Greater Cambridge Local Plan: Proposed Submission

APC requests deletion of Policy S/GF and its Policies Map allocation, and modification
of Policy S/DS and the housing trajectory to remove reliance on Grange Farm. These
changes are necessary because the allocation’s environmental acceptability, capacity
and infrastructure delivery have not been adequately demonstrated.
The Councils should correct the inconsistencies in the site-selection and Sustainability
Appraisal evidence and reassess reasonable alternatives, including suitable
intensification, earlier delivery at existing allocations and additional small sites. That
assessment should establish whether further provision is needed, taking account of
remaining housing headroom, and inform the amendments required to achieve a
justified and effective development strategy.
Without prejudice to that primary position, if Grange Farm is retained, APC seeks the
following amendments to Policy S/GF and its supporting allocation diagram/spatial
framework plan:
• Require an evidenced land-use budget and capacity assessment accounting for
infrastructure and environmental safeguards. Amend the allocation’s capacity,
boundary and housing trajectory accordingly, so that the assumed housing
contribution reflects what can realistically be accommodated.
• Specify landscape buffers, retained open land, building-height limits and longterm
management measures to conserve the affected heritage assets and their
settings. These must include a substantially wider Roman Road buffer and
substantial open land behind 8 Cambridge Road, and address the barrow
cemetery, Worsted Lodge Farmhouse, Great and Little Abington Conservation
Area and Grange Farmhouse.
• Require CSET Phase 2 and its extension into Grange Farm, together with funded
public transport services, to be operational before first occupation. Delete the
exception permitting reliance on temporary public transport arrangements, to
prevent occupation without the permanent connection on which the allocation
depends.
• Require a costed and funded transport infrastructure delivery strategy, identifying
delivery responsibilities, programmes and triggers for critical and essential works.
Establish measurable trip-budget thresholds, funded corrective measures and
enforceable occupation controls compatible with the allocation’s capacity and
trajectory.
• Prohibit occupation of any phase until sufficient sustainable water supply capacity
and the necessary infrastructure are available, confirmed in consultation with
Cambridge Water and the Environment Agency. Require the phasing plan to
identify reliance on the Grafham Transfer and Fens Reservoir, or an equivalent
sustainable alternative, so that occupation does not exceed available supply.
• Require a deliverable wastewater strategy with the first planning application. Any
on-site discharge to ground must be supported by hydrogeological assessment
and modelling demonstrating protection of the aquifer, public water supplies and
River Granta, and a realistic prospect of obtaining the necessary permit.
Otherwise, an off-site solution must be secured. Occupation must await
operational infrastructure with agreed ownership, management and monitoring
arrangements in place.

Policy S/GF: Land adjacent to A11 and A1307 at Grange Farm Greater Cambridge Local Plan: Proposed Submission and Policy S/DS Development Strategy
Regulation 19 of the Town and Country Planning (Local Planning) (England) Regulations 2012

Introduction
1. We are instructed by Abington Parish Council and lodge our client’s formal objection to the
Regulation 19 Consultation to the proposed Plan and Policies S/GF: Land adjacent to A11 and
A1307 at Grange Farm in the Greater Cambridge Local Plan, and Policy S/DS Development
Strategy. The Parish Council comprises of councillors elected to represent the approximately 1,500 residents of Great Abington and Little Abington and improve their quality of life.

2. The Parish Council has been supported by Save Abington Village Environment (SAVE)1 through financial contributions for the legal team and the five technical experts whose reports support these objections. SAVE is submitting their own objection in support of the Parish
Council’s objection.

3. The Parish Council’s independent expert reports address the following matters and are referenced as indicated:
a. Planning Matters and Evidence Basis – Steven Stroud MRPTI, James Bailey Planning [JB]
b. Landscape – Pete Leaver CMLI, Robert Davies John West Ltd [PL]
c. Transport - John Russell, CMILT, MCIHT, JR Transport Planning [JR]
d. Flood Risk and Hydrology – John Sutton BSc, MSc, GWP Hydrogeological Consultants [GWP]
e. Heritage – Dr Nicholas Doggett, FSA, MICfA, IHBC, Asset Heritage Consulting Ltd. [ND]

4. The expert reports are submitted as a bundle to accompany this letter; we would respectfully
ask that they are read in full.
5. The Parish Council requests to participate in the examination hearings to ensure local residents voices are represented at the EiP and subject to funding will instruct counsel and their experts to attend to assist the Inspectors at the EiP.

Objection to proposed Policy S/GF
6. The Parish Council objects to proposed Policy S/GF: Land adjacent to A11 and A1307 at
Grange Farm on the basis the Plan has not been prepared in accordance with legal and
procedural requirements and fails the legal requirement for soundness as set out in the 2024
National Planning Policy Framework (NPPF 2024). In summary the Plan is unsound because:
(1) The Plan is not justified in relation to high landscape harm incapable of mitigation:
(i) key evidence contains material inconsistencies and inaccuracies, including the Housing and Economic Land Availability Assessment (‘HELAA’ 2026), the
Sustainability Appraisal (‘SA’ 2026), the Development Strategy Topic Papers (2026), and the Site Allocations Topic Paper (2026) [JB/2/2.1-2.10]. These inconsistencies and omissions undermine the reliability of the assessment of scale of adverse impacts on this sensitive and vulnerable Cambridgeshire Chalk Hills Landscape comprising Grange Farm and include: -
a. The fact that the site was taken forward despite its ‘red’ HELAA score requires appropriate mitigation to be addressed in the Development Strategy and Sites
Topic Papers; however those papers do not adequately explain how the identified significant adverse impacts on the Chalk Hills Landscape could be mitigated [JB/2.3];
b. The 2026 Sustainability Appraisal (SA) fails to record the overall ‘red’ and significant negative impact rating for Landscape as set out in the HELAA. Instead, the SA
records the site as rating ‘amber’. As a consequence, the SA process is unreliable and inevitably has led to a downplay in respect of landscape impacts [JB/2.4-2.7];
c. The SA is inconsistent when defining the proposed area being assessed with a variation of 26.98 ha [JB/2.8] which impacts inter alia on site area for infrastructure, landscape and heritage mitigation measures;
d. The failure to justify selection of Grange Farm, a sensitive Chalk Hills Landscape
against other less sensitive sites. The Council’s own evidence is that the Chalk Hills
Landscape is a sensitive landscape typology more vulnerable to change and so the
high adverse harm expected from this allocation potentially cannot be mitigated
[JB/2.9-2.15;];
e. Significant adverse effects on the landscape will remain with the consequence that
the strategic allocation cannot be delivered in accordance with the policy
requirement within S/GF (paragraph 12) which requires all phases of
masterplanning and design to: “Ensure the development respects, protects and
enhances the landscape within its rural setting, including surrounding chalk hills
and woodlands” [JB/2.16]. As the Landscape expert Pete Leaver records:
There is no evidence that during the decision making process, regard was given to
the landscape and visual sensitivities of the site within its landscape and visual
context. As a result, the allocation is inconsistent with other local plan policies and
with the National Planning Policy Framework. [PL/1.1.11]
The harm goes to the heart of the established settlement pattern of Cambridge: -
The landscape south and east of Cambridge is characterised by a pattern of
development in valley bottoms and lower valley slopes, with chalk uplands left
clear of development. The development parcel of the allocation strays well into
these unsettled Chalk Hills. It represents an unprecedented and major departure
from the existing landscape pattern of Greater Cambridge and from the plan
area’s settlement pattern [PL/1.1.4].
The proposed allocation would cause adverse effects to key landscape
characteristics and landscape sensitivities, particularly of the Chalk Hills
landscape, as described in the Landscape Character Assessment. Development
would not contribute to landscape management guidance for the area. Major
adverse effects could not be mitigated by masterplanning, site layout or design
[PL/1.1.7].
The consequence is that the sensitive Chalk Hills Landscape Character cannot be
conserved, protected or enhanced as required by policy GP/LC [JB/3.2-3.7; PL/1.1.4].
(2) Critical transport Infrastructure delivery is uncertain/ may be undeliverable
(i) There are fundamental funding and delivery risks for critical transport infrastructure
including (i) the making of the Transport and Works Act Order for the Cambridge South
East Transport (CSET) and funding gaps [JR/3.40-3.43] and (ii) the delivery of inter alia a
new bridge over the A11 from the CSET travel hub into the site necessary to demonstrate
a sustainable and deliverable transport strategy to support the allocation [JB/2.27;
JR/3.44]. This matters because there are presently significant constraints on walking and
cycling from the site to employment facilities and services [JR/3.7-3.20; 3.46] and limited
public (bus) transport [JR/3.21-3.23’ 3.47] and existing road network constraints [JR/3.24-
3.20; 3.49] and road safety considerations [JR/3.31-3.37]. As the transport expert John
Russell records, the uncertainty over delivery of CSET and the extension are such that
without this essential infrastructure the traffic impacts would mean the allocation is
unsustainable [JR/3.52]: -
Given the scale of the Site and the existing limitations of the transport network, any
significant delay to, or failure to deliver CSET would fundamentally undermine the
transport sustainability of Grange Farm.
(ii) The developer-led CSET extension into the Grange Farm site is critical to delivery of a
sustainable transport strategy [JR/3.52] but relies on uncertain developer funding
where site constraints may reduce capacity and so must be tested against viability and
therefore deliverability of the extension is unconfirmed [JB/2.28-2.31; 3.19-3.21; 4.7-
4.13]. The CSET and CSET extension uncertainties present a substantial risk to
delivery of the site as James Bailey records [JB/4.13].
If either scheme is substantially delayed or does not proceed, the basis for allocating
Grange Farm as a sustainable new settlement would be fundamentally undermined.
Any smaller scheme would require a fresh assessment of its transport impacts,
infrastructure requirements, viability and ability to deliver the Plan’s strategic
objectives. On the evidence presently available, the necessary delivery case has not
been demonstrated and the allocation should be deleted.
(3) Heritage harm
(i) The amber HELAA rating for Designated Heritage Assets comprising inter alia Worsted
Street, a Scheduled Ancient Monument Roman road and a Bronze age Barrow
Cemetery SAM [ND/1.2]2 has not been fully considered [JB/2.17-2.19] in
circumstances where Councils’ recent HIA 2026 identifies the risk of significant residual
heritage harm as high and undermines the amber rating of risks as capable of
mitigation [JB/2.21-2.24]. The heritage expert Dr Doggett concurs with the HIA on high residual risks to the Worsted Street principally because suggested ‘buffer’ to open land
to the south is insufficient to preserve the significance of the setting of the Roman Road
as a SAM [JB/3.8-3.9. ND/3.10-3.11].
(4) Loss of BMV farm land
(i) When tested against the 2024 NPPF and the new Defra maps which indicate that
almost all of the farm land is BMV land (Grade 2 or Grade 3a) the site selection is not
justified in national planning policy terms [JB/3.12-3.18].
(5) Risk to Water resources
(i) Finally the high-risk ground water environment (a chalk aquifer and chalk stream) at
Grange Farm gives rise to significant uncertainties for water resource safety,
uncertainties over costs for waste treatment and surface water discharge measures
which have not been adequately explored in accordance with EA guidance and puts
the groundwater environment at significant risk and uncertainty [JB/3.23-3.26; GWP,
pgs 1-3]. At an absolute minimum stringent water safety conditions need to be
incorporated into the policy if it proceeds in the submission draft plan as explained by
GWP.
Objection to proposed Policy S/DS
7. The Plan is unsound because of the over reliance on new settlements, including Grange
Farm, for delivery of the Councils’ Development Strategy (Policy S/DS) where a significant
proportion of the housing is likely to come forward after the plan period and therefore poses
a significant risk to the Councils’ development strategy [JB/2.32]. Specifically, the Grange
Farm trajectory is 2,550 by 2045 but this is uncertain given the critical infrastructure relied
upon to deliver such housing including CSET and the CSET extension [JB/2.33-2.34].
8. This uncertainty undermines the strategy where other allocations including Cambourne
North which will benefit from the recent TWAO for C-to-C busway warrant reconsideration
[JB/2.35-2.38] along with reconsideration of smaller sites and increased densities at existing
allocations [JB/2.39-2.43].
Conclusion
9. As Steven Stroud explains, the evidence identifies fundamental weaknesses in the justification
for allocating Grange Farm and in the assumptions supporting its capacity and delivery. The Councils have not demonstrated that the proposed settlement can accommodate the
necessary environmental safeguards while providing the homes, infrastructure and services
upon which its sustainability depends.
10. The consequence is that Policy S/GF has significant delivery risks that undermine the overall
housing delivery strategy in circumstances where alternatives have not been fully explored.
11. For these reasons, the Parish Council respectfully requests deletion of Policy S/GF and the
associated allocation from the Policies Map. The Councils are urged to reassess the housing
supply position, including the remaining headroom, and test whether any additional provision
which is needed to maintain a sound and sufficiently flexible strategy can be secured through
the reasonable alternatives identified in the James Bailey representations.

APC requests deletion of Policy S/GF and its Policies Map allocation, and modification of Policy S/DS and the housing trajectory to remove reliance on Grange Farm. These changes are necessary because the allocation’s environmental acceptability, capacity and infrastructure delivery have not been adequately demonstrated.
The Councils should correct the inconsistencies in the site-selection and Sustainability Appraisal evidence and reassess reasonable alternatives, including suitable intensification, earlier delivery at existing allocations and additional small sites. That assessment should establish whether further provision is needed, taking account of remaining housing headroom, and inform the amendments required to achieve a justified and effective development strategy.
Without prejudice to that primary position, if Grange Farm is retained, APC seeks the following amendments to Policy S/GF and its supporting allocation diagram/spatial framework plan:
• Require an evidenced land-use budget and capacity assessment accounting for infrastructure and environmental safeguards. Amend the allocation’s capacity, boundary and housing trajectory accordingly, so that the assumed housing contribution reflects what can realistically be accommodated.
• Specify landscape buffers, retained open land, building-height limits and long-term management measures to conserve the affected heritage assets and their settings. These must include a substantially wider Roman Road buffer and substantial open land behind 8 Cambridge Road, and address the barrow cemetery, Worsted Lodge Farmhouse, Great and Little Abington Conservation Area and Grange Farmhouse.
• Require CSET Phase 2 and its extension into Grange Farm, together with funded public transport services, to be operational before first occupation. Delete the exception permitting reliance on temporary public transport arrangements, to prevent occupation without the permanent connection on which the allocation depends.
• Require a costed and funded transport infrastructure delivery strategy, identifying delivery responsibilities, programmes and triggers for critical and essential works. Establish measurable trip-budget thresholds, funded corrective measures and enforceable occupation controls compatible with the allocation’s capacity and trajectory.
• Prohibit occupation of any phase until sufficient sustainable water supply capacity and the necessary infrastructure are available, confirmed in consultation with Cambridge Water and the Environment Agency. Require the phasing plan to identify reliance on the Grafham Transfer and Fens Reservoir, or an equivalent sustainable alternative, so that occupation does not exceed available supply.
• Require a deliverable wastewater strategy with the first planning application. Any on-site discharge to ground must be supported by hydrogeological assessment and modelling demonstrating protection of the aquifer, public water supplies and River Granta, and a realistic prospect of obtaining the necessary permit. Otherwise, an off-site solution must be secured. Occupation must await operational infrastructure with agreed ownership, management and monitoring arrangements in place.

Policy S/GF: Land adjacent to A11 and A1307 at Grange Farm Greater Cambridge Local Plan: Proposed Submission and Policy S/DS Development Strategy
Regulation 19 of the Town and Country Planning (Local Planning) (England) Regulations 2012

Introduction
1. We are instructed by Abington Parish Council and lodge our client’s formal objection to the
Regulation 19 Consultation to the proposed Plan and Policies S/GF: Land adjacent to A11 and
A1307 at Grange Farm in the Greater Cambridge Local Plan, and Policy S/DS Development
Strategy. The Parish Council comprises of councillors elected to represent the approximately 1,500 residents of Great Abington and Little Abington and improve their quality of life.

2. The Parish Council has been supported by Save Abington Village Environment (SAVE)1 through financial contributions for the legal team and the five technical experts whose reports support these objections. SAVE is submitting their own objection in support of the Parish
Council’s objection.

3. The Parish Council’s independent expert reports address the following matters and are referenced as indicated:
a. Planning Matters and Evidence Basis – Steven Stroud MRPTI, James Bailey Planning [JB]
b. Landscape – Pete Leaver CMLI, Robert Davies John West Ltd [PL]
c. Transport - John Russell, CMILT, MCIHT, JR Transport Planning [JR]
d. Flood Risk and Hydrology – John Sutton BSc, MSc, GWP Hydrogeological Consultants [GWP]
e. Heritage – Dr Nicholas Doggett, FSA, MICfA, IHBC, Asset Heritage Consulting Ltd. [ND]

4. The expert reports are submitted as a bundle to accompany this letter; we would respectfully
ask that they are read in full.
5. The Parish Council requests to participate in the examination hearings to ensure local residents voices are represented at the EiP and subject to funding will instruct counsel and their experts to attend to assist the Inspectors at the EiP.

Objection to proposed Policy S/GF
6. The Parish Council objects to proposed Policy S/GF: Land adjacent to A11 and A1307 at
Grange Farm on the basis the Plan has not been prepared in accordance with legal and
procedural requirements and fails the legal requirement for soundness as set out in the 2024
National Planning Policy Framework (NPPF 2024). In summary the Plan is unsound because:
(1) The Plan is not justified in relation to high landscape harm incapable of mitigation:
(i) key evidence contains material inconsistencies and inaccuracies, including the Housing and Economic Land Availability Assessment (‘HELAA’ 2026), the
Sustainability Appraisal (‘SA’ 2026), the Development Strategy Topic Papers (2026), and the Site Allocations Topic Paper (2026) [JB/2/2.1-2.10]. These inconsistencies and omissions undermine the reliability of the assessment of scale of adverse impacts on this sensitive and vulnerable Cambridgeshire Chalk Hills Landscape comprising Grange Farm and include: -
a. The fact that the site was taken forward despite its ‘red’ HELAA score requires appropriate mitigation to be addressed in the Development Strategy and Sites
Topic Papers; however those papers do not adequately explain how the identified significant adverse impacts on the Chalk Hills Landscape could be mitigated [JB/2.3];
b. The 2026 Sustainability Appraisal (SA) fails to record the overall ‘red’ and significant negative impact rating for Landscape as set out in the HELAA. Instead, the SA
records the site as rating ‘amber’. As a consequence, the SA process is unreliable and inevitably has led to a downplay in respect of landscape impacts [JB/2.4-2.7];
c. The SA is inconsistent when defining the proposed area being assessed with a variation of 26.98 ha [JB/2.8] which impacts inter alia on site area for infrastructure, landscape and heritage mitigation measures;
d. The failure to justify selection of Grange Farm, a sensitive Chalk Hills Landscape
against other less sensitive sites. The Council’s own evidence is that the Chalk Hills
Landscape is a sensitive landscape typology more vulnerable to change and so the
high adverse harm expected from this allocation potentially cannot be mitigated
[JB/2.9-2.15;];
e. Significant adverse effects on the landscape will remain with the consequence that
the strategic allocation cannot be delivered in accordance with the policy
requirement within S/GF (paragraph 12) which requires all phases of
masterplanning and design to: “Ensure the development respects, protects and
enhances the landscape within its rural setting, including surrounding chalk hills
and woodlands” [JB/2.16]. As the Landscape expert Pete Leaver records:
There is no evidence that during the decision making process, regard was given to
the landscape and visual sensitivities of the site within its landscape and visual
context. As a result, the allocation is inconsistent with other local plan policies and
with the National Planning Policy Framework. [PL/1.1.11]
The harm goes to the heart of the established settlement pattern of Cambridge: -
The landscape south and east of Cambridge is characterised by a pattern of
development in valley bottoms and lower valley slopes, with chalk uplands left
clear of development. The development parcel of the allocation strays well into
these unsettled Chalk Hills. It represents an unprecedented and major departure
from the existing landscape pattern of Greater Cambridge and from the plan
area’s settlement pattern [PL/1.1.4].
The proposed allocation would cause adverse effects to key landscape
characteristics and landscape sensitivities, particularly of the Chalk Hills
landscape, as described in the Landscape Character Assessment. Development
would not contribute to landscape management guidance for the area. Major
adverse effects could not be mitigated by masterplanning, site layout or design
[PL/1.1.7].
The consequence is that the sensitive Chalk Hills Landscape Character cannot be
conserved, protected or enhanced as required by policy GP/LC [JB/3.2-3.7; PL/1.1.4].
(2) Critical transport Infrastructure delivery is uncertain/ may be undeliverable
(i) There are fundamental funding and delivery risks for critical transport infrastructure
including (i) the making of the Transport and Works Act Order for the Cambridge South
East Transport (CSET) and funding gaps [JR/3.40-3.43] and (ii) the delivery of inter alia a
new bridge over the A11 from the CSET travel hub into the site necessary to demonstrate
a sustainable and deliverable transport strategy to support the allocation [JB/2.27;
JR/3.44]. This matters because there are presently significant constraints on walking and
cycling from the site to employment facilities and services [JR/3.7-3.20; 3.46] and limited
public (bus) transport [JR/3.21-3.23’ 3.47] and existing road network constraints [JR/3.24-
3.20; 3.49] and road safety considerations [JR/3.31-3.37]. As the transport expert John
Russell records, the uncertainty over delivery of CSET and the extension are such that
without this essential infrastructure the traffic impacts would mean the allocation is
unsustainable [JR/3.52]: -
Given the scale of the Site and the existing limitations of the transport network, any
significant delay to, or failure to deliver CSET would fundamentally undermine the
transport sustainability of Grange Farm.
(ii) The developer-led CSET extension into the Grange Farm site is critical to delivery of a
sustainable transport strategy [JR/3.52] but relies on uncertain developer funding
where site constraints may reduce capacity and so must be tested against viability and
therefore deliverability of the extension is unconfirmed [JB/2.28-2.31; 3.19-3.21; 4.7-
4.13]. The CSET and CSET extension uncertainties present a substantial risk to
delivery of the site as James Bailey records [JB/4.13].
If either scheme is substantially delayed or does not proceed, the basis for allocating
Grange Farm as a sustainable new settlement would be fundamentally undermined.
Any smaller scheme would require a fresh assessment of its transport impacts,
infrastructure requirements, viability and ability to deliver the Plan’s strategic
objectives. On the evidence presently available, the necessary delivery case has not
been demonstrated and the allocation should be deleted.
(3) Heritage harm
(i) The amber HELAA rating for Designated Heritage Assets comprising inter alia Worsted
Street, a Scheduled Ancient Monument Roman road and a Bronze age Barrow
Cemetery SAM [ND/1.2]2 has not been fully considered [JB/2.17-2.19] in
circumstances where Councils’ recent HIA 2026 identifies the risk of significant residual
heritage harm as high and undermines the amber rating of risks as capable of
mitigation [JB/2.21-2.24]. The heritage expert Dr Doggett concurs with the HIA on high residual risks to the Worsted Street principally because suggested ‘buffer’ to open land
to the south is insufficient to preserve the significance of the setting of the Roman Road
as a SAM [JB/3.8-3.9. ND/3.10-3.11].
(4) Loss of BMV farm land
(i) When tested against the 2024 NPPF and the new Defra maps which indicate that
almost all of the farm land is BMV land (Grade 2 or Grade 3a) the site selection is not
justified in national planning policy terms [JB/3.12-3.18].
(5) Risk to Water resources
(i) Finally the high-risk ground water environment (a chalk aquifer and chalk stream) at
Grange Farm gives rise to significant uncertainties for water resource safety,
uncertainties over costs for waste treatment and surface water discharge measures
which have not been adequately explored in accordance with EA guidance and puts
the groundwater environment at significant risk and uncertainty [JB/3.23-3.26; GWP,
pgs 1-3]. At an absolute minimum stringent water safety conditions need to be
incorporated into the policy if it proceeds in the submission draft plan as explained by
GWP.
Objection to proposed Policy S/DS
7. The Plan is unsound because of the over reliance on new settlements, including Grange
Farm, for delivery of the Councils’ Development Strategy (Policy S/DS) where a significant
proportion of the housing is likely to come forward after the plan period and therefore poses
a significant risk to the Councils’ development strategy [JB/2.32]. Specifically, the Grange
Farm trajectory is 2,550 by 2045 but this is uncertain given the critical infrastructure relied
upon to deliver such housing including CSET and the CSET extension [JB/2.33-2.34].
8. This uncertainty undermines the strategy where other allocations including Cambourne
North which will benefit from the recent TWAO for C-to-C busway warrant reconsideration
[JB/2.35-2.38] along with reconsideration of smaller sites and increased densities at existing
allocations [JB/2.39-2.43].
Conclusion
9. As Steven Stroud explains, the evidence identifies fundamental weaknesses in the justification
for allocating Grange Farm and in the assumptions supporting its capacity and delivery. The Councils have not demonstrated that the proposed settlement can accommodate the
necessary environmental safeguards while providing the homes, infrastructure and services
upon which its sustainability depends.
10. The consequence is that Policy S/GF has significant delivery risks that undermine the overall
housing delivery strategy in circumstances where alternatives have not been fully explored.
11. For these reasons, the Parish Council respectfully requests deletion of Policy S/GF and the
associated allocation from the Policies Map. The Councils are urged to reassess the housing
supply position, including the remaining headroom, and test whether any additional provision
which is needed to maintain a sound and sufficiently flexible strategy can be secured through
the reasonable alternatives identified in the James Bailey representations.

APC requests deletion of Policy S/GF and its Policies Map allocation, and modification
of Policy S/DS and the housing trajectory to remove reliance on Grange Farm. These
changes are necessary because the allocation’s environmental acceptability, capacity
and infrastructure delivery have not been adequately demonstrated.
The Councils should correct the inconsistencies in the site-selection and Sustainability
Appraisal evidence and reassess reasonable alternatives, including suitable
intensification, earlier delivery at existing allocations and additional small sites. That
assessment should establish whether further provision is needed, taking account of
remaining housing headroom, and inform the amendments required to achieve a
justified and effective development strategy.
Without prejudice to that primary position, if Grange Farm is retained, APC seeks the
following amendments to Policy S/GF and its supporting allocation diagram/spatial
framework plan:
• Require an evidenced land-use budget and capacity assessment accounting for
infrastructure and environmental safeguards. Amend the allocation’s capacity,
boundary and housing trajectory accordingly, so that the assumed housing
contribution reflects what can realistically be accommodated.
• Specify landscape buffers, retained open land, building-height limits and longterm
management measures to conserve the affected heritage assets and their
settings. These must include a substantially wider Roman Road buffer and
substantial open land behind 8 Cambridge Road, and address the barrow
cemetery, Worsted Lodge Farmhouse, Great and Little Abington Conservation
Area and Grange Farmhouse.
• Require CSET Phase 2 and its extension into Grange Farm, together with funded
public transport services, to be operational before first occupation. Delete the
exception permitting reliance on temporary public transport arrangements, to
prevent occupation without the permanent connection on which the allocation
depends.
• Require a costed and funded transport infrastructure delivery strategy, identifying
delivery responsibilities, programmes and triggers for critical and essential works.
Establish measurable trip-budget thresholds, funded corrective measures and
enforceable occupation controls compatible with the allocation’s capacity and
trajectory.
• Prohibit occupation of any phase until sufficient sustainable water supply capacity
and the necessary infrastructure are available, confirmed in consultation with
Cambridge Water and the Environment Agency. Require the phasing plan to
identify reliance on the Grafham Transfer and Fens Reservoir, or an equivalent
sustainable alternative, so that occupation does not exceed available supply.
• Require a deliverable wastewater strategy with the first planning application. Any
on-site discharge to ground must be supported by hydrogeological assessment
and modelling demonstrating protection of the aquifer, public water supplies and
River Granta, and a realistic prospect of obtaining the necessary permit.
Otherwise, an off-site solution must be secured. Occupation must await
operational infrastructure with agreed ownership, management and monitoring
arrangements in place.

Policy S/GF: Land adjacent to A11 and A1307 at Grange Farm Greater Cambridge Local Plan: Proposed Submission and Policy S/DS Development Strategy
Regulation 19 of the Town and Country Planning (Local Planning) (England) Regulations 2012

Introduction
1. We are instructed by Abington Parish Council and lodge our client’s formal objection to the
Regulation 19 Consultation to the proposed Plan and Policies S/GF: Land adjacent to A11 and
A1307 at Grange Farm in the Greater Cambridge Local Plan, and Policy S/DS Development
Strategy. The Parish Council comprises of councillors elected to represent the approximately 1,500 residents of Great Abington and Little Abington and improve their quality of life.

2. The Parish Council has been supported by Save Abington Village Environment (SAVE)1 through financial contributions for the legal team and the five technical experts whose reports support these objections. SAVE is submitting their own objection in support of the Parish
Council’s objection.

3. The Parish Council’s independent expert reports address the following matters and are referenced as indicated:
a. Planning Matters and Evidence Basis – Steven Stroud MRPTI, James Bailey Planning [JB]
b. Landscape – Pete Leaver CMLI, Robert Davies John West Ltd [PL]
c. Transport - John Russell, CMILT, MCIHT, JR Transport Planning [JR]
d. Flood Risk and Hydrology – John Sutton BSc, MSc, GWP Hydrogeological Consultants [GWP]
e. Heritage – Dr Nicholas Doggett, FSA, MICfA, IHBC, Asset Heritage Consulting Ltd. [ND]

4. The expert reports are submitted as a bundle to accompany this letter; we would respectfully
ask that they are read in full.
5. The Parish Council requests to participate in the examination hearings to ensure local residents voices are represented at the EiP and subject to funding will instruct counsel and their experts to attend to assist the Inspectors at the EiP.

Objection to proposed Policy S/GF
6. The Parish Council objects to proposed Policy S/GF: Land adjacent to A11 and A1307 at
Grange Farm on the basis the Plan has not been prepared in accordance with legal and
procedural requirements and fails the legal requirement for soundness as set out in the 2024
National Planning Policy Framework (NPPF 2024). In summary the Plan is unsound because:
(1) The Plan is not justified in relation to high landscape harm incapable of mitigation:
(i) key evidence contains material inconsistencies and inaccuracies, including the Housing and Economic Land Availability Assessment (‘HELAA’ 2026), the
Sustainability Appraisal (‘SA’ 2026), the Development Strategy Topic Papers (2026), and the Site Allocations Topic Paper (2026) [JB/2/2.1-2.10]. These inconsistencies and omissions undermine the reliability of the assessment of scale of adverse impacts on this sensitive and vulnerable Cambridgeshire Chalk Hills Landscape comprising Grange Farm and include: -
a. The fact that the site was taken forward despite its ‘red’ HELAA score requires appropriate mitigation to be addressed in the Development Strategy and Sites
Topic Papers; however those papers do not adequately explain how the identified significant adverse impacts on the Chalk Hills Landscape could be mitigated [JB/2.3];
b. The 2026 Sustainability Appraisal (SA) fails to record the overall ‘red’ and significant negative impact rating for Landscape as set out in the HELAA. Instead, the SA
records the site as rating ‘amber’. As a consequence, the SA process is unreliable and inevitably has led to a downplay in respect of landscape impacts [JB/2.4-2.7];
c. The SA is inconsistent when defining the proposed area being assessed with a variation of 26.98 ha [JB/2.8] which impacts inter alia on site area for infrastructure, landscape and heritage mitigation measures;
d. The failure to justify selection of Grange Farm, a sensitive Chalk Hills Landscape
against other less sensitive sites. The Council’s own evidence is that the Chalk Hills
Landscape is a sensitive landscape typology more vulnerable to change and so the
high adverse harm expected from this allocation potentially cannot be mitigated
[JB/2.9-2.15;];
e. Significant adverse effects on the landscape will remain with the consequence that
the strategic allocation cannot be delivered in accordance with the policy
requirement within S/GF (paragraph 12) which requires all phases of
masterplanning and design to: “Ensure the development respects, protects and
enhances the landscape within its rural setting, including surrounding chalk hills
and woodlands” [JB/2.16]. As the Landscape expert Pete Leaver records:
There is no evidence that during the decision making process, regard was given to
the landscape and visual sensitivities of the site within its landscape and visual
context. As a result, the allocation is inconsistent with other local plan policies and
with the National Planning Policy Framework. [PL/1.1.11]
The harm goes to the heart of the established settlement pattern of Cambridge: -
The landscape south and east of Cambridge is characterised by a pattern of
development in valley bottoms and lower valley slopes, with chalk uplands left
clear of development. The development parcel of the allocation strays well into
these unsettled Chalk Hills. It represents an unprecedented and major departure
from the existing landscape pattern of Greater Cambridge and from the plan
area’s settlement pattern [PL/1.1.4].
The proposed allocation would cause adverse effects to key landscape
characteristics and landscape sensitivities, particularly of the Chalk Hills
landscape, as described in the Landscape Character Assessment. Development
would not contribute to landscape management guidance for the area. Major
adverse effects could not be mitigated by masterplanning, site layout or design
[PL/1.1.7].
The consequence is that the sensitive Chalk Hills Landscape Character cannot be
conserved, protected or enhanced as required by policy GP/LC [JB/3.2-3.7; PL/1.1.4].
(2) Critical transport Infrastructure delivery is uncertain/ may be undeliverable
(i) There are fundamental funding and delivery risks for critical transport infrastructure
including (i) the making of the Transport and Works Act Order for the Cambridge South
East Transport (CSET) and funding gaps [JR/3.40-3.43] and (ii) the delivery of inter alia a
new bridge over the A11 from the CSET travel hub into the site necessary to demonstrate
a sustainable and deliverable transport strategy to support the allocation [JB/2.27;
JR/3.44]. This matters because there are presently significant constraints on walking and
cycling from the site to employment facilities and services [JR/3.7-3.20; 3.46] and limited
public (bus) transport [JR/3.21-3.23’ 3.47] and existing road network constraints [JR/3.24-
3.20; 3.49] and road safety considerations [JR/3.31-3.37]. As the transport expert John
Russell records, the uncertainty over delivery of CSET and the extension are such that
without this essential infrastructure the traffic impacts would mean the allocation is
unsustainable [JR/3.52]: -
Given the scale of the Site and the existing limitations of the transport network, any
significant delay to, or failure to deliver CSET would fundamentally undermine the
transport sustainability of Grange Farm.
(ii) The developer-led CSET extension into the Grange Farm site is critical to delivery of a
sustainable transport strategy [JR/3.52] but relies on uncertain developer funding
where site constraints may reduce capacity and so must be tested against viability and
therefore deliverability of the extension is unconfirmed [JB/2.28-2.31; 3.19-3.21; 4.7-
4.13]. The CSET and CSET extension uncertainties present a substantial risk to
delivery of the site as James Bailey records [JB/4.13].
If either scheme is substantially delayed or does not proceed, the basis for allocating
Grange Farm as a sustainable new settlement would be fundamentally undermined.
Any smaller scheme would require a fresh assessment of its transport impacts,
infrastructure requirements, viability and ability to deliver the Plan’s strategic
objectives. On the evidence presently available, the necessary delivery case has not
been demonstrated and the allocation should be deleted.
(3) Heritage harm
(i) The amber HELAA rating for Designated Heritage Assets comprising inter alia Worsted
Street, a Scheduled Ancient Monument Roman road and a Bronze age Barrow
Cemetery SAM [ND/1.2]2 has not been fully considered [JB/2.17-2.19] in
circumstances where Councils’ recent HIA 2026 identifies the risk of significant residual
heritage harm as high and undermines the amber rating of risks as capable of
mitigation [JB/2.21-2.24]. The heritage expert Dr Doggett concurs with the HIA on high residual risks to the Worsted Street principally because suggested ‘buffer’ to open land
to the south is insufficient to preserve the significance of the setting of the Roman Road
as a SAM [JB/3.8-3.9. ND/3.10-3.11].
(4) Loss of BMV farm land
(i) When tested against the 2024 NPPF and the new Defra maps which indicate that
almost all of the farm land is BMV land (Grade 2 or Grade 3a) the site selection is not
justified in national planning policy terms [JB/3.12-3.18].
(5) Risk to Water resources
(i) Finally the high-risk ground water environment (a chalk aquifer and chalk stream) at
Grange Farm gives rise to significant uncertainties for water resource safety,
uncertainties over costs for waste treatment and surface water discharge measures
which have not been adequately explored in accordance with EA guidance and puts
the groundwater environment at significant risk and uncertainty [JB/3.23-3.26; GWP,
pgs 1-3]. At an absolute minimum stringent water safety conditions need to be
incorporated into the policy if it proceeds in the submission draft plan as explained by
GWP.
Objection to proposed Policy S/DS
7. The Plan is unsound because of the over reliance on new settlements, including Grange
Farm, for delivery of the Councils’ Development Strategy (Policy S/DS) where a significant
proportion of the housing is likely to come forward after the plan period and therefore poses
a significant risk to the Councils’ development strategy [JB/2.32]. Specifically, the Grange
Farm trajectory is 2,550 by 2045 but this is uncertain given the critical infrastructure relied
upon to deliver such housing including CSET and the CSET extension [JB/2.33-2.34].
8. This uncertainty undermines the strategy where other allocations including Cambourne
North which will benefit from the recent TWAO for C-to-C busway warrant reconsideration
[JB/2.35-2.38] along with reconsideration of smaller sites and increased densities at existing
allocations [JB/2.39-2.43].
Conclusion
9. As Steven Stroud explains, the evidence identifies fundamental weaknesses in the justification
for allocating Grange Farm and in the assumptions supporting its capacity and delivery. The Councils have not demonstrated that the proposed settlement can accommodate the
necessary environmental safeguards while providing the homes, infrastructure and services
upon which its sustainability depends.
10. The consequence is that Policy S/GF has significant delivery risks that undermine the overall
housing delivery strategy in circumstances where alternatives have not been fully explored.
11. For these reasons, the Parish Council respectfully requests deletion of Policy S/GF and the
associated allocation from the Policies Map. The Councils are urged to reassess the housing
supply position, including the remaining headroom, and test whether any additional provision
which is needed to maintain a sound and sufficiently flexible strategy can be secured through
the reasonable alternatives identified in the James Bailey representations.