Greater Cambridge Local Plan: Proposed Submission

Criterion 2: The requirement for all major developments to submit a Green Infrastructure Plan and, at outline stage, a Green Infrastructure Statement should be amended so that these documents are only required where proportionate to the scale, nature and complexity of the development. Many proposals will already be supported by landscape, biodiversity and masterplanning information, making additional assessments unnecessary.
Criterion 3: The encouragement for developments of 5,000sqm GIA or more to seek accreditation under the Building with Nature Standard requires greater clarity and justification. The policy should provide further guidance on the purpose of the accreditation, its expected application, and the implications for applicants to ensure the requirement is understood and can be implemented consistently.

Stanhope supports the overall objectives of the policy, however it objects to the policy as drafted on the grounds that it introduces additional assessment and accreditation requirements that are insufficiently justified that may adversely affect viability.
Criterion 2 requires major developments to submit a Green Infrastructure Plan and at outline planning stage a Green Infrastructure Statement. This represents an additional layer of assessment, which may result in unnecessary cost implications particularly where proposals are already supported by landscape, biodiversity and masterplanning information. The policy should be amended to ensure Green Infrastructure Plans and Statements are only required where proportionate to a major scale of development.
Criterion 3 encourages developments of 5,000sqm GIA or more to seek accreditation under the ‘building with nature standard’. However, this policy provides limited justification for this approach. The policy should provide further guidance and clarity regarding the expectations associated with the standard to ensure applicants can properly understand the requirement and its implications.

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

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

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

Stanhope supports the objectives of the policy but objects to its current wording on the grounds that it is overly prescriptive and may create unreasonable burdens on commercial development coming forward. The policy wording should be amended to provide greater flexibility and ensure that its requirements are proportionate and deliverable.
Criterion 1 requires all new developments of 1,000 sqm or more to submit and implement an Employment and Skills Plan for both the construction and occupation phases of development. This requirement also applies to developments that form part of a larger development which would cumulatively exceed the 1,000sqm threshold. The proposed threshold is unreasonably low and risks imposing a disproportionate burden on smaller commercial developments. It is recommended that consideration be given to increasing the threshold to ensure the requirement is targeted towards developments that are capable of delivering meaningful employment and skills outcomes and of a scale that can reasonably afford and have in place an Employment and Skills coordinator post-scheme completion.
Criterion 4 states that development proposal must secure 20% of all jobs created by the construction phase of the development of local residents. Whilst the objective of maximising local employment opportunities is supported, the policy wording is overly rigid and fails to recognise that construction jobs will be influenced by labour market conditions and skills availability. The requirement should therefore be amended so that applicants are required to "seek to" achieve the 20% target, rather than "must" achieve it.
Furthermore, the term "local residents" is not defined, creating uncertainty regarding how the requirement would be applied and monitored. The policy should clearly define the relevant geographical area, such as Greater Cambridge or catchment area, to provide greater certainty and clarity.

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. Therefore 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 base cost 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.

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

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

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

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

Paragraph 69 of the NPPF (2024) is clear that local planning authorities may need to plan for higher levels of growth than their identified housing need where this is required to reflect growth ambitions linked to economic development or infrastructure investment. This direction of travel is reinforced through proposed Policy HO2(b) of the NPPF (2026), which makes clear that housing requirements within Local Plans should be set higher than the figure identified within a housing needs assessment where appropriate, including where a higher requirement is necessary to support economic growth ambitions or infrastructure investment. Whilst the Greater Cambridge Local Plan will be examined against the NPPF (2024), it is nevertheless clear that central government policy is increasingly focused on enabling growth, with a particular emphasis on Cambridge and the surrounding region. The draft plan does not do this. Cambridge and the surrounding region are central to the Government's ambition to deliver and facilitate "supercharged growth", yet the emerging Local Plan does not reflect this ambition and will not meet the Government's expectations.

This position is reinforced by significant national, regional and local investment in infrastructure. Greater Cambridge has recently benefited from, and will continue to benefit from, major infrastructure projects that establish the area as a location of regional and national significance where growth should be accommodated. These include the opening of Cambridge South Station, providing direct connectivity between Cambridge Biomedical Campus and London; the granting of consent for the Cambourne to Cambridge Busway; and the progression of Cambridge South East Transport (CSET) to public inquiry. In a national context, the continued commitment to East West Rail further establishes Greater Cambridge as an area benefiting from major transport investment. The East West Rail Development Consent Order is anticipated to be submitted in 2027 and will deliver a new station at Cambourne, with services operating through Cambridge South Station and the city's existing rail network. Collectively, these projects demonstrate an ongoing commitment to the delivery of major infrastructure to support future growth.

Growth for Greater Cambridge is also set to be delivered by the Greater Cambridge Development Corporation (GCDC), which is now legally established and backed by £400 million of central government funding. However, the emerging Local Plan cannot rely upon the future work of the GCDC to address the area's growth requirements. Whilst the GCDC may ultimately deliver growth over and above the minimum provision within the Draft Greater Cambridge Local Plan, it has yet to receive plan-making powers, will need to prepare its own plan following adoption of the GCLP, and will be required to undertake consultation, examination and adoption processes in the normal way. Any successor plan is therefore likely to be many years away, whereas the need to support and plan positively for growth exists now. The GCLP should therefore address growth requirements directly rather than relying on the preparation of a future GCDC plan.
We contend that, to ensure the Plan is found sound, the unique nature of Cambridge, its strategic economic role and its projected capacity for growth must be properly reflected within the emerging Local Plan. Specifically, this should be achieved through increased housing delivery across the plan period, with housing provision recognised as critical to supporting employment growth, economic competitiveness and productivity.

We acknowledge that Policy S/JH identifies a housing need of 48,069 dwellings over the plan period, equivalent to 2,289 dwellings per annum and broadly consistent with the Standard Method output for Greater Cambridge. The Employment and Housing Needs Update (EHNU) (2026) adopts a preferred employment scenario which generates 73,248 jobs over the plan period and aligns this with a housing requirement of 48,069 dwellings. However, the EHNU derives these conclusions from the "central growth" scenario, while dismissing the "high growth" scenario despite acknowledging that higher growth could be achieved through a step change in investment.

The EHNU rightly identifies the relationship between employment growth and housing need, recognising that higher levels of economic growth create derived demand for housing. There is therefore a clear interdependency between job growth and housing provision. However, the adoption of the preferred central growth scenario of approximately 73,300 additional jobs produces a housing requirement of approximately 48,069 dwellings, or around 2,295 homes per annum, a figure almost identical to the Standard Method requirement. This is considered problematic.

The central growth scenario incorporates assumptions around periods of slower growth, contractions and economic shocks. As a result, both the employment and housing figures proposed within the Draft Local Plan are inherently conservative rather than reflective of the full growth potential of the Greater Cambridge economy. In contrast, the EHNU acknowledges both a "High" and "High Sensitivity" scenario whereby growth would meet or exceed the trajectory experienced between 2010 and 2020. The recently adopted Local Growth Plan set out by Cambridgeshire and Peterborough Combined Authority includes a higher requirement of at least 59,409 homes, but potentially substantially more, generating the need for further jobs beyond those currently assigned. Given the scale of planned infrastructure investment, Government support, the establishment of the GCDC and Cambridge's continuing economic significance, such higher levels of growth remain entirely feasible and should not be ruled out through policy.

Whilst the Authority has technically met its identified housing need through application of the Standard Method, it is important to recognise that the Standard Method does not account for the specific growth agenda surrounding Cambridge or its role as a focus for nationally significant economic expansion. It is therefore not sufficient to rely solely upon the Standard Method figure when national policy explicitly allows authorities to plan for higher levels of growth where justified by economic ambitions and infrastructure investment.

We also note a significant inconsistency between the Regulation 18 and Regulation 19 versions of the Plan. The Regulation 18 Local Plan proposed delivery of approximately 2,463 dwellings per annum to support employment growth of 66,000 jobs. By contrast, the Regulation 19 Plan proposes delivery of only 2,292 dwellings per annum despite forecasting approximately 73,200 jobs over the plan period. This represents a reduction in housing delivery whilst simultaneously planning for higher employment growth.

The EHNU explains this outcome on the basis that average household sizes have increased, resulting in a larger working-age population and an expectation of greater levels of in-commuting, thereby reducing the number of additional local residents required to fill newly created jobs. We are concerned that this represents an unsustainable approach to development strategy. It reflects a housing market in which many younger people are unable to move out of the family home or live closer to employment opportunities within Greater Cambridge. This is particularly relevant given the concentration of jobs at key employment locations such as CB1, Cambridge Biomedical Campus and Cambridge Science Park.

Rather than embedding and relying upon increasing household sizes as a response to housing affordability pressures, the Plan should seek to address affordability directly by planning for increased growth and housing supply in response to growing demand. A strategy of increased housing delivery would better support the functioning of the local economy, improve labour market accessibility and make it easier for people to live closer to employment opportunities.
Furthermore, making provision for additional housing growth in sustainable locations would help deliver more sustainable travel patterns, consistent with paragraph 111 of the NPPF (2024), which requires planning policies to minimise the length and number of journeys required for employment and other day-to-day needs.

In addition to increasing housing provision, the wording of Policy S/JH should provide greater flexibility in relation to employment growth. The reference to 73,300 additional jobs should be treated as a minimum target rather than expressed, or capable of being inferred, as a cap on future growth. As currently drafted, there is a risk that the figure could be interpreted as limiting future employment opportunities. The policy should make clear that the target represents a minimum level of employment growth and should not act as a constraint on the delivery of additional jobs where sustainable economic opportunities arise through acceptable development proposals.

It is evident that committed and future infrastructure projects continue to reinforce Cambridge's position as an area capable of supporting and delivering higher levels of growth. Within this context, Cambridge remains a priority location for the Government's growth agenda and ambition to deliver "supercharged growth". The Local Plan should therefore utilise more ambitious and realistic assumptions regarding employment and housing growth, make provision for higher housing delivery, and include explicit support for higher-growth scenarios within Policy S/JH.

Without these changes, Policy S/JH risks being unsound and inconsistent with national policy objectives to support sustainable economic growth, productivity and infrastructure-led development.