Draft Greater Cambridge Local Plan for consultation

Expanding on the previous questions which are constraining in only allowing "Yes" or "No".

Do you consider the plan to be sound? The National Planning Policy Framework requires a transport scheme that supports the housing plan. We believe that EWR does not - please see details in attached documents.

Does the plan comply with the duty to cooperate? We believe that GCSP needs to collaborate with EWR.

This response critiques the Rail Integration Study for Cambourne's expansion. It highlights that adding 13,500 houses would triple trip demand, yet EWR's own 2023 data shows only 3% of Cambridge commuters would use the railway – remaining 97% would drive. The plan lacks quantitative evidence that roads won't exceed capacity. While EWR's business case claims credit for 25,000 new houses, it only serves 3% of commuters. The response argues GCSP must prove rail mode share can reach nearly 100% to avoid overwhelming the road network, warning that ideology-driven planning may fail commercially, citing poor Northstowe sales as a cautionary example.

Expanding on the previous questions which are constraining in only allowing "Yes" or "No".

Do you consider the plan to be sound? The National Planning Policy Framework requires a transport scheme that supports the housing plan. We believe that EWR does not - please see details in attached documents.

Does the plan comply with the duty to cooperate? We believe that GCSP needs to collaborate with EWR.

This response to a local plan consultation challenges the proposed Cambourne expansion linked to East West Rail (EWR). Key concerns include: the County Council's Transport Evidence Report shows only 1% of trips from extended Cambourne would go to Cambridge Biomedical Campus, contradicting EWR's justification for the route; despite £8 billion costs, EWR would contribute minimally to Cambridge's economic growth; the development of 13,500 houses appears viable without EWR; and there's insufficient justification for linking the housing development to the railway project, potentially wasting public funds through lack of accountability between planning authorities and EWR Company.

Expanding on the previous questions which are constraining in only allowing "Yes" or "No".

Do you consider the plan to be legally compliant? We believe the Local Plan fails to comply with the Habitats Regulations 2017 - please see details in attached document.

Do you consider the plan to be sound? We have no opinion on this question.

Does the plan comply with the duty to cooperate? We believe that GCSP should be working with EWR rather than devolving responsibility for a transport scheme that the Local Plan depends on.

The Local Plan fails to comply with the Habitats Regulations 2017 and UK law in that the HRA for Eversden and Wimpole Woods SAC does not list or consider all the relevant development proposals which, in combination and cumulatively with those in the GCLP, pose threats which may adversely affect the integrity of the SAC and its CSZ. Major infrastructure transport plans and projects are serious omissions, including EWR which alone could extinguish the SAC’s Barbastelle bats. We consider that the HRA undertaken by LUC for the GCLP is lacking in the evidence necessary to inform a robust Appropriate Assessment.

Expanding on the previous questions which are constraining in only allowing "Yes" or "No".

Do you consider the plan to be legally compliant? We believe the Local Plan fails to comply with the Habitats Regulations 2017 - please see details in attached document.

Do you consider the plan to be sound? We have no opinion on this question.

Does the plan comply with the duty to cooperate? We believe that GCSP should be working with EWR rather than devolving responsibility for a transport scheme that the Local Plan depends on.

The Local Plan fails to comply with the Habitats Regulations 2017 and UK law in that the HRA for Eversden and Wimpole Woods SAC does not list or consider all the relevant development proposals which, in combination and cumulatively with those in the GCLP, pose threats which may adversely affect the integrity of the SAC and its CSZ. Major infrastructure transport plans and projects are serious omissions, including EWR which alone could extinguish the SAC’s Barbastelle bats. We consider that the HRA undertaken by LUC for the GCLP is lacking in the evidence necessary to inform a robust Appropriate Assessment.

Expanding on the previous questions which are constraining in only allowing "Yes" or "No".

Do you consider the plan to be sound? We believe the Local Plan presents a high-growth strategy without meeting the soundness tests for infrastructure delivery mandated by the National Planning Policy Framework.

Does the plan comply with the duty to cooperate? We believe the Local Plan does not have a supporting plan from other bodies - please see details in attached document.

GCSP’s Local Plan says its overarching objective is sustainable development, targeting to add 73,300 jobs and 48,195 homes by 2045 – equivalent to a second Cambridge City next to the existing one. GC is under serious water stress now, it is urgent to provide new water infrastructure (but none anticipated before 2032) and reduce current demand (how effective are proposed measures). With uncertainties, risks, lack of control over timing, costs and deliverables we believe the LP’s water plan is not sustainable. We are similarly concerned on transport, wastewater, energy, healthcare, and on significant additional growth pressure from Government and CGC.