There appears to be no mention of Digital Tech Hubs. Such places are Recognised by the UK Government as the country’s fastest-growing tech sector.

A Tech Start-up with ambitious plans would likely start out with a requirement for a high quality affordable workplace. Cambridge is an area with a great deal of tech companies. If tech start-ups can not be supported in Cambridgeshire, they will in all likelihood start-up and expand in areas with support.

At Para 20.9 the draft SPD states. … “New major commercial developments, including mixed use schemes, are encouraged to make provision for affordable employment space. The provision of an element of affordable employment space will be most suited to large commercial schemes, e.g. proposals over 10,000m2, in use classes
E(g), B2 and B8, with 10% as the suggested amount of floorspace to be given
over to affordable use”.

The adopted Cambridge and South Cambridgeshire Local Plans do not include policies requiring affordable workspace provision. In other words there are no adopted plan policies for affordable workspace to be supplementary to. It is noted that…”The potential for a requirement is being explored through the emerging Greater Cambridge Local Plan”.

Whilst at this stage the wording appears discretionary Caius, along with its partners IWM and Henry Boot Developments at IWM Duxford AvTech (which is proposing circa 50,000 sqm of specialised employment space) are concerned that the stated intention to encourage 10% affordable workspace could give rise to uncertainty in viability assessments and pressure to deliver the 10% target in negotiations, delaying delivery of important development projects. If the planning authorities wish to encourage 10% affordable workspace, then this should be a matter for an independent Inspector of the emerging Local Plan to review by way of an EiP based on whether it will actually impact viability of development, as this is outside the remit of the SPD.

Pigeon considers that the requirement for new major commercial development to make provision for an element of affordable workspace has no clear or justified policy basis. Paragraphs 20.7 and 20.8 of the SPD refer to generic objectives and policies within the respective Local Plans that provide no clear link with employment or the economy and do not provide an appropriate policy basis or justification for the obligations being sought.

Pigeon is therefore concerned that the Councils appear to be introducing new policy approaches which go beyond the requirements of the adopted Development Plan, contrary to Planning Practice Guidance.

As such, it is considered that the proposed approach within the draft SPD would not meet the statutory tests within Regulation 122. Accordingly, this section should be deleted in its entirety

Endurance is concerned that there the requirement for large commercial developments to provide affordable workspace goes beyond the requirements of the adopted Development Plan.

Endurance considers that there is insufficient policy support to justify the use of planning obligations for this purpose and is concerned that the Councils appear to be introducing new policy approaches which go beyond the requirements of the adopted Development Plan contrary to the PPG and are not justified. It is considered that the proposed approach within the draft SPD would not meet the statutory and policy tests within Regulation 122 and the NPPF.

Newlands Developments welcomes the opportunity to make comments on the Autumn 2025 draft Greater Cambridge Planning Obligations SPD. Newlands is making this representation pursuant to their interest in land at Brickyard Farm, Boxworth (currently known as ‘Boxworth Gateway’) which has been promoted through the Call for Sites and Regulation 18 Greater Cambridge Local Plan (GCLP) consultation process (including the latest call for sites in March 2025) feeding into the emerging GCLP.

The land is subject to Call for Sites/HELAA Reference 47353, and Newlands are promoting it through the Local Plan to enable delivery of a highly sustainable Logistics development of up to 150,000 sq m. That would help address an acute shortfall of supply, and deliver on significant demand for logistics space in Greater Cambridge, as identified by Iceni’s ‘Greater Cambridge Warehouse & Industrial Space Needs’ (March 2025).

Planning Obligations context (Chapter 1)
SPDs should not introduce new planning policies. The National Planning Practice Guide (PPG) references what the role of supplementary planning documents is intended to be, stating:

Supplementary planning documents (SPDs) should build upon and provide more detailed advice or guidance on policies in an adopted local plan. As they do not form part of the development plan, they cannot introduce new planning policies into the development plan. They are however a material consideration in decision-making. They should not add unnecessarily to the financial burdens on development.

*Planning Practice Guidance - Paragraph: 008 Reference ID: 61-008-20190315

Indeed Para 1.6 of the draft SPD recognises that “The SPD does not introduce new planning policy but seeks to give effect to existing development plan policies”, i.e. the Cambridge City Local Plan 2018 and the South Cambridgeshire Local Plan 2018.

We comment below on Affordable Workspace where the draft SPD appears to encourage new or greater obligations than either national law/national planning policy or adopted local planning policy allow or require. In other words, the Affordable Workspace (10%) obligation is not supplementary to existing adopted local plan policy, nor consistent with national policy or Law.

Further, at present a Community Infrastructure Levy (CIL) does not apply to the Greater Cambridge Authorities. Thus, planning obligations will typically be secured through a s106 Agreement, made under Section 106 of the Town and Country Planning Act 1990. Regulation 122 of the Community Infrastructure Levy Regulations 2010 (“the CIL Regulations”) (as amended) sets out that it is unlawful for a planning obligation to be taken, if the obligation does not meet all of the following tests:
a. necessary to make the development acceptable in planning terms;
b. directly related to the development; and
c. fairly and reasonably related in scale and kind to the development.

In this context, the draft SPD sets out 20 potential areas (Chapters 4 to 23) where planning obligations may be sought. This could place significant additional costs on development, and it is important to ensure the Reg 122 tests are appropriately applied by the planning authority.

Affordable workspace (Chapter 20)

At Para 20.9 the draft SPD states. … “New major commercial developments, including mixed use schemes, are encouraged to make provision for affordable employment space. The provision of an element of affordable employment space will be most suited to large commercial schemes, e.g. proposals over 10,000m2, in use classes E(g), B2 and B8, with 10% as the suggested amount of floorspace to be given over to affordable use”.
The adopted Cambridge and South Cambridgeshire Local Plans do not include policies requiring affordable workspace provision. As such, there are no adopted plan policies for affordable workspace to be supplementary to. It is insufficient to simply state that “The potential for a requirement is being explored through the emerging Greater Cambridge Local Plan”.

Such an aspiration may or may not come forward in the Local Plan, and given it is currently at Regulation 18, the Joint Local Plan should be afforded very little weight.
This reference creates confusion. The SPD as a whole (if adopted) should be considered a material consideration for decision making, rather than parts of it. A consistent approach to that taken in the London Plan should apply, where it specifically states that affordable workspace policies should only be defined in Development Plans and Section 106 Agreements – i.e. not in SPDs.

Furthermore, the SPD applies the affordable workspace approach to all employment uses over 10,000 sq m. It isn’t clear from any evidence which specific business sectors are considered to justify a need for it. Further, Greater Cambridge is a large area, covering two authorities. The market conditions in the City Centre will be very different to city edges, villages and peripheral parts of South Cambridgeshire, so any policy for affordable workspace should be informed by specific market evidence in different locations and only be applied where there is a clear policy objective, and need for their introduction. In our view, this doesn’t work as a ‘one size fits all’.
Should there be, for example, a requirement for affordable space in a specific area of R&D, it doesn’t follow that the same requirement applies to logistics. Where the issue is less acute (geographically or sector-specific) and intervention is not required, the policy should not apply, as it could threaten the viability of development of certain types, and in certain locations.

Without further assessment of the types of business that might be defined as in need of 'affordable workspace' it is not possible to determine where they may locate. If demand/take-up did not exist, provision of such space would further erode industrial capacity in an area where the Council’s own evidence base has identified significant constraints on supply. This provision of smaller affordable units can fetter the ability for large logistics sites to function more efficiently, particularly given the requirements for large format commercial units, sufficient yard space and depth, HGV and car parking provision, SuDs, strategic landscaping and BNG areas. This requirement would place an additional strain on viability.

Accounting for land and Construction costs, viability differs in certain locations. A blanket obligation to all employment uses in all locations could ultimately undermine delivery of commercial space, for which Greater Cambridge has identified considerable need, given such space would also need to be managed by the landlord. This adds an additional financial burden.

All of the above, flags why extensive work is required to inform an evidence base and justify such an interventionist policy within defined geographical areas. It is considered confusing and unsound to apply any reference to affordable workspace within the SPD. Pursuant to the PPG, there is no policy for this to be supplemental to, and only through independent examination and locational scrutiny, which in the absence of a Spatial Strategy, can only be done through a DPD.

This representation has been prepared on behalf of Wrenbridge Land Limited (hereafter ‘Wrenbridge’) in
response to the Greater Cambridge Planning Obligation Supplementary Planning Document (SPD)
consultation closing 17 October 2025.

Wrenbridge has delivered several successful commercial schemes across Greater Cambridge including
recently at Lockton House, with other recent permissions at Clarendon House and Mercers Row.

Wrenbridge also maintain future land interests for developments across Greater Cambridge, they are
therefore well placed to provide a response to the draft SPD, particularly in relation to commercial
development and obligations.

Consultation Response

Below sets out our consultation response structured by the relevant chapters within the consultation
document.

This feedback is set out with the Community Infrastructure Levy 122 statutory tests in mind, which state
obligations can only be sought where they meet the following tests:
• Necessary to make the development acceptable in planning terms;
• Directly related to the development;
• Fairly and reasonably related in scale and kind to the development.
This test is also enshrined in paragraph 58 of the National Planning Policy Framework.

Chapter 7: Community Facilities

The need for all major commercial development to provide or contribute towards community facilities is
unclear (introduced at paragraph 7.10). Paragraph 7.13 goes onto explain that commercial
developments of greater than 5,000m2 will be required to ‘consider’ how the needs of workers and
visitors will be met in relation to social and leisure facilities. If the need is not met via existing or new onsite
facilities and contribution will be sought to address the impact.

It is not clear whether at paragraph 7.13 ‘existing or new on site-facilities’ means existing facilities on-site
or whether this can include a review of existing facilities within the general area. The paragraph should
be re-written to clarify this point. It could be re-written to state: If the need cannot be met through
existing facilities on-site, in the surrounding area or new on-site facilities […]’. This provides the
necessary clarification, with the pre-application process used to agree the scope of review ahead of a
planning submission.

However, should the ‘existing’ wording relate solely to on-site facilities then the following feedback is
provided.

It is not a sound approach to require all commercial developments of greater than 5,000m2 provide new
on-site facilities if they do not benefit from existing facilities. New commercial development may support
existing community facilities in their wider area by helping ensure their viability (ie: new customers for
existing public houses).

Chapter 14: Public Open Space & Chapter 15: Indoor Sports, Including Swimming

The same comments are made on these sections as for chapter 7 above. The reference to ‘existing’ in
paragraph 14.8 and 15.5 should be made clearer, that it also refers to a review of provision within the
wider area.

Chapter 20: Planning Obligations to Support Affordable Workspace

It is important to set out the purpose of SPDs in terms of decision making. The National Planning Policy
Framework defines them as:
‘Documents which add further detail to the policies in the development plan. They can be used to provide
further guidance for development on specific sites, or on particular issues, such as design.
Supplementary planning documents are capable of being a material consideration in planning decisions
but are not part of the development plan.’

The key strand of this is that SPDs add further details to policies in the development plan. They should
not be used to create in effect create new policies that have not been through the scrutiny of the Local
Plan process.

This is further elaborated upon in the Plan-Making Planning Practice Guidance and also add that they
should not add unnecessarily to the financial burden of development. Whilst The Town and Country
Planning (Local Planning) (England) Regulations 2012 at Part 4, Regulation 8, Limb (3) states that SPDs
must not conflict with the adopted development plan.
This is important to draw out as the Council acknowledge at paragraph 20.4, neither development plan
contain policies relating to affordable workspace.

The introduction of such an obligation or potential requirement may have a significant impact on the
viability of commercial developments across Greater Cambridge, which has not been subject the scrutiny
of Local Plan Examination. Nor does it appear any in-depth evidence has been prepared to support the
10% of floorspace aspiration including viability assessments, rather the Council has lifted a similar
approach from the London Plan.

Until such time as a future policy is subject to a fully evidenced approach that is scrutinised via the Local
Plan process, we believe that this chapter should be removed from the SPD entirely. The SPD can then
be updated in the future in this regard (if necessary) once a new Local Plan is adopted.

If you have any questions, please do not hesitate to get in touch.

This representation has been prepared on behalf of Wrenbridge Land Limited (hereafter ‘Wrenbridge’) in
response to the Greater Cambridge Planning Obligation Supplementary Planning Document (SPD)
consultation closing 17 October 2025.

Wrenbridge has delivered several successful commercial schemes across Greater Cambridge including
recently at Lockton House, with other recent permissions at Clarendon House and Mercers Row.

Wrenbridge also maintain future land interests for developments across Greater Cambridge, they are
therefore well placed to provide a response to the draft SPD, particularly in relation to commercial
development and obligations.

Consultation Response

Below sets out our consultation response structured by the relevant chapters within the consultation
document.

This feedback is set out with the Community Infrastructure Levy 122 statutory tests in mind, which state
obligations can only be sought where they meet the following tests:
• Necessary to make the development acceptable in planning terms;
• Directly related to the development;
• Fairly and reasonably related in scale and kind to the development.
This test is also enshrined in paragraph 58 of the National Planning Policy Framework.

Chapter 7: Community Facilities

The need for all major commercial development to provide or contribute towards community facilities is
unclear (introduced at paragraph 7.10). Paragraph 7.13 goes onto explain that commercial
developments of greater than 5,000m2 will be required to ‘consider’ how the needs of workers and
visitors will be met in relation to social and leisure facilities. If the need is not met via existing or new onsite
facilities and contribution will be sought to address the impact.

It is not clear whether at paragraph 7.13 ‘existing or new on site-facilities’ means existing facilities on-site
or whether this can include a review of existing facilities within the general area. The paragraph should
be re-written to clarify this point. It could be re-written to state: If the need cannot be met through
existing facilities on-site, in the surrounding area or new on-site facilities […]’. This provides the
necessary clarification, with the pre-application process used to agree the scope of review ahead of a
planning submission.

However, should the ‘existing’ wording relate solely to on-site facilities then the following feedback is
provided.

It is not a sound approach to require all commercial developments of greater than 5,000m2 provide new
on-site facilities if they do not benefit from existing facilities. New commercial development may support
existing community facilities in their wider area by helping ensure their viability (ie: new customers for
existing public houses).

Chapter 14: Public Open Space & Chapter 15: Indoor Sports, Including Swimming

The same comments are made on these sections as for chapter 7 above. The reference to ‘existing’ in
paragraph 14.8 and 15.5 should be made clearer, that it also refers to a review of provision within the
wider area.

Chapter 20: Planning Obligations to Support Affordable Workspace

It is important to set out the purpose of SPDs in terms of decision making. The National Planning Policy
Framework defines them as:
‘Documents which add further detail to the policies in the development plan. They can be used to provide
further guidance for development on specific sites, or on particular issues, such as design.
Supplementary planning documents are capable of being a material consideration in planning decisions
but are not part of the development plan.’

The key strand of this is that SPDs add further details to policies in the development plan. They should
not be used to create in effect create new policies that have not been through the scrutiny of the Local
Plan process.

This is further elaborated upon in the Plan-Making Planning Practice Guidance and also add that they
should not add unnecessarily to the financial burden of development. Whilst The Town and Country
Planning (Local Planning) (England) Regulations 2012 at Part 4, Regulation 8, Limb (3) states that SPDs
must not conflict with the adopted development plan.
This is important to draw out as the Council acknowledge at paragraph 20.4, neither development plan
contain policies relating to affordable workspace.

The introduction of such an obligation or potential requirement may have a significant impact on the
viability of commercial developments across Greater Cambridge, which has not been subject the scrutiny
of Local Plan Examination. Nor does it appear any in-depth evidence has been prepared to support the
10% of floorspace aspiration including viability assessments, rather the Council has lifted a similar
approach from the London Plan.

Until such time as a future policy is subject to a fully evidenced approach that is scrutinised via the Local
Plan process, we believe that this chapter should be removed from the SPD entirely. The SPD can then
be updated in the future in this regard (if necessary) once a new Local Plan is adopted.

If you have any questions, please do not hesitate to get in touch.

This representation has been prepared on behalf of Wrenbridge Land Limited (hereafter ‘Wrenbridge’) in
response to the Greater Cambridge Planning Obligation Supplementary Planning Document (SPD)
consultation closing 17 October 2025.

Wrenbridge has delivered several successful commercial schemes across Greater Cambridge including
recently at Lockton House, with other recent permissions at Clarendon House and Mercers Row.

Wrenbridge also maintain future land interests for developments across Greater Cambridge, they are
therefore well placed to provide a response to the draft SPD, particularly in relation to commercial
development and obligations.

Consultation Response

Below sets out our consultation response structured by the relevant chapters within the consultation
document.

This feedback is set out with the Community Infrastructure Levy 122 statutory tests in mind, which state
obligations can only be sought where they meet the following tests:
• Necessary to make the development acceptable in planning terms;
• Directly related to the development;
• Fairly and reasonably related in scale and kind to the development.
This test is also enshrined in paragraph 58 of the National Planning Policy Framework.

Chapter 7: Community Facilities

The need for all major commercial development to provide or contribute towards community facilities is
unclear (introduced at paragraph 7.10). Paragraph 7.13 goes onto explain that commercial
developments of greater than 5,000m2 will be required to ‘consider’ how the needs of workers and
visitors will be met in relation to social and leisure facilities. If the need is not met via existing or new onsite
facilities and contribution will be sought to address the impact.

It is not clear whether at paragraph 7.13 ‘existing or new on site-facilities’ means existing facilities on-site
or whether this can include a review of existing facilities within the general area. The paragraph should
be re-written to clarify this point. It could be re-written to state: If the need cannot be met through
existing facilities on-site, in the surrounding area or new on-site facilities […]’. This provides the
necessary clarification, with the pre-application process used to agree the scope of review ahead of a
planning submission.

However, should the ‘existing’ wording relate solely to on-site facilities then the following feedback is
provided.

It is not a sound approach to require all commercial developments of greater than 5,000m2 provide new
on-site facilities if they do not benefit from existing facilities. New commercial development may support
existing community facilities in their wider area by helping ensure their viability (ie: new customers for
existing public houses).

Chapter 14: Public Open Space & Chapter 15: Indoor Sports, Including Swimming

The same comments are made on these sections as for chapter 7 above. The reference to ‘existing’ in
paragraph 14.8 and 15.5 should be made clearer, that it also refers to a review of provision within the
wider area.

Chapter 20: Planning Obligations to Support Affordable Workspace

It is important to set out the purpose of SPDs in terms of decision making. The National Planning Policy
Framework defines them as:
‘Documents which add further detail to the policies in the development plan. They can be used to provide
further guidance for development on specific sites, or on particular issues, such as design.
Supplementary planning documents are capable of being a material consideration in planning decisions
but are not part of the development plan.’

The key strand of this is that SPDs add further details to policies in the development plan. They should
not be used to create in effect create new policies that have not been through the scrutiny of the Local
Plan process.

This is further elaborated upon in the Plan-Making Planning Practice Guidance and also add that they
should not add unnecessarily to the financial burden of development. Whilst The Town and Country
Planning (Local Planning) (England) Regulations 2012 at Part 4, Regulation 8, Limb (3) states that SPDs
must not conflict with the adopted development plan.
This is important to draw out as the Council acknowledge at paragraph 20.4, neither development plan
contain policies relating to affordable workspace.

The introduction of such an obligation or potential requirement may have a significant impact on the
viability of commercial developments across Greater Cambridge, which has not been subject the scrutiny
of Local Plan Examination. Nor does it appear any in-depth evidence has been prepared to support the
10% of floorspace aspiration including viability assessments, rather the Council has lifted a similar
approach from the London Plan.

Until such time as a future policy is subject to a fully evidenced approach that is scrutinised via the Local
Plan process, we believe that this chapter should be removed from the SPD entirely. The SPD can then
be updated in the future in this regard (if necessary) once a new Local Plan is adopted.

If you have any questions, please do not hesitate to get in touch.