Draft Greater Cambridge Local Plan for consultation

Include in the policy a requirement
• For applications to include a full assessment of impact on the public realm during construction.
• For developers to repair damage and compensate the Highway Authority for accelerated wear of the public highway.
• Set (in agree with the Highway Authority) a formula for calculating the cost of accelerated wear so that developers can estimate it in advance, and price it in.

As highlighted by the University Arms extension, the recently-approved Christ’s College Library proposals, and the Council’s current Civic Quarter proposals, all significant construction proposals within the historic core may have major impacts on the public realm, space available to the public, and in particular accessibility. These potential impacts should be fully assessed and detailed as part of planning applications.

Section 59 of the Highways Act 1980 gives the Highway Authority powers to recover from a developer the cost of repairing road damage “as may be proved to the satisfaction of the court having cognizance of the case to have been or to be likely to be incurred by the highway authority by reason of the damage arising from the extraordinary traffic.”

This requires the Highway Authority to be in possession of evidence that the damage was caused by the developers’ vehicles. Given the generally poor state of roads now, it cannot be assumed that damage identified after construction starts was caused by construction vehicles. Therefore, all development above a certain scale should be accompanied by pre-commencement planning condition that requires the developer to record the state of roads used by construction vehicles to travel to and from the site.

Section 59 only covers provable damage; it does not cover accelerated wear. The additional long-term maintenance cost (i.e. road or footway resurfacing or rebuilding works having to be scheduled earlier than would otherwise be the case) should also be borne by the developer, rather than the taxpayer.

It would be prudent to include in the Local Plan the principle that developers will contribute towards those increased long-term maintenance costs. The Highway Authority should provide a formula for calculating this based on the total weight of machinery and materials carried on and off site. The developer should be required to record and report this to the Highway Authority, so that it may calculate and invoice the sum on completion of the development.

The allocation should be scaled back in size and ambition.

Policy should restrict development to low rise to reduce impact on landscape.

Policy should mandate that built forms are heavily screened and integrated into the landscape, set amongst significant new tree planting to soften the visual profile against the rising skyline.

Policy to make clear that ancillary development, such as the bridge, is subject to the same policy requirements regarding landscape, heritage and ecology.

Policies must include specific mitigation strategies and funding to manage the impacts of increased recreational activity on the important ecological, heritage and amenity assets on the adjacent Gog Magog Hills – so that they continue to contribute to the quality of life of the wider Cambridge population, which is the vision for the Local Plan.

11 d is revised by relacing 'minimise' with 'avoid' and to take into account Wandlebury and Magog Down by adding 'and other nature and heritage sites : “Ensuring that appropriate measures are implemented to avoid recreational disturbance and pressures on ecology at nearby SSSIs and other nature and heritage sites”.

We note policy 13c but how will the development prevent unofficial access points to the Roman Road being created?

The policy must provide robust evidence on how the development can proceed without further jeopardizing the fragile local water table and the health of these rare chalk stream habitats.

Recommendations regarding transport
Commission detailed modelling of the transport impacts of this development to identify the full suite of transport interventions required to make the development acceptable in planning terms, and to test its viability.

Design supporting bus infrastructure and services to link this development to destinations along the A11 and A505, potentially as far as Royston.

Test the feasibility and viability of this site allocation without CSET, given that scheme is both unfunded and at risk of not securing the order required for its construction.

CPPF is concerned that the scale of this development is wrong and that its size is derived more from the need to meet housing numbers than good planning. On one hand it is too small to be self-sustaining, meaning that it will be a suburb in the countryside and residents will need to travel to meet many of their needs. On the other hand, it is too large to be a village that sits comfortably in its landscape; and its size will place pressures on existing local infrastructure and services. Our view is that it should be scaled back in size and ambition.

This policy presents significant topographical, environmental, and recreational challenges that must be addressed within the policy wording.

Landscape Impact and Built Form
The topography of the Grange Farm site is particularly sensitive, as the land rises relatively sharply from the A1307. We are concerned about the lack of clarity regarding the proposed density and the potential for tall buildings on this elevated ground (for example the inclusion of a last mile distribution centre and taller buildings in the town centre). To avoid a detrimental impact on the wider landscape and the setting of the city, it is essential that any development remains low-rise.
Furthermore, the policy should mandate that built forms are heavily screened and integrated into the landscape, set amongst significant new tree planting to soften the visual profile against the rising skyline.
We are also concerned about the potential negative impacts of the proposed A11 bus/active travel bridge on the landscape north of the A1307 and also the setting of Babraham Village. This infrastructure will require a green belt location. It should be made clear that ancillary development, such as the bridge, is subject to the same policy requirements regarding landscape, heritage and ecology.

Nature/Recreational Pressure on Gog Magog Hills
The impact of 12,000+ new residents on existing local infrastructure is a primary concern. While the policy may include the provision of new open space, such assets take considerable time to mature and become functional for the public and are less attractive than established places nearby. In both the interim and long-term, this development will inevitably place significant pressure on nearby wildlife and heritage sites such as Wandlebury Country Park, where the car park is already operating at capacity during weekends, Magog Down and the Roman Road. Wandlebury and Magog Down are further than 2km from the site and therefore we would like to see policy 11c revised accordingly to ensure they are taken into account. We suggest 11 d is revised to: “Ensuring that appropriate measures are implemented to minimise avoid recreational disturbance and pressures on ecology at nearby SSSIs and other nature and heritage sites”. We note policy 13c but how will the development prevent unofficial access points to the Roman Road being created?
Policies must include specific mitigation strategies and funding to manage the impacts of increased recreational activity on the important ecological, heritage and amenity assets on the adjacent Gog Magog Hills – so that they continue to contribute to the quality of life of the wider Cambridge population, which is the vision for the Local Plan.

Water Stress and Chalk Stream Protection
Finally, we wish to highlight a significant environmental contradiction regarding the site’s sustainability. We understand that a local borehole is currently being shut down specifically to protect the flow and health of the nearby chalk stream (River Granta). Proposing a new settlement in the same location where water abstraction is being actively curtailed for environmental protection appears inconsistent. The policy must provide robust evidence on how the development can proceed without further jeopardizing the fragile local water table and the health of these rare chalk stream habitats.

Transport Infrastructure and viability
The Grange Farm site will require an extension to the CSET busway, which has an estimated cost of £30m (1).

The spatial framework in Figure 81 shows the CSET busway extending north over the A1307 and then east over the A11. This would provide direct access to South Cambridge Business Park and the Cambridge Biomedical Campus, but not any other major local employments sites – Granta Park, Babraham Research Campus, Wellcome Genome Campus, IWM Duxford, the industrial area south of Duxford, Chesterford Research Park.

§13(b) requires improvements to walking and cycling infrastructure to most of these destinations. This will require construction of new paths and bridges over the A11 and A505, at considerable cost. Potential land ownership barriers will also make this challenging. There is no equivalent of a DCO or TWAO to compulsorily acquire complete corridors of land to construct active travel ways.

There will also need to be bus links to destinations along the A11 and A505 because, even with good cycling infrastructure in place, the distances and terrain will not be attractive to most people. For people travelling towards London, a bus connection to Whittlesford Parkway would be more convenient, quicker and cheaper than travelling by bus to Cambridge South station. It may even be quicker to travel to London King’s Cross and St Pancras via a bus to Royston.

§15 states, “Ensure transport and junction modelling is be undertaken to confirm points of vehicular access into the site and the necessary road and junction enhancements required to satisfy the Highways Authority and National Highways.” Transport modelling for this site is essential before it can be confirmed as feasible and viable for allocation.
Such a large site will require major interventions to the A1307, A11 interchange and A505, which will come at a high additional cost to the busway bridge.
The development is likely also to trigger the need for new connections at each end of the A11, to the M11 north and the A14 west, without which the A505 and Wilbraham Road could be overwhelmed.

Currently the funding offered by Homes England to construct the CSET busway is in the form of a loan (“recoverable funding”) (2). There is no identified means for the County Council to repay this loan. If the intention is for the Grange Farm development to cover the entire cost of CSET in addition to funding the extension over the A11 (i.e. £191m in 2025 prices), it would have to contribute, for instance, £30,000 per dwelling plus £300/sq. m. of commercial space. It is likely that this would make the development unviable, even if it could be argued successfully that such a large contribution complied with CIL Regulation 122. To pay for the extension alone would require a contribution of close to £5,000 per dwelling (but this would of course be of very limited use if CSET or some other bus priority scheme into the Biomedical Campus is not built).
Costs for upgrading the A1307 and A11 interchange, and building active travel paths to destinations along the A11 and A505 would be additional to this.

For reference, the Bourn Airfield development has outline planning consent for 3,500 dwellings and commercial space, with a condition requiring delivery of a transport scheme before the 500th occupation, will pay £20m in 2024 prices towards the CtoC busway. That works out at £5,700 per dwelling.

(1) IDP p34, Table 5-1
(2) https://gat04-live-1517c8a4486c41609369c68f30c8-aa81074.divio-media.org/filer_public/be/28/be283c84-a41f-4fcf-a2e2-f7c24db5a3de/cd14-01_letter_from_earmonn_boylan_homes_england_to_peter_blake_gcp__letter_of_support_to_facilitate_cset.pdf

The allocation should be scaled back in size and ambition.

Policy should restrict development to low rise to reduce impact on landscape.

Policy should mandate that built forms are heavily screened and integrated into the landscape, set amongst significant new tree planting to soften the visual profile against the rising skyline.

Policy to make clear that ancillary development, such as the bridge, is subject to the same policy requirements regarding landscape, heritage and ecology.

Policies must include specific mitigation strategies and funding to manage the impacts of increased recreational activity on the important ecological, heritage and amenity assets on the adjacent Gog Magog Hills – so that they continue to contribute to the quality of life of the wider Cambridge population, which is the vision for the Local Plan.

11 d is revised by relacing 'minimise' with 'avoid' and to take into account Wandlebury and Magog Down by adding 'and other nature and heritage sites : “Ensuring that appropriate measures are implemented to avoid recreational disturbance and pressures on ecology at nearby SSSIs and other nature and heritage sites”.

We note policy 13c but how will the development prevent unofficial access points to the Roman Road being created?

The policy must provide robust evidence on how the development can proceed without further jeopardizing the fragile local water table and the health of these rare chalk stream habitats.

Recommendations regarding transport
Commission detailed modelling of the transport impacts of this development to identify the full suite of transport interventions required to make the development acceptable in planning terms, and to test its viability.

Design supporting bus infrastructure and services to link this development to destinations along the A11 and A505, potentially as far as Royston.

Test the feasibility and viability of this site allocation without CSET, given that scheme is both unfunded and at risk of not securing the order required for its construction.

CPPF is concerned that the scale of this development is wrong and that its size is derived more from the need to meet housing numbers than good planning. On one hand it is too small to be self-sustaining, meaning that it will be a suburb in the countryside and residents will need to travel to meet many of their needs. On the other hand, it is too large to be a village that sits comfortably in its landscape; and its size will place pressures on existing local infrastructure and services. Our view is that it should be scaled back in size and ambition.

This policy presents significant topographical, environmental, and recreational challenges that must be addressed within the policy wording.

Landscape Impact and Built Form
The topography of the Grange Farm site is particularly sensitive, as the land rises relatively sharply from the A1307. We are concerned about the lack of clarity regarding the proposed density and the potential for tall buildings on this elevated ground (for example the inclusion of a last mile distribution centre and taller buildings in the town centre). To avoid a detrimental impact on the wider landscape and the setting of the city, it is essential that any development remains low-rise.
Furthermore, the policy should mandate that built forms are heavily screened and integrated into the landscape, set amongst significant new tree planting to soften the visual profile against the rising skyline.
We are also concerned about the potential negative impacts of the proposed A11 bus/active travel bridge on the landscape north of the A1307 and also the setting of Babraham Village. This infrastructure will require a green belt location. It should be made clear that ancillary development, such as the bridge, is subject to the same policy requirements regarding landscape, heritage and ecology.

Nature/Recreational Pressure on Gog Magog Hills
The impact of 12,000+ new residents on existing local infrastructure is a primary concern. While the policy may include the provision of new open space, such assets take considerable time to mature and become functional for the public and are less attractive than established places nearby. In both the interim and long-term, this development will inevitably place significant pressure on nearby wildlife and heritage sites such as Wandlebury Country Park, where the car park is already operating at capacity during weekends, Magog Down and the Roman Road. Wandlebury and Magog Down are further than 2km from the site and therefore we would like to see policy 11c revised accordingly to ensure they are taken into account. We suggest 11 d is revised to: “Ensuring that appropriate measures are implemented to minimise avoid recreational disturbance and pressures on ecology at nearby SSSIs and other nature and heritage sites”. We note policy 13c but how will the development prevent unofficial access points to the Roman Road being created?
Policies must include specific mitigation strategies and funding to manage the impacts of increased recreational activity on the important ecological, heritage and amenity assets on the adjacent Gog Magog Hills – so that they continue to contribute to the quality of life of the wider Cambridge population, which is the vision for the Local Plan.

Water Stress and Chalk Stream Protection
Finally, we wish to highlight a significant environmental contradiction regarding the site’s sustainability. We understand that a local borehole is currently being shut down specifically to protect the flow and health of the nearby chalk stream (River Granta). Proposing a new settlement in the same location where water abstraction is being actively curtailed for environmental protection appears inconsistent. The policy must provide robust evidence on how the development can proceed without further jeopardizing the fragile local water table and the health of these rare chalk stream habitats.

Transport Infrastructure and viability
The Grange Farm site will require an extension to the CSET busway, which has an estimated cost of £30m (1).

The spatial framework in Figure 81 shows the CSET busway extending north over the A1307 and then east over the A11. This would provide direct access to South Cambridge Business Park and the Cambridge Biomedical Campus, but not any other major local employments sites – Granta Park, Babraham Research Campus, Wellcome Genome Campus, IWM Duxford, the industrial area south of Duxford, Chesterford Research Park.

§13(b) requires improvements to walking and cycling infrastructure to most of these destinations. This will require construction of new paths and bridges over the A11 and A505, at considerable cost. Potential land ownership barriers will also make this challenging. There is no equivalent of a DCO or TWAO to compulsorily acquire complete corridors of land to construct active travel ways.

There will also need to be bus links to destinations along the A11 and A505 because, even with good cycling infrastructure in place, the distances and terrain will not be attractive to most people. For people travelling towards London, a bus connection to Whittlesford Parkway would be more convenient, quicker and cheaper than travelling by bus to Cambridge South station. It may even be quicker to travel to London King’s Cross and St Pancras via a bus to Royston.

§15 states, “Ensure transport and junction modelling is be undertaken to confirm points of vehicular access into the site and the necessary road and junction enhancements required to satisfy the Highways Authority and National Highways.” Transport modelling for this site is essential before it can be confirmed as feasible and viable for allocation.
Such a large site will require major interventions to the A1307, A11 interchange and A505, which will come at a high additional cost to the busway bridge.
The development is likely also to trigger the need for new connections at each end of the A11, to the M11 north and the A14 west, without which the A505 and Wilbraham Road could be overwhelmed.

Currently the funding offered by Homes England to construct the CSET busway is in the form of a loan (“recoverable funding”) (2). There is no identified means for the County Council to repay this loan. If the intention is for the Grange Farm development to cover the entire cost of CSET in addition to funding the extension over the A11 (i.e. £191m in 2025 prices), it would have to contribute, for instance, £30,000 per dwelling plus £300/sq. m. of commercial space. It is likely that this would make the development unviable, even if it could be argued successfully that such a large contribution complied with CIL Regulation 122. To pay for the extension alone would require a contribution of close to £5,000 per dwelling (but this would of course be of very limited use if CSET or some other bus priority scheme into the Biomedical Campus is not built).
Costs for upgrading the A1307 and A11 interchange, and building active travel paths to destinations along the A11 and A505 would be additional to this.

For reference, the Bourn Airfield development has outline planning consent for 3,500 dwellings and commercial space, with a condition requiring delivery of a transport scheme before the 500th occupation, will pay £20m in 2024 prices towards the CtoC busway. That works out at £5,700 per dwelling.

(1) IDP p34, Table 5-1
(2) https://gat04-live-1517c8a4486c41609369c68f30c8-aa81074.divio-media.org/filer_public/be/28/be283c84-a41f-4fcf-a2e2-f7c24db5a3de/cd14-01_letter_from_earmonn_boylan_homes_england_to_peter_blake_gcp__letter_of_support_to_facilitate_cset.pdf

The allocation should be scaled back in size and ambition.

Policy should restrict development to low rise to reduce impact on landscape.

Policy should mandate that built forms are heavily screened and integrated into the landscape, set amongst significant new tree planting to soften the visual profile against the rising skyline.

Policy to make clear that ancillary development, such as the bridge, is subject to the same policy requirements regarding landscape, heritage and ecology.

Policies must include specific mitigation strategies and funding to manage the impacts of increased recreational activity on the important ecological, heritage and amenity assets on the adjacent Gog Magog Hills – so that they continue to contribute to the quality of life of the wider Cambridge population, which is the vision for the Local Plan.

11 d is revised by relacing 'minimise' with 'avoid' and to take into account Wandlebury and Magog Down by adding 'and other nature and heritage sites : “Ensuring that appropriate measures are implemented to avoid recreational disturbance and pressures on ecology at nearby SSSIs and other nature and heritage sites”.

We note policy 13c but how will the development prevent unofficial access points to the Roman Road being created?

The policy must provide robust evidence on how the development can proceed without further jeopardizing the fragile local water table and the health of these rare chalk stream habitats.

Recommendations regarding transport
Commission detailed modelling of the transport impacts of this development to identify the full suite of transport interventions required to make the development acceptable in planning terms, and to test its viability.

Design supporting bus infrastructure and services to link this development to destinations along the A11 and A505, potentially as far as Royston.

Test the feasibility and viability of this site allocation without CSET, given that scheme is both unfunded and at risk of not securing the order required for its construction.

CPPF is concerned that the scale of this development is wrong and that its size is derived more from the need to meet housing numbers than good planning. On one hand it is too small to be self-sustaining, meaning that it will be a suburb in the countryside and residents will need to travel to meet many of their needs. On the other hand, it is too large to be a village that sits comfortably in its landscape; and its size will place pressures on existing local infrastructure and services. Our view is that it should be scaled back in size and ambition.

This policy presents significant topographical, environmental, and recreational challenges that must be addressed within the policy wording.

Landscape Impact and Built Form
The topography of the Grange Farm site is particularly sensitive, as the land rises relatively sharply from the A1307. We are concerned about the lack of clarity regarding the proposed density and the potential for tall buildings on this elevated ground (for example the inclusion of a last mile distribution centre and taller buildings in the town centre). To avoid a detrimental impact on the wider landscape and the setting of the city, it is essential that any development remains low-rise.
Furthermore, the policy should mandate that built forms are heavily screened and integrated into the landscape, set amongst significant new tree planting to soften the visual profile against the rising skyline.
We are also concerned about the potential negative impacts of the proposed A11 bus/active travel bridge on the landscape north of the A1307 and also the setting of Babraham Village. This infrastructure will require a green belt location. It should be made clear that ancillary development, such as the bridge, is subject to the same policy requirements regarding landscape, heritage and ecology.

Nature/Recreational Pressure on Gog Magog Hills
The impact of 12,000+ new residents on existing local infrastructure is a primary concern. While the policy may include the provision of new open space, such assets take considerable time to mature and become functional for the public and are less attractive than established places nearby. In both the interim and long-term, this development will inevitably place significant pressure on nearby wildlife and heritage sites such as Wandlebury Country Park, where the car park is already operating at capacity during weekends, Magog Down and the Roman Road. Wandlebury and Magog Down are further than 2km from the site and therefore we would like to see policy 11c revised accordingly to ensure they are taken into account. We suggest 11 d is revised to: “Ensuring that appropriate measures are implemented to minimise avoid recreational disturbance and pressures on ecology at nearby SSSIs and other nature and heritage sites”. We note policy 13c but how will the development prevent unofficial access points to the Roman Road being created?
Policies must include specific mitigation strategies and funding to manage the impacts of increased recreational activity on the important ecological, heritage and amenity assets on the adjacent Gog Magog Hills – so that they continue to contribute to the quality of life of the wider Cambridge population, which is the vision for the Local Plan.

Water Stress and Chalk Stream Protection
Finally, we wish to highlight a significant environmental contradiction regarding the site’s sustainability. We understand that a local borehole is currently being shut down specifically to protect the flow and health of the nearby chalk stream (River Granta). Proposing a new settlement in the same location where water abstraction is being actively curtailed for environmental protection appears inconsistent. The policy must provide robust evidence on how the development can proceed without further jeopardizing the fragile local water table and the health of these rare chalk stream habitats.

Transport Infrastructure and viability
The Grange Farm site will require an extension to the CSET busway, which has an estimated cost of £30m (1).

The spatial framework in Figure 81 shows the CSET busway extending north over the A1307 and then east over the A11. This would provide direct access to South Cambridge Business Park and the Cambridge Biomedical Campus, but not any other major local employments sites – Granta Park, Babraham Research Campus, Wellcome Genome Campus, IWM Duxford, the industrial area south of Duxford, Chesterford Research Park.

§13(b) requires improvements to walking and cycling infrastructure to most of these destinations. This will require construction of new paths and bridges over the A11 and A505, at considerable cost. Potential land ownership barriers will also make this challenging. There is no equivalent of a DCO or TWAO to compulsorily acquire complete corridors of land to construct active travel ways.

There will also need to be bus links to destinations along the A11 and A505 because, even with good cycling infrastructure in place, the distances and terrain will not be attractive to most people. For people travelling towards London, a bus connection to Whittlesford Parkway would be more convenient, quicker and cheaper than travelling by bus to Cambridge South station. It may even be quicker to travel to London King’s Cross and St Pancras via a bus to Royston.

§15 states, “Ensure transport and junction modelling is be undertaken to confirm points of vehicular access into the site and the necessary road and junction enhancements required to satisfy the Highways Authority and National Highways.” Transport modelling for this site is essential before it can be confirmed as feasible and viable for allocation.
Such a large site will require major interventions to the A1307, A11 interchange and A505, which will come at a high additional cost to the busway bridge.
The development is likely also to trigger the need for new connections at each end of the A11, to the M11 north and the A14 west, without which the A505 and Wilbraham Road could be overwhelmed.

Currently the funding offered by Homes England to construct the CSET busway is in the form of a loan (“recoverable funding”) (2). There is no identified means for the County Council to repay this loan. If the intention is for the Grange Farm development to cover the entire cost of CSET in addition to funding the extension over the A11 (i.e. £191m in 2025 prices), it would have to contribute, for instance, £30,000 per dwelling plus £300/sq. m. of commercial space. It is likely that this would make the development unviable, even if it could be argued successfully that such a large contribution complied with CIL Regulation 122. To pay for the extension alone would require a contribution of close to £5,000 per dwelling (but this would of course be of very limited use if CSET or some other bus priority scheme into the Biomedical Campus is not built).
Costs for upgrading the A1307 and A11 interchange, and building active travel paths to destinations along the A11 and A505 would be additional to this.

For reference, the Bourn Airfield development has outline planning consent for 3,500 dwellings and commercial space, with a condition requiring delivery of a transport scheme before the 500th occupation, will pay £20m in 2024 prices towards the CtoC busway. That works out at £5,700 per dwelling.

(1) IDP p34, Table 5-1
(2) https://gat04-live-1517c8a4486c41609369c68f30c8-aa81074.divio-media.org/filer_public/be/28/be283c84-a41f-4fcf-a2e2-f7c24db5a3de/cd14-01_letter_from_earmonn_boylan_homes_england_to_peter_blake_gcp__letter_of_support_to_facilitate_cset.pdf

Part 2 of the policy needs to be coordinated with the transport strategy for Cambridge.
Additional policy added: 1g: Protect and enhance any heritage assets and their setting.
Include within the policy a requirement that any development over a certain size to be mixed use to help meet the city’s housing need.

Policies 1b and 2 and highlights how this draft Local Plan is not co-ordinated with transport planning. The transport strategy for Cambridge (as pursued by the councils and GCP) is for bus-based travel, with a reliance on Park & Ride. For this strategy to work, buses need to be able to travel relatively quickly and reliably. One of the factors that reduces speed and reliability is traffic being held at crossings. This is why the Elizabeth Way roundabout has a subway and why a subway was created for the Chisholm Trail. At the same time, we have several new developments along the same stretch of Newmarket Road that are potentially introducing new at-grade crossings. The approach is confused. Either we have bus priority and introduce subways and bridges, or we don’t have a bus-based strategy?

We are concerned that this policy does not include any reference to heritage (which is why we believe that a Historic Environment Strategy is required as part of the Local Plan). We would like to see an additional policy added: 1g: Protect and enhance any heritage assets and their setting.

There has been massive frustration in Cambridge (including from the Council) that the redevelopment of the Beehive will not involve a residential element. This area of Cambridge is perfect for new residential development and one of the few remaining places in the city that has potential to meet the city’s housing need. The reason that the city was not able to persuade the developer to bring forward a mixed-use development at the Beehive was because there was no policy hook to do so. Please do not repeat that mistake and include a policy which requires any development over a certain size to be mixed use to help meet the city’s housing need.

Part 2 of the policy needs to be coordinated with the transport strategy for Cambridge.
Additional policy added: 1g: Protect and enhance any heritage assets and their setting.
Include within the policy a requirement that any development over a certain size to be mixed use to help meet the city’s housing need.

Policies 1b and 2 and highlights how this draft Local Plan is not co-ordinated with transport planning. The transport strategy for Cambridge (as pursued by the councils and GCP) is for bus-based travel, with a reliance on Park & Ride. For this strategy to work, buses need to be able to travel relatively quickly and reliably. One of the factors that reduces speed and reliability is traffic being held at crossings. This is why the Elizabeth Way roundabout has a subway and why a subway was created for the Chisholm Trail. At the same time, we have several new developments along the same stretch of Newmarket Road that are potentially introducing new at-grade crossings. The approach is confused. Either we have bus priority and introduce subways and bridges, or we don’t have a bus-based strategy?

We are concerned that this policy does not include any reference to heritage (which is why we believe that a Historic Environment Strategy is required as part of the Local Plan). We would like to see an additional policy added: 1g: Protect and enhance any heritage assets and their setting.

There has been massive frustration in Cambridge (including from the Council) that the redevelopment of the Beehive will not involve a residential element. This area of Cambridge is perfect for new residential development and one of the few remaining places in the city that has potential to meet the city’s housing need. The reason that the city was not able to persuade the developer to bring forward a mixed-use development at the Beehive was because there was no policy hook to do so. Please do not repeat that mistake and include a policy which requires any development over a certain size to be mixed use to help meet the city’s housing need.

Part 2 of the policy needs to be coordinated with the transport strategy for Cambridge.
Additional policy added: 1g: Protect and enhance any heritage assets and their setting.
Include within the policy a requirement that any development over a certain size to be mixed use to help meet the city’s housing need.

Policies 1b and 2 and highlights how this draft Local Plan is not co-ordinated with transport planning. The transport strategy for Cambridge (as pursued by the councils and GCP) is for bus-based travel, with a reliance on Park & Ride. For this strategy to work, buses need to be able to travel relatively quickly and reliably. One of the factors that reduces speed and reliability is traffic being held at crossings. This is why the Elizabeth Way roundabout has a subway and why a subway was created for the Chisholm Trail. At the same time, we have several new developments along the same stretch of Newmarket Road that are potentially introducing new at-grade crossings. The approach is confused. Either we have bus priority and introduce subways and bridges, or we don’t have a bus-based strategy?

We are concerned that this policy does not include any reference to heritage (which is why we believe that a Historic Environment Strategy is required as part of the Local Plan). We would like to see an additional policy added: 1g: Protect and enhance any heritage assets and their setting.

There has been massive frustration in Cambridge (including from the Council) that the redevelopment of the Beehive will not involve a residential element. This area of Cambridge is perfect for new residential development and one of the few remaining places in the city that has potential to meet the city’s housing need. The reason that the city was not able to persuade the developer to bring forward a mixed-use development at the Beehive was because there was no policy hook to do so. Please do not repeat that mistake and include a policy which requires any development over a certain size to be mixed use to help meet the city’s housing need.

Policy to include similar residential occupancy condition as that of Policy S/WGC.

Amend point 6 to replace 'should' with 'must' : "Gardens surrounding the Grade I Church and Grade II* Babraham Hall must be excluded from development."
Amend point 9 by adding "including views for the higher land to the north from the Gog Magog Hills and Roman Road," between '...wider landscape character' and 'whilst creating ...'
Figure 94/Site plan should identify area of Strategic Enhancement Area

Amend policy to deliver deliver traffic management and bus priority measures on the A1307 to ensure that travel by bus to the Campus from either direction is as convenient and reliable as possible.
a) A busway between the Cambridge Biomedical Campus and the Hinton Way roundabout via the proposed south-easterly expansion
a) A bus lane (if and when needed) along the A1307 westbound to Hinton Way roundabout
b) Signals controls and lead-in bus lanes at the Babraham Research Park access roundabout
c) Priority measures at the A11 interchange or a new bus and active travel bridge over the A11, linking the A1307 and Newmarket Road

To safeguard the dwellings for campus workers, a residential occupancy condition needs to be applied similar to that of policy S/WGC Wellcome Genome Campus.
The policy needs to be strengthened to protect heritage assets and Gog Magog landscape.
The Babraham Research Campus’s expansion, any development on Grange Farm and improved access to Granta Park can all be achieved with more targeted, lower cost interventions:
a) A busway between the Cambridge Biomedical Campus and the Hinton Way roundabout via the proposed south-easterly expansion
a) A bus lane (if and when needed) along the A1307 westbound to Hinton Way roundabout
b) Signals controls and lead-in bus lanes at the Babraham Research Park access roundabout
c) Priority measures at the A11 interchange or a new bus and active travel bridge over the A11, linking the A1307 and Newmarket Road
The policy needs to deliver traffic management and bus priority measures on the A1307 to ensure that travel by bus to the Campus from either direction is as convenient and reliable as possible.

Policy to include similar residential occupancy condition as that of Policy S/WGC.

Amend point 6 to replace 'should' with 'must' : "Gardens surrounding the Grade I Church and Grade II* Babraham Hall must be excluded from development."
Amend point 9 by adding "including views for the higher land to the north from the Gog Magog Hills and Roman Road," between '...wider landscape character' and 'whilst creating ...'
Figure 94/Site plan should identify area of Strategic Enhancement Area

Amend policy to deliver deliver traffic management and bus priority measures on the A1307 to ensure that travel by bus to the Campus from either direction is as convenient and reliable as possible.
a) A busway between the Cambridge Biomedical Campus and the Hinton Way roundabout via the proposed south-easterly expansion
a) A bus lane (if and when needed) along the A1307 westbound to Hinton Way roundabout
b) Signals controls and lead-in bus lanes at the Babraham Research Park access roundabout
c) Priority measures at the A11 interchange or a new bus and active travel bridge over the A11, linking the A1307 and Newmarket Road

To safeguard the dwellings for campus workers, a residential occupancy condition needs to be applied similar to that of policy S/WGC Wellcome Genome Campus.
The policy needs to be strengthened to protect heritage assets and Gog Magog landscape.
The Babraham Research Campus’s expansion, any development on Grange Farm and improved access to Granta Park can all be achieved with more targeted, lower cost interventions:
a) A busway between the Cambridge Biomedical Campus and the Hinton Way roundabout via the proposed south-easterly expansion
a) A bus lane (if and when needed) along the A1307 westbound to Hinton Way roundabout
b) Signals controls and lead-in bus lanes at the Babraham Research Park access roundabout
c) Priority measures at the A11 interchange or a new bus and active travel bridge over the A11, linking the A1307 and Newmarket Road
The policy needs to deliver traffic management and bus priority measures on the A1307 to ensure that travel by bus to the Campus from either direction is as convenient and reliable as possible.

Supporting Information needs to refer to Cambridge Biomedical Campus SPD.
Policy needs to require the masterplan to be updated.
Consider restricting development to those uses where it is essential to be onsite.
Amend policy to direct housing development to sites not needed for biomedical purposes.
Heavily scrutinise and sensitivity-test forecasts for modal shares for transport to/from the CBC. Test all routes onto and through the Campus for adequate capacity for all modes, recognising that there will be large cohorts of people walking and cycling to and from Cambridge South station.
Revisit the options for providing bus priority between the Babraham P&R and the Biomedical Campus to also accommodate buses arriving on the A1307 from Haverhill via the Babraham Research Park.

Land use
CPPF recognise the local, national and international importance of this site and consider that the public benefits arising from the clinical and research investment justify the release of Green Belt land. However, CPPF would challenge further boundary creep every time the Local Plan is reviewed.
The Cambridge Biomedical Campus SPD was adopted in April 2025 and therefore is relevant and should be referred to in the supporting information.
There should be a requirement to update the existing master plan for the entire site to demonstrate where redevelopment opportunities exist so housing and other uses can be accommodated and make efficient use of land, including within the hospital site or outmoded hospital residential accommodation. The masterplan should also identify locations for strategic landscaping to mitigate the impact of large buildings on the open landscape and Gog Magog Hills.
CPPF is concerned that the limited land available for the CBC is not given up for uses which could be provided elsewhere in the Cambridge area, leading to future proposals for further CBC expansion into the Green Belt and Gog Magog Hills in this sensitive location.

CPPF are concerned that residential development will result in the loss of land for biomedical development resulting in the need to release more land from the Green Belt. Residential accommodation must only be built on land which is not suitable for other purposes. If the residential development is to be provided in high rise blocks, they need to be located in areas suitable for tall buildings.
Suggest amending point 8d to include “in locations where the land is not suitable for health and life sciences, commercial and innovation floorspace.’
The housing should be restricted to key worker housing.

Context
CPPF strongly supports policies 14a, b and c.

Built Form
CPPF strongly supports policies 16d, e, f and g.

Nature & Green Space
We welcome the significant greenspace habitat creation being proposed by the policy but believe there could be a different approach taken to development and green space on the south-east boundary of Cambridge, which could deliver even better outcomes for nature and people. We refer you to the response made by the Wildlife Trust BCN and the potential for an enabling development which could better deliver the ambitions of the Cambridge Nature Network by extending new green space and habitat creation from Nine Wells, northeastwards to Cherry Hinton Chalk Pits. We would welcome the opportunity to discuss this in more detail with officers, where we can also show plans of potential locations for extended green space/habitats and active travel improvements.
In designing the mitigation strategy and planning new habitats, it is important to use the significant data available on red listed farmland birds which use the area south of the Campus. These birds are of high conservation concern because changes to the farmed environment have led to rapid and significant population declines. New habitats should be suitable replacement habitat, such as meadows, and should include areas with no public access to support ground-nesting birds. Or alternatively, mitigation will need to be off-site areas of nature friendly arable farming with a secure long-term future.

Transport
The Transport Strategy (Appendix A) indicates that, by 2050, the number of daily trips to the CBC will reach 93,874 , almost double the number in 2023 (48,096). (CBC Transport Strategy Appendix A Table 4).
This is a staggering level of growth in the context of poor provision for walking onto or around the CBC site, slow and convoluted access for buses, inadequate cycle parking, and persistently severe congestion on Babraham/Hills Road, Hauxton Road and Addenbrooke’s Road. It is essential that the strategy for accommodating this growth is scrutinised for realism and robustness, in particular with respect to the mode-shares by train and bus, which will have to absorb most of the growth in trips.
The technical note on the proposed realignment of Granham’s Road (Realignment of Granham’s Road page 8) is unclear on precisely what options have been tested, and some of the claimed advantages of the Do Something option do not stand up to scrutiny (e.g. that the Do Something provides a “better integrated and connected CBC and P&R” than the Do Maximum, which provides a “physically direct connection”).
Consideration needs to be given to services arriving on the A1307 from Haverhill and the Babraham Research Campus. Even with CSET2 built, the most direct route between the Biomedical Campus and the Babraham Research Campus will be via the A1307. The advantage afforded by a continuous inbound bus lane and/or separate busway from at least the Hinton Way roundabout could be significant.