Greater Cambridge Local Plan: Proposed Submission

Hill full representations are set out within the attached document named: "GCLP Reg 19 Consultation Representations - Cambridge East". Specifically please see Section 4: Development Management Policies for relevant comments regarding Policy H/AH.

Hill full representations are set out within the attached document named: "GCLP Reg 19 Consultation Representations - Cambridge East". Specifically please see Section 4: Development Management Policies for relevant comments regarding Policy H/AH

Policy H/AH: Affordable Housing
Marshall’s Regulation 18 representations highlighted that draft Policy H/AH sets a specific breakdown of tenure types for schemes over 15 dwellings, with no allowance in the policy for a departure from that tenure split where a more appropriate solution can be justified at the time of application based on evidence of need.
This Policy remains unchanged from the Regulation 18 Plan, requiring major development proposals to provide affordable housing in accordance with Table 6 of the GCLP, which then sets out the mix of tenures within the affordable housing component of scheme. The lack of flexibility is arguably at odds with both 2024 NPPF paragraph 66 and with 2026 NPPF Policy HO8, both of which recognise the role that location plays in determining what the appropriate tenure mix may be.
Whilst the draft policies reflect GCSP’s view of city-wide issues, they are not necessarily right for every site and it is inevitable that the need for different types of affordable housing will vary based on location. The urban nature of Cambridge East, which will provide a significant proportion of employment floorspace and is well-connected to the City Centre and key employment hubs, is likely to generate a different need and breakdown of affordable housing tenures to new settlements or village locations. Whilst it might be appropriate to indicate an illustrative breakdown of tenure types to guide applications, sufficient flexibility should be baked into the policy to enable sites to accommodate affordable housing that truly reflect the community’s needs.
Amendments to tenure mix are commonplace on strategic sites, with Marleigh and Waterbeach being two examples where this has occurred. Hill anticipates that a bespoke Site Wide Housing Strategy would be submitted with a planning application for the site and that this would provide a more appropriate vehicle for determining the right affordable housing mix at Cambridge East.

Hill full representations are set out within the attached document named: "GCLP Reg 19 Consultation Representations - Cambridge East". Specifically please see Section 5: Infrastructure and Viability for relevant comments regarding Policy I/ID.

Hill full representations are set out within the attached document named: "GCLP Reg 19 Consultation Representations - Cambridge East". Specifically please see Section 5: Infrastructure and Viability for relevant comments regarding Policy I/ID.

Infrastructure and Delivery
Draft Policy I/ID (Infrastructure and Delivery) confirms that planning permission will only be granted for proposals that have made suitable arrangements for the improvement or provision of physical and social infrastructure necessary to make the scheme acceptable in planning terms. This requirement is supported by the Infrastructure Delivery Plan (IDP) which identifies a list of infrastructure requirements that GCSP has deemed necessary to support the growth strategy.
For Cambridge East, a specific itemised list is included at Appendix A of the Infrastructure Delivery Plan and it assumes delivery of 3,950 homes and 21,750sqm of commercial floorspace within the plan period (i.e. 2024-2045). Delivery of development at Cambridge East is scheduled to extend beyond the plan period, and consequently there are details to be established through a planning application in relation to phasing and timing of infrastructure to ensure the development is appropriately serviced and any impacts of the development mitigated.
Hill reserves the right to demonstrate and evidence the appropriate package of infrastructure requirements for the development, having regard to the requirements of the IDP, once there is greater clarity on the scope of the application.
In the meantime, Hill have more detailed comments on the specific requirements listed in Appendix A of the Infrastructure Delivery Schedule for Cambridge East.
Notwithstanding the above, the IDP fails to identify several key pieces of transport infrastructure that are considered to be relevant to the delivery of Cambridge East:
 Newmarket Road Travel Hub: The Greater Cambridge Partnership (GCP) is proposing to relocate the existing Newmarket Road Park & Ride to a new Newmarket Road Travel Hub site near the Newmarket Road and Airport Way junction. The current Park & Ride is on leased land within the Marleigh development and is safeguarded for future development, so GCP is progressing a replacement site off Airport Way. The new travel hub would form part of the movement network serving the development at Cambridge East, materially strengthening the site’s wider connectivity. GCP has been preparing an application which it is proposing to submit later in 2026. The Travel Hub has been progressed as part of the Cambridge Eastern Access programme and the GCP budget indicates funding of £58.5m is agreed to deliver this2.
 Eastern Access Phase A: Phase A, proposed by the GCP, is not dependent on the relocation of airport activities but would see Newmarket Road improved for public transport, walking and cycling alongside enhanced landscaping and environmental schemes. Whilst not dependent on the airport being redeveloped, Phase A will have significant benefits for Cambridge East by delivering infrastructure that will enable a positive modal shift for both the existing and any new community. The Phase A Business Case has been approved and detailed scheme designs have been prepared by the GCP. Phase A is funded with the current GCP budgets.
 Fulbourn Greenway: This has not yet been delivered, but forms an important component of the wider active travel network within which Cambridge East will sit. The scheme is being promoted and funded separately through the GCP Greenways project and is therefore not an item that Cambridge East is required to deliver directly. However, it remains a strategically important corridor that will provide enhanced walking, wheeling and cycling connections between Cambridge East, Fulbourn and destinations further south and east. Whilst the Greenway has not yet been delivered, it should be identified within the list of related transport schemes to ensure that the masterplanning and delivery of Cambridge East facilitates appropriate connections to it, thereby maximising sustainable travel opportunities and strengthening the site's integration with the wider active travel network.
Comments on the social infrastructure requirements are as follows:
 Education: 3,950 homes in the allocation does not in itself justify the delivery of an 8FE secondary school. The IDP and Local Plan policies must make explicit that education delivery should always be proportionate to need from the development and that, should a school be required in excess of the needs of the Cambridge East site, funding for both land and capital cost will be pooled from other developments and/or Basic Needs funding. The IDP Appendix A for Cambridge East should make it explicit whether sixth form is intended to be included or excluded from both the land-take and capital contribution.
 New healthcare facility: £15m is a very high cost for a health centre of the likely scale required here – all contributions will be based on a realistic and proportionate cost planning exercise at the time of agreeing the S106.
 Community Centres and Libraries: Budgets for library and community floorspace should be seen as indicative until an appropriate site-specific strategy is agreed, relevant to the needs of the community at the time.
 Sports Hall: The option should be retained for the sports hall provision to be met by an appropriately designed collocated facility at the secondary school and therefore have negligible net additional cost.
 Swimming Pool: The swimming pool requirement in the IDP should take account of the representations made for Policy S/CE regarding the specific size dimensions of the pool which should be determined based on up-to-date evidence at the time the application is submitted. Any swimming pool meeting wider regional needs will require contributions from other developments where this facility is addressing those needs.
 Outdoor Sports: The sports provision should be made flexible to respond to more diverse outdoor sport, recreation and activity needs at the time of delivery, including sport for women and girls.
Hill request that the IDP Appendix A Infrastructure Delivery Schedule for Cambridge East is reconsidered on the basis of the comments identified above.

Viability
Hill have reviewed the Council's viability evidence and consider that a number of the assumptions underpinning the assessment require further scrutiny before the conclusions can be relied upon.
While the viability appraisal provides a high-level assessment of plan-wide viability, it does not fully reflect the specific circumstances, costs and infrastructure requirements associated with the delivery of Cambridge East. The evidence should therefore not be treated as a definitive assessment of the viability implications of the allocation or the policy requirements proposed within the Plan.
In particular, there is insufficient evidence that the full cost of strategic transport infrastructure required to support Cambridge East has been tested through the viability appraisal.
The assessment states that "the cost of mitigation measures (e.g. highways improvements, travel plans, bus contributions) is assumed to be included in the CIL rate and the site-specific s106 contributions." (page 23). However, the current CIL charging schedule was established to address infrastructure requirements associated with the adopted Local Plans (which doesnt not include an allocation for Cambridge East) and the assessment does not reflect the transport interventions necessary to support the scale of growth proposed through the emerging Greater Cambridge Local Plan. Equally, the extent of site-specific transport mitigation required to support Cambridge East has not yet been fully determined, which will be established through ongoing masterplanning, transport modelling and infrastructure planning work. The full cost implications of these requirements are not yet known and hence have not been reflected in the viability assessment.
This is acknowledged in the Council’s appraisal which states "at this point our appraisals do not incorporate any infrastructure costs over and above standard development costs" and that "site specific constraints may affect costs on a case-by-case basis” (page 24). Cambridge East is a complex strategic allocation with a range of site-specific costs, including relocation and vacant possession costs associated with existing airport operations, together with transport infrastructure requirements that remain subject to further assessment. By its own admission, the viability appraisal has not incorporated these costs. As a result, the assessment does not provide a complete picture of the cost assumptions associated with the delivery of Cambridge East.
There is also a risk that the infrastructure assumptions underpinning the viability evidence do not fully reflect the long-term delivery trajectory of Cambridge East. The Infrastructure Delivery Plan principally considers infrastructure required to support development within the plan period, whereas Cambridge East will continue to be delivered significantly beyond that timeframe. Consequently, the appraisal has not assessed the full extent of infrastructure requirements that may arise over the lifetime of the development, particularly where strategic transport interventions are linked to later phases of growth.
Hill will continue to undertake detailed masterplanning and technical work to better understand the precise costs associated with the development, which will provide a more detailed picture than presented in the evidence that supports the Local Plan. If necessary, in accordance with the requirements of Policy DM5 of the NPPF (2026), this will support a financial viability assessment that may be submitted along the future planning application for the site.

Community Infrastructure Levy
5.15 The draft policy states that financial contributions via the Community Infrastructure Levy will be required where this is operable at the point of the application. In relation to Cambridge East, Quod submitted representations on behalf of Marshalls to the Draft Charging Schedule consultation which took place in February and March 2026 (Appendix 5). These representations highlight that the proposed CIL appears to have been calculated to help meet a gap in infrastructure funding relevant to the 2018 local plans. Those local plans do not assume or plan for the development of the Cambridge East site – they in fact prevent its development until after those local plans have been reviewed. Hill intends to submit a Hearing Statement ahead of the CIL examination which builds upon Marshall’s earlier representations.
Through those representations, it is therefore proposed that the Charging Schedule should not apply to the development of the land and amendments have been sought to ensure the status of the Charging Schedule and its relationship to future growth is clarified.
Hill have commenced a masterplanning exercise to determine the type and scale of development that planning permission will be sought for, but this is currently at an early stage. In the meantime, the draft site allocation in the emerging GCLP (Policy S/CE) indicates that the site’s development will need to be supported by a range of infrastructure albeit the scale of development and the range of infrastructure has not yet been masterplanned or assessed.
For example, the Regulation 19 draft GCLP sets high expectations for the site’s sustainable development, including in relation to transport. In particular, draft Policy S/CE provides that the site’s development must:
“Ensure an exemplar approach to movement and transport within and through the site, transforming the wider connectivity of the eastern edge of Cambridge and promoting a low car living approach where ‘walking and wheeling’ are the first choice for most residents, workers and visitors from the outset.”
It is apparent from the draft Policy that a deliberate site-specific solution is required in order to ensure that this and other critical objectives for the site are achieved. The draft site allocation provides:
“To support delivery of the agreed masterplan, a strategic and local transport mitigation plan must be prepared by the developer for agreement with the Local Highways Authority and Local Planning Authority. This must include:
a. Active and public transport measures;
b. Vehicular transport measures, including site access arrangements;
c. A comprehensive parking strategy aligned with low-car living objectives;
d. Infrastructure costing and delivery phasing, demonstrating how the necessary transport measures identified above will be delivered at a time that enables optimal transport outcomes and remains within the agreed trip budget; and
e. Mechanisms for delivery, monitoring and review including potential delivery through Section 106 obligations, or CIL or other appropriate funding mechanisms.”
No discussions have yet taken place about how any site-specific funding and delivery mechanism will work but it is clear that it must be tailored to the requirements of the site, rather than a generalised city-wide CIL.
Similarly, draft Policy S/CE requires the site’s development to contain internal travel networks which connect Cambridge East to other key destinations through:
“iii. A package of bus service enhancements, or other public transport modes where appropriate, connecting the site with North East Cambridge, West Cambridge, Cambridge City Centre, Cambridge railway station and the Cambridge Biomedical Campus;
iv. A high-quality public transport scheme, linking the high-quality public transport route within the site to the city centre; and
v. Active travel enhancements to wider connections linking with key destinations including Cambridge railway station, City Centre and onwards to West Cambridge and wider destinations on radial high quality public transport corridors (HQPT); Cambridge Regional College, North East Cambridge and Cambridge North Station; Cambridge Biomedical Campus, Cambridge South Station and Cambridge Leisure site.”
To help achieve this, a wider Greater Cambridge Transport Study (“GCTS”) is being prepared to underpin the GCLP. However, that GCTS is not yet developed, tested or costed by the authorities and no funding mechanism has been drafted to enable its delivery.
These issues will be worked up through the finalisation of the GCLP and the submission of a planning application. There is no reference to them in the documents supporting or justifying the current draft CIL. It would be inappropriate to apply a CIL which is based on delivering the 2018 Local Plans to development and infrastructure which is being planned and costed in the emerging GCLP, which will need to devise its own delivery and funding mechanism if it is to be found sound. Any CIL or other funding mechanism relevant to Cambridge East, therefore, needs to be planned and tested alongside the policies of the GCLP, not the 2018 plans.
As a strategic site and a cornerstone of the emerging GCLP, the Cambridge East site is very different from other sites that may be allocated in the plan. In particular, the emerging draft allocation Policy S/CE identifies that Cambridge East will have its own unique infrastructure requirements – and that sufficient confidence in the provision of that infrastructure side by side with the development of the site will be necessary.
The timely provision of bespoke infrastructure would be jeopardised if Cambridge East is simply another site contributing to pooled infrastructure funding. In order to demonstrate and achieve its deliverability, a bespoke outcome will be necessary.
Exclusion from general CIL would not be unusual for strategic sites of the scale of Cambridge East (or often smaller). For strategic sites and infrastructure, the PPG references the need for a charging authority to “take development costs into account when setting its levy rate or rates, particularly those likely to be incurred on strategic sites or brownfield land. A realistic understanding of costs is essential to the proper assessment of viability in an area.” (paragraph 021).
In relation to strategic sites, it further provides:
“Can authorities set different rates for strategic sites?
“Charging authorities may want to consider how zonal rates can ensure that the levy compliments plan policies for strategic sites. This may include setting specific rates for strategic sites that reflect the land value uplift their development creates. Low or zero rates may be appropriate where plan policies require significant contributions towards housing or infrastructure through planning obligations and this is evidenced by an assessment of viability". Paragraph: 026 Reference ID: 25-026-20190901
The Guidance reflects the fact that the application of a generalised CIL becomes an added complication for a strategic site. The Council will seek to secure the delivery of site-specific infrastructure through planning conditions and obligations. A generalised CIL adds cost without ensuring delivery, compared with the direct link that would be achieved between securing the requirement through planning obligations.
The addition of a generalised CIL also risks undermining delivery by double taxing strategic sites (with CIL and a full s.106 package). The recently published Planning Obligations SPD (adopted by the Councils in 2026) makes little reference to CIL and gives no comfort in this regard. Planning obligations are the most effective route to securing infrastructure when it is required alongside the delivery of new homes.
Therefore, Hill seek, either through amendments to this policy, the Cambridge East policy, through amendments to the draft CIL Charging Schedule or a statement of common ground, that the Cambridge East is nil rated for CIL and the bespoke package of infrastructure required to support the development is determined through up to date evidence submitted with the planning application. If at the time an application is advanced the current draft CIL Charging Schedule linked to the 2018 Local Plan is adopted and an update to the Charging Schedule based on the GCLP is not in place, as per Policy H013 of the NPPF, Hill will wish to work with the local planning authority to develop a 'consenting framework’ to reflect the strategic nature of the site and potential change in circumstances for infrastructure delivery.

Hill full representations are set out within the attached document named: "GCLP Reg 19 Consultation Representations - Cambridge East". Specifically please see Section 4: Development Management Policies for relevant comments regarding Policy CC/WE.

The Regulation 19 policy continues to require residential development of 100 or more dwellings to achieve water consumption of no more than 80 litres/person/day, a level which remains significantly beyond current industry practice and whose delivery is dependent upon technological, regulatory and infrastructure changes that are currently outside the control of developers.

Hill full representations are set out within the attached document named: "GCLP Reg 19 Consultation Representations - Cambridge East". Specifically please see Section 4: Development Management Policies for relevant comments regarding Policy CC/WE.

Marshall’s Regulation 18 representations in relation to Policy CC/WE remain relevant and should be read alongside these Regulation 19 representations. Whilst a number of amendments have been made to the policy wording, the principal concerns raised at Regulation 18 have not been substantively addressed.
In particular, the Regulation 19 policy continues to require residential development of 100 or more dwellings to achieve water consumption of no more than 80 litres/person/day, a level which remains significantly beyond current industry practice and whose delivery is dependent upon technological, regulatory and infrastructure changes that are currently outside the control of developers.
4.46 The policy also continues to rely upon water reuse and recycling solutions without addressing the concerns previously raised regarding the ownership, operation, maintenance and long-term viability of such systems, nor the absence of an established regulatory framework to provide consumer protection.
Similarly, the Regulation 19 draft does not address the concerns raised regarding the treatment of Managed Aquifer Recharge (MAR) within water consumption calculations. As previously noted, current approaches risk discouraging solutions that facilitate groundwater recharge in favour of measures that divert water away from natural recharge processes, potentially undermining the wider objective of protecting local groundwater resources and chalk streams.
The Regulation 19 policy also continues to provide limited recognition of the important role that strategic water infrastructure projects, district-scale water reuse schemes, future potable water recycling initiatives and the emerging Greater Cambridge Water Credits scheme are expected to play in achieving the Plan's water efficiency objectives. Achieving the requirements of the policy therefore remains substantially dependent on actions by water companies, regulators and public authorities, rather than developers alone.
For these reasons, Hill stand by the position set out within Marshall’s Regulation 18 representations. The key points raised therein remain applicable and should be given full consideration in the examination of the Plan and the further development of Policy CC/WE and its supporting text.

Hill full representations are set out within the attached document named: "GCLP Reg 19 Consultation Representations - Cambridge East". Specifically please see Section 4: Development Management Policies for relevant comments regarding general Great Places policies.

Hill full representations are set out within the attached document named: "GCLP Reg 19 Consultation Representations - Cambridge East". Specifically please see Section 4: Development Management Policies for relevant comments regarding general Great Places policies and Jobs.

Chapter 6 (Wellbeing and Social Inclusion) & Chapter 7 (Great Places)
The policies in these chapters are well intentioned but there are many areas where the policies are:
 Repetitious – with many repeated references to the same principles. For example transport and accessibility of services and facilities, provision of routes and sustainability of transport are repeated throughout. There are 43 instances of the term “well designed”; 18 instances of “sustainable travel”. There are c.45 policy provisions or supporting statements that make explicit reference to locating development in sustainable locations; walking, cycling or active travel; or public transport and sustainable transport choices. Policy WS/HD acknowledges this cross reference but then continues to provide extensive supporting text that is unnecessary. Health or wellbeing are then mentioned in around 50 other places. We have no doubt these are important points but this can be dealt with through a single well worded policy, not to be repeated under every section.
 Highly subjective and qualitative – making them very challenging to meaningfully measure against or ensure compliance with, i.e. ‘well-designed’. The policies are full of caveats and exclusions, and we encourage the authority to consider whether, when such flexibility or range of variables is clearly needed, it is appropriate to be controlling these factors through the Local Plan process.
The supporting text has many contextual details that are interesting and could form guidance or ‘best practice notes’. But these sections add large amounts of text to an already very long document without illuminating the policy or aiding interpretation of that policy in any meaningful or specific way. They should be removed to aid overall clarity and brevity.

Policy J/AW: Affordable workspace and creative industries
Hill does not support the introduction of an affordable workspace policy in any form related to the Cambridge East site allocation.
Affordable workspace policies emerged from a concern in London that specific, niche, clustered businesses that have an economic or cultural benefit outside their immediate sphere (such as the historical, cultural and economic significance of Hatton Garden) could be under pressure from rent rises. In such specific and localised circumstances, it may be justified to implement policies to protect access for those business to workspace in that area.
There is no evidence to demonstrate that the use of more generalised affordable workspace policies is a good use of economic resources and planning powers for these reasons:
They represent a diversion of resources that effectively acts as a subsidy to private enterprises. There is no justification for mandating resources to be diverted from other obligations (affordable housing, open space, etc) to subsidise the operation of private business. This is an opportunity cost which, in a challenging market, is very unlikely to result in the best public outcomes;
It is unlikely to meet an unmet need. Even at very high discount rates, brand new Cat A floorspace is very unlikely to be more affordable than much of the space on the second-hand market. The effect is to subsidise businesses who are already doing relatively well. A blanket affordable workspace requirement also risks delivering space for which there is limited operator or occupier demand, particularly where it is not targeted at specific sectors or identified needs, potentially resulting in underutilised floorspace and reduced market flexibility. In some cases the beneficiaries may be a charity or social enterprise, but if the authority is intending to deliver a 10% of all net additional floorspace in its plan as affordable, that is well in excess of the space needed for such occupiers (90,000 sqm in total across the plan).
It creates a constraint and risk around delivery of business and employment space which is front and centre of the GCSP and national aspirations for growth. Cambridge is one of the most important growth zones in the UK and any impediment to growth in this area (such as occupation triggers, Grampians, and challenges of finding eligible operators and tenants) would add risk, complexity and investment aversion.
Many commercial operators chose to offer rent free periods, discounts, amortised fitouts and flexible terms in order to attract a wide range of occupiers and a resilient occupier base. It is very likely that such offers will be available at this site, but they should not be mandated. Small or flexible sized units are naturally more affordable and would generally be part of any strategic commercial offer. Commercial operators also voluntarily run incubators and SME hubs because it makes good business sense. These approaches do not need to be mandated but are a natural response from developers to placemaking, value creation and tenant offer, achieved without creating risk to investment in Cambridge.

Hill full representations are set out within the attached document named: "GCLP Reg 19 Consultation Representations - Cambridge East". Specifically please see Section 5: Infrastructure and Viability for relevant comments regarding Policy I/ID.

Infrastructure and Delivery
Draft Policy I/ID (Infrastructure and Delivery) confirms that planning permission will only be granted for proposals that have made suitable arrangements for the improvement or provision of physical and social infrastructure necessary to make the scheme acceptable in planning terms. This requirement is supported by the Infrastructure Delivery Plan (IDP) which identifies a list of infrastructure requirements that GCSP has deemed necessary to support the growth strategy.
For Cambridge East, a specific itemised list is included at Appendix A of the Infrastructure Delivery Plan and it assumes delivery of 3,950 homes and 21,750sqm of commercial floorspace within the plan period (i.e. 2024-2045). Delivery of development at Cambridge East is scheduled to extend beyond the plan period, and consequently there are details to be established through a planning application in relation to phasing and timing of infrastructure to ensure the development is appropriately serviced and any impacts of the development mitigated.
Hill reserves the right to demonstrate and evidence the appropriate package of infrastructure requirements for the development, having regard to the requirements of the IDP, once there is greater clarity on the scope of the application.
In the meantime, Hill have more detailed comments on the specific requirements listed in Appendix A of the Infrastructure Delivery Schedule for Cambridge East.
Notwithstanding the above, the IDP fails to identify several key pieces of transport infrastructure that are considered to be relevant to the delivery of Cambridge East:
 Newmarket Road Travel Hub: The Greater Cambridge Partnership (GCP) is proposing to relocate the existing Newmarket Road Park & Ride to a new Newmarket Road Travel Hub site near the Newmarket Road and Airport Way junction. The current Park & Ride is on leased land within the Marleigh development and is safeguarded for future development, so GCP is progressing a replacement site off Airport Way. The new travel hub would form part of the movement network serving the development at Cambridge East, materially strengthening the site’s wider connectivity. GCP has been preparing an application which it is proposing to submit later in 2026. The Travel Hub has been progressed as part of the Cambridge Eastern Access programme and the GCP budget indicates funding of £58.5m is agreed to deliver this2.
 Eastern Access Phase A: Phase A, proposed by the GCP, is not dependent on the relocation of airport activities but would see Newmarket Road improved for public transport, walking and cycling alongside enhanced landscaping and environmental schemes. Whilst not dependent on the airport being redeveloped, Phase A will have significant benefits for Cambridge East by delivering infrastructure that will enable a positive modal shift for both the existing and any new community. The Phase A Business Case has been approved and detailed scheme designs have been prepared by the GCP. Phase A is funded with the current GCP budgets.
 Fulbourn Greenway: This has not yet been delivered, but forms an important component of the wider active travel network within which Cambridge East will sit. The scheme is being promoted and funded separately through the GCP Greenways project and is therefore not an item that Cambridge East is required to deliver directly. However, it remains a strategically important corridor that will provide enhanced walking, wheeling and cycling connections between Cambridge East, Fulbourn and destinations further south and east. Whilst the Greenway has not yet been delivered, it should be identified within the list of related transport schemes to ensure that the masterplanning and delivery of Cambridge East facilitates appropriate connections to it, thereby maximising sustainable travel opportunities and strengthening the site's integration with the wider active travel network.
Comments on the social infrastructure requirements are as follows:
 Education: 3,950 homes in the allocation does not in itself justify the delivery of an 8FE secondary school. The IDP and Local Plan policies must make explicit that education delivery should always be proportionate to need from the development and that, should a school be required in excess of the needs of the Cambridge East site, funding for both land and capital cost will be pooled from other developments and/or Basic Needs funding. The IDP Appendix A for Cambridge East should make it explicit whether sixth form is intended to be included or excluded from both the land-take and capital contribution.
 New healthcare facility: £15m is a very high cost for a health centre of the likely scale required here – all contributions will be based on a realistic and proportionate cost planning exercise at the time of agreeing the S106.
 Community Centres and Libraries: Budgets for library and community floorspace should be seen as indicative until an appropriate site-specific strategy is agreed, relevant to the needs of the community at the time.
 Sports Hall: The option should be retained for the sports hall provision to be met by an appropriately designed collocated facility at the secondary school and therefore have negligible net additional cost.
 Swimming Pool: The swimming pool requirement in the IDP should take account of the representations made for Policy S/CE regarding the specific size dimensions of the pool which should be determined based on up-to-date evidence at the time the application is submitted. Any swimming pool meeting wider regional needs will require contributions from other developments where this facility is addressing those needs.
 Outdoor Sports: The sports provision should be made flexible to respond to more diverse outdoor sport, recreation and activity needs at the time of delivery, including sport for women and girls.
Hill request that the IDP Appendix A Infrastructure Delivery Schedule for Cambridge East is reconsidered on the basis of the comments identified above.

Viability
Hill have reviewed the Council's viability evidence and consider that a number of the assumptions underpinning the assessment require further scrutiny before the conclusions can be relied upon.
While the viability appraisal provides a high-level assessment of plan-wide viability, it does not fully reflect the specific circumstances, costs and infrastructure requirements associated with the delivery of Cambridge East. The evidence should therefore not be treated as a definitive assessment of the viability implications of the allocation or the policy requirements proposed within the Plan.
In particular, there is insufficient evidence that the full cost of strategic transport infrastructure required to support Cambridge East has been tested through the viability appraisal.
The assessment states that "the cost of mitigation measures (e.g. highways improvements, travel plans, bus contributions) is assumed to be included in the CIL rate and the site-specific s106 contributions." (page 23). However, the current CIL charging schedule was established to address infrastructure requirements associated with the adopted Local Plans (which doesnt not include an allocation for Cambridge East) and the assessment does not reflect the transport interventions necessary to support the scale of growth proposed through the emerging Greater Cambridge Local Plan. Equally, the extent of site-specific transport mitigation required to support Cambridge East has not yet been fully determined, which will be established through ongoing masterplanning, transport modelling and infrastructure planning work. The full cost implications of these requirements are not yet known and hence have not been reflected in the viability assessment.
This is acknowledged in the Council’s appraisal which states "at this point our appraisals do not incorporate any infrastructure costs over and above standard development costs" and that "site specific constraints may affect costs on a case-by-case basis” (page 24). Cambridge East is a complex strategic allocation with a range of site-specific costs, including relocation and vacant possession costs associated with existing airport operations, together with transport infrastructure requirements that remain subject to further assessment. By its own admission, the viability appraisal has not incorporated these costs. As a result, the assessment does not provide a complete picture of the cost assumptions associated with the delivery of Cambridge East.
There is also a risk that the infrastructure assumptions underpinning the viability evidence do not fully reflect the long-term delivery trajectory of Cambridge East. The Infrastructure Delivery Plan principally considers infrastructure required to support development within the plan period, whereas Cambridge East will continue to be delivered significantly beyond that timeframe. Consequently, the appraisal has not assessed the full extent of infrastructure requirements that may arise over the lifetime of the development, particularly where strategic transport interventions are linked to later phases of growth.
Hill will continue to undertake detailed masterplanning and technical work to better understand the precise costs associated with the development, which will provide a more detailed picture than presented in the evidence that supports the Local Plan. If necessary, in accordance with the requirements of Policy DM5 of the NPPF (2026), this will support a financial viability assessment that may be submitted along the future planning application for the site.

Community Infrastructure Levy
5.15 The draft policy states that financial contributions via the Community Infrastructure Levy will be required where this is operable at the point of the application. In relation to Cambridge East, Quod submitted representations on behalf of Marshalls to the Draft Charging Schedule consultation which took place in February and March 2026 (Appendix 5). These representations highlight that the proposed CIL appears to have been calculated to help meet a gap in infrastructure funding relevant to the 2018 local plans. Those local plans do not assume or plan for the development of the Cambridge East site – they in fact prevent its development until after those local plans have been reviewed. Hill intends to submit a Hearing Statement ahead of the CIL examination which builds upon Marshall’s earlier representations.
Through those representations, it is therefore proposed that the Charging Schedule should not apply to the development of the land and amendments have been sought to ensure the status of the Charging Schedule and its relationship to future growth is clarified.
Hill have commenced a masterplanning exercise to determine the type and scale of development that planning permission will be sought for, but this is currently at an early stage. In the meantime, the draft site allocation in the emerging GCLP (Policy S/CE) indicates that the site’s development will need to be supported by a range of infrastructure albeit the scale of development and the range of infrastructure has not yet been masterplanned or assessed.
For example, the Regulation 19 draft GCLP sets high expectations for the site’s sustainable development, including in relation to transport. In particular, draft Policy S/CE provides that the site’s development must:
“Ensure an exemplar approach to movement and transport within and through the site, transforming the wider connectivity of the eastern edge of Cambridge and promoting a low car living approach where ‘walking and wheeling’ are the first choice for most residents, workers and visitors from the outset.”
It is apparent from the draft Policy that a deliberate site-specific solution is required in order to ensure that this and other critical objectives for the site are achieved. The draft site allocation provides:
“To support delivery of the agreed masterplan, a strategic and local transport mitigation plan must be prepared by the developer for agreement with the Local Highways Authority and Local Planning Authority. This must include:
a. Active and public transport measures;
b. Vehicular transport measures, including site access arrangements;
c. A comprehensive parking strategy aligned with low-car living objectives;
d. Infrastructure costing and delivery phasing, demonstrating how the necessary transport measures identified above will be delivered at a time that enables optimal transport outcomes and remains within the agreed trip budget; and
e. Mechanisms for delivery, monitoring and review including potential delivery through Section 106 obligations, or CIL or other appropriate funding mechanisms.”
No discussions have yet taken place about how any site-specific funding and delivery mechanism will work but it is clear that it must be tailored to the requirements of the site, rather than a generalised city-wide CIL.
Similarly, draft Policy S/CE requires the site’s development to contain internal travel networks which connect Cambridge East to other key destinations through:
“iii. A package of bus service enhancements, or other public transport modes where appropriate, connecting the site with North East Cambridge, West Cambridge, Cambridge City Centre, Cambridge railway station and the Cambridge Biomedical Campus;
iv. A high-quality public transport scheme, linking the high-quality public transport route within the site to the city centre; and
v. Active travel enhancements to wider connections linking with key destinations including Cambridge railway station, City Centre and onwards to West Cambridge and wider destinations on radial high quality public transport corridors (HQPT); Cambridge Regional College, North East Cambridge and Cambridge North Station; Cambridge Biomedical Campus, Cambridge South Station and Cambridge Leisure site.”
To help achieve this, a wider Greater Cambridge Transport Study (“GCTS”) is being prepared to underpin the GCLP. However, that GCTS is not yet developed, tested or costed by the authorities and no funding mechanism has been drafted to enable its delivery.
These issues will be worked up through the finalisation of the GCLP and the submission of a planning application. There is no reference to them in the documents supporting or justifying the current draft CIL. It would be inappropriate to apply a CIL which is based on delivering the 2018 Local Plans to development and infrastructure which is being planned and costed in the emerging GCLP, which will need to devise its own delivery and funding mechanism if it is to be found sound. Any CIL or other funding mechanism relevant to Cambridge East, therefore, needs to be planned and tested alongside the policies of the GCLP, not the 2018 plans.
As a strategic site and a cornerstone of the emerging GCLP, the Cambridge East site is very different from other sites that may be allocated in the plan. In particular, the emerging draft allocation Policy S/CE identifies that Cambridge East will have its own unique infrastructure requirements – and that sufficient confidence in the provision of that infrastructure side by side with the development of the site will be necessary.
The timely provision of bespoke infrastructure would be jeopardised if Cambridge East is simply another site contributing to pooled infrastructure funding. In order to demonstrate and achieve its deliverability, a bespoke outcome will be necessary.
Exclusion from general CIL would not be unusual for strategic sites of the scale of Cambridge East (or often smaller). For strategic sites and infrastructure, the PPG references the need for a charging authority to “take development costs into account when setting its levy rate or rates, particularly those likely to be incurred on strategic sites or brownfield land. A realistic understanding of costs is essential to the proper assessment of viability in an area.” (paragraph 021).
In relation to strategic sites, it further provides:
“Can authorities set different rates for strategic sites?
“Charging authorities may want to consider how zonal rates can ensure that the levy compliments plan policies for strategic sites. This may include setting specific rates for strategic sites that reflect the land value uplift their development creates. Low or zero rates may be appropriate where plan policies require significant contributions towards housing or infrastructure through planning obligations and this is evidenced by an assessment of viability". Paragraph: 026 Reference ID: 25-026-20190901
The Guidance reflects the fact that the application of a generalised CIL becomes an added complication for a strategic site. The Council will seek to secure the delivery of site-specific infrastructure through planning conditions and obligations. A generalised CIL adds cost without ensuring delivery, compared with the direct link that would be achieved between securing the requirement through planning obligations.
The addition of a generalised CIL also risks undermining delivery by double taxing strategic sites (with CIL and a full s.106 package). The recently published Planning Obligations SPD (adopted by the Councils in 2026) makes little reference to CIL and gives no comfort in this regard. Planning obligations are the most effective route to securing infrastructure when it is required alongside the delivery of new homes.
Therefore, Hill seek, either through amendments to this policy, the Cambridge East policy, through amendments to the draft CIL Charging Schedule or a statement of common ground, that the Cambridge East is nil rated for CIL and the bespoke package of infrastructure required to support the development is determined through up to date evidence submitted with the planning application. If at the time an application is advanced the current draft CIL Charging Schedule linked to the 2018 Local Plan is adopted and an update to the Charging Schedule based on the GCLP is not in place, as per Policy H013 of the NPPF, Hill will wish to work with the local planning authority to develop a 'consenting framework’ to reflect the strategic nature of the site and potential change in circumstances for infrastructure delivery.

See Appendix 4 of submission for tracked changed version

Hill full representations are set out within the attached document named: "GCLP Reg 19 Consultation Representations - Cambridge East". Specifically please see Section 4: Development Management Policies for relevant comments regarding Policy GP/ST.

Policy GP/ST: Skyline and Tall Buildings
The need to deliver growth across Greater Cambridge is well known. Government has made it clear that delivering transformational growth at Cambridge is a national priority and the GCDC has been set up to drive and accelerate the delivery of that growth.
Cambridge East represents a critical part of the development strategy for the GCLP and is also likely to play a significant role in GCDC’s wider growth aspirations. It is therefore essential that development plan policies do not inappropriately limit the scale of growth and ambition for Cambridge East.
The site allocation policy for Cambridge East (Policy S/CE) specifically recognises that the development will include height and massing to create a ‘distinctive city district’, which will include taller buildings in appropriate locations.
Whilst Hill accept the need for new development to respond appropriately to the existing context, the policies of the GCLP should be clearly prepared in the knowledge that to achieve the scale of growth that Government aspires to, development will naturally need to be transformational and at a higher density, mass and scale than the existing context.
However, Policy GP/ST is an example of a policy which is negatively drafted and is predicated on the premise that changes to the skyline should be by exception. That fails to recognise the scale of growth and ambition that Cambridge is required to accommodate. That of course does not mean that development should be allowed to happen at the expense of any change to the skyline, but the policy should recognise that change to the skyline is, by definition of the very scale of development proposed, inevitable, and the key objective should be to ensure that any change is carefully and appropriately assessed and managed.
The policy wording, supporting text and Appendix H, do not adequately reflect the positive aspects of the evidence base report – ‘Skyline and Tall Buildings Baseline, Strategy and Guidance’ (hereafter known as the ‘Skyline Strategy’) – and instead place emphasis on the application of restrictive policy rather than policy that promotes an informed approach to consideration of height and skyline matters.
While the general urban form of Cambridge is ‘subtle and a restrained skyline when viewed from most angles and distances in and around the city’ (Paragraph 2.6.2 of the Skyline Strategy), tall buildings are acknowledged as characteristic and not inconsistent with the city’s character, in particular around the Airport (Paragraphs 2.6.5 and 2.6.6 of the Skyline Strategy). The policy therefore needs to be framed to support the delivery of well-designed and appropriately located development. A change to the skyline could be perceived as positive and a new quarter in this part of the city could, in time itself become a valued part of the city’s skyline and character, much like many of the existing features.
In this context, Hill make two primary comments on draft Policy GP/ST and its supporting text.
Firstly, Criteria 1 of the policy states that proposals that ‘break’ or ‘result in significant change’ to the existing skyline, or are significantly taller than the surrounding build form, must demonstrate how they ‘maintain or enhance’ the skyline and character of Cambridge.
Development at Cambridge East, a highly sustainable location supported by a new EWR station, is likely to change the existing skyline – this is an inevitable outcome that follows the optimisation of the site and supporting transformational growth across Greater Cambridge.
Cambridge East is identified in the Skyline Strategy as ‘bracketing’ the views of the city along with Addenbrookes, and it is noted that the site is ‘distinct’ from the city. As a result, the evidence indicates that a continuation of suburban development is not required and that the distinct nature of the site presents an opportunity to bring forward a proposal that should consider more ambitious development heights than the surrounding suburban development while responding appropriately to the city’s character. This is not clearly reflected in the Skyline Strategy, for example Figure 27 (Tall Building Thresholds) which identifies the baseline for this part of the site as ‘suburban / low rural height zone’. This fails to recognise the core proposition behind the site allocation and the significant change in circumstances that arise from the confirmation of the new Cambridge East station to the immediate south of the site. Instead height proposals for major sites should be subject to separate, detailed review.
Consequently, the 'maintain and enhance' test does not adequately reflect the circumstances of Cambridge East. The evidence base identifies the site as a distinct location from the existing city and acknowledges the opportunity for a more ambitious approach to building heights. Given the scale of development proposed, changes to the skyline and townscape character will inevitably occur. As such, requiring the existing skyline to be 'maintained' is neither realistic nor aligned with the objectives of the allocation. In addition, the term 'enhance' is highly subjective and introduces unnecessary uncertainty. The policy should instead be amended to recognise that change may occur, provided it is appropriately justified through the design process and responds positively to the site's context and Cambridge's valued character.
Secondly, the policy and the explanatory text are supported by evidence in Appendix H and the Skyline Strategy. Hill’s technical team has carefully reviewed these documents and has identified as series of serious issues, including:
The Key View study within the Skyline Strategy, places emphasis on the existing character of the city as essentially low with localised tall historic buildings in the core and more modern tall buildings to the periphery (including the Airport site) which defines the skyline. This is particularly important for Cambridge East, where the scale of the allocation and its role as a major new urban extension will necessitate a degree of flexibility in building heights to support sustainable densities, create legible centres and landmarks, and respond to the emerging transport infrastructure, whilst ensuring that any impact on the wider city skyline is appropriately assessed and managed.
It is important to ensure matters of skyline character, visibility and historic setting are not confused - we are concerned that the matters appear to be conflated. In relation to Viewpoint K from Little Wilbraham Road, there appears to be no justification for the inclusion of that view within the set of strategic views for the Skyline Strategy and the Regulation 19 GCLP more generally. However, as set out in Appendix D of the Skyline Strategy and despite recognition of its ‘illustrative nature’ (Addendum to Heritage Impact Assessment (2026) - Appendix A), the view acts as a principal restriction to height at Cambridge East. As such, the elevation of View K to a strategic view in the Skyline Strategy, and subsequent integration into Appendix H and reference in Policy GP/ST 1B, is of significant concern.
It is also important to note that Strategic Views – Heritage Impact Assessment Baseline 2021 prepared by CBA states at paragraph 1.2.3 “… the study […] does not focus on an identified historic asset or defined group of assets […] Instead, it addresses Cambridge as a city, which is not a defined heritage asset.” Although heritage assets are advanced as reasons for limiting heights or ascribing sensitivities, heritage assessments are specifically aimed at the significance of a heritage asset, rather than the visibility of a heritage asset in a view being equated with a specific heritage sensitivity. Indeed, Historic England’s guidance on setting, The Setting of Heritage Assets, Historic Environment Good Practice Advice in Planning Note 3 (Second Edition – Dec. 2017) notes in the text box at the top right of page 7:
“Being tall structures, church towers and spires are often widely visible across land- and townscapes but, where development does not impact on the significance of heritage assets visible in a wider setting or where not allowing significance to be appreciated, they are unlikely to be affected by small-scale development, unless that development competes with them, as tower blocks and wind turbines may. Even then, such an impact is more likely to be on the landscape values of the tower or spire rather than the heritage values, unless the development impacts on its significance, for instance by impacting on a designed or associative view.”
The Skyline Strategy does not reflect Historic England’s guidance on setting. Instead, sweeping statements are made, for example under the guise of heritage assets, that contradict Historic England’s guidance on setting, e.g. paragraph 2.5.3:
“Many of the [heritage] assets contribute to the skyline of Cambridge in long distance, medium distance and close up views. In particular, the colleges and churches in and around the core are a key feature of the skyline of the City, marking its historic heart.”
The quote above has nothing to do with the significance of the heritage assets, and instead deals with the skyline of Cambridge, though this is cited under the heritage topic. The same section in the document appears to equate the visibility of taller structures with harm to heritage significance, a concept that has been dispelled in numerous appeal decisions but which appears to underpin the conclusions of the study.
It is also noted that heritage assets are highlighted in the various view analyses. Again, this may be relevant to aspects such as the skyline and landmarks, but in most cases the significance of the heritage asset in the views are not properly appreciable. The fact that a heritage asset is visible in a view does not mean the view contributes to its heritage significance. This distinction is not covered in the Skyline Strategy or Appendix H which instead appears to imply any view containing a heritage asset must be of some sensitivity.
The Appendix H and Skyline Strategy, identifies the area south of the green corridor as ‘Suburban /Rural Height Zone 13m (4+ Rst)’. This is assumed to be founded on the Skyline Strategy document, that identifies the existing settlement as Suburban /Rural Height Zone and ‘Somewhat Sensitive’ to tall buildings; an adjoining an area of outline permission with agreed height parameters; and adjoining existing open space that is ‘Highly Sensitive’ to tall building typologies.
However, the evidence fails to recognise that a) the ‘highly sensitive’ open space has tall buildings that appear in its views; b) tall buildings already exist at the Airport and c) the conscious decision to allocate significant growth at Cambridge East. Furthermore, a new EWR station is now to be delivered in the immediate vicinity of this location and as a result there is a clear policy direction that it should support an intensification of development. The new station provides a clear foundation to secure higher densities and by implication heights, which is not reflected in the approach of Appendix H or the Skyline Strategy document.
In light of the above, Hill consider the evidence base to be fundamentally flawed in a number of respects and as a result it should not be cited in the policy or supporting text as a basis for undertaking site specific assessments in support of planning applications. If despite our views reference to the document is to be retained in policy and / or supporting text, it will need to be comprehensively amended to address the matters raised above and associated concerns.
Overall, Hill consider Policy GP/ST to be unsound as drafted, and set out at Appendix 4 the alterations required to the policy wording and the supporting text.