Greater Cambridge Local Plan: Proposed Submission

The wording of policies of the draft Local Plan, including S/RSC/FSS, require further detailed consideration as to
the soundness and deliverability implications that they present. These policies should be amended to ensure they are sound and provide for deliverable development to be brought forward. They need to be amended to ensure they are clear for future developers and decision-makers and to avoid any restrictions, which are not absolutely necessary, are allowed to endure. Restrictions risk preventing the delivery of economic growth and employment potential over the Plan period where there is a significant shortfall at present.

On behalf of Huawei (hereinafter ‘our Client’ / ‘the Landowner’), we write to set out formal representations to the draft Greater Cambridge Local Plan (Regulation 19). These representations follow the submission of the landholdings in Sawston, Cambridgeshire (hereinafter ‘the Site’) in January 2026 and refer to the planning history of the Site. A Site Location Plan is provided at Appendix 1 for clarity.

Appendix 1

In summary, these representations support the principle of the preparation and production of the Greater Cambridge Local Plan. However, there are changes required to the draft Local Plan to ensure compliance with the NPPF in relation to soundness. Specifically, the evidence supports the allocation and ultimate redevelopment of the ‘Former Spicers Site’ for employment development but does not adequately justify the specific constraints imposed by Policy S/RSC/FSS.

As a consequence, these representations seek to release the constraints imposed in Policy S/RSC/FSS in relation to the:
• Range of employment uses;
• Developable extent of the allocation; and
• Division of the site by the green line associated with the Borough Hill Scheduled
Ancient Monument (‘SAM’).

The effect of these constraints is to impact the deliverability of the site for employment use, thereby impacting the economic potential of the Site. As a consequence, these constraints mean that the tests of positively prepared, justified, effective and consistent
with national policy are incapable of being evidenced.

These representations have been prepared having reviewed the draft Greater Cambridge Local Plan and its associated evidence base; the site context; the planning history of the site; and other submissions made to the Council in the course of promotion of the site for
employment development.

The specific matters that we comment upon within these representations are limited to those directly relevant to the draft allocation of the Site under Policy S/RSC/FSS. As such, these representations do not purport to respond to any wider issues arising with the framing, content or compliance of the wider policies or evidence base of the draft Local Plan. As a consequence, our Client reserves the right to comment on other policies in future stages of consultation on the draft Local Plan. These representations should not be considered as supportive of any policies or evidence base documents that are not
commented on.

The Site – Description and Planning Context
Description

The Site as a whole comprises over 200 hectares (over 500 acres) of land including Sawston Business Park, vacant agricultural buildings, agricultural land, and woodland. The Site is split in two parcels by the Cambridgeshire to London railway line.

Within the central part of the Site is Sawston Business Park which comprises a collection of commercial buildings providing approximately 46,500sq.m (500,000sq.ft) floorspace. Of this, approximately two thirds of the floorspace is occupied with the remaining floorspace providing an opportunity for development to deliver jobs and economic growth opportunities for the area.

The Site lies to the west of Sawston Village and to the north of Whittlesford Village. The highway network connects from the A1301 to Sawston (Cambridge Road), which also includes the main cycle route running from the village to Cambridge. The M11 is accessed in under 10 minutes by vehicles via A-roads. It is a strategically well-located Site with a broad potential catchment.

It is a long established and attractive location for employment growth, being located in close proximity to two train stations, 2.4 miles to Whittlesford Parkway to the south and 2.1 miles to Shelford Station to the north and Cambridge located approximately 6 miles to the north of the Site.

The majority of the Site is located within the Green Belt with Sawston Business Park inset
from the Green Belt.

Planning Context

The planning history of the site forms an important part of the context for these
representations. In summary, the substantive planning history that is relevant to the
consideration of the Site through the Local Plan process is identified below:

• S/0750/01/F I Warehouse with Ancillary Offices. Granted 24 Apr 2004
• S/0108/09/F | Phase 1 - Development of Sawston Business Park for Mixed B1(c) B2 & B8 Scheme & Associated Infrastructure & Landscaping Work. Granted 22 Apr 2009
• S/0069/09/O | Phase 2 - Redevelopment of Land at Sawston Business Park for a Mixed B1(c) B2 B8 Scheme and Associated Infrastructure. Granted 22 Apr 2009
• S/0680/15/FL | Change of use from B8 to B2 use class and associated alterations to the Vision Centre including additional fenestration internal floorspace extension
installation of plant and external works. Granted 03 Sep 2015
• S/0158/20/FL I Demolition of 582sq.m (GIA) storage building (B8 Use Class) and erection of 50,445sq.m (GIA) of research and development accommodation (B1(b)
Use Class), including ancillary accommodation and broken down as follows: (i) Office accommodation (9,503sq.m); (ii) Wafer fabrication (FAB) cleanroom (22,351sq.m); (iii) Single level basement incorporating 284 no. car parking spaces (9,417sq.m); (iv) Central Utilities Building (8,694sq.m); (v) External storage building (480sq.m); (vi) Cycle parking spaces (80 for staff and 6 for visitors, total 86); (vii) Surface, disabled and visitor car parking (16 spaces) adjacent to the office building entrance; (viii) Access and circulation roads, engineering works and footpaths / cycleways; (ix) Drainage and
servicing infrastructure; and (x) Hard and soft landscaping. Granted 14 Aug 2020

Significantly, the planning permission for the erection of 50,445sq.m employment floorspace development is considered material to the draft Local Plan. The planning
application, while it has lapsed, was accompanied by comprehensive, clear and compelling evidence. Specifically, the application included detailed and site-specific evidence on the effects of the proposals on the site and surrounding area. This included detailed assessment of the historic environment and ultimately concluded with the decision to grant planning permission.

Material Considerations in the Plan-Making Process

The planning permission (now lapsed, under /0158/20/FL) for the erection of 50,445sq.m employment floorspace was subject to full and rigorous assessment through the usual
process. This culminated in the review of the application by officers of South Cambridgeshire District Council and the preparation of an officer report (‘OR’) to the Planning Committee on 25 June 2020 (see Appendix 2). The application was approved by nine votes in favour to one, subject to the completion of the Section 106 agreement
and the variation of two conditions that had been proposed in the officer report. These conditions related to Natural England and re-use and recycling. They did not relate to
heritage matters, or specifically the Borough Hill SAM.

Appendix 2

The minute of the meeting of the Planning Committee on 25 June 2020 (see Appendix 3) records that the debate about the planning application was focused on matters listed below, which expressly excluded any debate about heritage or the Borough Hill SAM:

• Water supply issues, including potential impact on the water table
• Landscaping and design
• Concern about the apparent lack of cycling connectivity with nearby villages, although officers explained that current proposals were proportionate to the application being considered, and that further opportunities would arise in future as the site was developed
• Biodiversity issues that had been addressed by statutory consultees
• Clarification that the proposal site was not in the Green Belt
• Prematurity
• The need for a Masterplan
• Issues surrounding ‘high end’ employment, housing, and sustainable transport

Appendix 3

The OR correctly recorded that Historic England did not object to the proposed development and summarised the representation as follows [OR55]:

“Broadly support the changes to the revised landscape along the access road which is adjacent to the monument stating that it will help soften the transition between the
monument and the hard edge of the proposed buildings. Also broadly supports the approach to the proposed Conservation Management and Community Outreach
Plan, setting out that the document has been developed further following previous HE advice and that, implemented in full, the Plan will result in the enhanced
management of the monument, long-term conservation of its significance and greater accessibility for public access and interpretation. Recommends the key proposals of the Conservation Management and Community Outreach Plan be secured by S106 agreement and welcomes the applicant's commitment with this approach. Raises concerns over the landscape and biodiversity proposals for the site, whilst acknowledging that the management improvements to the SAM will result in the creation of a new habitat, which is supported. Nevertheless, HE recommends that the Technical Note on BNG is revised to note any works to the SAM area will require further statutory consents and to cross-reference the Conservation Management and Community Outreach Plan. Further, HE requires drawings are revised to reflect the need for further consents necessary to any works being done in the SAM area, and for the proposals for woodland in the area to be clarified/reconsidered. Reiterates the need for a condition to be imposed to any permission granted, ensuring an archaeological programme is undertaken in the area.”

It went on to confirm that the Historic Environment Team (Cambridgeshire County Council) also recorded no objection to the proposals, with the summary of the feedback being
[OR56]:

“Welcomes the applicant's consideration of the heritage and its setting within this landholding. Welcomes the submission of a draft Archaeological Conservation
Management and Community Outreach Plan (ACMCOP) and supports the policies (1-12) for the scheduled monument shown in the current ACMCOP, noting it
encapsulates previous discussions including with CCC Historic Environment team. Recommends that the ACMCOP is modified to indicate that it is an Estate-wide
management, with a special section that addresses the specific restoration and management of Borough Hill Marsh Fort. The LEMP should cross refers to this estate
management plan to ensure that all assets are suitably protected when threatened by groundworks. Recommends that the long-term management and conservation plans to protect and enhance heritage assets are secured through S106 agreement and an archaeological condition be imposed, with respective informative. The S106 should indicate that it applies to an archaeological management strategy for the whole of the Huawei estate and not be restricted to the scheduled monument at its heart. Therefore, the title of the ACMCOP document should be altered to reflect this.”

The OR also correctly recorded the following matters of significance:

• The site lies within an Established Employment Area (EEA), as designated by Policy E/15 of the South Cambridgeshire Local Plan (2018), where appropriate development for employment will be permitted. The EEAs are identified outside the Green Belt; however Policy E/15 (3) requires permission be refused where there would be a
negative impact on the surrounding countryside or landscape character [OR70]
• The proposal for the erection of 50,445sq.m of B1(b) of commercial research and development floorspace in this EEA location fulfils expectations of Policy E/15 given
the nature of the proposed use to the buildings, which will employ between 350 and 400 people during operation, as set out in the submission documents [OR71]
• Whilst acknowledged the proposed development would have a visual impact particularly in the immediate surroundings, the buildings are considered to sit well in
the landscape context, and their design to be reflective of the surrounding countryside and their employment use. In fact, the proposals are considered to deliver an improved
quality of design to the built environment of this EEA, with a much-reduced negligible impact on the surrounding landscape from distant views [OR72]
• The area between the courtyard and the SAM has been revised to reflect landscape comments and response from Historic England and the County Archaeologist. This
area now provides a softer transition in landscape terms between the scheduled monument and the site, with wildflower mix proposed along the 3m wide planted edge
between the access road and the cycle/footway to reinforce the transition. Fagus sylvatica will be planted to the south of the cycle/footway, where it is not constrained
by the planter width, combined with groups of Acer campestre, in the proposed green area at the entrance of the courtyard. This is accepted by the Council's Landscape advisor and supported by Historic England. No specific comments were made by the County Council Archaeologist following revision of this part of the on-site landscaped area [OR92]
• The Planning Statement submitted with the application sets out that Huawei intends to redevelop the former Spicers site as a whole over a number of phases and that the quantum and form of any future development of the wider site is yet to be determined in detail. However, further consideration has been given to how the development of the wider site may come forward in the future to ensure that the current proposals would
integrate well with further development of the wider estate [OR97]
• Accordingly, an illustrative masterplan and a series of parameter plans have been provided within Section 2 of the submitted DAS to indicate how the wider redevelopment of the site could be organised in the future. Whilst the plans submitted are not for approval and therefore will not be considered with this application, the
information submitted with the DAS provide a current understanding of the future redevelopment potential. As such, officers are satisfied that it demonstrates the
proposal has taken a comprehensive and inclusive approach in relation to the development potential of the wider estate [OR98]

The OR considered the matters relating to the Historic Environment in paragraphs OR109-118, with the review of the designated assets in OR109-115 and the review of non-designated assets in OR116-117, ultimately concluding at OR118. Within this assessment, it was established that:

• Overall officers are of the view that the proposed ACoMPCOP will contribute to remove factors causing risk to the SAM and represents potential for permanent improvements to the asset's management and conservation, with correspondent increase in access
and knowledge by the public in general. In further correspondence dated 5 May 2020, Historic England has stated that the draft ACoMPCOP including all the proposed actions and if secured by a S106 agreement can provide the elements of a public benefit needed to outweigh the harm as set out by paragraph 196 of the NPPF. This is agreed and planning obligations to be set out in a S106 agreement are recommended
accordingly [OR115]
• Overall, the proposals raised no objection from Historic England and the County Council's Archaeologist and are considered that management of the SAM through the
establishment of the ACoMPCOP with programme for further archaeological investigations on and around the site and SAM setting will contribute to the assets'
conservation in a manner appropriate to their significance. Further, the community outreach element of the ACoMPCOP will enable the enjoyment of the SAM by the
public, for their contribution to the quality of life of existing and future generations. It is considered that the direct benefits from the proposals to the designated and non
designated assets on and around the site outweigh any harm caused to these assets and, in balance, the proposal is acceptable in terms of the NPPF and Policy NH/14 of
the Local Plan [OR118]

The OR considered the planning balance at OR196-202 and confirmed that the harms identified with the proposed development had been fully and properly evaluated and it is established that they were outweighed by the planning benefits that the scheme would bring. [OR197 – note the errata sheet issued prior to the Planning Committee corrected the error in the weighting of the heritage harm in the original drafting]

These planning benefits were identified in the subsequent paragraphs, with the principal benefit identified in OR198 which confirmed that “Substantial economic benefits locally will result from the proposed development, through the employment of between 350 and 400 people directly during operation only”. This did not need to consider secondary or tertiary employment matters, but it is clear that the Council considered the employment of this quantum would provide ‘substantial benefits’.

In summary, the 2020 planning permission demonstrates that a substantial employment development, extending beyond the area now shown as developable in Figure 80, was capable of being found acceptable following detailed assessment. Neither Historic England nor the County Council Archaeologist sought the imposition of an absolute
development boundary equivalent to the proposed green line. Instead, the effects upon the Scheduled Monument and its setting were addressed through scheme-specific design, landscaping, archaeological investigation, long-term management and planning obligations. This provides material evidence that a flexible, criteria-based policy approach is available and that the permanent spatial restriction shown in Figure 80 has not been adequately justified. Nor would it allow the allocation to deliver its full employment potential and range of economic benefits, which were established as public benefits of the 2020
planning permission.

Engagement in the Plan-Making Process

The Site has been submitted to the Council through the call-for-sites process (via submissions dated 30 January 2026), which identified the potential of the land owned by
our client as a whole. As the Site forms only part of the wider landholding, we consider that the draft allocation misses an opportunity to build on the principles established in the planning application and the opportunity to deliver on the wider growth and economic ambitions of the draft Local Plan.

In the context of the approach to date to the allocation of the site in both the previous draft Local Plan (December 2025) and Regulation 18 draft Local Plan, our Client had a
legitimate expectation that the Council would not seek to impose the restrictions it has done in the current draft Local Plan. It was noted that the December 2025 draft contained a material inconsistency between the two stated capacity figures (approximately 40,000sq.m in the draft allocation and around 50,000sq.m in the supporting text).
However, nothing foreshadowed the current approach.

The draft allocation in the Regulation 18 draft Local Plan is reported in the Consultation Statement to have attracted eight representations, comprising one objection and seven
comments. The detail of these representations does not appear to be available to view, but our Client does not consider that the matters raised in these representations contained sufficient evidence to support the restrictions proposed within the draft allocation.

Adopted Development Plan

The adopted South Cambridgeshire Local Plan sets out the strategy and policies to guide development in the area until 2031. Policy S/1 (Vision) sets out the broad vision for South Cambridge to “be the best place to live, work and study in the country.” In seeking to achieve this, it is critical that the draft Local Plan reflects on this aspiration, reviews how the adopted plan performed in seeking to deliver on the vision and how it can be maintained.

The Site is identified in the adopted Development Plan as an Established Employment Site, allocated under Policy E/15 (2k) which permits redevelopment and appropriate
employment development. It precluded development that would result in “a negative impact on the surrounding countryside, or landscape character”.

It is significant that the area of allocation under Policy E/15 (2k) includes an area identified as falling within the Borough Hill SAM.

The Site is clearly capable of accommodating significant areas of new employment development to deliver jobs and economic growth.

Requirements of the NPPF 2024

The NPPF requires Local Plans to be:

• Succinct and up to date [15]
• Prepared positively in a way that is aspirational but deliverable [16]
• Shaped by effective engagement between plan-makers and businesses [16]
• Clearly written and unambiguous [16]
• Serve a clear purpose [16]
• Underpinned by relevant and up-to-date evidence [32]
• Focused tightly on supporting and justifying the policies and take into account relevant market signals [32]
• Sound [36]

For the reasons identified in these representations, the draft Local Plan as drafted fails to adequately address and embrace the requirements of the NPPF in this regard.

In addition to the above, Section 6 of the NPPF sets out the aspirations of the planning system in relation to the delivery of a strong competitive economy. The content of this section of the NPPF focuses on the significance of helping to create conditions in which businesses can invest, expand and adapt, requiring significant weight to be placed on the need to support economic growth.

Paragraph 86 requires planning policies to, inter alia, pay particular regard to facilitating development to meet the needs of a modern economy, seek to address potential barriers to investment and be flexible enough to accommodate needs not anticipated in the Plan.

The draft Regulation 19 Local Plan

The draft Regulation 19 Local Plan confirms, inter alia, that development proposals will be decided against all relevant policies of the Plan [1.36]; the Plan will support a flourishing, dynamic and mixed economy in Greater Cambridge which includes a wide range of jobs [2.4]; will seek to deliver the 73,300 additional jobs identified as the objectively assessed need [Policy S/JH]; and will support economic growth and productivity [2.8].

In seeking to achieve this it is clearly critical that the policies of the Plan do not artificially constrain or reduce the capacity of sustainable development sites to deliver on these goals and objectives.

Paragraphs 2.10 to 2.12 identify the nature and scale of the job growth and the evidence base upon which the objectively assessed needs is based. It is important to note that within this, the evidence base identified a higher growth forecast than that being pursued in the Plan, which demonstrates that there is capacity to go significantly beyond what is proposed in the draft Local Plan.

Paragraphs 2.68 to 2.71 inclusive set out the high-level ‘Employment strategy’ for the draft Local Plan. It is notable that this strategy seeks to direct life sciences and ICT to specific locations, mid-tech space (Use Classes E(g)/B2/B8) allocations on the edge of the urban area and logistics floorspace (Use Classes B2/B8) to two substantial new allocations and several mixed-use allocations.

The Site is not identified in this high-level strategy, but it is noted that the restricted range of employment uses proposed within the draft allocation does not accord with the strategy in principle due to the location of the site. To accord with the strategy in principle, the draft allocation should not seek to constrain the form of development that can be accommodated within it.

The rural southern cluster is identified at Section 3.4 of the draft Local Plan. This confirms that the ambition is to support and grow this successful and nationally important business cluster by providing more business space where needed. [3.4.2].

The draft allocation of the Site is set out in Policy S/RSC/FSS Former Spicers Site, Sawston Business Park, Sawston. It identifies capacity for “approximately 40,000 square metres gross internal area of employment floorspace including research and development E(g)(ii) floorspace with the potential for additional floorspace in future phases subject to future exploration of capacity including evidence of suitable site access.” It then proposes a series of criteria against which development proposals will be assessed.

Our Client supports the allocation of the site for employment use in the Local Plan. However, it does not support the drafting of the policy, on the basis that it is both unduly restrictive and unnecessarily complex. In the context of the existing levels of built development at the Site (approx. 46,500sq.m), its recent planning history, the evidence to support the previous planning approvals and the historic allocation, it is not considered that the form of the draft allocation meets the requirements of the NPPF, specifically the needs to ensure the Plan is ‘prepared positively, in a way that is aspirational but deliverable’, sufficiently clear and unambiguous and serving a clear purpose in line with Paragraphs 16, 32 and 36.

With specific reference to the planning history of the site, this confirms that the Council accepted as recently as 2020 that the site can support the development of 50,445sq.m (GIA) across a range of different uses. The draft Local Plan does not provide any clear or coherent evidence base to demonstrate why the proposed restrictions in the draft allocation. What is required at the Site, which is consistent with the extant allocation and
planning history, is a careful, evidence-led management of development near the Borough Hill SAM, including an application-specific assessment of the necessary stand-off and controls over physical works. It does not require the application of restrictions as set out in the draft allocation.

To clarify, the evidence base for the draft Local Plan does not support, and does not even purport to support:
• Any form of confinement of the acceptable uses to a narrowly defined R&D or life sciences use;
• The exclusion of other parts of the ‘Former Spicers Estate’;
• The Borough Hill SAM or its setting requires the site to be divided by an arbitrary green line that risks becoming a ‘fixed feature’ if the allocation is carried forward in its current form;
• That the land on one side of that line is developable while all land on the other side must remain undeveloped, as there is no defined ‘line’ that determines the setting
of the Borough Hill SAM or its setting, or that sensitive treatment of development within the setting should be precluded.

Furthermore, the use of the arbitrary green line within the draft allocation has not been supported by heritage evidence relating to significance, effect, harm, mitigation and enhancement, or the weighting of harm against public benefits. It is not appropriate or deliverable to introduce a mapped line in the draft allocation that could be treated as an absolute constraint to development.

As an alternative, the draft allocation should be amended to remove the green line and to identify a wider form of development that can be accommodated. We recommend that this is framed in similar wording to the below, which would be supported in principle by our Client and justified by the context and evidence base:
“Employment-led development, including research and development, laboratories, offices, advanced manufacturing, innovation and other compatible employment generating uses, together with ancillary and complementary uses necessary to create a sustainable employment campus.”

In place of the arbitrary green line, our Client would be willing to accept the insertion of additional policy wording to the effect that:
“Development must conserve the significance of Borough Hill Scheduled Monument, including those elements of its setting which contribute to its significance. Proposals
should be informed by an up-to-date archaeological and heritage assessment and should demonstrate an appropriate built form and layout, access and movement,
open space and landscaping. Physical works within or close to the scheduled boundary will require early engagement with the Council and Historic England.”

It would also be appropriate and in line with the wider strategy and policies of the draft Local Plan and the requirements of the NPPF to delete Figure 80.

Conclusion
Our Client supports the principle of the preparation of the draft Local Plan, and broadly agrees with the vision and objectives of delivering development to support the needs of the area, including the provision of high-quality economic and employment growth. In particular, the Client supports the principle of the allocation of the ‘Former Spicers Site’ under Policy S/RSC/FSS for employment.

However, the wording of policies of the draft Local Plan, including S/RSC/FSS, require further detailed consideration as to the soundness and deliverability implications that they present. These policies should be amended to ensure they are sound and provide for
deliverable development to be brought forward. They need to be amended to ensure they are clear for future developers and decision-makers and to avoid any restrictions, which are not absolutely necessary, are allowed to endure. Restrictions risk preventing the
delivery of economic growth and employment potential over the Plan period where there is a significant shortfall at present.

Therefore, we consider that the draft Local Plan in its current form, would not pass the tests of soundness in the NPPF. Once amended, the draft Local Plan is capable of being found to be sound.

While we comment on a number of specific policies within these representations, our Client reserves the right to comment on other policies contained within the draft Local Plan at future consultation stages. These representations should not be read as being supportive of any policies that have not been commented on.

We also confirm that our Client wishes to appear at the Local Plan Examination in Public in due course, to further address the matters raised within these representations.

The wording of policies of the draft Local Plan, including S/RSC/FSS, require further detailed consideration as to
the soundness and deliverability implications that they present. These policies should be amended to ensure they are sound and provide for deliverable development to be brought forward. They need to be amended to ensure they are clear for future developers and decision-makers and to avoid any restrictions, which are not absolutely necessary, are allowed to endure. Restrictions risk preventing the delivery of economic growth and employment potential over the Plan period where there is a significant shortfall at present.

On behalf of Huawei (hereinafter ‘our Client’ / ‘the Landowner’), we write to set out formal representations to the draft Greater Cambridge Local Plan (Regulation 19). These representations follow the submission of the landholdings in Sawston, Cambridgeshire (hereinafter ‘the Site’) in January 2026 and refer to the planning history of the Site. A Site Location Plan is provided at Appendix 1 for clarity.

Appendix 1

In summary, these representations support the principle of the preparation and production of the Greater Cambridge Local Plan. However, there are changes required to the draft Local Plan to ensure compliance with the NPPF in relation to soundness. Specifically, the evidence supports the allocation and ultimate redevelopment of the ‘Former Spicers Site’ for employment development but does not adequately justify the specific constraints imposed by Policy S/RSC/FSS.

As a consequence, these representations seek to release the constraints imposed in Policy S/RSC/FSS in relation to the:
• Range of employment uses;
• Developable extent of the allocation; and
• Division of the site by the green line associated with the Borough Hill Scheduled
Ancient Monument (‘SAM’).

The effect of these constraints is to impact the deliverability of the site for employment use, thereby impacting the economic potential of the Site. As a consequence, these constraints mean that the tests of positively prepared, justified, effective and consistent
with national policy are incapable of being evidenced.

These representations have been prepared having reviewed the draft Greater Cambridge Local Plan and its associated evidence base; the site context; the planning history of the site; and other submissions made to the Council in the course of promotion of the site for
employment development.

The specific matters that we comment upon within these representations are limited to those directly relevant to the draft allocation of the Site under Policy S/RSC/FSS. As such, these representations do not purport to respond to any wider issues arising with the framing, content or compliance of the wider policies or evidence base of the draft Local Plan. As a consequence, our Client reserves the right to comment on other policies in future stages of consultation on the draft Local Plan. These representations should not be considered as supportive of any policies or evidence base documents that are not
commented on.

The Site – Description and Planning Context
Description

The Site as a whole comprises over 200 hectares (over 500 acres) of land including Sawston Business Park, vacant agricultural buildings, agricultural land, and woodland. The Site is split in two parcels by the Cambridgeshire to London railway line.

Within the central part of the Site is Sawston Business Park which comprises a collection of commercial buildings providing approximately 46,500sq.m (500,000sq.ft) floorspace. Of this, approximately two thirds of the floorspace is occupied with the remaining floorspace providing an opportunity for development to deliver jobs and economic growth opportunities for the area.

The Site lies to the west of Sawston Village and to the north of Whittlesford Village. The highway network connects from the A1301 to Sawston (Cambridge Road), which also includes the main cycle route running from the village to Cambridge. The M11 is accessed in under 10 minutes by vehicles via A-roads. It is a strategically well-located Site with a broad potential catchment.

It is a long established and attractive location for employment growth, being located in close proximity to two train stations, 2.4 miles to Whittlesford Parkway to the south and 2.1 miles to Shelford Station to the north and Cambridge located approximately 6 miles to the north of the Site.

The majority of the Site is located within the Green Belt with Sawston Business Park inset
from the Green Belt.

Planning Context

The planning history of the site forms an important part of the context for these
representations. In summary, the substantive planning history that is relevant to the
consideration of the Site through the Local Plan process is identified below:

• S/0750/01/F I Warehouse with Ancillary Offices. Granted 24 Apr 2004
• S/0108/09/F | Phase 1 - Development of Sawston Business Park for Mixed B1(c) B2 & B8 Scheme & Associated Infrastructure & Landscaping Work. Granted 22 Apr 2009
• S/0069/09/O | Phase 2 - Redevelopment of Land at Sawston Business Park for a Mixed B1(c) B2 B8 Scheme and Associated Infrastructure. Granted 22 Apr 2009
• S/0680/15/FL | Change of use from B8 to B2 use class and associated alterations to the Vision Centre including additional fenestration internal floorspace extension
installation of plant and external works. Granted 03 Sep 2015
• S/0158/20/FL I Demolition of 582sq.m (GIA) storage building (B8 Use Class) and erection of 50,445sq.m (GIA) of research and development accommodation (B1(b)
Use Class), including ancillary accommodation and broken down as follows: (i) Office accommodation (9,503sq.m); (ii) Wafer fabrication (FAB) cleanroom (22,351sq.m); (iii) Single level basement incorporating 284 no. car parking spaces (9,417sq.m); (iv) Central Utilities Building (8,694sq.m); (v) External storage building (480sq.m); (vi) Cycle parking spaces (80 for staff and 6 for visitors, total 86); (vii) Surface, disabled and visitor car parking (16 spaces) adjacent to the office building entrance; (viii) Access and circulation roads, engineering works and footpaths / cycleways; (ix) Drainage and
servicing infrastructure; and (x) Hard and soft landscaping. Granted 14 Aug 2020

Significantly, the planning permission for the erection of 50,445sq.m employment floorspace development is considered material to the draft Local Plan. The planning
application, while it has lapsed, was accompanied by comprehensive, clear and compelling evidence. Specifically, the application included detailed and site-specific evidence on the effects of the proposals on the site and surrounding area. This included detailed assessment of the historic environment and ultimately concluded with the decision to grant planning permission.

Material Considerations in the Plan-Making Process

The planning permission (now lapsed, under /0158/20/FL) for the erection of 50,445sq.m employment floorspace was subject to full and rigorous assessment through the usual
process. This culminated in the review of the application by officers of South Cambridgeshire District Council and the preparation of an officer report (‘OR’) to the Planning Committee on 25 June 2020 (see Appendix 2). The application was approved by nine votes in favour to one, subject to the completion of the Section 106 agreement
and the variation of two conditions that had been proposed in the officer report. These conditions related to Natural England and re-use and recycling. They did not relate to
heritage matters, or specifically the Borough Hill SAM.

Appendix 2

The minute of the meeting of the Planning Committee on 25 June 2020 (see Appendix 3) records that the debate about the planning application was focused on matters listed below, which expressly excluded any debate about heritage or the Borough Hill SAM:

• Water supply issues, including potential impact on the water table
• Landscaping and design
• Concern about the apparent lack of cycling connectivity with nearby villages, although officers explained that current proposals were proportionate to the application being considered, and that further opportunities would arise in future as the site was developed
• Biodiversity issues that had been addressed by statutory consultees
• Clarification that the proposal site was not in the Green Belt
• Prematurity
• The need for a Masterplan
• Issues surrounding ‘high end’ employment, housing, and sustainable transport

Appendix 3

The OR correctly recorded that Historic England did not object to the proposed development and summarised the representation as follows [OR55]:

“Broadly support the changes to the revised landscape along the access road which is adjacent to the monument stating that it will help soften the transition between the
monument and the hard edge of the proposed buildings. Also broadly supports the approach to the proposed Conservation Management and Community Outreach
Plan, setting out that the document has been developed further following previous HE advice and that, implemented in full, the Plan will result in the enhanced
management of the monument, long-term conservation of its significance and greater accessibility for public access and interpretation. Recommends the key proposals of the Conservation Management and Community Outreach Plan be secured by S106 agreement and welcomes the applicant's commitment with this approach. Raises concerns over the landscape and biodiversity proposals for the site, whilst acknowledging that the management improvements to the SAM will result in the creation of a new habitat, which is supported. Nevertheless, HE recommends that the Technical Note on BNG is revised to note any works to the SAM area will require further statutory consents and to cross-reference the Conservation Management and Community Outreach Plan. Further, HE requires drawings are revised to reflect the need for further consents necessary to any works being done in the SAM area, and for the proposals for woodland in the area to be clarified/reconsidered. Reiterates the need for a condition to be imposed to any permission granted, ensuring an archaeological programme is undertaken in the area.”

It went on to confirm that the Historic Environment Team (Cambridgeshire County Council) also recorded no objection to the proposals, with the summary of the feedback being
[OR56]:

“Welcomes the applicant's consideration of the heritage and its setting within this landholding. Welcomes the submission of a draft Archaeological Conservation
Management and Community Outreach Plan (ACMCOP) and supports the policies (1-12) for the scheduled monument shown in the current ACMCOP, noting it
encapsulates previous discussions including with CCC Historic Environment team. Recommends that the ACMCOP is modified to indicate that it is an Estate-wide
management, with a special section that addresses the specific restoration and management of Borough Hill Marsh Fort. The LEMP should cross refers to this estate
management plan to ensure that all assets are suitably protected when threatened by groundworks. Recommends that the long-term management and conservation plans to protect and enhance heritage assets are secured through S106 agreement and an archaeological condition be imposed, with respective informative. The S106 should indicate that it applies to an archaeological management strategy for the whole of the Huawei estate and not be restricted to the scheduled monument at its heart. Therefore, the title of the ACMCOP document should be altered to reflect this.”

The OR also correctly recorded the following matters of significance:

• The site lies within an Established Employment Area (EEA), as designated by Policy E/15 of the South Cambridgeshire Local Plan (2018), where appropriate development for employment will be permitted. The EEAs are identified outside the Green Belt; however Policy E/15 (3) requires permission be refused where there would be a
negative impact on the surrounding countryside or landscape character [OR70]
• The proposal for the erection of 50,445sq.m of B1(b) of commercial research and development floorspace in this EEA location fulfils expectations of Policy E/15 given
the nature of the proposed use to the buildings, which will employ between 350 and 400 people during operation, as set out in the submission documents [OR71]
• Whilst acknowledged the proposed development would have a visual impact particularly in the immediate surroundings, the buildings are considered to sit well in
the landscape context, and their design to be reflective of the surrounding countryside and their employment use. In fact, the proposals are considered to deliver an improved
quality of design to the built environment of this EEA, with a much-reduced negligible impact on the surrounding landscape from distant views [OR72]
• The area between the courtyard and the SAM has been revised to reflect landscape comments and response from Historic England and the County Archaeologist. This
area now provides a softer transition in landscape terms between the scheduled monument and the site, with wildflower mix proposed along the 3m wide planted edge
between the access road and the cycle/footway to reinforce the transition. Fagus sylvatica will be planted to the south of the cycle/footway, where it is not constrained
by the planter width, combined with groups of Acer campestre, in the proposed green area at the entrance of the courtyard. This is accepted by the Council's Landscape advisor and supported by Historic England. No specific comments were made by the County Council Archaeologist following revision of this part of the on-site landscaped area [OR92]
• The Planning Statement submitted with the application sets out that Huawei intends to redevelop the former Spicers site as a whole over a number of phases and that the quantum and form of any future development of the wider site is yet to be determined in detail. However, further consideration has been given to how the development of the wider site may come forward in the future to ensure that the current proposals would
integrate well with further development of the wider estate [OR97]
• Accordingly, an illustrative masterplan and a series of parameter plans have been provided within Section 2 of the submitted DAS to indicate how the wider redevelopment of the site could be organised in the future. Whilst the plans submitted are not for approval and therefore will not be considered with this application, the
information submitted with the DAS provide a current understanding of the future redevelopment potential. As such, officers are satisfied that it demonstrates the
proposal has taken a comprehensive and inclusive approach in relation to the development potential of the wider estate [OR98]

The OR considered the matters relating to the Historic Environment in paragraphs OR109-118, with the review of the designated assets in OR109-115 and the review of non-designated assets in OR116-117, ultimately concluding at OR118. Within this assessment, it was established that:

• Overall officers are of the view that the proposed ACoMPCOP will contribute to remove factors causing risk to the SAM and represents potential for permanent improvements to the asset's management and conservation, with correspondent increase in access
and knowledge by the public in general. In further correspondence dated 5 May 2020, Historic England has stated that the draft ACoMPCOP including all the proposed actions and if secured by a S106 agreement can provide the elements of a public benefit needed to outweigh the harm as set out by paragraph 196 of the NPPF. This is agreed and planning obligations to be set out in a S106 agreement are recommended
accordingly [OR115]
• Overall, the proposals raised no objection from Historic England and the County Council's Archaeologist and are considered that management of the SAM through the
establishment of the ACoMPCOP with programme for further archaeological investigations on and around the site and SAM setting will contribute to the assets'
conservation in a manner appropriate to their significance. Further, the community outreach element of the ACoMPCOP will enable the enjoyment of the SAM by the
public, for their contribution to the quality of life of existing and future generations. It is considered that the direct benefits from the proposals to the designated and non
designated assets on and around the site outweigh any harm caused to these assets and, in balance, the proposal is acceptable in terms of the NPPF and Policy NH/14 of
the Local Plan [OR118]

The OR considered the planning balance at OR196-202 and confirmed that the harms identified with the proposed development had been fully and properly evaluated and it is established that they were outweighed by the planning benefits that the scheme would bring. [OR197 – note the errata sheet issued prior to the Planning Committee corrected the error in the weighting of the heritage harm in the original drafting]

These planning benefits were identified in the subsequent paragraphs, with the principal benefit identified in OR198 which confirmed that “Substantial economic benefits locally will result from the proposed development, through the employment of between 350 and 400 people directly during operation only”. This did not need to consider secondary or tertiary employment matters, but it is clear that the Council considered the employment of this quantum would provide ‘substantial benefits’.

In summary, the 2020 planning permission demonstrates that a substantial employment development, extending beyond the area now shown as developable in Figure 80, was capable of being found acceptable following detailed assessment. Neither Historic England nor the County Council Archaeologist sought the imposition of an absolute
development boundary equivalent to the proposed green line. Instead, the effects upon the Scheduled Monument and its setting were addressed through scheme-specific design, landscaping, archaeological investigation, long-term management and planning obligations. This provides material evidence that a flexible, criteria-based policy approach is available and that the permanent spatial restriction shown in Figure 80 has not been adequately justified. Nor would it allow the allocation to deliver its full employment potential and range of economic benefits, which were established as public benefits of the 2020
planning permission.

Engagement in the Plan-Making Process

The Site has been submitted to the Council through the call-for-sites process (via submissions dated 30 January 2026), which identified the potential of the land owned by
our client as a whole. As the Site forms only part of the wider landholding, we consider that the draft allocation misses an opportunity to build on the principles established in the planning application and the opportunity to deliver on the wider growth and economic ambitions of the draft Local Plan.

In the context of the approach to date to the allocation of the site in both the previous draft Local Plan (December 2025) and Regulation 18 draft Local Plan, our Client had a
legitimate expectation that the Council would not seek to impose the restrictions it has done in the current draft Local Plan. It was noted that the December 2025 draft contained a material inconsistency between the two stated capacity figures (approximately 40,000sq.m in the draft allocation and around 50,000sq.m in the supporting text).
However, nothing foreshadowed the current approach.

The draft allocation in the Regulation 18 draft Local Plan is reported in the Consultation Statement to have attracted eight representations, comprising one objection and seven
comments. The detail of these representations does not appear to be available to view, but our Client does not consider that the matters raised in these representations contained sufficient evidence to support the restrictions proposed within the draft allocation.

Adopted Development Plan

The adopted South Cambridgeshire Local Plan sets out the strategy and policies to guide development in the area until 2031. Policy S/1 (Vision) sets out the broad vision for South Cambridge to “be the best place to live, work and study in the country.” In seeking to achieve this, it is critical that the draft Local Plan reflects on this aspiration, reviews how the adopted plan performed in seeking to deliver on the vision and how it can be maintained.

The Site is identified in the adopted Development Plan as an Established Employment Site, allocated under Policy E/15 (2k) which permits redevelopment and appropriate
employment development. It precluded development that would result in “a negative impact on the surrounding countryside, or landscape character”.

It is significant that the area of allocation under Policy E/15 (2k) includes an area identified as falling within the Borough Hill SAM.

The Site is clearly capable of accommodating significant areas of new employment development to deliver jobs and economic growth.

Requirements of the NPPF 2024

The NPPF requires Local Plans to be:

• Succinct and up to date [15]
• Prepared positively in a way that is aspirational but deliverable [16]
• Shaped by effective engagement between plan-makers and businesses [16]
• Clearly written and unambiguous [16]
• Serve a clear purpose [16]
• Underpinned by relevant and up-to-date evidence [32]
• Focused tightly on supporting and justifying the policies and take into account relevant market signals [32]
• Sound [36]

For the reasons identified in these representations, the draft Local Plan as drafted fails to adequately address and embrace the requirements of the NPPF in this regard.

In addition to the above, Section 6 of the NPPF sets out the aspirations of the planning system in relation to the delivery of a strong competitive economy. The content of this section of the NPPF focuses on the significance of helping to create conditions in which businesses can invest, expand and adapt, requiring significant weight to be placed on the need to support economic growth.

Paragraph 86 requires planning policies to, inter alia, pay particular regard to facilitating development to meet the needs of a modern economy, seek to address potential barriers to investment and be flexible enough to accommodate needs not anticipated in the Plan.

The draft Regulation 19 Local Plan

The draft Regulation 19 Local Plan confirms, inter alia, that development proposals will be decided against all relevant policies of the Plan [1.36]; the Plan will support a flourishing, dynamic and mixed economy in Greater Cambridge which includes a wide range of jobs [2.4]; will seek to deliver the 73,300 additional jobs identified as the objectively assessed need [Policy S/JH]; and will support economic growth and productivity [2.8].

In seeking to achieve this it is clearly critical that the policies of the Plan do not artificially constrain or reduce the capacity of sustainable development sites to deliver on these goals and objectives.

Paragraphs 2.10 to 2.12 identify the nature and scale of the job growth and the evidence base upon which the objectively assessed needs is based. It is important to note that within this, the evidence base identified a higher growth forecast than that being pursued in the Plan, which demonstrates that there is capacity to go significantly beyond what is proposed in the draft Local Plan.

Paragraphs 2.68 to 2.71 inclusive set out the high-level ‘Employment strategy’ for the draft Local Plan. It is notable that this strategy seeks to direct life sciences and ICT to specific locations, mid-tech space (Use Classes E(g)/B2/B8) allocations on the edge of the urban area and logistics floorspace (Use Classes B2/B8) to two substantial new allocations and several mixed-use allocations.

The Site is not identified in this high-level strategy, but it is noted that the restricted range of employment uses proposed within the draft allocation does not accord with the strategy in principle due to the location of the site. To accord with the strategy in principle, the draft allocation should not seek to constrain the form of development that can be accommodated within it.

The rural southern cluster is identified at Section 3.4 of the draft Local Plan. This confirms that the ambition is to support and grow this successful and nationally important business cluster by providing more business space where needed. [3.4.2].

The draft allocation of the Site is set out in Policy S/RSC/FSS Former Spicers Site, Sawston Business Park, Sawston. It identifies capacity for “approximately 40,000 square metres gross internal area of employment floorspace including research and development E(g)(ii) floorspace with the potential for additional floorspace in future phases subject to future exploration of capacity including evidence of suitable site access.” It then proposes a series of criteria against which development proposals will be assessed.

Our Client supports the allocation of the site for employment use in the Local Plan. However, it does not support the drafting of the policy, on the basis that it is both unduly restrictive and unnecessarily complex. In the context of the existing levels of built development at the Site (approx. 46,500sq.m), its recent planning history, the evidence to support the previous planning approvals and the historic allocation, it is not considered that the form of the draft allocation meets the requirements of the NPPF, specifically the needs to ensure the Plan is ‘prepared positively, in a way that is aspirational but deliverable’, sufficiently clear and unambiguous and serving a clear purpose in line with Paragraphs 16, 32 and 36.

With specific reference to the planning history of the site, this confirms that the Council accepted as recently as 2020 that the site can support the development of 50,445sq.m (GIA) across a range of different uses. The draft Local Plan does not provide any clear or coherent evidence base to demonstrate why the proposed restrictions in the draft allocation. What is required at the Site, which is consistent with the extant allocation and
planning history, is a careful, evidence-led management of development near the Borough Hill SAM, including an application-specific assessment of the necessary stand-off and controls over physical works. It does not require the application of restrictions as set out in the draft allocation.

To clarify, the evidence base for the draft Local Plan does not support, and does not even purport to support:
• Any form of confinement of the acceptable uses to a narrowly defined R&D or life sciences use;
• The exclusion of other parts of the ‘Former Spicers Estate’;
• The Borough Hill SAM or its setting requires the site to be divided by an arbitrary green line that risks becoming a ‘fixed feature’ if the allocation is carried forward in its current form;
• That the land on one side of that line is developable while all land on the other side must remain undeveloped, as there is no defined ‘line’ that determines the setting
of the Borough Hill SAM or its setting, or that sensitive treatment of development within the setting should be precluded.

Furthermore, the use of the arbitrary green line within the draft allocation has not been supported by heritage evidence relating to significance, effect, harm, mitigation and enhancement, or the weighting of harm against public benefits. It is not appropriate or deliverable to introduce a mapped line in the draft allocation that could be treated as an absolute constraint to development.

As an alternative, the draft allocation should be amended to remove the green line and to identify a wider form of development that can be accommodated. We recommend that this is framed in similar wording to the below, which would be supported in principle by our Client and justified by the context and evidence base:
“Employment-led development, including research and development, laboratories, offices, advanced manufacturing, innovation and other compatible employment generating uses, together with ancillary and complementary uses necessary to create a sustainable employment campus.”

In place of the arbitrary green line, our Client would be willing to accept the insertion of additional policy wording to the effect that:
“Development must conserve the significance of Borough Hill Scheduled Monument, including those elements of its setting which contribute to its significance. Proposals
should be informed by an up-to-date archaeological and heritage assessment and should demonstrate an appropriate built form and layout, access and movement,
open space and landscaping. Physical works within or close to the scheduled boundary will require early engagement with the Council and Historic England.”

It would also be appropriate and in line with the wider strategy and policies of the draft Local Plan and the requirements of the NPPF to delete Figure 80.

Conclusion
Our Client supports the principle of the preparation of the draft Local Plan, and broadly agrees with the vision and objectives of delivering development to support the needs of the area, including the provision of high-quality economic and employment growth. In particular, the Client supports the principle of the allocation of the ‘Former Spicers Site’ under Policy S/RSC/FSS for employment.

However, the wording of policies of the draft Local Plan, including S/RSC/FSS, require further detailed consideration as to the soundness and deliverability implications that they present. These policies should be amended to ensure they are sound and provide for
deliverable development to be brought forward. They need to be amended to ensure they are clear for future developers and decision-makers and to avoid any restrictions, which are not absolutely necessary, are allowed to endure. Restrictions risk preventing the
delivery of economic growth and employment potential over the Plan period where there is a significant shortfall at present.

Therefore, we consider that the draft Local Plan in its current form, would not pass the tests of soundness in the NPPF. Once amended, the draft Local Plan is capable of being found to be sound.

While we comment on a number of specific policies within these representations, our Client reserves the right to comment on other policies contained within the draft Local Plan at future consultation stages. These representations should not be read as being supportive of any policies that have not been commented on.

We also confirm that our Client wishes to appear at the Local Plan Examination in Public in due course, to further address the matters raised within these representations.