Greater Cambridge Local Plan: Proposed Submission

We would respectfully ask that the AvTech 2 and residential proposal are allocated in the draft submitted to Government and that the allocation is included in the Rural Southern Cluster (RSC) policy area recognising AvTech and its related industries is an important and growing sector significant locally, regionally and nationally. The
addition of an aviation related cluster would extend and diversify the RSC and should be supported in the same way as other campuses in the RSC.

With its partners IWM and Henry Boot Developments, Gonville & Caius College (Caius)
will shortly submit a hybrid planning applications for AvTech Phase 1. This will include up
to 50,000 sqm GEA of employment space for advanced aviation and related
technologies ( i.e.“AvTech”) - together with circa 11,000 sqm GEA of new conservation
and storage space for IWMs own use) at IWM Duxford.
Caius therefore welcomes and supports Reg 19 draft Policy S/AMC/IWM: Imperial War
Museum, Duxford (inc. AvTech 1) Area of Major Change, which explicitly recognises
the opportunity to develop additional commercial and aviation technology and related
space at IWM Duxford, by including “AvTech 1” within the policy title. This proposed
allocation in the Reg 19 Plan confirms the Council’s support for AvTech as a priority
employment sector in the Duxford area. We have commented separately on draft Policy
S/AMC/IWM.
Since 2019 Caius has responded to all “call for sites” exercises (Site Reference: 40095
ID: 115180) and previous consultations on the GCLP for the Plan to also recognise and
include an allocation for AvTech Phase 2 and related employment space (circa 70,000
sqm) and 800 new homes on Caius land east of the M11, south of the A505 and
adjacent to Duxford village. The Reg 19 GCLP does not include such an allocation. The
site is currently in agricultural use and is not within the green belt.
Caius remains of the view that an allocation should be made for the following reasons:

1. NPPF 2024 (para 86) sets out that Plans should…”set out a clear economic vision and strategy which positively and proactively encourages sustainable
economic growth, having regard to the national industrial strategy”. In our view AvTech falls within the priority sectors identified in Footnote 43.
2. NPPF 2024 (para 87) sets out…” Planning policies and decisions should recognise and address the specific locational requirements of different sectors…including the expansion or modernisation of other industries of local, regional or national importance to support economic growth and resilience.” Again we would consider AvTech falls within this description.
3. Reg 19 Plan Policy S/JH: New jobs and homes is to meet objectively assessed needs in Greater Cambridge over the period 2024-2045. Caius proposals would help meet those needs within the plan period on what Caius consider is a suitable, available and deliverable site. It would help build in additional flexibility and headroom to the councils employment/housing need figures which may be needed, particularly given the rapid growth seen in Greater Cambridge, the rise of new typologies such as mid-tech, the reduced potential at North East Cambridge,and where UK government is promoting further growth and productivity gains.
4. The AvTech Phase 2 proposals would provide expansion space (circa 70,000sqm) that investors and AvTech occupiers will need as part of a growing aviation
and related technologies economic ecosystem around Duxford.
5. The principle of AvTech and its economic benefits locally, regionally and nationally has been accepted in the proposed allocation at draft Reg 19 Policy
S/AMC/IWM: Imperial War Museum, Duxford (inc. AvTech 1) Area of Major Change. This Reg 19 policy explicitly identifies and recognises “AvTech 1”, de facto acknowledging there maybe need of additional nearby Avtech and related space (e.g. AvTech 2 providing expansion space for AvTech 1 occupiers and
others drawn to the cluster) as the technology hub grows. In turn this would be in keeping with an “area of major change” allocation.
6. The new homes and community infrastructure proposed would help meet local and Greater Cambridge housing and affordability needs, as well as potentially some AvTech workers as the technology cluster matures.
7. Provision of new local homes, social and community infrastructure (including a 40ha country park) would help provide a revitalised and sustainable future for an
expanded Duxford village.
8. Promoting sustainable development by encouraging walking and cycling to work is a key consideration and the AvTech Phase 2 masterplan proposals include a “green link” from close by Whittlesford Parkway through Duxford and would linkup with the enhanced bus provision planned for the AvTech 1 proposals from IWM Duxford to Whittlesford Parkway.
9. The Caius proposals are very well located at the intersection of the M11/A505,
and the development can be delivered without the need for a major level of strategic infrastructure investment. However, given Caius wider landownership in the area, Caius could help with any proposed A505 corridor improvements.
10. A masterplan approach would ensure there are no adverse impacts on the designated heritage assets and their setting, including listed assets and conservation areas, as well as aviation safety.

In summary we consider by not including provision for AvTech 2 the Reg 19 Plan is unsound in that:
1. It has not been positively prepared as it fails to allocate a site which would assist in meeting the objectively assessed needs for employment and housing and is suitable, available and deliverable.
2. Its approach to the site allocations assessment process is not justified as it fails to acknowledge that AvTech 2 and related uses would provide expansion space for AvTech 1 occupiers (which the Plan explicitly recognises through its draft Policy S/AMC/IWM) and for others attracted to be part of the advanced aviation
and related uses technology cluster.
3. It is not consistent with national planning policy which seeks to identify and make provision for growth of priority employment sectors which advanced aviation technology falls into.

Given the exceptional circumstances identified above, the land at Rectory Farm, Milton, provides an excellent opportunity for early development, and provides a
sound basis for allocation as part of the GCLP.

This could be promoted as a masterplan led “Area of Major Change” where the College would be keen to work with all relevant partners.

Additionally given the importance of the Waterbeach to Cambridge busway proposal and its impacts on landscape and green belt, the Plan should consider allocating a Phase 1 mixed use development, i.e. the land between the A10 and proposed busway to be delivered early in the plan period ( 6-15 years), with Phase 2 to follow at a later stage.

Rectory Farm is owned by Gonville & Caius. It covers a total area of approximately 95 hectares and is located on land to the north-west of the village of Milton. It currently consists of agricultural land and lies within the green belt. Caius has confirmed Rectory Farm is available, achievable and we would consider suitable.

The Waterbeach to Cambridge busway agreed route passes through the site effectively dividing it in two. Caius supports the busway and has agreed a private treaty sale for the land required. A Transport and Works Act Order (TWAO) is to be submitted.

Caius has responded to “call for sites” exercises (Site Reference: 54906 ID: 115167) and previous consultations on the GCLP. An updated masterplan (2025 – see attached supporting Reg 18 submission) was prepared taking account the busway route, giving capacity for circa 1,500 new homes and circa 50,000 (Min) – 100,000 (Max) sqm of commercial and employment floor space with substantial public open space/linear park.

The busway will be raised above the surrounding low lying topography and will materially change the landscape and green belt characteristics. It will divide the site in two and have an urbanising effect, reducing the contrast between the Milton settlement and the surrounding land with the busway creating a strong, physical boundary between
itself and the A10.

This will provide a clear and logical defined boundary on the eastern side of the busway for in-fill development up to the A10. The HELAA 2025 comments that the busway would…”arguably further degrade the rural character of the site”.

The councils Green Belt assessment (2021 and 2025 update) of this land parcel (MI1) does not consider the introduction of the busway, which as noted above is raised above the surrounding topography, and would in our view materially change the assessment of Parcel MI1.

An eastern Phase 1(within the A10 and busway route) would consist of circa 1,000 residential units and 40,000 sqm of commercial floorspace, plus a local centre consisting of retail, recreational and leisure facilities. This could be delivered before the busway is implemented and be built out over years 6 -15.

A western Phase 2 development would need to wait for busway works to be complete but would consist of a further 500 dwellings and a further 40,000 sqm commercial space, built out over years 11-16 + within the Plan period to 2045.

NPPF 2024 introduces grey belt land and Annex 2 defines it as …”land in the Green Belt comprising previously developed land and/or any other land that, in either case, does not strongly contribute to any of purposes (a), (b), or (d) in paragraph 143”. We consider there is also a strong case (increased by the busway) for considering the site as grey belt, as it does not make a strong contribution to the three core Green Belt purposes.

With the Anglian Water waste facility at Hartree not now relocating this has raised
significant questions for the Reg19 Plan given North East Cambridge was to deliver 234,500 sqm of workspace and 8500 new homes. To maintain needs targets and
headroom, Reg 19 has upped housing capacity in existing major designations as well as a new Grange Farm allocation. To meet employment needs existing clusters and hubs and Cambridge East are being accelerated along with densification at Cambridge Science and Business parks. We note there is also new impetus for development north of A14 with the Chivers/Trinity College and Ely Diocese proposals.

Rectory Farm has not been allocated in the Reg 19 Plan. However, Caius is of the view that Rectory Farm could form part of major mixed use expansion north of the A14 and that there are exceptional circumstances for its release from the green belt and allocation in the plan on the following grounds:
1. NPPF 2024 (146) states… ”exceptional circumstances in this context include, but
are not limited to, instances where an authority cannot meet its identified need for homes, commercial or other development through other means” (our bold italics).
2. For reasons set out above (and in attached supporting Reg 18 submission) we consider the busway as raised above the surrounding low lying topography will
materially change the landscape and green belt characteristics and create a new boundary.
3. NPPF 148 states…. “when drawing up or reviewing Green Belt boundaries, the need to promote sustainable patterns of development should determine whether
a site’s location is appropriate…”. In terms of sustainability:
• Rectory Farm is located adjacent to, rather than remote from existing employment concentrations. This places the site in a particularly strong position to support shorter commuting distances and to enable high levels of walking, cycling and public transport;
• It is in a sustainable location, adjacent to the A10. It is situated within a major growth corridor, with North East Cambridge and Science Park to the South and Waterbeach New Settlement to the north;
• It is adjacent to Milton Park & Ride and also benefits from very good cycle access to Cambridge City;
• Its sustainable location will be enhanced with the new Waterbeach to Cambridge busway (and associated cycling and walking improvements) to further improve public transport and cycling/ walking; and
• The provision for substantial growth at Milton would fully align with the objectives of achieving a cluster of growth along the Cambridge North East- Waterbeach Corridor.
4. Reg 19 Policy S/JH: New jobs and homes is to meet objectively assessed needs in Greater Cambridge over the period 2024-2045. Caius proposals would help
meet those needs within the plan period on what it considers is a suitable, available and deliverable site. It would help build in additional flexibility and headroom to the councils employment/housing need figures which may be needed, particularly given the rapid growth seen in Greater Cambridge, the rise of new typologies such as mid-tech, the reduced potential at North East Cambridge
(where Rectory Farm could help compliment and meet those needs locally in what is a major north/south growth corridor), and where UK government is promoting further growth and productivity gains.
5. In this context a first phase of mixed use development (circa 40,000 sqm employment and circa 1000 dwellings) i.e. that which would lie between the busway and A10 corridor, could proceed before Waterbeach to Cambridge busway is completed, early in the plan period.
6. Policy S/DS: Development Strategy considers in meeting general needs there is no requirement to release green belt land, but it does find exceptional circumstances for specialist needs. In context of NPPF 146, we consider the above factors represent exceptional circumstances for the release or part release of Rectory Farm from the green belt .
7. There is in any event a strong case for considering the site as grey belt, as it does
not make a strong contribution to the relevant NPPF Para 143 a), b), d) core Green Belt purposes, with the contribution further diminished by the introduction
of the busway and the presence of the adjacent park and ride.
8. Caius therefore considers that by not releasing Rectory Farm from the green belt and allocating the site, the Reg 19 Plan is unsound in that:
• It has not been positively prepared as it fails to allocate the site which would assist in meeting the objectively assessed needs and is suitable, available and
deliverable.
• is not justified as it fails to acknowledge that the introduction of the Waterbeach - Cambridge busway, which will materially change the landscape and green belt characteristics of the site, is an exceptional circumstance which justifies inclusion of this site within its site selection assessments.
• It is not consistent with national planning policy as it fails to allocate land in a sustainable location close to existing and proposed transport hubs and does not recognise the exceptional circumstances that justify the proposed
allocation of this site.

Caius would request the following change to Policy BG/BG

2. Major development should achieve the statutory biodiversity net gain of 10%. A higher percentage may be required where supported by site-specific evidence
demonstrating local need, local opportunities, viability and deliverability, in accordance with national planning policy and guidance”.

Gonville & Caius College, University of Cambridge (“Caius”) supports the principle of biodiversity net gain (BNG) and notes the statutory requirement for development is to deliver at least 10% biodiversity net gain (Environment Act 2021)

However, Caius object to the proposed requirement in Policy BG/BG that …” Major development must provide a minimum 20% biodiversity net gain”.

The College does not consider a blanket 20% requirement on all major sites – which will have very different physical, value and ecological typologies (city centre, rural, greenfield or brownfield) – has been evidenced in terms of practical deliverability and impacts on viability on different and specific sites - as opposed to a whole plan viability argument.

The NPPF 2024 does not set out a percentage target – neither does the current NPPF set out a specific target.

Significantly PPG (Reference ID: 74-006-20240214 006) notes…”Plan-makers should not seek a higher percentage than the statutory objective of 10% biodiversity net gain,
either on an area-wide basis or for specific allocations for development unless justified”
…and goes on to notes such justification/evidence relates to local needs, local opportunities for a higher percentage and any impacts on viability for development.
Seeking a higher requirement should only be by way of an exception, and in this case, demonstrating that Greater Cambridge is significantly worse than any other part of the
country as a whole with regards to the negative impacts on biodiversity seems realistic and unproven.

Moreover, a material consideration is not whether the 20% BNG requirement can be accommodated in isolation, but whether development remains viable when the cumulative effect of Policy BG/BG is considered alongside the Plan’s other policy requirements, Section 106 obligations, and the forthcoming introduction of CIL.

Caius therefore considers Policy BG/BG requirement for a minimum of 20% BNG on major development to be unsound. The policy requirement does not meet the NPPF
requirements:

Positively prepared - the 20% requirement could lead to viability issues impacting on the plans objectively assessed needs);
Justified - a more site by site approach would be a more appropriate strategy rather than the blanket approach proposed); and
Consistent with national planning policy - not in accord with NPPF or the PPG

Gonville & Caius College, University of Cambridge (“Caius”) recognises that Cambridge and South Cambridgeshire are areas of high affordability pressure and there is an need for affordable housing in Greater Cambridge.

Policy H/AH requires all self-contained dwellings to provide at least 40% of the new homes on site as affordable housing, with co-living developments a financial contribution for off-site provision is to be provided. This requirement applies to all residential developments of the equivalent of 10 or more dwellings.

NPPF (2024) (para 59) makes it clear it is up to the applicant to demonstrate whether particular circumstances justify the need for a viability assessment at the application stage and these should reflect the recommended approach in national planning practice guidance.

In this context we note that the councils have progressed a Community Infrastructure Levy (CIL) Charging Schedule shortly to go to Examination. The approach proposed in Greater Cambridge appears significantly different from many other situations, as the councils have confirmed that CIL will be used solely to fund strategic transport infrastructure with affordable housing, all other infrastructure, education, open space, community facilities, utilities, biodiversity and site‑specific works, continuing to be secured through Section 106. However, this seems at odds with the recently adopted (April 2026) Planning Obligations SPD (Para 10.14) which says …” Obligations will be sought where….there is a need generated for strategic transport improvements including measures to promote walking, cycling, public transport and highways traffic calming and capacity improvements” , i.e. off-site strategic infrastructure. SPD Para 10.21 gives further details of “strategic transport interventions”.

Prima facie it would appear Section 106 costs will not reduce following the introduction of CIL, rather CIL will operate as an additional charge on top of existing obligations.

Whilst qualifying affordable housing is eligible for 100% relief from CIL, it is concerning for the delivery of affordable housing as with other S106 charges ( e.g. a minimum requirement for 20% BNG – which we comment on separately) it is likley to give rise to more development viability assessment testing by applicants (NPPF Para 59) potentially resulting in reduced levels of provision or developments not progressing.

Caius support Policy H/AH where it states an affordable housing contribution will not be sought where the proposed development of student accommodation is for the redevelopment of buildings and land owned by the University of Cambridge, Anglia Ruskin University or a University of Cambridge College, and which will continue to be owned by one of these institutions after the redevelopment.

However, where student accommodation is delivered privately on other non-university sites of 10 or more units this is still to provide 40% affordable units.

We also note this 40% requirement also applies where the University of Cambridge, Anglia Ruskin University or a University of Cambridge College land or building is being redeveloped for other forms of housing.

This could risk a situation where a proportion of students who could potentially be housed in college accommodation, are remaining in the private rental market.

If the Councils are minded to retain Policy J/AW in relation to E(g)(iii), B2 and B8 development, Caius considers that it should be substantially amended to provide a more
targeted, flexible and proportionate approach.

In particular, the blanket 10% requirement should be replaced with a scheme-specific approach based on demonstrated local need, operational suitability and viability, including the cumulative cost of other Local Plan and infrastructure requirements.

Gonville & Caius College, University of Cambridge (“Caius”) recognises some businesses within Greater Cambridge experience affordability pressures and supports the overarching objective of promoting the provision of affordable workspace within employment developments.

However, Caius has concerns as to the soundness of Policy J/AW particularly whether it has been properly evidenced and would be effective in meeting its objectives. The evidence identifies affordability pressures particularly affecting SMEs, start-ups and creative businesses, but the policy applies a uniform requirement to a broad range of industrial and storage development with very different characteristics, values and operational requirements.

The policy, requiring discount to market rents of 20-30% in perpetuity and requiring affordable space to be predominately on site, could also have significant financial and operational implications.

The evidence does not sufficiently establish why 10% is an appropriate proportion of affordable workspace across all qualifying employment development.

The Affordable Workspace Study (2026) (9.1.2) says…”The evidence suggests that affordable workspace requirements should be tailored to the differing market conditions across Greater Cambridge rather than applying a single approach everywhere”…and …
“…with around 10% frequently used as a benchmark.

However, the level of provision is typically subject to viability, with flexibility applied depending on site characteristics and development context.”(10.2.1).

This would appear to differ materially from the Reg19 policy, which establishes a minimum 10% requirement for all qualifying E(g)(i-iii), B2 and B8 development, regardless of location, scheme type, land value or market conditions, and scale over 1000 sqm (offices and R&D) (requiring 30% market rent discount in Cambridge and 20% in South Cambridge) and 2500 sqm (industrial/logistics) (requiring 20% discount to market rents) thresholds.

We consider how the 10% requirement has been derived and why a uniform proportion is appropriate across the full range of affected development, from relatively small multiunit industrial schemes to large single-occupier logistics schemes should be clearly evidenced. It should also explain why the proportion should not instead be determined through a scheme-specific assessment of need and viability.

In this regard we note that London Plan Policy E3 (the area containing most established affordable workspace policies) is circumstances-based rather than a general
development requirement where planning obligations may be used to secure workspace at rents maintained below market rate for a specific social, cultural or economic
development purpose.

Moreover, a material consideration is not whether the 10% requirement can be accommodated in isolation, but whether development remains viable when the
cumulative effect of Policy J/AW is considered alongside the Plan’s other policy requirements, Section 106 obligations, and the planned introduction of CIL.
This cumulative impact is particularly important for employment development, where development and land values can vary significantly between locations and development typologies.

The payment-in-lieu provisions raise a separate concern. Where strategic industrial or logistics sites are unsuitable for affordable workspace, but the in lieu provision is
primarily intended for SME, start-ups and creative occupiers in more suitable locations,
the Policy should set out why large employment space should fund small employment space elsewhere.

There also appears inconsistency for the “in lieu” calculations. The Policy refers to GIA as the relevant starting point ,but Appendix G refers to NIA as the starting point.

Caius therefore finds Policy J/AW unsound on the following grounds:
Positively prepared - the 10% space requirement and discount to market rents of a minimum 30% within Cambridge and 20% discount to market rent in perpetuity in south Cambridge could lead to viability issues impacting on the plans objectively assessed needs.
Justified - a more site by site or employment typology approach would be a more appropriate strategy rather than the blanket approach proposed; and
Consistent with national planning policy - whilst the NPPF supports employment and business it provides no framework or policy requirement for affordable workspace,
hence the Reg 19 policy requires to be fully evidenced.

Suggested amendments at Para 2 to make clear a) it is not comprehensive redevelopment of the full site (Figure 87) but development within the policy area site,
and b) to recognise a masterplan for IWM Duxford as whole has been in place for some years and new proposals within policy area need to be themselves masterplan led and align with the IWM Duxford masterplan.
2. “Development of within the site will be masterplan led.
A masterplan for development focused on aviation and other complementary uses to support the future of the museum site must align with the wider masterplan for IWM
Duxford museum and airfield. This approach will enable development and associated infrastructure provision to be planned for and delivered in a comprehensive manner.”

Gonville & Caius College, University of Cambridge (“Caius”) supports Policy S/AMC/IWM: Imperial War Museum, Duxford (inc. AvTech 1) Area of Major Change.

The supporting text to the draft policy recognises...”‘there are opportunities for further development focused on aviation and other uses which are complementary and support the future of the museum site”. Caius is the adjacent landowner to IWM within the extended site policy area (Figure 87) and in partnership with IWM and Henry Boot Developments the parties are progressing
a masterplan led hybrid planning application for an advanced aviation technology centre
with new IWM conservation and storage facilities. These proposals would be in accord with the draft policy supporting text.

It is noted that the policy requires a masterplan led approach. In this context IWM has had a Duxford masterplan for some years which was prepared in consultation with key stakeholders including the local authority and Historic England, and this continues to
guide future development at IWM Duxford.
Caius considers the policy accords with NPPF 2024 (under which the GCLP is progressing) in that it is :
a) Positively prepared - helping meet the area’s objectively assessed employment and economic needs;
b) Justified - with an appropriate strategy for advanced aviation technology users as well
as IWM which both need airside access to an operational airfield and IWM Duxford is the only suitable, available and deliverable option;
c) Effective – being deliverable over the plan period; and
d) Consistent with national planning policy - including NPPF 111(f) - enabling the delivery of sustainable development focused on technologies themselves looking to decarbonise air based vehicles.