Greater Cambridge Local Plan: Proposed Submission

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.

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 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 of large and strategic schemes 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 adopted 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 (Bidwells, Sept 2026) 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 (Bidwells, Sept 2026). 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.

Changes Required
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;
• 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.

The proposed changes are as follows:
• Addition of “where relevant and appropriate” to the requirements of Criterions 3, 16, 19 and 20
• Removal of 3(e) which repeats an existing requirement under Policy J/AW
• Clarification on the mechanism of the “agreed trip budget” to ensure flexibility throughout the Plan period which is subject to material changes in circumstance

Stanhope support the ambition expressed by S/AMC/NEC but it is often seeking too much from all developments across the whole of North East Cambridge (NEC). Different parts of NEC are characteristically very different to each other and geographically in very different locations when assessing their proximity to the train station or nature reserves, for example. The policy must be more nuanced and recognise throughout that developments will need to be assessed according to their scale, location and impact.

Criterion 3 lists 7 points which need to be met by all development proposals for new or intensified Commercial and Research & Development E(g)(i) and E(g)(ii) at existing campuses. New developments of smaller scale will not be able to deliver all of these requirements. For example a single development will not be able to provide shared business support or collaboration space for start-ups and SMEs or other services and amenities. Development at the park is such that a concentration of higher quality facilities can be provided at key nodes to support other developments and each development does therefore not need to be self-sufficient and provide its own additional amenity. Point 3(e) also unnecessarily repeats requirements outlined under Policy J/AW: Affordable Workspace and as such should not be referenced in this policy in accordance with Paragraph 16(f) of the NPPF (2024). Please refer to separate objection from Stanhope in relation to Policy J/AW and submitted Viability Representations (Bidwells, Sept 2026).

Similarly, Criterions 16, Criterion 19 and 20 list further requirements which are not feasible for all scales of development. The requirements of Criterion 3,16, 19 and 20 should be amended to state that proposals should meet these requirements “where relevant and appropriate”.

Criterion 17(a) refers to the “agreed NEC trip budget” however it is unclear under what mechanism this trip budget is agreed. The Local Plan covers the period up to 2045, and it is possible that there may be material changes which would occur to lead to a different and appropriate trip budget at some future point. Further clarification is required on this point, and flexibility to allow for its relevance over the full plan period. Criterion 17 should also include an additional part to balance sustainable transport strategies with the commercial requirements of new developments and market trends. Schemes that have been pushed to include vastly reduced car parking are now struggling to find occupiers and sit empty. It is therefore important to have buildings that are attractive to occupiers as a matter for the planning balance and designing well-balanced schemes which are able to support Cambridge’s growing economy.

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

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

To ensure the policy deliverable across a range of commercial development types, greater flexibility in the policy wording should be introduced. Accordingly, Criterion (d) should be amended as follows:
“Then look to full-building mechanical ventilation/cooling systems: Where appropriate the lowest carbon/energy options are selected and are only considered after all other elements of the hierarchy have been utilised” (emphasis added).

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

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

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

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

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

Stanhope supports the overall policy objectives; however, the policy as drafted is overly prescriptive and should be amended to provide greater flexibility.
The objectives of the policy align with Stanhope’s own ambition to achieve net zero carbon by 2030 by halving carbon intensity and only delivering net zero carbon buildings by 2030.
However, the policy wording states that new development must achieve net zero operational emission. To ensure the policy remains effective and deliverable, this wording should be amended to state that developments are "encouraged to" or "should seek to meet the identified standards unless technical or viability reasons indicate otherwise". Without such flexibility, there is a risk that the policy could constrain the delivery of some 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.

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.”

There are also proposed amends to part b.

The proposed amended policy wording is as below:

1. Development proposals that break or result in a significant change to the existing skyline, or are significantly taller than the surrounding built form (as defined by the local context heights in Appendix I: Skyline and Tall Buildings Guidance), must demonstrate how they will maintain or enhance the distinctive skyline and character of Cambridge and the surrounding district. Such proposals will only be supported where they demonstrate a positive response to their wider setting and satisfy the following criteria:
a. Location, setting and context – applicants must demonstrate through visual appraisals, with supporting accurate visual representations, how the proposals fit within the existing landscape and townscape and demonstrate how the proposal maintains or enhances the character and quality of the skyline. Proposals for tall buildings will be assessed on a site-by-site basis with the expectation that a robust evidence base will be provided to demonstrate that they are appropriate to their context;
b. Impact on the historic environment – applicants must demonstrate and quantify the potential harm of proposals to the significance of heritage assets or other sensitive receptors (view of, backdrop and setting), assessed on a site-by-site basis. These will include impact on key landmarks and viewpoints (identified in Appendix I) and from main streets, local vantage points (such as bridges) and open spaces as well as, dynamic views from roads and, where applicable, The River Cam corridor. Cambridge presents as a city with many layers of history, including modern additions to the townscape; proposals must show how they respond to the character and appearance of Cambridge including an appreciation of it as a city with spires and towers emerging from the established tree line;
c. Scale and massing – applicants must demonstrate using scaled drawings, sections, accurate visual representations and models, how their proposals would form a high-quality addition to the skyline. This will include assessment of the cumulative impact at both strategic and local levels with other committed proposals as well as against the baseline at the time the application is being made;
d. Design quality – applicants must demonstrate how their proposals create high quality, well-proportioned buildings expressing elegance, proportionality and verticality that articulate base, middle and top using high quality materials and detailing that architecturally integrates plant, lift overruns and flues to ensure a well-articulated skyline. Where appropriate, proposals should introduce a mix of uses that generate activity and a human scale at street level;
e. Amenity and microclimate – applicants must demonstrate that there is no unacceptable impact on neighbouring buildings and open spaces in terms of the diversion of wind, overlooking, overshadowing, overheating, glare and reflectivity. Proposals must demonstrate through appropriate technical testing that acceptable microclimatic conditions will be achieved and that opportunities have been taken to minimise urban heat island effects, including through design responses to wind, thermal comfort and surface overheating, and that there is adequate daylight to habitable rooms and sunlight to external spaces both within the proposals and to neighbouring properties and open spaces; and
f. Suicide prevention – applicants must demonstrate how their proposal incorporates proportionate design measures to reduce access to means of suicide having regard to the height, form and public accessibility of the building. Design will be determined by the structure of the buildings and its surroundings.

Stanhope 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 North East Cambridge (S/AMC/NEC) where densification can provide vitality and ensure the best/ most efficient use of previously developed land. For example, Part 3(b) of Policy S/AMC/NEC states that proposals should “Make efficient use of land through intensification, including…increased heights” which may require an increase in height above the Urban Zone Height Threshold of 19m allocated to “designated growth areas on the city fringes”. This has been demonstrated as capable of being acceptable through several extant planning permissions at Cambridge Science Park. 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.
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, but should express also that it shows a mix of development types and scales.
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.

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

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

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

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

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

Criterion 4 of Policy BG/EO should be amended as follows:

All commercial developments for 2,000 square metres or more (Gross Internal Area) within Use Classes E(g)(i), E(g)(ii), as well as sui generis uses where the proposal comprises a research, innovation or institutional campus and existing provision is not already sufficient, must:
b. Demonstrate open space provision equivalent to 2.0 hectares of open space per 1,000 employees; (which may be ground level provision or by roof terraces, roof gardens, courtyards and other forms of amenity space at an appropriate scale to the development); or
c. Demonstrate a smaller provision is acceptable by reference to local provision and impacts of the development; or
c. Where justified and agreed with the LPA, make this provision off-site via financial contributions, with a focus on contributions to local greenspaces likely to be impacted by visits by on-site employees following occupation.

Stanhope 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 and creating an efficient layout to achieve 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. One such example is Cambridge Science Park, which represents an existing parkland setting with open space provision capable of supporting further development. 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 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.

Policy BG/UGF should be 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.’

Stanhope 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 request this is amended 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.

Stanhope 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.’

Proposed changes to the policy text include:
• An additional clause to Criterion 1, stating ‘where there is a demonstrable need, and it is viable and deliverable to do so.’
• Deletion of criterion 6 and 9
• Reference in criterion 11 to assessing phasing of delivery on a case-by-case basis

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

Criterion 2 requires employment development of more than 5,000sqm to be informed by detailed assessments of community needs and strategies to address those needs. The 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. This represents a particular challenge for developers when deciding whether to acquire sites; 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 that community, cultural and recreational facilities are already provided with many commercial and employment developments, often those types that can serve the employees and the local community and give such facilities longevity. Furthermore, it does not adequately justify why commercial proposals should be expected to deliver such significant social infrastructure. Employees do not generate demand for local community and cultural facilities in the same way as residential developments.

Criterion 7 and 9 similarly place unreasonable expectation on commercial developments to provide or contribute toward sports and recreational facilities. The policy does not adequately account for existing provision 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.

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

Stanhope, as a certified BCorp company, supports the objective of promoting sustainable resource use and reducing waste. However, Policy CC/CE as drafted places disproportionate weight on embodied carbon considerations, exceeds national policy requirements and may unnecessarily constrain redevelopment and regeneration opportunities. Accordingly, the policy should be amended to provide greater flexibility and better account for the wider sustainability benefits, viability and deliverability of development proposals.
In particular, Criterion 2 places disproportionate weight on embodied carbon considerations by introducing a strong presumption in favour of retaining existing buildings and requiring applicants to provide a full justification for demolition. Embodied carbon should not become the determining factor in assessing redevelopment proposals. The policy as drafted fails to adequately recognise the wider benefits that demolition and redevelopment can deliver including regeneration, improved building performance, economic growth, and enhanced long-term sustainability outcomes. As drafted, the policy risks preventing otherwise sustainable and beneficial redevelopment proposals to come forward. The presumption in favour of retention and reuse should therefore be amended to allow greater consideration of site-specific circumstances and the wider benefits of redevelopment.
The requirement to provide a full justification for demolition also fails to adequately reflect the existing legislative framework under the Town and Country Planning (General Permitted Development) (England) Order 2015, which under Class B sets out the Permitted Development rights for demolition of a building. The policy therefore imposes an additional burden on development proposals that is not required by national legislation and should be removed or amended accordingly.
Criterion 2(d) is particularly onerous and should be revised so that embodied carbon is considered as one material planning consideration within the overall planning balance, rather than a determining test.