Greater Cambridge Local Plan: Proposed Submission

• The Council welcomes the improved closer working on the Greater Cambridge Local Plan (GCLP) with the Local Planning Authority (LPA) and requests that this continues through further development of the Plan and any associated transport evidence.
• The Council welcomes the positive changes to transport policies made in response to our comments provided at the Reg 18 consultation, specifically in relation to strengthening and clarifying transport infrastructure policies and development management policies.
• The Council welcomes the inclusion of clarity or enhanced coverage of some rail proposals within the Plan, in particular with relation to East West Rail with the Cambridge Station Eastern Access, Cambridge East Station and Cambourne Station reflected.
• The Council welcomes further emphasis and clear provision on the safeguarding of land for transport infrastructure in the Plan. This is vital for the continued development of the strategic transport network, including rail and the Greater Cambridge Partnership programme of schemes.
• The Council is pleased to see clear references to the requirement for developers to submit Transport Assessments and Transport Statements for new developments, and for the inclusion of policy wording covering trip budgets for strategic sites. The Council also welcomes strengthened policy in relation to development proposals needing agreement and joint working with the Council as Local Highway Authority (LHA) and the Cambridge and Peterborough Combined Authority (CPCA) as Local Transport Authority.
• The Council is content that, on the basis of evidence presented in the Transport Evidence Report and through the detail in the Draft Plan (including the various policies), that the development strategy is deliverable in transport terms and that this has been satisfactorily proven to an appropriate level of detail for plan making.
• The Council would however note that vision led planning can only work if viable sustainable modes of transport are provided, and to support a strong and aspirational vision development proposals need to be founded in robust evidence, with appropriate mitigation delivered at the right time.
• The Council welcomes the continued joint working with the LPA and partners on the Infrastructure Delivery Plan (IDP). The Council notes the position in the draft Statement of Common Ground regarding the responsibility for delivery of infrastructure for site specific mitigation.
• The Council notes and supports the policy wording detailing required mitigation for the strategic sites at the earliest opportunity, with alternative mitigation for early stages of delivery requiring sufficient evidence to be agreed with the Council as LHA to demonstrate that the transport impact can be mitigated.

• In broad transport terms the Council supports the GCLP and the associated overarching development strategy. The transport evidence produced to date in the Transport Evidence Report (TER) alongside the development strategy demonstrates that the GCLP is deliverable in transport terms, if sufficient mitigation at the key development locations is provided.
• The Council acknowledges that the CPCA, together with partners is developing a new Transport Strategy for Cambridge and South Cambridgeshire. The transport related comments made by the Council in response to the Draft GCLP are therefore made with the assumption that this new Transport Strategy will be delivered alongside and fully cognisant of the Local Plan, Development Strategy and site-specific mitigation.
• Whilst the Council agrees that in transport terms, the development strategy is able to be delivered and mitigated, the Council must reaffirm that all the strategic sites contained in the draft Local Plan require transport mitigation strategies, agreed with the Council as LHA, to support their delivery. These will be delivered at the appropriate time through the use of Transport Assessments, as noted in the policies.
• The Council is pleased to have been able to work alongside GCSP and partners in the development of the site-specific mitigation strategies to date. This mitigation includes stringent trip budgets, currently included as draft within the plan, which are to be agreed with the Council as LHA through further development of site-specific evidence as set out in the trip budget methodology. In addition, the transport infrastructure requirements for each of the strategic sites are significant, therefore deliverability and viability will continue to be key considerations going forward.
• Related to the above point on mitigation, the Council would re-emphasise that in transport terms, the strategic sites are heavily reliant on the GCP programme of works being delivered. The deliverability and viability of these sites and indeed the deliverability of the wider development strategy is intrinsically linked to the delivery of the GCP transport schemes. Therefore strategic development sites will be expected to facilitate where appropriate as well as contribute to the delivery of these GCP schemes, to support public sector, Community Infrastructure Levy, or other sources of funding.
• The development of the Greater Cambridge Transport Strategy (led by the CPCA) will provide the overarching Transport Strategy to support the GCLP. The Council is working closely with the CPCA to support this process.

• In relation to deliverability and viability, the Council is pleased to have been able to work closely with the LPA and partners on the development of the IDP and the costing of schemes required to deliver the development strategy. The Greater Cambridge Partnership (GCP) schemes, as already noted, are heavily relied upon within the Plan and whilst the GCP programme has funding, it is predicated on match funding for infrastructure and therefore developers are expected to contribute towards schemes that serve their sites. Therefore, it is vital that the IDP contains the obligations for both infrastructure as well as for commuted sums for maintenance and operation, and that costs are periodically refreshed.
• The Council welcomes the work and collaboration on the Infrastructure Delivery Plan and would appreciate future involvement (or with any successor authority) as the IDP is regularly reviewed. The commitment to review the IDP will support its continued robustness.

• The Masterplan for Clifton Rd area should be agreed with the Council (or any successor authority) as LHA, based on suitable transport evidence.
• The Council recognises and supports the importance of active travel for this site, including the delivery of the Chisolm Trail, and restates the importance of effective public transport provision as part of the development, which should be aligned closely with proposals for a new access to Cambridge Station by the East West Rail project. Wider consideration would also see provision for public transport at the Clifton Road site and should be developed through any Transport Assessment and master planning work, supported by appropriate transport evidence.

The LLFA recommends updating the Plan to reflect the August 2026 NPPF, including the new flood risk chapter, incorporation of flood zone and vulnerability guidance, compliance with the 2025 SuDS Standards, and new validation requirements for FRAs and SuDS statements.

A drafting amendment is also required to replace “safe access and egress route” with “safe access and escape route” in line with PPG.

The LLFA further encourages stronger support for above-ground, open SuDS and the SuDS management train approach, prioritising source control measures to deliver flood risk, water quality, biodiversity, amenity and groundwater benefits.

The LLFA has reviewed the Local Plan submitted for review under Regulation 19 of the Town and Country Planning (Local Planning) 2012 and have the following comments to ensure that the Plan is consistent with national policy:
• Officers recommend a review of the latest National Planning Policy Framework (NPPF) changes in 2026 and how this can be applied to the Local Plan. The August 2026 NPPF replaces the December 2024 Framework in full. The main flood risk changes are:
o A dedicated flood risk chapter (F1-F9), which consolidates national flood risk policy into a dedicated section. Alignment with these policies will help ensure the Local Plan remains consistent with the current NPPF.
o Flood Zones, vulnerability classifications and compatibility tables are now in the NPPF itself.
o SuDS must now be designed in accordance with the 2025 National Standards for SuDS.
o National validation requirements introduced, including site-specific Flood Risk Areas (FRAs) and SuDS statements as part of the information expected for relevant applications.
• Please note, on page 135 of the Proposed Submission, there is a reference to 'safe access and egress route'; however, this should be revised to read as 'safe access and escape route' in line with Planning Policy Guidance (PPG).
Officers would encourage specific promotion of above-ground open SuDS such as wetlands, attenuation basins, ponds and swales as they provide water quantity, water quality, amenity and biodiversity benefits. PPG Paragraph 55 details the importance of SuDS which includes reducing the need for carbon-intensive construction and pumped systems, replenishing groundwater resources and capturing and re-using rainwater. There should be reference made to the SuDS Management train. The management train is a sequence of drainage features that collect, convey, store and manage quality of surface water runoff as it drains through the development. Source control, in the management train, should prioritised. They assist in mimicking the natural runoff from the site and provides the first stage of the SuDS Management Train, intercepting surface water at a localised level. As source control can be in the form of bioretention, rain gardens, over paved areas (permeable paving) and on roofs (green roofs) it is possible to fit this in every development around the hard landscaping without taking up much space.

• Soundness – Effectiveness
Additional supporting text requested to be included in supporting information section (pages 229-233): Site area includes a safeguarded Waste Management Area for the partially implemented Energy Innovation Centre (EIC) as shown on the Cambridgeshire and Peterborough Minerals and Waste Local Plan (2021) Policies Map. Developers should be made aware that the partial implementation of this EIC involved the construction of underground tunnels; and this should be considered in any design. It is requested that supporting text to this effect is included in the Plan for this allocation.

• Soundness – Effectiveness
Additional supporting text requested to be included in supporting information section (pages 229-233): Site area includes a safeguarded Waste Management Area for the partially implemented Energy Innovation Centre (EIC) as shown on the Cambridgeshire and Peterborough Minerals and Waste Local Plan (2021) Policies Map. Developers should be made aware that the partial implementation of this EIC involved the construction of underground tunnels; and this should be considered in any design. It is requested that supporting text to this effect is included in the Plan for this allocation.

The County Council has engaged constructively with Greater Cambridge Shared Planning throughout the preparation of the Plan. We are satisfied that the Proposed Submission Plan reflects and addresses the key matters previously raised by the Council in relation to digital connectivity and telecommunications infrastructure.

• The Council supports the new settlement allocation at Cambourne North and Cambourne, noting that the transport evidence produced to date suggests that development here can be mitigated, subject to the delivery of East-West Rail and both the proposed Cambourne to Cambridge scheme, and a future segregated extension into the site at Cambourne North, along with other site specific highway, public transport and active travel improvements. In addition, the Council supports the development of a stringent trip budget for the new settlement, which will need to be kept under review as evidence develops.
• The Council has and is continuing to work, in its role as LHA, with GCSP and other local authority partners on a comprehensive transport mitigation strategy for Cambourne and welcomes the opportunity for this. This work adds detail to the agreed evidence on the deliverability of Cambourne North which is set out in the TER.
• The Council notes the importance of ensuring, in terms of transport and movement, that the new settlement north of Cambourne has strong connectivity with the existing Cambourne villages. The Council supports the emphasis on active travel for this.
• Cambourne North requires the delivery of East West Rail, the Cambourne to Cambridge busway, and an extension of the Cambourne to Cambridge busway across the A428 to Cambourne North and onto Papworth, as well as public transport and active travel links between North Cambourne and the existing Cambourne villages. This mitigation package is not inconsiderable. The Council welcomes work on the detailed transport strategy for Cambourne and continues to work with GCSP and partners on the development of this evidence.

• The Council supports the allocation of Cambridge East, with evidence in the TER suggesting it is able to be mitigated subject to infrastructure requirements being delivered. This has been demonstrated to an appropriate level of detail for plan making.
• The Council would like to continue to be actively involved in the development and agreement of transport evidence and strategy for Cambridge East, and would like to reinforce the close relationship between the strategic public transport proposals for this area and the level of development coming forwards. These will need to be closely aligned.

• The Council acknowledges and agrees that the site at Grange Farm is deliverable in transport terms if a sufficient mitigation package is delivered alongside the development. Transport modelling undertaken demonstrates this point, with the delivery of the GCP’s CSETS Phase 2 scheme required, and a further extension to CSETS across the A11 to deliver grade separated, high quality public transport and active travel access to the site from Cambridge along the A1307 corridor. This grade separated crossing of the A11 along with a new junction with bus priority to cross the A1307 into the site would, it is agreed, provide sufficient public transport access to aid mitigation of the site. In addition, the Council supports the development of a stringent trip budget for the new settlement.
• It is important to note that in terms of the GCP CSETS phase 2 scheme, an extension to this across the A11 is currently untested and is not funded.
• As such, the Council believe that this site would benefit from a detailed transport strategy to refine the trip budget for the site which is currently set out in the Draft Plan, as well as setting out the full mitigation package required. The Council welcomes the continued opportunity to work with GCSP (and other Local Authority partners) on this transport strategy.
• The Council notes and agrees with the policy wording in Policy S/GF regarding an alternative to CSETS Phase 2 extension being acceptable in the early phase of the development if this can be evidenced and agreed with the Council as LHA that transport impact can be mitigated. It should be noted that at this stage this has not been evidenced or agreed.