidenced operational, technical, safety or environmental requirements of a use, including research and development and other specialist facilities, proposals should demonstrate that demand has been minimised and that the selected system represents the most appropriate low-carbon solution.

Policy CC/DC should recognise that mechanical cooling may be necessary for research, laboratory and other specialist uses where passive, natural or mixed-mode solutions cannot meet operational, technical, safety or environmental requirements. The proposed amendment retains the cooling hierarchy by requiring demand to be minimised and the lowest-carbon solution to be selected, while allowing justified mechanical cooling. This provides a proportionate framework that supports climate objectives and the local research and innovation economy. The proposed amendment is to ensure the policy is effective.

Additional line added to Part 10: Development proposals, including major refurbishments in the 2025 Heat Network Priority Area boundary, as shown on the Policies Map, should connect to existing heat networks or networks under development within this area, unless evidence is provided that demonstrates a connection would impact on the technical feasibility or viability of a proposal, or that connection would not represent the most sustainable or effective energy solution for the development. Further guidance on connection requirements is included within the CCCHN Future Proofing Guidance.

Policy CC/RE should provide flexibility where connection to a heat network would not be the most sustainable or effective energy solution. In particular, requiring connection to a gas-led network could increase operational carbon emissions and conflict with the Plan’s net zero requirements. The proposed amendment ensures that the network’s fuel source and carbon performance are considered, allowing an alternative solution where this would deliver a lower-carbon outcome. The proposed amendment is to ensure the policy is effective.

Additional words at end of Part (7): All major development proposals, including strategic sites, should seek opportunities to enhance the carbon sequestration potential of their proposals through green infrastructure and new habitat creation. The demonstration of meaningful carbon sequestration where there is a significant net gain within a proposal through nature-based solutions will be a material consideration in the decision-making process, including as part of the WLC Assessment.

The proposed amendment is necessary to provide clarity on how sequestration will be a material consideration in decision making. The proposed amendment is to ensure the policy is effective.

Additional text added to part 12: All development must provide integrated nest boxes (a combination of bird, bat & insect boxes) appropriate to type and scale of development to target protected, priority and other species associated with the built environment where practical and viable.

The addition of ‘where practical and viable’ to paragraph 12 is necessary to recognise that integrated nest boxes may not be appropriate for all forms of development. Medical and other specialist buildings may be subject to operational, patient safety, hygiene or maintenance constraints that prevent their installation. The amendment retains the requirement wherever feasible, while allowing site-specific constraints to be taken into account. The proposed amendment is to ensure the policy is effective.

Amendment to part 6: 6. A GI Operation and Maintenance Plan must be submitted to and approved in writing by the relevant Local Planning Authority, before any development is occupied. The approved plan shall outline how the space will be managed for a 30-year period and the funding and stewardship arrangement for implementing the management plan, secured via condition.

The amendment to paragraph 6 aligns the policy with Policy BG/EO by applying a consistent 30-year management period for green infrastructure. This provides a clear and proportionate timeframe for securing funding, stewardship and ongoing maintenance, while avoiding the uncertain and potentially disproportionate requirement to manage green infrastructure for the lifetime of the development. The amendment would therefore make the policy more consistent, effective and capable of implementation.

Amendments to paragraphs 7 and 8: 7. The size of buffer zone to be provided between development proposals and ancient woodland must be agreed with the LPA, supported by evidence demonstrating how this avoids harm to the relevant ancient woodland. Development proposals, including through the construction phase, must maintain at least a 15 metre buffer zone from the boundary of any ancient woodland, and should aim for 50 metres, unless otherwise approved by the Local Planning Authority.
8. Development proposals must maintain a buffer zone around individual ancient and veteran trees of at least 15 times the tree's diameter, or 5 metres from the edge of the tree’s canopy if that area is larger , unless otherwise approved by the Local Planning Authority. The scale of buffer zone around an ancient or veteran trees should be informed by the calculated Root Protection Area.

The amendments to paragraphs 7 and 8 clarify the applicable minimum buffer zones for ancient woodland and ancient or veteran trees. They retain the expectation that development should avoid these buffers, while allowing a different approach to be agreed with the Local Planning Authority where justified by site-specific evidence and where harm can be avoided or appropriately mitigated. This provides necessary flexibility without weakening the protection afforded to these irreplaceable habitats.

Revise policy to place greater emphasis on the quality, accessibility and functionality of open space, whilst allowing the amount and form of provision to respond to site circumstances, viability, operational requirements, existing local provision and the character of the surrounding green infrastructure network.

The proposed amendments introduce necessary flexibility into paragraph 4 and are supported as a minimum. However, the underlying requirement for commercial development to provide 2 hectares of open space per 1,000 employees is not sound and should be reviewed further before adoption.
The proposed standard appears significantly higher than the level of open space typically delivered within successful research, innovation and healthcare campuses. Experience from the Cambridge Biomedical Campus demonstrates that occupier demand is driven primarily by the quality, functionality and accessibility of open space rather than a prescribed quantitative ratio. These locations continue to attract world-leading organisations despite providing lower levels of open space than those proposed.
The standard should therefore be reviewed and calibrated against local evidence and delivery experience. As drafted, the policy risks imposing a requirement that is not representative of successful employment environments already operating within Cambridge. It could result in less dense development, contrary to the requirement for an urban grain that facilitates interaction.
In addition, requiring 2 hectares of open space per 1,000 employees could result in less efficient use of land in the most sustainable and accessible locations, including land released from the Green Belt to meet identified development needs. This would run counter to the objectives of concentrating growth in highly sustainable locations, supporting compact patterns of development and maximising the use of scarce land resources. There is also a risk that excessive on-site requirements could divert land from research, healthcare and employment floorspace, potentially undermining the delivery of strategic economic objectives.
The policy should therefore place greater emphasis on the quality, accessibility and functionality of open space, whilst allowing the amount and form of provision to respond to site circumstances, viability, operational requirements, existing local provision and the character of the surrounding green infrastructure network. Any quantitative standard should be evidence-based and refined to reflect the lessons learned from the delivery and operation of major employment sites.

New text to be added, part (e): e. Within strategic allocations, science parks, and major research, healthcare or innovation campuses, a bespoke approach to affordable workspace provision may be agreed with the Councils, having regard to the scale, function, phasing and operational requirements of the development. This may include the consolidation of affordable workspace provision within dedicated innovation, incubation or accelerator space, or alternative mechanisms that demonstrably support start-up, scale-up, community, health, research or innovation-related occupiers.

The objective of supporting affordable workspace is supported; however, the policy should provide greater flexibility for strategic sites, science parks and major research and healthcare campuses. These locations operate differently from conventional office developments, with occupiers often requiring highly specialised accommodation, shared facilities, collaboration space and opportunities for business incubation and growth.
A requirement to distribute affordable workspace across individual plots or buildings may not deliver the most effective outcome and could result in fragmented provision that is difficult to manage and less attractive to prospective occupiers. Experience at the Cambridge Biomedical Campus and other established innovation clusters demonstrates that dedicated innovation hubs, incubator space and managed grow-on accommodation can often provide greater economic and innovation benefits than dispersed affordable floorspace.
The policy should therefore allow strategic sites to agree a bespoke delivery model that responds to their particular functions, phasing and operational requirements. This could include consolidating affordable workspace provision within a dedicated building or campus-wide offer, enabling a broader range of start-ups, scale-ups, health, research, innovation and community-focused organisations to access suitable accommodation. Such an approach would better support the wider ecosystem, provide greater flexibility over time and help maximise the economic and social benefits generated by these nationally significant employment locations.

Please see attached response on individual parts of the policy.

Please see attached response on individual parts of the policy.
Cambridgeshire County Council and Prologis Development strongly support the overall approach to the Cambridge Biomedical Campus and Policy S/CBC. The representations in the accompanying document are intended to assist GCSP in refining the policy wording to ensure the allocation is sound, deliverable and capable of supporting the continued growth and evolution of this globally significant research, healthcare and innovation cluster.

The Cambridge Biomedical Campus including the land allocated for expansion through release of land from the Green Belt as shown on the Policies Map, is appropriate for a mix of uses centred on the Campus’ unique function of bringing together clinical care, clinical and academic education, and clinical and academic research including medical research institutes and life sciences which meet local, regional or national health care needs – together with related commercial biomedical and biotechnology research and development activities. The Campus will include provision for an innovation hub, visitor accommodation, additional campus worker homes, public open spaces and other supporting services and facilities to support those that work, live, visit and pass through the Campus.

Please see attached response on individual parts of the policy.
Cambridgeshire County Council and Prologis Development strongly support the overall approach to the Cambridge Biomedical Campus and Policy S/CBC. The representations in the accompanying document are intended to assist GCSP in refining the policy wording to ensure the allocation is sound, deliverable and capable of supporting the continued growth and evolution of this globally significant research, healthcare and innovation cluster.