Greater Cambridge Local Plan: Proposed Submission

BHS requests that Policy S/RRA/SHF and its supporting requirements be modified to:

Protect and enhance the existing PROW and wider countryside-access network through and around the site, including Bridleways 151/10, 151/15 and 168/9, maintaining their legal status, continuity, usability, rural character and recreational function.
Provide dedicated Active Travel infrastructure necessary to serve the scale and nature of the development, rather than relying on existing rural bridleways to perform the functions of development-related Active Travel infrastructure.
Ensure that improvements to existing bridleways do not unnecessarily urbanise or hard-surface established rural routes where a rural surface remains suitable.
Require equestrians to be considered from the earliest stage of route planning and design. Where Active Travel provision can safely accommodate equestrian use, it should do so unless a relevant site-specific physical, environmental, legal or safety constraint provides a clear and evidenced reason for exclusion.
Where equestrian use is excluded, require the relevant constraint and the consequences of that exclusion, including consequences for equestrian safety on the highway network and for the safety and connectivity of the wider PROW and countryside-access network, to be identified and evidenced.
Protect and enhance the wider countryside-access network, including opportunities for new and improved links, circular routes and safe connections to surrounding settlements and the countryside.
Secure a site-wide Public Rights of Way, Equestrian Access and Green Infrastructure Strategy as part of the first planning application, addressing existing and proposed routes, legal status, lawful users, enhancements, wider connections, phasing, funding and long-term management, including opportunities for equestrian and, where appropriate, carriage-driving connectivity.

The British Horse Society
Greater Cambridge Local Plan – Regulation 19
Policy S/RRA/SHF: Land north of A1307, Bar Hill (Slate Hall Farm)
Representation: Support with Modification
Soundness tests: Positively prepared; Justified; Effective; Consistent with national policy
1. Introduction
The British Horse Society (BHS) makes no comment on the principle or merits of the proposed allocation. This representation is concerned solely with the provision, protection and enhancement of public rights of way and countryside access associated with the allocation.
The site contains, and is closely connected to, an established network of rural public rights of way, including Bridleways 151/10, 151/15 and 168/9. These routes should be considered as an interconnected countryside-access and recreational network rather than as isolated routes or simply as components of the development's walking and cycling infrastructure.
The BHS considers that the policy should be modified so that the development protects and enhances the existing natural and rural rights-of-way network, provides appropriate new Active Travel infrastructure, and positively considers equestrian inclusion where new infrastructure can safely and practicably accommodate it.
2. Existing policy – positive but insufficient
Policy S/RRA/SHF contains useful provisions concerning active travel, green infrastructure, landscape, masterplanning, transport mitigation and infrastructure delivery. In particular, the policy requires the usability of the bridleways through and around the site to be maintained.
BHS welcomes these provisions. However, maintaining usability is not the same as protecting and enhancing the wider Public Rights of Way network. The policy does not adequately safeguard the established rural and recreational character of the bridleways, distinguish them from development-related Active Travel infrastructure, or require the development to make a positive contribution to the wider countryside-access network.
The policy should therefore be strengthened before adoption.
3. Protecting and enhancing the existing rural rights-of-way network
The interconnected bridleway network around the site provides an important countryside-access and recreational network for its lawful users. Bridleway 151/10 is particularly important because it connects the A1307 with the wider network towards Longstanton. Bridleways 168/9 and 151/15 connect into this network.
The Cambridge 25 planning application confirms that the tree-lined 151/10 bridleway passes through the site and that the surrounding area remains predominantly rural in character. The development will generate substantial new demand for walking, cycling and other forms of active travel.
An existing rural bridleway should not be treated as spare capacity within the Active Travel network. The development should provide the infrastructure required to serve its new demand rather than relying upon the progressive urbanisation of established rural rights of way.
Policy S/RRA/SHF should therefore require existing bridleways to be protected not only in terms of legal continuity and physical usability, but also in terms of their rural character, recreational function and suitability for their lawful users.
4. Wilson's Road – an important local lesson
The experience of Wilson's Road provides an important local lesson for the allocation. The bridleway has been severed by the Southern Access Road West (SARW) into Northstowe. The section between the SARW bridge and Bar Hill was subsequently hard surfaced. Since that intervention, this section has deteriorated significantly: vegetation has encroached, usable width has been lost and the urbanised tarmac surface has not been maintained adequately.
In contrast, the section between the SARW bridge and Longstanton has retained its natural surface and rural character and continues to provide a valuable green countryside-access corridor. Strong local and stakeholder opposition was an important factor in retaining that natural-surface character.
The contrasting condition and character of the two sections demonstrate that simply applying a sealed surface to an established rural bridleway does not necessarily enhance its usefulness or recreational value. They also demonstrate why the Local Plan should distinguish between enhancing an established rural Public Right of Way and providing new infrastructure to meet the Active Travel requirements of major development.
Local concern about Wilson's Road has involved a wide range of interests, including the BHS, Swavesey & District Bridleways Association, Longstanton Parish Council, Swavesey Parish Council, Westwick Parish Council, Oakington & Westwick Environmental Group and the Ramblers. The Definitive Map team has also raised matters requiring further information concerning the bridleway.
This provides a strong local evidence base for protecting the rural character and recreational function of established rights of way and for ensuring that new development-related Active Travel infrastructure is provided separately where required.
5. Active Travel and equestrian inclusion
Active Travel infrastructure and the Public Rights of Way and wider countryside-access network have different but complementary functions. The designation of infrastructure as Active Travel should not, in itself, result in the exclusion of equestrians where equestrian use could safely and appropriately be accommodated.
Active Travel infrastructure and the Public Rights of Way/countryside-access network have different but complementary functions. This distinction should not, however, result in equestrians being excluded from new infrastructure by default.
Equestrians should be considered from the earliest stage of route planning and design. Where Active Travel provision can safely accommodate equestrian use, it should do so unless a relevant site-specific physical, environmental, legal or safety constraint provides a clear and evidenced reason for exclusion. Where equestrian use is excluded, the relevant physical, environmental, legal or safety constraint and the consequences of that exclusion should be identified and evidenced, including consequences for equestrian safety on the highway network and for the safety and connectivity of the wider PROW and countryside-access network.
This does not mean that every Active Travel route must accommodate equestrians. It means that exclusion should not arise simply from a general assumption that highway-related or Active Travel infrastructure is unsuitable for equestrian use.
The A1307 provides an important local example of new Active Travel/highway infrastructure alongside a busy road being designed to accommodate pedestrians, cyclists and equestrians. The existing signed multi-user route alongside the A1307 and its equestrian facilities demonstrate that equestrian access can be incorporated into new infrastructure through positive design. BHS does not rely on this route as an example of a recorded bridleway; the relevant planning lesson is its multi-user function.
6. A14 mitigation – positive planning precedent
The A14 mitigation programme provides a further local precedent for integrating major highway infrastructure with the Public Rights of Way network. The programme has included provision and regularisation of routes with bridleway and restricted byway status and demonstrates that major highway infrastructure can be accompanied by improvements to the wider countryside-access network.
This is relevant to S/RRA/SHF because the site is located immediately alongside the A1307 and within a landscape significantly influenced by major transport infrastructure. The appropriate response to highway safety and connectivity constraints should therefore be positive design and appropriate new infrastructure, rather than an assumption that equestrians must be excluded.
7. Enhancement required by the new national policy context
NPPF paragraph 105 (December 2024) states that planning policies and decisions should protect and enhance public rights of way and access, including opportunities to provide better facilities for users. The policy should therefore provide an effective local framework for protecting and enhancing the established rural PROW network and considering appropriate new connections.
The present requirement in S/RRA/SHF to maintain the usability of existing bridleways does not fully capture this strengthened national approach. The scale of the proposed development provides an opportunity to do more than avoid harm. It should make a positive contribution to the wider countryside-access network.
This should include consideration of:
improvements to existing bridleways;
new links where these can safely and practicably be provided;
connections to surrounding villages and the wider countryside;
opportunities for circular recreational routes;
safe crossings of roads and other infrastructure;
appropriate legal status for any new public rights;
protection of rural character and appropriate rural surfaces; and
continuity of access during construction and through subsequent phases.
The objective should be a net enhancement of the natural and rural rights-of-way network rather than simply retaining existing routes in their present condition.
8. Development-related infrastructure, phasing and delivery
The Local Plan evidence identifies active travel improvements along Bridleway 151/10 as essential infrastructure. BHS considers that this wording should not be relied upon to justify the conversion of the existing rural bridleway into a principal urban Active Travel route.
The policy should instead make clear that:
the development must provide appropriate dedicated Active Travel infrastructure required by its scale and nature;
existing rural bridleways should not be relied upon to perform functions for which new development-related Active Travel infrastructure is required;
any improvement to an existing bridleway must protect its legal status, lawful users, rural character and recreational function;
new countryside-access infrastructure must be properly phased with development;
legal status, land ownership, funding, maintenance and long-term management must be secured; and
opportunities to enhance the wider rights-of-way network should be identified at masterplanning stage rather than left to individual reserved-matters applications.
9. Proposed modification
BHS requests that Policy S/RRA/SHF is modified to strengthen the existing movement and countryside-access requirements as follows:
Protect and enhance the existing countryside-access network
“Protect and enhance the existing public rights of way and countryside-access network through and around the site, including Bridleways 151/10, 151/15 and 168/9. Maintain their legal status, continuity, usability, rural character and recreational function for their lawful users. Development-related improvements must not unnecessarily urbanise or hard-surface established rural bridleways where a rural surface remains suitable.”
Provide appropriate new infrastructure
“Provide dedicated Active Travel infrastructure necessary to serve the scale and nature of the development, rather than relying on existing rural bridleways to perform the functions of new development-related Active Travel infrastructure.”
Equestrian consideration
“Equestrians should be considered from the earliest stage of route planning and design. Where Active Travel provision can safely accommodate equestrian use, it should do so unless a relevant site-specific physical, environmental, legal or safety constraint provides a clear and evidenced reason for exclusion. Where equestrian use is excluded, the relevant physical, environmental, legal or safety constraint and the consequences of that exclusion should be identified and evidenced, including consequences for equestrian safety on the highway network and for the safety and connectivity of the wider PROW and countryside-access network.”
Network enhancement
“Protect and enhance the existing Public Rights of Way and wider countryside-access network and take opportunities to extend, link and improve existing routes, including new direct and circular routes and safe connections to surrounding settlements and the countryside, consistent with NPPF paragraph 105 (December 2024).”
Masterplanning and delivery
“Secure a site-wide Public Rights of Way, Equestrian Access and Green Infrastructure Strategy as part of the first planning application, identifying existing and proposed routes, their legal status and intended lawful users, proposed enhancements, opportunities for equestrian and, where appropriate, carriage-driving connectivity, connections to the wider network, phasing, funding and long-term maintenance and management arrangements.”
10. Soundness
BHS considers that Policy S/RRA/SHF is broadly positively prepared and justified, but requires modification to be sufficiently effective in relation to countryside access. The existing requirement to maintain the usability of bridleways is positive, but does not provide a sufficiently comprehensive framework for enhancement of the wider network, early consideration of horse riders, or the relationship between established rural PROWs and new development-related Active Travel infrastructure.
In particular, the current policy does not adequately:
implement the December 2024 NPPF requirement to protect and enhance the Public Rights of Way network and access;
distinguish the established recreational function of rural bridleways from development-related Active Travel infrastructure;
secure enhancement of the wider countryside-access network;
ensure that equestrian use is considered positively in new infrastructure; or
prevent unnecessary urbanisation of established rural routes.
The requested modifications are proportionate to the scale and location of the allocation and are necessary to ensure that the policy provides a clear and effective framework for its delivery.
11. Conclusion
BHS requests that Policy S/RRA/SHF is modified as set out above.
The site provides an opportunity to demonstrate how major employment development, Active Travel infrastructure, green infrastructure and the rural Public Rights of Way network can be planned together.
Local experience at Wilson's Road demonstrates the consequences of treating an established rural bridleway as an alternative to providing appropriate new Active Travel infrastructure. The contrast between the deteriorated hard-surfaced section towards Bar Hill and the retained natural-surface green corridor towards Longstanton is particularly instructive.
Conversely, the A1307 provides a local example of new infrastructure alongside a busy highway accommodating pedestrians, cyclists and equestrians through positive design. The A14 mitigation programme provides further evidence that major transport infrastructure can be planned alongside improvements to the Public Rights of Way network.
The Local Plan should therefore require S/RRA/SHF to do more than maintain existing bridleways. It should require the development to protect and enhance the natural and rural rights-of-way network, provide appropriate new Active Travel infrastructure, and apply the early-stage equestrian consideration set out above to new and improved infrastructure, with site-specific evidence where equestrian use is not proposed.

The BHS requests that Policy S/RSC/BRC and its supporting text be modified to:

Retain and clarify criterion 19(a), including its explicit requirement for equestrian routes, and require the site-wide Masterplan to identify safe connections between the Campus, existing PROW/countryside-access network and the proposed CSET Travel Hub, should CSET proceed.
Safeguard the wider countryside-access network, including opportunities associated with Footpaths 12/5 and 12/11 and a potential connection towards Byway 12/3 and the Roman Road network, subject to necessary permissions and safe crossings.
Support additional countryside-access provision, including permissive routes and recreational loops, with new routes designed to accommodate the widest practicable range of relevant lawful users where this can safely and reasonably be achieved. Where carriage-driving rights are intended, the legal status and physical design should reflect those rights.
Distinguish the PROW/countryside-access network from Active Travel, while requiring equestrians to be considered from the earliest stage of route planning and design. Where Active Travel infrastructure can safely accommodate equestrians, it should do so unless a clear, site-specific and evidenced reason for exclusion exists. The consequences of exclusion, including highway safety and wider network connectivity, should also be assessed.
Secure delivery, with the Masterplan and Infrastructure Delivery Strategy identifying land, responsibilities, funding, phasing and appropriate delivery triggers. The policy should not assume that wider strategic connectivity will be resolved through CSET or the Linton Greenway

The British Horse Society
Greater Cambridge Local Plan – Regulation 19
Policy S/RSC/BRC – Babraham Research Campus
Soundness tests: Positively prepared; Justified; Effective; Consistent with national policy
Representation: Support with Modification

1. Introduction
The British Horse Society (BHS) supports the explicit recognition of equestrian routes in criterion 19(a), and the policy’s objective of improving connections to nearby villages, railway stations and the proposed Cambridge South East Transport (CSET) travel hub. This representation addresses only Public Rights of Way (PROW), wider countryside access and equestrian connectivity; it does not comment on whether the allocation itself should proceed.
2. Retain and clarify the equestrian commitment
Criterion 19(a) is welcomed and should be retained. It requires improvements to pedestrian, cycle and equestrian routes connecting to nearby villages, railway stations and the proposed CSET Travel Hub. If CSET proceeds, the Travel Hub will be an important strategic destination for the surrounding countryside-access network, including potential connections from Grange Farm. However, the current CSET proposal does not provide an equestrian route all the way to the Travel Hub: the proposed bridleway runs from Granham’s Road in Great Shelford to High Street, Babraham, where it terminates.
The BRC policy should therefore ensure that the site-wide Masterplan identifies how equestrians can connect from the existing PROW and wider countryside-access network to the equestrian connection associated with the proposed Travel Hub, should CSET proceed. This should not be assumed to be provided by CSET.
3. The existing A1307 crossing and the connectivity gap
BRC has already funded an equestrian signalised crossing at its A1307 roundabout. However, there is currently no onward equestrian-accessible route from that crossing on either side of the A1307, in either direction. The withdrawal of equestrian provision from the CBC–Babraham section of the Linton Greenway has therefore left the crossing as an isolated facility rather than part of a connected equestrian network.
The BHS does not consider it proportionate to require BRC to fund a replacement A1307 crossing simply because equestrian provision has been withdrawn from the Linton Greenway. The appropriate Local Plan requirement is for the Masterplan to identify and safeguard alternative safe and practicable connections. Any necessary infrastructure and funding should then be considered through the appropriate transport and planning mechanisms.
4. Opportunities through and around the Campus
Babraham footpath 12/5 appears to offer an opportunity for a useful local countryside-access link, subject to its legal status and landownership position. The Masterplan should identify and safeguard this opportunity where it can be provided appropriately.
Babraham footpath 12/11 is potentially more significant strategically. It exits north towards the A1307, opposite Babraham Byway 12/3. Subject to the legal and landownership position and provision of a safe A1307 crossing, this could provide a potential connection from the Campus towards the Roman Road and wider countryside-access network. It should therefore be identified and safeguarded as an opportunity, rather than being lost through development.
The BHS also supports the creation of additional countryside-access routes which BRC may wish to provide, including permissive routes, recreational loops and other connections within the Strategic Enhancement Area, where compatible with the landscape, ecological and heritage requirements of the site. New routes should be designed to accommodate the widest practicable range of relevant lawful users where this can be achieved safely and reasonably, with their legal status and physical design reflecting their intended use. Where carriage-driving rights are intended, the route’s legal status and physical design should reflect those rights.
5. Network connectivity and delivery
The policy already requires a site-wide Masterplan and strategic and local transport mitigation plan. These provide the appropriate mechanisms to identify existing rights, lawful users, missing links, crossings and connections to the wider countryside. The Masterplan should distinguish the PROW and wider countryside-access network from the Active Travel network, while considering the relationship between the two to achieve safe and coherent connectivity. The fact that infrastructure is classified as Active Travel should not, in itself, result in the exclusion of equestrians where equestrian use could safely and appropriately be accommodated. Equestrians should be considered from the earliest stage of route planning and design. Where Active Travel provision can safely accommodate equestrian use, it should do so unless a relevant site-specific physical, environmental, legal or safety constraint provides a clear and evidenced reason for exclusion. Where equestrian use is excluded, the relevant physical, environmental, legal or safety constraint and the consequences of that exclusion should be identified and evidenced, including consequences for equestrian safety on the highway network and for the safety and connectivity of the wider PROW and countryside-access network.
Where new or improved countryside-access routes are proposed, the nature of the route should reflect its function and rural setting. An ‘improvement’ should not automatically mean a sealed urban-style surface where a rural or firm-natural surface would better serve the route and its users.
6. Soundness
The BHS considers that Policy S/RSC/BRC is broadly positively prepared and justified, but requires modification to be sufficiently effective in relation to PROW, wider countryside access and equestrian connectivity. Criterion 19(a) provides a positive basis for equestrian inclusion, but the policy should ensure that the commitment is translated into safe, connected and deliverable infrastructure through the Masterplan and transport mitigation arrangements. The requested modifications would also strengthen the policy’s consistency with NPPF paragraph 105 (December 2024), which requires planning policies and decisions to protect and enhance public rights of way and access, including opportunities to provide better facilities for users.
Proposed modification
A. Retain and clarify criterion 19(a). Retain the explicit requirement for equestrian routes connecting to nearby villages, railway stations and the proposed CSET Travel Hub. Require the site-wide Masterplan to identify safe and appropriate routes by which equestrians can reach the relevant CSET/Travel Hub connection from the existing PROW and wider countryside-access network, should CSET proceed.
B. Safeguard the countryside-access network. Require the Masterplan to identify existing PROWs and other countryside-access routes, their lawful users, missing links and opportunities for new or enhanced connections within and around the Campus, including consideration of Footpaths 12/5 and 12/11 and the potential connection towards Byway 12/3 and the Roman Road network, subject to identification of practicable crossings and other necessary permissions.
C. Support additional countryside access. Support the creation of additional countryside-access routes, including permissive routes and recreational loops, where these can be provided compatibly with the landscape, ecological and heritage requirements of the site. New routes should accommodate the widest practicable range of relevant lawful users where this can be achieved safely and reasonably, and where carriage-driving rights are intended their legal status and physical design should reflect those rights.
D. Active Travel and equestrian safety. Require the Masterplan and strategic and local transport mitigation plan to consider equestrians from the earliest stage of route planning and design. Where Active Travel provision can safely accommodate equestrian use, it should do so unless a relevant site-specific physical, environmental, legal or safety constraint provides a clear and evidenced reason for exclusion. Where equestrian use is excluded, require the relevant physical, environmental, legal or safety constraint and the consequences of that exclusion to be identified and evidenced, including consequences for equestrian safety on the highway network and for the safety and connectivity of the wider PROW and countryside-access network.
E. Secure delivery. Require the Masterplan and Infrastructure Delivery Strategy/transport mitigation arrangements to identify land, responsibilities, funding mechanisms, phasing and appropriate triggers for delivery of the identified countryside-access connections. The policy should not assume that wider strategic connectivity issues will be resolved by CSET or the Linton Greenway.
Conclusion
The BHS supports Policy S/RSC/BRC with modification. The explicit inclusion of equestrian routes in criterion 19(a) is welcomed and should be retained. The policy should, however, ensure that this commitment results in a safe, connected and deliverable network rather than isolated facilities. In particular, the Masterplan should identify how the Campus can connect into the wider equestrian and countryside-access network, safeguard opportunities associated with Babraham Footpaths 12/5 and 12/11, and support additional countryside-access routes that BRC may wish to create. It should also ensure that Active Travel proposals properly consider equestrian safety and the consequences of exclusion, including potential consequences for highway safety and wider PROW and countryside-access connectivity.

The BHS requests that Policy S/WNT and its supporting text should:

Require the two landownership parcels forming Waterbeach New Town to be planned, phased and delivered as one connected countryside-access network, coordinated with the wider movement network.
Safeguard and deliver the outstanding recreational, country-park and proposed equestrian connections as integral parts of that network.
Address the River Cam as a strategic connectivity barrier and safeguard the opportunity for any replacement or refurbished bridge to provide an inclusive NMU crossing accommodating pedestrians, cyclists and equestrians, where physically, technically and legally feasible.
Protect the continuity and safety of existing countryside access, including Bannold Drove, in the design and delivery of the relocated railway station and associated infrastructure.
Require Active Travel and permissive routes to consider equestrian inclusion from the outset, with any exclusion supported by a clear, site-specific and evidence-based justification, including consideration of the consequences for equestrian safety and wider network connectivity.
Ensure Mere Way is delivered and managed in accordance with its legal status and lawful users, rather than treating cycle infrastructure as a substitute for existing byway rights.
Secure the network through appropriate phasing, funding, land requirements, legal arrangements, delivery triggers and long-term stewardship, so that countryside-access provision keeps pace with development.

The British Horse Society
Greater Cambridge Local Plan – Regulation 19
Policy S/WNT: Waterbeach New Town
Soundness tests: Positively prepared; Justified; Effective; Consistent with national policy
Representation: Support with Modification
1. A coordinated countryside-access network
The British Horse Society (BHS) supports the continued allocation of Waterbeach New Town and recognises the substantial progress already made in identifying and delivering countryside-access and equestrian provision within the Urban & Civic part of the site.
The principal concern is the connectivity between the two landownership parcels. Policy S/WNT correctly requires a coordinated and comprehensive approach to delivery and states that collaborative working must continue through construction and long-term stewardship. This principle should apply equally to the countryside-access and equestrian network.
The Local Plan should ensure that the two parcels are planned and delivered as one connected network, rather than allowing good provision within one parcel to become disconnected from unresolved provision within the other.
2. Existing and proposed equestrian provision
The BHS welcomes the equestrian and wider NMU provision already identified within the Urban & Civic development. The issue is not therefore a lack of provision across the whole allocation, but whether that provision can connect safely and conveniently to the wider countryside-access network.
There remains considerably less certainty about the detailed countryside-access provision on the eastern part of the allocation. The outstanding recreational and country-park provision and the proposed equestrian connection should be identified as strategic elements of the overall network and safeguarded through the masterplanning and delivery process.
Policy S/WNT already requires a multifunctional Strategic Enhancement Area providing sports, recreation, ecological and wellbeing functions and requires it to be planned and delivered in a coordinated manner. The countryside-access network should be treated as an integral part of that coordinated provision.
3. River Cam – a strategic connectivity barrier
The River Cam is a major physical barrier to east-west connectivity. There are currently no proposals for a separate equestrian crossing; the proposals concern replacement or refurbishment of the existing bridge. The opportunity should therefore be safeguarded through the Local Plan for the replacement or refurbished structure to provide an inclusive non-motorised-user crossing capable of accommodating pedestrians, cyclists and equestrians, wherever physically, technically and legally feasible.
This is a strategic matter which should be addressed through the Local Plan rather than left to individual reserved-matters applications. The replacement or refurbished bridge should be assessed as an opportunity to provide an inclusive connection for the widest practicable range of relevant non-motorised users. A crossing serving only pedestrians and cyclists would not provide an equivalent connection for equestrians and would leave a gap in the wider countryside-access network.
Where carriage-driving rights are intended, the route’s legal status and physical design should reflect those rights. Where the replacement or refurbished bridge and associated countryside-access infrastructure could appropriately accommodate carriage drivers, this opportunity should be considered at the planning and design stage.
4. Bannolds Road, Bannold Drove and the relocated railway station
The relocated railway station and associated infrastructure create an important point at which the existing countryside-access network must be protected and safely integrated.
Policy S/WNT specifically identifies Bannold Drove as a key historical feature to be retained and enhanced. The existing byway should therefore be considered as part of the movement and countryside-access network, not simply as a landscape feature. The Plan should ensure that the relocated railway station and associated infrastructure protect the continuity and safety of lawful countryside-access users, including equestrians.
Where infrastructure changes the way lawful equestrian users reach or negotiate an existing route, the assessment should consider where those users will travel instead and whether the resulting arrangement increases interaction with motor traffic, cyclists or other users. The objective should be to avoid transferring risk to users who are excluded from a new facility or prejudicing the continuity of safe countryside access.
5. Active Travel / permissive routes
The Plan should not allow a pedestrian/cycle permissive route to be treated as an equivalent replacement for an existing or proposed route carrying equestrian rights.
An existing permissive cycleway runs alongside the River Cam towards Waterbeach. The route is an example of landowner-supported access contributing to the wider network. There is no evidence available to BHS that equestrian use was considered or included when the permissive access arrangement was established. BHS does not seek to attribute responsibility for that decision without evidence, but considers that future planning of the Waterbeach network should recognise the opportunity to provide more inclusive access where practicable.
Where a particular user group is excluded from a permissive route, the relevant physical, environmental, legal or safety constraint and the consequences of that exclusion should be identified and evidenced. The fact that a route is permissive should not, in itself, be treated as a reason why potentially suitable opportunities for inclusive access need not be considered.
This principle should also apply where permissive routes contribute to the strategic countryside-access network. A permissive route does not create a public right of access for users not included by the landowner, and BHS does not suggest otherwise. However, where existing or proposed permissive routes contribute to development-related countryside connectivity, opportunities for inclusive access should be considered at the planning and design stage, including equestrian use where this can safely and practically be accommodated.
Where equestrian use is excluded, the relevant physical, environmental, legal or safety constraint and the consequences of that exclusion should be identified and evidenced, including consequences for equestrian safety on the highway network and for the safety and connectivity of the wider PROW and countryside-access network.
Equestrians should be considered from the earliest stage of route planning and design. Where Active Travel provision can safely accommodate equestrian use, it should do so unless a relevant site-specific physical, environmental, legal or safety constraint provides a clear and evidenced reason for exclusion.
Active Travel infrastructure and the PROW/wider countryside-access network have different but complementary functions. Classification as Active Travel should not itself exclude equestrians where equestrian use could safely and appropriately be accommodated.
6. Mere Way – delivery and lawful users
Mere Way is an existing public byway and an important part of the wider countryside-access network. The S106 provision associated with Waterbeach provides for an NMU route incorporating a cycle path. The BHS's concern is that the intended NMU provision has not been delivered in a form which properly secures the needs of all relevant lawful users.
The existing rural byway has been substantially altered by the provision of a wide tarmac surface associated with the Waterbeach development. This has changed the character and function of the route and has not, in itself, resolved the needs of equestrians or carriage drivers.
The BHS considers that Mere Way demonstrates why delivery of a route described as an NMU connection must be assessed against its actual legal status, lawful users, physical design, safety and practical usability. The Local Plan should not assume that a route has been satisfactorily delivered simply because an NMU/cycle connection is shown in the development framework. Any proposals affecting Mere Way should respect its existing legal status and lawful users and should not result in a deterioration in its safety, usability or countryside character.
The BHS is not seeking through S/WNT to resolve the wider countywide issue of byways affected by TROs or physical barriers which restrict lawful carriage-driving access. However, Waterbeach should not perpetuate that problem by treating cycle infrastructure as an adequate substitute for the existing rights of a byway.
7. Phasing, funding and long-term stewardship
The scale and complexity of Waterbeach make coordinated delivery particularly important. Policy S/WNT already requires infrastructure to be phased with development, identifies financial contributions and enabling measures, and requires mechanisms for delivery, monitoring and review and long-term stewardship.
These provisions should expressly encompass the countryside-access and equestrian network. The Council should ensure that one landownership parcel cannot progress in a way which prevents or prejudices delivery of connections within the other parcel, and that strategic crossings and external connections are secured before dependent development is brought forward. The strategy should identify route alignments, land requirements, legal status, funding, delivery mechanisms, delivery triggers, necessary crossings and long-term management arrangements.
The network should also be secured through appropriate funding, delivery triggers and long-term management arrangements, rather than relying on unresolved matters being addressed at a later stage.
Proposed modification
• secure appropriate phasing, funding, delivery triggers, land requirements, legal arrangements and long-term stewardship for the complete countryside-access network.
• protect the rural character and appropriate rural surfaces of existing countryside routes, recognising that a sealed urban-style surface should not automatically be regarded as an improvement to a rural PROW; and
• where carriage-driving rights are intended, ensure that the relevant route has appropriate legal status and physical design, and consider opportunities to accommodate carriage drivers within new countryside-access infrastructure where appropriate;
• ensure that the Mere Way NMU/S106 provision is assessed and delivered in accordance with the actual legal status and lawful users of the route and is not treated as a cycle-only or pedestrian/cycle substitute;
• ensure that Active Travel routes are assessed for equestrian inclusion from the outset, with exclusion requiring a clear, site-specific and evidence-based justification and consideration of the consequences for equestrian safety and wider network connectivity;
• assess and resolve the effect of the relocated railway station and associated infrastructure on Bannold Drove and the safety and continuity of countryside access, including equestrian access;
• where a user group is excluded from a permissive route, identify and evidence the relevant constraint and the consequences for safety and the continuity and connectivity of the wider countryside-access network;
• ensure that existing and proposed permissive routes which contribute to development-related countryside connectivity are considered for inclusive access at the planning and design stage, including equestrian use where this can safely and practically be accommodated;
• address the River Cam as a strategic barrier to countryside-access connectivity and safeguard the opportunity for the replacement or refurbished bridge to provide an inclusive non-motorised-user crossing accommodating pedestrians, cyclists and equestrians, where physically, technically and legally feasible;
• give effect to Policy 20 by securing connected and safe measures for equestrians, particularly within the Strategic Enhancement Area and open spaces forming part of the Active Travel network;
• safeguard and deliver the outstanding recreational/country-park and proposed equestrian connections;
• coordinate countryside-access provision between the two landownership parcels and ensure that provision is delivered as one connected network;
• identify existing and proposed equestrian connections, network gaps and points of severance;
• identify existing and proposed PROWs, their legal status and lawful users;
• Plan, phase and deliver the two landownership parcels forming Waterbeach New Town as one connected countryside-access network, coordinated with the wider movement network.
Conclusion
The BHS supports Policy S/WNT with modification.

Waterbeach provides a significant opportunity to demonstrate how a major new settlement can integrate Active Travel, public rights of way, recreational access and equestrian connectivity. Some of the necessary provision is already being established within the Urban & Civic part of the site.

The critical issue is to ensure that this provision does not become an isolated network within one landownership parcel. The Local Plan should secure the wider access to and connections between the two parcels and address the strategic barriers and unresolved delivery issues, particularly the River Cam, Bannolds Road/Bannold Drove and Mere Way.

This is necessary to ensure that the Plan is effective and deliverable and that the substantial investment already being made in Waterbeach produces a genuinely connected countryside-access network rather than a series of disconnected routes.

The BHS requests that Policy I/ST and its supporting evidence be modified to:

Make clear that Active Travel and the wider PROW and countryside-access network are distinct but complementary networks, with different functions, legal statuses, lawful users and design requirements.
Require equestrian needs to be considered from the earliest stage of planning and design. Where an Active Travel route forms part of a connection serving the wider PROW and countryside-access network, equestrian use should be accommodated where this can be achieved safely and reasonably, unless a relevant site-specific physical, environmental, legal or safety constraint is identified and evidenced.
Require the consequences of excluding equestrians to be assessed, including consequences for equestrian safety, the safety of other highway users, route continuity and wider countryside-access connectivity.
Require relevant PROWs, their legal status and lawful users, important crossings, missing links and external connections to be identified and safeguarded through transport and development planning.
Ensure that transport interventions do not transfer or increase safety risks between lawful user groups, including where cyclists use infrastructure alongside horses remaining on the carriageway.
Ensure that existing rural PROWs are improved according to their legal status, function, character and lawful users, without an assumption that Active Travel connectivity requires urban-style or sealed surfacing.
Where carriage-driving rights are intended, ensure that the appropriate legal status and physical design are secured from the outset.

The British Horse Society
Greater Cambridge Local Plan – Regulation 19
Policy I/ST – Sustainable Transport and Connectivity
Supplementary Representation: Topic Papers / Evidence Base
This is a supplementary representation to the BHS representation already submitted on Policy I/ST. It does not replace or withdraw that representation.
1. Purpose of this supplementary representation
The British Horse Society has already submitted a substantive representation on Policy I/ST – Sustainable Transport and Connectivity. This supplementary representation places on the Examination record the specific evidence-base issues identified through the BHS review of the current Regulation 19 Topic Papers, particularly the Greater Cambridge Local Plan: Infrastructure Topic Paper (2026), with related evidence from the Site Allocations Topic Paper (2026) and Biodiversity and Green Spaces Topic Paper (2026).
The purpose is not to repeat the BHS's existing I/ST representation, but to identify why the supporting evidence should be strengthened so that Policy I/ST can be justified and implemented effectively in relation to the wider PROW and countryside-access network and equestrian users. The supplementary request is therefore intended to reinforce the evidence base for the same policy approach, not to introduce a different test or threshold for equestrian inclusion.
2. Infrastructure Topic Paper – evidence supporting I/ST
The Infrastructure Topic Paper recognises sustainable and active travel and records amendments to I/ST concerning new and improved opportunities for recreational and leisure movement, safety and inclusivity for all road users, and joined-up routes and networks. The BHS supports this direction.
However, the evidence does not consistently explain the relationship between the Active Travel network and the wider PROW and countryside-access network. These are distinct but complementary networks, with different functions, legal statuses, lawful users and design considerations. The evidence should make that relationship explicit.
In particular, the evidence should establish and support the position already advanced in the BHS I/ST representation: the needs of horse riders should be considered at the earliest stage of planning and designing Active Travel routes. Where a proposed Active Travel route forms part of a connection serving the wider PROW and countryside-access network, equestrian use should be accommodated where this can be achieved safely and reasonably, unless a relevant site-specific physical, environmental, legal or safety constraint is identified and evidenced.
Where equestrian use is not proposed, the relevant site-specific physical, environmental, legal or safety constraint and the consequences of that exclusion should be identified and evidenced, including consequences for equestrian safety on the highway network and for the safety and connectivity of the wider PROW and countryside-access network. A walking/cycling-only route may improve provision for some users while leaving equestrians on the highway or requiring a longer or less direct alternative.
3. Highway safety evidence
The consequences of exclusion are relevant to the effectiveness of I/ST. The current Highway Code identifies horse riders among road users most at risk from road traffic. Rule 63 gives specific advice to cyclists sharing space with horse riders and horse-drawn vehicles, including that cyclists should not pass a horse on its left. Rule 204 identifies horse riders among road users most at risk from road traffic. These provisions are relevant when considering whether excluding equestrians from an off-road connection transfers risk to the highway network.
From an equestrian safety perspective, passing a horse on the inside can present a particular risk because horses are accustomed to traffic approaching and passing on their outside. A cyclist passing on the inside may therefore startle a horse even where the cyclist has attempted to make their presence known. The potential safety consequence is not confined to the horse and rider. If a horse is startled by a cyclist passing on the inside while the horse remains on the carriageway, the horse may react by moving or changing direction towards the traffic flow. This can create a secondary risk for other highway users, including the possibility of a collision or evasive manoeuvre involving motor vehicles or other road users. This is an equestrian safety explanation of the practical implications and is distinct from the Highway Code wording.
The evidence supporting I/ST should therefore identify, where equestrian use is excluded, where those users would travel instead and assess the resulting safety and connectivity consequences. A transport or safety intervention should not simply transfer or increase risk to another group of lawful users.
4. Relationship with the wider evidence base
The Site Allocations Topic Paper contains some references to PROWs, rural lanes and green lanes, but does not consistently identify their legal status, lawful users, equestrian function, network gaps or the consequences of strategic infrastructure and development for continuity of the wider countryside-access network. The BHS considers that relevant allocation evidence should address these matters proportionately where they are material.
The Biodiversity and Green Spaces Topic Paper provides substantial evidence on green infrastructure, access to nature, accessible greenspace, ecological networks, recreational importance and long-term management. The BHS considers that the wider countryside-access network, including equestrian access, should also be recognised where it forms a multifunctional component of green infrastructure.
These matters reinforce the need for I/ST to recognise the relationship between Active Travel investment and the wider countryside-access network, without treating the two networks as interchangeable.
5. Proposed modification to the evidence supporting I/ST
The BHS requests that the evidence supporting Policy I/ST be amended or clarified to:
• recognise the PROW and wider countryside-access network as a distinct but complementary network alongside Active Travel;
• identify equestrian use as a lawful and material consideration in relevant transport evidence;
• require equestrians to be considered from the earliest stage of route planning and design;
• where a proposed Active Travel route forms part of a connection serving the wider PROW and countryside-access network, require equestrian use to be accommodated where this can be achieved safely and reasonably, unless a relevant site-specific physical, environmental, legal or safety constraint is identified and evidenced;
• where equestrian use is excluded, identify the reason for exclusion and assess the consequences for equestrian safety, the safety of other highway users, and wider PROW/countryside-access connectivity, including the potential for increased interaction between horses, cyclists and motor traffic;
• identify relevant existing and proposed routes, legal status, lawful users, network gaps, significant crossings, external connections and delivery dependencies where these are material to I/ST; and
• ensure that implementation of I/ST does not inadvertently transfer or increase safety or connectivity problems for another group of lawful users.
6. Conclusion
The BHS continues to support the overall direction of Policy I/ST as set out in its substantive representation. This supplementary representation identifies a specific evidence-base issue arising from the current Regulation 19 Topic Papers.
The requested changes are proportionate. The BHS is not seeking to require every Active Travel route to accommodate equestrians, nor a new comprehensive technical study for every scheme. The requirement is that equestrian use, the wider PROW and countryside-access network, and the consequences of exclusion are properly considered where relevant, with evidence-based reasons for exclusion.
The BHS therefore asks the Council and Examination to consider this supplementary evidence alongside the BHS's existing Policy I/ST representation and to make any necessary modifications or clarifications to the supporting evidence so that I/ST is properly justified and capable of effective implementation.
Source documents
This supplementary representation has been prepared with reference to the following current Regulation 19 evidence documents:
• Greater Cambridge Local Plan: Infrastructure Topic Paper (2026)
• Greater Cambridge Local Plan: Site Allocations Topic Paper (2026)
• Greater Cambridge Local Plan: Biodiversity and Green Spaces Topic Paper (2026)
It also refers to the current GOV.UK version of The Highway Code, including Rules 63 and 204, updated 22 October 2025.

The BHS requests that Policy BG/GI and/or its supporting text and evidence be strengthened to make clear that:

Green Infrastructure Plans should identify relevant existing and proposed PROWs and wider countryside-access routes, including their legal status and lawful users.
Where relevant, they should identify equestrian connections, missing links, severance, crossings and external connections, and opportunities to strengthen connections between development, settlements and the wider countryside.
Equestrian needs should be considered from the earliest stage of planning and design. Where equestrian use is excluded, the relevant site-specific constraint and the consequences for equestrian safety and wider network connectivity should be identified and evidenced.
Where carriage-driving rights are intended, the legal status and physical design of the route should reflect those rights.
The recreational function and rural character of existing rural PROWs should be recognised; sealed urban-style surfacing should not automatically be treated as an improvement where an appropriate rural surface is suitable for the lawful users and purposes of the route.
The delivery, phasing and long-term management of relevant countryside-access routes should be addressed alongside other green infrastructure, so that important connections are secured as part of development rather than deferred or lost through later phases.

The British Horse Society
Greater Cambridge Local Plan – Regulation 19
Policy BG/GI – Green Infrastructure
Supplementary Representation: Topic Papers / Evidence Base
1. Purpose
This is a supplementary representation to the BHS representation already submitted on Policy BG/GI. It does not replace or withdraw that representation. It addresses the evidence supporting BG/GI, particularly the 2026 Biodiversity and Green Spaces Topic Paper, and explains why the evidence should be strengthened to support the modifications already sought by the BHS.
The BHS's original representation supports the overall direction of BG/GI but seeks clearer recognition of the existing and proposed Public Rights of Way (PROW) and wider countryside-access network as a component of multifunctional green infrastructure. It asks that Green Infrastructure Plans identify relevant routes, their legal status and lawful users, equestrian connections, missing links, severance, crossings, connections to the wider countryside and opportunities for enhancement and new provision.
2. Relevance of the Biodiversity and Green Spaces Topic Paper
The 2026 Biodiversity and Green Spaces Topic Paper provides substantial evidence concerning green infrastructure, access to nature, accessible greenspace, ecological networks, recreational importance and long-term management of green infrastructure. The BHS welcomes this evidence and the recognition of green infrastructure as a multifunctional and connected network.
However, the evidence does not sufficiently carry that multifunctional approach through to the wider countryside-access network. In particular, it does not consistently recognise equestrian access, the lawful users and legal status of individual routes, or the need to consider countryside access as a connected network. This creates a gap between the policy objective of multifunctional, connected green infrastructure and the evidence available to support its implementation.
The Topic Papers evidence therefore supports, rather than replaces, the modifications sought in the BHS's substantive BG/GI representation. The evidence should provide a clear basis for applying the policy to green corridors and other strategic green infrastructure which also forms, or could form, part of the wider countryside-access network.
3. Green infrastructure and the countryside-access network
Where green infrastructure includes routes and corridors used by people, the evidence should recognise that these may perform functions beyond walking and cycling. Existing and proposed countryside-access routes can form part of a multifunctional green infrastructure network and can provide recreational, health and wellbeing benefits as well as connections between settlements and the wider countryside.
The BHS therefore considers that relevant Green Infrastructure Plans should identify existing PROWs and their legal status and lawful users at an early stage. Where routes carry equestrian rights, those rights and the route's function should be recognised. The evidence should also identify relevant missing links, severance, crossings and external connections so that green infrastructure is planned as a functioning network rather than as a series of visually connected but potentially disconnected spaces.
This is consistent with the evidence-base concerns identified by the BHS in its review of the 2026 Topic Papers: major development should be considered in terms of the wider countryside-access network, including opportunities for outward connections and the infrastructure, land, phasing and delivery arrangements necessary to secure those connections.
4. Inclusive access and equestrian consideration
The Topic Paper should more clearly support the policy requirement for green infrastructure to be multifunctional and accessible by recognising lawful equestrian use where relevant. Equestrians should be considered from the earliest stage of planning and design. Where a proposed green corridor or countryside-access connection can accommodate equestrian use, it should be considered before a more restrictive walking/cycling-only solution is adopted.
Where equestrian use is excluded, the relevant site-specific physical, environmental, legal or safety constraint should be identified and evidenced, together with the consequences for equestrian safety and the connectivity of the wider PROW and countryside-access network. This does not require every green corridor to accommodate every form of non-motorised use; it requires the potential for inclusive countryside access to be properly considered before a more restrictive route is adopted.
Where carriage-driving rights are intended, these should be treated separately from horse-riding provision. The legal status and physical design of the route should reflect the rights intended to be provided. A bridleway should not be treated as providing carriage-driving rights, and a walking/cycling or footpath connection should not be treated as an equivalent replacement for a route carrying higher lawful rights.
5. Rural character and surfacing
The Topic Paper also provides an opportunity to recognise that multifunctional green infrastructure does not necessarily require urban-style infrastructure. Where an existing rural PROW forms part of the green infrastructure network, its recreational and landscape function and rural character should be respected. A sealed urban-style surface should not automatically be regarded as an improvement where a natural or appropriate rural surface is suitable for the lawful users and purposes of the route.
6. Delivery and long-term management
The BHS welcomes the Topic Paper's consideration of the long-term management of green infrastructure. The same approach should apply to the countryside-access component of green infrastructure. Where relevant routes are identified within Green Infrastructure Plans, the evidence should demonstrate how they will be protected, connected, delivered, appropriately phased and maintained for their intended function and lawful users.
For strategic development, this should include consideration of the relationship between countryside-access provision and the phasing of development. Connectivity should not be left to later phases where earlier development could create barriers or severance. Where new green infrastructure is intended to contribute to the wider countryside-access network, the evidence should identify the land, infrastructure, funding and delivery dependencies necessary to secure the connection.
7. Proposed modification
The BHS requests that Policy BG/GI and/or its supporting text, together with the supporting Biodiversity and Green Spaces evidence, be strengthened to make clear that:
• Green Infrastructure Plans should identify relevant existing and proposed PROWs and wider countryside-access routes, including their legal status and lawful users, where these are affected by or form part of the green infrastructure network;
• where relevant, Green Infrastructure Plans should identify equestrian connections, missing links, severance, crossings, external connections and opportunities to strengthen connectivity between development, settlements and the wider countryside;
• the needs of horse riders should be considered from the earliest stage of planning and designing relevant green infrastructure and countryside-access provision; where equestrian use is excluded, the relevant site-specific constraint and the consequences for equestrian safety and wider network connectivity should be identified and evidenced;
• where carriage-driving rights are intended, the legal status and physical design of the route should reflect those rights;
• the recreational function and rural character of existing rural PROWs should be recognised, and sealed urban-style surfacing should not be assumed to be an improvement where an appropriate rural surface is suitable for the lawful users and purposes of the route; and
• the delivery, phasing and long-term management of relevant countryside-access routes should be addressed alongside other green infrastructure so that connections are secured as part of the development rather than deferred or lost through later phases.
8. Conclusion
The BHS supports the overall direction of Policy BG/GI and its emphasis on multifunctional, connected and well-managed green infrastructure. The 2026 Biodiversity and Green Spaces Topic Paper provides relevant supporting evidence but does not sufficiently recognise the wider PROW and countryside-access network, including equestrian access, as a component of that multifunctional network.
The BHS therefore maintains the modifications sought in its substantive BG/GI representation and requests that the supporting evidence and policy implementation framework be strengthened accordingly. The purpose is not to require every green corridor to accommodate every type of user, but to ensure that relevant countryside-access functions, lawful users, connectivity, safety and delivery requirements are considered and evidenced at the appropriate stage of planning.
Source document: Greater Cambridge Local Plan: Biodiversity and Green Spaces Topic Paper (2026), together with the BHS substantive Regulation 19 representation on Policy BG/GI and the BHS Regulation 19 Topic Papers / Evidence Base representation.

Policy S/NST should require the existing Public Rights of Way and wider countryside-access network to be protected and enhanced, including its legal status, continuity, rural character and recreational function. Active Travel and countryside-access networks should be planned as distinct but complementary networks. Equestrian use should be considered from the earliest stage where new Active Travel, green-corridor or other movement infrastructure forms part of, or connects to, the wider countryside-access network and should be included where reasonably practicable unless a clear, site-specific and evidenced reason for exclusion is established. New countryside-access routes should accommodate the widest practicable range of relevant lawful users, including horse riding, and green corridors should be multifunctional. Existing rural bridleways, including the remaining natural-surface section of Wilson's Road, should not be unnecessarily hard surfaced or urbanised. The policy should secure these requirements through all phases of Northstowe and retain the explicit provision for horse riding in paragraph 27(a).

Proposed Submission Greater Cambridge Local Plan 2024–2045
Regulation 19 Representation
Policy S/NST – Northstowe New Town
Representation: Support with Modification
Soundness tests: Positively prepared; Justified; Effective; Consistent with national policy
Soundness issue
The British Horse Society supports the strategic approach to Northstowe, including the comprehensive movement and connectivity network, connected green spaces and the requirement for an improved rights of way network connecting the town with neighbouring villages and the open countryside. The explicit reference to horse riding in paragraph 27(a) is welcomed.
However, the policy should be strengthened to prevent potential equestrian exclusion as the remaining development comes forward. Paragraph 5 identifies green corridors incorporating Active Travel routes and associated infrastructure, but Active Travel provision does not automatically provide for equestrians. Active Travel and the Public Rights of Way and wider countryside-access network are distinct but complementary networks.
The policy should therefore require equestrian use to be considered from the outset where new Active Travel, green-corridor or countryside-access infrastructure forms part of, or provides a connection to, the wider countryside-access network. Where equestrian use is excluded, the relevant site-specific physical, environmental, legal or safety constraint should be identified and evidenced, together with the consequences for equestrian safety and wider network connectivity.
Reason for representation
Policy S/NST already contains strong principles. Paragraph 20 requires a connected network of green spaces and connections with the wider countryside; paragraph 23 requires a comprehensive movement and connectivity network; and paragraph 27(a) requires an improved rights of way network connecting Northstowe to neighbouring villages and the open countryside, including for walking, cycling and horse riding. Paragraphs 28 and 34 also provide for transport mitigation, delivery, phasing and comprehensive masterplanning and delivery. Paragraph 5 identifies green corridors incorporating Active Travel routes and associated infrastructure.
Northstowe is planned for approximately 10,180 homes and the policy recognises that development will continue during the Local Plan period and beyond. The 2026 Site Allocations Topic Paper confirms that six outline planning permissions cover the allocated site and reserved land, with reserved matters applications and construction underway. The Local Plan therefore needs to ensure that later phases complete and connect the countryside-access network rather than allowing opportunities for equestrian connectivity to be designed out through individual schemes.
Significant walking and cycling infrastructure is already secured through existing permissions. The issue is therefore not simply whether individual routes are provided, but whether the network as a whole remains connected and capable of serving the wider countryside.
Where equestrian use is excluded, the relevant physical, environmental, legal or safety constraint and the consequences of that exclusion should be identified and evidenced, including consequences for equestrian safety on the highway network and for the safety and connectivity of the wider PROW and countryside-access network.
Equestrians should be considered from the earliest stage of route planning and design. Where Active Travel provision can accommodate equestrian use, it should do so unless a relevant site-specific physical, environmental, legal or safety constraint provides a clear and evidenced reason for exclusion.
Active Travel infrastructure and the PROW/wider countryside-access network have different but complementary functions. Classification as Active Travel should not itself exclude equestrians where equestrian use could safely and reasonably be accommodated.
This principle should also apply where permissive routes contribute to the strategic countryside-access network. A permissive route does not create a public right of access for users not included by the landowner, and BHS does not suggest otherwise. However, where existing or proposed permissive routes contribute to development-related countryside connectivity, opportunities for inclusive access should be considered at the planning and design stage, including equestrian use where this can safely and practically be accommodated.
The BHS does not support an assumption that a green corridor or Active Travel route cannot be an equestrian-inclusive route. Whilst Active Travel primarily serves utility journeys, the PROW and wider countryside-access network has important recreational, health, wellbeing and countryside-access functions. They should be planned alongside one another as distinct but complementary networks. Green corridors should be planned as multifunctional countryside-access assets rather than as walking and cycling corridors by default.
New rights of way and countryside-access routes should, wherever reasonably practicable, be designed and established to accommodate the widest practicable range of relevant non-motorised users, including horse riding. Where carriage-driving rights are intended, they should be considered separately from horse-riding provision and the route should have the appropriate legal status and physical design to provide those rights. A bridleway does not confer carriage-driving rights.
The network should also protect existing routes and provide opportunities for new direct and circular connections as Northstowe and the surrounding network evolve. This is consistent with paragraph 105 of the December 2024 NPPF, which requires planning policies and decisions to protect and enhance public rights of way and access and to take opportunities to provide better facilities and links to existing rights of way networks.
A practical example of the consequences of excluding equestrians from Active Travel infrastructure is provided by the Southern Access Road West (SWAR) at Northstowe. A substantial off-road path runs immediately alongside the carriageway, but the regulatory signage at this location restricts its use to pedestrians and pedal cyclists. The Traffic Signs Manual confirms that Diagram 956 is for pedal cycles and pedestrians only; where ridden horses are permitted, Diagram 956.1 is used, and where horse-drawn vehicles are also permitted, Diagram 956.2 is used.
The result is that an equestrian may be physically alongside a substantial off-road facility but legally unable to use it, and must instead remain on the carriageway. At this location, the carriageway is subject to a 50 mph speed limit, while cyclists are provided with a parallel off-road facility immediately alongside the road. This is a clear illustration of how Active Travel infrastructure can improve provision for some users while leaving equestrians in a less protected position. The current Highway Code identifies horse riders among the road users most at risk from road traffic. Rule 63 gives specific advice to cyclists sharing space with horse riders and horse-drawn vehicles, including that cyclists should not pass a horse on its left. Rule 204 similarly identifies horse riders among the road users most at risk from road traffic. These provisions are relevant when considering whether excluding equestrians from an off-road connection transfers risk to the highway network.
From an equestrian safety perspective, passing a horse on the inside can present a particular risk because horses are accustomed to traffic approaching and passing on their outside. A cyclist passing on the inside may therefore startle a horse even where the cyclist has attempted to make their presence known. The potential safety consequence is not confined to the horse and rider. If a horse is startled by a cyclist passing on the inside while the horse remains on the carriageway, the horse may react by moving or changing direction towards the traffic flow. This can create a secondary risk for other highway users, including the possibility of a collision or evasive manoeuvre involving motor vehicles or other road users. This is an equestrian safety explanation of the practical implications and is distinct from the Highway Code wording.
This example demonstrates why the provision of an Active Travel route should not, in itself, be treated as providing equivalent or improved access for equestrians. It also demonstrates the potential safety consequences of designing or authorising walking and cycling infrastructure without considering the needs of other lawful road users and the wider Public Rights of Way network. Where excluding equestrians from an off-road connection leaves them on the highway alongside cyclists, the consequences for equestrian safety and for other highway users should be considered. The issue is not that every Active Travel route must accommodate horses, but that potentially suitable infrastructure should not be made unavailable to equestrians without a clear, site-specific and evidenced reason, and without considering the consequences for equestrian safety and network connectivity.
The SWAR example is particularly relevant to the remaining development of Northstowe. It demonstrates why equestrian use needs to be considered at the earliest stage when Active Travel routes and green corridors are planned, particularly where they run alongside strategic roads or could provide a connection to the wider countryside-access network.
This is directly relevant to Policy S/NST because Northstowe is responsible for substantial ongoing development and infrastructure delivery, while the adjoining Slate Hall Farm allocation may generate additional pressure on the same countryside-access corridor. The two allocations should not be considered in isolation where their combined effects could progressively urbanise an established rural right of way.
The BHS understands that, under the Section 106 arrangements associated with the Northstowe development, works were required on Wilson's Road bridleway. Local opposition has so far prevented the relevant works to the remaining natural-surface section from proceeding. Whatever the eventual position on those works, the Local Plan should provide clear protection for the rural character, natural surface and recreational function of the remaining section and should not allow either Northstowe or Slate Hall Farm to use future development or infrastructure requirements as a reason to hard surface it. Any proposed intervention should first demonstrate that it is necessary, appropriate to the legal status and function of the bridleway, and compatible with its established rural character.
This remaining rural section should be protected from further hard surfacing or urbanisation arising from either the Northstowe development or the adjacent Slate Hall Farm allocation. The fact that development-related works have previously been proposed or required on Wilson's Road does not mean that an established rural bridleway should be converted into an urban Active Travel route. The experience of the already hard-surfaced section demonstrates why the Local Plan should distinguish between maintaining or enhancing a rural Public Right of Way and providing new infrastructure required to serve development-related walking and cycling demand.
The experience of Wilson's Road provides a further important local lesson. The bridleway has been severed by the Southern Access Road West (SARW) into Northstowe. The section between the SARW bridge and Bar Hill was subsequently hard surfaced and has deteriorated significantly, with vegetation encroachment, loss of usable width and inadequate maintenance. In contrast, the remaining natural-surface section between the SARW bridge and Longstanton has retained its rural character and continues to provide a valuable green countryside-access corridor. Strong local and stakeholder opposition was an important factor in retaining that natural-surface character.
Proposed Modification
Existing rural rights of way – including Wilson's Road bridleway – shall be protected from unnecessary hard surfacing or urbanisation. In particular, the remaining natural-surface section of Wilson's Road shall retain its rural character, appropriate rural surface and recreational function. Neither Northstowe nor adjacent development at Slate Hall Farm should result in its conversion to an urban Active Travel route. Where works are proposed, their necessity, legal basis, effects on lawful users and compatibility with the established rural character of the bridleway shall be demonstrated.
Modify Policy S/NST to make clear:
The movement, green-corridor, Active Travel and Public Rights of Way/countryside-access networks shall be planned and delivered as distinct but complementary and connected networks, providing safe, direct, convenient and coherent connections within Northstowe and to neighbouring settlements and the wider countryside.
Where an Active Travel route, green corridor or other movement infrastructure could form part of, or provide a connection to, the wider countryside-access network, equestrian use shall be considered from the earliest stage of planning and design. Where the infrastructure can reasonably accommodate equestrian use, this should be included unless a clear, site-specific physical, environmental, legal or safety constraint provides an evidenced reason for exclusion. Where equestrian use is excluded, the reason for exclusion and the consequences for equestrian safety and wider network connectivity shall be identified and assessed.
Green corridors shall be planned as multifunctional countryside-access assets rather than as walking and cycling corridors by default.
New rights of way and countryside-access routes shall, wherever reasonably practicable, accommodate the widest practicable range of relevant non-motorised users, including horse riding. Where carriage-driving rights are intended, the route shall have the appropriate legal status and physical design to provide those rights.
The policy shall protect and enhance existing routes and provide opportunities for new direct and circular connections, including equestrian connections, as the development and surrounding network evolve. Paragraph 27(a), including its explicit reference to horse riding, should be retained and its application to the continuing development of the whole Northstowe allocation made clear.
The provision of pedestrian and cycle infrastructure should not be assumed to provide equivalent access for equestrians where regulatory restrictions prevent equestrian use.
Conclusion
The BHS supports Policy S/NST in principle. Its concern is that the current wording does not provide sufficient protection against equestrian exclusion as the remaining phases of Northstowe are designed and delivered, particularly where green corridors and Active Travel infrastructure could otherwise become walking and cycling-only routes. It should also expressly protect established rural rights of way, including the remaining natural-surface section of Wilson's Road, from unnecessary hard surfacing or urbanisation.
The SWAR and Wilson's Road examples demonstrate the practical consequences of treating development-related Active Travel infrastructure and established rural bridleways as interchangeable. The proposed modifications would not require every Active Travel route to accommodate horses or every route to be a bridleway or restricted byway. They would establish a clear planning principle that equestrian use is considered before exclusion, that new countryside-access routes are planned for the widest practicable range of relevant users, and that existing rural rights of way retain their legal status, rural character and recreational function unless a clear and evidenced case for change is established.
For Northstowe, the scale and long-term build-out of the allocation make this particularly important. The policy should retain its explicit commitment to equestrians, protect the established rural countryside-access network, and provide sufficient direction for future phases, masterplanning, design and delivery to secure a coherent and connected countryside-access network.

Policies S/EOC/NWO and S/EOC/SWO should be modified to:

Protect existing bridleways and countryside-access routes, including their legal status, continuity, usability and rural character.
Recognise the western/peripheral bridleway as part of the wider countryside-access and equestrian network and safeguard its future connectivity.
Ensure implementation of the existing Worts’ Causeway permissions does not prejudice opportunities to connect the countryside-access and equestrian network with the Cambridge Biomedical Campus and wider countryside.
Recognise the strategic relationship with the Cambridge Biomedical Campus, with the corresponding connection from the Granham’s Road area addressed through Policy S/CBC, its Campus-wide Masterplan and Infrastructure Delivery Strategy.
Safeguard opportunities for onward equestrian connectivity towards the Beechwoods, Wandlebury and wider Roman Road network.
Require new or retained permissive countryside-access routes to accommodate the widest practicable range of appropriate users, including horse riders and, where legally and physically appropriate, carriage drivers. Where equestrian access is excluded, the site-specific reason and consequences for safety and network connectivity should be identified.
Ensure that any road or infrastructure interaction involving equestrians is designed and assessed with appropriate regard to safety.

This would allow the two policies to protect the Worts’ Causeway end of the strategic network without seeking to retrospectively alter the existing planning permissions.

The British Horse Society
Greater Cambridge Local Plan – Regulation 19
Policies S/EOC/NWO – Land North of Worts’ Causeway
and S/EOC/SWO – Land South of Worts’ Causeway
Representation: Support with Modification
1. Representation
This representation applies to both Policy S/EOC/NWO – Land North of Worts’ Causeway and Policy S/EOC/SWO – Land South of Worts’ Causeway. The policies are considered together because the two allocations form a connected development area and the countryside-access and equestrian network cannot be effectively planned or delivered through either allocation in isolation.
The British Horse Society (the BHS) does not comment on whether the development proposed through these allocations should proceed. The BHS’s representation is concerned solely with ensuring that, if the allocations are retained, the policies properly protect and enhance the existing countryside-access and equestrian network and secure the opportunities for connectivity arising from the developments. Both policies recognise the importance of the bridleway network and provide for a green link along Worts’ Causeway with space for pedestrians, horse riders and cyclists. The BHS supports these elements of the policies and seeks their strengthening to ensure that the wider countryside-access and equestrian network is not left disconnected.
However, the BHS considers that the policies are not sufficiently effective or specific to secure a coherent equestrian and wider countryside-access network connecting the two developments with the Cambridge Biomedical Campus (CBC) and the wider countryside network.
The BHS therefore supports the policies with modification.
The current Regulation 19 Plan is being examined under the legacy plan-making system. The Councils confirm that the soundness of the Plan is to be considered against the National Planning Policy Framework of 12 December 2024. The four soundness tests include whether the Plan is positively prepared, justified, effective and consistent with national policy.
Paragraph 105 of the NPPF states that planning policies and decisions should protect and enhance public rights of way and access, including taking opportunities to provide better facilities and links to existing rights of way networks.
BHS considers that the two Worts’ Causeway allocations provide an important opportunity to apply this principle.
2. S/EOC/NWO – Land North of Worts’ Causeway
The BHS supports the recognition within Policy S/EOC/NWO of:
• the existing bridleway and rural character of Worts’ Causeway;
• the need for appropriate countryside connections;
• the provision of a green link with space for pedestrians, horse riders and cyclists; and
• the relationship between the North and South Worts’ Causeway sites.
The policy identifies the North site as approximately 7.84 hectares with capacity for approximately 200 homes. Its movement requirements include public footpaths linking the development with the surrounding chalk farmland and retention of Worts’ Causeway as a green link with space for pedestrians, horse riders and cyclists.
However, BHS considers that the policy needs to go further by securing the equestrian element of the wider network, rather than relying upon the general reference to space for horse riders.
Relationship with the South site
The two allocations should not be considered in isolation.
The planning history demonstrates that the two sites were planned as a wider development area comprising approximately 200 dwellings on the North site and approximately 230 dwellings on the South site.
The planning history is particularly relevant to the equestrian network. The officer report for the North site records that:
“A bridleway is proposed to run along the western boundary of the GB2 site, with access given from Worts’ Causeway.”
The report explains that this was intended to provide horse riders travelling from the rural areas east of the developments with access towards the rural area south of Babraham Road.
This demonstrates that the western/peripheral bridleway was identified as part of the planning solution for the GB2 development and is now particularly relevant to the delivery of a coherent equestrian network.
The Plan should ensure that this route is retained, its legal status and continuity are secured, and that it provides meaningful connectivity beyond the site.
3. S/EOC/SWO – Land South of Worts’ Causeway
The BHS supports the current policy’s specific recognition of:
• the existing bridleway;
• the existing permissive footpath on the western edge of the site;
• the country-lane character of Worts’ Causeway; and
• a green link providing space for pedestrians, horse riders and cyclists.
Policy S/EOC/SWO requires these features to be retained and states that the site should provide a green link into the Cambridge Green Belt with space for pedestrians, horse riders and cyclists.
However, BHS considers that the policy does not adequately secure the connection between the proposed bridleway infrastructure on the South site and the wider equestrian network beyond the site boundary.
This is the principal modification sought by the BHS.
4. The western/peripheral bridleway
The South site provides an important opportunity to secure a relatively short but strategically significant section of the equestrian network.
The planning history confirms that a bridleway was proposed along the western boundary of the South site, with access from Worts’ Causeway. The Council’s assessment was that this would provide horse riders with a route between the rural areas east of the development and the rural area south of Babraham Road.
The BHS considers that this peripheral route should be treated as an important component of the wider countryside-access network.
The BHS does not rely in this representation upon the earlier planning history concerning a possible alternative diagonal alignment across the site, as that detail has not been sufficiently verified within the time available for this Regulation 19 submission.
The important point for the Local Plan is that the western/peripheral bridleway was identified as part of the planning solution for the GB2 development and is now particularly relevant to the delivery of a coherent equestrian network.
The Plan should therefore not merely retain the bridleway within the site. It should ensure that its legal status, continuity and connections beyond the site are secured.
5. The Cambridge Biomedical Campus connection
The connection through the Cambridge Biomedical Campus is particularly important.
The CBC area already contains a substantial shared-use route for pedestrians and cyclists. The BHS has historic evidence showing that the route through this area was previously used by equestrians and that bridleway gates and a visible route existed before the present development and infrastructure were constructed.
The BHS does not assert that this historic route was necessarily a recorded public right of way. Its legal status has not been established and it may have operated as permissive access or through another form of land-management arrangement.
Nevertheless, its historical use is important evidence of an established equestrian desire line and of a connection which previously enabled equestrian movement through this part of the countryside.
The present position is particularly significant:
• a shared route for pedestrians and cyclists now exists through the CBC area;
• it is in use;
• the historic equestrian connection has not been retained; and
• the proposed bridleway associated with the South Worts’ Causeway development provides an opportunity to reconnect the equestrian network.
In effect, the walking and cycling connection has been provided, while equestrian connectivity is the missing component.
The BHS considers that this should be addressed through the Local Plan rather than leaving the issue to be considered separately by each development or infrastructure project.
6. Linton Greenway and inclusive permissive access
This issue also illustrates a wider planning principle which BHS has raised elsewhere in its Regulation 19 representations.
The BHS recognises the role of Active Travel infrastructure in providing for everyday journeys by walking, wheeling and cycling. However, Active Travel infrastructure should not be treated as a substitute for, or as defining the requirements of, the wider countryside-access network. The exclusion of equestrians from Active Travel infrastructure should not result in the wider countryside-access network being planned solely around walking and cycling. Where Active Travel infrastructure forms part of, or connects to, the wider countryside-access network, the needs of horse riders should be considered from the outset.
The BHS position is that Active Travel and the wider Public Rights of Way/countryside-access network are distinct but complementary.
Where a new shared or permissive countryside-access route is being created, the widest practicable range of appropriate users should be considered from the outset.
This does not mean that every route must accommodate horses. It means that where equestrian use can reasonably and safely be accommodated, it should be considered before a walking/cycling-only solution is established, rather than being treated as a subsequent addition.
This is particularly relevant at Worts’ Causeway because there is already:
• a proposed/required bridleway associated with the South site;
• an historic equestrian route towards CBC;
• existing walking and cycling infrastructure through CBC;
• emerging equestrian connections associated with CSET and the wider southern Cambridge network; and
• an opportunity to connect these routes into the wider countryside network.
The current policy should therefore secure an inclusive network, rather than simply a collection of individual routes.
7. Strategic network connection beyond the Worts’ Causeway developments
The immediate connection through CBC should form part of a longer-term strategic objective.
The BHS considers that the two Worts’ Causeway allocations provide an opportunity to create a connected equestrian and countryside-access network linking:
Worts’ Causeway → proposed western/peripheral bridleway → Cambridge Biomedical Campus → Beechwoods/Wandlebury and Roman Road network → CSET/Sawston Greenway and the wider southern Cambridge network.
The purpose is not to require all of these links to be delivered by either Worts’ Causeway site individually.
Rather, the Local Plan should identify the strategic connection as part of the wider countryside-access network and safeguard the opportunity to complete it. The Council should use the planning and infrastructure opportunities that remain available through the implementation of the existing permissions, adjoining development and future transport and infrastructure schemes to secure the missing links wherever reasonably practicable. Individual schemes should not prejudice the ability to complete the wider network.
This is particularly important because the current Plan recognises the relationship between the North and South sites. The same integrated approach should apply to countryside access and equestrian connectivity.
8. Permissive access should be inclusive where reasonably practicable
The Worts’ Causeway sites also provide a useful example of the wider BHS policy position on permissive access.
A permissive route can make an important contribution to the countryside-access network, but its value is significantly increased where it provides connectivity for the widest practicable range of appropriate users.
BHS therefore considers that the Plan should establish the following principle:
Where development provides new or retained permissive countryside-access routes, the widest practicable range of appropriate users should be considered from the outset, including horse riders and, where legally and physically appropriate, carriage drivers. Where equestrian access is excluded, a clear, site-specific and evidence-based reason for exclusion should be identified, together with an assessment of the consequences of that exclusion for equestrian safety, route continuity and the wider countryside-access network. Where exclusion would leave equestrians using a road or other less suitable route, the resulting safety implications should be specifically assessed and, where necessary, appropriate mitigation or an alternative safe route should be provided.
This is consistent with BHS’s wider position that safety should be addressed through appropriate design and mitigation, rather than by simply transferring risk to the excluded user.
It also reflects the NPPF requirement to protect and enhance public rights of way and access and to take opportunities to provide better facilities and links to existing networks.
9. Safety
The BHS considers that safety should be addressed through the design of appropriate countryside-access routes and the safe management of points where different forms of movement interact.
Where equestrian routes cross or interact with roads or other development infrastructure, the design and safety assessment should consider:
• visibility;
• appropriate crossing locations;
• traffic speeds and volumes;
• separation from motor traffic where reasonably practicable;
• adequate space and appropriate surface conditions for horses;
• interaction with pedestrians and cyclists; and
• the potential consequences of conflict between different lawful users.
Where equestrian access is excluded, the consequences of that exclusion should also be considered. In particular, the assessment should establish whether exclusion transfers equestrians onto a road or other route with greater exposure to traffic or other hazards. Where this occurs, the resulting safety implications should be assessed and, where necessary, appropriate mitigation or an alternative safe route should be provided.
The objective should therefore be to provide a safe and coherent countryside-access network for its lawful users, with the design of individual routes and crossing points responding to the circumstances of the site.
10. Rural character and surface treatment
BHS supports the current policy’s recognition of the country-lane appearance and character of Worts’ Causeway, including its verges and hedgerows.
This should extend to the treatment of the countryside-access network.
The creation of a connection should not automatically result in an established rural route being converted into an urban-style pedestrian and cycle facility.
Where a rural surface is appropriate and safe for its intended lawful users, it should be retained.
Where a more substantial surface is necessary for accessibility, safety or other demonstrated purposes, its design should nevertheless reflect the rural context and the requirements of the full range of intended users.
11. Why modification is necessary for soundness
The BHS considers that the policies contain important elements relating to countryside access, including recognition of horse riders within the Worts’ Causeway green link. However, modification is necessary to ensure that the policies are effective in protecting and improving the wider countryside-access and equestrian network associated with the two allocations.
In particular, the policies should:
• recognise the strategic importance of the western/peripheral bridleway and its connection to the wider countryside-access network;
• protect the opportunity for future connectivity towards the Cambridge Biomedical Campus and the wider countryside-access network;
• recognise the importance of maintaining opportunities for onward connectivity towards Beechwoods, Wandlebury and the wider Roman Road network;
• ensure that existing development and infrastructure do not prejudice opportunities for future countryside-access and equestrian connections;
• establish an appropriate principle for inclusive permissive countryside-access routes; and
• ensure that the consequences for equestrian safety and route continuity are considered where equestrian access is excluded.
The BHS recognises that both allocations already benefit from planning permissions and that the Local Plan cannot retrospectively impose new requirements on those permissions. The purpose of the proposed modifications is therefore not to rewrite the existing permissions, but to establish the strategic countryside-access and equestrian network, safeguard opportunities for its future completion and ensure that implementation of the existing developments does not prejudice those opportunities.
This is particularly important because development is already progressing and opportunities to influence the relationship between the two sites, adjoining development and strategic infrastructure will diminish as development is implemented. The Local Plan should therefore provide a clear strategic framework within which remaining planning and infrastructure opportunities can contribute to completion of the wider network.
12. Proposed modification
The BHS requests that Policies S/EOC/NWO and S/EOC/SWO are modified to establish and safeguard a coherent countryside-access and equestrian network associated with the two allocations, while recognising that both sites already benefit from planning permissions.
The following wording is proposed:
Countryside access and equestrian connectivity
The relationship between Land North and Land South of Worts’ Causeway and the wider countryside-access and Public Rights of Way network shall be recognised in planning and infrastructure decisions.
Existing bridleways and other countryside-access routes shall be retained and enhanced, with their legal status, continuity, usability and rural character protected.
The western/peripheral bridleway associated with Land South of Worts’ Causeway shall be recognised as an important component of the wider countryside-access network. The opportunity for it to connect with the wider network, including towards the Cambridge Biomedical Campus, shall be safeguarded. The implementation of the existing development should not prejudice the ability to provide such connections through adjoining development, future planning applications or appropriate transport and infrastructure schemes.
The strategic relationship between the two Worts’ Causeway developments, the Cambridge Biomedical Campus and adjoining strategic transport infrastructure shall be recognised so that the countryside-access and equestrian network can connect between these areas. The implementation of the Worts’ Causeway developments should not prejudice the ability to complete the wider connection. The requirements for the Cambridge Biomedical Campus to safeguard and facilitate the corresponding connection from the Granham’s Road area should be addressed through Policy S/CBC, its Campus-wide Masterplan and Infrastructure Delivery Strategy. Where adjoining development, future planning applications or transport and infrastructure schemes provide an opportunity to complete the wider network, including onward connectivity towards the Beechwoods, Wandlebury and the wider Roman Road network, those opportunities should be identified and considered at the earliest appropriate stage.
New or retained permissive countryside-access routes should accommodate the widest practicable range of appropriate users, including horse riders and, where legally and physically appropriate, carriage drivers. Where equestrian use is not proposed, the relevant site-specific physical, environmental, legal or safety constraint should be identified and evidenced, together with an assessment of the consequences for equestrian safety, route continuity and the wider countryside-access network. Where exclusion would leave equestrians using a road or other less suitable route, appropriate mitigation or an alternative safe route should be provided where necessary.
The relevant planning and infrastructure processes should identify appropriate land, legal status, funding and delivery mechanisms for future connections where these are necessary and reasonably practicable.
13. Conclusion
The BHS does not comment on whether the development proposed through the two allocations should proceed. Its representation is concerned with the countryside-access and equestrian implications of the policies and with ensuring that, if the allocations are retained and implemented, they do not prejudice the wider network.
The BHS welcomes the explicit recognition of horse riders within the proposed Worts’ Causeway green link and the recognition of the bridleway network. However, recognition of horse riders as users of the green link is not sufficient on its own. The Plan should also protect the opportunity for the western/peripheral bridleway to form part of a wider connected countryside-access network.
The two Worts’ Causeway developments form part of an important strategic opportunity to protect and extend countryside-access and equestrian connectivity towards the Cambridge Biomedical Campus and, ultimately, the wider network towards Beechwoods, Wandlebury and the Roman Road. The Local Plan should safeguard these opportunities while recognising that the existing planning permissions cannot be retrospectively rewritten. The corresponding requirement to safeguard and facilitate the connection through the Cambridge Biomedical Campus is addressed separately through Policy S/CBC and its Campus-wide Masterplan and Infrastructure Delivery Strategy.
The established walking and cycling infrastructure through the Cambridge Biomedical Campus area, alongside the absence of an equivalent equestrian connection, illustrates why the wider countryside-access network should be considered separately from Active Travel infrastructure and why future opportunities for equestrian connectivity should not be lost.
The BHS therefore requests that Policies S/EOC/NWO and S/EOC/SWO are modified as set out above so that the Plan provides an effective strategic framework for protecting and extending the countryside-access and equestrian network, while ensuring that existing and future development and infrastructure do not prejudice opportunities to complete the wider network.

Policies S/EOC/NWO and S/EOC/SWO should be modified to:

Protect existing bridleways and countryside-access routes, including their legal status, continuity, usability and rural character.
Recognise the western/peripheral bridleway as part of the wider countryside-access and equestrian network and safeguard its future connectivity.
Ensure implementation of the existing Worts’ Causeway permissions does not prejudice opportunities to connect the countryside-access and equestrian network with the Cambridge Biomedical Campus and wider countryside.
Recognise the strategic relationship with the Cambridge Biomedical Campus, with the corresponding connection from the Granham’s Road area addressed through Policy S/CBC, its Campus-wide Masterplan and Infrastructure Delivery Strategy.
Safeguard opportunities for onward equestrian connectivity towards the Beechwoods, Wandlebury and wider Roman Road network.
Require new or retained permissive countryside-access routes to accommodate the widest practicable range of appropriate users, including horse riders and, where legally and physically appropriate, carriage drivers. Where equestrian access is excluded, the site-specific reason and consequences for safety and network connectivity should be identified.
Ensure that any road or infrastructure interaction involving equestrians is designed and assessed with appropriate regard to safety.

This would allow the two policies to protect the Worts’ Causeway end of the strategic network without seeking to retrospectively alter the existing planning permissions.

The British Horse Society
Greater Cambridge Local Plan – Regulation 19
Policies S/EOC/NWO – Land North of Worts’ Causeway
and S/EOC/SWO – Land South of Worts’ Causeway
Representation: Support with Modification
1. Representation
This representation applies to both Policy S/EOC/NWO – Land North of Worts’ Causeway and Policy S/EOC/SWO – Land South of Worts’ Causeway. The policies are considered together because the two allocations form a connected development area and the countryside-access and equestrian network cannot be effectively planned or delivered through either allocation in isolation.
The British Horse Society (the BHS) does not comment on whether the development proposed through these allocations should proceed. The BHS’s representation is concerned solely with ensuring that, if the allocations are retained, the policies properly protect and enhance the existing countryside-access and equestrian network and secure the opportunities for connectivity arising from the developments. Both policies recognise the importance of the bridleway network and provide for a green link along Worts’ Causeway with space for pedestrians, horse riders and cyclists. The BHS supports these elements of the policies and seeks their strengthening to ensure that the wider countryside-access and equestrian network is not left disconnected.
However, the BHS considers that the policies are not sufficiently effective or specific to secure a coherent equestrian and wider countryside-access network connecting the two developments with the Cambridge Biomedical Campus (CBC) and the wider countryside network.
The BHS therefore supports the policies with modification.
The current Regulation 19 Plan is being examined under the legacy plan-making system. The Councils confirm that the soundness of the Plan is to be considered against the National Planning Policy Framework of 12 December 2024. The four soundness tests include whether the Plan is positively prepared, justified, effective and consistent with national policy.
Paragraph 105 of the NPPF states that planning policies and decisions should protect and enhance public rights of way and access, including taking opportunities to provide better facilities and links to existing rights of way networks.
BHS considers that the two Worts’ Causeway allocations provide an important opportunity to apply this principle.
2. S/EOC/NWO – Land North of Worts’ Causeway
The BHS supports the recognition within Policy S/EOC/NWO of:
• the existing bridleway and rural character of Worts’ Causeway;
• the need for appropriate countryside connections;
• the provision of a green link with space for pedestrians, horse riders and cyclists; and
• the relationship between the North and South Worts’ Causeway sites.
The policy identifies the North site as approximately 7.84 hectares with capacity for approximately 200 homes. Its movement requirements include public footpaths linking the development with the surrounding chalk farmland and retention of Worts’ Causeway as a green link with space for pedestrians, horse riders and cyclists.
However, BHS considers that the policy needs to go further by securing the equestrian element of the wider network, rather than relying upon the general reference to space for horse riders.
Relationship with the South site
The two allocations should not be considered in isolation.
The planning history demonstrates that the two sites were planned as a wider development area comprising approximately 200 dwellings on the North site and approximately 230 dwellings on the South site.
The planning history is particularly relevant to the equestrian network. The officer report for the North site records that:
“A bridleway is proposed to run along the western boundary of the GB2 site, with access given from Worts’ Causeway.”
The report explains that this was intended to provide horse riders travelling from the rural areas east of the developments with access towards the rural area south of Babraham Road.
This demonstrates that the western/peripheral bridleway was identified as part of the planning solution for the GB2 development and is now particularly relevant to the delivery of a coherent equestrian network.
The Plan should ensure that this route is retained, its legal status and continuity are secured, and that it provides meaningful connectivity beyond the site.
3. S/EOC/SWO – Land South of Worts’ Causeway
The BHS supports the current policy’s specific recognition of:
• the existing bridleway;
• the existing permissive footpath on the western edge of the site;
• the country-lane character of Worts’ Causeway; and
• a green link providing space for pedestrians, horse riders and cyclists.
Policy S/EOC/SWO requires these features to be retained and states that the site should provide a green link into the Cambridge Green Belt with space for pedestrians, horse riders and cyclists.
However, BHS considers that the policy does not adequately secure the connection between the proposed bridleway infrastructure on the South site and the wider equestrian network beyond the site boundary.
This is the principal modification sought by the BHS.
4. The western/peripheral bridleway
The South site provides an important opportunity to secure a relatively short but strategically significant section of the equestrian network.
The planning history confirms that a bridleway was proposed along the western boundary of the South site, with access from Worts’ Causeway. The Council’s assessment was that this would provide horse riders with a route between the rural areas east of the development and the rural area south of Babraham Road.
The BHS considers that this peripheral route should be treated as an important component of the wider countryside-access network.
The BHS does not rely in this representation upon the earlier planning history concerning a possible alternative diagonal alignment across the site, as that detail has not been sufficiently verified within the time available for this Regulation 19 submission.
The important point for the Local Plan is that the western/peripheral bridleway was identified as part of the planning solution for the GB2 development and is now particularly relevant to the delivery of a coherent equestrian network.
The Plan should therefore not merely retain the bridleway within the site. It should ensure that its legal status, continuity and connections beyond the site are secured.
5. The Cambridge Biomedical Campus connection
The connection through the Cambridge Biomedical Campus is particularly important.
The CBC area already contains a substantial shared-use route for pedestrians and cyclists. The BHS has historic evidence showing that the route through this area was previously used by equestrians and that bridleway gates and a visible route existed before the present development and infrastructure were constructed.
The BHS does not assert that this historic route was necessarily a recorded public right of way. Its legal status has not been established and it may have operated as permissive access or through another form of land-management arrangement.
Nevertheless, its historical use is important evidence of an established equestrian desire line and of a connection which previously enabled equestrian movement through this part of the countryside.
The present position is particularly significant:
• a shared route for pedestrians and cyclists now exists through the CBC area;
• it is in use;
• the historic equestrian connection has not been retained; and
• the proposed bridleway associated with the South Worts’ Causeway development provides an opportunity to reconnect the equestrian network.
In effect, the walking and cycling connection has been provided, while equestrian connectivity is the missing component.
The BHS considers that this should be addressed through the Local Plan rather than leaving the issue to be considered separately by each development or infrastructure project.
6. Linton Greenway and inclusive permissive access
This issue also illustrates a wider planning principle which BHS has raised elsewhere in its Regulation 19 representations.
The BHS recognises the role of Active Travel infrastructure in providing for everyday journeys by walking, wheeling and cycling. However, Active Travel infrastructure should not be treated as a substitute for, or as defining the requirements of, the wider countryside-access network. The exclusion of equestrians from Active Travel infrastructure should not result in the wider countryside-access network being planned solely around walking and cycling. Where Active Travel infrastructure forms part of, or connects to, the wider countryside-access network, the needs of horse riders should be considered from the outset.
The BHS position is that Active Travel and the wider Public Rights of Way/countryside-access network are distinct but complementary.
Where a new shared or permissive countryside-access route is being created, the widest practicable range of appropriate users should be considered from the outset.
This does not mean that every route must accommodate horses. It means that where equestrian use can reasonably and safely be accommodated, it should be considered before a walking/cycling-only solution is established, rather than being treated as a subsequent addition.
This is particularly relevant at Worts’ Causeway because there is already:
• a proposed/required bridleway associated with the South site;
• an historic equestrian route towards CBC;
• existing walking and cycling infrastructure through CBC;
• emerging equestrian connections associated with CSET and the wider southern Cambridge network; and
• an opportunity to connect these routes into the wider countryside network.
The current policy should therefore secure an inclusive network, rather than simply a collection of individual routes.
7. Strategic network connection beyond the Worts’ Causeway developments
The immediate connection through CBC should form part of a longer-term strategic objective.
The BHS considers that the two Worts’ Causeway allocations provide an opportunity to create a connected equestrian and countryside-access network linking:
Worts’ Causeway → proposed western/peripheral bridleway → Cambridge Biomedical Campus → Beechwoods/Wandlebury and Roman Road network → CSET/Sawston Greenway and the wider southern Cambridge network.
The purpose is not to require all of these links to be delivered by either Worts’ Causeway site individually.
Rather, the Local Plan should identify the strategic connection as part of the wider countryside-access network and safeguard the opportunity to complete it. The Council should use the planning and infrastructure opportunities that remain available through the implementation of the existing permissions, adjoining development and future transport and infrastructure schemes to secure the missing links wherever reasonably practicable. Individual schemes should not prejudice the ability to complete the wider network.
This is particularly important because the current Plan recognises the relationship between the North and South sites. The same integrated approach should apply to countryside access and equestrian connectivity.
8. Permissive access should be inclusive where reasonably practicable
The Worts’ Causeway sites also provide a useful example of the wider BHS policy position on permissive access.
A permissive route can make an important contribution to the countryside-access network, but its value is significantly increased where it provides connectivity for the widest practicable range of appropriate users.
BHS therefore considers that the Plan should establish the following principle:
Where development provides new or retained permissive countryside-access routes, the widest practicable range of appropriate users should be considered from the outset, including horse riders and, where legally and physically appropriate, carriage drivers. Where equestrian access is excluded, a clear, site-specific and evidence-based reason for exclusion should be identified, together with an assessment of the consequences of that exclusion for equestrian safety, route continuity and the wider countryside-access network. Where exclusion would leave equestrians using a road or other less suitable route, the resulting safety implications should be specifically assessed and, where necessary, appropriate mitigation or an alternative safe route should be provided.
This is consistent with BHS’s wider position that safety should be addressed through appropriate design and mitigation, rather than by simply transferring risk to the excluded user.
It also reflects the NPPF requirement to protect and enhance public rights of way and access and to take opportunities to provide better facilities and links to existing networks.
9. Safety
The BHS considers that safety should be addressed through the design of appropriate countryside-access routes and the safe management of points where different forms of movement interact.
Where equestrian routes cross or interact with roads or other development infrastructure, the design and safety assessment should consider:
• visibility;
• appropriate crossing locations;
• traffic speeds and volumes;
• separation from motor traffic where reasonably practicable;
• adequate space and appropriate surface conditions for horses;
• interaction with pedestrians and cyclists; and
• the potential consequences of conflict between different lawful users.
Where equestrian access is excluded, the consequences of that exclusion should also be considered. In particular, the assessment should establish whether exclusion transfers equestrians onto a road or other route with greater exposure to traffic or other hazards. Where this occurs, the resulting safety implications should be assessed and, where necessary, appropriate mitigation or an alternative safe route should be provided.
The objective should therefore be to provide a safe and coherent countryside-access network for its lawful users, with the design of individual routes and crossing points responding to the circumstances of the site.
10. Rural character and surface treatment
BHS supports the current policy’s recognition of the country-lane appearance and character of Worts’ Causeway, including its verges and hedgerows.
This should extend to the treatment of the countryside-access network.
The creation of a connection should not automatically result in an established rural route being converted into an urban-style pedestrian and cycle facility.
Where a rural surface is appropriate and safe for its intended lawful users, it should be retained.
Where a more substantial surface is necessary for accessibility, safety or other demonstrated purposes, its design should nevertheless reflect the rural context and the requirements of the full range of intended users.
11. Why modification is necessary for soundness
The BHS considers that the policies contain important elements relating to countryside access, including recognition of horse riders within the Worts’ Causeway green link. However, modification is necessary to ensure that the policies are effective in protecting and improving the wider countryside-access and equestrian network associated with the two allocations.
In particular, the policies should:
• recognise the strategic importance of the western/peripheral bridleway and its connection to the wider countryside-access network;
• protect the opportunity for future connectivity towards the Cambridge Biomedical Campus and the wider countryside-access network;
• recognise the importance of maintaining opportunities for onward connectivity towards Beechwoods, Wandlebury and the wider Roman Road network;
• ensure that existing development and infrastructure do not prejudice opportunities for future countryside-access and equestrian connections;
• establish an appropriate principle for inclusive permissive countryside-access routes; and
• ensure that the consequences for equestrian safety and route continuity are considered where equestrian access is excluded.
The BHS recognises that both allocations already benefit from planning permissions and that the Local Plan cannot retrospectively impose new requirements on those permissions. The purpose of the proposed modifications is therefore not to rewrite the existing permissions, but to establish the strategic countryside-access and equestrian network, safeguard opportunities for its future completion and ensure that implementation of the existing developments does not prejudice those opportunities.
This is particularly important because development is already progressing and opportunities to influence the relationship between the two sites, adjoining development and strategic infrastructure will diminish as development is implemented. The Local Plan should therefore provide a clear strategic framework within which remaining planning and infrastructure opportunities can contribute to completion of the wider network.
12. Proposed modification
The BHS requests that Policies S/EOC/NWO and S/EOC/SWO are modified to establish and safeguard a coherent countryside-access and equestrian network associated with the two allocations, while recognising that both sites already benefit from planning permissions.
The following wording is proposed:
Countryside access and equestrian connectivity
The relationship between Land North and Land South of Worts’ Causeway and the wider countryside-access and Public Rights of Way network shall be recognised in planning and infrastructure decisions.
Existing bridleways and other countryside-access routes shall be retained and enhanced, with their legal status, continuity, usability and rural character protected.
The western/peripheral bridleway associated with Land South of Worts’ Causeway shall be recognised as an important component of the wider countryside-access network. The opportunity for it to connect with the wider network, including towards the Cambridge Biomedical Campus, shall be safeguarded. The implementation of the existing development should not prejudice the ability to provide such connections through adjoining development, future planning applications or appropriate transport and infrastructure schemes.
The strategic relationship between the two Worts’ Causeway developments, the Cambridge Biomedical Campus and adjoining strategic transport infrastructure shall be recognised so that the countryside-access and equestrian network can connect between these areas. The implementation of the Worts’ Causeway developments should not prejudice the ability to complete the wider connection. The requirements for the Cambridge Biomedical Campus to safeguard and facilitate the corresponding connection from the Granham’s Road area should be addressed through Policy S/CBC, its Campus-wide Masterplan and Infrastructure Delivery Strategy. Where adjoining development, future planning applications or transport and infrastructure schemes provide an opportunity to complete the wider network, including onward connectivity towards the Beechwoods, Wandlebury and the wider Roman Road network, those opportunities should be identified and considered at the earliest appropriate stage.
New or retained permissive countryside-access routes should accommodate the widest practicable range of appropriate users, including horse riders and, where legally and physically appropriate, carriage drivers. Where equestrian use is not proposed, the relevant site-specific physical, environmental, legal or safety constraint should be identified and evidenced, together with an assessment of the consequences for equestrian safety, route continuity and the wider countryside-access network. Where exclusion would leave equestrians using a road or other less suitable route, appropriate mitigation or an alternative safe route should be provided where necessary.
The relevant planning and infrastructure processes should identify appropriate land, legal status, funding and delivery mechanisms for future connections where these are necessary and reasonably practicable.
13. Conclusion
The BHS does not comment on whether the development proposed through the two allocations should proceed. Its representation is concerned with the countryside-access and equestrian implications of the policies and with ensuring that, if the allocations are retained and implemented, they do not prejudice the wider network.
The BHS welcomes the explicit recognition of horse riders within the proposed Worts’ Causeway green link and the recognition of the bridleway network. However, recognition of horse riders as users of the green link is not sufficient on its own. The Plan should also protect the opportunity for the western/peripheral bridleway to form part of a wider connected countryside-access network.
The two Worts’ Causeway developments form part of an important strategic opportunity to protect and extend countryside-access and equestrian connectivity towards the Cambridge Biomedical Campus and, ultimately, the wider network towards Beechwoods, Wandlebury and the Roman Road. The Local Plan should safeguard these opportunities while recognising that the existing planning permissions cannot be retrospectively rewritten. The corresponding requirement to safeguard and facilitate the connection through the Cambridge Biomedical Campus is addressed separately through Policy S/CBC and its Campus-wide Masterplan and Infrastructure Delivery Strategy.
The established walking and cycling infrastructure through the Cambridge Biomedical Campus area, alongside the absence of an equivalent equestrian connection, illustrates why the wider countryside-access network should be considered separately from Active Travel infrastructure and why future opportunities for equestrian connectivity should not be lost.
The BHS therefore requests that Policies S/EOC/NWO and S/EOC/SWO are modified as set out above so that the Plan provides an effective strategic framework for protecting and extending the countryside-access and equestrian network, while ensuring that existing and future development and infrastructure do not prejudice opportunities to complete the wider network.