Greater Cambridge Local Plan: Proposed Submission

See attached document section 7.

This representation objects to the Local Plan's HRA, which omits EWR's in-combination effects on Eversden and Wimpole Woods SAC's barbastelle bat colony, despite the Councils' screening chapter saying this would be examined at Appropriate Assessment stage. Citing Regulation 105, the Habitats Directive and case law including Waddenzee, Moorburg and Caffyn, Cambridge Approaches argues this omission makes the Plan legally non-compliant, unjustified and ineffective, and should not be adopted until resolved.

Update the Habitats Regulations Assessment to identify Hardwick Wood's barbastelle maternity colony and its shared foraging resource with Eversden and Wimpole Woods SAC, using the East West Rail Company's 2022 radio-tracking evidence and any further available survey data. Assess whether recreation and visitor pressure from the Local Plan's allocations, individually and cumulatively, could affect this shared foraging resource, and whether Policy BG/BG and related mitigation are sufficient. Revisit Appendix E's assessment of Bourn Airfield to distinguish the site's functional connectivity from the connectivity and foraging requirements of the SAC's qualifying population. Amend the HRA before adoption as necessary.

HPC objects to the Plan because its HRA does not appear to have adequately considered the barbastelle foraging resource shared between Hardwick Wood and Eversden and Wimpole Woods SAC. EWRCo.'s 2022 radio-tracking survey identifies shared foraging resources between the Hardwick Wood, Madingley Wood and SAC populations, while the HRA itself records functional connectivity towards Hardwick Wood but does not follow this evidence through to the SAC's qualifying population. HPC considers that this gap in the evidence base undermines confidence in the HRA's assessment of cumulative effects and the conclusion that the Plan will have no adverse effect on the SAC.

Amend the Local Plan so that the scale, density and phasing of Cambourne North are not dependent on an assumed East West Rail mode share that has not been adequately evidenced. Provide transport evidence and Sustainability Appraisal to assess the road traffic generated by the proposed development and to test reasonable alternatives, including the recently approved C2C guided busway and its potential extension or reinforcement. Demonstrate that sufficient transport capacity is secured for Cambourne North irrespective of EWR, and clarify responsibility for modelling and mitigating development-generated traffic. The housing trajectory should reflect the delivery of secured transport capacity.

It is considered legally non-compliant because its Sustainability Appraisal has not demonstrated that reasonable transport alternatives to an EWR-dependent strategy have been identified, described and evaluated, as required by the Environmental Assessment of Plans and Programmes Regulations 2004. It is unsound because the transport strategy for Cambourne North is not justified or effective: it relies on an assumed EWR mode share without an evidenced business case or demonstrated capacity, while development-generated road traffic is excluded from relevant EWR modelling. The Plan therefore fails to demonstrate that an appropriate, deliverable transport strategy supports the proposed scale, density and phasing of development.

Amend Policy I/SI to confirm that MRAO safeguarding applies to all development, including Nationally Significant Infrastructure and Development Consent Order projects. Require robust, independently verifiable evidence that major infrastructure will not cause electromagnetic, vibration or other interference or prejudice MRAO's future scientific capability. Require avoidance of interference before reliance on mitigation. Amend the supporting text to recognise the conflict between the proposed EWR Southern Approach and MRAO safeguarding. Revise the Sustainability Appraisal and transport evidence to assess alternative EWR routes and reasonable alternative transport modes where the proposed heavy-rail infrastructure cannot satisfy MRAO safeguarding requirements.

Policy I/SI is unjustified and ineffective because it fails to address the conflict between its protection of the Mullard Radio Astronomy Observatory (MRAO) and the proposed East West Rail Southern Approach which passes through all three Lord’s Bridge safeguarding areas. The Plan relies substantially on EWR in its development and transport strategy, yet the proposed heavy railway appears incompatible with the protection required by Policy I/SI. The Plan should assess this conflict, including reasonable alternatives such as other transport modes and alternative EWR routes and require evidence that MRAO will suffer no interference or loss of future scientific capability.

Amend paragraph 4.5 to explicitly distinguish between a transport mode's per-journey carbon intensity and the total emissions impact resulting from the massive scale of growth it enables. The evidence base should assess the cumulative and in-combination carbon and water impacts of reasonably foreseeable growth from both East West Rail’s dependent development and that promoted through the Cambridge Development Corporation, and demonstrate that the resulting strategy is consistent with sustainable development.

Paragraph 4.5 is not positively prepared or justified because it conflates a transport mode being lower-carbon per journey with the overall scale of growth it enables. East West Rail depends on approximately 70,000 new homes coming forward, generating massive embodied, land-use, and construction emissions. The Cambridge Development Corporation is considering further growth. The climate strategy cannot be justified or positively prepared if it ignores the total embodied, land-use, construction and operational carbon consequences of this growth, rather than treating lower-carbon transport as sufficient evidence that the resulting growth is sustainable.

Apply the Sustainability Checklist standards to all householder applications. The required detail can be proportionate to scale, ensuring that residential extensions and rebuilds are held to the same mandatory sustainable development standard as other forms of development.

The policy is not justified because it arbitrarily excludes householder applications (extensions, rebuilds) without an evidence-based rationale. While we appreciate the mandatory language applying the Climate Change Act 2008 duty, excluding residential extensions contradicts the Plan's broader rationale. Given Policy CC/CE emphasizes a retrofit-first and existing-stock-first approach, excluding householder development from baseline sustainability standards creates an unjustified loophole.

Provide an evidence-based explanation for CC/SR's advisory approach, or introduce mandatory requirements for retrofits. At a minimum, mandate standards for major non-residential refurbishments (matching CC/CE's thresholds). The policy should also reference Warm Homes Plan funding to address any cost viability concerns for householders.

This policy is not justified because it relies entirely on advisory language ("will be supported", "encouraged") for retrofitting. Paragraph 4.70 acknowledges existing buildings as the area's largest emissions source, yet the policy imposes no mandatory standards, embodied-carbon requirements, or offsetting mechanisms. This is highly inconsistent with the mandatory language used for new builds in CC/NZ and CC/WE, and the Plan offers no evidence justifying this disparity.

Establish a consistent monitoring and enforcement framework across this chapter, specifically detailing the required frequency of checks, the responsible body, and the exact consequences for non-compliance. Furthermore, set out clear mechanisms for capturing tree, hedgerow, and undesignated open space losses that occur ahead of a planning application. This ensures clearance timed to pre-empt policy protections does not go unaddressed.

This chapter is not effective because it lacks functional mechanisms to monitor or enforce its ambitions. While we support the 20% biodiversity net gain, Policies BG/BG, BG/GI, and BG/TC mandate habitat measures but omit monitoring frequencies, responsible bodies, or consequences for non-compliance. Additionally, protections are ineffective because they only engage once a planning application exists. Policy BG/TC allows pre-application tree clearance to bypass safeguards entirely, a critical loophole that Policy BG/PO shares for undesignated open space.

We strongly support this policy's recognition of peat as a critical carbon store. However, although Natural England explicitly advises that tree planting on peat is "not normally appropriate", Point 7 fails to reflect this guidance. We suggest point 7 or paragraph 4.68 be amended to explicitly exclude tree planting from any green infrastructure proposed on peat soils, aligning directly with Natural England's advice.

Align the Circular Economy Statement threshold in CC/CE with the Whole Life Carbon Assessment threshold in CC/NZ (100 dwellings or 10,000m²). This ensures critical process details are captured consistently across all developments of comparable scale.

There is an unjustified threshold gap between this policy and CC/NZ. Policy CC/NZ requires a Whole Life Carbon Assessment above 100 dwellings or 10,000m². However, CC/CE only requires a Circular Economy Statement (which includes vital process evidence like disassembly design) above 150 dwellings or 15,000m². Consequently, a scale of development deemed significant enough for detailed carbon assessments escapes equivalent circularity requirements, weakening the Plan's effectiveness.