Draft Greater Cambridge Local Plan for consultation

Incorporate the impact of East West Rail on the transportation aspects of the plan at this stage, in particular with respect to Cambourne North.

Soundness Test 1: Positively Prepared
Requirement
The Plan should be based on a strategy that seeks to meet objectively assessed development and infrastructure needs, including transport, in a realistic and deliverable way.
EWR-related concerns
• The Plan allocates substantial housing growth at Cambourne and Tempsford on the assumption that East West Rail (EWR) will provide the necessary transport capacity to Cambridge.
• The only published evidence of EWR-modelled passenger demand (ref 1) predicts that only a very small proportion of residents would use EWR to commute to Cambridge (approximately 3% from Cambourne and 2% from Tempsford). A consequence of this is that approximately 97% of Cambridge commuters from Cambourne would use the road.
• EWR Co has since stated (ref 2) that it has moved away from this model but has not published any replacement analysis.
Why this matters
Without credible, current evidence that EWR will meet a significant proportion of travel demand arising from planned development, the Plan cannot be said to be positively prepared. Instead, it risks underestimating the scale of unmet transport need and associated road congestion.
Soundness Test 2: Justified
Requirement
The Plan must be based on proportionate, robust, and credible evidence and represent the most appropriate strategy when reasonable alternatives are considered.
EWR-related concerns
• The selection of the Southern Approach to Cambridge was explicitly justified in 2023 by the need to serve employment growth at the Cambridge Biomedical Campus (CBC) (ref 3), despite higher cost and environmental impact.
• Subsequent evidence undermines this justification:
o The ETR predicted very low levels of EWR commuting to Cambridge even under optimistic housing assumptions (ref 4).
o EWR Co’s revised transport analysis (ref 5) does not include any additional housing for Cambourne North (even though their business case assumed about 25,000 new houses).
o The County Council’s transport assessment (ref 6) indicates that only around 1% of trips from extended Cambourne would be destined for the CBC.
o Changes in the pharmaceutical and life sciences sector have reduced the certainty of large-scale employment growth at the CBC (ref 7).
• No updated passenger demand forecasts or alternative scenarios have been published. The Plan states (ref 8) that the Greater Cambridge Transport Strategy is being prepared by the Cambridgeshire and Peterborough Combined Authority and is scheduled "for completion by the end of 2026".
Why this matters
The Plan relies on assumptions that are either outdated or contradicted by other evidence. Reasonable alternatives—such as different transport strategies, different spatial distributions of growth, or phased development—have not been properly tested. This calls into question whether the strategy is justified.
Soundness Test 3: Effective
Requirement
The Plan must be deliverable over the Plan period, with clear mechanisms for infrastructure delivery, funding and joint working.
EWR-related concerns
• East West Rail has not yet secured a Development Consent Order and its delivery timetable remains uncertain.
• The Plan nonetheless appears to treat EWR as a fixed and reliable piece of infrastructure, allocating large housing numbers to it.
• If EWR is delayed, scaled back or delivers fewer trips than assumed, the Plan has no clear contingency to manage the resulting increase in road traffic.
• Attributing all housing north of Cambourne to EWR risks overstating economic (ref 9) and transport benefits while underplaying delivery risk.
Why this matters
A Plan that depends on a major, undetermined infrastructure scheme without robust fallback options cannot be considered effective. There is a real risk that development will proceed without the infrastructure needed to support it.
Soundness Test 4: Consistent with National Policy
Requirement
The Plan should enable sustainable development in accordance with the National Planning Policy Framework (NPPF), including promoting sustainable transport and reducing reliance on private cars.
EWR-related concerns
• The Plan assumes a level of rail mode share that is not supported by the available evidence (see Soundness Test 2 above).
• If only a small proportion of trips use EWR, most external trips from Cambourne and Tempsford will be by road, increasing congestion and environmental harm.
• The reliance on an expensive and environmentally damaging rail alignment has not been clearly justified by demonstrable transport or sustainability benefits.
Why this matters
If the outcome of the Plan is increased car dependency and congestion due to over-reliance on unproven rail assumptions, it is not consistent with national policy objectives for sustainable transport.
References
(1) EWRCo. Route Update Announcement, Economic and Technical Report Appendix 4 Table 4.1
(2) Meeting between EWR Co, Pippa Heylings MP and local parish councillors 10 Dec 25
(3) https://www.youtube.com/watch?v=mgd10ZiriUo
(4) EWRCo. Route Update Announcement, Economic and Technical Report Appendix 4 Table 4.1
(5) EWR Transport Update Report, Non-statutory consultation, November 2024, §13.2.2
(6) https://consultations.greatercambridgeplanning.org/sites/gcp/files/2025-10/EBGCLPDCGTEROct25.pdf
(7) https://www.clinicaltrialsarena.com/news/uk-pharma-industry-risks-losing-world-leading-status-as-investment-plummets/
(8) Draft Greater Cambridge Local Plan, p27
(9) https://www.gov.uk/government/speeches/east-west-rail-autumn-announcement-2025

Incorporate an assessment of the impact of East West Rail on the Eversden and Wimpole Woods SAC in the plan.

Soundness Test 1: Positively Prepared
Requirement
The Plan should be based on a strategy that meets development needs while addressing environmental constraints, including legally protected habitats.
EWR-related concerns
• The proposed development of land north of the A428 at Cambourne is presented as being dependent on East West Rail .
• However, the Habitats Regulations Assessment (HRA) supporting the Local Plan does not assess the impacts of EWR on the Eversden Woods and Wimpole Special Area of Conservation (SAC), despite EWR being integral to the delivery of the strategy.
• This omission is particularly concerning given that the same consultants preparing the HRA for the Local Plan (LUC) have included EWR in HRAs for housing development elsewhere, notably in Oxfordshire.
Why this matters
A Plan that relies on a major infrastructure scheme but fails to assess its impacts on a European protected site cannot be considered positively prepared. The Plan does not demonstrate that environmental constraints have been properly understood or addressed at the strategic level.
Soundness Test 2: Justified
Requirement
The Plan must be based on robust and credible evidence and represent the most appropriate strategy in the light of reasonable alternatives.
EWR-related concerns
• The chosen route (ref 1) would introduce embankments and viaducts between the breeding, roosting and foraging areas of the SAC’s barbastelle bat population.
• Barbastelle bats are highly sensitive to habitat fragmentation. If the railway disrupts movement between roosting and foraging areas, the bats will be unable to feed and the integrity of the SAC would be compromised.
• EWR Co has acknowledged this risk by proposing mitigation measures such as bat bridges and underpasses, supported by extensive survey work. This reflects their legal obligation to demonstrate no adverse effect on the SAC.
• However, published ecological evidence (ref 2) shows that:
o Barbastelle bats use linear features such as hedgerows and tree lines during initial twilight emergence.
o Return flights to roosts are fast, direct and cross open landscapes freely, with little use of linear features.
o Individual bats repeatedly return to their own foraging areas each night.
Why this matters
This behaviour strongly suggests that bats currently cross the line of the proposed railway at numerous locations, not at a small number of predictable points. As a result, limited numbers of green bridges or underpasses are unlikely to provide effective mitigation. The Local Plan contains no evidence demonstrating that the scale, cost or feasibility of mitigation required to avoid harm to the SAC has been properly assessed. Without this evidence, the strategy cannot be considered justified.
Soundness Test 3: Effective
Requirement
The Plan must be deliverable over the Plan period and based on clear, realistic implementation mechanisms.
EWR-related concerns
• Effective mitigation may require extremely extensive measures, potentially including long sections of bat tunnelling or equivalent solutions, with significant cost and engineering implications.
• This is a direct consequence of the chosen EWR alignment and not an unavoidable environmental constraint.
• EWR Co has stated at a meeting with parish councillors on 10 December 2025 that it is not yet ready to discuss SAC impacts (ref 3).
• Despite this, the Local Plan proceeds as though the issue will be resolved in due course.
Why this matters
A Plan that assumes a legally compliant solution will emerge at a later stage, without evidence that such a solution is deliverable, affordable or timely, is not effective. There is a real risk that the issue is deferred until it becomes prohibitively expensive or impossible to resolve without altering the scheme.
Soundness Test 4: Consistent with National Policy
Requirement
The Plan must be consistent with national planning policy, including the strict legal protections afforded to European sites under the Habitats Regulations.
EWR-related concerns
• Both EWR Co and GCSP have a legal obligation to demonstrate, beyond reasonable scientific doubt, that their plans will not adversely affect the integrity of the SAC.
• To date:
o EWR Co has not published its HRA.
o GCSP’s Local Plan HRA excludes the impacts of EWR altogether.
• At the Local Plan launch, GCSP stated that it was waiting for EWR Co’s survey results before addressing the issue.
Why this matters
This passive approach does not meet the requirements of the Habitats Regulations or national policy. The precautionary principle applies: where there is credible evidence of a likely significant effect on a SAC, impacts must be assessed at the plan level, not deferred to a future project stage.
Offer of Engagement
Local naturalists with detailed knowledge of the barbastelle bat population and its behaviour would be willing to engage with GCSP to explain the evidence and implications for plan-making.

References
(1) East West Rail, Non-statutory consultation November 2024
(2) Zeale, Matt R K, et al, 2012, Home range use and habitat selection by barbastelle bats (Barbastella barbastellus): Implications for conservation, Journal of Mammology
(3) Meeting between EWR Co, Pippa Heylings MP and local parish councillors 10 Dec 25

Assess the impact of EWR on the landscape character in South Cambridgeshire and make representations to EWR Co if it fails to meet the requirements of this policy.

1. Policy Context: GP/LC
The Plan is dependent on the EWR project in respect of its proposal to develop approximately 13,500 homes in Cambourne North. Policy GP/LC requires development to:
• Respect and, where possible, enhance the distinctive character and qualities of the landscape;
• Be informed by landscape character assessment (ref 1);
• Avoid significant harm to landscape character, including through scale, massing, landform change and visual intrusion;
• Protect tranquil rural landscapes and long-distance views.
2. Nature of the East West Rail Works
Between Cambourne and Harston, the EWR scheme (ref 2) would involve:
• Extensive deep cuttings and high embankments;
• Viaducts and engineered landforms extending over long distances;
• Permanent alteration of natural landform, field patterns, hedgerows and historic landscape features.
These works would introduce large, linear engineered structures into a predominantly open, low-lying agricultural landscape characterised by gentle topography, long views and a strong sense of rural tranquillity.
3. Impact on Landscape Character
The Parish Council considers that the proposed EWR alignment would:
• Fundamentally alter landform, replacing subtle natural gradients with engineered cuttings and embankments that are alien to the existing landscape character.
• Fragment the landscape, severing historic field patterns, hedgerows and ecological networks.
• Intrude into long-distance views, particularly from public rights of way, villages and elevated ground across south Cambridgeshire.
• Erode rural tranquillity, through both the physical presence of infrastructure and its operational impacts.
• Create a permanent and visually dominant feature that cannot realistically be mitigated through planting or screening within the Plan period.
This scale of intervention goes beyond “mitigation” and represents a wholesale transformation of landscape character, contrary to the intent of Policy GP/LC.
4. Lack of Plan-Level Justification and Assessment
• The Local Plan treats EWR as accepted infrastructure without demonstrating that its landscape impacts are compatible with Policy GP/LC.
• There is no evidence that alternative alignments or less harmful design approaches have been properly assessed at plan level in landscape terms.
• Assertions that harm can be mitigated rely heavily on future planting and earthworks, which will take decades to mature and cannot restore lost landform or historic character.

References
(1) Greater Cambridge Landscape Character Assessment, February 2021
(2) East West Rail, Non-statutory consultation, November 2024

The plan should be delayed, or scaled back, until such time as some critical issues on which it depends are determined.

Soundness Test 1: Positively Prepared
To be sound, a plan must meet objectively assessed needs and align growth with infrastructure. While the plan identifies a need for 48,195 homes and 73,300 jobs , it fails to provide a guaranteed strategy for the infrastructure required to support this scale of growth.
• Uncertainty of Strategy: The plan admits that its programme has been longer than expected due to unresolved issues regarding water supply and transport .
• Infrastructure Misalignment: The NPPF requires growth and infrastructure to be aligned (ref 1). However, the Councils acknowledge "uncertainty" regarding the delivery of the vision for North East Cambridge following the government's withdrawal of funding for the Waste Water Treatment Plant (ref 2) relocation . Proceeding with these allocations despite the lack of a secured alternative funding strategy is not a "positive" approach to planning.

Soundness Test 2: Justified
A justified plan must be the most appropriate strategy based on proportionate evidence. The current evidence base for infrastructure delivery is incomplete and speculative.
• Lack of Costing and Funding Details: The IDP states that "costings, funding streams and delivery bodies are yet to be finalised" for many priority schemes . Key projects, such as the "Public transport improvements for Cambridge," have costs listed as "TBC" .
• Unsubstantiated Estimates: The IDP itself notes that for many projects, it has "not yet been possible to comprehensively map costs," particularly for later phases . A plan cannot be justified if the financial viability of its essential infrastructure relies on "high-level assumptions" rather than concrete commitments .

Soundness Test 3: Effective
The test of effectiveness requires the plan to be deliverable over the plan period. The draft plan is reliant on critical infrastructure that is either beyond the Councils’ control or scheduled too late to support early-phase development.
• Critical Water Scarcity: Delivery is "reliant on the provision of a significant level of infrastructure," specifically water supply . Sustainable supplies from the Fens Reservoir are not expected until 2035–2037, and the Grafham Water pipeline connection is not anticipated until 2032 . The plan’s reliance on "Grampian conditions" to prevent occupation until water is available is an admission that the plan is not currently effective or deliverable in its own right .
• Unresolved Transport Strategy: The Greater Cambridge Transport Strategy, which identifies the mitigation required for the Local Plan, will not even be completed until the end of 2026 . The Councils admit that transport remain a "substantive challenge that needs to be resolved" .
• Wastewater Constraints: Several Water Recycling Centres are already "exceeding the Dry Water Flow condition of their permit," yet the plan lacks a confirmed investment strategy to resolve these constraints following the relocation project’s funding loss .
Soundness Test 4: Consistent with National Policy
The NPPF states that plans should be "aspirational but deliverable" and should not be undermined by a lack of infrastructure.

Haslingfield Parish Council believe the plan is currently unsound as it fails the four tests set out in the National Planning Policy Framework (NPPF) .
• Infrastructure Provision: National policy requires strategic policies to make "sufficient provision" for infrastructure, including energy and water supply . The draft plan fails this by deferring the identification of specific solutions. For example, the Cambridgeshire Local Area Energy Plan—required to address energy demands expected to triple—is still in preparation .
• Effective Joint Working: While the Councils claim to work with stakeholders, the IDP identifies "bottlenecks" in waste transfer capacity and a lack of confirmed primary care space, with the NHS still undertaking "initial exercises" to estimate requirements . This demonstrates that the "effective joint working" required by the NPPF has not yet resulted in a deliverable infrastructure schedule.

References
(1) National Planning Policy Framework, Ministry of Housing, Communities & Local Government, December 2024, §11a
(2) Draft Greater Cambridge Local Plan, §1.33