Greater Cambridge Local Plan Issues & Options 2020

4.99 This approach is supported given the responses to the preceding questions. When considered against the context of the Brickyard Farm site, the adjacent services and the adjacent Buckingway Business Park provide a unique opportunity to deliver a combined employment led cluster that can be self-sufficient thus alleviating pressure on infrastructure and services in the wider area.

4.100 For the reasons given in response to preceding questions, we strongly believe that siting development along transport corridors will assist in alleviating pressure on the main conurbation i.e. Cambridge. 4.101 This also has the benefit of expanding the economic benefits to areas outside of Cambridge through job creation, which in the case of Brickyard Farm is estimated in excess of 1,000 full time equivalent jobs during construction phases and between 2,900 and 3,260 full time equivalent jobs during operational phases, which can be drawn from several conurbations along the A14 and other routes.

4.102 As highlighted in Section 6 of the Logistics Need Report the Adopted Local Plan aims to “ensure there is sufficient employment land available, in the right places to support the economy”14 and support a target of 22,000 new jobs being provided in the district by 2031. 4.103 Reflecting the role of research and development in the economy, the Plan rightly places a strong emphasis on providing opportunities for new high technology and research and development at various locations close to the boundary with Cambridge City including Granta Park, Babraham Institute and the Wellcome Trust Genome Campus, in addition to Cambridge Science Park through Policy E/1. 4.104 In addition to the sites identified above, the Plan allocates further land for B1 uses at the following sites: • Policy E/2 - Extension to Cambridge Biomedical Campus to provide for biomedical and biotechnology research and development; 14 South Cambridgeshire District Council (2018) South Cambridgeshire Local Plan, p. 171 • Policy E/3 - Land adjoining Peterhouse Technology Park for B1 employment uses; • Policy E/4 – Land North of Hatton Road, Longstanton and Pampisford for B1 employment uses; and • Policy E/5 – Land at Norman Way, Over (1.7 ha.) and Land at Papworth Everard (2.5 ha.) for B1, B2 and B8 employment uses. 4.105 Policy E/9 of the Local Plan places importance on the promotion of employment clusters in the following sectors: • Biotechnology and biomedical; • Computer services; • Electronic engineering; • High-technology manufacturing; • Information technology / telecommunications; • Healthcare, teaching and research; • Research and development; • Clean Technology; and • Other locally driven clusters as they emerge. 4.106 The adopted Local Plan also aims to provide opportunities for a wider range of other employment that supports sustainable economic growth. However, whilst proposals for warehousing that supports other employment uses or meets local needs are supported, it is of note currently only two sites are allocated for B1, B2 and B8 use under policy Policy E/5: • Land at Norman Way, Over (1.7 ha); and • Land at Papworth Everard (2.5 ha). 4.107 Furthermore, in terms of logistics Policy E/11 explicitly states that ‘Large scale warehousing and distribution centres will not be permitted in the district’. The Council justify this approach at Paragraph 8.51 of the supporting text to the policy on the basis that: “These uses require a large land area, but generate relatively low numbers of jobs. They could quickly reduce the available land supply, and increase pressure on transport networks, which could harm the continued prosperity of the high technology clusters” 4.108 Moreover and despite having only been adopted in the last two years it is of note that the above Local Plan policies are informed by evidence15 produced nearly 8 years ago 15 SQW (2012) Employment Land Review Update and Review of Selective Management of Employment Policies: Report to South Cambridgeshire District Council and Cambridge City Council in 2012. In the intervening period the economic context has changed substantively, not least as a consequence of the strong growth in e-commerce. 4.109 Whilst growth on the scale witnessed in the intervening period might not have been foreseen in 2012, this evidence did identify the industrial and distribution sector as being an essential component of the local economy, which at the time was predominantly tied to servicing the R&D sector, Offices and Colleges. Although the market was perceived to be smaller than the regional key large scale distribution hubs of Peterborough and Bedford, there was also evidence of medium size requirements extending along the A1, A10 and A14 corridors, many of which at the time were not being satisfied. It is also notable that although there were fewer large scale occupiers in comparison to the wider region, this was primarily due to the shortage of large buildings to take up this demand16. 4.110 It follows that whilst the role of the sector was evidently apparent, the adopted Local Plan currently does very little to accommodate these needs. Whilst no evidence has yet been published by the Councils to confirm the extent of the shortage of industrial and warehouse land, the earlier sections of this report present unequivocal evidence that a growing need for such land in the Greater Cambridge area does in fact still exist. 4.111 In view of the need to maintain the economic buoyancy of the area, and in the context of the updated requirements of the NPPF and PPG, this evidently represents an important consideration for the emerging Joint Local Plan. 4.112 Indeed, failing to respond positively to identified needs will only serve to further constrain demand and sustainable logistics responses to satisfy consumer demand and the needs of businesses which form a critical part of the areas supply chain. 4.113 The Greater Cambridge Sustainable Design and Construction Supplementary Planning Document provides guidance on achieving the relevant sustainability policy the requirements of Sustainability Statements. The SPD acknowledges that current policy (in particular Policy 28) does not take a life cycle approach to reducing carbon emissions and focuses only on the operation of completed development. The SPD therefore introduces a suggestion for new development to strive to reduce carbon emissions from construction. 4.114 As set out within our response to Question 8, we would welcome a fair and flexible approach to net zero carbon which also includes consideration of embodied carbon. 4.115 One of the requirements within the SPD is for non-residential development to achieve BREEAM ‘Excellent’ rating. Whilst Newlands acknowledges that BREEAM can be an effective marketing tool, it does not necessarily deliver (or reward) sustainable buildings. The recent delivery of the BREEAM New Construction 2018 update was marred with issues including the oversight of SAP10 factors and a re-write of Land Use and Ecology credits after ecologists voiced concern over the feasibility and implementation of this section. The issues relating to energy have been partially fixed as they now include SAP10 factors, however there have been instances where all 16 Ibid, pX electric buildings which achieve a 30% carbon reduction on site under current building regulations do not meet the mandatory number of credits under Ene 01. These issues are largely related to the BRE methodology disproportionally awarding credits based on low energy demands rather than on-site energy generation which can negatively impact buildings with large on-site energy loads such as process and manufacturing industrial units. Requiring BREEAM ‘Excellent’ can also affect the viability of a development, with inflexible credit criteria requiring additional consultants to be appointed prior to Planning Submission. An example of this is within credit Hea 06 (exemplary criteria) which requires SABRE assessments (a new standard developed by the BRE) to be undertaken at an early stage in the development. 4.116 Instead of requiring BREEAM, it is suggested that the approach to sustainable development is communicated by the developer through a Sustainability Statement, which clearly outlines the credentials of the proposed development in line with policy. Delivering net zero carbon buildings should not come at the expense of the implementation and cost of BREEAM given the current state of Climate Emergency. Furthermore, implementing policies requiring a net biodiversity gain, climate resilience, and consideration of public health and well-being will deliver buildings with a holistic approach to sustainability in support of Greater Cambridge’s aspirations to be a sustainable and net zero carbon society.

4.117 In light of the responses provided within this report, we consider that the next Local Plan should give full and detailed consideration of the role the logistics sector and the allocation of the Brickyard Farm site will have in fostering economic growth for the plan period and beyond.

No choices made

4.96 New development should be sited a) where there is available brownfield or previously developed land within Cambridge and surrounding villages; b) where availability of such land does not meet the needs of a particular development sector it is considered that sites along the major road network and at the edge or just outside of existing village boundaries should be considered.