Greater Cambridge Local Plan: Proposed Submission

Hill full representations are set out within the attached document named: "GCLP Reg 19 Consultation Representations - Cambridge East". Specifically please see Section 2: GCLP Strategic Approach & Cambridge East for relevant comments regarding Policy S/JH.

Hill full representations are set out within the attached document named: "GCLP Reg 19 Consultation Representations - Cambridge East". Specifically please see Section 2: GCLP Strategic Approach & Cambridge East for relevant comments regarding Policy S/JH.

Marshall’s representations to the Regulation 18 consultation, which we endorse, supported the ambition to deliver sustainable growth in Greater Cambridge, but concluded that the draft Plan was unambitious in responding to the area's economic potential and national policy objectives. It was noted that the Plan was only planning to meet its minimum housing requirement and therefore was failing to respond with housing proposals that reflect the scale of the economic opportunity.
It was flagged in the previous representations that Government policy recognises that housing requirements may need to exceed minimum assessed housing need where this is necessary to support economic growth ambitions or major infrastructure investment. In the case of Cambridge, successive Government statements have consistently identified the city and its wider economic area as being of national importance, with a clear objective of unlocking and accelerating growth. Furthermore, the evidence base prepared in support of the Regulation 18 GCLP demonstrated that higher growth scenarios had been tested and could be delivered, provided that appropriate investment was made in housing, transport and other supporting infrastructure.
Against this background, the representations concluded that the Plan's reliance on a more cautious growth scenario appeared difficult to reconcile with the Government's stated ambitions for Cambridge and the need to address longstanding challenges relating to housing affordability, labour supply and economic competitiveness. It was suggested that a positively prepared plan should seek to facilitate and enable growth by planning proactively for future opportunities, rather than embedding assumptions that risk constraining the area's economic potential.
Since the Regulation 18 consultation, Government has confirmed that the GCDC will assume plan making powers post adoption of the GCLP. However, that should not alter the growth minded ambition that should be applied to the GCLP, especially as it will set the baseline for GCDC’s future growth plan.
The GCSP has not acknowledged, through amendments in the relevant policies, that the horizon has changed as a result of the establishment of the GCDC, nor the announcement by EWR that there will now be a mainline station adjoining the Cambridge East site.
Government has clearly and repeatedly stated that it considers supporting the growth of Greater Cambridge and its economy to be a national priority. Such statements have come in the form of written ministerial statements, publications and considerable funding for infrastructure aimed at unlocking development.
Mayor Bristow’s Local Growth Plan matches this ambition, seeking to double the size of the Combined Authority’s economy with a stretch target to triple it.
One of the most significant actions that Government has taken is the establishment of the GCDC. As the GCDC consultation document1 states:
“The proposed Development Corporation would have a clear remit to deliver lasting benefits for both existing and future communities. It would do so by accelerating economic growth; coordinating enabling infrastructure; leveraging public and private investment; delivering environmentally sustainable outcomes; and reducing inequality through affordable housing and skills development. Building upon the exceptional quality of place seen across much of Greater Cambridge, the objective of the Development Corporation would be to deliver exemplary development in the form of high-quality, well-designed, attractive, and sustainable homes and neighbourhoods.”
2.9 In respect of the GCDC’s role in planning making and decision making, Government’s response to the consultation explained that granting these powers was “essential to accelerating strategic growth in an integrated and coordinated way”.
The consequence of these Government announcements, in particular the formation of the GCDC, is so significant to the strategic planning of Greater Cambridge that it should be acknowledged in the approach of the GCLP. The risk of not doing so would be to undermine the ‘integrated’ and ‘coordinated’ planning of Greater Cambridge, inconsistent with Government objectives.
However, the approach of the GCLP has not materially changed since these announcements were made, and there is a risk that its restrictive approach is now even more out of step.
Consequently, Hill stand by the previous comments raised in respect of Policy S/JH forming part of Marshall’s Regulation 18 representations that are included as Appendix 1. These state that the evidence continues to demonstrate that significantly higher levels of employment and housing growth are possible. The GCLP should provide the strategic platform from which the GCDC can prepare and deliver their Growth Plan, enabling future investment and growth opportunities to come forward. Instead, the draft GCLP seeks to define growth by reference to existing infrastructure constraints and minimum requirements, potentially prejudicing the ability of the GCDC to pursue a more ambitious strategy.

Suggested amendment to put a minimum of 8,000 rather than approximately. Concerns raised about the proposed masterplanning requirements and it not reflecting the anticipated planning framework for Cambridge East. Specify that the design codes are required for the reserved matters stages. Require the removal of 10% for specialist accommodation because the amendment proposes to remove reference to precise proportion of homes to be specialist accommodation and is necessary because the requirement is inconsistent with other policies in the Plan, such as Policy H/SH which allow schemes to provide their own evidence. It is too early to be prescriptive about the provision of specific sports facilities including a regional swimming pool. Proposed amended wording is included in Table 3.1 in the attached pdf.

Hill full representations are set out within the attached document named: "GCLP Reg 19 Consultation Representations - Cambridge East". Specifically please see Section 2: GCLP Strategic Approach & Cambridge East and Section 3: Policy S/CE: Cambridge East for relevant comments regarding Policy S/CE.

Hill full representations are set out within the attached document named: "GCLP Reg 19 Consultation Representations - Cambridge East". Specifically please see Section 2: GCLP Strategic Approach & Cambridge East and Section 3: Policy S/CE: Cambridge East for relevant comments regarding Policy S/CE.

Introduction
Representations submitted to the Regulation 18 consultation on behalf of Marshall provided support for the allocation of the safeguarded land for a new urban quarter. Notwithstanding this, there were comments raised relating to a number of elements of the policy that were either considered to be too detailed for this stage of the Plan, start to prematurely predetermine a masterplan which the policy identifies as still to be developed, and / or are not justified having regard to the evidence base supporting the Local Plan.
Since the publication of the Regulation 18 draft GCLP, the Government has confirmed that the GCDC will be the planning authority for the Cambridge East application. As a result, the concerns raised in our Regulation 18 representations are intensified.
3.3 The NPPG is clear that plans should be concise and that sufficient detail should be given to provide clarity to developers, local communities and other interested parties about the nature and scale of the development. The Cambridge East site allocation policy is overly detailed and contrary to the NPPG on the basis that it seeks to control matters better left to design codes, masterplans or the development management process. The policy should be framed in broad strategic terms and should avoid imposing detailed requirements that could prejudice future decision.
Cambridge East represents one of the most significant regeneration and growth opportunities in Greater Cambridge and the wider UK, with the capacity to make a substantial contribution towards meeting the area's housing, economic growth, infrastructure and placemaking objectives. However, the full opportunity that this Site presents cannot be achieved through an overly detailed and constraining approach to the allocation.
The majority of the key points raised at Regulation 18 stage remain relevant particularly as some policy wording has become even more prescriptive, which is a move in the opposite direction to the flexibility sought in the Regulation 18 representations. In addition, further technical work, changes in site ownership, the advancement of EWR and Cambridge East Station proposals, and the evolving strategic planning context have highlighted a number of additional matters that should be addressed to ensure that the policy is effective, deliverable and capable of realising the full potential of Cambridge East.
The primary matters are explained in turn below, with a number of other necessary changes captured in Table Appendix 3 provides a track changed version of the policy and its supporting text based on Hill’s proposed amends.

Cambridge East Allocation Boundary & Green Belt Corridor
Criteria 1 of the policy states that the built area of Cambridge East “will be contained within the Site Allocation boundary identified on the Proposals Map”.
The Proposals Map shows a definitive site allocation boundary which is split by the proposed green corridor.
However, the explanatory text to the policy specifically acknowledges that the green corridor alignment as shown is not the appropriate final form and that the precise boundary is to be determined through future masterplanning as set out in paragraphs 3.2.13 and 3.2.14.
Hill agree that the masterplanning exercise should ultimately determine the correct boundaries and alignment of the green corridor. However, the policy currently suggests that development within the corridor would be subject to Green Belt policy restrictions, notwithstanding that the extent and function of the corridor will only be established through the masterplanning process.
This is a disappointingly restrictive policy for one of the most important growth locations in Greater Cambridge. Hill continue to challenge the principle of the Green Belt designation through the corridor, as the land does not fulfil the purposes of the Green Belt as set out in the NPPF. The principle and function of the corridor can be secured through the policy framework and masterplanning process without imposing a restrictive and inappropriate Green Belt designation.
Instead, the site allocation boundary should cover the full site (including the green corridor), and the policy should be clear that the masterplanning process associated with the preparation of a planning application will define and agree the precise alignment, extent and boundaries of the corridor. Proposed revised explanatory text wording is set out in Table 3.1.
In previous representations we have explained why the land should not be designated as Green Belt at all, or require any “compensatory widening”. The supporting text at paragraph 3.2.14 suggests additional widening may be required where narrowing of the corridor is identified through the masterplanning process.
If the masterplanning exercise demonstrates that a revised corridor alignment or width is necessary to achieve high-quality placemaking whilst maintaining or enhancing the function of the green corridor, there should be no requirement for further additional provision elsewhere.
The masterplanning process is the appropriate mechanism through which the extent, alignment and function of the corridor should be tested and resolved. Requiring additional widening would prejudge the outcome of that exercise and impose an unnecessary constraint. The key consideration should be whether the function of the corridor is maintained or enhanced overall, not whether any reduction in width at one location is offset elsewhere.
Accordingly, the supporting text should be amended to confirm that the boundaries, alignment and width of the green corridor will be determined through the masterplanning process and that no automatic requirement for additional widening will apply where the corridor's function is maintained or enhanced overall.
Hill stand by the Regulation 18 representations in challenging the principle of the Green Belt designation, the inappropriateness of potential additional widening of the corridor and its omission from the site allocation boundary. The Regulation 19 representations further emphasise that the boundaries and extent of the corridor should be determined through the masterplanning process and as a result the corridor should be included in the Site Allocation boundary.

Masterplanning & Indicative Spatial Framework
The Regulation 19 draft has introduced a new policy requirement (criteria 2) in respect of masterplanning. In summary it requires the following:
• A site wide masterplan is to be prepared in conjunction with the Council and in consultation with the local community and other stakeholders;
• The masterplan is required to “broadly align” with the Indicative Spatial Framework;
• The masterplan is to identify the broad distribution of land uses, infrastructure delivery and phasing;
• The masterplan is to be used as a “basis for the consideration of subsequent applications”; and
• The masterplan is required to be “agreed by the Council prior to the approval of any planning applications”.
This new wording fails to understand the realities of how Cambridge East will be planned and delivered.
Hill envisage submitting a hybrid planning application. Given the scale of the Site and the long delivery period, the majority of the development will be sought in ‘outline’. As is common for schemes of this nature, the outline component of the application will be supported by a set of Parameter Plans and a Design Code which will set the envelope for the testing of the scheme in the Environmental Statement, and will create a flexible framework to control the submission of Reserved Matter Applications.
The outline application will be supported by an illustrative masterplan which will show one way the development might come forward consistent with the Parameter Plans and Design Code. However, this masterplan will only depict one possible outcome and is indicative.
It is entirely inappropriate to produce a masterplan that will be agreed with the Council, ahead of any planning application, and for that masterplan to guide future applications. The process of agreeing a masterplan ahead of the submission of an application would be an unnecessary step that would inevitably delay the submission of the application, without adding any benefit to the planning process. The same outcomes can be achieved through the application process.
In addition, to approve a masterplan ahead of the submission of a planning application would have the consequence of fettering the decision-making of the authority determining the application. An approved masterplan would fix certain elements of the scheme and the substantive content of an application before it has the benefit of full assessment through a suite of supporting information and an EIA is submitted with an application.
The paragraph should be deleted in full.

Place Book
The Regulation 19 wording has introduced the concept of a ‘Place Book’.
At criteria 3 of the policy it is suggested that a site-wide Place Book should be prepared to “establish the vision, place-making objectives and quality expectations for the new community and provide the foundation for a site-wide masterplan and design codes”.
Paragraph 3.2.4 of the explanatory text explains that the Place Book will “articulate the place-making principles, outcomes and quality expectations that will guide its planning, design and delivery. It will set out the characteristics, ambitions and defining qualities that are intended to shape the new settlement, whilst demonstrating how key themes such as movement, green and blue infrastructure, land use, community infrastructure, health and wellbeing, climate resilience, governance and stewardship should work together to create a sustainable, distinctive and well-connected place”.
Paragraph 3.2.5 also explains that the Place Book will “provide the foundation for subsequent spatial planning and design work, informing the preparation of a site wide masterplan, together with parameter plans, a strategic design code, place briefs and detailed design codes. These documents will translate the vision, principles and outcomes established through the place book into a coherent spatial structure and development framework capable of phased implementation whilst maintaining a consistent and high-quality sense of place throughout the lifetime of the development”.
Hill endorse the need for the Cambridge East planning application to address the matters referred to in the policy and supporting text – namely ‘place-making principles, outcomes and quality expectations that will guide its planning, design and delivery. As is traditional for applications of this nature, Hill propose to address these matters within the body of key application documents in particular the Parameter Plans and Design Code.
However, the current drafting suggests (much like the masterplanning process) that the Place Book will be prepared and agreed with the Council prior to the submission of an application, in order to inform the Parameter Plans and Design Code. Hill consider this to be an unnecessary step that will have the effect of delaying the submission of the application, without adding any benefit to the planning process. Instead, the applicant and local planning authority should work together constructively through the pre-application process, with the ultimate control being that if agreement is not reached planning permission will not be granted.

Quantum
Marshall’s Regulation 18 representations confirmed that capacity testing and supporting technical evidence that had been prepared demonstrated that Cambridge East could accommodate development at a scale significantly greater than that proposed in the draft allocation.
While the draft allocation identified capacity for approximately 8,000 dwellings, Marshall’s position was that this figure should be treated as a minimum, reflecting the site's extensive brownfield characteristics, sustainable location, and the benefits of the proposed Cambridge East station, which would support higher densities and a greater quantum of employment floorspace.
Marshall also highlighted that the policy understated the site's economic potential, contending that Cambridge East could accommodate world-class employment development alongside a substantially larger residential-led mixed-use community.
Since the Regulation 18 representations were submitted, two significant changes have occurred that further strengthen the points raised in those representations in respect of quantum.
Firstly, EWR has confirmed through its DCO consultation in April – June 2026 that a Cambridge East station will form part of the scope of the project. This was anticipated in the supporting text of the Regulation 18 version of the Plan which acknowledged that “if a station were to be included in the East West Rail Development Consent Order application this would alter the local context; this could therefore result in a change of scale and layout of development at Cambridge East to that outlined above.”
The confirmation of the station, therefore, represents a significant material change in circumstances which has not been reflected through changes to the policy. The failure of the policy to respond meaningfully to the confirmation of the station means the Plan is already lagging behind the evolving strategic context for Cambridge. The station significantly enhances the sustainability credentials of the allocation, creates opportunities for higher density development particularly in the south of the site and reinforces the site's overall ability to accommodate a greater quantum of housing and employment development. The policy should fully reflect the opportunity presented by this station by optimising quantum and density of development on the site.
This is not currently reflected in the policy. Hill note that whilst some additional text has been added to the policy recognising that the development must realise the strategic opportunity presented by Cambridge East railway station, it continues to refer to the same scale and quantum.
Secondly, ownership of the site transferred from Marshall to Hill / HE in June 2026. The allocation is therefore entering a new phase, with a comprehensive masterplanning exercise now being progressed by parties whose shared ambition is to deliver a high-quality, sustainable and nationally significant new city district.
Hill's experience of delivering large-scale mixed-use communities provides a strong platform for a more ambitious vision for the site. The emerging masterplanning process will test how best to optimise the opportunities presented by the site, including the confirmed railway station, whilst delivering exemplary placemaking.
Against this context, it is surprising that the policy continues to identify the same development quantum as the Regulation 18 version of the Plan. This is reinforced in the new NPPF (2026) which makes clear at Policies L2 and L3 (which immediately take effect in decision-taking) that brownfield land should be optimised by achieving appropriate densities in order to meet as much housing need as possible. Policy L3(2)(a) specifically states that “within settlements, development proposals for residential and mixed-use development should contribute to an increase in the density of the area in which they are situated.”
NPPF Policy L3 is clear that development proposals that do not make efficient use of land will be refused. This is the policy test that any application at Cambridge East will be required to demonstrate.
Overall, the changes in circumstances since Regulation 18 significantly strengthen the case that the quantum identified for Cambridge East is no longer an appropriate reflection of the site's development potential. The confirmation that a Cambridge East station will be delivered through the EWR DCO process, together with the transfer of the site into the control of Hill and Homes England and the commencement of a comprehensive masterplanning exercise, materially alter the context within which the allocation should be planned and delivered. These changes reinforce the conclusions of the Regulation 18 representations that the site is capable of accommodating development at a scale substantially greater than 8,000 dwellings whilst continuing to deliver high-quality placemaking, sustainable transport outcomes and significant employment growth.
In these circumstances, it is difficult to justify the continued inclusion of the same approximate quantum that appeared in the Regulation 18 draft Plan. The allocation now benefits from a confirmed strategic transport investment that will support higher densities and more intensive development, particularly around the station area, and national policy is increasingly focused on optimising the use of sustainable brownfield land. Retaining an unchanged figure risks unnecessarily constraining the long-term potential of the Site.
Whilst the ongoing masterplanning process will establish the most appropriate development capacity for the site, it would be premature to replace the existing figure with a higher specific number that has not yet been formally tested and evidenced. The more appropriate response is for the policy to recognise that 8,000 dwellings represents a minimum capacity rather than an approximate capacity. This would ensure the allocation remains sufficiently flexible to respond to the confirmed station and the emerging evidence base whilst remaining consistent with national planning guidance.

Specific Uses
In the Regulation 18 representations, Marshall supported the objective of delivering a genuinely mixed-use development at Cambridge East but set out that the policy should retain sufficient flexibility to allow the future masterplan to determine the most appropriate mix of uses and development quantum. Marshall considered that references to specific facilities and a fixed requirement for 10% specialist housing were overly prescriptive at this stage and should instead be guided by up-to-date evidence of need, market demand and placemaking considerations over the long-term build-out of the site.
Rather than responding to those concerns, the Regulation 19 version of Policy S/CE has become increasingly prescriptive, with additional requirements and specific facilities now identified within the draft policy. This is considered to be inappropriate for a policy that is intended to operate at a strategic level.
Specific concerns are as follows:
• 10% of the homes are to be specialist accommodation (within use classes C2 or C3) particularly for older people or those with disabilities (policy criteria 7aii) – Hill support the need for the development to include a range of dwelling types and tenure, importantly including specialist accommodation, however, the 10% requirement is unnecessary and is not supported by the evidence base. GCSP’s Development Strategy Topic Paper Appendix 12 confirms that the Housing Needs of Specific Groups (HNSG) Update “potentially overstates the level of need” (paragraph 1.3). The HNSG makes clear that the current and future demand for specialist accommodation is influenced by a host of factors. On that basis, it is premature to assume what percentage of the houses will be needed for specialist accommodation. The requirement is also inconsistent with other policies in the Plan, such as Policy H/SH which allow schemes to provide their own evidence. Policy H/SH relates to specialist housing, and only requires unallocated schemes to provide 10%. Given there is already a policy proposed on specialist housing, any application would be determined in that context and therefore the unjustified level of specialist housing Policy S/CE is also unnecessary. The proportion of specialist housing should therefore be removed from the policy; • Provision of sports and leisure facilities (criteria 7di and 7dii) – Hill support the inclusion of sports and leisure facilities within the development, which may include a swimming pool and sports hall. However, the policy is unnecessarily prescriptive in specifying the dimensions of a swimming pool, identifying a preferred location, and requiring the sports hall to be collocated with the pool. At this stage of the masterplanning process it is premature to prescribe the form, scale, location and relationship of these facilities. These matters should instead be determined following a thorough masterplanning process;
• “Provision of a regional cultural hub that will complement and not compete with Cambridge city centre. This will include but not be limited to provision of a creative hub comprising a mix creative work, production and leisure spaces, and a community arts centre” (policy criteria 7e) – As above, Hill support the intent of the development accommodating cultural facilities, however, the specificity in the policy wording is not effective ahead of masterplanning and community engagement to ascertain the nature of those facilities.
Given the scale of the allocation and the need to complete a masterplanning process as part of a planning application, it is neither necessary nor appropriate for the policy to prescribe such detailed matters at this stage.
The needs of future residents, businesses, visitors and the wider Greater Cambridge area will continue to evolve over the lifetime of the development, as will the evidence base that informs infrastructure and community facility requirements.
The allocation is now entering a new phase under the ownership of Hill / HE, with a comprehensive masterplanning exercise having started and engagement with GCDC underway.
That process should be free to establish the most appropriate land use strategy for the site, informed by robust evidence, stakeholder engagement and a clear vision for the creation of a successful new city district. Whilst the policy should identify the broad range of uses that may be appropriate within a major mixed-use allocation, it should not seek to predetermine the precise nature, scale or specification of individual facilities.
Hill are open to a more flexible form of words that accepts that the scheme would be expected to include sports and leisure facilities which may include a swimming pool and indoor sports centre, and cultural facilities, but allows the nature of these uses to be informed by need and evidence within the planning application. Proposed amended wording is included in Table 3.1 below.

Heritage
At Regulation 18 stage, Marshall supported the objective of conserving and celebrating the site’s heritage assets, including the Grade II listed Control and Office Building, but considered that the policy was overly prescriptive in identifying specific buildings for retention and predetermining heritage outcomes ahead of the masterplanning process. Marshall highlighted that matters such as the treatment of Hangar 1, the relationship between new development and heritage assets, and the protection of Teversham’s setting should be addressed through detailed masterplanning.
Hill endorse the amendments to the wording of paragraph 10(a) which now seek to ensure that the retention of any historic buildings (beyond the control and office building) is determined based on a thorough assessment of their heritage significance through a planning application. However, some minor amendments to the policy wording are required (see Table 3.1) to ensure that the wording is not misinterpreted and to ensure that the text allows for buildings to be modified or removed if it is deemed that this forms part of the optimum approach once a thorough assessment has been undertaken.

Site Delivery
Marshall’s Regulation 18 representations highlighted the importance of retaining the site-specific viability provisions contained within the adopted Cambridge East Area Action Plan (“AAP”). These comments are still relevant as they have not been reflected in the current drafting. On the basis that the AAP will be superseded by the GCLP, the Development Plan will no longer acknowledge the specific viability considerations associated with the delivery of Cambridge East that have formed part of the planning framework for the site since adoption of the AAP.
The circumstances which justified the inclusion of site-specific viability wording in the AAP remain materially unchanged. Cambridge East remains a strategic, long-term development opportunity requiring substantial enabling investment, including infrastructure delivery, relocation of existing operations, demolition and remediation works. These are recognised characteristics of the site and should continue to be reflected in the policy framework.
The viability wording contained within the AAP provides an appropriate policy mechanism for recognising the unique and complex development circumstances of the site and the need to balance a wide range of policy, infrastructure and placemaking objectives as detailed proposals come forward, in accordance with Policy DM5 of the NPPF (2026). This approach was tested through the delivery of the Marleigh development and has provided a clear and effective framework for considering affordable housing and other planning obligations alongside the site's specific development requirements.
In the absence of any substantive change in circumstance that would justify a departure from the AAP approach, Hill consider it appropriate that the relevant viability provisions are carried forward into the Regulation 19 policy. Reinstating this wording would provide clarity and consistency for applicants, decision-makers and stakeholders, ensure continuity with the established planning framework for Cambridge East, and recognise the site's unique delivery context.

Transport
Transport is a significant consideration for the delivery and ultimate capacity of Cambridge East. Marshall’s Regulation 18 representations supported the sustainable transport principles then proposed for Policy S/CE, including low-car development, walkable neighbourhoods, high-quality active travel and public transport connections, mobility hubs and a monitor and manage approach. Those representations nevertheless identified the need for the policy to retain sufficient flexibility to respond to evolving evidence, infrastructure programmes and travel behaviour over the long build-out period. Hill continue to rely on those representations where they remain relevant.
The publication of the Interim Greater Cambridge Transport Strategy (GCTS) represents a material change since the Regulation 18 consultation and should be acknowledged in the Plan. Hill welcome the provision of an updated strategic framework and its emphasis on enabling growth through an integrated package of public transport, active travel and demand-management measures. This direction is consistent with the vision-led approach advocated at Regulation 18 and with the ambition for Cambridge East to be a highly sustainable, well-connected new city district.
3.61 However, the Interim GCTS does not remove the need for flexibility in Policy S/CE. A number of the strategic interventions relevant to Cambridge East remain subject to further development, funding, phasing and delivery decisions. The site-specific transport strategy should therefore be established through the planning application using the best available evidence at that time, with an appropriate trip budget agreed as part of that process and supported by monitoring, review and phased mitigation. Exact trip-budget figures or a fully defined package of strategic measures should not be fixed prematurely through the Local Plan, particularly where delivery depends on third parties or infrastructure beyond the Site.
The updated strategic context reinforces rather than diminishes the case made at Regulation 18. Cambridge East can directly deliver substantial walking, cycling, public transport and mobility infrastructure within the Site, facilitate wider connections and make appropriate contributions to off-site measures. Its transport strategy must also respond positively to the confirmed Cambridge East railway station, the proposed Newmarket Road Travel Hub and emerging wider connections, whilst recognising the existing trip-making associated with the operational airport as a basis for early phases. The amendments proposed in Table 3.1 accordingly seek a proportionate, evidence-led and adaptive framework that secures sustainable outcomes without constraining the Site’s development potential before the relevant modelling and application-stage assessment have been completed.

Hill full representations are set out within the attached document named: "GCLP Reg 19 Consultation Representations - Cambridge East". Specifically please see Section 4: Development Management Policies for relevant comments regarding Policy CC/NZ.

Hill full representations are set out within the attached document named: "GCLP Reg 19 Consultation Representations - Cambridge East". Specifically please see Section 4: Development Management Policies for relevant comments regarding Policy CC/NZ.

Policy CC/NZ: Net zero carbon new buildings
Hill support the ambition of reducing carbon emissions and delivering highly sustainable development. However, Cambridge East is at an early stage in the masterplanning process and detailed work is currently underway to establish the most appropriate development framework, mix of uses, density profile, infrastructure strategy, energy strategy and delivery approach for the allocation. The implications of the draft Net zero carbon new buildings policy, including the cumulative impact of the various performance standards and requirements, cannot therefore be fully assessed at this stage. The ongoing comprehensive masterplanning exercise will provide the evidence necessary to understand how such requirements can be integrated into the development in a manner that is technically feasible, deliverable and consistent with the wider placemaking objectives of the allocation.
In these circumstances, this representation should be treated as a holding representation. Hill reserve the right to provide further evidence and detailed comments on the policy requirements through the examination process once the masterplanning, technical assessments and supporting evidence base have evolved sufficiently to enable a robust assessment of the policy's implications for the development and delivery of Cambridge East. The absence of detailed comments at this stage should not be interpreted as agreement with the policy requirements or an acceptance that they are justified, effective or consistent with national policy.

Hill full representations are set out within the attached document named: "GCLP Reg 19 Consultation Representations - Cambridge East". Specifically please see Section 2: GCLP Strategic Approach & Cambridge East for relevant comments regarding Policy S/DS.

Hill full representations are set out within the attached document named: "GCLP Reg 19 Consultation Representations - Cambridge East". Specifically please see Section 2: GCLP Strategic Approach & Cambridge East for relevant comments regarding Policy S/DS.

It is evident from the latest wording of draft Policy S/DS, and it is confirmed through the Development Strategy Topic Paper, that there are no substantial amendments to the approach to the development strategy in the Regulation 19 version of the GCLP. Therefore, the draft policy confirms that the need for jobs and homes will be met through a blended strategy on sites in the following order of preference:
- Within the Cambridge urban area;
- On the edge of Cambridge;
- At an expanded Cambourne;
- At other new settlements; and
In the rural southern cluster and wider rural area at Rural Centres and Minor Rural Centres.
On that basis, Hill wish to reiterate the comments submitted through Marshall’s Regulation 18 representations, which remain relevant following publication of the Regulation 19 evidence base.
Whilst draft Policy S/DS is presented as a strategy to support sustainable growth, climate change objectives and a polycentric pattern of development, the practical effect of the policy is to prioritise the retention of Green Belt land over the delivery of growth in the most sustainable locations.
The chosen strategy is inconsistent with the Councils' own evidence base, which repeatedly identifies Edge of Cambridge Green Belt locations as among the most sustainable locations for growth.
Should the Local Plan Inspectors conclude that the GCLP should plan for a higher level of growth and/or that it should provide additional sites to enable choice and flexibility to achieve growth requirements, Hill reiterate representations submitted at Regulation 18 stage on the appropriateness of the Expansion Land (as described later in this section) for development, as part of a coordinated Cambridge East development.

Hill full representations are set out within the attached document named: "GCLP Reg 19 Consultation Representations - Cambridge East". Specifically please see Section 4: Development Management Policies for relevant comments regarding Policy BG/BG.

Hill full representations are set out within the attached document named: "GCLP Reg 19 Consultation Representations - Cambridge East". Specifically please see Section 4: Development Management Policies for relevant comments regarding Policy BG/BG.

Policy BG/BG: Biodiversity and geodiversity
Policy BG/BG remains fundamentally unchanged from the Regulation 18 version and therefore the points raised in Marshall’s previous representations (provided as Appendix 1) in relation to the policy’s inconsistency with Government guidance, still stand.
The policy requires major development to provide a minimum 20% biodiversity net gain on-site where feasible and effective, or off-site where on-site options for BNG have been evidenced and exhausted, as agreed with the LPA. Schedule 7A of the Town and Country Planning Act 1990 (inserted by the Environment Act 2021) states that all developments are to deliver at least a 10% increase in biodiversity value relative to the pre-development biodiversity value of the onsite habitat, unless the development falls within one of the exemptions.
The NPPG directs that:
“Plan-makers should not seek a higher percentage than the statutory objective of 10% biodiversity net gain, either on an area-wide basis or for specific allocations for development unless justified. To justify such policies they will need to be evidenced including as to local need for a higher percentage, local opportunities for a higher percentage and any impacts on viability for development. Consideration will also need to be given to how the policy will be implemented.” (Paragraph: 006, Reference ID: 74-006-20240214).
Hill supports achieving BNG across Greater Cambridge. However, a ‘blanket’ BNG expectation exceeding 10% appears to contradict the NPPG, which advocates enhanced BNG delivery at a site-specific level based on its merits.
The Biodiversity and Green Spaces Topic Paper lists 8 sites in Table 1 that have achieved over 20% BNG since the mandatory requirement began. Of these, five sites have 12 units or fewer, while the remaining three involve schemes with 70, 120 dwellings, and a commercial development. Table 2 covers sites with planned BNG before the mandatory target; most are purely commercial projects without the infrastructure conflicts typical of large-scale mixed-use developments. Several of these permissions include conditions for a minimum of 10% BNG, aligned with the current statutory requirement. The evidence suggests that achieving a 20% BNG target for major strategic mixed-use sites, which may have additional infrastructure needs, appears unlikely at this time, unless opportunities for the delivery of strategic, landscape-scale mitigation and compensation can be brought forward.
We would welcome a nuanced site-specific approach.

Hill full representations are set out within the attached document named: "GCLP Reg 19 Consultation Representations - Cambridge East". Specifically please see Section 4: Development Management Policies for relevant comments regarding Policy BG/EO.

Hill full representations are set out within the attached document named: "GCLP Reg 19 Consultation Representations - Cambridge East". Specifically please see Section 4: Development Management Policies for relevant comments regarding Policy BG/EO.

Policy BG/EO: Providing and enhancing open spaces
Policy BG/EO was introduced as part of the Regulation 19 process and is supported by a report prepared by LUC – ‘Green Infrastructure and Open Spaces Standards Framework’ Final Report June 2026. Both have been carefully reviewed by Hill and their technical team.
Hill support the principle of an open space policy to ensure that adequate and proportionate provision is made in support of new communities. However, Hill are extremely concerned that the proposed policy as drafted will undermine the successful delivery of one of, if not the, most important site allocation to the growth of Greater Cambridge.
In respect of commercial development, criteria 4 of the policy requires open space equivalent to 2 ha per 1000 employees.
Whilst Hill agree that workplace environments should support health and wellbeing, it is not appropriate for a strategic mixed-use development such as Cambridge East to require a minimum standard of greenspace for commercial / employment development.
Cambridge East is acknowledged to be one of the most sustainable locations to accommodate growth across Greater Cambridge. Consistent with national planning policy, development in these locations should be optimised. This is reinforced by the confirmation that EWR will include a station at Cambridge East. Having already been accepted as a sustainable site, the confirmation of a rail station is a step change in the density of development that should be accommodated to secure maximum benefit of the public transport opportunities it will provide.
At this early stage of the masterplanning process the precise scale of commercial development is unknown. However, consistent with Government aspirations for Greater Cambridge and in light of the availability of a rail station, Hill wish to embrace the objective to maximise economic opportunities. Hill are testing a variety of schemes including one that accommodates c4.5m sqft (NIA) of office / lab floorspace. Based on the requirements of the policy, this scenario would generate (subject to assumptions on development form and employment density) a requirement for c.42 ha of open space, which would cover (alongside the area of the office / lab development itself) approximately 45% of the site (excluding the green corridor), before any residential homes or associated community facilities are considered.
The outcomes of the policy are disproportionate and not appropriate to a strategic mixed-use site such as Cambridge East. Hill consider criteria 4 of the policy to be unsound. It should be deleted in full or express reference should be added to confirm it does not apply to Cambridge East.
For residential led development, the draft policy directs the promoter to provide a total area of 7ha per 1000 population - 3ha provided on site and 4 ha provided offsite.
The 3 ha per 1000 onsite provision broadly aligns with the Fields in Trust standard that is often applied in local plans. However, the GCLP draft policy excludes play space and food growing space from this area allowance – effectively extending the total area requirement to 4 ha per 1000 population.
Hill do not consider that the justification for play space and food growing space being separately counted due it not being ‘accessible’ is justified. Growing space and play provision allowances should be included in the on-site open space allowance.
Within the context of the policy requirement for 3ha per 1,000 population (including food growing and play space), Hill would also raise the following points:
Large scale open spaces are often not conducive to “compact, walkable and sustainable urban form”. As a result, for strategic sites such as Cambridge East, the open space metrics should be seen as a maximum with impact on urban form given primacy where provision of the maximum amount of open space would compromise that. The policy should explicitly recognise the need for site specific circumstances to be considered.
Specifically in respect of Cambridge Airport, this policy (or Policy S/CE) should make it explicit that provision of space within the green corridor counts towards the on-site provision of open space.
Provision of outdoor sport that better serves the needs of a wider range of ages and types of people (including women) should be explicitly referenced.
The scale of offsite accessible open space provision is significant and represents a potential risk to development delivery. Hill support the policy ambition for a ‘no net loss of accessible open space per capita’, however in its current form it places a potentially exceptional burden on development with a requirement for 4ha per 1000 population to be provided over and above the on-site requirement.
Hill suggest that a clear and proportionate policy is required that considers each project on its merits. The policy should be amended to recognise that off-site provision must be assessed on a site-specific basis and be directly relevant, necessary and proportionate to development impacts.
Hill consider it necessary that the policy be amended as explained above in order to be found sound.

Hill full representations are set out within the attached document named: "GCLP Reg 19 Consultation Representations - Cambridge East". Specifically please see Section 4: Development Management Policies for relevant comments regarding general comments on Wellbeing and Social Inclusion policies.

Hill full representations are set out within the attached document named: "GCLP Reg 19 Consultation Representations - Cambridge East". Specifically please see Section 4: Development Management Policies for relevant comments regarding general comments on Wellbeing and Social Inclusion policies.

Chapter 6 (Wellbeing and Social Inclusion) & Chapter 7 (Great Places)
4.52 The policies in these chapters are well intentioned but there are many areas where the policies are:
 Repetitious – with many repeated references to the same principles. For example transport and accessibility of services and facilities, provision of routes and sustainability of transport are repeated throughout. There are 43 instances of the term “well designed”; 18 instances of “sustainable travel”. There are c.45 policy provisions or supporting statements that make explicit reference to locating development in sustainable locations; walking, cycling or active travel; or public transport and sustainable transport choices. Policy WS/HD acknowledges this cross reference but then continues to provide extensive supporting text that is unnecessary. Health or wellbeing are then mentioned in around 50 other places. We have no doubt these are important points but this can be dealt with through a single well worded policy, not to be repeated under every section.
 Highly subjective and qualitative – making them very challenging to meaningfully measure against or ensure compliance with, i.e. ‘well-designed’. The policies are full of caveats and exclusions, and we encourage the authority to consider whether, when such flexibility or range of variables is clearly needed, it is appropriate to be controlling these factors through the Local Plan process.
4.53 The supporting text has many contextual details that are interesting and could form guidance or ‘best practice notes’. But these sections add large amounts of text to an already very long document without illuminating the policy or aiding interpretation of that policy in any meaningful or specific way. They should be removed to aid overall clarity and brevity.

Hill full representations are set out within the attached document named: "GCLP Reg 19 Consultation Representations - Cambridge East". Specifically please see Section 4: Development Management Policies for relevant comments regarding general Great Places policies.

Hill full representations are set out within the attached document named: "GCLP Reg 19 Consultation Representations - Cambridge East". Specifically please see Section 4: Development Management Policies for relevant comments regarding general Great Places policies and Jobs.

Chapter 6 (Wellbeing and Social Inclusion) & Chapter 7 (Great Places)
The policies in these chapters are well intentioned but there are many areas where the policies are:
 Repetitious – with many repeated references to the same principles. For example transport and accessibility of services and facilities, provision of routes and sustainability of transport are repeated throughout. There are 43 instances of the term “well designed”; 18 instances of “sustainable travel”. There are c.45 policy provisions or supporting statements that make explicit reference to locating development in sustainable locations; walking, cycling or active travel; or public transport and sustainable transport choices. Policy WS/HD acknowledges this cross reference but then continues to provide extensive supporting text that is unnecessary. Health or wellbeing are then mentioned in around 50 other places. We have no doubt these are important points but this can be dealt with through a single well worded policy, not to be repeated under every section.
 Highly subjective and qualitative – making them very challenging to meaningfully measure against or ensure compliance with, i.e. ‘well-designed’. The policies are full of caveats and exclusions, and we encourage the authority to consider whether, when such flexibility or range of variables is clearly needed, it is appropriate to be controlling these factors through the Local Plan process.
The supporting text has many contextual details that are interesting and could form guidance or ‘best practice notes’. But these sections add large amounts of text to an already very long document without illuminating the policy or aiding interpretation of that policy in any meaningful or specific way. They should be removed to aid overall clarity and brevity.

Policy J/AW: Affordable workspace and creative industries
Hill does not support the introduction of an affordable workspace policy in any form related to the Cambridge East site allocation.
Affordable workspace policies emerged from a concern in London that specific, niche, clustered businesses that have an economic or cultural benefit outside their immediate sphere (such as the historical, cultural and economic significance of Hatton Garden) could be under pressure from rent rises. In such specific and localised circumstances, it may be justified to implement policies to protect access for those business to workspace in that area.
There is no evidence to demonstrate that the use of more generalised affordable workspace policies is a good use of economic resources and planning powers for these reasons:
They represent a diversion of resources that effectively acts as a subsidy to private enterprises. There is no justification for mandating resources to be diverted from other obligations (affordable housing, open space, etc) to subsidise the operation of private business. This is an opportunity cost which, in a challenging market, is very unlikely to result in the best public outcomes;
It is unlikely to meet an unmet need. Even at very high discount rates, brand new Cat A floorspace is very unlikely to be more affordable than much of the space on the second-hand market. The effect is to subsidise businesses who are already doing relatively well. A blanket affordable workspace requirement also risks delivering space for which there is limited operator or occupier demand, particularly where it is not targeted at specific sectors or identified needs, potentially resulting in underutilised floorspace and reduced market flexibility. In some cases the beneficiaries may be a charity or social enterprise, but if the authority is intending to deliver a 10% of all net additional floorspace in its plan as affordable, that is well in excess of the space needed for such occupiers (90,000 sqm in total across the plan).
It creates a constraint and risk around delivery of business and employment space which is front and centre of the GCSP and national aspirations for growth. Cambridge is one of the most important growth zones in the UK and any impediment to growth in this area (such as occupation triggers, Grampians, and challenges of finding eligible operators and tenants) would add risk, complexity and investment aversion.
Many commercial operators chose to offer rent free periods, discounts, amortised fitouts and flexible terms in order to attract a wide range of occupiers and a resilient occupier base. It is very likely that such offers will be available at this site, but they should not be mandated. Small or flexible sized units are naturally more affordable and would generally be part of any strategic commercial offer. Commercial operators also voluntarily run incubators and SME hubs because it makes good business sense. These approaches do not need to be mandated but are a natural response from developers to placemaking, value creation and tenant offer, achieved without creating risk to investment in Cambridge.

Hill full representations are set out within the attached document named: "GCLP Reg 19 Consultation Representations - Cambridge East". Specifically please see Section 4: Development Management Policies for relevant comments regarding Policy GP/ST.

Hill full representations are set out within the attached document named: "GCLP Reg 19 Consultation Representations - Cambridge East". Specifically please see Section 4: Development Management Policies for relevant comments regarding Policy GP/ST.

Policy GP/ST: Skyline and Tall Buildings
The need to deliver growth across Greater Cambridge is well known. Government has made it clear that delivering transformational growth at Cambridge is a national priority and the GCDC has been set up to drive and accelerate the delivery of that growth.
Cambridge East represents a critical part of the development strategy for the GCLP and is also likely to play a significant role in GCDC’s wider growth aspirations. It is therefore essential that development plan policies do not inappropriately limit the scale of growth and ambition for Cambridge East.
The site allocation policy for Cambridge East (Policy S/CE) specifically recognises that the development will include height and massing to create a ‘distinctive city district’, which will include taller buildings in appropriate locations.
Whilst Hill accept the need for new development to respond appropriately to the existing context, the policies of the GCLP should be clearly prepared in the knowledge that to achieve the scale of growth that Government aspires to, development will naturally need to be transformational and at a higher density, mass and scale than the existing context.
However, Policy GP/ST is an example of a policy which is negatively drafted and is predicated on the premise that changes to the skyline should be by exception. That fails to recognise the scale of growth and ambition that Cambridge is required to accommodate. That of course does not mean that development should be allowed to happen at the expense of any change to the skyline, but the policy should recognise that change to the skyline is, by definition of the very scale of development proposed, inevitable, and the key objective should be to ensure that any change is carefully and appropriately assessed and managed.
The policy wording, supporting text and Appendix H, do not adequately reflect the positive aspects of the evidence base report – ‘Skyline and Tall Buildings Baseline, Strategy and Guidance’ (hereafter known as the ‘Skyline Strategy’) – and instead place emphasis on the application of restrictive policy rather than policy that promotes an informed approach to consideration of height and skyline matters.
While the general urban form of Cambridge is ‘subtle and a restrained skyline when viewed from most angles and distances in and around the city’ (Paragraph 2.6.2 of the Skyline Strategy), tall buildings are acknowledged as characteristic and not inconsistent with the city’s character, in particular around the Airport (Paragraphs 2.6.5 and 2.6.6 of the Skyline Strategy). The policy therefore needs to be framed to support the delivery of well-designed and appropriately located development. A change to the skyline could be perceived as positive and a new quarter in this part of the city could, in time itself become a valued part of the city’s skyline and character, much like many of the existing features.
In this context, Hill make two primary comments on draft Policy GP/ST and its supporting text.
Firstly, Criteria 1 of the policy states that proposals that ‘break’ or ‘result in significant change’ to the existing skyline, or are significantly taller than the surrounding build form, must demonstrate how they ‘maintain or enhance’ the skyline and character of Cambridge.
Development at Cambridge East, a highly sustainable location supported by a new EWR station, is likely to change the existing skyline – this is an inevitable outcome that follows the optimisation of the site and supporting transformational growth across Greater Cambridge.
Cambridge East is identified in the Skyline Strategy as ‘bracketing’ the views of the city along with Addenbrookes, and it is noted that the site is ‘distinct’ from the city. As a result, the evidence indicates that a continuation of suburban development is not required and that the distinct nature of the site presents an opportunity to bring forward a proposal that should consider more ambitious development heights than the surrounding suburban development while responding appropriately to the city’s character. This is not clearly reflected in the Skyline Strategy, for example Figure 27 (Tall Building Thresholds) which identifies the baseline for this part of the site as ‘suburban / low rural height zone’. This fails to recognise the core proposition behind the site allocation and the significant change in circumstances that arise from the confirmation of the new Cambridge East station to the immediate south of the site. Instead height proposals for major sites should be subject to separate, detailed review.
Consequently, the 'maintain and enhance' test does not adequately reflect the circumstances of Cambridge East. The evidence base identifies the site as a distinct location from the existing city and acknowledges the opportunity for a more ambitious approach to building heights. Given the scale of development proposed, changes to the skyline and townscape character will inevitably occur. As such, requiring the existing skyline to be 'maintained' is neither realistic nor aligned with the objectives of the allocation. In addition, the term 'enhance' is highly subjective and introduces unnecessary uncertainty. The policy should instead be amended to recognise that change may occur, provided it is appropriately justified through the design process and responds positively to the site's context and Cambridge's valued character.
Secondly, the policy and the explanatory text are supported by evidence in Appendix H and the Skyline Strategy. Hill’s technical team has carefully reviewed these documents and has identified as series of serious issues, including:
The Key View study within the Skyline Strategy, places emphasis on the existing character of the city as essentially low with localised tall historic buildings in the core and more modern tall buildings to the periphery (including the Airport site) which defines the skyline. This is particularly important for Cambridge East, where the scale of the allocation and its role as a major new urban extension will necessitate a degree of flexibility in building heights to support sustainable densities, create legible centres and landmarks, and respond to the emerging transport infrastructure, whilst ensuring that any impact on the wider city skyline is appropriately assessed and managed.
It is important to ensure matters of skyline character, visibility and historic setting are not confused - we are concerned that the matters appear to be conflated. In relation to Viewpoint K from Little Wilbraham Road, there appears to be no justification for the inclusion of that view within the set of strategic views for the Skyline Strategy and the Regulation 19 GCLP more generally. However, as set out in Appendix D of the Skyline Strategy and despite recognition of its ‘illustrative nature’ (Addendum to Heritage Impact Assessment (2026) - Appendix A), the view acts as a principal restriction to height at Cambridge East. As such, the elevation of View K to a strategic view in the Skyline Strategy, and subsequent integration into Appendix H and reference in Policy GP/ST 1B, is of significant concern.
It is also important to note that Strategic Views – Heritage Impact Assessment Baseline 2021 prepared by CBA states at paragraph 1.2.3 “… the study […] does not focus on an identified historic asset or defined group of assets […] Instead, it addresses Cambridge as a city, which is not a defined heritage asset.” Although heritage assets are advanced as reasons for limiting heights or ascribing sensitivities, heritage assessments are specifically aimed at the significance of a heritage asset, rather than the visibility of a heritage asset in a view being equated with a specific heritage sensitivity. Indeed, Historic England’s guidance on setting, The Setting of Heritage Assets, Historic Environment Good Practice Advice in Planning Note 3 (Second Edition – Dec. 2017) notes in the text box at the top right of page 7:
“Being tall structures, church towers and spires are often widely visible across land- and townscapes but, where development does not impact on the significance of heritage assets visible in a wider setting or where not allowing significance to be appreciated, they are unlikely to be affected by small-scale development, unless that development competes with them, as tower blocks and wind turbines may. Even then, such an impact is more likely to be on the landscape values of the tower or spire rather than the heritage values, unless the development impacts on its significance, for instance by impacting on a designed or associative view.”
The Skyline Strategy does not reflect Historic England’s guidance on setting. Instead, sweeping statements are made, for example under the guise of heritage assets, that contradict Historic England’s guidance on setting, e.g. paragraph 2.5.3:
“Many of the [heritage] assets contribute to the skyline of Cambridge in long distance, medium distance and close up views. In particular, the colleges and churches in and around the core are a key feature of the skyline of the City, marking its historic heart.”
The quote above has nothing to do with the significance of the heritage assets, and instead deals with the skyline of Cambridge, though this is cited under the heritage topic. The same section in the document appears to equate the visibility of taller structures with harm to heritage significance, a concept that has been dispelled in numerous appeal decisions but which appears to underpin the conclusions of the study.
It is also noted that heritage assets are highlighted in the various view analyses. Again, this may be relevant to aspects such as the skyline and landmarks, but in most cases the significance of the heritage asset in the views are not properly appreciable. The fact that a heritage asset is visible in a view does not mean the view contributes to its heritage significance. This distinction is not covered in the Skyline Strategy or Appendix H which instead appears to imply any view containing a heritage asset must be of some sensitivity.
The Appendix H and Skyline Strategy, identifies the area south of the green corridor as ‘Suburban /Rural Height Zone 13m (4+ Rst)’. This is assumed to be founded on the Skyline Strategy document, that identifies the existing settlement as Suburban /Rural Height Zone and ‘Somewhat Sensitive’ to tall buildings; an adjoining an area of outline permission with agreed height parameters; and adjoining existing open space that is ‘Highly Sensitive’ to tall building typologies.
However, the evidence fails to recognise that a) the ‘highly sensitive’ open space has tall buildings that appear in its views; b) tall buildings already exist at the Airport and c) the conscious decision to allocate significant growth at Cambridge East. Furthermore, a new EWR station is now to be delivered in the immediate vicinity of this location and as a result there is a clear policy direction that it should support an intensification of development. The new station provides a clear foundation to secure higher densities and by implication heights, which is not reflected in the approach of Appendix H or the Skyline Strategy document.
In light of the above, Hill consider the evidence base to be fundamentally flawed in a number of respects and as a result it should not be cited in the policy or supporting text as a basis for undertaking site specific assessments in support of planning applications. If despite our views reference to the document is to be retained in policy and / or supporting text, it will need to be comprehensively amended to address the matters raised above and associated concerns.
Overall, Hill consider Policy GP/ST to be unsound as drafted, and set out at Appendix 4 the alterations required to the policy wording and the supporting text.

Hill full representations are set out within the attached document named: "GCLP Reg 19 Consultation Representations - Cambridge East". Specifically please see Section 4: Development Management Policies for relevant comments regarding Policy J/AW.

Hill full representations are set out within the attached document named: "GCLP Reg 19 Consultation Representations - Cambridge East". Specifically please see Section 4: Development Management Policies for relevant comments regarding Policy J/AW.

Policy J/AW: Affordable workspace and creative industries
Hill does not support the introduction of an affordable workspace policy in any form related to the Cambridge East site allocation.
Affordable workspace policies emerged from a concern in London that specific, niche, clustered businesses that have an economic or cultural benefit outside their immediate sphere (such as the historical, cultural and economic significance of Hatton Garden) could be under pressure from rent rises. In such specific and localised circumstances, it may be justified to implement policies to protect access for those business to workspace in that area.
There is no evidence to demonstrate that the use of more generalised affordable workspace policies is a good use of economic resources and planning powers for these reasons:
They represent a diversion of resources that effectively acts as a subsidy to private enterprises. There is no justification for mandating resources to be diverted from other obligations (affordable housing, open space, etc) to subsidise the operation of private business. This is an opportunity cost which, in a challenging market, is very unlikely to result in the best public outcomes;
It is unlikely to meet an unmet need. Even at very high discount rates, brand new Cat A floorspace is very unlikely to be more affordable than much of the space on the second-hand market. The effect is to subsidise businesses who are already doing relatively well. A blanket affordable workspace requirement also risks delivering space for which there is limited operator or occupier demand, particularly where it is not targeted at specific sectors or identified needs, potentially resulting in underutilised floorspace and reduced market flexibility. In some cases the beneficiaries may be a charity or social enterprise, but if the authority is intending to deliver a 10% of all net additional floorspace in its plan as affordable, that is well in excess of the space needed for such occupiers (90,000 sqm in total across the plan).
It creates a constraint and risk around delivery of business and employment space which is front and centre of the GCSP and national aspirations for growth. Cambridge is one of the most important growth zones in the UK and any impediment to growth in this area (such as occupation triggers, Grampians, and challenges of finding eligible operators and tenants) would add risk, complexity and investment aversion.
Many commercial operators chose to offer rent free periods, discounts, amortised fitouts and flexible terms in order to attract a wide range of occupiers and a resilient occupier base. It is very likely that such offers will be available at this site, but they should not be mandated. Small or flexible sized units are naturally more affordable and would generally be part of any strategic commercial offer. Commercial operators also voluntarily run incubators and SME hubs because it makes good business sense. These approaches do not need to be mandated but are a natural response from developers to placemaking, value creation and tenant offer, achieved without creating risk to investment in Cambridge.