Greater Cambridge Local Plan: Proposed Submission

The policy should be strengthened to reflect the scale of growth ambitions for Greater Cambridge and the significant public investment being made in strategic infrastructure. The Local Plan should proactively support Cambridge’s role as a nationally important knowledge economy by increasing housing delivery across the plan period to ensure the workforce needed for future job growth can be accommodated.

The Plan should not rely on the future Greater Cambridge Development Corporation to deliver growth beyond the current allocations. While the GCDC has been established, it has yet to secure plan-making powers and any formally adopted 'successor' plan is likely to be many years away. Given the immediate growth ambitions for Greater Cambridge, the Local Plan must address these requirements now to provide certainty, support investment, and ensure growth now.

The reference to 73,300 additional jobs should be treated as a minimum target rather than a ceiling on growth. The policy should explicitly state that employment growth beyond this figure will be supported where sustainable opportunities arise. This will ensure the Plan remains flexible and responsive to future investment and expansion.

AstraZenca supports the overall ambition of the policy to deliver new jobs and homes and, in particular, maintain Greater Cambridge's position as a leading location for knowledge-intensive sectors. However, greater clarity and flexibility are required to ensure the policy can respond effectively to future growth opportunities.

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. The draft plan does not do this. Cambridge and the surrounding region are central to the government’s ambition to ‘supercharge’ growth. The draft plan does not reflect this ambition and will not meet the government’s expectations.

This is backed by national, regional and authority level investment in infrastructure including the new Cambridge South Train Station providing direct connectivity between Cambridge Biomedical Campus and London, the granting of the Cambourne to Cambridge busway and progression of Cambridge South East Transport 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 for Greater Cambridge is also set to be delivered by the Greater Cambridge Development Corporation (GCDC). A body that is now legally formed.

The approach of the LPA may be that the GCDC will deliver the growth over-and-above the minimum provision in the Draft Local Plan, but; the GCDC is yet to receive plan-making powers; it will prepare a Plan after the adoption of the Draft GCLP; it will need to undertake formal consultation and examination in public in the normal way to lead to a formally adopted “successor” Plan. Such a successor Plan will be many years away, while the growth ambition is now. The GCLP needs to address growth now and not rely on a possible GCDC Plan.

We contend that, in order to ensure the plan is found sound the unique nature of Cambridge and its projected capacity for growth must be supported and planned for by the emerging Local Plan. Specifically, this should be met through increased housing delivery across the Plan period. Housing delivery being critical to support the delivery of employment and wider economic growth.

Furthermore, the reference to 73,300 additional jobs should be treated as a minimum target rather than expressed, or even inferred, as a cap on growth beyond this number. As currently drafted, there is a risk that the figure could be interpreted as limiting future employment growth opportunities. The policy should make clear that the target represents a minimum level of employment growth and should not act as a constraint to the delivery of additional jobs where sustainable economic opportunities arise through acceptable developments at that time.

To ensure the Plan is effective policy S/CBC must be clearer about how it relates to existing occupiers and how it relates to the undeveloped Phase 3 and 4.

The Policy is overwhelmingly long and difficult to unpick each and every component and how they stitch together. In this context it is recommended that an extra paragraph is included at the very end of the policy.

“The policy covers the entirety of the existing and proposed campus. The policy will be applied appropriately to recognise that occupiers within CBC will not be able to adhere to many of the site wide assessment and strategies, especially the timing of them. The policy is to support and foster the important role of CBC, which extends to meeting, whenever possible, the needs of existing occupiers in a timely manner’.

The overarching ambition of the policy is supported in recognition of Cambridge Biomedical Campus (CBC) as a globally significant centre for healthcare, research, development and innovation; a significance which would increase with its expansion.

AstraZeneca relocated its principal UK operations to Cambridge in 2017 to become a leading part of the life sciences ecosystem and, importantly, because it was able to establish its headquarters within CBC. The continued growth of CBC is supported as it will strengthen the cluster, facilitate collaboration between businesses and institutions, expand the skilled workforce and create a more connected and attractive environment for employees, visitors and the local community.

However, it is important that the delivery of Phases 3 and 4 does not come at the expense of established occupiers within Phase 1, being the largely developed area north of Dame Mary Archer Way. AstraZeneca operates its own campus within CBC, comprising existing buildings, an extant consent for an additional building, and further planned-for development opportunities that may be required to support future business growth. The potential for further development of the AstraZeneca campus has long been recognised within CBC planning frameworks, as first identified in the 2009 outline planning permission.

It would therefore be inappropriate, and contrary to the long-term success of an expanded CBC, for policy requirements intended primarily to facilitate the comprehensive delivery of Phases 3 and 4 to constrain the operational flexibility and growth of existing occupiers.

The S/CBC policy is extensive and places substantial requirements on future development. Whilst many of these may be justified in relation to the strategic planning and delivery of Phases 3 and 4, the policy area also includes Phase 1. Numerous requirements involve the preparation and approval of strategies, assessments and masterplanning documents before development can proceed. Whilst such measures may be appropriate for undeveloped land, they could have the unintended consequence of delaying or constraining development needed to support existing occupiers.

The policy should therefore explicitly recognise the fundamental difference between Phase 1, which is largely developed and operational, and Phases 3 and 4, which remain substantially undeveloped. This distinction should be reflected throughout the policy to ensure that requirements intended for strategic growth areas do not unnecessarily restrict smaller-scale development proposals needed to support existing occupiers and the continued success of CBC.

Detailed comments:-
1. The Policy is far too long. It is difficult to fully digest what the policy is trying to achieve and to understand each component of the policy and how different components interrelate

2. ‘Uses’ - this includes various floorspace figures against different uses. It is not clear if Astra Zeneca’s existing floorspace is a part of these figures and/or future floorspace that has always been set into the full build out of the Astra Zeneca campus. The Astra Zeneca campus sits immediately adjacent to the new Cambridge South Railway Station; it is now previously developed land and in a highly sustainable location. It would be inappropriate for S/CBC to act in any way to dimmish the appropriate development of the Astra Zeneca campus or look to prioritise/redirect floorspace to a future development field in favour of an existing and important occupier in the most sustainable part of the entire campus.

3. ‘Movement’ part c refers to an ‘agreed trip budget’. It is not clear what this is, what it includes and how it will relate to existing occupiers. Part c ii suggests that existing occupiers may be subject to the trip budget. Similar to point 2 above, it would be inappropriate and damaging to CBC for the policy to act to curtail existing occupiers, especially to Astra Zeneca where it is well understood that it has parts of its own campus not yet developed.

4. ‘Comprehensive Campus-Wide masterplan – part 31. Who will be responsible for the masterplan and what is the process for its preparation and approval? How will this masterplan relate to existing occupiers? Part 33 infers that any development within the entire campus will need to ‘integrate seamlessly’, but, again, how does this relate to existing occupiers. It is inappropriate, and may not result in a deliverable masterplan, to impose assumptions across existing occupiers, especially mix and scale of uses. If a campus wide masterplan is deemed appropriate then it is necessary for the policy to be much clearer about which requirements relate to the undeveloped Phase 3 and 4 and which parts are to describe Phase 1.

● The policy drafting is overly prescriptive and lacks flexibility.
● The policy should be amended so that Sustainability Assessments are required to address criteria 2(a)-(i) only "where appropriate" to recognise that specific and bespoke to the operational requirements of individual employment proposals.
● Criterion 2(b) should be amended or removed as it requires assessment against net zero operational carbon objectives that go beyond current national policy and Building Regulations requirements.
● Criterion 2(f) should also be clarified through the inclusion of a clear definition of "nature-based solutions" to ensure consistent interpretation and application.
● The Council should further demonstrate that the cumulative sustainability requirements in criteria 2(a)-(i) can be delivered across a range of commercial development types, including office, lab-enabled, dry lab and wet lab schemes. The policy should therefore be amended to ensure it is justified, effective and deliverable.

AstraZeneca supports the overall policy objectives. However, the policy as drafted is overly prescriptive and should be amended to provide greater flexibility, ensuring it can appropriately respond to the diverse range of development proposals anticipated to come forward over the plan period.

The policy should be amended to require Sustainability Assessments to address criteria 2(a)-(i) only "where appropriate", recognising that supporting information should be specific and bespoke to the operational requirements of individual employment proposals to avoid unnecessary burdens that could affect viability and deliverability.

In particular, criterion 2(b), which requires assessment against net zero operational carbon objectives, goes beyond current national policy and regulatory requirements. Whilst AstraZeneca supports the transition to net zero and the overarching aims of the policy, neither the Building Regulations nor the NPPF requires development proposals to achieve net zero operational carbon. The requirement therefore risks imposing additional costs that could adversely affect the viability and delivery of development.

Furthermore, criterion 2(f) lacks clarity regarding what constitutes a "nature-based solution", creating uncertainty. The policy should include a clear definition to ensure consistent interpretation and implementation.

AstraZenca is also concerned that the Council's Viability Appraisal does not does adequately account for the increased build costs of the extensive sustainability requirements set out in 2(a)-(i). In the absence of robust viability evidence demonstrating that these requirements can be delivered across a range of developments (and the important and distinct variety across office, lab-enabled, dry lab and wet lab typologies), the policy risks undermining the delivery of commercially beneficial sustainable development. This policy should therefore be amended to ensure it is justified, effective and consistent with national policy.

As drafted, the policy does not adequately reflect the specialist operational and technical requirements for R&D and laboratory uses.

Criterion (d) is overly prescriptive and fails to recognise that for many R&D and laboratory uses, mechanical ventilation and cooling are fundamental operational requirements necessary requirements rather than optional design choices.

To ensure the policy deliverable across a range of commercial development types, greater flexibility in the policy wording should be introduced. Accordingly, Criterion (d) should be amended as follows:

“Then look to full-building mechanical ventilation/cooling systems: Where appropriate the lowest carbon/energy options are selected and are only considered after all other elements of the hierarchy have been utilised”.

AstraZeneca supports the overall policy objectives, however the policy does not adequately recognise the specialist operational and technical requirements of R&D and laboratory uses. Consequently, the requirements of this policy are not always feasible or compatible with such operational requirements.

In particular, criterion (d) requires full-building mechanical ventilation/cooling systems: ensuring the lowest carbon/energy option are selected and are only considered after all other elements of the hierarchy have been utilised. This is overly prescriptive and may constrain the appropriate design and operation of specialist R&D development, as mechanical ventilation and cooling are often fundamental operational requirements rather than optional design choices.

Accordingly, it is recommended that the policy should therefore be amended to recognise that it cannot be imposed as a blanket requirement across all commercial development types, but to allow flexibility where operational, technical or building performance requirements justify an alternative approach. The policy requires balance; sustainability is of great important, but equally the economic, environmental and social benefits of a scheme are of equal importance.

The policy should be amended to provide greater flexibility in the application of its net zero operational emissions requirements. Rather than requiring all development to achieve net zero operational emissions, the policy should state that developments are "encouraged to" or "should seek to meet" the identified standards unless technical or viability considerations justify an alternative approach.

The requirements relating to Part A (Space Heating Demand) and Part B (Energy Use Intensity (EUI)) are particularly prescriptive, exceeding current Building Regulations standards and relying on evolving industry benchmarks. This policy requirement should be amended or removed.

AstraZeneca supports the overall policy objectives; however, the policy as drafted is overly prescriptive and should be amended to provide greater flexibility.

This objectives of the policy align with AZ's own global Ambition Zero Carbon strategy, which is pursuing science-based decarbonisation targets, with the aim of achieving carbon zero by 2030 and net zero by 2045.

However, the policy wording states that new development must achieve net zero operational emission. To ensure the policy remains effective and deliverable, this wording should be amended to state that developments are "encouraged to" or "should seek to meet the identified standards unless technical or viability reasons indicate otherwise". Without such flexibility, there is a risk that the policy could constrain the delivery of individual commercial developments that are part of a wider sustainability strategy and hinder sustainable growth delivery across Greater Cambridge.

Given that several of the requirements exceed current Building Regulations standards, a more proportionate approach is required to ensure the policy remains effective and deliverable.

• Part A (Space Heating Demand) requires development to achieve a space heating demand of 15-20 kWh/m² GIA/year. While this reflects best practice standards associated with LETI and Passivhaus, it goes beyond national requirements and will have significant design and cost implications. Requiring compliance in all circumstances is unrealistic and fails to recognise the practical challenges associated with delivering development across different sites.

• Part B (Energy Use Intensity (EUI)) requires offices, research facilities and other non-residential development to align with the UK Net Zero Carbon Buildings Standard 2030 EUI targets. This approach is similarly prescriptive and relies on evolving benchmarks that may change over time. The policy should therefore provide flexibility rather than requiring strict compliance with standards that continue to develop.

As drafted, the cumulative effect of these requirements risks undermining the viability and deliverability of commercial development, contrary to the objective of supporting sustainable economic growth across Greater Cambridge.

The policy should recognise that embodied carbon is one of a number of material planning considerations, however it should not be the determining factor in assessing redevelopment proposals. Greater weight should be given to site-specific circumstances and the wider benefits of redevelopment. In addition, the requirement for a full justification for demolition should be removed, as it imposes burdens beyond those established through national legislation. Criterion 2(d) should also be removed to ensure embodied carbon forms part of the overall planning balance rather than acting as a barrier to redevelopment.

AstraZeneca supports the objective of promoting sustainable resource use and reducing waste. However, Policy CC/CE as drafted places disproportionate weight on embodied carbon considerations, exceeds national policy requirements and may unnecessarily constrain redevelopment and regeneration opportunities. Accordingly, the policy should be amended to provide greater flexibility and better account for the wider sustainability benefits, viability and deliverability of development proposals.

In particular, Criterion 2 places disproportionate weight on embodied carbon considerations by introducing a strong presumption in favour of retaining existing buildings and requiring applicants to provide a full justification for demolition. Embodied carbon should not become the determining factor in assessing redevelopment proposals. The policy as drafted fails to adequately recognise the wider benefits that demolition and redevelopment can deliver including regeneration, improved building performance, economic growth, and enhanced long-term 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.

The requirement to provide a full justification for demolition also fails to adequately reflect the existing legislative framework 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. The policy therefore imposes an additional burden on development proposals that is not required by national legislation and should be removed or amended accordingly.

Criterion 2(d) is particularly onerous and should be removed so that embodied carbon is considered as one material planning consideration within the overall planning balance, rather than a determining test.

Summary of Recommended Changes
• Criterion 2: The 5,000sqm threshold should be increased, as it is unreasonably low and places responsibility on commercial developers to identify and address community infrastructure needs that should be established through the Council's strategic evidence base. The policy should provide greater certainty on potential requirements and costs to enable informed site acquisition and development decisions.

• Criterion 6: The policy should recognise existing community, cultural and recreational facilities already provided within employment developments and campuses. Requirements for additional provision or contributions should be clearly justified and directly related to the impacts of the development.

• Criterion 7 and 9: The policy should ensure that any requirements for sports and recreational facilities are based on demonstrable need and take account of existing provision, including facilities already available within employment campuses.

• Criterion 11: The requirement for infrastructure and facilities to be delivered during the "early phases" of development should be revised to allow delivery timings to be agreed on a case-by-case basis, taking account of the scale, nature and phasing of individual developments.

AstraZenca objects to Policy WS/NC as drafted on the grounds that it places disproportionate obligations on commercial development, lacks certainty regarding the scale of infrastructure requirements, and will likely adversely affect development viability and deliverability of commercial developments to come forward.

Criterion 2 requires employment development of more than 5,000sqm to be informed by detailed assessments of community needs and strategies to address those needs. The proposed threshold is unreasonably low and places the burden on small-scale commercial developers to assess and respond to community infrastructure needs that are more appropriately identified through the Council's evidence base in a coordinated manner. The policy provides insufficient certainty regarding the extent and scale of contributions that may be required, making it difficult to accurately assess development costs, viability and deliverability of development proposals. A particular challenge when deciding to purchase a site before entering the planning process; planning policy should give a high degree of certainty to assess a site pre-planning.

Criterion 6 is particularly onerous in requiring contributions towards community and cultural facilities based on prescribed floorspace standards, alongside the submission of Community and Cultural Plans. The policy fails to recognise existing community, cultural and recreational facilities already provided with many commercial and employment developments. Furthermore, it does not adequately justify why commercial proposals should be expected to deliver such significant social infrastructure. Employees do not generate demand for local community and cultural facilities in the same way as residential developments.

Criterion 7 and 9 similarly place unreasonable expectation on commercial developments to provide or contribute toward sports and recreational facilities. The policy does not adequately account for existing provision, on-site facilities already delivered as part of employment campuses, or whether a development proposal would generate a demonstrable need for additional facilities. Any requirement for on-site provision or financial contributions should be evidence-based, proportionate and directly related to the impacts arising from the development.

Criterion 11 requires services and facilities to be delivered during the "early phases" of development. This lacks clarity and provides limited certainty for the timing as to when infrastructure and facilities would be expected to come forward. To ensure the policy remains flexible, it is recommended that the policy should allow the timing of delivery to be determined on a case-by-case basis, taking into account the scale and phasing of the development.

• Criterion 1: The 1,000sqm threshold for requiring an Employment and Skills Plan should be increased. The current threshold captures relatively small developments and may impose unreasonable costs and administrative burdens.

• Criterion 4: The requirement that developments must secure 20% of construction jobs for local residents should be amended to require applicants to "seek to achieve" this target (emphasis added). This would better reflect labour market realities, skills availability and factors outside an applicant's control.

• Definition of Local Residents: The term "local residents" should be clearly defined within the policy, such as Greater Cambridge or an agreed catchment area, should be specified.

AstraZenca supports the objectives of the policy but objects to its current wording on the grounds that it is overly prescriptive and may create unreasonable burdens on commercial development coming forward. The policy wording should be amended to provide greater flexibility and ensure that its requirements are proportionate and deliverable.

Criterion 1 requires all new developments of 1,000 sqm or more to submit and implement an Employment and Skills Plan for both the construction and occupation phases of development. This requirement also applies to developments that form part of a larger development which would cumulatively exceed the 1,000sqm threshold. The proposed threshold is unreasonably low and risks imposing a disproportionate burden on smaller commercial developments. It is recommended that consideration be given to increasing the threshold to ensure the requirement is targeted towards developments that are capable of delivering meaningful employment and skills outcomes and of a scale that can reasonable afford and have in place an Employment and Skills coordinator post-scheme completion.

Criterion 4 states that development proposal must secure 20% of all jobs created by the construction phase of the development of local residents. Whilst the objective of maximising local employment opportunities is supported, the policy wording is overly rigid and fails to recognise that construction jobs will be influenced by labour market conditions and skills availability. The requirement should therefore be amended so that applicants are required to "seek to" achieve the 20% target, rather than "must" achieve it.

Furthermore, the term "local residents" is not defined, creating uncertainty regarding how the requirement would be applied and monitored. The policy should clearly define the relevant geographical area, such as Greater Cambridge or catchment area, to provide greater certainty and clarity.

Criterion 2 should be amended so that applicants are "encouraged" to achieve 20% BNG rather than "must" achieve it. The policy exceeds the nationally required 10% BNG standard and has not been sufficiently justified. The policy should also provide greater flexibility to account for site-specific constraints. Additionally, a blanket requirement for 20% BNG fails to recognise that some sites, particularly those that are constrained, may have limited opportunities to deliver biodiversity enhancements on- site. Requiring 20% BNG in all circumstances risks increasing development costs and adversely affecting viability and deliverability.

AstraZenca supports the objective of enhancing biodiversity; however, objects to Criterion 2 due to its requirements exceeding the nationally mandated 10% requirement, lack of sufficient flexibility and likelihood of adversely affecting the viability and deliverability of development. An overly prescriptive numerical approach to planning assessments erodes the ability to undertake a planning balance and ensure that a scheme is designed in the round as most appropriate for that development in that context.

Criterion 2 states that all major development must deliver a minimum of 20% biodiversity net gain (BNG) to be provided on-site where feasible, or off-site only where onsite opportunities have been evidenced to be exhausted. This requirement exceeds the nationally mandatory position of 10% BNG requirement and has not been sufficiently justified.

This blanket requirement for 20% BNG fails to account for sites that are located on constrained site where opportunities for on-site BNG provision may be limited. As drafted, the policy provides insufficient flexibility to account for these site specific constraints. Requiring a minimum of 20% BNG in all circumstances is therefore overly prescriptive and risks imposing additional costs that could affect viability and deliverability of development.

The policy should therefore be amended to align with national mandatory requirements of 10% BNG. The requirement should therefore be amended so that applicants can be “encouraged” to achieve the 20% target, rather than "must” achieve it. This approach ensure the policy remains aligned with national requirements whilst being effective and deliverable.

• Criterion 2: The requirement for all major developments to submit a Green Infrastructure Plan and, at outline stage, a Green Infrastructure Statement should be amended so that these documents are only required where proportionate to the scale, nature and complexity of the development. Many proposals will already be supported by landscape, biodiversity and masterplanning information, making additional assessments unnecessary.

• Criterion 3: The encouragement for developments of 5,000sqm GIA or more to seek accreditation under the Building with Nature Standard requires greater clarity and justification. The policy should provide further guidance on the purpose of the accreditation, its expected application, and the implications for applicants to ensure the requirement is understood and can be implemented consistently.

Astrazenca supports the overall objectives of the policy, however objects to the policy as drafted on the grounds that it introduces additional assessment and accreditation requirements that are insufficiently justified that may adversely affect viability.

Criterion 2 requires major developments to submit a Green Infrastructure Plan, and at outline planning stage a Green Infrastructure Statement. This represents an additional layer of assessment, which may result in unnecessary costs implications particularly where proposals are already supported by landscape, biodiversity and masterplanning information. The policy should be amended to ensure Green Infrastructure Plans and Statements are only required where proportionate to a major scale of development.

Criterion 3 encourages developments of 5,000sqm GIA or more to seek accreditation under the ‘building with nature standard’. However, this policy provides limited justification for this approach. The policy should provide further guidance and clarity regarding the expectations associated with the standard to ensure applicants can properly understand the requirement and its implications.