Greater Cambridge Local Plan: Proposed Submission

Part 1 of the policy should be amended to align with the supporting text by replacing "must" with "should" in relation to achieving Urban Greening Factor (UGF) requirements to accord with the supporting text.

Recommend that Policy BG/UGF is amended to state that ‘all policies should include the latest version of...’ and a viability clause is added such as ‘Where it can be demonstrated that achieving the target UGF score is not financially viable or technically feasible, a lower score may be accepted.’

AstraZeneca supports the objectives of this policy but objects to its current wording. There is an inherent policy contradiction within Policy BG/UGF which notes in part 1 that ‘all policies must include the latest version of....’, whilst the supporting information at Paragraph 5.46 states that ‘Major development proposals should contribute to the greening of Greater Cambridge by including urban greening’ (emphasis added). An objection is made to the use of ‘must’ within the policy wording and respectfully request that the Inspector amend this to ‘should’ in order to accord with the supporting text. 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.

The policy also fails to reflect site specific circumstances through the omission of a viability clause, which is required to ensure that sustainable development is always possible in the right locations. The policy should encourage developers to achieve the identified standards whilst taking account of site-specific circumstances, technical feasibility and viability considerations.

AstraZeneca therefore recommend that Policy BG/UGF is amended to state that ‘all policies should include the latest version of...’ and a viability clause is added such as ‘Where it can be demonstrated that achieving the target UGF score is not financially viable or technically feasible, a lower score may be accepted.’

• Review the 2,000sqm GIA threshold, as it is too low and captures a wide range of schemes where open space requirements may be disproportionate.
• Remove blanket requirement to provide 2.0ha of open space per 1,000 employees and replaced it with flexible, site-specific approach that accounts for type, location and scale of development.
• Recognition of existing open spaces provision within established employment campuses and commercial developments, ensuring developers are not required to provide additional open space where sufficient provision already exists.
• Clarification on how the policy applies to phased development and employment campuses is necessary to ensure open space can be considered across a wider masterplanned area rather than requiring each development plot to provide a standalone allocation.
• Include a viability mechanism to ensure that open space remains proprieties and does not affect the delivery of employment development.

AstraZeneca principally supports the objective of providing and enhancing open space. However, it objects to the policy as drafted as it fails to adequately recognise the specific characteristics of commercial development across Greater Cambridge.

Criterion 4 requires all commercial developments exceeding 2,000 sqm GIA to provide open space equivalent to 2.0 hectares per 1,000 employees. This requirement is overly prescriptive and risks undermining the efficient use of employment land. The 2,000 sqm threshold is low and the blanket requirement for 20 sqm of open space per employee is unlikely to be appropriate across all development types and locations. In particular, schemes in more constrained and urban locations may struggle to meet the requirement without comprising the efficient use of land, creating an efficient layout and achieving development viability.  

The policy also fails to adequately recognise existing open space provision or consider whether additional open space is necessary in all circumstances. For example some established employment campuses and commercial settings have been masterplanned to incorporate significant areas of green infrastructure and open space from the outset or are sited in locations that are well-served by open space. The policy could penalise developers/occupiers that have already provided open space in early phases. Requiring each individual development to provide further open space, irrespective of the existing provision, does not reflect a proportionate approach to development requirements.
Furthermore, the policy does not sufficiently recognise the range of open space solutions that may be appropriate in commercial environments including roof terraces, roof gardens, courtyards and other forms of amenity space that can contribute to employee wellbeing and reduce any demand arising to existing public opens from the occupation of new commercial floorspace.

The policy also provides limited clarity on how the requirement would apply to phased developments or future phases within larger employment campuses. This creates uncertainty for applicants and makes site planning, masterplanning and viability assessments more challenging.

The cumulative effect of these requirements risks placing an unnecessary burden on commercial development, contrary to the objective of supporting sustainable economic growth across Greater Cambridge.

The policy should be amended to recognise that, in appropriate and sustainable locations, taller buildings can make a positive contribution to economic growth, intensification and the optimisation of constrained sites, particularly within key employment and innovation clusters.

Criterion (e) currently requires applicants to demonstrates that there is “no adverse impact”. This sets an unrealistic and unduly restrictive test, as most development proposals generate some degree of impact. It should be replaced with "Applications must demonstrate that there is no unacceptable impact on neighbouring buildings and open space”.

The policy is overly restrictive and should be amended to provide greater flexibility and ensure that decisions are based on a balanced assessment of planning considerations.

The policy adopts a cautious approach to tall buildings and places significant limitation on opportunities to optimise development capacity. This is of particular concern for commercial development, where building upwards can be an effective way of accommodating growth, supporting intensification and making efficient use of constrained sites. The policy should be amended to clearly recognise that, in appropriate locations, taller buildings can make a positive contribution to sustainable development and economic growth.

Criterion e states that “applications must demonstrate that there is no adverse impact on neighbouring buildings and open space…” (emphasis added) . By its nature, development can give rise to some level of impact, and the planning system requires these impacts to be weighed against the benefits of a proposal. The current wording establishes an unreasonable "no adverse impact" test, rather than applying the balanced approach expected through the planning process. It must be changed to “no unacceptable impact”.

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

Conclusion:-
For the reasons above, and having regard to the accompanying viability evidence, Policy J/AW has not been shown to be positively prepared, justified, effective or consistent with national policy as required by paragraph 36 of the NPPF. The evidence does not demonstrate that the affordable workspace obligations can be delivered without prejudicing the viability and delivery of employment development central to the Greater Cambridge economy. The policy should therefore be significantly modified or deleted.

While the objective of increasing affordable workspace in Greater Cambridge is supported in principle, draft Policy J/AW does not meet the soundness tests in paragraph 36 of the NPPF. It has not been shown to be positively prepared, justified, effective or consistent with national policy and should therefore be substantially revised or deleted. This objection should be read with the accompanying expert ‘Bidwells Viability Representation’, which identifies significant shortcomings in the Councils’ evidence base.

Assessment of Whether the Policy is Justified:-
Paragraph 36 of the NPPF (2024) requires Local Plans to be justified, meaning they must represent an appropriate strategy, consider reasonable alternatives and be based on proportionate evidence.

The Councils have not demonstrated that Policy J/AW is the most appropriate strategy for increasing the amount of commercial floorspace affordable and available.

Although the evidence identifies a need for affordable workspace, it does not justify the policy’s most onerous requirements, including:
• 10% affordable workspace across a broad range of commercial development types;
• rental discounts of up to 30% below market rents;
• affordable provision secured in perpetuity;
• the reduction in the office and R&D threshold from circa 2,500sqm to 1,000sqm; and
• a largely uniform approach across materially different commercial markets.

The Iceni Affordable Workspace Study (2026), which forms part of the Council’s Evidence Base, acknowledges that comparable policies vary widely in thresholds, discounts and affordability periods, but does not explain why the Councils have selected one of the most onerous combinations. Reasonable alternatives, including higher thresholds, lower discounts, fixed-term affordability or more flexible viability-led mechanisms, do not appear to have been robustly assessed or discounted.

The Affordable Workspace Study relies heavily on London comparators, including Southwark, Brent, Waltham Forest and Wandsworth, and the draft policy appears consistent with Lambeth and Westminster approaches. This is flawed because London’s market, economic and geographic conditions differ significantly from Greater Cambridge, particularly South Cambridgeshire’s dispersed, rural and science-park-led economy. Oxford, the only non-London reference point, concerns Community Employment and Procurement Plans rather than affordable workspace. The read-across to Greater Cambridge has therefore not been adequately evidenced.

Oxford City Council’s Regulation 19 Proposed Submission Local Plan includes draft Policy E4 (Affordable Workspaces), which requires:
• development proposals delivering a net gain of 5,000sqm GIA of employment uses (E-Class) to produce an affordable workspace strategy for specified sites; and
• the strategy to set out the details, size, marketing, servicing, management and delivery of the space.

The Oxford approach is a more flexible and site-specific approach, enabling affordable workspace where it is justified by need and deliverability. Given Oxford’s strong R&D sector and similar affordability pressures for SMEs, it is more comparable to Greater Cambridge than the London examples. The Cambridge context would align more closely with Oxford’s emerging policy on this issue.

We acknowledge Oxford’s emerging Local Plan has not been examined yet and hence the policy has not yet been demonstrated to be sound yet. Nonetheless we contend this indicates a flexible, market led approach in a comparable context to Greater Cambridge, facing similar issues with regards to University spin outs, SME’s and supply and demand of commercial floorspace.

The in-perpetuity requirement is unjustified. The evidence recognises that comparable policies often use fixed periods yet gives no compelling reason for a permanent restriction in Greater Cambridge. A perpetual discount permanently suppresses rental income and investment value, unlike a time-limited obligation. Lambeth’s policy requirement for a scheme, for example, expires after 15 years.

The basis for reducing the office and R&D threshold to 1,000sqm is unclear. The evidence relies substantially on London benchmarking, which does not reflect Greater Cambridge’s dispersed science park, innovation campus and rural employment locations. The threshold therefore lacks a robust local evidential basis.

We also raise concern that the 1,000sqm threshold is arbitrary and risks creating a cliff-edge for development required to provide affordable workspace. We recommend a transitional and graduated approach should be introduced rather than a square cut off at 1,000sqm which may discourage developers from pursuing schemes which may trigger the 1,000sqm threshold but do not benefit from the economies of scale large and strategic schemes do which may be better placed to absorb affordable workspace requirements. Introducing such a low threshold with such severe policy implications will create a two-tier offer in the commercial market, with those schemes consented after the policy is introduced having a commercial disadvantage in an already competitive market. If the policy principle is supported, then a much higher threshold will support a softer transition such that only larger schemes that are more able to accommodate the impacts of the policy are first asked to accommodate affordable workspace.

Policy J/AW is not shown to represent the most appropriate strategy or to be supported by proportionate evidence. It is not justified under paragraph 36 of the NPPF (2024).

Assessment of Whether the Policy is Effective:-
Paragraph 36 of the NPPF (2024) requires Local Plan policies to be effective and deliverable over the plan period.

The Councils have not shown that Policy J/AW can be delivered without harming the employment development needed to support Greater Cambridge’s growth ambitions.

Policy J/AW would also sit alongside biodiversity net gain, net-zero carbon requirements, transport mitigation, open space, green infrastructure, Section 106 contributions and the emerging Community Infrastructure Levy regime.

Although some requirements have been assessed individually, the evidence does not convincingly demonstrate that commercial development can absorb the cumulative cost of Local Plan and regulatory obligations across the Plan area.

This is particularly important in current market conditions. Greater Cambridge’s office, laboratory and life sciences sectors are undergoing market adjustment, as set out in the Viability Representation prepared by Bidwells. The Councils’ evidence acknowledges changing occupier demand, increased laboratory vacancy, financing pressures and economic uncertainty. In this context, any policy that permanently reduces investment returns risks suppressing development activity and undermining delivery.

The viability representation identifies substantial concerns with the Local Plan Viability Assessment, including assumptions on rents, yields, benchmark land values, build costs, developer return and brownfield redevelopment costs. These concerns call into question the robustness of the viability and deliverability conclusions.

The Councils have therefore not shown that the policy will be deliverable across the commercial schemes to which it would apply. There remains a significant risk that it will reduce delivery of office, R&D, laboratory and industrial floorspace during the Plan period.

It should be noted that this requirement is being introduced at the same time as Employment and Skills Plans which we support. We consider this mechanism to be an effective, meaningful way to help individuals in the employment market. In comparison we query the overall effectiveness of affordable workspace provisions on individuals in the job market.

As drafted, the policy risks threatening commercial viability and reducing investment in Greater Cambridge. Contrary to its aim, it could reduce overall affordable workspace provision. The policy is therefore not effective.

Assessment of Whether the Policy is Consistent with National Policy:-
Chapter 6 of the NPPF (2024) promotes a strong, competitive economy. Paragraph 85 requires planning policies to give significant weight to economic growth and to maintain conditions for investment and sustainable development.

The NPPF also makes clear that planning policies should not undermine viability or impose burdens that threaten delivery.

Policy J/AW is inflexible and does not adequately respond to changing market conditions. Its affordable workspace requirement, discount levels and affordability period are fixed, with viability considerations focused mainly on payment in lieu rather than the principle of provision. This rigidity is inconsistent with the NPPF’s emphasis on delivery, flexibility and maintaining viability.

The Councils have not justified why an in-perpetuity requirement is necessary, or why the policy should apply unchanged regardless of future economic, occupational or investment conditions. Commercial markets fluctuate, and policy must be able to respond.

Without robust evidence that the requirements can be absorbed without harming delivery, the policy is not consistent with national objectives for economic growth, productivity and investment.

Assessment of Whether the Policy has been Positively Prepared:-
The Local Plan must be positively prepared and provide a strategy capable of meeting identified needs, in accordance with paragraph 36a of the NPPF.

Greater Cambridge’s economic success depends on continued employment floorspace delivery and its global strength in life sciences, R&D, biomedical and IT sectors. The growth strategy relies on offices, laboratories, innovation space and industrial accommodation across a range of locations.

Although Policy J/AW seeks to address affordable workspace need, it risks undermining the wider commercial floorspace delivery on which economic growth depends, given the concerns in the Viability Representation. Additional obligations may reduce investment, delay delivery and discourage employment-land redevelopment, particularly on constrained brownfield sites affected by contamination and remediation costs.
If the policy reduces overall commercial development delivery, it would frustrate rather than support the Plan’s wider economic objectives and cannot reasonably be regarded as positively prepared.

A particular concern is that many of the newly proposed policy requirements are drafted as generic obligations, with limited regard to site-specific circumstances, viability considerations or demonstrable local need.

Greater flexibility and clearer mechanisms for policy aspirations against deliverability and viability should be incorporated. This is particularly important for sites already progressing through the development pipeline, where land transactions and investment decisions could not reasonably have anticipated such a substantial increase in policy requirements (and potentially CIL liabilities).

Paragraphs 8 to 10 of Policy I/ID should be strengthened to confirm that viability considerations apply not only to direct financial costs but also to the practical implications of policy requirements.

There is an extensive policy burden within the Draft Plan, representing a significant increase compared with both the 2018 Adopted Local Plans and the 2026 NPPF (in relation to development management policies).

Whilst many of the individual policies are proposed for valid reasons and support Greater Cambridge's ambition to achieve high quality development, their cumulative effect presents a significant risk to the deliverability of future schemes. For example, the Draft Local Plan introduces a number of new policy requirements, including:
• Net Zero Operational Carbon (CC/NZ);
• Supporting a circular economy and sustainable resource use, including a greater emphasis on retaining existing buildings, which can be complex and costly to deliver, may reduce overall floorspace, and can affect market attractiveness (CC/CE);
• Biodiversity Net Gain of 20% (BG/BN);
• Accreditation under the Building with Nature Standards (BG/GI);
• Urban Greening Factor requirements (BG/UGF);
• Provision and enhancement of open space within commercial schemes (BG/EO); and
• Affordable Workspace requirements (J/AW).

These requirements sit alongside the already high expectations for development quality within Greater Cambridge, including standards relating to public realm, landscaping, architecture, materials, public art and cycling infrastructure. Whilst these are positive and important aspects of successful development, they contribute to a higher cost base for development in Greater Cambridge than in many competing locations.

A particular concern is that many of the newly proposed policy requirements are drafted as generic obligations, with limited regard to site-specific circumstances, viability considerations or demonstrable local need. The cumulative impact of these requirements risks undermining the delivery of development, particularly during the first five to ten years of the Plan period. This issue is likely to be most acute for sites already under contract or progressing through the development pipeline, where land transactions and investment decisions could not reasonably have anticipated such a substantial increase in policy requirements (and potentially CIL liabilities).

Paragraphs 8 to 10 of Policy I/ID appropriately recognise viability as a material consideration in the planning process. However, viability can be affected not only by direct financial costs, but also by the practical operation of policy requirements. For example, mandating affordable workspace within smaller commercial schemes may present significant delivery challenges, whilst requiring the retention of existing buildings may reduce market appeal and limit the flexibility needed to meet occupier requirements.

Given the number of fixed and broadly applicable policy requirements proposed, the Plan should provide a clear mechanism for balancing policy aspirations against deliverability and viability considerations. Such flexibility is necessary to ensure that high quality, commercially attractive and sustainable development can continue to come forward, supporting Greater Cambridge's growth objectives while delivering buildings and places capable of meeting long-term market needs.

A particular concern is that many of the newly proposed policy requirements are drafted as generic obligations, with limited regard to site-specific circumstances, viability considerations or demonstrable local need.

Greater flexibility and clearer mechanisms for policy aspirations against deliverability and viability should be incorporated. This is particularly important for sites already progressing through the development pipeline, where land transactions and investment decisions could not reasonably have anticipated such a substantial increase in policy requirements (and potentially CIL liabilities).

Paragraphs 8 to 10 of Policy I/ID should be strengthened to confirm that viability considerations apply not only to direct financial costs but also to the practical implications of policy requirements.

There is an extensive policy burden within the Draft Plan, representing a significant increase compared with both the 2018 Adopted Local Plans and the 2026 NPPF (in relation to development management policies).

Whilst many of the individual policies are proposed for valid reasons and support Greater Cambridge's ambition to achieve high quality development, their cumulative effect presents a significant risk to the deliverability of future schemes. For example, the Draft Local Plan introduces a number of new policy requirements, including:
• Net Zero Operational Carbon (CC/NZ);
• Supporting a circular economy and sustainable resource use, including a greater emphasis on retaining existing buildings, which can be complex and costly to deliver, may reduce overall floorspace, and can affect market attractiveness (CC/CE);
• Biodiversity Net Gain of 20% (BG/BN);
• Accreditation under the Building with Nature Standards (BG/GI);
• Urban Greening Factor requirements (BG/UGF);
• Provision and enhancement of open space within commercial schemes (BG/EO); and
• Affordable Workspace requirements (J/AW).

These requirements sit alongside the already high expectations for development quality within Greater Cambridge, including standards relating to public realm, landscaping, architecture, materials, public art and cycling infrastructure. Whilst these are positive and important aspects of successful development, they contribute to a higher cost base for development in Greater Cambridge than in many competing locations.

A particular concern is that many of the newly proposed policy requirements are drafted as generic obligations, with limited regard to site-specific circumstances, viability considerations or demonstrable local need. The cumulative impact of these requirements risks undermining the delivery of development, particularly during the first five to ten years of the Plan period. This issue is likely to be most acute for sites already under contract or progressing through the development pipeline, where land transactions and investment decisions could not reasonably have anticipated such a substantial increase in policy requirements (and potentially CIL liabilities).

Paragraphs 8 to 10 of Policy I/ID appropriately recognise viability as a material consideration in the planning process. However, viability can be affected not only by direct financial costs, but also by the practical operation of policy requirements. For example, mandating affordable workspace within smaller commercial schemes may present significant delivery challenges, whilst requiring the retention of existing buildings may reduce market appeal and limit the flexibility needed to meet occupier requirements.

Given the number of fixed and broadly applicable policy requirements proposed, the Plan should provide a clear mechanism for balancing policy aspirations against deliverability and viability considerations. Such flexibility is necessary to ensure that high quality, commercially attractive and sustainable development can continue to come forward, supporting Greater Cambridge's growth objectives while delivering buildings and places capable of meeting long-term market needs.

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

Conclusion:-
For the reasons above, and having regard to the accompanying viability evidence, Policy J/AW has not been shown to be positively prepared, justified, effective or consistent with national policy as required by paragraph 36 of the NPPF. The evidence does not demonstrate that the affordable workspace obligations can be delivered without prejudicing the viability and delivery of employment development central to the Greater Cambridge economy. The policy should therefore be significantly modified or deleted.

While the objective of increasing affordable workspace in Greater Cambridge is supported in principle, draft Policy J/AW does not meet the soundness tests in paragraph 36 of the NPPF. It has not been shown to be positively prepared, justified, effective or consistent with national policy and should therefore be substantially revised or deleted. This objection should be read with the accompanying expert ‘Bidwells Viability Representation’, which identifies significant shortcomings in the Councils’ evidence base.

Assessment of Whether the Policy is Justified:-
Paragraph 36 of the NPPF (2024) requires Local Plans to be justified, meaning they must represent an appropriate strategy, consider reasonable alternatives and be based on proportionate evidence.

The Councils have not demonstrated that Policy J/AW is the most appropriate strategy for increasing the amount of commercial floorspace affordable and available.

Although the evidence identifies a need for affordable workspace, it does not justify the policy’s most onerous requirements, including:
• 10% affordable workspace across a broad range of commercial development types;
• rental discounts of up to 30% below market rents;
• affordable provision secured in perpetuity;
• the reduction in the office and R&D threshold from circa 2,500sqm to 1,000sqm; and
• a largely uniform approach across materially different commercial markets.

The Iceni Affordable Workspace Study (2026), which forms part of the Council’s Evidence Base, acknowledges that comparable policies vary widely in thresholds, discounts and affordability periods, but does not explain why the Councils have selected one of the most onerous combinations. Reasonable alternatives, including higher thresholds, lower discounts, fixed-term affordability or more flexible viability-led mechanisms, do not appear to have been robustly assessed or discounted.

The Affordable Workspace Study relies heavily on London comparators, including Southwark, Brent, Waltham Forest and Wandsworth, and the draft policy appears consistent with Lambeth and Westminster approaches. This is flawed because London’s market, economic and geographic conditions differ significantly from Greater Cambridge, particularly South Cambridgeshire’s dispersed, rural and science-park-led economy. Oxford, the only non-London reference point, concerns Community Employment and Procurement Plans rather than affordable workspace. The read-across to Greater Cambridge has therefore not been adequately evidenced.

Oxford City Council’s Regulation 19 Proposed Submission Local Plan includes draft Policy E4 (Affordable Workspaces), which requires:
• development proposals delivering a net gain of 5,000sqm GIA of employment uses (E-Class) to produce an affordable workspace strategy for specified sites; and
• the strategy to set out the details, size, marketing, servicing, management and delivery of the space.

The Oxford approach is a more flexible and site-specific approach, enabling affordable workspace where it is justified by need and deliverability. Given Oxford’s strong R&D sector and similar affordability pressures for SMEs, it is more comparable to Greater Cambridge than the London examples. The Cambridge context would align more closely with Oxford’s emerging policy on this issue.

We acknowledge Oxford’s emerging Local Plan has not been examined yet and hence the policy has not yet been demonstrated to be sound yet. Nonetheless we contend this indicates a flexible, market led approach in a comparable context to Greater Cambridge, facing similar issues with regards to University spin outs, SME’s and supply and demand of commercial floorspace.

The in-perpetuity requirement is unjustified. The evidence recognises that comparable policies often use fixed periods yet gives no compelling reason for a permanent restriction in Greater Cambridge. A perpetual discount permanently suppresses rental income and investment value, unlike a time-limited obligation. Lambeth’s policy requirement for a scheme, for example, expires after 15 years.

The basis for reducing the office and R&D threshold to 1,000sqm is unclear. The evidence relies substantially on London benchmarking, which does not reflect Greater Cambridge’s dispersed science park, innovation campus and rural employment locations. The threshold therefore lacks a robust local evidential basis.

We also raise concern that the 1,000sqm threshold is arbitrary and risks creating a cliff-edge for development required to provide affordable workspace. We recommend a transitional and graduated approach should be introduced rather than a square cut off at 1,000sqm which may discourage developers from pursuing schemes which may trigger the 1,000sqm threshold but do not benefit from the economies of scale large and strategic schemes do which may be better placed to absorb affordable workspace requirements. Introducing such a low threshold with such severe policy implications will create a two-tier offer in the commercial market, with those schemes consented after the policy is introduced having a commercial disadvantage in an already competitive market. If the policy principle is supported, then a much higher threshold will support a softer transition such that only larger schemes that are more able to accommodate the impacts of the policy are first asked to accommodate affordable workspace.

Policy J/AW is not shown to represent the most appropriate strategy or to be supported by proportionate evidence. It is not justified under paragraph 36 of the NPPF (2024).

Assessment of Whether the Policy is Effective:-
Paragraph 36 of the NPPF (2024) requires Local Plan policies to be effective and deliverable over the plan period.

The Councils have not shown that Policy J/AW can be delivered without harming the employment development needed to support Greater Cambridge’s growth ambitions.

Policy J/AW would also sit alongside biodiversity net gain, net-zero carbon requirements, transport mitigation, open space, green infrastructure, Section 106 contributions and the emerging Community Infrastructure Levy regime.

Although some requirements have been assessed individually, the evidence does not convincingly demonstrate that commercial development can absorb the cumulative cost of Local Plan and regulatory obligations across the Plan area.

This is particularly important in current market conditions. Greater Cambridge’s office, laboratory and life sciences sectors are undergoing market adjustment, as set out in the Viability Representation prepared by Bidwells. The Councils’ evidence acknowledges changing occupier demand, increased laboratory vacancy, financing pressures and economic uncertainty. In this context, any policy that permanently reduces investment returns risks suppressing development activity and undermining delivery.

The viability representation identifies substantial concerns with the Local Plan Viability Assessment, including assumptions on rents, yields, benchmark land values, build costs, developer return and brownfield redevelopment costs. These concerns call into question the robustness of the viability and deliverability conclusions.

The Councils have therefore not shown that the policy will be deliverable across the commercial schemes to which it would apply. There remains a significant risk that it will reduce delivery of office, R&D, laboratory and industrial floorspace during the Plan period.

It should be noted that this requirement is being introduced at the same time as Employment and Skills Plans which we support. We consider this mechanism to be an effective, meaningful way to help individuals in the employment market. In comparison we query the overall effectiveness of affordable workspace provisions on individuals in the job market.

As drafted, the policy risks threatening commercial viability and reducing investment in Greater Cambridge. Contrary to its aim, it could reduce overall affordable workspace provision. The policy is therefore not effective.

Assessment of Whether the Policy is Consistent with National Policy:-
Chapter 6 of the NPPF (2024) promotes a strong, competitive economy. Paragraph 85 requires planning policies to give significant weight to economic growth and to maintain conditions for investment and sustainable development.

The NPPF also makes clear that planning policies should not undermine viability or impose burdens that threaten delivery.

Policy J/AW is inflexible and does not adequately respond to changing market conditions. Its affordable workspace requirement, discount levels and affordability period are fixed, with viability considerations focused mainly on payment in lieu rather than the principle of provision. This rigidity is inconsistent with the NPPF’s emphasis on delivery, flexibility and maintaining viability.

The Councils have not justified why an in-perpetuity requirement is necessary, or why the policy should apply unchanged regardless of future economic, occupational or investment conditions. Commercial markets fluctuate, and policy must be able to respond.

Without robust evidence that the requirements can be absorbed without harming delivery, the policy is not consistent with national objectives for economic growth, productivity and investment.

Assessment of Whether the Policy has been Positively Prepared:-
The Local Plan must be positively prepared and provide a strategy capable of meeting identified needs, in accordance with paragraph 36a of the NPPF.

Greater Cambridge’s economic success depends on continued employment floorspace delivery and its global strength in life sciences, R&D, biomedical and IT sectors. The growth strategy relies on offices, laboratories, innovation space and industrial accommodation across a range of locations.

Although Policy J/AW seeks to address affordable workspace need, it risks undermining the wider commercial floorspace delivery on which economic growth depends, given the concerns in the Viability Representation. Additional obligations may reduce investment, delay delivery and discourage employment-land redevelopment, particularly on constrained brownfield sites affected by contamination and remediation costs.
If the policy reduces overall commercial development delivery, it would frustrate rather than support the Plan’s wider economic objectives and cannot reasonably be regarded as positively prepared.

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

Conclusion:-
For the reasons above, and having regard to the accompanying viability evidence, Policy J/AW has not been shown to be positively prepared, justified, effective or consistent with national policy as required by paragraph 36 of the NPPF. The evidence does not demonstrate that the affordable workspace obligations can be delivered without prejudicing the viability and delivery of employment development central to the Greater Cambridge economy. The policy should therefore be significantly modified or deleted.

While the objective of increasing affordable workspace in Greater Cambridge is supported in principle, draft Policy J/AW does not meet the soundness tests in paragraph 36 of the NPPF. It has not been shown to be positively prepared, justified, effective or consistent with national policy and should therefore be substantially revised or deleted. This objection should be read with the accompanying expert ‘Bidwells Viability Representation’, which identifies significant shortcomings in the Councils’ evidence base.

Assessment of Whether the Policy is Justified:-
Paragraph 36 of the NPPF (2024) requires Local Plans to be justified, meaning they must represent an appropriate strategy, consider reasonable alternatives and be based on proportionate evidence.

The Councils have not demonstrated that Policy J/AW is the most appropriate strategy for increasing the amount of commercial floorspace affordable and available.

Although the evidence identifies a need for affordable workspace, it does not justify the policy’s most onerous requirements, including:
• 10% affordable workspace across a broad range of commercial development types;
• rental discounts of up to 30% below market rents;
• affordable provision secured in perpetuity;
• the reduction in the office and R&D threshold from circa 2,500sqm to 1,000sqm; and
• a largely uniform approach across materially different commercial markets.

The Iceni Affordable Workspace Study (2026), which forms part of the Council’s Evidence Base, acknowledges that comparable policies vary widely in thresholds, discounts and affordability periods, but does not explain why the Councils have selected one of the most onerous combinations. Reasonable alternatives, including higher thresholds, lower discounts, fixed-term affordability or more flexible viability-led mechanisms, do not appear to have been robustly assessed or discounted.

The Affordable Workspace Study relies heavily on London comparators, including Southwark, Brent, Waltham Forest and Wandsworth, and the draft policy appears consistent with Lambeth and Westminster approaches. This is flawed because London’s market, economic and geographic conditions differ significantly from Greater Cambridge, particularly South Cambridgeshire’s dispersed, rural and science-park-led economy. Oxford, the only non-London reference point, concerns Community Employment and Procurement Plans rather than affordable workspace. The read-across to Greater Cambridge has therefore not been adequately evidenced.

Oxford City Council’s Regulation 19 Proposed Submission Local Plan includes draft Policy E4 (Affordable Workspaces), which requires:
• development proposals delivering a net gain of 5,000sqm GIA of employment uses (E-Class) to produce an affordable workspace strategy for specified sites; and
• the strategy to set out the details, size, marketing, servicing, management and delivery of the space.

The Oxford approach is a more flexible and site-specific approach, enabling affordable workspace where it is justified by need and deliverability. Given Oxford’s strong R&D sector and similar affordability pressures for SMEs, it is more comparable to Greater Cambridge than the London examples. The Cambridge context would align more closely with Oxford’s emerging policy on this issue.

We acknowledge Oxford’s emerging Local Plan has not been examined yet and hence the policy has not yet been demonstrated to be sound yet. Nonetheless we contend this indicates a flexible, market led approach in a comparable context to Greater Cambridge, facing similar issues with regards to University spin outs, SME’s and supply and demand of commercial floorspace.

The in-perpetuity requirement is unjustified. The evidence recognises that comparable policies often use fixed periods yet gives no compelling reason for a permanent restriction in Greater Cambridge. A perpetual discount permanently suppresses rental income and investment value, unlike a time-limited obligation. Lambeth’s policy requirement for a scheme, for example, expires after 15 years.

The basis for reducing the office and R&D threshold to 1,000sqm is unclear. The evidence relies substantially on London benchmarking, which does not reflect Greater Cambridge’s dispersed science park, innovation campus and rural employment locations. The threshold therefore lacks a robust local evidential basis.

We also raise concern that the 1,000sqm threshold is arbitrary and risks creating a cliff-edge for development required to provide affordable workspace. We recommend a transitional and graduated approach should be introduced rather than a square cut off at 1,000sqm which may discourage developers from pursuing schemes which may trigger the 1,000sqm threshold but do not benefit from the economies of scale large and strategic schemes do which may be better placed to absorb affordable workspace requirements. Introducing such a low threshold with such severe policy implications will create a two-tier offer in the commercial market, with those schemes consented after the policy is introduced having a commercial disadvantage in an already competitive market. If the policy principle is supported, then a much higher threshold will support a softer transition such that only larger schemes that are more able to accommodate the impacts of the policy are first asked to accommodate affordable workspace.

Policy J/AW is not shown to represent the most appropriate strategy or to be supported by proportionate evidence. It is not justified under paragraph 36 of the NPPF (2024).

Assessment of Whether the Policy is Effective:-
Paragraph 36 of the NPPF (2024) requires Local Plan policies to be effective and deliverable over the plan period.

The Councils have not shown that Policy J/AW can be delivered without harming the employment development needed to support Greater Cambridge’s growth ambitions.

Policy J/AW would also sit alongside biodiversity net gain, net-zero carbon requirements, transport mitigation, open space, green infrastructure, Section 106 contributions and the emerging Community Infrastructure Levy regime.

Although some requirements have been assessed individually, the evidence does not convincingly demonstrate that commercial development can absorb the cumulative cost of Local Plan and regulatory obligations across the Plan area.

This is particularly important in current market conditions. Greater Cambridge’s office, laboratory and life sciences sectors are undergoing market adjustment, as set out in the Viability Representation prepared by Bidwells. The Councils’ evidence acknowledges changing occupier demand, increased laboratory vacancy, financing pressures and economic uncertainty. In this context, any policy that permanently reduces investment returns risks suppressing development activity and undermining delivery.

The viability representation identifies substantial concerns with the Local Plan Viability Assessment, including assumptions on rents, yields, benchmark land values, build costs, developer return and brownfield redevelopment costs. These concerns call into question the robustness of the viability and deliverability conclusions.

The Councils have therefore not shown that the policy will be deliverable across the commercial schemes to which it would apply. There remains a significant risk that it will reduce delivery of office, R&D, laboratory and industrial floorspace during the Plan period.

It should be noted that this requirement is being introduced at the same time as Employment and Skills Plans which we support. We consider this mechanism to be an effective, meaningful way to help individuals in the employment market. In comparison we query the overall effectiveness of affordable workspace provisions on individuals in the job market.

As drafted, the policy risks threatening commercial viability and reducing investment in Greater Cambridge. Contrary to its aim, it could reduce overall affordable workspace provision. The policy is therefore not effective.

Assessment of Whether the Policy is Consistent with National Policy:-
Chapter 6 of the NPPF (2024) promotes a strong, competitive economy. Paragraph 85 requires planning policies to give significant weight to economic growth and to maintain conditions for investment and sustainable development.

The NPPF also makes clear that planning policies should not undermine viability or impose burdens that threaten delivery.

Policy J/AW is inflexible and does not adequately respond to changing market conditions. Its affordable workspace requirement, discount levels and affordability period are fixed, with viability considerations focused mainly on payment in lieu rather than the principle of provision. This rigidity is inconsistent with the NPPF’s emphasis on delivery, flexibility and maintaining viability.

The Councils have not justified why an in-perpetuity requirement is necessary, or why the policy should apply unchanged regardless of future economic, occupational or investment conditions. Commercial markets fluctuate, and policy must be able to respond.

Without robust evidence that the requirements can be absorbed without harming delivery, the policy is not consistent with national objectives for economic growth, productivity and investment.

Assessment of Whether the Policy has been Positively Prepared:-
The Local Plan must be positively prepared and provide a strategy capable of meeting identified needs, in accordance with paragraph 36a of the NPPF.

Greater Cambridge’s economic success depends on continued employment floorspace delivery and its global strength in life sciences, R&D, biomedical and IT sectors. The growth strategy relies on offices, laboratories, innovation space and industrial accommodation across a range of locations.

Although Policy J/AW seeks to address affordable workspace need, it risks undermining the wider commercial floorspace delivery on which economic growth depends, given the concerns in the Viability Representation. Additional obligations may reduce investment, delay delivery and discourage employment-land redevelopment, particularly on constrained brownfield sites affected by contamination and remediation costs.
If the policy reduces overall commercial development delivery, it would frustrate rather than support the Plan’s wider economic objectives and cannot reasonably be regarded as positively prepared.

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

Conclusion:-
For the reasons above, and having regard to the accompanying viability evidence, Policy J/AW has not been shown to be positively prepared, justified, effective or consistent with national policy as required by paragraph 36 of the NPPF. The evidence does not demonstrate that the affordable workspace obligations can be delivered without prejudicing the viability and delivery of employment development central to the Greater Cambridge economy. The policy should therefore be significantly modified or deleted.

While the objective of increasing affordable workspace in Greater Cambridge is supported in principle, draft Policy J/AW does not meet the soundness tests in paragraph 36 of the NPPF. It has not been shown to be positively prepared, justified, effective or consistent with national policy and should therefore be substantially revised or deleted. This objection should be read with the accompanying expert ‘Bidwells Viability Representation’, which identifies significant shortcomings in the Councils’ evidence base.

Assessment of Whether the Policy is Justified:-
Paragraph 36 of the NPPF (2024) requires Local Plans to be justified, meaning they must represent an appropriate strategy, consider reasonable alternatives and be based on proportionate evidence.

The Councils have not demonstrated that Policy J/AW is the most appropriate strategy for increasing the amount of commercial floorspace affordable and available.

Although the evidence identifies a need for affordable workspace, it does not justify the policy’s most onerous requirements, including:
• 10% affordable workspace across a broad range of commercial development types;
• rental discounts of up to 30% below market rents;
• affordable provision secured in perpetuity;
• the reduction in the office and R&D threshold from circa 2,500sqm to 1,000sqm; and
• a largely uniform approach across materially different commercial markets.

The Iceni Affordable Workspace Study (2026), which forms part of the Council’s Evidence Base, acknowledges that comparable policies vary widely in thresholds, discounts and affordability periods, but does not explain why the Councils have selected one of the most onerous combinations. Reasonable alternatives, including higher thresholds, lower discounts, fixed-term affordability or more flexible viability-led mechanisms, do not appear to have been robustly assessed or discounted.

The Affordable Workspace Study relies heavily on London comparators, including Southwark, Brent, Waltham Forest and Wandsworth, and the draft policy appears consistent with Lambeth and Westminster approaches. This is flawed because London’s market, economic and geographic conditions differ significantly from Greater Cambridge, particularly South Cambridgeshire’s dispersed, rural and science-park-led economy. Oxford, the only non-London reference point, concerns Community Employment and Procurement Plans rather than affordable workspace. The read-across to Greater Cambridge has therefore not been adequately evidenced.

Oxford City Council’s Regulation 19 Proposed Submission Local Plan includes draft Policy E4 (Affordable Workspaces), which requires:
• development proposals delivering a net gain of 5,000sqm GIA of employment uses (E-Class) to produce an affordable workspace strategy for specified sites; and
• the strategy to set out the details, size, marketing, servicing, management and delivery of the space.

The Oxford approach is a more flexible and site-specific approach, enabling affordable workspace where it is justified by need and deliverability. Given Oxford’s strong R&D sector and similar affordability pressures for SMEs, it is more comparable to Greater Cambridge than the London examples. The Cambridge context would align more closely with Oxford’s emerging policy on this issue.

We acknowledge Oxford’s emerging Local Plan has not been examined yet and hence the policy has not yet been demonstrated to be sound yet. Nonetheless we contend this indicates a flexible, market led approach in a comparable context to Greater Cambridge, facing similar issues with regards to University spin outs, SME’s and supply and demand of commercial floorspace.

The in-perpetuity requirement is unjustified. The evidence recognises that comparable policies often use fixed periods yet gives no compelling reason for a permanent restriction in Greater Cambridge. A perpetual discount permanently suppresses rental income and investment value, unlike a time-limited obligation. Lambeth’s policy requirement for a scheme, for example, expires after 15 years.

The basis for reducing the office and R&D threshold to 1,000sqm is unclear. The evidence relies substantially on London benchmarking, which does not reflect Greater Cambridge’s dispersed science park, innovation campus and rural employment locations. The threshold therefore lacks a robust local evidential basis.

We also raise concern that the 1,000sqm threshold is arbitrary and risks creating a cliff-edge for development required to provide affordable workspace. We recommend a transitional and graduated approach should be introduced rather than a square cut off at 1,000sqm which may discourage developers from pursuing schemes which may trigger the 1,000sqm threshold but do not benefit from the economies of scale large and strategic schemes do which may be better placed to absorb affordable workspace requirements. Introducing such a low threshold with such severe policy implications will create a two-tier offer in the commercial market, with those schemes consented after the policy is introduced having a commercial disadvantage in an already competitive market. If the policy principle is supported, then a much higher threshold will support a softer transition such that only larger schemes that are more able to accommodate the impacts of the policy are first asked to accommodate affordable workspace.

Policy J/AW is not shown to represent the most appropriate strategy or to be supported by proportionate evidence. It is not justified under paragraph 36 of the NPPF (2024).

Assessment of Whether the Policy is Effective:-
Paragraph 36 of the NPPF (2024) requires Local Plan policies to be effective and deliverable over the plan period.

The Councils have not shown that Policy J/AW can be delivered without harming the employment development needed to support Greater Cambridge’s growth ambitions.

Policy J/AW would also sit alongside biodiversity net gain, net-zero carbon requirements, transport mitigation, open space, green infrastructure, Section 106 contributions and the emerging Community Infrastructure Levy regime.

Although some requirements have been assessed individually, the evidence does not convincingly demonstrate that commercial development can absorb the cumulative cost of Local Plan and regulatory obligations across the Plan area.

This is particularly important in current market conditions. Greater Cambridge’s office, laboratory and life sciences sectors are undergoing market adjustment, as set out in the Viability Representation prepared by Bidwells. The Councils’ evidence acknowledges changing occupier demand, increased laboratory vacancy, financing pressures and economic uncertainty. In this context, any policy that permanently reduces investment returns risks suppressing development activity and undermining delivery.

The viability representation identifies substantial concerns with the Local Plan Viability Assessment, including assumptions on rents, yields, benchmark land values, build costs, developer return and brownfield redevelopment costs. These concerns call into question the robustness of the viability and deliverability conclusions.

The Councils have therefore not shown that the policy will be deliverable across the commercial schemes to which it would apply. There remains a significant risk that it will reduce delivery of office, R&D, laboratory and industrial floorspace during the Plan period.

It should be noted that this requirement is being introduced at the same time as Employment and Skills Plans which we support. We consider this mechanism to be an effective, meaningful way to help individuals in the employment market. In comparison we query the overall effectiveness of affordable workspace provisions on individuals in the job market.

As drafted, the policy risks threatening commercial viability and reducing investment in Greater Cambridge. Contrary to its aim, it could reduce overall affordable workspace provision. The policy is therefore not effective.

Assessment of Whether the Policy is Consistent with National Policy:-
Chapter 6 of the NPPF (2024) promotes a strong, competitive economy. Paragraph 85 requires planning policies to give significant weight to economic growth and to maintain conditions for investment and sustainable development.

The NPPF also makes clear that planning policies should not undermine viability or impose burdens that threaten delivery.

Policy J/AW is inflexible and does not adequately respond to changing market conditions. Its affordable workspace requirement, discount levels and affordability period are fixed, with viability considerations focused mainly on payment in lieu rather than the principle of provision. This rigidity is inconsistent with the NPPF’s emphasis on delivery, flexibility and maintaining viability.

The Councils have not justified why an in-perpetuity requirement is necessary, or why the policy should apply unchanged regardless of future economic, occupational or investment conditions. Commercial markets fluctuate, and policy must be able to respond.

Without robust evidence that the requirements can be absorbed without harming delivery, the policy is not consistent with national objectives for economic growth, productivity and investment.

Assessment of Whether the Policy has been Positively Prepared:-
The Local Plan must be positively prepared and provide a strategy capable of meeting identified needs, in accordance with paragraph 36a of the NPPF.

Greater Cambridge’s economic success depends on continued employment floorspace delivery and its global strength in life sciences, R&D, biomedical and IT sectors. The growth strategy relies on offices, laboratories, innovation space and industrial accommodation across a range of locations.

Although Policy J/AW seeks to address affordable workspace need, it risks undermining the wider commercial floorspace delivery on which economic growth depends, given the concerns in the Viability Representation. Additional obligations may reduce investment, delay delivery and discourage employment-land redevelopment, particularly on constrained brownfield sites affected by contamination and remediation costs.
If the policy reduces overall commercial development delivery, it would frustrate rather than support the Plan’s wider economic objectives and cannot reasonably be regarded as positively prepared.

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

Conclusion:-
For the reasons above, and having regard to the accompanying viability evidence, Policy J/AW has not been shown to be positively prepared, justified, effective or consistent with national policy as required by paragraph 36 of the NPPF. The evidence does not demonstrate that the affordable workspace obligations can be delivered without prejudicing the viability and delivery of employment development central to the Greater Cambridge economy. The policy should therefore be significantly modified or deleted.

While the objective of increasing affordable workspace in Greater Cambridge is supported in principle, draft Policy J/AW does not meet the soundness tests in paragraph 36 of the NPPF. It has not been shown to be positively prepared, justified, effective or consistent with national policy and should therefore be substantially revised or deleted. This objection should be read with the accompanying expert ‘Bidwells Viability Representation’, which identifies significant shortcomings in the Councils’ evidence base.

Assessment of Whether the Policy is Justified:-
Paragraph 36 of the NPPF (2024) requires Local Plans to be justified, meaning they must represent an appropriate strategy, consider reasonable alternatives and be based on proportionate evidence.

The Councils have not demonstrated that Policy J/AW is the most appropriate strategy for increasing the amount of commercial floorspace affordable and available.

Although the evidence identifies a need for affordable workspace, it does not justify the policy’s most onerous requirements, including:
• 10% affordable workspace across a broad range of commercial development types;
• rental discounts of up to 30% below market rents;
• affordable provision secured in perpetuity;
• the reduction in the office and R&D threshold from circa 2,500sqm to 1,000sqm; and
• a largely uniform approach across materially different commercial markets.

The Iceni Affordable Workspace Study (2026), which forms part of the Council’s Evidence Base, acknowledges that comparable policies vary widely in thresholds, discounts and affordability periods, but does not explain why the Councils have selected one of the most onerous combinations. Reasonable alternatives, including higher thresholds, lower discounts, fixed-term affordability or more flexible viability-led mechanisms, do not appear to have been robustly assessed or discounted.

The Affordable Workspace Study relies heavily on London comparators, including Southwark, Brent, Waltham Forest and Wandsworth, and the draft policy appears consistent with Lambeth and Westminster approaches. This is flawed because London’s market, economic and geographic conditions differ significantly from Greater Cambridge, particularly South Cambridgeshire’s dispersed, rural and science-park-led economy. Oxford, the only non-London reference point, concerns Community Employment and Procurement Plans rather than affordable workspace. The read-across to Greater Cambridge has therefore not been adequately evidenced.

Oxford City Council’s Regulation 19 Proposed Submission Local Plan includes draft Policy E4 (Affordable Workspaces), which requires:
• development proposals delivering a net gain of 5,000sqm GIA of employment uses (E-Class) to produce an affordable workspace strategy for specified sites; and
• the strategy to set out the details, size, marketing, servicing, management and delivery of the space.

The Oxford approach is a more flexible and site-specific approach, enabling affordable workspace where it is justified by need and deliverability. Given Oxford’s strong R&D sector and similar affordability pressures for SMEs, it is more comparable to Greater Cambridge than the London examples. The Cambridge context would align more closely with Oxford’s emerging policy on this issue.

We acknowledge Oxford’s emerging Local Plan has not been examined yet and hence the policy has not yet been demonstrated to be sound yet. Nonetheless we contend this indicates a flexible, market led approach in a comparable context to Greater Cambridge, facing similar issues with regards to University spin outs, SME’s and supply and demand of commercial floorspace.

The in-perpetuity requirement is unjustified. The evidence recognises that comparable policies often use fixed periods yet gives no compelling reason for a permanent restriction in Greater Cambridge. A perpetual discount permanently suppresses rental income and investment value, unlike a time-limited obligation. Lambeth’s policy requirement for a scheme, for example, expires after 15 years.

The basis for reducing the office and R&D threshold to 1,000sqm is unclear. The evidence relies substantially on London benchmarking, which does not reflect Greater Cambridge’s dispersed science park, innovation campus and rural employment locations. The threshold therefore lacks a robust local evidential basis.

We also raise concern that the 1,000sqm threshold is arbitrary and risks creating a cliff-edge for development required to provide affordable workspace. We recommend a transitional and graduated approach should be introduced rather than a square cut off at 1,000sqm which may discourage developers from pursuing schemes which may trigger the 1,000sqm threshold but do not benefit from the economies of scale large and strategic schemes do which may be better placed to absorb affordable workspace requirements. Introducing such a low threshold with such severe policy implications will create a two-tier offer in the commercial market, with those schemes consented after the policy is introduced having a commercial disadvantage in an already competitive market. If the policy principle is supported, then a much higher threshold will support a softer transition such that only larger schemes that are more able to accommodate the impacts of the policy are first asked to accommodate affordable workspace.

Policy J/AW is not shown to represent the most appropriate strategy or to be supported by proportionate evidence. It is not justified under paragraph 36 of the NPPF (2024).

Assessment of Whether the Policy is Effective:-
Paragraph 36 of the NPPF (2024) requires Local Plan policies to be effective and deliverable over the plan period.

The Councils have not shown that Policy J/AW can be delivered without harming the employment development needed to support Greater Cambridge’s growth ambitions.

Policy J/AW would also sit alongside biodiversity net gain, net-zero carbon requirements, transport mitigation, open space, green infrastructure, Section 106 contributions and the emerging Community Infrastructure Levy regime.

Although some requirements have been assessed individually, the evidence does not convincingly demonstrate that commercial development can absorb the cumulative cost of Local Plan and regulatory obligations across the Plan area.

This is particularly important in current market conditions. Greater Cambridge’s office, laboratory and life sciences sectors are undergoing market adjustment, as set out in the Viability Representation prepared by Bidwells. The Councils’ evidence acknowledges changing occupier demand, increased laboratory vacancy, financing pressures and economic uncertainty. In this context, any policy that permanently reduces investment returns risks suppressing development activity and undermining delivery.

The viability representation identifies substantial concerns with the Local Plan Viability Assessment, including assumptions on rents, yields, benchmark land values, build costs, developer return and brownfield redevelopment costs. These concerns call into question the robustness of the viability and deliverability conclusions.

The Councils have therefore not shown that the policy will be deliverable across the commercial schemes to which it would apply. There remains a significant risk that it will reduce delivery of office, R&D, laboratory and industrial floorspace during the Plan period.

It should be noted that this requirement is being introduced at the same time as Employment and Skills Plans which we support. We consider this mechanism to be an effective, meaningful way to help individuals in the employment market. In comparison we query the overall effectiveness of affordable workspace provisions on individuals in the job market.

As drafted, the policy risks threatening commercial viability and reducing investment in Greater Cambridge. Contrary to its aim, it could reduce overall affordable workspace provision. The policy is therefore not effective.

Assessment of Whether the Policy is Consistent with National Policy:-
Chapter 6 of the NPPF (2024) promotes a strong, competitive economy. Paragraph 85 requires planning policies to give significant weight to economic growth and to maintain conditions for investment and sustainable development.

The NPPF also makes clear that planning policies should not undermine viability or impose burdens that threaten delivery.

Policy J/AW is inflexible and does not adequately respond to changing market conditions. Its affordable workspace requirement, discount levels and affordability period are fixed, with viability considerations focused mainly on payment in lieu rather than the principle of provision. This rigidity is inconsistent with the NPPF’s emphasis on delivery, flexibility and maintaining viability.

The Councils have not justified why an in-perpetuity requirement is necessary, or why the policy should apply unchanged regardless of future economic, occupational or investment conditions. Commercial markets fluctuate, and policy must be able to respond.

Without robust evidence that the requirements can be absorbed without harming delivery, the policy is not consistent with national objectives for economic growth, productivity and investment.

Assessment of Whether the Policy has been Positively Prepared:-
The Local Plan must be positively prepared and provide a strategy capable of meeting identified needs, in accordance with paragraph 36a of the NPPF.

Greater Cambridge’s economic success depends on continued employment floorspace delivery and its global strength in life sciences, R&D, biomedical and IT sectors. The growth strategy relies on offices, laboratories, innovation space and industrial accommodation across a range of locations.

Although Policy J/AW seeks to address affordable workspace need, it risks undermining the wider commercial floorspace delivery on which economic growth depends, given the concerns in the Viability Representation. Additional obligations may reduce investment, delay delivery and discourage employment-land redevelopment, particularly on constrained brownfield sites affected by contamination and remediation costs.
If the policy reduces overall commercial development delivery, it would frustrate rather than support the Plan’s wider economic objectives and cannot reasonably be regarded as positively prepared.