Greater Cambridge Local Plan: Proposed Submission

That the Pre-Submission Local Plan be modified to allocate the Site for a new industrial/tech park at land north of A505, Duxford, supported by an appropriate site-specific policy and corresponding amendment to the Policies Map

Please refer to the submission attachments for the correctly formatted full submission, which includes figures.

1 Introduction

1.1.1 These representations have been prepared by Lanpro Services on behalf of Russell Smith Farms Ltd and Seatonhurst Limited (our clients). The representations respond to Greater Cambridge's Pre-Submission Local Plan Regulation 19 and how they relate to our clients' interest at land to the north of the A505, Duxford, Cambridgeshire ('the Site'). A location plan of the Site is shown at Appendix 1.

1.1.2 Lanpro Services did submit representations to Greater Cambridge's Regulation 18 consultation in January 2026 on behalf of Russell Smith Farms Ltd.

1.1.3 Since the submission of the Regulation 18 representations, Seatonhurst Ltd has purchased land within the wider holding. Therefore, these representations are submitted on behalf of both landowners.

1.1.4 Information on Seatonhurst Ltd is set out below. Details on Russell Smith Farms Ltd was provided as part of the response to Greater Cambridge's Regulation 18 consultation, so this has not been repeated for brevity.

1.1.5 Alongside the response to the Regulation 18 Consultation, the Site has been promoted during the Call for Sites process. It was promoted as new sustainable settlement for employment uses, with a focus on life sciences, Mid Tech and startup as well as other specialist types of employment space, including data centres. The sustainable settlement is also seeking to provide a community hub, including retail, sports, leisure and community uses as well as a strategic mobility hub.

1.1.6 Our clients have been engaging in positive discussions with key neighbouring stakeholders, including the Imperial War Museum, Duxford (IWM) and the promoters of the proposed Aviation Technology Campus. In particular, our clients are undertaking technical engagement to ensure that any development would not cause unacceptable impacts on the flying activity at the IWM.

1.1.7 Since the submission of the previous representations, there has been additional evidence published by Greater Cambridge, which affects the context of the Site; this is explicitly referenced in Section 1.3 below.

1.2 Seatonhurst Ltd
1.2.1 Seatonhurst Ltd is a property investment and development company based in Cambridge.

1.3 Greater Cambridge Green Belt Assessment: Review following changes to National Policy and Guidance (July 2026)

1.3.1 As part of its Regulation 18 representations, our clients set out justification that the Site falls within the definition of Grey Belt as set out in national policy and should be designated as part of the emerging Local Plan.

1.3.2 Given the size of the Site, it comprises a number of parcels. In the Regulation 18 consultation, our clients noted that the previous Green Belt Assessment published by the Council (August 2021)¹, concluded that two parcels did not 'strongly contribute' to the purposes of the Green Belt. These Parcels are listed below:
• Parcel HE2 (located to the west of the M11, adjacent to the Junction) – moderate high.
• Parcel HE3 (located to the west of Parcel HE2) - moderate

1.3.3 The other Parcels within the Site were considered to contribute either highly or very highly due to concerns about the merging of settlements.

1.3.4 Greater Cambridge's map showing the land to the west of M11 and its contribution to the purposes of the Green Belt is set out below:

Figure 1.1: Map showing Green Belt Assessment - Greater Cambridge Green Belt Assessment (2021)
[Please refer to the submission attachments for the referenced figure.]
1.3.5 Regarding to the land to the east of the M11, it was considered by the 2021 Green Belt Assessment that the land either contributed highly or very highly to the purposes of the Green Belt due the potential merging of settlements.

1.3.6 Greater Cambridge's map showing the land to the east of M11 and its contribution to the purposes of the Green Belt is set out below:

Figure 1.2: Map showing Green Belt Assessment - Greater Cambridge Green Belt Assessment (2021)
[Please refer to the submission attachments for the referenced figure.]

1.3.7 In July 2026, Greater Cambridge published an updated Green Belt Assessment². The aim of this assessment was to identify sites that could be considered as Grey Belt.

1.3.8 The Report notes that there are clear similarities between NPPF Purpose a) and Purpose b) in the 2021 Green Belt Assessment. However, the 2026 Report noted that the city only has a Green Belt because of its historic character, so a more helpful structure is to analyse sites against purpose d) of the 2024 NPPF "to preserve the setting and special character of historic towns" (paragraph 31.14).

1.3.9 The Assessment confirmed that the two parcels that did not 'strongly contribute' to the purposes of the Green Belt in the 2021 Assessment should, therefore, be designated as Green Belt.

1.3.10 These parcels are HE2 (moderate contribution to Purpose d) and HE3 (moderate contribution to Purpose d)).

1.3.11 The remaining Parcels were considered to 'strongly contribute' to Purpose d) and therefore, were not designated as Grey Belt.

1.3.12 Our clients are pleased that the updated evidence produced by Greater Cambridge indicates that some of the Parcels are Grey Belt. However, our clients still maintain that the other Parcels should be considered Grey Belt as they should be reflected on their own merits, against the Illustrative Plan, set out in the Vision Document that accompanied the Regulation 18 submission.

1.4 Regulation 19 Consultation
1.4.1 The Regulation 19 Consultation considers whether the Pre-Submission Local Plan is legally compliant and 'sound'.

1.4.2 Regarding whether the Plan is 'sound', it must meet the criteria set out in Paragraph 36 of the National Planning Policy Framework (NPPF). Our clients acknowledge that a subsequent NPPF was published in August 2026. However, it is the intention of Greater Cambridge to submit the emerging Local Plan to the Inspectorate in December 2025. Therefore, it will be assessed against the 2024 NPPF.

1.4.3 Paragraph 36 states that a Local Plan must be:
a) "Positively prepared providing a strategy which, as a minimum, seeks to meet the area's objectively assessed needs; and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development.
b) Justified- an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence.
c) Effective - deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than defend, as evidence by the statement of common ground.
d) Consistent with national policy- enabling the delivery of sustainable development in accordance with the policies in this Framework and other statements of national planning policy, where relevant."

1.4.4 Our clients do not consider that the emerging Local Plan is 'sound' as it does not meet criteria b) and c) of Paragraph 36.

1.4.5 Notwithstanding the above, the 2026 NPPF is clear at Appendix A that it is a material consideration, which must be taken into account in decision-making from the date of publication. In this context, our clients strongly contend that the direction of the 2026 NPPF should be reflected within the emerging Local Plan, specifically in relation to proposals that assist with housing delivery and achieving a strong and effective economy.

1.5 Structure of Document
1.5.1 These representations to the Greater Cambridge Regulation 19 consultation are structured as follows:
• Chapter 1: Introduction - This Chapter sets out an overview to these representations.
• Chapter 2: Response to consultation - This Chapter provides a response to the Greater Cambridge Pre-Submission Local Plan.
• Chapter 3: Conclusion - This Chapter summarises these representations.

2 Response to Consultation

2.1.1 This Chapter sets out our clients' response and considers issues that are relevant to this Regulation 19 Pre-Submission Local Plan.

2.1.2 Our clients have examined the evidence base behind the proposed allocations for employment uses to support Greater Cambridge's Employment Needs. Our clients do not consider that Greater Cambridge's ambitions for growth, particularly with regard to life sciences and Mid Tech accommodation.

2.2 Provision of Additional Space for Employment Uses to support Greater Cambridge's Employment Needs
2.2.1 Emerging Policy S/JH states that development will meet the objectively assessed needs in Greater Cambridge between 2024-2045 for 73,300 additional jobs to support Greater Cambridge's knowledge intensive sectors.

2.2.2 Part of the evidence to support Greater Cambridge's emerging Local Plan is the Greater Cambridge Warehouse and Industrial Spaces Needs (prepared by Iceni in March 2025) 3.

2.2.3 The conclusions of the Report note that there is a need for additional industrial and warehousing floorspace. These locations should be adjacent to the Strategic Road Network (M11, A14 and A428), which provide "optimum locations" (paragraph 7.21). Therefore, the Site is ideally located to support these types of commercial uses.

2.2.4 To meet its immediate needs for industrial floorspace and local needs for logistics floorspace, the Regulation 19 Local Plan proposes two new allocations in the A14 corridor, with longer term provision at an expanded Cambourne. The Regulation 19 Local Plan also proposes land at several mixed-use allocations for general industrial space.

2.2.5 Policy J/NE continues to explicitly state that there is a presumption against proposals for large-scale warehousing and distribution facilities providing for national or regional needs, unless in specific instances.

2.2.6 The proposed allocations for industrial growth are focused on the accessibility of the A14, yet Greater Cambridge's own evidence points to the M11 as also being an appropriate location. The 2026 NPPF (which Greater Cambridge should consider) has several policies on building an effective economy. Policy E2 states that specific locational requirements should be met. As stated above, the focus from Greater Cambridge is on provision along the M11. However, our clients consider that the Council has not sufficiently demonstrated that the geographical distribution of the allocations meet future occupiers' locational requirements. The Site adjacent to Junction 10 of the M11 provides a suitable alternative.

2.2.7 Policy E3 considers the suitability for freight and logistics. It states that development should have good access to transport networks and be sited and designed to limit environmental impacts. The Site is adjacent to the Strategic Road Network and can be designed to mitigate any impacts on existing settlements and is therefore located to support commercial, warehouse and logistic uses.

2.2.8 Mid tech (as one of the uses forming part of the tech park) comprises a mixture of Class 'B' uses with larger officer space. It supports Greater Cambridge's knowledge intensive sectors (principally life sciences and IT). Therefore, there is a growing need to provide these spaces during the emerging Local Plan Period.

2.2.9 The Report states that a new phase at Eddington meets the requirement for Mid Tech uses. The recent resolution to grant approval at Committee for Eddington Phase 2 has sought to provide flexibility employment floorspace for Class E(g) and sui generis (Greater Cambridge reference: 25/037456/OUT)⁴. This does not include a full complement of Mid Tech uses, which also comprise B2 and B8 uses.

2.2.10 Therefore, it is not considered that the proposed employment at Eddington meets the criteria set out in the 2025 Report and it is crucial that alternative provision is made to support these Mid Tech uses.

2.2.11 The Cambridge economy is recognised in the emerging Local Plan as being crucial both nationally and internationally (paragraph 2.68). The economic strategy to meet the emerging needs of Cambridge's differing sectors seeks to allocate emerging Mid Tech needs at Eddington and Cambridge East, with longer term provision at an expanded Cambourne (paragraph 2.69). it acknowledges that Mid Tech comprises Use Classes E(g)/B2/B8.

2.2.12 As stated above, the description of development for Eddington Phase 2 does not include B2/B8 uses so does not fall into the definition of Mid Tech. Therefore, there is a clear lack of employment floorspace to accommodate Mid Tech. Additional employment land should be allocated to help meet this shortfall.

2.2.13 In terms of Cambridge East, emerging Policy S/CE states that it will provide a new city district of approximately 8,000 homes delivered from 2032 and significant employment space, which includes 20,000sqm (GIA) of B2/B8 space for Mid Tech and general industrial uses.

2.2.14 As the emerging policy clearly states, housing is set to be delivered from 2032. Therefore, it is considered that the earliest both Mid Tech and general industrial floorspace could be delivered is also from 2032.

2.2.15 This is acknowledged in the 2025 Report (paragraph 7.22), which states:
"Cambridge East could play a role in meeting Mid Tech but is coming later in the Plan Period which would not meet shorter term demand"


2.2.16 The emerging Local Plan Policy also references Mid Tech to be delivered at an expanded Cambourne in the longer term (paragraph 2.69). However, this eventual allocation does not alleviate the need to provide Mid Tech uses in the early years of the Local Plan.

2.2.17 It is clear that there is an immediate shortfall in Mid Tech floorspace on the adoption of the Local Plan (anticipated in 2028) which is in conflict with Greater Cambridge which states that this is an "emerging need" (paragraph 2.69) and Greater Cambridge's own evidence base.

2.2.18 Greater Cambridge must allocate additional employment space that can be delivered early in the Plan Period to support its growth ambitions.

2.2.19 In summary, Eddington, Cambridge East and Cambourne are not considered to accommodate Mid Tech floorspace, which is required early in the Plan Period as there is a current demand. Additional land must be allocated, and the Site is ideally suited.

2.2.20 The Assessment states that there is a need for both general industrial space and Mid Tech, forming a new mixed industrial/tech park on the Strategic Road Network and has set this out as one of the recommendations in its Report (paragraph 7.25).

2.2.21 The Vision Document that was an appendix of the Regulation 18 representations, provided a masterplan which details how the employment could come forward, helping to meet Greater Cambridge's current shortfall.

2.2.22 The Vision Document also details other proposed uses for the scheme, which benefit existing residents. These include retail and leisure facilities as well as a strategic mobility hub located adjacent to Junction 10 of the M11. It shows an active travel corridor running through the Site and the strategic hub to Whittlesford and principally Whittlesford Parkway Train Station. Whittlesford Parkway provides regular services to London Liverpool Street, Cambridge (including Cambridge Biomedical Campus at Cambridge South) and Stansted Airport.

2.2.23 In conclusion, the Site is ideally located to meet the shortfall in commercial uses, particularly Mid Tech and industrial and logistics space due to its proximity to the Strategic Road Network (M11). The provision of a new mixed industrial/tech park on the Strategic Road Network is a recommendation in Greater Cambridge's own evidence base, and the Site is ideally suited to meet this recommendation

2.3 Emerging Policy S/GB - The Green Belt

2.3.1 Emerging Policy S/GB states that a Green Belt will be maintained around Cambridge to preserve the unique character of Cambridge, maintain and enhance the quality of its setting and prevent communities in the environs of Cambridge from merging into each other and Cambridge. It adds that new development will only be approved in accordance with policy set out in the NPPF.

2.3.2 The land is within the Green Belt. Given the size of the Site, a number of parcels have been assessed against the purposes of the Green Belt.

2.3.3 As stated in Chapter 1, two of the Parcels within the Site have been designated as Grey Belt, which our clients support. Tour clients are particularly pleased that Parcel HE2 (the proposed location for the Strategic Transport Hub) is designated as Grey Belt as it will support both the new employment site but also existing residents in nearby settlements.

2.3.4 However, our clients still have concerns about the accuracy of the updated Green Belt Assessment, with respect to the other Parcels.

2.3.5 Our clients maintain the conclusions set out in the Regulation 18 response in relation to Green Belt (shown at Appendix 2) are still valid. The proposed masterplan includes high- quality landscaping to reduce any threat of coalescence between the settlements which would affect the historic setting of the city.

2.3.6 Our clients would be willing to work with stakeholders throughout the process to consider additional mitigation measures where appropriate.

2.3.7 Despite our client's assertion that the Site can be considered Grey Belt, they nevertheless consider that there are "exceptional circumstances" to alter Green Belt boundaries, as per Paragraph 145 of the 2024 NPPF.

2.3.8 Greater Cambridge's own evidence base has confirmed that there is a need to provide an industrial/tech park adjacent to the Strategic Road Network to meet its commercial needs. The Site is ideally placed to provide this park as it is adjacent to Junction 10 of the M11. It can also seek to deliver the employment earlier in the Plan Period, which is noted by Greater Cambridge's own evidence, prior to Cambridge East coming forward.

2.3.9 Therefore, it should be considered favourably as an allocation in Greater Cambridge's emerging Local Plan.

3 Conclusion

3.1 Summary

3.1.1 In conclusion, our clients consider that the Plan would currently be found unsound at Examination as it is not considered justified or effective when assessed against the relevant tests in the 2024 iteration of the NPPF.

3.1.2 Regarding the delivery of commercial floorspace (particularly Mid Tech), the Plan relies of two edge-of-centre settlements, Eddington and Cambridge East with additional delivery in the expansion of Cambourne later in the Plan Period. Phase 2 of Eddington has just been given a resolution to grant at Committee. However, the description of development does not cite B2/B8 uses, which provide the flexibility for Mid Tech users.

3.1.3 In addition, the emerging Local Plan states that the initial houses will be delivered at Cambridge East in 2032. There is no immediate delivery in the emerging Local Plan to accommodate these uses, which is also the case for the proposed future allocations at Cambourne. The lack of sites that can be delivered earlier in the Plan Period has been acknowledged by Greater Cambridge's own evidence base but has not been carried forward into the actual Pre-Submission Local Plan.

3.1.4 Our client is pleased to note that the two of the Parcels has been designated as Grey Belt in Greater Cambridge's updated Green Belt Assessment, including the land proposed for the Sustainable Transport Hub.

3.1.5 However, our clients still have fundamental concerns that the conclusions regarding the other Parcels are not accurate as it has not considered the proposed mitigation measures set out in the Vision Document that accompanied the Regulation 18 representations (Appendix 2).

3.1.6 Given the overwhelming need for more employment to support Greater Cambridge's knowledge intensive sectors and the ideal location for the Site, adjacent to the Strategic Road Network, our clients request that the Pre-Submission Local Plan be modified to allocate the Site for a new industrial/tech park, supported by an appropriate site-specific policy and corresponding amendment to the Policies Map.

3.1.7 Our clients wish to participate in the relevant hearing sessions at the Examination in Public to explain and develop the matters raised in these representations.

Footnotes:
1 Appendix A - Contribution to CP1
2 Greater Cambridge Green Belt Assessment
3 EBGCLPIWSSMar25v1Mar25 0.pdf
4 25.03746.OUT and 25.03753.OUT Committee Report Final.pdf

[Please refer to the submission attachments for the appendices.]

Please refer to the submission attachments for the correctly formatted full submission, which includes figures.

1 Introduction

1.1.1 These representations have been prepared by Lanpro Services on behalf of Russell Smith Farms Ltd and Seatonhurst Limited (our clients). The representations respond to Greater Cambridge's Pre-Submission Local Plan Regulation 19 and how they relate to our clients' interest at land to the north of the A505, Duxford, Cambridgeshire ('the Site'). A location plan of the Site is shown at Appendix 1.

1.1.2 Lanpro Services did submit representations to Greater Cambridge's Regulation 18 consultation in January 2026 on behalf of Russell Smith Farms Ltd.

1.1.3 Since the submission of the Regulation 18 representations, Seatonhurst Ltd has purchased land within the wider holding. Therefore, these representations are submitted on behalf of both landowners.

1.1.4 Information on Seatonhurst Ltd is set out below. Details on Russell Smith Farms Ltd was provided as part of the response to Greater Cambridge's Regulation 18 consultation, so this has not been repeated for brevity.

1.1.5 Alongside the response to the Regulation 18 Consultation, the Site has been promoted during the Call for Sites process. It was promoted as new sustainable settlement for employment uses, with a focus on life sciences, Mid Tech and startup as well as other specialist types of employment space, including data centres. The sustainable settlement is also seeking to provide a community hub, including retail, sports, leisure and community uses as well as a strategic mobility hub.

1.1.6 Our clients have been engaging in positive discussions with key neighbouring stakeholders, including the Imperial War Museum, Duxford (IWM) and the promoters of the proposed Aviation Technology Campus. In particular, our clients are undertaking technical engagement to ensure that any development would not cause unacceptable impacts on the flying activity at the IWM.

1.1.7 Since the submission of the previous representations, there has been additional evidence published by Greater Cambridge, which affects the context of the Site; this is explicitly referenced in Section 1.3 below.

1.2 Seatonhurst Ltd
1.2.1 Seatonhurst Ltd is a property investment and development company based in Cambridge.

1.3 Greater Cambridge Green Belt Assessment: Review following changes to National Policy and Guidance (July 2026)

1.3.1 As part of its Regulation 18 representations, our clients set out justification that the Site falls within the definition of Grey Belt as set out in national policy and should be designated as part of the emerging Local Plan.

1.3.2 Given the size of the Site, it comprises a number of parcels. In the Regulation 18 consultation, our clients noted that the previous Green Belt Assessment published by the Council (August 2021)¹, concluded that two parcels did not 'strongly contribute' to the purposes of the Green Belt. These Parcels are listed below:
• Parcel HE2 (located to the west of the M11, adjacent to the Junction) – moderate high.
• Parcel HE3 (located to the west of Parcel HE2) - moderate

1.3.3 The other Parcels within the Site were considered to contribute either highly or very highly due to concerns about the merging of settlements.

1.3.4 Greater Cambridge's map showing the land to the west of M11 and its contribution to the purposes of the Green Belt is set out below:

Figure 1.1: Map showing Green Belt Assessment - Greater Cambridge Green Belt Assessment (2021)
[Please refer to the submission attachments for the referenced figure.]
1.3.5 Regarding to the land to the east of the M11, it was considered by the 2021 Green Belt Assessment that the land either contributed highly or very highly to the purposes of the Green Belt due the potential merging of settlements.

1.3.6 Greater Cambridge's map showing the land to the east of M11 and its contribution to the purposes of the Green Belt is set out below:

Figure 1.2: Map showing Green Belt Assessment - Greater Cambridge Green Belt Assessment (2021)
[Please refer to the submission attachments for the referenced figure.]

1.3.7 In July 2026, Greater Cambridge published an updated Green Belt Assessment². The aim of this assessment was to identify sites that could be considered as Grey Belt.

1.3.8 The Report notes that there are clear similarities between NPPF Purpose a) and Purpose b) in the 2021 Green Belt Assessment. However, the 2026 Report noted that the city only has a Green Belt because of its historic character, so a more helpful structure is to analyse sites against purpose d) of the 2024 NPPF "to preserve the setting and special character of historic towns" (paragraph 31.14).

1.3.9 The Assessment confirmed that the two parcels that did not 'strongly contribute' to the purposes of the Green Belt in the 2021 Assessment should, therefore, be designated as Green Belt.

1.3.10 These parcels are HE2 (moderate contribution to Purpose d) and HE3 (moderate contribution to Purpose d)).

1.3.11 The remaining Parcels were considered to 'strongly contribute' to Purpose d) and therefore, were not designated as Grey Belt.

1.3.12 Our clients are pleased that the updated evidence produced by Greater Cambridge indicates that some of the Parcels are Grey Belt. However, our clients still maintain that the other Parcels should be considered Grey Belt as they should be reflected on their own merits, against the Illustrative Plan, set out in the Vision Document that accompanied the Regulation 18 submission.

1.4 Regulation 19 Consultation
1.4.1 The Regulation 19 Consultation considers whether the Pre-Submission Local Plan is legally compliant and 'sound'.

1.4.2 Regarding whether the Plan is 'sound', it must meet the criteria set out in Paragraph 36 of the National Planning Policy Framework (NPPF). Our clients acknowledge that a subsequent NPPF was published in August 2026. However, it is the intention of Greater Cambridge to submit the emerging Local Plan to the Inspectorate in December 2025. Therefore, it will be assessed against the 2024 NPPF.

1.4.3 Paragraph 36 states that a Local Plan must be:
a) "Positively prepared providing a strategy which, as a minimum, seeks to meet the area's objectively assessed needs; and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development.
b) Justified- an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence.
c) Effective - deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than defend, as evidence by the statement of common ground.
d) Consistent with national policy- enabling the delivery of sustainable development in accordance with the policies in this Framework and other statements of national planning policy, where relevant."

1.4.4 Our clients do not consider that the emerging Local Plan is 'sound' as it does not meet criteria b) and c) of Paragraph 36.

1.4.5 Notwithstanding the above, the 2026 NPPF is clear at Appendix A that it is a material consideration, which must be taken into account in decision-making from the date of publication. In this context, our clients strongly contend that the direction of the 2026 NPPF should be reflected within the emerging Local Plan, specifically in relation to proposals that assist with housing delivery and achieving a strong and effective economy.

1.5 Structure of Document
1.5.1 These representations to the Greater Cambridge Regulation 19 consultation are structured as follows:
• Chapter 1: Introduction - This Chapter sets out an overview to these representations.
• Chapter 2: Response to consultation - This Chapter provides a response to the Greater Cambridge Pre-Submission Local Plan.
• Chapter 3: Conclusion - This Chapter summarises these representations.

2 Response to Consultation

2.1.1 This Chapter sets out our clients' response and considers issues that are relevant to this Regulation 19 Pre-Submission Local Plan.

2.1.2 Our clients have examined the evidence base behind the proposed allocations for employment uses to support Greater Cambridge's Employment Needs. Our clients do not consider that Greater Cambridge's ambitions for growth, particularly with regard to life sciences and Mid Tech accommodation.

2.2 Provision of Additional Space for Employment Uses to support Greater Cambridge's Employment Needs
2.2.1 Emerging Policy S/JH states that development will meet the objectively assessed needs in Greater Cambridge between 2024-2045 for 73,300 additional jobs to support Greater Cambridge's knowledge intensive sectors.

2.2.2 Part of the evidence to support Greater Cambridge's emerging Local Plan is the Greater Cambridge Warehouse and Industrial Spaces Needs (prepared by Iceni in March 2025) 3.

2.2.3 The conclusions of the Report note that there is a need for additional industrial and warehousing floorspace. These locations should be adjacent to the Strategic Road Network (M11, A14 and A428), which provide "optimum locations" (paragraph 7.21). Therefore, the Site is ideally located to support these types of commercial uses.

2.2.4 To meet its immediate needs for industrial floorspace and local needs for logistics floorspace, the Regulation 19 Local Plan proposes two new allocations in the A14 corridor, with longer term provision at an expanded Cambourne. The Regulation 19 Local Plan also proposes land at several mixed-use allocations for general industrial space.

2.2.5 Policy J/NE continues to explicitly state that there is a presumption against proposals for large-scale warehousing and distribution facilities providing for national or regional needs, unless in specific instances.

2.2.6 The proposed allocations for industrial growth are focused on the accessibility of the A14, yet Greater Cambridge's own evidence points to the M11 as also being an appropriate location. The 2026 NPPF (which Greater Cambridge should consider) has several policies on building an effective economy. Policy E2 states that specific locational requirements should be met. As stated above, the focus from Greater Cambridge is on provision along the M11. However, our clients consider that the Council has not sufficiently demonstrated that the geographical distribution of the allocations meet future occupiers' locational requirements. The Site adjacent to Junction 10 of the M11 provides a suitable alternative.

2.2.7 Policy E3 considers the suitability for freight and logistics. It states that development should have good access to transport networks and be sited and designed to limit environmental impacts. The Site is adjacent to the Strategic Road Network and can be designed to mitigate any impacts on existing settlements and is therefore located to support commercial, warehouse and logistic uses.

2.2.8 Mid tech (as one of the uses forming part of the tech park) comprises a mixture of Class 'B' uses with larger officer space. It supports Greater Cambridge's knowledge intensive sectors (principally life sciences and IT). Therefore, there is a growing need to provide these spaces during the emerging Local Plan Period.

2.2.9 The Report states that a new phase at Eddington meets the requirement for Mid Tech uses. The recent resolution to grant approval at Committee for Eddington Phase 2 has sought to provide flexibility employment floorspace for Class E(g) and sui generis (Greater Cambridge reference: 25/037456/OUT)⁴. This does not include a full complement of Mid Tech uses, which also comprise B2 and B8 uses.

2.2.10 Therefore, it is not considered that the proposed employment at Eddington meets the criteria set out in the 2025 Report and it is crucial that alternative provision is made to support these Mid Tech uses.

2.2.11 The Cambridge economy is recognised in the emerging Local Plan as being crucial both nationally and internationally (paragraph 2.68). The economic strategy to meet the emerging needs of Cambridge's differing sectors seeks to allocate emerging Mid Tech needs at Eddington and Cambridge East, with longer term provision at an expanded Cambourne (paragraph 2.69). it acknowledges that Mid Tech comprises Use Classes E(g)/B2/B8.

2.2.12 As stated above, the description of development for Eddington Phase 2 does not include B2/B8 uses so does not fall into the definition of Mid Tech. Therefore, there is a clear lack of employment floorspace to accommodate Mid Tech. Additional employment land should be allocated to help meet this shortfall.

2.2.13 In terms of Cambridge East, emerging Policy S/CE states that it will provide a new city district of approximately 8,000 homes delivered from 2032 and significant employment space, which includes 20,000sqm (GIA) of B2/B8 space for Mid Tech and general industrial uses.

2.2.14 As the emerging policy clearly states, housing is set to be delivered from 2032. Therefore, it is considered that the earliest both Mid Tech and general industrial floorspace could be delivered is also from 2032.

2.2.15 This is acknowledged in the 2025 Report (paragraph 7.22), which states:
"Cambridge East could play a role in meeting Mid Tech but is coming later in the Plan Period which would not meet shorter term demand"


2.2.16 The emerging Local Plan Policy also references Mid Tech to be delivered at an expanded Cambourne in the longer term (paragraph 2.69). However, this eventual allocation does not alleviate the need to provide Mid Tech uses in the early years of the Local Plan.

2.2.17 It is clear that there is an immediate shortfall in Mid Tech floorspace on the adoption of the Local Plan (anticipated in 2028) which is in conflict with Greater Cambridge which states that this is an "emerging need" (paragraph 2.69) and Greater Cambridge's own evidence base.

2.2.18 Greater Cambridge must allocate additional employment space that can be delivered early in the Plan Period to support its growth ambitions.

2.2.19 In summary, Eddington, Cambridge East and Cambourne are not considered to accommodate Mid Tech floorspace, which is required early in the Plan Period as there is a current demand. Additional land must be allocated, and the Site is ideally suited.

2.2.20 The Assessment states that there is a need for both general industrial space and Mid Tech, forming a new mixed industrial/tech park on the Strategic Road Network and has set this out as one of the recommendations in its Report (paragraph 7.25).

2.2.21 The Vision Document that was an appendix of the Regulation 18 representations, provided a masterplan which details how the employment could come forward, helping to meet Greater Cambridge's current shortfall.

2.2.22 The Vision Document also details other proposed uses for the scheme, which benefit existing residents. These include retail and leisure facilities as well as a strategic mobility hub located adjacent to Junction 10 of the M11. It shows an active travel corridor running through the Site and the strategic hub to Whittlesford and principally Whittlesford Parkway Train Station. Whittlesford Parkway provides regular services to London Liverpool Street, Cambridge (including Cambridge Biomedical Campus at Cambridge South) and Stansted Airport.

2.2.23 In conclusion, the Site is ideally located to meet the shortfall in commercial uses, particularly Mid Tech and industrial and logistics space due to its proximity to the Strategic Road Network (M11). The provision of a new mixed industrial/tech park on the Strategic Road Network is a recommendation in Greater Cambridge's own evidence base, and the Site is ideally suited to meet this recommendation

2.3 Emerging Policy S/GB - The Green Belt

2.3.1 Emerging Policy S/GB states that a Green Belt will be maintained around Cambridge to preserve the unique character of Cambridge, maintain and enhance the quality of its setting and prevent communities in the environs of Cambridge from merging into each other and Cambridge. It adds that new development will only be approved in accordance with policy set out in the NPPF.

2.3.2 The land is within the Green Belt. Given the size of the Site, a number of parcels have been assessed against the purposes of the Green Belt.

2.3.3 As stated in Chapter 1, two of the Parcels within the Site have been designated as Grey Belt, which our clients support. Tour clients are particularly pleased that Parcel HE2 (the proposed location for the Strategic Transport Hub) is designated as Grey Belt as it will support both the new employment site but also existing residents in nearby settlements.

2.3.4 However, our clients still have concerns about the accuracy of the updated Green Belt Assessment, with respect to the other Parcels.

2.3.5 Our clients maintain the conclusions set out in the Regulation 18 response in relation to Green Belt (shown at Appendix 2) are still valid. The proposed masterplan includes high- quality landscaping to reduce any threat of coalescence between the settlements which would affect the historic setting of the city.

2.3.6 Our clients would be willing to work with stakeholders throughout the process to consider additional mitigation measures where appropriate.

2.3.7 Despite our client's assertion that the Site can be considered Grey Belt, they nevertheless consider that there are "exceptional circumstances" to alter Green Belt boundaries, as per Paragraph 145 of the 2024 NPPF.

2.3.8 Greater Cambridge's own evidence base has confirmed that there is a need to provide an industrial/tech park adjacent to the Strategic Road Network to meet its commercial needs. The Site is ideally placed to provide this park as it is adjacent to Junction 10 of the M11. It can also seek to deliver the employment earlier in the Plan Period, which is noted by Greater Cambridge's own evidence, prior to Cambridge East coming forward.

2.3.9 Therefore, it should be considered favourably as an allocation in Greater Cambridge's emerging Local Plan.

3 Conclusion

3.1 Summary

3.1.1 In conclusion, our clients consider that the Plan would currently be found unsound at Examination as it is not considered justified or effective when assessed against the relevant tests in the 2024 iteration of the NPPF.

3.1.2 Regarding the delivery of commercial floorspace (particularly Mid Tech), the Plan relies of two edge-of-centre settlements, Eddington and Cambridge East with additional delivery in the expansion of Cambourne later in the Plan Period. Phase 2 of Eddington has just been given a resolution to grant at Committee. However, the description of development does not cite B2/B8 uses, which provide the flexibility for Mid Tech users.

3.1.3 In addition, the emerging Local Plan states that the initial houses will be delivered at Cambridge East in 2032. There is no immediate delivery in the emerging Local Plan to accommodate these uses, which is also the case for the proposed future allocations at Cambourne. The lack of sites that can be delivered earlier in the Plan Period has been acknowledged by Greater Cambridge's own evidence base but has not been carried forward into the actual Pre-Submission Local Plan.

3.1.4 Our client is pleased to note that the two of the Parcels has been designated as Grey Belt in Greater Cambridge's updated Green Belt Assessment, including the land proposed for the Sustainable Transport Hub.

3.1.5 However, our clients still have fundamental concerns that the conclusions regarding the other Parcels are not accurate as it has not considered the proposed mitigation measures set out in the Vision Document that accompanied the Regulation 18 representations (Appendix 2).

3.1.6 Given the overwhelming need for more employment to support Greater Cambridge's knowledge intensive sectors and the ideal location for the Site, adjacent to the Strategic Road Network, our clients request that the Pre-Submission Local Plan be modified to allocate the Site for a new industrial/tech park, supported by an appropriate site-specific policy and corresponding amendment to the Policies Map.

3.1.7 Our clients wish to participate in the relevant hearing sessions at the Examination in Public to explain and develop the matters raised in these representations.

Footnotes:
1 Appendix A - Contribution to CP1
2 Greater Cambridge Green Belt Assessment
3 EBGCLPIWSSMar25v1Mar25 0.pdf
4 25.03746.OUT and 25.03753.OUT Committee Report Final.pdf

[Please refer to the submission attachments for the appendices.]

That the Pre-Submission Local Plan be modified to allocate the Site for a new industrial/tech park at land north of A505, Duxford, supported by an appropriate site-specific policy and corresponding amendment to the Policies Map.

Our client is pleased to note that the two of the Parcels has been designated as Grey Belt in Greater Cambridge’s updated Green Belt Assessment, including the land proposed for the Sustainable Transport Hub. However, our clients still have fundamental concerns that the conclusions regarding the other Parcels are not accurate as it has not considered the proposed mitigation measures set out in the Vision Document that accompanied the Regulation 18 representations.

Please refer to the submission attachments for the correctly formatted full submission, which includes figures.

1 Introduction

1.1.1 These representations have been prepared by Lanpro Services on behalf of Russell Smith Farms Ltd and Seatonhurst Limited (our clients). The representations respond to Greater Cambridge's Pre-Submission Local Plan Regulation 19 and how they relate to our clients' interest at land to the north of the A505, Duxford, Cambridgeshire ('the Site'). A location plan of the Site is shown at Appendix 1.

1.1.2 Lanpro Services did submit representations to Greater Cambridge's Regulation 18 consultation in January 2026 on behalf of Russell Smith Farms Ltd.

1.1.3 Since the submission of the Regulation 18 representations, Seatonhurst Ltd has purchased land within the wider holding. Therefore, these representations are submitted on behalf of both landowners.

1.1.4 Information on Seatonhurst Ltd is set out below. Details on Russell Smith Farms Ltd was provided as part of the response to Greater Cambridge's Regulation 18 consultation, so this has not been repeated for brevity.

1.1.5 Alongside the response to the Regulation 18 Consultation, the Site has been promoted during the Call for Sites process. It was promoted as new sustainable settlement for employment uses, with a focus on life sciences, Mid Tech and startup as well as other specialist types of employment space, including data centres. The sustainable settlement is also seeking to provide a community hub, including retail, sports, leisure and community uses as well as a strategic mobility hub.

1.1.6 Our clients have been engaging in positive discussions with key neighbouring stakeholders, including the Imperial War Museum, Duxford (IWM) and the promoters of the proposed Aviation Technology Campus. In particular, our clients are undertaking technical engagement to ensure that any development would not cause unacceptable impacts on the flying activity at the IWM.

1.1.7 Since the submission of the previous representations, there has been additional evidence published by Greater Cambridge, which affects the context of the Site; this is explicitly referenced in Section 1.3 below.

1.2 Seatonhurst Ltd
1.2.1 Seatonhurst Ltd is a property investment and development company based in Cambridge.

1.3 Greater Cambridge Green Belt Assessment: Review following changes to National Policy and Guidance (July 2026)

1.3.1 As part of its Regulation 18 representations, our clients set out justification that the Site falls within the definition of Grey Belt as set out in national policy and should be designated as part of the emerging Local Plan.

1.3.2 Given the size of the Site, it comprises a number of parcels. In the Regulation 18 consultation, our clients noted that the previous Green Belt Assessment published by the Council (August 2021)¹, concluded that two parcels did not 'strongly contribute' to the purposes of the Green Belt. These Parcels are listed below:
• Parcel HE2 (located to the west of the M11, adjacent to the Junction) – moderate high.
• Parcel HE3 (located to the west of Parcel HE2) - moderate

1.3.3 The other Parcels within the Site were considered to contribute either highly or very highly due to concerns about the merging of settlements.

1.3.4 Greater Cambridge's map showing the land to the west of M11 and its contribution to the purposes of the Green Belt is set out below:

Figure 1.1: Map showing Green Belt Assessment - Greater Cambridge Green Belt Assessment (2021)
[Please refer to the submission attachments for the referenced figure.]
1.3.5 Regarding to the land to the east of the M11, it was considered by the 2021 Green Belt Assessment that the land either contributed highly or very highly to the purposes of the Green Belt due the potential merging of settlements.

1.3.6 Greater Cambridge's map showing the land to the east of M11 and its contribution to the purposes of the Green Belt is set out below:

Figure 1.2: Map showing Green Belt Assessment - Greater Cambridge Green Belt Assessment (2021)
[Please refer to the submission attachments for the referenced figure.]

1.3.7 In July 2026, Greater Cambridge published an updated Green Belt Assessment². The aim of this assessment was to identify sites that could be considered as Grey Belt.

1.3.8 The Report notes that there are clear similarities between NPPF Purpose a) and Purpose b) in the 2021 Green Belt Assessment. However, the 2026 Report noted that the city only has a Green Belt because of its historic character, so a more helpful structure is to analyse sites against purpose d) of the 2024 NPPF "to preserve the setting and special character of historic towns" (paragraph 31.14).

1.3.9 The Assessment confirmed that the two parcels that did not 'strongly contribute' to the purposes of the Green Belt in the 2021 Assessment should, therefore, be designated as Green Belt.

1.3.10 These parcels are HE2 (moderate contribution to Purpose d) and HE3 (moderate contribution to Purpose d)).

1.3.11 The remaining Parcels were considered to 'strongly contribute' to Purpose d) and therefore, were not designated as Grey Belt.

1.3.12 Our clients are pleased that the updated evidence produced by Greater Cambridge indicates that some of the Parcels are Grey Belt. However, our clients still maintain that the other Parcels should be considered Grey Belt as they should be reflected on their own merits, against the Illustrative Plan, set out in the Vision Document that accompanied the Regulation 18 submission.

1.4 Regulation 19 Consultation
1.4.1 The Regulation 19 Consultation considers whether the Pre-Submission Local Plan is legally compliant and 'sound'.

1.4.2 Regarding whether the Plan is 'sound', it must meet the criteria set out in Paragraph 36 of the National Planning Policy Framework (NPPF). Our clients acknowledge that a subsequent NPPF was published in August 2026. However, it is the intention of Greater Cambridge to submit the emerging Local Plan to the Inspectorate in December 2025. Therefore, it will be assessed against the 2024 NPPF.

1.4.3 Paragraph 36 states that a Local Plan must be:
a) "Positively prepared providing a strategy which, as a minimum, seeks to meet the area's objectively assessed needs; and is informed by agreements with other authorities, so that unmet need from neighbouring areas is accommodated where it is practical to do so and is consistent with achieving sustainable development.
b) Justified- an appropriate strategy, taking into account the reasonable alternatives, and based on proportionate evidence.
c) Effective - deliverable over the plan period, and based on effective joint working on cross-boundary strategic matters that have been dealt with rather than defend, as evidence by the statement of common ground.
d) Consistent with national policy- enabling the delivery of sustainable development in accordance with the policies in this Framework and other statements of national planning policy, where relevant."

1.4.4 Our clients do not consider that the emerging Local Plan is 'sound' as it does not meet criteria b) and c) of Paragraph 36.

1.4.5 Notwithstanding the above, the 2026 NPPF is clear at Appendix A that it is a material consideration, which must be taken into account in decision-making from the date of publication. In this context, our clients strongly contend that the direction of the 2026 NPPF should be reflected within the emerging Local Plan, specifically in relation to proposals that assist with housing delivery and achieving a strong and effective economy.

1.5 Structure of Document
1.5.1 These representations to the Greater Cambridge Regulation 19 consultation are structured as follows:
• Chapter 1: Introduction - This Chapter sets out an overview to these representations.
• Chapter 2: Response to consultation - This Chapter provides a response to the Greater Cambridge Pre-Submission Local Plan.
• Chapter 3: Conclusion - This Chapter summarises these representations.

2 Response to Consultation

2.1.1 This Chapter sets out our clients' response and considers issues that are relevant to this Regulation 19 Pre-Submission Local Plan.

2.1.2 Our clients have examined the evidence base behind the proposed allocations for employment uses to support Greater Cambridge's Employment Needs. Our clients do not consider that Greater Cambridge's ambitions for growth, particularly with regard to life sciences and Mid Tech accommodation.

2.2 Provision of Additional Space for Employment Uses to support Greater Cambridge's Employment Needs
2.2.1 Emerging Policy S/JH states that development will meet the objectively assessed needs in Greater Cambridge between 2024-2045 for 73,300 additional jobs to support Greater Cambridge's knowledge intensive sectors.

2.2.2 Part of the evidence to support Greater Cambridge's emerging Local Plan is the Greater Cambridge Warehouse and Industrial Spaces Needs (prepared by Iceni in March 2025) 3.

2.2.3 The conclusions of the Report note that there is a need for additional industrial and warehousing floorspace. These locations should be adjacent to the Strategic Road Network (M11, A14 and A428), which provide "optimum locations" (paragraph 7.21). Therefore, the Site is ideally located to support these types of commercial uses.

2.2.4 To meet its immediate needs for industrial floorspace and local needs for logistics floorspace, the Regulation 19 Local Plan proposes two new allocations in the A14 corridor, with longer term provision at an expanded Cambourne. The Regulation 19 Local Plan also proposes land at several mixed-use allocations for general industrial space.

2.2.5 Policy J/NE continues to explicitly state that there is a presumption against proposals for large-scale warehousing and distribution facilities providing for national or regional needs, unless in specific instances.

2.2.6 The proposed allocations for industrial growth are focused on the accessibility of the A14, yet Greater Cambridge's own evidence points to the M11 as also being an appropriate location. The 2026 NPPF (which Greater Cambridge should consider) has several policies on building an effective economy. Policy E2 states that specific locational requirements should be met. As stated above, the focus from Greater Cambridge is on provision along the M11. However, our clients consider that the Council has not sufficiently demonstrated that the geographical distribution of the allocations meet future occupiers' locational requirements. The Site adjacent to Junction 10 of the M11 provides a suitable alternative.

2.2.7 Policy E3 considers the suitability for freight and logistics. It states that development should have good access to transport networks and be sited and designed to limit environmental impacts. The Site is adjacent to the Strategic Road Network and can be designed to mitigate any impacts on existing settlements and is therefore located to support commercial, warehouse and logistic uses.

2.2.8 Mid tech (as one of the uses forming part of the tech park) comprises a mixture of Class 'B' uses with larger officer space. It supports Greater Cambridge's knowledge intensive sectors (principally life sciences and IT). Therefore, there is a growing need to provide these spaces during the emerging Local Plan Period.

2.2.9 The Report states that a new phase at Eddington meets the requirement for Mid Tech uses. The recent resolution to grant approval at Committee for Eddington Phase 2 has sought to provide flexibility employment floorspace for Class E(g) and sui generis (Greater Cambridge reference: 25/037456/OUT)⁴. This does not include a full complement of Mid Tech uses, which also comprise B2 and B8 uses.

2.2.10 Therefore, it is not considered that the proposed employment at Eddington meets the criteria set out in the 2025 Report and it is crucial that alternative provision is made to support these Mid Tech uses.

2.2.11 The Cambridge economy is recognised in the emerging Local Plan as being crucial both nationally and internationally (paragraph 2.68). The economic strategy to meet the emerging needs of Cambridge's differing sectors seeks to allocate emerging Mid Tech needs at Eddington and Cambridge East, with longer term provision at an expanded Cambourne (paragraph 2.69). it acknowledges that Mid Tech comprises Use Classes E(g)/B2/B8.

2.2.12 As stated above, the description of development for Eddington Phase 2 does not include B2/B8 uses so does not fall into the definition of Mid Tech. Therefore, there is a clear lack of employment floorspace to accommodate Mid Tech. Additional employment land should be allocated to help meet this shortfall.

2.2.13 In terms of Cambridge East, emerging Policy S/CE states that it will provide a new city district of approximately 8,000 homes delivered from 2032 and significant employment space, which includes 20,000sqm (GIA) of B2/B8 space for Mid Tech and general industrial uses.

2.2.14 As the emerging policy clearly states, housing is set to be delivered from 2032. Therefore, it is considered that the earliest both Mid Tech and general industrial floorspace could be delivered is also from 2032.

2.2.15 This is acknowledged in the 2025 Report (paragraph 7.22), which states:
"Cambridge East could play a role in meeting Mid Tech but is coming later in the Plan Period which would not meet shorter term demand"


2.2.16 The emerging Local Plan Policy also references Mid Tech to be delivered at an expanded Cambourne in the longer term (paragraph 2.69). However, this eventual allocation does not alleviate the need to provide Mid Tech uses in the early years of the Local Plan.

2.2.17 It is clear that there is an immediate shortfall in Mid Tech floorspace on the adoption of the Local Plan (anticipated in 2028) which is in conflict with Greater Cambridge which states that this is an "emerging need" (paragraph 2.69) and Greater Cambridge's own evidence base.

2.2.18 Greater Cambridge must allocate additional employment space that can be delivered early in the Plan Period to support its growth ambitions.

2.2.19 In summary, Eddington, Cambridge East and Cambourne are not considered to accommodate Mid Tech floorspace, which is required early in the Plan Period as there is a current demand. Additional land must be allocated, and the Site is ideally suited.

2.2.20 The Assessment states that there is a need for both general industrial space and Mid Tech, forming a new mixed industrial/tech park on the Strategic Road Network and has set this out as one of the recommendations in its Report (paragraph 7.25).

2.2.21 The Vision Document that was an appendix of the Regulation 18 representations, provided a masterplan which details how the employment could come forward, helping to meet Greater Cambridge's current shortfall.

2.2.22 The Vision Document also details other proposed uses for the scheme, which benefit existing residents. These include retail and leisure facilities as well as a strategic mobility hub located adjacent to Junction 10 of the M11. It shows an active travel corridor running through the Site and the strategic hub to Whittlesford and principally Whittlesford Parkway Train Station. Whittlesford Parkway provides regular services to London Liverpool Street, Cambridge (including Cambridge Biomedical Campus at Cambridge South) and Stansted Airport.

2.2.23 In conclusion, the Site is ideally located to meet the shortfall in commercial uses, particularly Mid Tech and industrial and logistics space due to its proximity to the Strategic Road Network (M11). The provision of a new mixed industrial/tech park on the Strategic Road Network is a recommendation in Greater Cambridge's own evidence base, and the Site is ideally suited to meet this recommendation

2.3 Emerging Policy S/GB - The Green Belt

2.3.1 Emerging Policy S/GB states that a Green Belt will be maintained around Cambridge to preserve the unique character of Cambridge, maintain and enhance the quality of its setting and prevent communities in the environs of Cambridge from merging into each other and Cambridge. It adds that new development will only be approved in accordance with policy set out in the NPPF.

2.3.2 The land is within the Green Belt. Given the size of the Site, a number of parcels have been assessed against the purposes of the Green Belt.

2.3.3 As stated in Chapter 1, two of the Parcels within the Site have been designated as Grey Belt, which our clients support. Tour clients are particularly pleased that Parcel HE2 (the proposed location for the Strategic Transport Hub) is designated as Grey Belt as it will support both the new employment site but also existing residents in nearby settlements.

2.3.4 However, our clients still have concerns about the accuracy of the updated Green Belt Assessment, with respect to the other Parcels.

2.3.5 Our clients maintain the conclusions set out in the Regulation 18 response in relation to Green Belt (shown at Appendix 2) are still valid. The proposed masterplan includes high- quality landscaping to reduce any threat of coalescence between the settlements which would affect the historic setting of the city.

2.3.6 Our clients would be willing to work with stakeholders throughout the process to consider additional mitigation measures where appropriate.

2.3.7 Despite our client's assertion that the Site can be considered Grey Belt, they nevertheless consider that there are "exceptional circumstances" to alter Green Belt boundaries, as per Paragraph 145 of the 2024 NPPF.

2.3.8 Greater Cambridge's own evidence base has confirmed that there is a need to provide an industrial/tech park adjacent to the Strategic Road Network to meet its commercial needs. The Site is ideally placed to provide this park as it is adjacent to Junction 10 of the M11. It can also seek to deliver the employment earlier in the Plan Period, which is noted by Greater Cambridge's own evidence, prior to Cambridge East coming forward.

2.3.9 Therefore, it should be considered favourably as an allocation in Greater Cambridge's emerging Local Plan.

3 Conclusion

3.1 Summary

3.1.1 In conclusion, our clients consider that the Plan would currently be found unsound at Examination as it is not considered justified or effective when assessed against the relevant tests in the 2024 iteration of the NPPF.

3.1.2 Regarding the delivery of commercial floorspace (particularly Mid Tech), the Plan relies of two edge-of-centre settlements, Eddington and Cambridge East with additional delivery in the expansion of Cambourne later in the Plan Period. Phase 2 of Eddington has just been given a resolution to grant at Committee. However, the description of development does not cite B2/B8 uses, which provide the flexibility for Mid Tech users.

3.1.3 In addition, the emerging Local Plan states that the initial houses will be delivered at Cambridge East in 2032. There is no immediate delivery in the emerging Local Plan to accommodate these uses, which is also the case for the proposed future allocations at Cambourne. The lack of sites that can be delivered earlier in the Plan Period has been acknowledged by Greater Cambridge's own evidence base but has not been carried forward into the actual Pre-Submission Local Plan.

3.1.4 Our client is pleased to note that the two of the Parcels has been designated as Grey Belt in Greater Cambridge's updated Green Belt Assessment, including the land proposed for the Sustainable Transport Hub.

3.1.5 However, our clients still have fundamental concerns that the conclusions regarding the other Parcels are not accurate as it has not considered the proposed mitigation measures set out in the Vision Document that accompanied the Regulation 18 representations (Appendix 2).

3.1.6 Given the overwhelming need for more employment to support Greater Cambridge's knowledge intensive sectors and the ideal location for the Site, adjacent to the Strategic Road Network, our clients request that the Pre-Submission Local Plan be modified to allocate the Site for a new industrial/tech park, supported by an appropriate site-specific policy and corresponding amendment to the Policies Map.

3.1.7 Our clients wish to participate in the relevant hearing sessions at the Examination in Public to explain and develop the matters raised in these representations.

Footnotes:
1 Appendix A - Contribution to CP1
2 Greater Cambridge Green Belt Assessment
3 EBGCLPIWSSMar25v1Mar25 0.pdf
4 25.03746.OUT and 25.03753.OUT Committee Report Final.pdf

[Please refer to the submission attachments for the appendices.]