Greater Cambridge Local Plan: Proposed Submission

Paragraph 3 of Draft Local Plan Policy I/ST currently states:

“ …This will be achieved through direct improvements, securing direct commitments through planning conditions and/or contributions through planning obligations, community infrastructure levy or its successor, to address transport infrastructure in the wider area including across the district boundary, services or behavioural change measures to encourage the use of sustainable modes of transport…”

In this draft, it is not entirely clear that the term ‘services’ attaches to ‘transport’, and shared transport is not mentioned. In addition, since the measures listed are only effective in combination, not individually, ‘or’ at the end of the list should be ‘and’.

This should therefore be amended to:

“ …This will be achieved through direct improvements, securing direct commitments through planning conditions and/or contributions through planning obligations, community infrastructure levy or its successor, to address transport infrastructure in the wider area including across the district boundary, public and shared transport services, and behavioural change measures to encourage the use of sustainable modes of transport…”

The supporting information should also set out that ‘transport infrastructure’ in the Policy text encompasses infrastructure for people walking and wheeling, as the need for good infrastructure for pedestrians is too often overlooked.

The Plan is not sound because Policy I/ST is not effective. Policy I/ST does not clearly state that contributions through planning obligations and/or a Community Infrastructure Levy or its successor will be sought for public transport services and shared transport services (which include shared use cycles, car clubs and ride-sharing). By contrast, adopted Cambridge Local Plan Policy 85 expressly identifies public transport, separately from transport infrastructure, as a category towards which planning obligations may be sought.

The Plan relies on a substantial increase in sustainable travel to enable its growth strategy to be accommodated without severe residual cumulative impacts on the road network (NPPF, December 2024, paragraph 116) and to provide a genuine choice of transport modes (NPPF, December 2024, paragraph 110). However, the Plan does not set out any new revenue funding to support an expanded bus network and schedules, and expanded shared transport provision at a level that ensures Travel Plan targets for mode shares and, where specified, trip budgets for car travel are sustained over the long term. Infrastructure alone cannot provide an effective alternative to private car travel: ongoing services are also required.

Policy I/ST should therefore provide a clear mechanism for securing such services through planning obligations and a Community Infrastructure Levy to support the Plan's sustainable transport objectives.

The following changes need to be made to Policy I/ST:

Section 2.e. should have an additional sub-clause:
iv. Specifying which streets will facilitate safe, direct and efficient bus operation, with bus priority measures (i.e. bus lanes or gates) where needed and good visibility and access, free of unnecessary deflections and parked vehicles.

Section 2.f. should have an additional sub-clause:
v. The streets intended for use by buses will be identified at the outset, in line with 2.e.iv. above.

Then in addition:

LTN1/24, referred to in Policy I/ST’s supporting information, gives general guidance “for supporting and prioritising buses and their passengers within an integrated road network” to which “Local authorities are expected to demonstrate that they have given due consideration … when designing schemes that qualify for dedicated Government funding. [LTN1/24, p8]

Whilst LTN1/24 links to two documents on “Existing guidance on planning for buses in new developments” [LTN1/24, pp17/18] the first, from Stagecoach is no longer available, having been superseded by Bus Services & New Residential Developments Second Edition January 2025 [Go-Ahead, Stagecoach and Bus Centre of Excellence, January 2025].

This, and Buses in Urban Developments [Chartered Institution of Highways and Transportation, January 2018] referenced in LTN1/24, should be referred to directly in the supporting information to Policy I/ST: Sustainable transport and connectivity, as enshrining principles whose observance will be required by Greater Cambridge Shared Planning, for new residential developments to gain approval.

Subsequent pages of LTN1/24 give flow charts on “Problem identification” identifying “potential bus user priority solutions”, "Asess [sic] the road or street to determine its desired environment” [LTN1/24, pp19-21] which are not specific to new developments.

For new developments “Problem identification” should be irrelevant as excellent planning and design, informed by best practice in other LPA areas, with input from bus operator professionals, in collaboration with the Transport and Highway Authorities, will have prevented the occurrence of problems.

There is a need to include a requirement to collaborate at the pre-planning stage with bus operators to ensure that initial highway design specifies which streets will facilitate safe, direct and efficient bus operation.

Policy I/ST: Sustainable transport and connectivity should reference best practice as exemplified in Bus Services & New Residential Developments Second Edition January 2025 (BS&NRD) [Go-Ahead, Stagecoach and Bus Centre of Excellence, January 2025], and Buses in Urban Developments (BUD) [Chartered Institution of Highways and Transportation, January 2018] which would include bus permeability as an essential part of planning the road network, not as a retro-fit.

The avoidance of gratuitous curves [BUD, p24] and tight bends with poor visibility [BS&NRD, p5/PDFp4] on a planned bus route should be explicitly referenced.

The Policy should also reference the potential for pairs of distributor roads in new developments to be linked with a modal filter (bus/cycle section) to ease bus permeability. [BUD, p29 fig 26; BS&NRD, p9/PDFp4, fig9].

There is also a need to include a requirement for developers to work with the Highway and Transport Authorities to ensure that bus stops identified in planning applications are registered on the NaPTAN database when constructed so that they are ready for use the moment bus services start to operate.

Policy I/ST is unsound because it is not effective. The Plan depends on increased use of public transport, including buses, to reduce reliance on the private car. However, Policy I/ST does not set sufficiently clear requirements to ensure that residential development is designed from the outset to enable the operation of high-quality, high-frequency bus services. In particular, it does not require bus permeability, routing and infrastructure to be properly considered at the location, masterplanning and detailed-design stages. Without such requirements, developments may be designed in ways that constrain the delivery of direct, efficient and frequent bus services, making the Plan’s intended modal shift and reduction in car reliance more difficult to achieve. The policy thereby fails to provide an effective mechanism for securing the development patterns and highway infrastructure needed to deliver the transport outcomes on which the Plan’s development strategy depends.

Policy I/ST: Sustainable transport and connectivity states (inter alia) that:

(2.) development should … (2.e.) Maximise the incorporation of public and community transport (including demand responsive transport) into development by (2.e.i.) through the design embedding direct routes for and access to high quality public transport (2.e.ii.) Contributing to new or improved public transport routes, as necessary, that serve key destinations …
(2.f.) Ensure that where new road or road access is provided within or into the site … (2.f.i.) It secures the safety of all road users, utilising proportionate design solutions that slow the speed of traffic … (2.f.iii.) In appropriate circumstances, it restricts and/or affords lower priority to through access for general motor traffic, maintaining access for essential road users …

The Supporting information of Policy I/ST: Sustainable transport and connectivity states (inter alia) that:

10.8. New developments should deliver high quality places, designed around people … Where road access is provided through a site, generally the design should … facilitate easy access to public transport…
10.11. Major development will be expected to provide access to high quality public transport within reasonable walking distance of homes and jobs … Public transport infrastructure should be designed in accordance with LTN 1/24…
10.13. The policy sets out clear requirements regarding transport infrastructure provision and connectivity that is expected to address increased demand arising from new developments through the planning application process.

These paragraphs do not set sufficiently clear requirements to ensure that residential development is designed from the outset to enable high-quality, high-frequency bus services. Policy I/ST: Sustainable transport and connectivity and its supporting information require strengthening as they do not require bus permeability, routing and infrastructure to be properly considered at the location, masterplanning and detailed-design stages:

The Policy and supporting information lack a stipulation that bus provision should be properly considered at the outset – in development location, in master planning and in detailed design.

The Policy lacks a requirement that new developments’ transport infrastructure design must ensure permeability by high-quality, high-frequency bus services.

The reference to LTN 1/24 is insufficient to address this issue. LTN 1/24 provides guidance principally on bus-user priority and the identification of appropriate priority measures. Policy I/ST also needs to establish requirements concerning the design of new residential street networks.

The Local Plan's glossary should be amended to define the term "high quality public transport" so that it is not left open to interpretation:

High quality public transport: public transport that travels freely for the majority of its journey on an uncongested route or segregated corridor, and operates seven days a week with long operating hours, frequencies of 15 minutes or better at peak times and sufficiently late operating hours to provide a realistic public transport option outside conventional daytime working hours.

We note that Policy S/GF, paragraph 23, requires the delivery of:

“a comprehensive movement and connectivity network across the whole site that actively encourages and prioritises active travel and public transport providing connections across the site and to nearby villages and employment sites, and to key destinations within Cambridge, supported by residential, school and workplace travel planning. This outcome must be delivered by…..
v. A package of bus service improvements providing links to Granta Park, Babraham Research Campus, Genome Campus, Cambridge Biomedical Campus, North East Cambridge, Cambridge railway stations (including Cambridge South and Whittlesford Parkway station), Linton and Haverhill…”

And Policy S/CE (paragraph 17ciii) requires the delivery of:

“iii. A package of bus service enhancements, or other public transport modes where appropriate, connecting the site with North East Cambridge, West Cambridge, Cambridge City Centre, Cambridge railway station and the Cambridge Biomedical Campus...”

Policies S/CBN, S/CB, S/NST, S/WNT and S/BA, do not contain a similar requirement, however.

Policy S/CBN (paragraph 37d), Policy S/CB (paragraph 18), Policy S/NST (paragraph 23), Policy S/WNT (paragraph 22), and Policy S/BA (paragraph 21) should have an additional sub-clause as follows:

Contributing financially, as necessary, to new or improved high quality public transport routes, so that key destinations and centres of attraction, including Cambridge city centre, major centres of employment, places of education, community and leisure facilities, and key nodes in the public transport network (including mobility hubs) are served seven days a week, with long operating hours, frequencies of 15 minutes – or better – at peak times and a guaranteed last bus home from the first occupation of the development for a period of 10 years, or five years after the last occupation, whichever is later;

Paragraph 23 in Policy S/GF and paragraph 17ciii in Policy S/CE should be expanded to include requirements for bus transport to be high quality and available from first occupation:

“..so that key destinations and centres of attraction, including Cambridge city centre, major centres of employment, places of education, community and leisure facilities, and key nodes in the public transport network (including mobility hubs) are served seven days a week, with long operating hours, frequencies of 15 minutes – or better – at peak times and a guaranteed last bus home from the first occupation of the development for a period of 10 years, or five years after the last occupation, whichever is later.”

Lastly, Paragraph 1 of Policy I/ST: Sustainable transport and connectivity should be amended to read:

"Development must be designed through a vision-led approach which reflects the road user hierarchy, to: promote sustainable and active travel patterns from the first occupation of development; and provide users with a genuine choice of modes appropriate to the location and uses proposed from the first occupation of development, unless agreed otherwise with the relevant local authorities".

These modifications are necessary to make these Policies effective and to ensure that the Plan's strategy of reducing reliance on the private car is capable of being delivered in practice.

The Plan is not sound because Policies S/CBN: Cambourne North, S/CB: Cambourne, S/GF: Land adjacent to A11 and A1307 at Grange Farm, S/NST: Northstowe New Town, S/WNT: Waterbeach New Town, S/BA: Bourn Airfield New Village and S/CE: Cambridge East are neither effective, nor justified. These policies do not contain sufficiently clear or effective requirements to ensure that residents of major new developments have access to a high-quality public transport network and schedules from first occupation. In particular, they do not require bus services to operate to multiple key destinations, seven days a week, for sufficiently long operating hours, and at sufficiently frequent intervals at peak times, from the date of first occupation.

This is a significant omission because the Plan's strategy depends upon reducing reliance on the private car by providing residents with a genuine choice of sustainable modes of transport so that the growth the Plan sets out can be accommodated on the road network. A bus service which is unavailable when residents first need it cannot provide a genuine alternative to the private car. Attempting to retrofit a viable bus service after residents have moved in is also less likely to achieve the modal shift required by the Plan than providing that service from the date of first occupation, because residents moving into a new development without a viable public transport alternative are likely to establish car-dependent travel patterns – which will be resistant to change – from the outset.

The Plan is also unjustified because these policies do not contain sufficiently clear, measurable and effective requirements to secure the high-quality public transport provision that forms part of the Plan’s transport evidence. The Transport Evidence Report defines “High Quality Public Transport” (HQPT) as a bus service with a frequency of six or more buses per hour, or a rail service with four or more trains per hour. The transport evidence therefore is presumed to assess the ability of the transport network to accommodate the Plan's proposed growth on the basis that HQPT forms part of the sustainable transport offer. However, Policies S/CBN: Cambourne North, S/CB: Cambourne, Policy S/GF: Land adjacent to A11 and A1307 at Grange Farm, S/NST: Northstowe New Town, S/WNT: Waterbeach New Town, S/BA: Bourn Airfield New Village and S/CE: Cambridge East do not require a bus service of six or more buses per hour, or any other objectively measurable standard corresponding to the definition of HQPT used in the evidence base.

These deficiencies are particularly important given the scale of development proposed and the Plan's reliance on major public transport infrastructure. The Infrastructure Delivery Plan identifies major public transport interventions including the Cambourne to Cambridge bus corridor, the Waterbeach to Cambridge bus corridor and CSET Phase 2. These interventions will only achieve their intended purpose of reducing reliance on the private car if the bus services operating on them make bus travel a genuine option and provide an attractive alternative to driving. Infrastructure alone does not provide a sustainable transport choice: the early availability, frequency, hours of operation and reliability of the service are equally important.

For example, a busway serving major employment destinations will not provide a realistic alternative to car travel for medical, research, education or other shift workers if the service does not operate at the times those journeys are required. Seven-day operation and sufficiently long operating hours are therefore necessary characteristics of a genuinely useful bus service.

The Plan should consequently establish clear minimum service requirements for major developments and major public transport routes. These requirements should apply from first occupation so that sustainable travel is a realistic option before residents establish hard-to-shift patterns of car ownership and car-dependent travel.

Policy S/GF should be removed from the Plan and the reasonable alternatives to Grange Farm should be reassessed.

In particular, sites adjoining Cambridge should be reassessed using appropriate housing densities and robust, evidence-based assumptions concerning walking, wheeling, cycling and public transport mode shares, taking account of the experience of Eddington.

The reassessment should consider the infrastructure required to support each alternative, the certainty and timing of its funding and delivery, and the resulting implications for car dependency and the wider road network.

The Plan should then be amended to allocate an alternative site if the evidence demonstrates that it provides a more appropriate and deliverable strategy for accommodating the proposed growth.

The Plan is not sound because Policy S/GF is not effective and the allocation of Grange Farm is not justified. The proposed new settlement at Grange Farm depends on the delivery of Cambridge South East Transport (CSET) Phase 2 and an extension of CSET Phase 2 from the proposed A11 travel hub to the site. These schemes are necessary to provide the connectivity required for public transport to be a realistic alternative to private car travel for residents of the new settlement. If public transport is not a realistic alternative to private car travel, residents are likely to make more journeys by car, increasing the pressure placed on the road network. The Plan has not demonstrated that the road network can accommodate the additional traffic generated by the site if the necessary public transport infrastructure is not delivered.

The Plan itself identifies CSET Phase 2 and the CSET Busway Extension to Grange Farm as critical infrastructure. The Infrastructure Delivery Plan identifies an estimated cost of £161 million for CSET Phase 2 and £30 million for the Grange Farm extension. CSET Phase 2 is identified as being phased by 2035, while the phasing of the Grange Farm extension is currently stated to be ‘TBC’ (assumed to mean ‘to be confirmed’). CSET Phase 2 would provide a new public transport and active travel corridor between the A11 and Cambridge Biomedical Campus, including a new travel hub. The proposed extension would continue the busway across the A11 and A1307 to connect Grange Farm with the travel hub and the wider CSET corridor. The delivery of this infrastructure is therefore fundamental to the transport strategy for the allocation.

The Infrastructure Delivery Plan (IDP) identifies CSET Phase 2 as funded, with funding anticipated from the GCP. The GCP’s Transport Director has stated, however, that the cost of CSET Phase 2 beyond the planning stage will need to be met from sources other than the GCP.

The IDP identifies the CSET extension to Grange Farm as partially funded, with funding anticipated from the developer and the GCP. Given that the CSET busway is not currently funded to the A11 P&R, it is unclear how the GCP will assist with funding the extension.

The evidence therefore does not demonstrate that there is sufficient certainty that the full costs of these schemes will be covered.

The Plan therefore has not demonstrated that the transport infrastructure on which the allocation depends is deliverable at the time required to support the planned development. This is inconsistent with the requirement for the Plan to be effective and deliverable over the Plan period.

The longer-term strategic transport implications of the allocation should also be considered. The A1307 corridor has previously been assessed as a potential corridor for a range of strategic transport interventions, including reopening the Haverhill–Cambridge railway and segregated bus rapid transit. Although the 2016 assessment did not identify a viable business case for reopening the railway within the then City Deal programme or the South Cambridgeshire Local Plan period, it expressly recognised that the option might become viable under different future development scenarios and should be reconsidered at that time. The Plan should therefore demonstrate that committing to CSET Phase 2 and its extension to Grange Farm would not prejudice the ability to provide a future Haverhill–Cambridge rail connection, and should address the longer-term strategic implications of the proposed transport solution before confirming the allocation.

The allocation is also not justified because the Plan has not demonstrated that Grange Farm is the most appropriate location when reasonable alternatives are taken into account.

Sites adjoining Cambridge have the potential to achieve substantially greater levels of walking, wheeling, cycling and public transport use than a new settlement located further from the city. Their proximity to the existing urban area, employment, services and transport networks provides greater opportunities for sustainable travel and could reduce the extent of strategic transport infrastructure required to support development.

Some sites adjoining Cambridge were assessed using relatively low housing densities and conservative assumptions about future sustainable transport mode shares in the assessment underpinning the Plan. Those assumptions should be reconsidered in light of the development and travel characteristics being achieved at Eddington, an urban extension to Cambridge. The Plan should demonstrate that the assumptions used in comparing alternative locations remain appropriate and proportionate.

The reasonable alternatives should therefore be reassessed using realistic housing densities and robust, evidence-based assumptions concerning walking, wheeling, cycling and public transport mode shares. The assessment should also properly consider the infrastructure requirements, deliverability and likely transport consequences of each alternative.

The Plan has not demonstrated, on the basis of that evidence, that Grange Farm is the appropriate location for the proposed growth. The Plan has therefore not demonstrated that the selection of Grange Farm is justified when reasonable alternatives adjoining Cambridge are properly considered.

The Plan’s transport evidence should demonstrate, through updated transport modelling, that the measures proposed will provide the improvement in bus reliability and journey times necessary to achieve the level of mode shift on which the Plan’s development strategy depends. It should also demonstrate that, where specified, trip budgets for car travel can be achieved.

The Local Plan should be amended to support the introduction of measures capable of changing how road space is managed and, where necessary, reallocated so that buses can operate reliably in congested conditions. These could include measures such as road charging, a traffic circulation plan that prioritises sustainable modes, stronger bus priority and appropriate parking and kerbside management.

The Local Plan's Infrastructure Delivery Plan and the Draft Interim Greater Cambridge Transport Strategy's Capital Delivery Programme should be amended to identify and provide for measures capable of changing how road space is managed and, where necessary, reallocated so that buses can operate reliably in congested conditions. These could include measures such as road charging, a traffic circulation plan that prioritises sustainable modes, stronger bus priority and appropriate parking and kerbside management.

The Plan is unsound because it is not justified and not effective. It is not sufficiently supported by evidence demonstrating that its proposed growth can be accommodated on the transport network. The development strategy depends to a significant extent on increased use of public transport, including buses, to reduce reliance on the private car. However, existing motor traffic congestion causes substantial and unpredictable delays to bus services on the road network in the Cambridge area, making bus travel less attractive and less of a realistic alternative to the car. The Plan does not demonstrate that the measures proposed will provide the improvement in bus reliability and journey times necessary to achieve the level of mode shift on which the transport strategy depends, and, where specified, trip budgets for car travel can be achieved.

This is a fundamental issue for the deliverability of the Plan. If buses remain unreliable and unattractive because they are delayed by general motor traffic, the Plan has not demonstrated that the anticipated shift from car to bus can occur at the scale required. Additional development could then generate more motor traffic on an already congested network, rather than the mode shift assumed by the Plan sufficiently mitigating the additional demand. If the assumed mode shift cannot be achieved because buses remain subject to significant congestion and delay, the Plan would need to demonstrate how the resulting additional highway demand would instead be accommodated. The NPPF requires the significant transport impacts of development to be assessed and appropriately mitigated, including impacts on network capacity and congestion. The transport evidence therefore needs to demonstrate that the proposed pattern and scale of growth can be accommodated through an effective and deliverable package of transport measures.

Congestion also affects the financial sustainability and deliverability of the bus network. Where buses are delayed by congestion, the time required to operate each service increases, increasing the resources and therefore the cost required to provide a given frequency and level of service. The Plan’s assessment of the infrastructure and funding required to support its growth should therefore take account not only of whether sufficient bus services can be provided in principle, but also of the additional operating costs resulting from congestion. Without measures to reduce congestion and improve bus journey times and reliability, the cost of providing the additional bus services on which the Plan’s transport strategy relies will be greater, making their long-term funding and delivery more difficult.

The proposed busways and other public transport infrastructure the Plan identifies do not, by themselves, demonstrate that the required end-to-end improvement in bus journey times and reliability will be achieved. The three strategic busways proposed – Waterbeach to Cambridge, Cambourne to Cambridge and Cambridge South East Transport scheme (CSET) Phase 2 – provide segregated routes for substantial parts of journeys from the surrounding settlements towards Cambridge, but do not provide continuous segregation across the entire journey into and through Cambridge. Buses must therefore, for at least part of their journey, operate on the general road network within Cambridge. The Inspectors note this with regard to the Cambourne to Cambridge Busway in the Planning Inspectorate’s Cambourne to Cambridge order report, September 2026 (p149): “We note that the Order Scheme [the Cambourne to Cambridge busway] would not do anything to relieve congestion and improve journey times to the east of Grange Road in the City Centre."

Similarly, the localised bus-priority measures identified in the Plan may improve particular junctions or sections of road but do not necessarily provide reliable end-to-end journey times. The Plan therefore needs to demonstrate, through appropriate modelling and evidence, that the proposed package will provide sufficient priority for buses across the parts of the network where congestion would otherwise undermine the bus journey times, reliability and mode shift assumed in the transport evidence.

The Plan's own evidence recognises the scale of the problem. The Transport Evidence Report (TER) identifies that congestion and delay increase as a result of the proposed development strategy and states that further refinement of mitigation measures is required. The TER also indicates that mitigation commensurate with the City Access proxy is required for the transport network to accommodate the Plan.

The transport strategy available at the time of this Regulation 19 consultation is an interim Greater Cambridge Transport Strategy (GCTS). The Cambridgeshire and Peterborough Combined Authority has expressly stated that further work is required before the GCTS is completed, with final approval planned for November 2026. The interim strategy recognises the importance of improving bus reliability and journey times to encourage modal shift, while further technical assessment and modelling remains ongoing. The Plan should not therefore rely on the assumption that the future GCTS will resolve the congestion problem without demonstrating what measures will be delivered, when they will be delivered, and what effect they are expected to have on bus reliability, mode share and network capacity.

In particular, the Transport Strategy should address how road space will be managed and, where necessary, reallocated so that buses can operate reliably in congested conditions. This could include measures such as stronger bus priority, appropriate parking management, road charging and a traffic circulation plan that prioritises sustainable modes. The precise combination of measures should be determined by the evidence, but the Plan needs to support a credible package capable of achieving the required transport outcomes rather than relying principally on additional public transport capacity without adequately addressing the congestion which currently undermines bus reliability.

The Local Plan’s evidence base must describe in detail the transport measures and assumptions on which the TER’s conclusions depend, including the measures represented by ‘City Access’ and ‘City Access Proxy’. This is necessary to demonstrate that the Plan is based on proportionate evidence and is justified.

The Plan must also demonstrate that the mitigation required by the TER is deliverable and can be secured.

If ‘City Access proxy’ indeed indicates measures proposed in the GCP’s historical City Access programme (or commensurate), the Plan must identify that mitigation, explain how it will be funded and delivered, and demonstrate that it has a dependable policy and delivery basis. (Measures such as road charging and a workplace parking levy have no dependable policy basis in Greater Cambridge, and so cannot be relied upon to be delivered). If such mitigation cannot be demonstrated to be deliverable, the Plan must demonstrate through appropriate modelling and evidence that the proposed growth can nevertheless be accommodated on the transport network without it.

If ‘City Access proxy’ indicates a different suite of transport measures, the Local Plan must instead explain how these will be funded and delivered, and demonstrate that they have a dependable policy and delivery basis.

The Plan is not sound. It is neither effective nor justified because it does not include, or otherwise secure, key measures which the Transport Evidence Report (TER) identifies as necessary to accommodate the growth proposed by the Plan. The TER concludes that the development strategy can be accommodated on the transport network only if “mitigation commensurate with the city access proxy within the model runs is delivered” (TER, paragraph 20.1.3). This indicates that delivery of the Plan’s proposed growth is dependent upon transport mitigation of this scale and nature.

Neither “City Access” nor “City Access Proxy” is defined or explained in the Local Plan or its supporting evidence, including the Draft Interim Greater Cambridge Transport Strategy. The Greater Cambridge Partnership’s (GCP’s) City Access programme previously included proposals for measures to (a) generate funding for a transformed bus network, for example through a road charge, and (b) release capacity on Cambridge’s road network so that sustainable modes, particularly buses, can operate more effectively, for example through traffic filters or a road charge. (In 2021, the GCP ran a public consultation under its City Access programme on measures including an expanded bus network, a zonal road charge and higher parking charges. In 2022 the GCP ran a further City Access public consultation on measures including a transformation of the bus network and road charging in the form of a ‘Sustainable Travel Zone’ for Cambridge). Our interpretation of ‘City Access’ is therefore based on historical proposals considered by the GCP.
However neither the Local Plan’s Infrastructure Delivery Framework nor the Greater Cambridge Transport Strategy identifies measures commensurate with the GCP’s City Access programme.

The most effective measures proposed under the GCP’s ‘City Access’ programme to generate funding for a transformed bus network and release capacity on Cambridge’s roads so buses can operate more effectively have also been rejected by Paul Bristow, the current Mayor of Cambridgeshire and Peterborough, including road charging. In addition many of the historical City Access proposals are no longer being progressed by the GCP's Executive Board, including any form of road charging and/or a workplace parking levy. Furthermore, the Draft Interim Greater Cambridge Transport Strategy does not propose any form of road charging or equivalent revenue raising demand management measures.

This creates a fundamental gap between the Plan’s proposed growth and the infrastructure and mitigation required to make that growth deliverable. In the absence of measures capable of delivering the mitigation identified in the TER, there is no clear mechanism by which the transport impacts of the Plan’s growth can be accommodated.

This is particularly significant in relation to bus provision. A recent Cambridgeshire and Peterborough Combined Authority (CPCA) report predicts that over a third of bus services in the region may need to be cut by 2035 unless the costs of running buses are reduced and/or additional sources of funding for buses are found. Reducing congestion is identified as one means of reducing the costs of providing bus services (Leon Daniels OBE, speaking at CPCA’s Transport Committee in June 2026).

The Plan cannot demonstrate that its proposed growth can be accommodated on the transport network unless measures are identified and secured that can deliver the scale and nature of mitigation identified in the TER, including measures capable of enabling a substantial transformation of the bus network.

Before the Plan is adopted, the transport evidence should be updated and the transport impacts of the Plan reassessed using the most up-to-date and appropriate strategic transport model available, including the relevant CPCA modelling.

The assessment should:
establish a realistic 2041 transport baseline, including only transport interventions for which there is sufficient certainty of delivery;
clearly identify every strategic transport intervention assumed in the baseline and provide evidence of its funding, approvals, programme and realistic prospect of delivery by 2041;
reassess the modal split and highway impacts of the Local Plan using that realistic baseline;
identify the full mitigation package required to accommodate the resulting transport impacts; and
demonstrate that the necessary mitigations (or schemes that will have equivalent impacts) are funded, deliverable and capable of being provided at the required time.

In particular, the status and treatment of City Access, the A10 improvements, and the Foxton Travel Hub should be reviewed and the modelling should not rely upon their assumed benefits unless there is sufficient evidence that the relevant interventions will be delivered by 2041.

The Plan should not be found sound unless this work demonstrates that the transport impacts of the proposed development strategy can be accommodated and that the mitigation necessary to achieve this is deliverable over the Plan period.

The Plan is not sound because it is not justified or effective in transport terms. The transport evidence underpinning the Plan is not sufficiently robust, complete and up-to-date to demonstrate that the proposed development strategy can be accommodated on the transport network and that the mitigation necessary to achieve this is deliverable over the Plan period.

The Transport Evidence Report (TER) continues to rely on the Cambridge Sub-Regional Model (CSRM). The Plan should explain why reliance on CSRM remains appropriate given the development of the newer Cambridgeshire and Peterborough Combined Authority (CPCA) CaPCAM strategic transport model and its use to prepare other parts of the Local Plan’s three-part transport evidence base: the Draft Interim Greater Cambridge Transport Strategy (GCTS) and the transport analysis and evidence recently prepared for some specific sites. CPCA is undertaking preliminary modelling for the GCTS using CaPCAM, and further CaPCAM modelling has been commissioned which will form supporting material for Local Plan Examination. The GCTS is therefore being informed by more recent strategic modelling work. The Plan should demonstrate why the TER, which evidences the modelled cumulative impact of the whole Plan, should nevertheless continue to rely on the CSRM, rather than incorporating the most up-to-date and appropriate strategic modelling available. This is particularly important because the transport modelling analysed in the TER is being relied upon to establish both the likely transport impacts of the development strategy and the mitigation required to accommodate those impacts.

The TER also acknowledges that further work is required to refine the mitigation package. Part 4 of the TER (which dates from 2025, and should be read alongside Parts 1 to 3 of the TER, which date from 2021) states that there is further work needed to refine the mitigation package and that the conclusions depend on delivery of mitigation commensurate with City Access. This is an important qualification to the conclusion that the development strategy is deliverable. The TER also identifies further mitigation as necessary but not yet included in the modelling runs. In particular, vehicular trip budgets are identified as required for a number of strategic sites, but these have not been included in the mitigation modelling. The TER further states that there is scope for further refinement of mitigation to address congestion and delay. Consequently, the transport evidence does not yet demonstrate the full transport consequences of the Plan together with the complete mitigation package required to accommodate them.

There is also a concern about the transport schemes and assumptions incorporated into the TER’s 2041 model baseline. The baseline includes a number of major transport interventions, including Cambourne to Cambridge, City Access, Cambridge South East Transport Study and Cambridge South station. The Plan should demonstrate, for each significant intervention included in the 2041 baseline, that there is a realistic prospect of delivery by 2041. Where schemes are uncertain their assumed transport benefits should not be relied upon to demonstrate that the Local Plan is deliverable.This is important because the choice of baseline transport schemes and assumptions about future travel behaviour directly affects the forecast modal split, traffic flows and assessment of highway impacts. If the baseline assumes transport interventions or demand-management measures that are not reasonably certain to be delivered, the resulting assessment may understate the additional highway traffic arising from the Local Plan and the scale of mitigation required.

This is particularly important in relation to City Access. The TER identifies City Access as a baseline scheme, while the subsequent mitigation package refers to a “City Access Proxy”. The Plan should clearly explain what transport interventions and demand-management measures are represented by these assumptions, their current status, and the basis on which their modelled benefits can reasonably be relied upon in assessing the soundness and deliverability of the Plan.

The Greater Cambridge Transport Strategy is also relevant to the transport evidence underpinning the Plan. However, the GCTS remains under development: the most recent version in the Local Plan’s document library is titled Draft Interim GCTS. The analysis work underpinning the strategy is described by CPCA as being ‘based on connectivity assessments and preliminary outputs from recent CaPCAM transport modelling’; further modelling and analytical work is ongoing. CPCA’s own report describes some modelling and connectivity work being carried out to develop the GCTS as ‘outstanding’ (i.e. missing, unresolved). Key annexes to the GCTS cited as providing evidence as to why the Local Plan is justified have not yet been published. The Plan could evolve in response to ongoing modelling and analysis work. The Plan should therefore demonstrate that its transport strategy and mitigation requirements are justified following further modelling and analysis, and subsequent alterations to the GCTS. What is more, the anticipated public consultation on the GCTS has not been held, therefore the measures the GCTS outlines (in particular in its Draft Capital Delivery Programme) may lack the public support required for them to be deliverable. The final Greater Cambridge Transport Strategy is also not anticipated to be voted on for approval by CPCA’s Board until November 2026.

The National Planning Policy Framework requires local plan policies to be underpinned by relevant and up-to-date evidence which is adequate and proportionate to support and justify the policies concerned. It also requires an effective plan to be deliverable over the plan period. In this case, the transport evidence remains subject to significant ongoing refinement, the mitigation package is not yet fully established or tested, and the deliverability of important transport interventions relied upon in the modelling requires further demonstration. The Plan, therefore, has not demonstrated, on sufficiently robust and proportionate evidence, that the proposed scale and distribution of development can be accommodated by the transport network.

The Local Plan should be amended to support the introduction of measures capable of generating ongoing, locally-controlled revenue funding for the bus services (and other public transport services) required to support the growth proposed by the Plan.

The Local Plan's Infrastructure Delivery Plan and the Greater Cambridge Transport Strategy's Capital Delivery Programme should be amended to identify and provide for measures capable of generating ongoing, locally-controlled revenue funding for the bus services required to support the growth proposed by the Plan.
The funding mechanism should be sufficient to support a genuinely attractive and viable alternative to private car travel, including:

new bus routes serving the new developments;
operating frequencies, of every 15 minutes or better at peak times where appropriate;
seven-day operation;
sufficiently long operating hours; and
additional evening and weekend services, compared to the current service provision.
The Greater Cambridge Transport Strategy should:
identify the additional bus-service provision required to support the Plan's growth, including routes, frequencies, operating hours and phasing;
identify the estimated ongoing revenue cost of that provision and the organisations responsible for meeting;
identify committed, reasonably certain and potential sources of revenue funding and quantify any funding gap;
demonstrate how the funding requirement will be addressed under the proposed bus franchising arrangements;
distinguish between temporary or development-specific Section 106 support and the longer-term revenue funding required to maintain the network; and
identify credible mechanisms for securing additional recurring revenue
set out how responsibility for funding these services will be coordinated with the CPCA following the introduction of franchising.

Potential funding mechanisms include a zonal and/or time-based road user charge, a premium on car parking tariffs, a workplace parking levy, an increased mayoral precept and/or any other form of taxation that the CPCA is empowered to levy. A formal funding arrangement could be established with the CPCA to ensure that appropriate funding is available for the additional bus services required as a consequence of the Plan's growth.

Government funding and developer contributions through S106 may contribute to the provision of infrastructure and services, but they cannot reasonably be relied upon as the sole source of long-term revenue funding for an expanded bus network.

The Plan should therefore be modified so that the delivery of the growth it proposes is supported by a clear, credible and financially sustainable mechanism for funding the expanded bus network on which the Plan's transport strategy depends.

The Plan is unsound because it is neither effective nor justified in relation to the provision of the bus network required to accommodate its proposed growth.

The Plan relies on a substantial increase in bus travel to enable growth to be accommodated without having a severe adverse impact on the transport network (NPPF, December 2024, paragraph 116) and to provide a genuine alternative to private car travel (NPPF, December 2024, paragraph 110). However, the Plan, together with the accompanying draft Greater Cambridge Transport Strategy (GCTS), do not set out any new revenue funding to support an expanded bus network and schedules at a level that ensures Travel Plan targets for mode shares and, where specified, trip budgets for car travel are sustained over the long term.

Current funding is already insufficient to maintain the existing bus network over the longer term, and there is therefore no demonstrated basis for assuming that sufficient funding will be available to support the substantially expanded network required by the Plan. The Transport Strategy does not adequately address this funding gap, and therefore does not adequately support sustainable growth in housing and employment as envisaged in the Plan.
The Transport Strategy must identify measures capable of generating locally-controlled, ongoing revenue funding for bus services. Potential sources could include a zonal and/or time-based road user charge, a premium on car parking tariffs, a workplace parking levy, an increased mayoral precept and/or any other form of taxation that the CPCA is empowered to levy.

Government funding and developer contributions through S106 may contribute to the provision of infrastructure and services, but they cannot reasonably be relied upon as the sole source of long-term revenue funding for an expanded bus network.

The need for additional funding to support an expanded network and schedule of services that people can rely upon over the long term is reinforced by the recent report commissioned by CPCA, which predicts that more than a third of bus services in the region may need to be cut by 2035 because of insufficient funding (Independent Review of Implementation Pathways for Bus Franchising Scheme, Steer, 2026, Table 5.7). As of November 2025, the Combined Authority was having to draw on its reserves to continue to fund subsidised services (Contracted Bus Service Review Framework, CPCA Transport Committee Meeting, 17 Nov 2025).

In that context and without a Transport Strategy to address the funding shortfall, the Local Plan cannot assume that an expanded bus network will be available to support its proposed growth.

The failure of the Local Transport Authority to demonstrate it has a credible mechanism for securing ongoing funding for the bus network means that the Plan lacks critical evidence that its proposed growth can be accommodated in a sustainable manner. It is therefore not justified or effective.