Greater Cambridge Local Plan: Proposed Submission

1. Executive position
Cambridgeshire Chamber of Commerce supports the fundamental growth ambition of the
Proposed Submission Greater Cambridge Local Plan.
Greater Cambridge is one of the UK's most important centres for innovation, research, technology and life sciences, alongside a much wider economy encompassing biotech and high-tech manufacturing, general manufacturing, professional services, construction,
logistics, retail, hospitality and the rural economy.
The Plan anticipates approximately 73,300 additional jobs between 2024 and 2045 and at least 48,069 new homes. It also recognises the need for further employment
development and a sufficiently flexible supply of employment land.
The Chamber strongly supports planning positively for this growth.
Our principal concern is not the scale of the ambition, but whether it can be delivered.
Greater Cambridge will not fulfil its economic potential unless:
• housing delivery keeps reasonable pace with employment growth;
• sufficient employment land and commercial premises are available in the right places, of the right type and at the right time;
• water, wastewater and drainage infrastructure can be delivered in a timely and cost-
effective manner;
• sufficient electricity and grid capacity, including timely connections, is available;
• transport infrastructure connects people, businesses and strategic growth locations effectively;
• legitimate operational needs of existing and growing businesses are recognised;
• planning obligations remain cumulatively viable;

• planning applications and associated approvals are dealt with efficiently and predictably; and
• the Plan responds quickly when infrastructure, housing or economic growth diverges from its assumptions.
The Chamber therefore supports the Plan subject to targeted modifications designed to improve its effectiveness and deliverability.
Our principal recommendations are:
1. establish and monitor a rolling five-year supply of quality, deliverable employment land;
2. introduce stronger strategic infrastructure delivery milestones and contingencies;
3. monitor jobs, homes and infrastructure together with clear early-review triggers;
4. explicitly assess the cumulative viability of Local Plan requirements;
5. robustly apply the Agent of Change principle to protect established businesses;
6. establish an annual Greater Cambridge Growth and Infrastructure Dashboard;
7. create structured and continuing engagement with businesses, developers and infrastructure providers;
8. strengthen cross-boundary coordination;
9. promote a positive and efficient planning-delivery culture; and
10. identify opportunities to accelerate growth at locations where infrastructure capacity already exists or can be delivered quickly.
Our objective can be summarised simply:
Plan positively. Decide promptly. Deliver infrastructure. Enable growth.

2. Chamber evidence and national policy context
2.1 Local employer evidence
The Chamber's Cambridgeshire and Peterborough Skills Survey 2026 received responses from 341 employers.
It identified significant recruitment pressures, including:
• 52% of employers reporting recruitment to have been difficult or very difficult;

• 60% reporting applicants lacked relevant technical skills;
• particular challenges recruiting skilled technical occupations; and
• continuing difficulties recruiting specialist and professional roles.
The Chamber does not suggest that housing or transport alone causes these recruitment difficulties.
Businesses also identify wider issues including employment costs, regulation and skills availability.
The evidence does, however, demonstrate that access to labour is already a material
constraint on business growth. The Local Plan must therefore consider the wider conditions required for businesses to recruit, invest and expand.
The Chamber's Quarterly Economic Survey and Local Skills Improvement Plan work provide further continuing employer intelligence on recruitment, investment and business
conditions.
2.2 Existing Chamber position on Greater Cambridge
The Chamber has consistently identified infrastructure-first delivery as fundamental to successful Greater Cambridge growth.
Our policy work has particularly emphasised:
• transport;
• water resilience;
• wastewater and drainage;
• electricity and energy capacity;
• workforce housing;
• suitable employment premises; and
• coordination between economic growth and infrastructure.
These concerns pre-date this Regulation 19 consultation and reflect continuing feedback from employers and developers.
2.3 British Chambers of Commerce evidence
The Chamber's position is consistent with that of our national representative, the British Chambers of Commerce.

BCC's January 2026 report, Planning for Business and Growth, argues that planning should operate as a strategic enabler of investment and economic development rather than an
obstacle to growth.
Its recommendations include:
• giving employment land equal priority with housing;
• maintaining a five-year quality employment land supply;
• ensuring the totality of planning obligations does not render development unviable;
• protecting existing businesses through the Agent of Change principle;
• improving planning capacity and predictability;
• strengthening infrastructure delivery; and
• ensuring meaningful business engagement throughout plan-making and implementation.
The Chamber considers these principles particularly relevant to Greater Cambridge.
2.4 National Planning Policy Framework
The Chamber notes the publication of a new National Planning Policy Framework on 17 August 2026.
The new national policy direction continues to emphasise sustainable economic development, greater certainty and a positive approach to decision-making.
The Chamber particularly supports the principle that planning authorities should approach development proposals positively and creatively, work proactively with applicants and seek to approve sustainable development wherever possible.
We recognise that the examination of this Local Plan will be subject to the relevant national transitional provisions and the applicable version of national policy.
Nevertheless, the direction of national planning reform reinforces an important point for implementation of the Greater Cambridge Local Plan:
policy ambition must translate into timely, predictable and positive decision-making.

18. Consolidated modifications requested
The Chamber asks that the Local Plan be modified or supplemented to provide for:
1. A rolling five-year quality employment land supply
Employment land should be monitored by type, size, quality, geography, infrastructure availability, planning readiness and deliverability.
2. Stronger jobs-homes-infrastructure monitoring
Employment growth, housing delivery and infrastructure should be considered together with explicit early-review triggers.
3. A strategic infrastructure delivery trajectory
Critical water, wastewater, drainage, energy, transport and digital infrastructure should have identified owners, funding, milestones, connection expectations, deadlines and
contingencies.
4. Prioritisation of deliverable growth opportunities
Locations where necessary infrastructure already exists, or can be provided quickly, should be identified so sustainable development can proceed without unnecessary delay.
5. A Greater Cambridge Growth and Infrastructure Dashboard
Performance should be reported publicly at least annually.
6. Cumulative viability safeguards
The combined effect of Local Plan requirements should be assessed and monitored, with evidence-based flexibility where necessary.
7. Robust Agent of Change protection
New sensitive development should not prejudice legitimate established business activity.
8. Stronger cross-boundary coordination
Infrastructure, transport, utilities and economic development should be aligned across the wider functional economic area.
9. Ongoing formal business and utility-provider engagement
The Chamber proposes a Greater Cambridge Business and Growth Forum to support Plan implementation.
10. A positive planning-delivery culture
The Councils should pursue timely, collaborative and predictable planning processes with clear service standards and accountability.

19. Overall conclusion
Cambridgeshire Chamber of Commerce supports the ambition for Greater Cambridge to continue growing as a world-leading place to live, work, innovate and invest.
Our position is not that the Plan should pursue less growth or lower standards. Our position is that growth must be deliverable.
BCC has argued nationally that employment land must receive equal priority with housing, planning obligations must remain viable, businesses need greater certainty and policy ambition must translate into measurable delivery.
Those principles are particularly important in Greater Cambridge.
A Local Plan providing for approximately 73,300 additional jobs and 48,069 homes can succeed only if the infrastructure, workforce, commercial capacity and planning system required to support those ambitions are delivered at the necessary pace.
The Chamber therefore asks the Councils and Inspector to ensure that the final Plan:
• positively accommodates economic success;
• treats employment land as strategically important;
• delivers housing alongside jobs;
• provides critical infrastructure at the right time and at reasonable cost;
• protects established businesses;
• maintains proportionate and viable policy requirements;
• encourages sustainable innovation;
• monitors outcomes transparently;
• promotes timely and collaborative planning decisions; and
• responds rapidly where delivery is being constrained. Greater Cambridge has enormous economic potential.
The challenge is no longer simply to plan for growth. It is to deliver it.
The Chamber is ready to work constructively with the Councils, Combined Authority,
infrastructure providers, Government and the wider business community to help achieve that ambition.

The Chamber requests that Policy S/JH and/or its monitoring framework explicitly provide for:
1. annual monitoring of employment growth and housing delivery;
2. comparison of actual employment growth with the planned housing trajectory;
3. monitoring of relevant labour-market indicators;
4. infrastructure delivery monitoring alongside jobs and homes;

5. identification of sustained material divergence between these measures; and
6. clear corrective-action and early-review triggers.
Where economic growth exceeds assumptions, the response should consider whether
additional housing, employment land and infrastructure are required to accommodate that success sustainably.

Policy S/JH identifies a need for approximately 73,300 additional jobs and 48,069 new homes over the Plan period.
The Chamber strongly supports a positive approach to both economic growth and housing delivery.
However, the scale of employment growth envisaged requires an effective labour market capable of supporting it.
The Plan must recognise the relationship between:
• employment growth;
• housing supply and affordability;
• transport connectivity;
• skills;
• employment premises; and
• infrastructure.
Housing should therefore be regarded not only as a social requirement but as essential economic infrastructure.
A material and sustained divergence between jobs and homes could increase commuting pressures, compound recruitment difficulties and constrain competitiveness.
The reverse is equally important.
If Greater Cambridge's economy grows faster than forecast, that success should not become a reason to restrict further investment because housing, infrastructure or commercial capacity has failed to keep pace.

Soundness concern Effectiveness.
Modification sought

The Chamber requests a transparent infrastructure delivery trajectory for strategically significant growth locations identifying:
• critical infrastructure required;

• existing infrastructure capacity;
• responsible delivery organisation;
• funding status;
• expected delivery date;
• anticipated connection or delivery times;
• key dependencies;
• latest date by which infrastructure must become operational;
• consequences for planned development if delivery slips; and
• contingency or alternative delivery arrangements.
The Plan should also identify locations where growth can be delivered earlier because infrastructure capacity already exists or can be provided quickly.
Infrastructure constraints should not become a long-term ceiling on otherwise sustainable economic growth.

The Chamber supports directing growth towards sustainable locations and strategic sites capable of accommodating homes, employment and infrastructure.
However, the effectiveness of the development strategy depends heavily upon infrastructure delivery.
The Plan itself identifies direct dependencies, including development whose timing is linked to the availability of water infrastructure.
These are therefore not theoretical risks.
Our members' practical experience is that the delivery of roads, electricity connections, water, foul water and surface-water infrastructure can be slow, uncertain and costly.
The question is consequently not only whether theoretical network capacity exists, but:
• whether a practical connection can be secured;
• how long it will take;
• what it will cost; and
• who is accountable for delivery.
A strategic allocation is not genuinely deliverable simply because it is shown on a policies map.

The Chamber requests a strengthened infrastructure delivery mechanism which:
1. identifies critical infrastructure dependencies;
2. identifies responsibility for funding and delivery;
3. publishes measurable delivery and connection milestones;
4. monitors expected versus actual delivery times;
5. identifies contingency measures where projects or connections are delayed;
6. distinguishes site-specific requirements from strategic network deficiencies;
7. encourages coordinated engagement between planning authorities, applicants and utility providers;
8. considers opportunities for alternative or accelerated infrastructure delivery;
9. monitors capacity against actual economic and housing growth; and
10. triggers intervention or Plan review where infrastructure constraints materially threaten growth.
Utility providers should be directly involved in the continuing implementation and monitoring arrangements proposed by the Chamber.

Chamber position: SUPPORT, SUBJECT TO SIGNIFICANT MODIFICATION

Infrastructure delivery is one of the Chamber's highest priorities. We are particularly concerned about:
• water supply;
• wastewater treatment;
• foul and surface-water drainage;
• electricity-grid capacity;
• electricity connection times and costs;
• highways and access infrastructure;
• strategic transport;
• digital connectivity; and
• coordination between infrastructure providers and development sites. The Chamber strongly supports infrastructure and energy masterplanning.

However, businesses and individual developments should not be expected to resolve strategic network deficiencies which properly require action by utility companies,
regulators, government or wider public-sector partnerships.
Our members report that infrastructure works can involve high costs and lengthy processes which materially affect scheme viability and investment decisions.
Infrastructure delivery therefore needs to be tested on time, cost and practical deliverability, not simply theoretical capacity.

Chamber position: SUPPORT, SUBJECT TO SIGNIFICANT MODIFICATION

Infrastructure delivery is one of the Chamber's highest priorities. We are particularly concerned about:
• water supply;
• wastewater treatment;
• foul and surface-water drainage;
• electricity-grid capacity;
• electricity connection times and costs;
• highways and access infrastructure;
• strategic transport;
• digital connectivity; and
• coordination between infrastructure providers and development sites. The Chamber strongly supports infrastructure and energy masterplanning.

However, businesses and individual developments should not be expected to resolve strategic network deficiencies which properly require action by utility companies,
regulators, government or wider public-sector partnerships.
Our members report that infrastructure works can involve high costs and lengthy processes which materially affect scheme viability and investment decisions.
Infrastructure delivery therefore needs to be tested on time, cost and practical deliverability, not simply theoretical capacity.

The Chamber requests an annual public Greater Cambridge Growth and Infrastructure Dashboard.

Chamber position: MODIFICATION REQUESTED TO POLICY S/MO / MONITORING FRAMEWORK

The Chamber welcomes annual Local Plan monitoring but believes it should become considerably more transparent and outcome-focused.

The Chamber therefore requests an annual public Greater Cambridge Growth and Infrastructure Dashboard.
The term means a concise, publicly accessible assessment showing whether the principal assumptions and dependencies underpinning the Local Plan are actually being delivered.

It should include, as a minimum:
• net employment growth;
• employment floorspace delivered and lost;
• supply of available and deliverable employment land;
• housing completions;
• affordable housing completions;
• performance against housing trajectory;
• strategic employment-site delivery;
• water and wastewater infrastructure capacity and milestones;
• utility connection constraints and, where practicable, indicative delivery times;
• electricity-grid and strategic energy milestones;
• strategic transport milestones;
• major digital infrastructure dependencies; and
• performance of strategically important planning and infrastructure processes where relevant.

Monitoring should cover over-performance as well as under-performance.

If Greater Cambridge grows faster than anticipated, the Plan should respond positively by considering whether additional homes, commercial space and infrastructure are required.

The Chamber does not consider business-rate receipts to be an appropriate formal Local Plan monitoring indicator, although wider economic monitoring by local authorities and the Combined Authority should continue to consider the health and growth of the business base.

Soundness concern Effectiveness.
Modification sought

The Chamber requests that the Plan commits to maintaining and annually monitoring a
rolling five-year supply of quality, deliverable employment land, assessed by:
• location;
• use/type;
• size;
• quality;
• infrastructure availability;
• planning readiness;
• timescale for practical delivery; and
• reasonable commercial deliverability.

Where a persistent shortage emerges within a particular category or location, a mechanism should exist for corrective intervention and, where necessary, early review.
Employment land should not be treated as residual to housing provision.

Chamber position: STRONG SUPPORT, WITH ADDITIONAL MODIFICATION SOUGHT

The Chamber strongly supports maintaining a flexible supply of employment land. Greater Cambridge requires adequate provision for:
• offices;
• laboratories;
• R&D;
• biotechnology;
• advanced and high-tech manufacturing;
• general industrial uses;
• warehousing and logistics;
• workshops;
• start-ups;
• scale-ups;
• SMEs; and
• businesses serving the rural economy.
Monitoring aggregate employment floorspace alone is insufficient.
Businesses need premises of the right type, quality and scale, in the right location and at the right time when an investment decision is being made.
Land must also be genuinely deliverable.
That means considering both commercial deliverability and planning/infrastructure deliverability.
BCC's Planning for Business and Growth report similarly identifies shortages of
commercially developable and well-located employment land as a constraint on investment and productivity and recommends a five-year quality employment land supply.
Soundness concern Effectiveness.

The Chamber requests that the Plan commits to maintaining and annually monitoring a
rolling five-year supply of quality, deliverable employment land, assessed by:
• location;

• use/type;
• size;
• quality;
• infrastructure availability;
• planning readiness;
• timescale for practical delivery; and
• reasonable commercial deliverability.

Where a persistent shortage emerges within a particular category or location, a mechanism should exist for corrective intervention and, where necessary, early review.
Employment land should not be treated as residual to housing provision.

Chamber position: STRONG SUPPORT, WITH ADDITIONAL MODIFICATION SOUGHT

The Chamber strongly supports maintaining a flexible supply of employment land. Greater Cambridge requires adequate provision for:
• offices;
• laboratories;
• R&D;
• biotechnology;
• advanced and high-tech manufacturing;
• general industrial uses;
• warehousing and logistics;
• workshops;
• start-ups;
• scale-ups;
• SMEs; and
• businesses serving the rural economy.
Monitoring aggregate employment floorspace alone is insufficient.
Businesses need premises of the right type, quality and scale, in the right location and at the right time when an investment decision is being made.
Land must also be genuinely deliverable.
That means considering both commercial deliverability and planning/infrastructure deliverability.
BCC's Planning for Business and Growth report similarly identifies shortages of
commercially developable and well-located employment land as a constraint on investment and productivity and recommends a five-year quality employment land supply.
Soundness concern Effectiveness.

The Chamber requests robust application of the Agent of Change principle.
New sensitive development should incorporate sufficient mitigation to ensure that lawful existing business operations and reasonable future expansion are not subsequently
prejudiced.

Chamber position: ADDITIONAL POLICY SAFEGUARD REQUESTED
The Chamber welcomes the protection of existing business space.
We also consider it important that established lawful businesses are protected from
unreasonable constraints arising from sensitive development subsequently introduced nearby.
This is particularly relevant where residential or other sensitive development is introduced close to:
• industrial estates;
• manufacturing facilities;
• laboratories and research campuses;
• logistics operations;
• cultural or entertainment venues;
• workshops; and
• other established commercial operations. Potential impacts include legitimate:
• noise;

• odour;
• lighting;
• servicing activity;
• transport movements; and
• hours of operation.
BCC supports the Agent of Change principle, under which the party introducing a new sensitive use should take responsibility for appropriate mitigation.

The Chamber requests an evidence-based mechanism allowing the amount, form,
management or delivery of affordable workspace to be varied where robust evidence demonstrates that the standard requirement would:
• make otherwise sustainable employment development unviable;
• materially prejudice strategically important employment delivery; or
• conflict with genuine operational requirements.
Flexibility should be transparent and evidence-based rather than automatic.

Chamber position: OBJECT IN PART / MODIFICATION REQUIRED
The Chamber supports the objective of making suitable workspace accessible to start-ups, smaller businesses and creative enterprises.
Our concern is the cumulative viability effect of the affordable-workspace requirement when combined with other Local Plan obligations.
Commercial development viability varies significantly according to:
• location;
• use;
• specification;
• remediation;
• infrastructure requirements;
• financing;
• occupier needs; and
• market conditions.

A policy intended to increase access to workspace would be counterproductive if it reduced the total amount of employment development capable of proceeding.
BCC similarly argues that the totality of planning obligations should not make development unviable.
The Chamber also notes that the affordability of premises to SMEs is determined by total occupancy costs, not rent alone.
Business rates, energy and other fixed property costs can materially affect decisions to take additional space or expand.

Business-rates policy itself sits substantially outside the scope of the Local Plan. Nevertheless, affordable-workspace policy should recognise the complete cost environment facing smaller businesses.
Soundness concern

Justified and effective. Modification sought