Greater Cambridge Local Plan: Proposed Submission

Please refer to attached document for proposed amends to policy wording.

It is proposed that the policies should be simplified, with more explicit support for densification.

Points 2, 3a, 2b, 3d and point 4 should be deleted.

Areas of Major Change should be considered as areas of opportunity in which development is actively
supported and encouraged. Whilst the Regulation 19 draft addresses some of our comments at
Regulation 18 stage, we remain of the opinion that the wording of the proposed policy is such that it
seeks to negatively control development contrary to the presumption in favour. This is because the policy
seeks to establish controls which are not necessary and which increase the burden of planning policy
upon development viability. Further to the National Planning Policy Framework (August 2026) [NNPF26],
this fundamentally conflicts with aspiration to see growth in these areas, and must be avoided. Wider
requirements of the AMC policy are picked up elsewhere within the emerging Plan and should therefore
not be repeated within this policy.
For example, one such requirement is the need for a ‘Cultural and Community Plan’ at point 3d, which
duplicates Policy WS/NC. Pioneer Group Ltd object to the replication of this policy as this is considered
unsound. Furthermore, it is considered that the redevelopment of Areas of Major Change within
Cambridge City represent at their core a significant cultural and community benefit and this should be
recognised. Similarly, it may not be relevant in every instance to enhance public rights of way or
undertake on-site strategic landscaping and these additions may render crucial redevelopment unviable.
The omission of reference to support for higher densities in Areas of Major Change risks limiting the
ability of developers to bring genuine, meaningful transformation. Although the Submitted GCLP will be
examined against the NPPF 2024, the NPPF 2026 will be the relevant material consideration in terms of
national policy once adopted. In addition, all development plan polices which are materially inconsistent
with the national decision-making polices (NDMPs) in the NPPF 2026 should be given very limited weight
(Annex A, Paragraph 2). If adopted, the omission of support for higher densities would be materially
inconsistent with Policy L3 of the NPPF26 which notes that within settlement boundaries, applications for
development should involve an increase in density. Additionally Policy TC2 gives substantial weight to
the benefits of intensification where it supports the overall vitality and viability of town centres.
Accordingly, policy S/AMC should provide explicit support for densification.
An open mindset to densification is also beneficial as it may enable viability challenges to be overcome if
present. 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).
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.In conclusion, the
policy regarding Cambridge Areas of Major Change fails to adequately reflect the ambition for the
densification of key sites and adds onerous controls such as Community and Cultural Plans which are duplicated elsewhere in the plan. 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 is in addition
to potential CIL liabilities should this be adopted. The cumulative impact of these requirements represent
a potentially major viability hurdle which could be lessened with densification. Otherwise, the plan as it
stands risks rendering many opportunities unviable, meaning the district is unlikely to meet its projected
employment needs.

Please refer to the attached letter for proposed amended policy wording.

The proposed policy wording has been simplified and includes more explicit support for a flexibility of uses and intensification.

These amends include removal of points 1a,1b,1c,1d,4b, 5c, 5d and point 6.

With its funding partner Angelo Gordon TPG, Pioneer Group Ltd controls significant landholdings within
the Fitzroy Street, Burleigh Street and Grafton Area of Major Change, including the Grafton Centre.
Pioneer Group Ltd has previously made representations during the preparation of the Greater Cambridge
Local Plan and remains supportive of the principle of regeneration, intensification and diversification
within this highly sustainable city centre location.

However, Policy S/AMC/FBG is not considered sound in its current form for three key reasons as
expanded on below. Firstly, the lack of flexibility afforded to this key city centre Site contradicts national
policy support for city centre redevelopment and amendments to Class E of the Use Class Order.
Secondly, the policy should provide greater support for intensification, and thirdly that there should be
some recognition of the extant planning permission on the Site within the supporting text.

The policy should be worded so as to establish a baseline that development within the AMC is
acceptable, whereas the detailed policy as proposed operates principally as a cumulative list of
requirements, many of which conflict with the requirements of existing and emerging national policy
which work to support the flexibility of town centre uses and provide a ‘positive approach to their growth’
(NPPF, 2024). The policy wording requires simplification to ensure that development proposals within the
AMC are supported without being restricted by an overly onerous list of requirements.

Additionally, the supporting information notes that ‘A central objective of the policy is also to support a
flexible approach to uses which will enable a positive response to the shifting dynamics of consumer
trends and business needs across short, medium and long-term cycles.’ The policy wording however
does not reflect the changes afforded by the amendments to the Use Class Order in 2020 and
consequently is overly restrictive in the acceptable uses for the area. The 2020 Regulations created
Class E and brought together a wide range of former retail, financial and professional service, restaurant,
office, research and development, light industrial and other commercial and service uses, meaning that
changes between these uses no longer require planning permission under most circumstances.

Additionally, Policy TC2 (NPPF, 2026) provides support for ‘provision of residential accommodation’ in
town centres, which should be included in Policy S/AMC/FBG so as to ensure consistency.
Against that legislative context, the policy’s repeated distinction between retail, leisure, cultural, office
and other commercial uses is unnecessarily rigid. The policy should recognise the role of Class E in
enabling buildings and floorspace to respond to changing occupier requirements without repeated
applications for planning permission in respect of use.

It is accepted that some uses, including hotels, housing and student accommodation, fall outside Class E
and may require separate consideration. However, the policy should not seek to recreate distinctions
between individual Class E uses unless clear and proportionate evidence demonstrates that such
controls are necessary.

Furthermore, Part 2 requires proposals to be accompanied by evidence justifying “land uses, floorspaces
and their redevelopment on a proposal-by-proposal basis”. This is excessively broad and appears to
require all proposals to justify uses that may already be permitted by the Use Classes Order, the
development plan or an extant planning permission which conflicts with objectives set out in the
supporting text and national policy relating to objectives for flexibility, resilience and adaptation.
As well as supporting flexibility, the policy should provide further support to intensification of the Site in
line with the objectives of Areas of Major Change and Part 4 of the policy which describes that proposals
at the Grafton Shopping Centre should include ‘significant uplift in floorspace’. The omission of reference to support for higher densities in Areas of Major Change risks limiting the ability of developers to bring
genuine, meaningful transformation. Although the Submitted GCLP will be examined against the NPPF
2024, the NPPF 2026 will be the relevant material consideration in terms of national policy once adopted.
In addition, all development plan polices which are materially inconsistent with the national decision
making polices (NDMPs) in the NPPF 2026 should be given very limited weight (Annex A, Paragraph 2).
If adopted, the omission of support for higher densities would be materially inconsistent with Policy L3 of
the NPPF26 which notes that within settlement boundaries, applications for development should involve
an increase in density. Additionally Policy TC2 gives substantial weight to the benefits of intensification
where it supports the overall vitality and viability of town centres. Accordingly, policy S/AMC should
provide explicit support for densification.

This is also supported by the exploration of this area as a potentially suitable location for tall buildings in
the Skyline and Tall Buildings Strategy as part of the Newmarket Road Area of Search. This should also
be reflected in the policy wording, as supported by Policy L3 of the National Planning Policy Framework
(NPPF, 2026) which notes that within settlement boundaries, applications for development should involve
an increase in density. The reference in the policy to buildings that “complement” the skyline is subjective
and does not explain how the acknowledged opportunity for intensification is to be balanced against
townscape and heritage considerations. Instead, Policy S/AMC/FBG should establish that greater height
is acceptable in principle where supported by appropriate townscape, heritage, environmental and
design assessment.

An open mindset to densification is also beneficial as it may enable viability challenges to be overcome if
present. 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).
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.In conclusion, the
policy regarding Cambridge Areas of Major Change fails to adequately reflect the ambition for the
densification of key sites and adds onerous controls such as Community and Cultural Plans which are
duplicated elsewhere in the plan. 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 is in addition
to potential CIL liabilities should this be adopted. The cumulative impact of these requirements represent
a potentially major viability hurdle which could be lessened with densification. Otherwise, the plan as it
stands risks rendering many opportunities unviable, meaning the district is unlikely to meet its projected
employment needs.

Finally, the supporting text for Policy S/C/AMC: Cambridge Areas of Major Change highlights the
importance of having an ‘over-arching framework or equivalent masterplan’ to ensure that development
occurs in a ‘joined-up manner’. However, no reference is made in Policy S/AMC/FBG to the planning
permission which was granted in April 2025 (ref: 23/02685/FUL). Instead, the supporting information
references ‘The Grafton Area Masterplan and Supplementary Planning Document’ which was adopted in
2018, significantly predating the permission which has now been implemented. It is considered that this
document can only be afforded limited weight due to the significant change in context since then.
Reference should instead be made in the supporting text to note that permission for the comprehensive
redevelopment of the Grafton Centre has been granted and implemented.

Please refer to the attached letter for proposed amended policy wording.

Additions are required in Parts 1, 2 and 5 to include that a net zero operational emissions should be required 'where practical' and that applicants should 'strive to' meet specific specific targets

Additional words to read as the below:
Part A: Space heating
2. Achieve a specific space heating demand as follows:
a. All new dwellings must strive to achieve a space heating demand of 15 – 20 kilowatt-hours
(kWh) per meter squared Gross Internal Area (GIA) per year.
b. All new non-domestic buildings must strive to achieve a space heating demand of 15 – 20
kWh per meter squared GIA per year.
3. All heating should be provided through low carbon fuels (not fossil fuels).
4. No new developments should be connected to the gas grid.
Part B: Total Energy Use Intensity (EUI)
5. EUI targets are achieved as per building type (set out in kWh per meter squared GIA per year) as
follows:
a. All dwellings must strive to achieve an EUI of no more than 35 kWh per meter squared per
year.
b. Non-domestic buildings must strive to achieve the following EUI where technically feasible and
viable by building type:

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

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
commercial development and sustainable growth 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. Furthermore, once adopted the policy would be immediately materially inconsistent
with Policy PM13 (NPPF, 2026) which requires “clear and robust costed rationale” where energy
requirements go above the Building Regs. In the absence of such rationale the policy would be rendered
inconsistent and carry limited weight in decision making.

Please refer to the attached letter for proposed amended policy wording.

It is proposed that criteria 6 and 9 are deleted and that requirements should be looked at on a case-by-case basis, and only required where there is a demonstrable need, and when it is viable and deliverable to do so.

Pioneer Group Ltd object 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.
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 expectations 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.

Please refer to the attached letter for proposed amended policy wording.

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”.

An exemption should be applied to Appendix H at paragraph H.25 which notes that “Where extant
planning permissions have provided suitable assessment to demonstrate that the proposal will not cause
inacceptable impacts, no further assessment is required within those parameters.”

Pioneer Group Ltd consider that this 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 and
allow delivery of Cambridge’s growth aspirations without unnecessarily conflict with wider aspirations for
the optimisation of brownfield land.

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 in appropriate locations can be an effective way of accommodating growth, supporting
intensification and making efficient use of constrained sites. The policy should more clearly recognise
that, in these appropriate locations, taller buildings can make a positive contribution to sustainable
development and economic growth. This is especially true in brownfield locations such as the
Fitzroy/Burleigh Street/Grafton Area of Major Change (Policy S/AMC/FBG) where densification can
provide vitality and ensure the best/ most efficient use of previously developed land. For example, Part 4
of Policy S/AMC/FBG states that proposals at the Grafton Shopping Centre should include ‘significant
uplift in floorspace’ which may require an increase in height above the Urban Zone Height Threshold of
19m. This has been demonstrated as capable of being acceptable through the extant planning
permission 23/02685/FUL. Indeed, Policy L3 of the National Planning Policy Framework (2026)
[NPPF26] notes that within settlement boundaries, applications for development should involve an
increase in density. Therefore, to ensure that policies are materially consistent with national policy when
used for development management, policies should respond to the NPPF26, by providing additional
support for densification. Pioneer Group Ltd therefore propose that Areas of Major Change are not
subject to Policy GP/ST.

Additionally, densification serves to aid with viability of delivery, especially in the context of potential
future CIL liabilities and the requirements of the new Plan when considered as a whole. Where
densification is required to support other significant benefits, such as the vitality of town centres as
outlined in Policy TC2 [NPPF, 2026] it should be supported. Additionally, the Inspector’s call-in decision
relating to the Beehive Centre (Appeal ref: APP/Q0505/V/25/3360616) found that additional height was
not directly equivalent to harm. At IR13.19 the decision states “The scheme would not harm the
townscape of wider Cambridge. The parameter plan and Design Code would ensure that the
development was divided visually into separate parts, that the mass was broken up through varied
elevational design and material tones, and that an interesting roof profile was created, thus reducing the
scheme’s perceived bulk.” Therefore through effective design choices, the harm arising from
densification and taller buildings can be suitably mitigated.

In addition Criterion d notes that proposals in Cambridge must ‘ensure that the character and
appearance of a city of spires and towers emerging above the established tree line, remains dominant
from relevant viewpoints, including the Cambridge Commons’. The scale of development already
occurring in Cambridge and several extant planning permissions is such that this is not an accurate
description of the existing skyline and should be deleted.

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. To be consistent with national
policy and be considered sound, this must be addressed.

Please refer to the attached letter for proposed amended policy wording.

The policy wording should be amended to allow for off-site provision in other sites within a developer's portfolio, and should be subject to viability.

Additional clauses are suggested:
3(g)Affordable workspace should be delivered as shell or CAT A fit out to allow for flexibility of occupiers
5 Where fit out costs are likely to be high, for example in R&D or workshop space the proportion of affordable workspace provided could be lower than the policy requirement given the lower values associated with this type of space. The proportion of discounted floorspace in these cases will be determined through consideration of site characteristics and viability.

Pioneer Group Ltd objects to Policy J/AW as unsound and considers its drafting raises legal compliance
concerns under section 19(2) of the Planning and Compulsory Purchase Act 2004 (regard to national
policy). The objection is tested against the four tests of soundness: positively prepared, justified,
effective, and consistent with national policy.

Criterion 1 catches office and R&D development "over 1,000 square metres" with a minimum 30% (or
20%) rent discount "in perpetuity." The 30% tier alone applies across the Defined Development Extent of
Cambridge and sixteen named science and business parks (para 8.50, which is the knowledge-intensive
floorspace Policy S/JH relies on). Unlike affordable housing, which has extensive, tested national policy
behind it, NPPF contains no equivalent mandate for discounted commercial floorspace held in perpetuity,
this is a locally invented obligation with no defined review or release mechanism if the identified need
reduces over a building's life. It permanently impairs asset value, not merely development-stage viability,
and the evidence base does not appear to model that long-term effect.

The impact on development-stage viability, when all other cumulative requirements from the new Local
Plan and potential future CIL Viability is taken into account, is such that the required employment
projections set out in Policy S/JH are unlikely to be met. 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.
The delivery of 73,200 jobs during the Plan Period, or even more as set out under the recently adopted
Local Growth Plan, therefore risks being undeliverable with such constraints on developers.
Criteria 3(b)(ii) and 3(c) turn on matters "demonstrated to the satisfaction of the Council", which is an
undefined test. Criterion 3(b)(i)'s route via an "approved list" of providers cannot presently be relied on,
since paragraph 8.55 confirms the list "will be developed ahead of adoption" and so does not yet exist.
Payment in lieu is restricted to four narrow circumstances (criterion 4), with any general viability case
requiring a full independently assessed open-book assessment, the one general discount for high fit-out
typologies like R&D (para 8.43) is confined to supporting text, undefined in amount, and purely
discretionary. Pioneer Group request that this is added into the main policy text.

Criteria 4 accepts for payment in lieu under specific circumstances, however Pioneer Group Ltd note that
where developers have significant landholdings across the district it may be more appropriate to deliver
affordable workspace elsewhere in a more meaningful contribution on a different Site which is not
necessarily near to the development as stipulated by part 3(f). Clearer provision for offsite contribution
should be added into the policy to ensure that the best quality affordable workspace is provided in the
best locations, rather than a blanket requirement on each individual development. Similarly, in order to
support the diverse needs of start-ups and SMEs who seek to occupy these spaces, the policy should
make clear that the affordable workspace should be delivered to CAT A fitted out space. This also helps
to reduce the environmental costs of wasted fit outs where occupiers needs may differ.

This is a further, cumulative burden on scheme delivery, and Pioneer Group understand it is not alone in
that view. J/AW's 10% floorspace-in-perpetuity obligation, plus an annual monitoring requirement for the
life of the building, sits on top of Policy WS/NC's community needs assessment and contributions, Policy
BG/EO's 2.0 hectares per 1,000 employees open space standard, and Policy CC/CE's compliance costs,
all capable of applying to the same office or R&D building. Unless the whole-plan Viability Assessment
(para 2.27) has modelled this cumulative effect on representative office and R&D typologies, rather than
testing J/AW in isolation, the policy risks being neither justified nor effective, undermining delivery of
Policy S/JH's own 73,200 jobs requirement.

Paragraph 5 should be removed from Policy J/RC to reflect the flexibility afforded by the 2020
amendments to the Use Class Orders and in accordance with Paragraph 90(a) of the NPPF (2024)
which allows for diversification of town centres in response to industry changes.

The proposed policy approach incorporates a restriction on use which results in fundamental conflicts
with the NPPF and Town and Country Planning (Use Classes) Order as amended in 2020, which render
the proposed policy to be unsound. It is well established that clear intention of Class E is to allow
flexibility for businesses to adapt and diversify to meet changing demands. The current policy wording is
inconsistent with this approach and does not provide sufficient evidence to justify this position. To
achieve our understanding of the Councils’ aims in respect of Policy J/RC, it could choose to adopt a
requirement for active frontage and a requirement to consider the well-established principle of ‘Agent of
Change’ whereby the applicant seeking a change of use is responsible for providing any necessary
mitigation resulting from that change, rather than existing established uses being restricted.

Part 5 of Policy J/RC restricts proposals which would result in “the loss of any retail or other main town
centre use”, which is in direct conflict with national policy which works to support the flexibility of town
centre uses and provide a ‘positive approach to their growth’ (NPPF, 2024). As it stands, the policy
wording does not reflect the changes afforded by the amendments to the Use Class Order in 2020 and
consequently is overly restrictive in the acceptable uses for the area. The 2020 Regulations created
Class E and brought together a wide range of former retail, financial and professional service, restaurant,
office, research and development, light industrial and other commercial and service uses, meaning that
changes between these uses no longer requires planning permission under most circumstances. The policy should recognise the role of Class E in enabling buildings and floorspace to respond to changing
occupier requirements without repeated applications for planning permission.

Instead, the policy should focus on supporting the vitality of town centres through allowing flexibility as
outlined in Chapter 7 of the NPPF (2024) and particularly under paragraph 90(a) where planning policies
should support town centres to “grow and diversify in a way that can respond to rapid changes in the
retail and leisure industries, allows a suitable mix of uses (including housing) and reflects their distinctive
characters” (NPPF, 2024).

N/A

Pioneer Group Ltd objects to Policy J/AW as unsound and considers its drafting raises legal compliance
concerns under section 19(2) of the Planning and Compulsory Purchase Act 2004 (regard to national
policy). The objection is tested against the four tests of soundness: positively prepared, justified,
effective, and consistent with national policy.

Criterion 1 catches office and R&D development "over 1,000 square metres" with a minimum 30% (or
20%) rent discount "in perpetuity." The 30% tier alone applies across the Defined Development Extent of
Cambridge and sixteen named science and business parks (para 8.50, which is the knowledge-intensive
floorspace Policy S/JH relies on). Unlike affordable housing, which has extensive, tested national policy
behind it, NPPF contains no equivalent mandate for discounted commercial floorspace held in perpetuity,
this is a locally invented obligation with no defined review or release mechanism if the identified need
reduces over a building's life. It permanently impairs asset value, not merely development-stage viability,
and the evidence base does not appear to model that long-term effect.

The impact on development-stage viability, when all other cumulative requirements from the new Local
Plan and potential future CIL Viability is taken into account, is such that the required employment
projections set out in Policy S/JH are unlikely to be met. 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.
The delivery of 73,200 jobs during the Plan Period, or even more as set out under the recently adopted
Local Growth Plan, therefore risks being undeliverable with such constraints on developers.
Criteria 3(b)(ii) and 3(c) turn on matters "demonstrated to the satisfaction of the Council", which is an
undefined test. Criterion 3(b)(i)'s route via an "approved list" of providers cannot presently be relied on,
since paragraph 8.55 confirms the list "will be developed ahead of adoption" and so does not yet exist.
Payment in lieu is restricted to four narrow circumstances (criterion 4), with any general viability case
requiring a full independently assessed open-book assessment, the one general discount for high fit-out
typologies like R&D (para 8.43) is confined to supporting text, undefined in amount, and purely
discretionary. Pioneer Group request that this is added into the main policy text.

Criteria 4 accepts for payment in lieu under specific circumstances, however Pioneer Group Ltd note that
where developers have significant landholdings across the district it may be more appropriate to deliver
affordable workspace elsewhere in a more meaningful contribution on a different Site which is not
necessarily near to the development as stipulated by part 3(f). Clearer provision for offsite contribution
should be added into the policy to ensure that the best quality affordable workspace is provided in the
best locations, rather than a blanket requirement on each individual development. Similarly, in order to
support the diverse needs of start-ups and SMEs who seek to occupy these spaces, the policy should
make clear that the affordable workspace should be delivered to CAT A fitted out space. This also helps
to reduce the environmental costs of wasted fit outs where occupiers needs may differ.

This is a further, cumulative burden on scheme delivery, and Pioneer Group understand it is not alone in
that view. J/AW's 10% floorspace-in-perpetuity obligation, plus an annual monitoring requirement for the
life of the building, sits on top of Policy WS/NC's community needs assessment and contributions, Policy
BG/EO's 2.0 hectares per 1,000 employees open space standard, and Policy CC/CE's compliance costs,
all capable of applying to the same office or R&D building. Unless the whole-plan Viability Assessment
(para 2.27) has modelled this cumulative effect on representative office and R&D typologies, rather than
testing J/AW in isolation, the policy risks being neither justified nor effective, undermining delivery of
Policy S/JH's own 73,200 jobs requirement.