Full text:
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.
