Greater Cambridge Local Plan: Proposed Submission

7. Proposed Modifications
7.1 Cambridge Approaches does not seek to prescribe the mechanism by which the Councils close the gap identified above. What Regulation 105 does not permit is what the Local Plan currently does – relying on East West Rail to justify the scale, density and vision of the Cambourne and Cambourne North allocations while excluding East West Rail's effects from the Local Plan's Appropriate Assessment for its HRA. Whichever mechanism the Councils adopt, it must satisfy two conditions: the evidence relied upon must actually assess East West Rail's in-combination effect on the SAC, and that evidence must be tested through the same public process as the rest of the Plan's evidence base, not introduced or relied upon after independent examination has closed, when it can no longer be scrutinised or challenged.
7.2 One way of meeting those conditions would be for the Councils to obtain, or otherwise secure, an adequate assessment of East West Rail's effect on the SAC – whether EWR Co.'s habitats regulations assessment once available, before the Local Plan's Appropriate Assessment records 'no adverse effect' on the SAC (paragraph 5.236). Cambridge Approaches does not prescribe that this is the only way, or the procedural route by which it must be done; the essential point, whatever course is taken, is that this should be treated in Chapter 6 ('Next steps') as an outstanding matter requiring resolution before adoption, exactly as air quality is currently treated at paragraphs 6.5–6.11, and that any evidence relied upon is capable of being tested by interested parties before the Local Plan is adopted.
7.3 If it cannot be shown that the southern route’s effect on the SAC can be adequately mitigated, the housing trajectory for Cambourne and Cambourne North should not assume delivery of the railway until that question is resolved. Cambridge Approaches offers two further observations as suggestions, not as a prescribed way forward: greater openness from East West Rail Company about the evidence it already holds would materially assist in closing this gap; and EWR Co.'s published material confirms that a northern approach to Cambridge was found 'technically viable'16, which, if it avoided the SAC to a greater degree than the southern route, would remove much of the difficulty addressed in this representation. Cambridge Approaches does not have access to the detailed evidence needed to say more than this, and does not put forward a preferred mechanism beyond these observations. We note that Natural England’s advice in the early consultations with EWRCo. gave a strong steer that the northern approach to Cambridge for EWR might be preferrable from an environmental standpoint.
7.4 If reliance is placed on an assessment of East West Rail's effects obtained under 7.2 above, that evidence should be tested and secured (e.g. through a Statement of Common Ground with EWR Co, comparable to that already reached with Anglian Water on wastewater treatment capacity at HRA paragraphs 5.100–5.1046) before adoption, not left to a future, unsecured process.
8. Conclusion
8.1 For the reasons set out above, we object to the Proposed Submission Greater Cambridge Local Plan on the grounds that it relies on East West Rail to justify the scale, density and vision of the Cambourne and Cambourne North allocations, while the July 2026 HRA fails to meet legal requirements to assess East West Rail's effect on Eversden and Wimpole Woods SAC, contrary to Regulation 105. The Councils cannot rely on East West Rail for one purpose while disclaiming it for the other. We do not prescribe the mechanism by which that gap should be closed; greater openness from East West Rail Company about the evidence it already holds, and the alternative of a northern approach to Cambridge that EWR Co has itself described as technically viable, are both matters the Councils could usefully pursue, but we put forward no preferred way forward beyond that. What Regulation 105 does not permit is adoption of the Local Plan while that gap remains. We ask that the Proposed Submission Greater Cambridge Local Plan should not be adopted, until East West Rail's in-combination effects on Eversden and Wimpole Woods SAC have been properly and openly assessed at Appropriate Assessment stage. Failing that, we ask that the Planning Inspector be asked to consider this as a legal compliance and soundness matter. We wish to be notified of further stages in the preparation of the Local Plan and to participate in any hearing session dealing with this matter at the examination in public.

1. The statutory duty
1.1 Regulation 105 of the Conservation of Habitats and Species Regulations 2017 (SI 2017/1012) ( “the Regulations” and “Regulation 105”respectively) requires the competent authority preparing a land use plan – here, Cambridge City Council and South Cambridgeshire District Council jointly (as Greater Cambridge Shared Planning (“the Councils”)) – to undertake an Appropriate Assessment (of the implications of the plan for a European site, in view of that site's conservation objectives, where the plan is likely to have a significant effect on the site, either alone or in combination with other plans or projects. Under Regulation 105, the plan may only be given effect once the competent authority has ascertained, applying the precautionary principle, that it will not adversely affect the integrity of the site. The Court of Justice's test – established in Waddenzee, Case C-127/022, and Sweetman v An Bord Pleanála, Case C-258/113, and consistently applied by UK courts since, including in Wyatt v Fareham [2022] EWCA Civ 98313 – is that this conclusion may only be reached where there is no reasonable scientific doubt as to the absence of adverse effects. This document is in response to the GSCP Reg. 19 HRA and all paragraph and Appendix references in this representation (e.g. '5.23', 'Appendix F.14') are a reference to that document. Bold references are the sections in this document e.g. 1.1
1.2 The words 'either alone or in combination with other plans or projects' in Regulation 105(1)(a) are not an election available to the plan-making authority as to how it conducts its Appropriate Assessment; they define the trigger for when an Appropriate Assessment is required. The provision asks whether a likely significant effect on the SAC could arise via either route – the plan's own contribution, or the plan's contribution added to that of other plans and projects – and if either route produces a likely significant effect, an Appropriate Assessment must follow. ‘Or’ in domestic legislation is typically read as an inclusive rather than an exclusive. Nothing in Regulation 105(1) then confines what that Appropriate Assessment must examine to whichever route triggered it: the assessment required is 'of the implications for the site in view of that site's conservation objectives' – the object is the site's conservation objectives, not the Local Plan considered in isolation – and the ultimate question under Regulation 105(4) is whether the plan-making authority has ascertained that the land use plan 'will not adversely affect the integrity of' the site, a question about the real-world, cumulative pressure on the site which cannot be answered by examining only one contributor to it. Reading 'or' as conferring a choice would also make the words 'or in combination with other plans or projects' redundant: if an authority could always discharge Regulation 105 by assessing the plan alone, those words would do no legal work – contrary to the ordinary presumption against surplusage, and to the purpose of Article 6(3) of the Directive 92/43/EEC of 21 May 1992 on the conservation of natural habitats and wild fauna and flora (“Article 6(3)”), which Regulation 105 implemented and which uses the same 'individually or in combination' formulation for the same reason, i.e. to prevent the combined impact of separate plans or projects on a European site escaping assessment because each is considered only in isolation. The Court of Justice has confirmed exactly this in practice: in Case C-142/16 Commission v Germany ('Moorburg')12. Germany was found in breach of Article 6(3) precisely because a power station's effects on a protected fish population had been assessed, and mitigated, on their own, without combining them with the effects of an existing upstream plant on the same population – the fact that the scheme's contribution had been addressed did not satisfy the duty. In any event, this does not assist the Councils on the facts: the screening chapter did not rely on the 'alone' limb to the exclusion of the 'in combination' limb – paragraph 4.16 identifies East West Rail by name as a further contributor and states that the resulting effect 'is considered further at the Appropriate Assessment stage' (see 2.3 below). Having themselves treated the in-combination question as live and carried it forward to Chapter 5, the Councils cannot now treat Regulation 105(1) as permitting them to have left it unexamined there.
1.3 The population of barbastelle bats in the SAC is controlled by, amongst other factors, the available food resources. It will be in a Malthusian equilibrium where any adverse effect on neighbouring populations may increase competition for the remaining food supply. Any reduction in available food supply from other plans or projects in the area of the plan like East West Rail or the Cambourne to Cambridge Busway might also have an effect on competition for what food remains. This is what Regulation 105 (4) requires; the bats are potentially affected by all these things and have no knowledge of which plan or project might be causing their loss of food. They just starve to death. F.14 bullet 2 states ‘Any mitigation required of policies in the Local Plan in relation to loss of (or disturbance of species at) functionally linked habitats is intended to mitigate the contribution of the Local Plan to in-combination effects, not to mitigate the effects of East West Rail.’ No attempt is made to even assess the effects of East West Rail which is in direct contravention of the Moorburg case (see 1.2). There is a subsidiary point. The argument in the Reg. 19 GCSP HRA depends on reference 24 at paragraph 3.21 (Defra (2026) Draft Eversden & Wimpole Woods SAC bat protocol, unpublished). This is to an unpublished DEFRA document and if it is to be referred in the HRA to it needs to be published. The same applies to any other such reference not available to the public.
1.4 It is also not open to the competent authority to discharge this Appropriate Assessment duty by reference to an assessment that has not yet been carried out by a third party. Tiering of assessment to a later consent stage is only lawful where (a) there is no reasonable scientific doubt now that adverse effects can be avoided, and (b) the later stage constitutes a further, equally rigorous assessment with a secured outcome (R (Champion) v North Norfolk DC [2015] UKSC 524). Plan-level in-combination assessment must also properly address known, reasonably foreseeable projects; it cannot omit them because their assessment is incomplete (Wealden DC v Secretary of State for Communities and Local Government [2017] EWHC 351 (Admin)5). The 'no reasonable scientific doubt' standard, and the weight properly to be given to evidenced consultation with Natural England in meeting it, has since been restated by the Court of Appeal in R (Wyatt) v Fareham Borough Council [2022] EWCA Civ 98313; it is not met by a bare assertion that a related scheme's effects fall outside the scope of the assessment.
1.5 This is confirmed by the Court of Justice's judgment in Case C-461/17 Holohan v An Bord Pleanála14, which holds that an Appropriate Assessment 'may not have lacunae and must contain complete, precise and definitive findings and conclusions capable of dispelling all reasonable scientific doubt as to the effects of the works proposed on the protected site concerned', and that, before a plan or project is approved, 'all aspects of [it]... which may, either individually or in combination with other plans or projects, affect [the site's] conservation objectives must be identified, in the light of the best scientific knowledge in the field.' The Councils' screening chapter identifies East West Rail as such a project at paragraph 4.16 and states that it will be examined at Appropriate Assessment stage; the Appropriate Assessment then did not examine it (see 2.3 below). That is a lacuna in exactly the sense Holohan prohibits, and it is not cured by the explanation given at Appendix F.13 that the 'alone' trigger made further examination optional or even unnecessary (see 1.3 above).
1.6 It is clear from the 9 June 2026 South Cambridgeshire District Council (SCDC) Response to the 2026 EWR Non Statutory Consultation that the impact of EWR on the SAC was a concern. ‘Barbastelle bat SAC and ecological connectivity: The Eversden and Wimpole Woods Special Area of Conservation remain a significant ecological concern for the Council. The Council requires EWR Co to incorporate male barbastelle bat territories within the Habitats Regulations Assessment, share ecological survey data with the Council’s officers, and demonstrate a robust mitigation strategy. This should be reflected within the bridge and watercourse crossing designs, the Habitats Regulations Assessment, the Environmental Statement and the long-term management proposals.’23 This response was authored by Greater Cambridge Shared planning on behalf of SCDC. It demonstrates significant concern about the impact of EWR on the SAC and a requirement to share survey data. How can the conclusion of 5.23 be consistent with this consultation response? It is not.
2. What the July 2026 HRA actually does
2.1 The July 2026 HRA is a small improvement on the October 2025 draft habitats regulation assessment, which did not mention East West Rail at all. This version now mentions EWR and records, at Appendix F.14, that consultation 'has been undertaken with the East West Rail team (see paragraph F.18) to understand the approach that they have taken' to the habitats regulation assessment for that scheme, with further detail of that consultation – including a meeting with EWR Co.'s relevant consultants (Mott MacDonald/WSP) in April 2026 – given at Appendix F.18.
2.2 However, the substantive conclusion at paragraph 5.236 – that there will be 'no adverse effects on the integrity of Eversden and Wimpole Woods SAC, as a result of physical damage/loss or non-physical disturbance of functionally linked land' – relies exclusively on Local Plan policies (BG/BG, BG/TC, GP/QD, I/CM and site-specific safeguards in S/CB, S/BA, S/CBN and S/SEA/CBN) that mitigate the Local Plan's housing-related contribution: bat surveys, dark corridors, sensitive lighting and retained woodland on the allocated sites themselves. Nothing in that conclusion assesses or mitigates the severance and fragmentation of the barbastelle commuting/foraging corridor that would result from the East West Rail line itself cutting through the Core Sustenance Zone and Landscape Connectivity Zone of the SAC – the mapped 6km and 6–10.2km bands by which the Councils' HRA methodology gives concrete effect to the general concept of 'functionally linked land' for this species. Nor does the conclusion assess or consider how East West Rail will interact with and impinge upon the effectiveness of those Local Plan policies. The 2022 EWR Survey report has been available since 5 Feb 2025 on WhatDoTheyKnow.com and the unredacted maps were also obtained on appeal they show significant barbastelle foraging areas in Knapwell north of Cambourne where the houses are planned.24 We remain happy to share the unredacted maps even if EWRCo. are not. We could have shared this information earlier if SCDC had agreed to meet us as requested since January 2026. Of course, the males, although still essential to maintain the population Barbastelles tend to forage further afield perhaps more directly into the areas proposed for new housing such as Bourn Airfield and North Cambourne.
2.3 This is not simply an evidential gap; it is an internal inconsistency in the Councils' stated methodology. Paragraph 4.16 of the screening chapter of the July 2026 HRA identifies East West Rail by name as a potential contributor to in-combination effects on this same functionally linked habitat, and states in terms that '[the effect] is considered further at the Appropriate Assessment stage.' Chapter 5, paragraphs 5.11–5.236 – the Appropriate Assessment itself – does not mention East West Rail once. It moves directly from the Local Plan's site allocations (S/BA, S/CB, S/CBN, S/SEA/CBN) to Local Plan mitigation policies (BG/BG, BG/TC and site-specific safeguards) and then to the conclusion, at paragraph 5.23, that there will be 'no adverse effects on the integrity of Eversden and Wimpole Woods SAC.' The very matter the screening chapter said would be examined at Appropriate Assessment stage is simply absent from it. A 'no adverse effect' conclusion cannot lawfully be reached on the strength of an assessment that never carried out the enquiry its preceding chapter said it would (see also 1.3 above, where the Councils' explanation for this gap is addressed).
2.4 The Councils confirm the same substantive gap in terms at Appendix F.146: 'Any mitigation required of policies in the Local Plan in relation to loss of (or disturbance of species at) functionally linked habitats is intended to mitigate the contribution of the Local Plan to in-combination effects, not to mitigate the effects of East West Rail.' EWR Co.'s habitats regulations assessment does not yet exist and is not expected until EWR Co submits its Development Consent Order application, expected in 202710 – after this Local Plan is due to be submitted for examination. The efficacy of EWR's proposed mitigation (bat bridges and underpasses) is itself contested in evidence already before the Councils: Appendix F.116 records a representation citing a 2012 study indicating that barbastelle bats do not reliably use linear landscape features to commute, calling the effectiveness of bridge/viaduct mitigation into question.
2.5 Appendix F.14, bullet 2 states the principle the Councils rely on to justify this: ‘Any mitigation required of policies in the Local Plan in relation to loss of (or disturbance of species at) functionally linked habitats is intended to mitigate the contribution of the Local Plan to in-combination effects, not to mitigate the effects of East-West Rail.’ That principle is wrong, and the Court of Justice's decision in Moorburg12 shows why. Germany's authorisation of the Moorburg power station was found unlawful under Article 6(3) precisely because its effects on protected fish populations in the Elbe were assessed and mitigated – by proposed fish ladders – on their own, without combining them with the effects of the existing upstream Geesthacht plant on the same population. The power station's own mitigation may, on its own terms, have been perfectly adequate to its own contribution; that was not the point. The error the CJEU identified was treating 'this scheme's contribution has been mitigated' as sufficient, when Article 6(3) asks whether the site's conservation objectives are protected considering every relevant contributor together. Appendix F.14, bullet 2 states the same reasoning as a matter of policy for this Plan: the Local Plan's mitigation deals with the Local Plan's contribution, not East West Rail's. That is not an answer to what Regulation 105(4) requires, which is a conclusion about whether Eversden and Wimpole Woods SAC's integrity will be preserved, taking East West Rail's contribution into account alongside the Local Plan's own. We recognise that the LP has no powers to mitigate the effects of EWR, but their mitigated effect in combination with those of the plan still need to be assessed with respect to the conservation objectives of the SAC.
2.6 On this evidence, there is reasonable scientific doubt as to whether adverse effects on the integrity of the SAC can be excluded once EWR's contribution is taken into account. The HRA's 'no adverse effect' conclusion at paragraph 5.23 is not, therefore, safely reached in combination with EWR, notwithstanding that it may be sound in relation to the Local Plan's allocations considered alone.
3. The Plan itself depends on East West Rail – it does not merely coincide with it
3.1 This matters because the Councils cannot treat East West Rail as an independent, unrelated project whose effects are someone else's problem, while simultaneously relying on it to justify the scale, form and deliverability of the Cambourne allocations. The Councils' report to the Performance, Assets and Strategy Overview and Scrutiny Committee (4 November 2025, on the Draft Local Plan)7 states: 'Earlier stages of the Local Plan highlighted how the spatial strategy, and specific proposals under development, depended upon decisions on key infrastructure projects such as East West Rail (EWR)…'. The same report confirms that, as of that date, 'Decisions consenting key infrastructure projects such as East West Rail, the Cambourne to Cambridge, Cambridge South East and Waterbeach to Cambridge public transport corridors remain outstanding at this time' – i.e. EWR had not then, and still has not now, received development consent.
3.2 The Local Plan's vision and policy text for Cambourne8 confirm the same dependency. The supporting text states that 'Planned new infrastructure means that Cambourne will become one of the best-connected places in the region with the A428 upgrade, Greater Cambridge Partnership's proposed public transport corridor and East West Rail project connecting Cambridge with Oxford delivering a new railway station', and that it is 'Through the new railway station being delivered by the East West Rail project… Cambourne will become a destination in its own right'. Policy S/CBN itself requires development to 'Avoid prejudicing the delivery of the preferred East West Rail route alignment and associated rail infrastructure', and the supporting text records that 'The new East West Rail station and busway provide good opportunities to enable greater density of development' – i.e. the quantum and density of the allocation are themselves predicated on the railway being delivered.
3.3 The Plan cannot have it both ways. If the scale, density, movement strategy and 'destination' vision for Cambourne and Cambourne North depend on East West Rail being delivered – as the Councils' scrutiny report and policy text say they do (see 3.1 and 3.2 above) – then East West Rail is not a separate, insufficiently defined project that can be left out of the Plan's habitats regulations assessment, as the July 2026 HRA has done. It is integral to the Local Plan, and its effects on Eversden and Wimpole Woods SAC must be assessed as part of the Local Plan's Appropriate Assessment before that plan is adopted, not left to EWR Co.'s, as yet unpublished process. The only lawful alternatives are: (a) the Councils obtain and rely on adequate assessment – whether EWR Co.'s published, examined habitats regulations assessment or an equivalent evidenced and secured assessment – demonstrating no reasonable scientific doubt that the SAC's integrity will be preserved on the currently preferred southern route, before the Local Plan is submitted for examination; or (b) the Councils accept that this cannot presently be demonstrated, and act accordingly – supporting, for example, East West Rail's alternative northern approach to Cambridge while phasing the Cambourne and Cambourne North housing trajectory so that it does not assume delivery of the railway until the route question is resolved. It is not open to the Councils to rely on East West Rail to justify the allocation while disclaiming responsibility for assessing its ecological impact.
3.4 The Councils' methodology confirms that East West Rail was never too remote or speculative to require examination. The HRA's guidance on identifying relevant plans and projects for in-combination assessment6 states that consideration will focus on 'any strategic projects in the area that could have in-combination effects with the GCLP', and lists, citing the 'HRA Handbook', categories relevant to that exercise including 'proposals in draft plans formally published or submitted for final consultation, examination, or adoption.' East West Rail – with government funding committed, four rounds of public consultation since 2019 (2019, 2021, 2024 and 2026), a published preferred route and station location, and a Development Consent Order application – its next and only statutory stage – anticipated in 2027 – comfortably meets this test. In any event, the point is academic: paragraph 4.16 already treats East West Rail as sufficiently certain to require examination at Appropriate Assessment stage (see 2.3 above). The Councils cannot now credibly contend it was too remote to assess.
4. Anticipated response – 'this is covered by EWR Co's assessment' – and why that does not satisfy Regulation 105
4.1 The Councils may respond that no separate assessment of East West Rail's effect on the SAC is required in this Plan's HRA, even accepting the Plan's dependency on East West Rail described above, because that effect will be assessed by EWR Co as part of its Development Consent Order (DCO) application. That response does not answer our objection, for four reasons.
4.2 First, it conflates two distinct statutory duties held by two different competent authorities. Regulation 1051 imposes a duty on the Councils, as the competent authority preparing this Local Plan, to assess the plan's likely significant effects on the SAC alone and in combination with other plans and projects, before the Local Plan is given effect. A separate duty will fall on the Secretary of State, as the competent authority determining EWR Co.'s DCO application under the Planning Act 2008, to assess the railway's own and in-combination effects before that consent is granted, under the equivalent project-level provision, Regulation 639. EWR Co.'s future habitats regulations assessment will go towards discharging the Secretary of State's duty in relation to the railway; it cannot discharge the Councils' prior and distinct duty in relation to this Local Plan. There is no mechanism by which one competent authority's anticipated future compliance with its duty satisfies a different competent authority's separate duty to assess a plan now.
4.3 This is not merely a matter of statutory construction; it has been tested and confirmed in R (Caffyn) v Shropshire Council [2025] EWHC 1497 (Admin). The court rejected the argument that a competent authority may confine its in-combination assessment to projects within its own decision-making scope, addressing precisely the 'vertical division of labour' presented here – one type of consent given by one body, a different consent given by another: 'Smaller [projects] get consent from one body. Bigger [projects] get a different consent from another body. Each body would need to consider [relevant projects] within the decision-making scope of the other. Otherwise, there would be a lacuna. Real-world, in-combination effects would be missed. To the habitat and its species, there is no material distinction based on who hands out the permit.' The court went further: 'The existence of a parallel control regime – or another competent authority – is not a basis for confining and limiting the scope of an assessment which [the competent authority] is statutorily obliged to conduct… If each competent authority or species of competent authority considers only its own consented projects, there will be a disjointed habitats lacuna, in an holistic-effects protection regime.'
4.4 That reasoning applies with at least equal force here. East West Rail Company's Development Consent Order will be determined by the Secretary of State for Transport under the Planning Act 2008 – a different consenting tier from the Councils' Local Plan, on facts squarely within the 'vertical division of labour' the court in Caffyn described and decided under the same statutory formula (Regulation 63(1)(a)9) the court was there construing. The fact that a different, national-level body will determine EWR Co.'s consent is not a basis on which the Councils may confine their own Regulation 105 in-combination assessment to projects within their own decision-making scope. On Caffyn's reasoning, doing so is precisely the 'disjointed habitats lacuna' the in-combination duty exists to prevent.
4.5 Second, the 'in combination' limb of Regulation 105 exists precisely to capture cumulative effects that no single project's assessment will address. Wealden DC v Secretary of State for Communities and Local Government [2017] EWHC 351 (Admin)5 confirms that a plan-making authority cannot discharge its in-combination duty by pointing to the fact that another, related project will have its own separate assessment; it must itself assess the combined effect, using the best available evidence and reasonable worst-case assumptions where firm figures are not yet available. This is the outcome Regulation 105 is designed to prevent (see Figure 1 below).

Figure 1: ‘in combination’ requires the union of both circles – everything either scheme contributes – not just the narrow area where their footprints happen to overlap.
4.6 Third, R (Champion) v North Norfolk DC [2015] UKSC 524 does not support deferring the whole assessment of a contested pathway of harm to a separate consent regime run by a different public body, on a different project, to a different timetable. Champion concerned a technical implementation detail (a drainage scheme) reserved by condition within the same decision, where the decisionmaker had already concluded, on the evidence available to it, that adverse effects could be excluded beyond reasonable scientific doubt. That is not the position here: the efficacy of EWR's proposed mitigation is itself contested (see section 2 above), and the Councils' consultation record shows this is treated as a live, unresolved concern, not a matter of settled technical detail.
4.7 <Intentionally Left Blank>.
4.8 This is not simply a matter of how the objection reads Regulation 105 and Regulation 63 together; it reflects the Planning Inspectorate's current published advice on how competent authorities should coordinate exactly this situation. The Inspectorate's guidance 'Nationally Significant Infrastructure Projects: Advice on Habitats Regulations Assessments'15 advises that an NSIP applicant's in-combination assessment should treat 'projects identified in the relevant development plan (and emerging development plans... with appropriate weight being given as they move closer to adoption)' as a relevant factor – confirming that the obligation to consider the Local Plan and East West Rail together runs in both directions, not only from the Councils outward to EWR Co. The same guidance states that, where parallel consents are in play, applicants 'should consult other Competent Authorities... and confirm with those Competent Authorities whether they want to adopt the reasoning or conclusions of the assessment carried out' under the other regime. No such consultation, confirmation or agreed mechanism between the Councils and EWR Co, or the Secretary of State, is recorded anywhere in the July 2026 HRA or its Appendices. The Councils have not coordinated with the other competent authority in the manner official guidance describes; they have simply assumed that the other authority's future assessment will suffice.
4.9 A second, narrower response the Councils might give is that no in-combination assessment is required at all, because the Appropriate Assessment already found no residual effect from the Local Plan's own allocations. In R (Foster) v Forest of Dean District Council [2015] EWHC 2648 (Admin)18, Cranston J held that 'there is no basis to carry out an assessment of in combination effects when there are no effects to take into account', because the Council's finding that the development had no residual effect on bats, after mitigation, was 'supported by Natural England' and not shown to be irrational.
4.10 That defence does not apply here, for two reasons. First, paragraph 5.23 does not find that the Local Plan's allocations have no residual effect on the functionally linked habitat; it finds 'no adverse effects on... integrity... as a result of physical damage/loss or non-physical disturbance', reached only through active mitigation – bat surveys, dark corridors, sensitive lighting and retained woodland. A finding that mitigation has reduced an effect below the threshold of adversity to integrity is not the same as a finding that there is no effect at all: it presupposes one. Nor, unlike Foster, has Natural England agreed that the Local Plan's contribution is nil; its recorded involvement (Appendix F.15–F.186) concerns bat consultation bands and functionally linked habitat zones generally, not a finding of zero residual impact. In any event, this is a case where East West Rail itself could interact with and impact on the effectiveness of the active mitigation provided for in the Local Plan; the effectiveness of mitigation and in-combination effects cannot be untangled.
4.11 Second, and more fundamentally, the premise that this part of the landscape presents no residual effect from development is contradicted by evidence the Councils have not addressed at all. As set out in Cambridge Approaches' separate representation on the July 2026 HRA's treatment of Hardwick Wood, submitted alongside this representation, East West Rail Company's 2022 survey confirms a barbastelle maternity colony at Hardwick Wood SSSI sharing a foraging resource with the SAC's colony, and the Councils' Appendix E records functional connectivity between the Bourn Airfield Strategic Enhancement Area and Hardwick Wood without ever identifying or assessing that shared resource. A residual-effect finding of zero cannot be sustained for a functionally linked habitat whose most directly relevant additional roost site and shared foraging resource has not even been identified, let alone assessed.
4.12 A third response the Councils might give is that having screened East West Rail in at paragraph 4.16, they are nonetheless entitled to carry out no assessment of it at all because there is not yet sufficient information available to do so. That response does not survive scrutiny either, for three reasons.
4.13 First, the staged approach permitted in R (Together Against Sizewell C Ltd) v Secretary of State for Energy Security and Net Zero [2023] EWCA Civ 1517; [2024] Env LR 2219 does not assist the Councils, because it is not available on these facts. The Court of Appeal held that assessment of cumulative effects may lawfully await a later consenting stage only 'where the cumulative effects in question are not yet capable of being sufficiently identified for proper assessment at the consenting stage for the first project because the second is still unidentified' – and that, conversely, assessment 'should, in principle, be carried out as soon as the effects which the project in question is likely to have on a protected site are sufficiently identifiable.' East West Rail is not unidentified: it has a published preferred route, a published station location, four rounds of public consultation since 2019, and a Development Consent Order application anticipated in 202710. The precondition for lawful staging is not met. There is also a considerable amount of information that has been released under EIR from EWRCo. and Natural England and available on Whatdotheyknow.com (search under Euan Dunn and Leigh Carter).
4.14 Second, even where information genuinely is lacking, the lawful response is not to omit the assessment. In Oceana UK v Secretary of State for Energy Security and Net Zero and Oil and Gas Authority (t/a North Sea Transition Authority) [2025] EWHC 3146 (Admin)20, Mould J held that an assessor facing insufficient information 'may well conclude that it is not yet possible to make a meaningful assessment of the likely effects' – not that the assessor may conclude there is no effect. Paragraph 5.23 does not say the Councils cannot yet conclude; it says there will be 'no adverse effects'. If the true position were that there is insufficient information to assess East West Rail's effects, the lawful conclusion under the precautionary principle would be that no adverse effect cannot presently be excluded (see Section 7 below) – not the unconditional 'no adverse effect' finding actually reached.
4.15 Third, the premise that there is insufficient information is itself doubtful. Substantial, directly relevant evidence already exists: East West Rail Company's 2020 and 2022 radio-tracking, and 2020 transect and static detector surveys2; the Vine (2002) study of barbastelle foraging range from the SAC; and evidence from the Wensum Valley Barbastelle Project 20a directly relevant to the effectiveness of the green bridges and crossing structures East West Rail currently proposes as mitigation. On pp.74-75 of this study we find: ‘Conclusion: the barbastelle-specific evidence indicates that they avoid green bridges and there is a lack of other evidence to indicate that the proposed green bridges would be effective in significantly reducing barbastelle vehicle collision risk or the barrier effect… Conclusion: the available evidence suggests that underpasses may not be effective in helping barbastelles to avoid vehicle collisions or in reducing the barrier effect (and even if effective, insufficient in number to cover all likely crossing points)’ 20a EWRCo. are clearly proposing green bridges and underpasses for their railway in the vicinity of the Eversden and Wimpole Woods SAC. SCDC clearly had enough information to screen EWR in and to make quite a detailed response to the EWR 2026 Non Statutory consultation (see 1.6). This is not a case where nothing is known; it is a case where a considerable body of relevant evidence exists and has not been brought into the Councils' assessment.
4.16 In any event, if information genuinely is missing, that is not a gap the Councils are powerless to close. East West Rail Company has been conducting systematic radio-tracking surveys of barbastelle bats along the prospective route since 2020 2 – six years before this consultation, building on survey activity going back to at least 2019 – and holds a substantial body of survey data beyond what has so far been made public. It is open to East West Rail Company, at any time, to provide the Councils with the evidence needed to support a robust assessment of its effects on the SAC, if it wishes its project to continue to be relied upon to justify this Plan's housing strategy for Cambourne and Cambourne North. It has not done so. An absence of information cannot be relied upon as a reason to omit the assessment altogether when the party best placed to supply that information – and with every incentive to do so, given the Local Plan's dependence on its scheme (see Section 3 above) – has simply chosen not to or is it that GCSP simply has not asked.
4.17 The suggestion that there is insufficient information about this population is also difficult to reconcile with East West Rail Company's account of its evidence base. At a meeting between East West Rail Company and Cambridge Approaches on 14 March 2026, Tristan Lincoln-Gordon – East West Rail Company's Head of Environment – is recorded in Cambridge Approaches' contemporaneous note of that meeting as stating that this area 'would be the most studied for barbastelles anywhere', with monitoring ongoing for '4+ years' by that date. When shown peer-reviewed evidence that barbastelles do not reliably use bat bridges or underpasses and asked to share a German study he said showed the contrary, Mr Lincoln-Gordon declined, stating that East West Rail Company was 'under no legal obligation to do so'. That is, on Cambridge Approaches' contemporaneous account, both a direct acknowledgment from the officer responsible for East West Rail Company's environmental strategy that substantial survey information already exists, and a direct refusal to share evidence said to support its proposed mitigation when specifically asked for it. It turned out that the German study (to which we assume Lincoln-Gordon was referring) of a green bridge did not involve barbastelle bats.
4.18 Nor should the absence of shared data between East West Rail Company and the Councils be allowed to prejudice what is the appropriate habitats regulations assessment for the Local Plan. East West Railway Company Limited is wholly owned by the Department for Transport and was established to deliver a project that the Government's policy treats as integral to the growth of this area – the same growth the Local Plan itself relies upon East West Rail to deliver (see 3 above). The Councils are, equally, public authorities exercising statutory functions in the public interest. Neither is withholding confidential information from an unconnected private party; both are public bodies, and the Planning Inspectorate's guidance already expects coordination between them (see 4.8 above). A failure by one part of government to share environmental evidence with another should not be capable of lowering the standard of protection the legislation requires for a Special Area of Conservation.
4.19 <Intentionally Left Blank>.
5. This is not a new point – and the Councils' evidence undermines their conclusion
5.1 This is not the first time this point has been raised. Appendix F.116 records that the same substantive objection was made at Regulation 18 stage by Cambridge Approaches, Haslingfield Parish Council, Great Shelford Parish Council and a private respondent, and that both South Cambridgeshire District Council and Cambridgeshire County Council have themselves separately raised significant concerns about EWR's impact on the SAC's maternity roost in their responses to EWR Co's non-statutory consultations. The Councils' response to these representations at Appendix F.13–F.14 does not engage with the substance of the objection; it confirms that consultation has taken place with EWR Co's habitats regulations assessment team, and that the Local Plan's mitigation is not intended to address EWR's effects, without explaining how or when the in-combination effect will actually be assessed and, if necessary, mitigated and secured.
5.2 The inconsistency in the Councils' document reinforces the point. At paragraphs 6.5–6.116, the July 2026 HRA candidly acknowledges that adverse effects from air pollution 'cannot be ruled [out]' pending further air quality modelling, and commits to producing an addendum, with any necessary mitigation 'tested and secured (e.g. in policy wording) prior to the adoption of the Local Plan.' No equivalent treatment is applied to the Eversden and Wimpole Woods SAC/EWR in-combination effect, despite the underlying uncertainty being at least as significant – arguably more so, given the SAC supports what is described in the Councils' consultation responses to EWRCo. as a nationally important, potentially irreplaceable barbastelle maternity colony. Chapter 6 ('Next steps’) of the July 2026 HRA does not list this issue as outstanding, which indicates the Councils currently regard it as resolved. On the evidence in their document, it is not.
5.3 Despite this, sustained attempts by Cambridge Approaches and Haslingfield Parish Council to engage the Councils' officers directly on this point have not succeeded. The concern was formally raised at Haslingfield Parish Council on 8 December 2025, when Cllr Redrup (South Cambridgeshire District Council) agreed to try to facilitate discussion between the Local Plan team and the EWR team within the Council. By 9 March 2026, the Parish Council's minutes record that no meeting had yet been arranged with Cambridgeshire County Council, whose member, Cllr Damary-Homan, explained that the County Council could not share information at that stage owing to its consultee status, but that a meeting could take place after the consultation closed. A further direct request for a meeting between Cambridge Approaches' ecological experts and the relevant officers was made to Cllr Damary-Homan on 26 March 2026. As of the Parish Council's most recent minutes (13 July 2026), engaging with the County Council remained an item still 'to discuss at a future meeting' – no meeting between the Councils' HRA/ecology officers and either the Parish Council or Cambridge Approaches had taken place, more than seven months after the concern was first raised.
6. Consequence for legal compliance and soundness
6.1 Because the plan-level Appropriate Assessment does not lawfully exclude adverse effects on the integrity of Eversden and Wimpole Woods SAC when the Local Plan is considered in combination with East West Rail, the HRA does not satisfy Regulation 105. The Local Plan is accordingly not legally compliant.
6.2 For the same reason the Local Plan is not justified (the housing strategy for Cambourne and Cambourne North is not founded on a proportionate and robust evidence base as to its ecological effects) and not effective (the 'no adverse effect' conclusion, and by extension the deliverability of the S/CBN and related allocations as currently drafted, is not demonstrated, since it fails to address the interaction with EWR).
6.3 We have taken advice from specialist planning counsel, and this representation incorporates his advice.

7. Modifications sought
7.1 The HRA should be updated to identify Hardwick Wood's barbastelle maternity colony and its shared foraging resource with Eversden and Wimpole Woods SAC as part of the functionally-linked-habitat baseline for the SAC, drawing on East West Rail Company's 2022 radio-tracking survey and any further survey data available from East West Rail Company or the Cambridgeshire and Peterborough Environmental Records Centre.
7.2 The Appropriate Assessment should specifically consider whether recreation and visitor pressure arising from the Local Plan's allocations – individually and cumulatively – is capable of affecting the foraging resource shared between Hardwick Wood and the SAC, and whether the existing mitigation in Policy BG/BG and related policies is sufficient to address that pathway.
7.3 Appendix E's review of Policy S/SEA/BA should be revisited to distinguish clearly between the functional connectivity of the site being assessed and the connectivity and foraging requirements of the SAC's qualifying population, so that documented links of the kind identified in Section 2 above are not lost from the assessment.
8. Conclusion
8.1 For the reasons set out above, we object to the Proposed Submission Greater Cambridge Local Plan on the grounds that its Habitats Regulations Assessment does not properly identify or assess the barbastelle foraging resource shared between Hardwick Wood and Eversden and Wimpole Woods SAC, notwithstanding that this is established by evidence already available to the Councils, including Appendix E and East West Rail Company's 2022 radio-tracking survey. This representation is made in addition to, and independently of, Cambridge Approaches' separate representation on the HRA's treatment of East West Rail's in-combination effect on the SAC. We ask that the Planning Inspector be asked to consider this as a soundness matter requiring further work on the HRA before the Plan is adopted.

This representation is separate from, and additional to, Cambridge Approaches' representation on the Habitats Regulations Assessment's treatment of East West Rail. It concerns a different, independent gap in the same HRA: its treatment of Hardwick Wood and the barbastelle population associated with it. The two representations should be read together but stand independently – either point, on its own, supports the conclusion that the HRA's ‘no adverse effect’ conclusion for Eversden and Wimpole Woods SAC at paragraph 5.23 is not safely reached.
Document and paragraph to which this representation relates:
Habitats Regulations Assessment of the Greater Cambridge Local Plan (LUC, Final report, July 2026), Appendix E (site-level ecological review for Policy S/SEA/BA: Bourn Airfield Strategic Enhancement Area) and Chapter 5, paragraphs 5.63–5.68 (Appropriate Assessment: Eversden and Wimpole Woods SAC – recreation pressure); and Policy BG/BG (Biodiversity and Geodiversity) insofar as it does not address barbastelle foraging resource shared between Hardwick Wood and Eversden and Wimpole Woods SAC.

1. The SAC's barbastelle population is not confined to Eversden and Wimpole Woods
1.1 The Habitats Regulations Assessment treats Eversden and Wimpole Woods SAC as though it supports an isolated barbastelle population whose habitat requirements can be fully captured by a Core Sustenance Zone and Landscape Connectivity Zone drawn outward from the SAC boundary alone1. East West Rail Company's 2022 radio-tracking survey – obtained by Cambridge Approaches under the Freedom of Information Act and publicly available – establishes that this is not the ecological reality. That survey confirms separate barbastelle maternity colonies at Madingley Wood SSSI, Hardwick Wood SSSI and Waresley and Gransden Wood SSSI, and states in terms: ‘The surveys did however indicate that foraging resources are shared by the Madingley Wood SSSI, Hardwick Wood and Eversden and Wimpole Woods SAC barbastelle maternity colonies.’2 The SAC's qualifying population therefore depends, for its foraging resource, on land beyond what the HRA's own methodology treats as relevant.
1.2 This matters because Hardwick Wood lies close to, and shares a foraging landscape with, several of the Local Plan's own site allocations and policy areas in this part of South Cambridgeshire. A foraging resource used in common by more than one maternity colony is, by definition, more sensitive to incremental loss than the HRA's site-by-site, SAC-radius methodology assumes: pressure on that shared resource affects not only Hardwick Wood's own colony but the pool of foraging habitat the SAC's colony also depends on.
2. The Councils' evidence shows awareness of the Hardwick Wood connection, without it being carried into the assessment
2.1 Appendix E to the HRA, in its site-level review of Policy S/SEA/BA (the Strategic Enhancement Area adjoining Bourn Airfield New Village), records under ‘Functional connectivity’: “The hedgerows and woodland provide good connectivity to the wider area, such as Hardwick Wood to the southeast.”3 The accompanying figure shows commuting-corridor lines running toward Hardwick Wood. Hardwick Wood is therefore already present in the Councils' evidence base as a site with functional connectivity to the assessed area – but nowhere does the HRA identify Hardwick Wood as itself supporting a barbastelle maternity colony or ask whether development affecting that connectivity could affect a foraging resource shared with the SAC.
2.2 The Appendix E entry for S/SEA/BA appears, on the face of it, to describe the functional connectivity of the site being assessed rather than the SAC's connectivity requirements – the two are conflated in a way that risks the significance of the Hardwick Wood link being lost from the assessment altogether. Cambridge Approaches does not suggest this was anything other than an oversight, but it is one with real consequences: it means the Councils had, in their evidence base, a documented link to Hardwick Wood, and did not follow that link through to the maternity roost and shared foraging resource that East West Rail Company's survey had already identified by the time the Regulation 19 HRA was prepared.
3. East West Rail Company's Public Facing illustrates the population's significance, without disclosing it
3.1 East West Rail Company's 2026 consultation brochure includes the following, in relation to a proposed bridge near Hardwick Road: ‘This bridge would include a planted section to provide habitat connectivity for mammals, including barbastelle bats. It would allow wildlife to move between Hardwick Wood Site of Special Scientific Interest, ancient woodland, and foraging habitat to the east.’ 4 This passage describes mitigation for a generic connectivity concern. It does not disclose that Hardwick Wood supports a confirmed barbastelle maternity colony, or that this is what the mitigation is actually there to protect. A reader of the consultation brochure alone would have no way of knowing that a specific, located maternity roost – not a generic habitat corridor – lies behind this proposal.
3.2 Cambridge Approaches raises this not as a criticism of the Local Plan's HRA directly – East West Rail Company is a separate body with its own consultation obligations – but because it illustrates the point made in Section 1 above: the ecological significance of this part of the landscape is established and known, from the promoter's survey work, and has not found its way into the Greater Cambridge Local Plan's assessment.
4. Recreation and visitor pressure on the shared foraging resource is not assessed anywhere in the HRA
4.1 The HRA does contain a dedicated Appropriate Assessment of recreation pressure on Eversden and Wimpole Woods SAC, at paragraphs 5.63–5.681, concluding that adverse effects will be avoided through Policy BG/EO and the Bourn Airfield site policy's landscaping and open space requirements. Cambridge Approaches does not take issue with that assessment on its own terms.
4.2 What is absent is any assessment of recreation or visitor pressure on Hardwick Wood SSSI itself. This is not, in isolation, a gap in the HRA's legal scope: Hardwick Wood is not a European site, and the Habitats Regulations do not of themselves require it to be assessed as such. But given the shared foraging resource identified in Section 1 above, increased visitor pressure on Hardwick Wood – arising from the cumulative effect of the housing growth planned across this part of South Cambridgeshire, including but not limited to the Bourn Airfield and Cambourne allocations – is capable of affecting habitat that the SAC's qualifying population also relies upon. That is a functionally-linked-habitat question the HRA's conservation objectives for the SAC ought to capture and does not.
5. Wider context: Natural England has already identified suitable foraging resource in this area as scarce
5.1 Natural England's response to the 2018 First Proposals consultation on the Local Plan recorded: “Natural England is reviewing the Impact Risk Zone (IRZ) for Eversden and Wimpole Woods SAC to take into account the findings of emerging SAC barbastelle tracking surveys being undertaken for major development schemes. It will also take into consideration the availability of suitable foraging resource which is considered to be quite scarce in the local area.”5 Cambridge Approaches relies on this as context, not as a freestanding ground of objection: it supports treating the loss of any part of a shared foraging resource – including the resource shared with Hardwick Wood identified above – as significant, rather than assuming that a scarce resource can absorb incremental loss without cumulative consequence.
6. Public Domain Material which may assist GCSP’s HRA
6.1 This section introduces public domain material which GCSP should use in its HRA including for in combination assessment with EWR. You should search for Leigh Carter and separately Euan Dunn on whatdotheyknow.com. These will produce survey results from EWRCo. and correspondence between EWRCo. and Natural England on the subject of the Eversden and Wimpole Wood SAC. Look in particular at the evidence plan meetings in which Natural England express concern about the quality of the evidence that EWRCo. are producing.
6.2 EWRCo.’s 2022 Barbastelle Radio-Tracking Survey Report6 is key public domain material. This includes the following sections that are relevant to the Barbastelle Bats roosting in the Eversden and Wimpole Woods SAC: §§3.2.4-3.2.9, §§3.4.6-3.4.7, §4.2. §4.2.10 states ‘The radio-tracking surveys undertaken in August and September 2022 did not therefore provide evidence that the breeding colonies at Madingley Wood SSSI, Hardwick Wood SSSI and Waresley and Gransden Wood SSSI directly interact with the Eversden and Wimpole Woods SAC barbastelle maternity colony with respect to the interchanging of roosting. The surveys did however indicate that foraging resources are shared by the Hardwick Wood SSSI colony, Madingley Wood SSSI colony and the Eversden and Wimpole Woods SAC population.’
6.3 The tracking report referred to in §6.2 has the maps at the end redacted. We did get these maps in a very large file on appeal. They are very interesting and are available from us on request.

10. Modifications sought
10.1 This representation identifies two distinct harms, and the modifications sought address both. The first is that allocating the whole of Cambourne North's housing to East West Rail forecloses any search for a transport solution that could actually serve the rest of it. On the evidence at paragraph 4.4 above, at most 2–3% of Cambourne North's households will contain a resident commuting to a new Cambridge job by rail; the remaining 97% or more are left with no transport strategy for their journeys to work in other directions, to school, to the shops, or anywhere else, other than the road network – not because none exists, but because the paper allocation makes East West Rail look sufficient when it is not, and Section 6 shows a deliverable alternative has in the meantime been secured for the adjoining site without ever being tested here. The second is that the road traffic Cambourne North's development will actually generate is, on East West Rail Company's evidence (Section 5 above), not being modelled or mitigated by anyone at all. Cambridge Approaches does not seek to prescribe the mechanism by which the Councils address these harms, but whichever mechanism is adopted should: (a) test a transport-led alternative for serving Cambourne North that does not assume East West Rail is delivered at the mode share currently claimed, informed by the now-approved C2C scheme and its capacity for extension or reinforcement, so that the housing this railway cannot realistically serve is not left without any transport strategy at all; (b) require the road traffic actually generated by Cambourne North's development to be modelled and mitigated regardless of East West Rail's rail-demand claims, given that East West Rail Company's evidence confirms this traffic will not otherwise be assessed by anyone; and (c) condition the housing trajectory and phasing for Cambourne North on the delivery of transport capacity actually secured for it, rather than on an assumed rail contribution that does not match the housing being allocated or the business case supporting it.
10.2 Cambridgeshire County Council, as local highway authority, East West Rail Company, and the Greater Cambridge Development Corporation should each be asked, as part of the Examination, to confirm in writing which of them accepts responsibility for modelling and mitigating the road traffic generated by Cambourne North's housing, given that East West Rail Company's evidence confirms neither of the first two currently does. The Development Corporation's position is particularly material: this is the last Local Plan the Councils will prepare before the Development Corporation takes over responsibility for strategic development management above 250 homes – which covers Cambourne North many times over – from 2027, and for Local Plan-making thereafter.30 The Councils should not adopt a transport strategy for Cambourne North that the body about to inherit responsibility for delivering it has not itself confirmed it accepts. That commitment also needs to reckon with a structural bias against the alternative sought at paragraph 10.1(a) above: once housing is described, as it is here, as 'essential' or 'strategic' to East West Rail rather than examined on the numbers, it becomes correspondingly harder to justify funding or delivering any other transport solution for the same housing, because the paper allocation is treated as though the need has already been met. All three responses should be published as part of the Examination evidence base.
10.3 If reliance continues to be placed on an assumed East West Rail mode share to justify Cambourne North's scale, density or phasing, the evidence for that mode share should be tested and secured – for example through a Statement of Common Ground with East West Rail Company – before adoption, clarified to state the number of dwellings it assumes and tested against the housing actually proposed at Cambourne North, and supported by publication of the underlying business case rather than the single, adverse value-for-money ratio currently available.
11. Conclusion
11.1 For the reasons set out above, we object to the Proposed Submission Greater Cambridge Local Plan on the grounds that its transport strategy for Cambourne North relies on an East West Rail mode-share case that East West Rail Company's evidence does not support, that excludes from assessment the very road traffic this housing will generate, that has never been tested against a transport-led alternative which the Government has, in the meantime, approved for the immediately adjoining site, and that depends on a business case which remains unpublished and whose only disclosed metric records poor value for money. We do not prescribe the mechanism by which that gap should be closed, but what the Sustainability Appraisal Regulations and the tests of soundness do not permit is what the Plan currently does: allocating housing to East West Rail on the basis of a rail contribution larger than the evidence supports, while leaving the traffic that housing generates assessed by neither East West Rail Company nor the Councils, and while the underlying business case remains unseen. We ask that the Proposed Submission Greater Cambridge Local Plan should not be submitted for independent examination, or adopted, until this has been addressed. Failing that, we ask that the Planning Inspector be asked to consider this as a legal compliance and soundness matter requiring modification. We wish to be notified of further stages in the preparation of the Plan and to participate in any hearing session dealing with this matter at the Examination in Public.

Summary of this representation
This representation shows that the Local Plan's transport strategy for Cambourne North causes significant harm because it rests on East West Rail's rhetoric about its case, rather than on the facts that follow. East West Rail Company has not published a business case for the Bedford-to-Cambridge section, the one value-for-money figure it has published is poor, and its modelling explicitly excludes the traffic this same housing will generate (Sections 3 and 5 below). On the evidence at Section 4 below, at most 2–3% of Cambourne North's households will contain a resident commuting to a new Cambridge job by rail; the remaining 97% or more are left with no transport strategy for their journeys to work, to school, to the shops, or anywhere else, other than the road network, because the Plan has treated East West Rail's case as though it were already made. Sections 6 and 7 show that a funded, deliverable, non-rail transport solution already exists for the immediately adjoining site, and that others directly involved in delivering land in this corridor do not regard East West Rail as necessary either. Section 9 sets out why this makes the Plan unsound and non-compliant, and Section 10 sets out the modifications sought. At root, this is not an objection to East West Rail: it is an objection to a Local Plan that has assumed East West Rail's solution before establishing that one exists.
1. The applicable tests
1.1 A local plan is sound only if it is positively prepared, justified, effective, and consistent with national policy.1 'Justified' requires an appropriate strategy, taking into account reasonable alternatives, and based on proportionate evidence; 'effective' requires that the plan is deliverable over the plan period. Both tests are engaged by this representation.
1.2 The National Planning Policy Framework was comprehensively rewritten and republished on 17 August 2026, and no longer uses the terms 'justified' and 'effective' for plans examined under it. However, the new Framework's transitional provisions2 confirm that a plan submitted for independent examination before 31 December 2026 continues to be examined against the December 2024 Framework. The Regulation 19 stage of this Plan closes on 25 September 2026; a 'Proposed Submission' consultation is, by definition, the final stage before submission for examination, and there is no indication that submission will be delayed beyond the end of 2026. Cambridge Approaches accordingly addresses this representation to the December 2024 tests, as the Councils themselves have done in framing this consultation.
1.3 Separately, where a plan-making authority is required to prepare an environmental report under the Environmental Assessment of Plans and Programmes Regulations 20043, that report must identify, describe and evaluate the likely significant effects of reasonable alternatives to the plan, and give an outline of the reasons for selecting the alternatives dealt with. This is not a paper exercise: the Court of Appeal has confirmed that the duty requires a genuine and adequately reasoned assessment of the alternatives realistically available, not merely of the alternatives the plan-making authority happens to have already considered on other grounds.4 As set out below, the Sustainability Appraisal supporting this Plan has never applied that exercise to the question this representation raises: whether Cambourne North needs to be served by East West Rail at all.
2. The Plan's transport strategy for Cambourne North depends on an assumed East West Rail mode share
2.1 The Plan's vision and policy text for Cambourne and Cambourne North5 are framed around the delivery of an East West Rail station. The supporting text states that 'Planned new infrastructure means that Cambourne will become one of the best-connected places in the region with the A428 upgrade, Greater Cambridge Partnership's proposed public transport corridor and East West Rail project connecting Cambridge with Oxford delivering a new railway station', and that it is 'Through the new railway station being delivered by the East West Rail project… Cambourne will become a destination in its own right'. The supporting text further records that 'The new East West Rail station and busway provide good opportunities to enable greater density of development' – that is, the quantum and density proposed for Cambourne North is itself justified by reference to the station.
2.2 The scale of that dependency is not incidental. At a meeting between East West Rail Company and a representative of the Councils on 10 December 2025, recorded in Cambridge Approaches' representation on the Transport Evidence Report6, it was confirmed that all of the up to 13,500 houses proposed north of the A428 at Cambourne North had been 'allocated to' East West Rail. The Plan does not simply anticipate a station at Cambourne; it treats the entire Cambourne North allocation as a function of the railway's delivery.
2.3 This is consistent with East West Rail Company's public justification for its preferred route. At the May 2023 Route Update Announcement, the then Chief Executive of East West Rail Company, Beth West, explained the choice of a southern approach to Cambridge in these terms: 'It's to unlock sustainable growth between Oxford and Cambridge. The southern route connects to the Biomedical Campus, which has a huge opportunity for growth across the region.'7 Sections 4 and 5 below test that justification, and the scale of reliance the Plan places on it, against East West Rail Company's published evidence.
3. East West Rail's business case has not been published, and the one figure that has been is very poor value for money
3.1 East West Rail Company published its Economic and Technical Report in May 2023, but that report is not the business case for the Bedford-to-Cambridge section on which Cambourne North's transport strategy depends, and none of the formal stages of that business case have been published. The Strategic Outline Business Case was reportedly completed in 2019 and has still not been published, despite Freedom of Information requests. The Outline Business Case, which East West Rail Company intends to complete before its Development Consent Order application, has likewise not been published, and East West Rail Company has given no commitment to publish either document. East West Rail Company has confirmed only that the outline, and then full, business case will be submitted to government as part of the standard approval process for Nationally Significant Infrastructure Projects, and the Department for Transport has confirmed that publication, if it happens, will follow only once planning consent has been secured8 – that is, after the decisions this Local Plan and East West Rail Company's Development Consent Order both depend on have already been taken.
3.2 The published evidence on value for money is no better. The Department for Transport's cost-benefit analysis, examined by the National Audit Office, put the return at between 30p and 60p of benefit for every £1 spent on 'connection stages 2 and 3' – the Bletchley-to-Bedford-to-Cambridge sections that include the Bedford-to-Cambridge section on which Cambourne North depends – down from an already poor 50p to £1.10 assessed in 2021.9 On the Department's value-for-money categories, a Benefit-Cost Ratio below 1.0 already represents poor value for money; even at the upper end of this range, the scheme's monetised costs exceed its monetised benefits. The Councils are being asked to allocate the great majority of Cambourne North's housing, and to justify its scale and density, by reference to a project whose published cost-benefit assessment records it as poor value for money by a wide and worsening margin, and whose full justification neither the public nor, on the evidence available to Cambridge Approaches, the Councils themselves have been shown.
3.3 Two petitions have been raised on this specific point, and they should not be conflated. The first, on Change.org, calls on East West Rail Company to publish the Bedford-to-Cambridge business case and remains open; it passed 1,000 signatures within two weeks of its launch in August 2026.8 The second was a petition to South Cambridgeshire District Council itself – one of the two Councils preparing this Plan – asking the Council to debate requesting that East West Rail Company publish that business case. It required only 100 signatures to trigger a Council debate, met that threshold, and Cambridge Approaches understands it has since been removed and is no longer available online.10 The significance of the second petition is not the debate itself, but what the debate is about: South Cambridgeshire District Council debating whether to ask East West Rail Company for its business case is only intelligible if the Council does not itself have it. A Plan should not be adopted on the strength of a scheme whose business case is unknown even to one of the planning authorities responsible for allocating housing to it.
3.4 East West Rail Company disputes that this undermines the project's value, describing it as 'a once in a generation opportunity to unlock up to £78bn of economic growth in the region'.8 That figure, however, is dated to 2035. East West Rail Company's current published timeline states that the full railway, including the new Bedford-to-Cambridge section, is planned to open only 'by the mid-to-late 2030s',11 and Cambridge Approaches understands from a direct account given to it by East West Rail Company representatives in September 2026 that construction of this section is now expected to run from around 2030 to 2037. On either account, a Cambridge rail connection that will only just have opened, if it has opened at all, by 2035 cannot plausibly be the cause of growth claimed 'by 2035'; if anything, the gap between the claimed benefit date and the likely completion date has widened, not narrowed, since the £78bn figure was first published. Cambridge Approaches does not ask the Councils to resolve the wider dispute over East West Rail's economic case in this representation. It asks only that the Plan should not proceed on the assumption that the £78bn claim has any real bearing on the case for Cambourne North within this Plan period, while the business case said to support it, and the poor value-for-money figure that has already been published, remain unexamined by the Councils allocating housing on its strength.
3.5 This is not new criticism. The National Audit Office investigated the project in a report published 13 December 20239, which found that the Department for Levelling Up, Housing and Communities' housing growth plans for Cambridge were being prepared separately from East West Rail Company's business case, even though '[DLUHC's plan] intend[s] this to enable significant housing and business development in a new section of the city, while the business case for EWR depends on development along the rail route', and concluded that 'Government risks the planning for both projects being at cross purposes.' It recommended that the responsible departments establish effective cross-department governance 'to focus on achieving the benefits of East West Rail' – in substance, a call from Parliament's independent auditor for the scheme's proponents to demonstrate how its claimed benefits would actually be delivered. Almost three years on, and with this Local Plan now at Proposed Submission stage, that demonstration has still not been provided to the public or, on the evidence available to Cambridge Approaches, to the Councils. The fragmentation the National Audit Office identified between housing growth plans and the railway's business case is the same fragmentation addressed at paragraph 5.3 below, between this Local Plan, East West Rail Company and Cambourne North's developers.
3.6 When challenged directly on the scale of this reliance – including on the capital cost per daily commuter addressed at paragraph 9.2 below – the response Cambridge Approaches has received from those responsible for the scheme is not that the near-term forecasts are wrong, but that they are the wrong test. Cavendish Elithorn, Senior Responsible Owner for the East West Rail Programme at the Department for Transport, wrote to Cambridge Approaches on 25 October 2023: 'Quite a few of the points in the note take a static view of the current transport system rather than assuming it will evolve in the future as the railway is built and business and housing develops. By its very nature the railway's existence will lead to things being different to how they are now but we cannot predict with certainty exactly how, but we can make illustrative assumptions, but these are not predictions. The creation of EWR will be transformative rather than incremental so we have had to use additional methods than just traditional transport modelling.'12 Stephen Kelly, Joint Director of Planning and Economic Development at Greater Cambridge Shared Planning, gave a similar answer at a meeting with South Cambridgeshire's parish councils on 19 February 2026, describing how, as Cambourne grows from a 'dormitory' into a self-sufficient town, more services and jobs will be located within it and fewer trips will need to leave it at all.13
3.7 Cambridge Approaches does not dismiss the possibility that a transformative, long-term case of this kind could justify East West Rail's role in Cambourne North's transport strategy. But on the Department's own account, that case rests on 'illustrative assumptions' that are expressly 'not predictions' – not on the evidence base that is supposed to justify this Plan. If the real justification for allocating the whole of Cambourne North's housing to East West Rail is that the area will be transformed over several Local Plan cycles into something more like the corridor west of London, that is a proposition the Councils should state plainly, quantify and test – including by discounting for the substantial risk and uncertainty inherent in forecasting multi-decade transformation – rather than leave to be inferred from private correspondence and meetings years apart. The people being consulted should also be told that this is the real plan.
4. East West Rail Company's evidence does not support the scale of reliance placed on it
4.1 The Transport Evidence Report14 – prepared for the Councils by Cambridgeshire County Council, independently of East West Rail Company's modelling – gives a breakdown of trip destinations for an extended Cambourne. Despite Ms West's justification for the route, only 1% of trips originating in an extended Cambourne have the Cambridge Biomedical Campus as their destination, and that 1% is not broken down by mode. The single destination said to justify the route choice barely features in the Councils' evidence of where Cambourne's residents actually, or would, travel.
4.2 East West Rail Company's Economic and Technical Report Appendix 415 gives a forecast of rail demand from Cambourne, using a trip-end model calibrated against 2011 census travel-to-work data. Two scenarios are presented: a 'Conventional' scenario, reflecting market sizes and mode shares experienced today, and a 'Transformational' scenario, which East West Rail Company itself describes as 'a plausible but very aspirational world… which may not be transferrable between contexts'. Cambridge Approaches relies only on the Conventional scenario, being the one scenario East West Rail Company has calibrated against observed evidence rather than aspiration. On that scenario, Table 4.1 gives Cambourne a 30% share of the employed population commuting to Cambridge, a 10% rail mode share, 920 regular rail commuters per day and 540 peak-hour passengers.
4.3 Those figures cannot be checked against the housing actually proposed at Cambourne North, because Table 4.1 does not state how many dwellings its 'increase in population planned from dependent development' of 53,400 for Cambourne assumes. The only table in the same appendix that attaches a dwelling count to comparable growth – Table 4.6, headed 'D: Strengthen', which gives 19,300 homes for Cambourne – is generated under a different methodology entirely: the appendix states that this table applies 'the transformational scenario… to infer… what proportion of new residents in an area would commute to Cambridge', and Table 4.6 itself uses a 40% Cambridge-commuting share, not Table 4.1's 30%.15 It cannot be used to supply the dwelling figure missing from the Conventional-scenario table on which paragraph 4.2 above, and the Plan's reliance on East West Rail, actually depend. On the evidence East West Rail Company has published, nobody – not the Councils, not the public, not, it appears, East West Rail Company itself within this appendix – can say how many homes its 920-daily-commuter figure for Cambourne is meant to represent.
4.4 What Table 4.1 does supply, and what Cambridge Approaches relies on here, are its stated ratios, which set a ceiling on East West Rail's realistic contribution regardless of dwelling numbers. On the Conventional scenario, 30% of the employed population of an extended Cambourne commutes to Cambridge, and 10% of those commuters travel by rail – together, 3% of the employed population, or approximately 1.5% of total population, applying Table 4.1's stated 49.2% workforce-participation ratio (30,800 of 62,600). Converting that population share to a household share, using South Cambridgeshire's average household size of 2.40 persons (Census 2021),15 gives an illustrative ceiling of some 3–4% of households in an extended Cambourne containing any resident who commutes to Cambridge by rail, for any job, new or existing. Since Table 4.1 does not distinguish new employment from existing employment, the share of households containing a resident travelling specifically to a new Cambridge job created by the growth East West Rail is said to unlock will be smaller again – plausibly, on this evidence, in the region of 2–3% of households.
4.5 On this evidence, the great majority of Cambourne North's households – on the ceiling calculated above, some 96–97% or more – will contain no resident who commutes to Cambridge by rail at all, whether to a new job or an existing one (see paragraph 10.1 below). That is a ceiling, not a conservative estimate: it assumes the employed residents of a brand-new settlement will commute to Cambridge, and use rail once there, at the same rate as a long-established commuter village, calibrated on 2011 census data. East West Rail Company's justification for this route is that it unlocks new growth and new jobs, including at the Biomedical Campus itself (see paragraph 2.3 above); nothing in this evidence base tests whether residents of a settlement built around that premise would in fact travel to Cambridge by rail at anything like this rate, let alone specifically to the new jobs the scheme is said to unlock. On the evidence East West Rail Company has published, at most a small fraction of Cambourne North's housing can be said to depend on East West Rail for access to work in Cambridge at all.
4.6 There is a further, more basic problem with the housing allocation this evidence is used to justify. Cllr Bridget Smith, Leader of South Cambridgeshire District Council – one of the two Councils preparing this Plan – stated at a pre-election radio hustings in May 2026 that there are some 37,000 homes in South Cambridgeshire with planning permission that remain unsold and unbuilt.16 Before allocating yet more housing at Cambourne North, the Plan should have examined why that is the case. It has not. The point matters directly to the design response the mode-share target invites: reducing parking provision and specifying higher-density, higher-rise development around the East West Rail station may be a logical way to attempt to increase the rail mode share on paper, but it may equally reduce the probability that the housing concerned will actually sell, adding to rather than addressing the 37,000-home backlog the Leader of the Council has herself identified. Adam Smith's warning about the 'man of system' is apt: 'He seems to imagine that he can arrange the different members of a great society with as much ease as the hand arranges the different pieces upon a chess-board. He does not consider that the pieces upon the chess-board have no other principle of motion besides that which the hand impresses upon them; but that, in the great chess-board of human society, every single piece has a principle of motion of its own, altogether different from that which the legislature might chuse to impress upon it.'17 Prospective buyers, like the pieces on Adam Smith's chess-board, will respond to a scheme designed around a mode-share target according to their preferences, not the Plan's; a strategy that discounts this risk builds housing nobody will buy in order to serve a rail service few of its residents will use.
4.7 Cambridge Approaches heard the institutional response to this directly. At a meeting on 15 July 2025 between South Cambridgeshire District Council, Greater Cambridge Shared Planning and South Cambridgeshire's parish councils, attended by Cambridge Approaches, it was stated that only 71 houses were sold at Northstowe in the preceding year.18 Stephen Kelly, Joint Director of Planning and Economic Development at Greater Cambridge Shared Planning, explained the Councils' response: because a Local Plan concentrated in a small number of large strategic sites will see delivery vary more, site by site and year by year, than one spread across many smaller sites, more planning permission needs to be granted than the arithmetic housing requirement strictly calls for, to guard against the risk that any one site underperforms. It was suggested at the meeting that Northstowe's sales figures might indicate this approach would not work. Cambridge Approaches does not dispute the underlying statistics: concentrating housing in a small number of large sites will indeed produce more variance between sites than spreading it more widely. What that response does not do is ask why Northstowe is underperforming. If the cause is that the housing on offer does not match what buyers actually want, whether on price, space, or car parking, then adding margin by allocating still more of the same kind of housing elsewhere does not correct the shortfall; it risks reproducing it at a larger scale. This is the same habit of mind noted at paragraph 4.6 above: a shortfall in a plan that assumes people will behave as the plan requires is treated as a technical problem to be solved by adding more of the same kind of supply, rather than as a signal that the underlying assumption needs testing.
4.8 It may be the case that the design of Cambourne North around an EWR station pushes the rail mode share above 10% and/or the market share for Cambridge above 30% meaning more than 3% of commuters use EWR to commute to jobs in Cambridge. It is a very long way from 3% to a 100% allocation of Cambourne North houses to EWR. The argument that EWR is a catalyst or an enabler is hard to test and does not fix the problem of what the 97% of houses that do not use EWR to commute to Cambridge actually do.
5. East West Rail Company's transport modelling explicitly excludes the traffic this same housing will generate
5.1 East West Rail Company's Transport Update Report19 states, at paragraph A7.3.6: 'Dependent development will not be considered within the traffic modelling.'
5.2 This is not an isolated statement. Paragraph A5.1.13 of the same report states that passenger demand forecasts supporting the project's business case 'will not include demand associated with dependent developments', and paragraph A4.4.3 states that '[d]ependent development is not proposed to be considered as part of the [Transport Update Report] or [Transport Assessment]'. All three provisions use the same defined term addressed at Section 4 above.
5.3 The significance of this is straightforward, and a useful comparator illustrates why. In Japan, several major private railway companies also develop and let or sell the housing and employment sites along their lines, so the whole package – the railway's costs and revenue, and the property side that depends on it – is planned, and made to break even, together, by one body accountable for all of it. Nothing of that kind happens here. 'Dependent development' is the term East West Rail Company uses, in the very same Economic and Technical Report tables addressed at paragraphs 4.2–4.5 above, to claim rail-demand credit for Cambourne North's housing towards the business case for the railway. The same population is then expressly excluded from the assessment of the road traffic it will generate. East West Rail Company takes the benefit of this housing on the demand side of its case, while declining to take responsibility for it on the traffic-impact side, and the split between the Local Plan, East West Rail Company and the housing developers who will actually build Cambourne North lets each disclaim responsibility for the parts that do not add up. That fragmentation is what is allowing what may, on the evidence at Section 3 above, be a fundamentally poor overall business case to go untested by anyone, rather than examined as a whole.
5.4 Neither East West Rail Company nor the Councils have accepted responsibility for that gap. Cambridge Approaches' representation on the Transport Evidence Report6 records that '[t]he lack of justification for EWR and this development of Cambourne is falling between GCSP and EWRCo. Both are responsible for this failure… But EWRCo. say they are not responsible for the housing and GCSP feel they have no responsibility of EWR.' The road traffic generated by up to 13,500 new houses at Cambourne North is accordingly at risk of never being properly modelled or mitigated by either authority, notwithstanding that the Plan relies on East West Rail to justify allocating that housing in the first place.
6. The Sustainability Appraisal has never tested a non-East West Rail transport-led alternative for Cambourne North – and a deliverable one has now been approved for the immediately adjoining site
6.1 The Sustainability Appraisal of the Greater Cambridge Local Plan20 explains its approach to Cambourne in these terms: 'E.60 The First Proposals preferred development strategy identified Cambourne as a broad location for future development, in association with the opportunities provided by East West Rail and in particular the proposed new railway station… E.61 Ahead of the draft plan stage, East West Rail Company had developed the East West Rail project further. It confirmed a proposed new railway station location at Cambourne. Drawing upon this additional certainty regarding the project, the Councils determined that it was now possible to be more specific regarding the scale, form and location of development at Cambourne… E.63 Between the draft plan and Proposed Submission stages, East West Rail Company has continued to progress the East West Rail project towards its statutory Development Consent Order application. As such the Councils have maintained the Draft Plan approach… including the approach to reasonable alternatives described above.'
6.2 The 'reasonable alternatives' referred to throughout this passage are alternative sites for development within the Cambourne area – land to the north and west of existing Cambourne against land to the south and east, and individual parcels rejected or preferred by reference to proximity to the East West Rail station. They are never an alternative transport-led delivery strategy that does not assume East West Rail. The Sustainability Appraisal's Appendices covering strategic spatial options and site selection criteria21 contain no reference at all to a guided busway, bus rapid transit, mass rapid transit or light rail as an alternative means of serving Cambourne North. The question this representation raises – whether Cambourne North needs East West Rail's contribution at all, on the evidence addressed at Sections 3 to 5 above – has accordingly never been asked, let alone answered, in the Plan's evidence base.
6.3 That omission is not academic, and it is not because no alternative exists. On 8 September 2026, the Secretary of State for Transport – acting through the Rail Minister, Lord Hendy – approved the Cambourne to Cambridge (C2C) guided busway under a Transport and Works Act Order, with deemed planning permission, following an eight-week public inquiry at which the Planning Inspectorate recommended the scheme be granted.22 The approved route runs from Cambourne to Cambridge via the Bourn Airfield New Village, Hardwick, Coton and the University's West Cambridge site, together with a 2,000-space travel hub at Scotland Farm.23
6.4 Bourn Airfield New Village adjoins the Cambourne North allocation and lies within the same travel corridor. It was allocated for some 3,500 homes in the adopted 2018 South Cambridgeshire Local Plan, with outline planning permission granted in July 202424, and it is now to be served, on the Government's decision, by a dedicated public transport scheme that does not depend on East West Rail.
6.5 The point is a simple one. If a transport-led, non-rail alternative can be tested, consented and secured for 3,500 homes sharing this corridor and this road network, there is no rational basis on which the Sustainability Appraisal could have treated an equivalent transport-led alternative for Cambourne North's larger allocation as unworthy of testing. Yet, as paragraphs 6.1–6.2 above show, it was never tested at all.
6.6 This sharpens, rather than simply adds to, the objection at Sections 3 to 5. A funded, consented, non-East-West-Rail public transport solution already exists in, and was designed to serve, this corridor, and the economic case for the railway that is meant to justify preferring it remains unpublished. The Plan's continued exclusive reliance on an assumed East West Rail mode share to justify Cambourne North's scale and density – without the Sustainability Appraisal ever testing whether the C2C corridor, reinforced or extended, could perform some or all of the same function – is not a reasoned choice between evidenced alternatives. It is the one alternative that was never examined.
7. Independent corroboration that Cambourne North does not depend on East West Rail for its deliverability
7.1 This is not only Cambridge Approaches' assessment. In a representation dated 30 January 2026 on behalf of Martin Grant Land – the promoter of land north of Cambourne – Savills stated: 'Whilst MGL note that the East West Rail (EWR) scheme and the Cambourne to Cambridge (C2C) will enhance the sustainability of development in this location, Cambourne North can come forwards and be delivered (and shown to be sustainable) without either scheme going ahead.'25 The same representation states, of Policy S/CBN, that 'development at North Cambourne has been shown to be economically, environmentally and socially sustainable without either of the two proposed Infrastructure schemes, the benefits of both are significant and recognised by MGL.' This is the assessment of the site's promoter, who has every commercial interest in the scale of infrastructure investment attracted to the site, not a party seeking to resist development there. (The word 'sustainable' is examined further, from a carbon perspective, at Section 8 below.)
7.2 Two members of Cambridgeshire County Council have separately told Cambridge Approaches, in the course of this consultation, that Cambourne can be extended without East West Rail.26 Cambridge Approaches does not name the individuals concerned in this representation, in order to preserve ongoing working relationships.
8. The Plan's reliance on East West Rail as 'sustainable' has not been tested against its carbon impact
8.1 The Plan's transport strategy for Cambourne North is repeatedly described as 'sustainable', but that word is never tied to an assessment of carbon emissions. Policy S/CBN's vision for Cambourne North describes it as a 'well-connected, sustainable, thriving and prosperous town', in the same policy that credits the East West Rail station with delivering that connectivity (paragraph 2.1 above), and requires a 'Cambourne North Climate and Sustainability Strategy' as part of a 'holistic approach to Cambourne's environmental, economic and social sustainability which provides effective responses to the climate and ecological emergencies'.27 The promoter's representation, addressed at paragraph 7.1 above, uses the same word in the same way, describing Cambourne North as capable of being 'shown to be sustainable' with or without East West Rail.

8.2 No whole-life carbon assessment of East West Rail Company's Bedford-to-Cambridge section has been published that would test whether this description is accurate.28 Based on the available evidence reference 26 demonstrates quite the opposite. Cambridge Approaches does not ask the Councils to resolve that question in this representation, which is concerned with transport rather than climate policy; but a Plan that relies on 'sustainable' language to help justify East West Rail's role in Cambourne North's transport strategy should not be allowed to treat that word as equivalent to 'low-carbon' without the evidence to support it.
9. Consequence for legal compliance and soundness
9.1 Because the Sustainability Appraisal has never identified, described or evaluated a transport-led alternative to East West Rail for Cambourne North – notwithstanding that such an alternative has now been tested through public inquiry, recommended by the Planning Inspectorate and approved by the Secretary of State for Transport for the immediately adjoining site – it does not satisfy the duty to assess reasonable alternatives under the Environmental Assessment of Plans and Programmes Regulations 2004.3 The Local Plan is accordingly not legally compliant.
9.2 For the same reason, the Plan is not justified: the evidence base for Cambourne North's transport strategy rests on an East West Rail mode-share case whose published tables do not state the number of dwellings assumed, so that its correspondence to the 13,500 homes actually proposed cannot be checked, that excludes the resulting road traffic from assessment altogether, that has never been tested against an alternative which the Government has, in the meantime, found deliverable for the adjoining site, and that ultimately depends on a business case the Councils have not themselves been shown and which the only published metric records as poor value for money. Put in concrete terms, East West Rail Company's Table 4.1 total of 2,090 daily rail commuters across the whole route, set against the £8 billion capital cost Cambridge Approaches has already cited6, implies a capital cost of some £3.8 million for every daily commuter the railway is forecast to carry – compared with roughly £28,000 in capital cost per daily passenger on the Elizabeth line's £18.9 billion central section29, a difference of two orders of magnitude that the Plan does not examine, question, or even acknowledge. Nor is the Plan effective: the deliverability of the S/CBN allocation as currently drafted is not demonstrated, since it depends on a rail contribution that East West Rail Company's evidence does not support at the scale claimed.

Endnotes
1. National Planning Policy Framework (December 2024), paragraph 35: https://webarchive.nationalarchives.gov.uk/ukgwa/20250225172715/https://www.gov.uk/government/publications/national-planning-policy-framework--2
2. National Planning Policy Framework (17 August 2026), Annex 1, paragraphs 4–9 (transitional arrangements): https://www.gov.uk/guidance/national-planning-policy-framework . Annex 1 confirms that plans submitted for independent examination before 31 December 2026 continue to be examined against the December 2024 Framework.
3. The Environmental Assessment of Plans and Programmes Regulations 2004 (SI 2004/1633), regulation 12(2) and Schedule 2, paragraph 8: https://www.legislation.gov.uk/uksi/2004/1633/regulation/12/made and https://www.legislation.gov.uk/uksi/2004/1633/schedule/2
4. Ashdown Forest Economic Development LLP v Wealden District Council [2015] EWCA Civ 681; [2016] PTSR 78, Court of Appeal, on the duty to give genuine and adequately reasoned consideration to reasonable alternatives under the Environmental Assessment of Plans and Programmes Regulations 2004.
5. Draft Greater Cambridge Local Plan, Policy S/CBN ('Cambourne North') and supporting text: https://consultations.greatercambridgeplanning.org/draft-greater-cambridge-local-plan-consultation/site-allocations/new-settlements/policy-scbn
6. Cambridge Approaches, representation on the Greater Cambridge Local Plan Transport Evidence Report (October 2025), submitted alongside the Regulation 18 Greater Cambridge Local Plan consultation, paragraphs 3, 5 and 6 (£8 billion capital cost figure at paragraph 5). East West Rail Company's capital cost estimates were originally expressed in 2010 prices before being rebased to Q2 2021 prices – shortly before the sharp construction-cost inflation of 2022–2023 – so this figure, itself now several years old, is likely to understate rather than overstate the current capital cost.
7. Beth West, then Chief Executive Officer of East West Rail Company, speaking at the launch of the May 2023 Route Update Announcement: https://www.youtube.com/watch?v=mgd10ZiriUo (1:26).
8. 'More than 1,000 sign petition urging East West Rail to reveal Bedford to Cambridge section business case', Cambridge Independent, 27 August 2026: https://www.cambridgeindependent.co.uk/news/more-than-1-000-sign-petition-urging-east-west-rail-to-revea-9480284/ ; petition: 'Publish the Business Case for East West Rail CS3 (Bedford-Cambridge)': https://www.change.org/p/publish-the-business-case-for-east-west-rail-cs3-bedford-cambridge
9. National Audit Office, 'Investigation into the East West Rail project (Oxford – Cambridge)', published 13 December 2023: https://www.nao.org.uk/reports/investigation-into-the-east-west-rail-project-oxford-cambridge/ . DfT's 2021 assessment (50p–£1.10 of benefit per £1 spent) and its later assessment for 'connection stages 2 and 3' (30p–60p of benefit per £1 spent) are given in the report and accompanying press release; the DLUHC/EWR Co 'cross purposes' finding and the recommendation for cross-department governance are also from the press release: https://www.nao.org.uk/press-releases/investigation-into-the-east-west-rail-project-oxford-cambridge/
10. Petition to South Cambridgeshire District Council requesting that the Council debate asking East West Rail Company to publish its business case for the Bedford-to-Cambridge section; threshold of 100 signatures required to trigger a Council debate, met. Cambridge Approaches understands the petition page is no longer available online; details on file.
11. East West Rail Company, 'Consultation 2026 FAQs' (consultation ran 14 April to 9 June 2026): 'We plan to open the full railway by the mid-to-late 2030s. By this time, the new section of railway between Bedford and Cambridge would have been completed, and all new stations would have been opened.': https://eastwestrail.co.uk/consultation/frequently-asked-questions . The 2030-to-2037 construction estimate is from a direct account given to Cambridge Approaches by East West Rail Company representatives in September 2026; details on file.
12. Cavendish Elithorn, Senior Responsible Owner (SRO) for the East West Rail Programme, Department for Transport, email to Cambridge Approaches, 25 October 2023; details on file. His role is confirmed in Safeguarding Directions for development affecting the route and associated works for the East West Railway Project, signed by authority of the Secretary of State for Transport, in force from 14 November 2024: https://gat04-live-1517c8a4486c41609369c68f30c8-aa81074.divio-media.org/filer_public/98/9d/989d81d6-7836-4e33-b3d5-9b1b70dfad50/obj-247_app1-1_ewr-safeguarding-direction-with-signature.pdf
13. Minutes of a meeting between South Cambridgeshire District Council (Cllr Bridget Smith, Leader), Greater Cambridge Shared Planning (Stephen Kelly, Joint Director of Planning and Economic Development) and the South Cambridgeshire Parish Rail Group, 19 February 2026; details on file.
14. Greater Cambridge Local Plan Transport Evidence Report (October 2025), Table 90: https://consultations.greatercambridgeplanning.org/sites/gcp/files/2025-10/EBGCLPDCGTEROct25.pdf
15. East West Rail Company, Economic and Technical Report, Report Appendices (May 2023 Route Update Announcement), Appendix 4 'Theory of Change Trip-End Modelling': Table 4.1 (Conventional Scenario, p.59); Table 4.2 (Transformational Scenario, p.59, giving Cambourne a 40% Cambridge-commuting share); and Table 4.6 ('D: Strengthen', p.63, giving 19,300 dwellings for Cambourne), introduced at p.60 as applying 'the transformational scenario… to infer… what proportion of new residents in an area would commute to Cambridge': https://eastwestrail-production.s3.eu-west-2.amazonaws.com/public/Route-Update-Announcement/9a2d6ec314/ETR-Appendices-2023.pdf . Average household size for South Cambridgeshire, 2.40 persons (Census 2021): Cambridgeshire & Peterborough Insight, 'Households and population commentary': https://cambridgeshireinsight.org.uk/population/census-2021/ward-demography-dashboard/households-and-population-commentary/ . The calculations at paragraphs 4.4–4.5 and 10.1 of this representation are Cambridge Approaches' calculations, applying Table 4.1's stated ratios and the cited household-size figure; East West Rail Company's evidence does not itself state either a dwelling count for Table 4.1 or a household-level commuting share.
16. Cllr Bridget Smith, Leader of South Cambridgeshire District Council, speaking at a pre-election radio hustings, May 2026. Recollection of Cambridge Approaches; details on file.
17. Adam Smith, The Theory of Moral Sentiments (1759), Part VI, Section II, Chapter II, paragraph 42.
18. Minutes of a meeting between South Cambridgeshire District Council (Cllr Bridget Smith, Leader), Greater Cambridge Shared Planning (Stephen Kelly, Joint Director of Planning and Economic Development) and South Cambridgeshire's parish councils, 15 July 2025, attended by Cambridge Approaches; details on file.
19. East West Rail Company, Transport Update Report (2024 non-statutory consultation), Appendix A – TA Scoping Report, paragraphs A4.4.3, A5.1.13 and A7.3.6: https://eastwestrail.co.uk/previous-consultations/consultation2024/transport-update-report ; PDF version: https://ewr-production-files.s3.eu-west-2.amazonaws.com/public/2024-con-docs-/b9bfa9d5ca/Transport-Update-Report-online-PDF.pdf (paragraph A7.3.6 appears at p.234 of 242).
20. Sustainability Appraisal of the Greater Cambridge Local Plan, Appendices E and F (July 2026), paragraphs E.60–E.63: https://consultations.greatercambridgeplanning.org/sites/gcp/files/2026-07/ACPSGCLPSAAEF_2026.pdf
21. Sustainability Appraisal of the Greater Cambridge Local Plan, Appendices C and D (July 2026): https://consultations.greatercambridgeplanning.org/sites/gcp/files/2026-07/ACPSGCLPSAACD_2026.pdf
22. Department for Transport, 'Cambourne to Cambridge guided busway: Transport and Works Act order', decision published 8 September 2026: https://www.gov.uk/government/publications/cambourne-to-cambridge-guided-busway-transport-and-works-act-order
23. 'Government gives green light to controversial £192m Cambourne to Cambridge busway', Cambridge Independent, 8 September 2026: https://www.cambridgeindependent.co.uk/news/government-gives-green-light-to-controversial-192m-cambourn-9481977/
24. South Cambridgeshire Local Plan (2018), Policy SS/7 (Bourn Airfield New Village, approximately 3,500 dwellings): https://www.scambs.gov.uk/media/ghxi3aly/south-cambridgeshire-local-plan-2018-chapter-3-strategic-sites.pdf ; outline planning permission ref. S/3440/18/OL, granted July 2024.
25. Savills (UK) Ltd, on behalf of Martin Grant Land, representation on the Draft Greater Cambridge Local Plan (Regulation 18 consultation), 30 January 2026, executive summary and commentary on Policy S/CBN, paragraph 3.
26. Direct oral communication to Cambridge Approaches from two Cambridgeshire County Councillors, in the course of this consultation. Names are withheld in this representation to preserve ongoing working relationships.
27. Proposed Submission Greater Cambridge Local Plan, Policy S/CBN: Cambourne North, paragraphs 5 and 36(d): https://consultations.greatercambridgeplanning.org/proposed-submission-greater-cambridge-local-plan/site-allocations/new-settlements/policy-scbn
28. Cambridge Approaches, ‘EWR Bedford to Cambridge: Does it reduce CO2 emissions?’ https://cambridgeapproaches.org/ewr-bedford-to-cambridge-does-it-reduce-co2-emissions/
29. Elizabeth line: central-section construction cost of approximately £18.9 billion; ridership of 243 million passengers in the financial year ending March 2025, an average of approximately 665,000 passengers per day: https://en.wikipedia.org/wiki/Elizabeth_line
30. Cambridge City Council, 'Initial response to government's Development Corporation for Greater Cambridge' (3 June 2026): https://www.cambridge.gov.uk/news/2026/06/03/initial-response-to-governments-development-corporation-for-greater-cambridge . The Greater Cambridge Development Corporation was established by government Order on 23 July 2026, and is expected to take on development management powers for schemes above 250 dwellings and 5,000 sq.m of commercial space from 2027, and to take over Local Plan-making after this Plan.