Greater Cambridge Local Plan: Proposed Submission

Establish an Overarching Headline Commitment on Physical Capacity & Cumulative Impact:
Insert a prominent headline statement into the core Vision text explicitly committing the Plan to:
"Recognise, address, and reconcile the cumulative impacts of the proposed quantum of growth, ensuring that development is accommodated strictly within the finite physical capacity limits of Cambridge’s historic environment, its skyline, its streets and public spaces, and its landscape setting, without causing irreparable harm."

Elevate Heritage and Landscape to Equal Status
Amend the introductory paragraphs of the Vision text to explicitly recognise the area's "internationally valued heritage, historic built environment, and landscape setting" alongside its internationally significant economy.

Embed Capacity Limits and Environmental Safeguards
Insert explicit wording into the core Vision statement committing the Councils to "manage economic and housing growth strictly within the physical, social, and environmental capacity limits of Greater Cambridge."

Add Infrastructure Forward-Funding and Delivery Prerequisites
Add a binding Vision Principle stating that "economic growth and development allocations will be phased and managed to ensure critical strategic infrastructure—specifically water supply, healthcare facilities, and strategic green infrastructure—is fully committed and delivered ahead of or alongside development."

Explicit Commitment to Balancing Growth with Nature Recovery
Amend the strategic spatial vision to mandate that "where economic growth conflicts with climate mitigation, net-zero targets, historic setting, or biodiversity recovery goals, priority will be given to staying within environmental limits and protecting natural and heritage assets."

While Cambridge Past, Present & Future (CPPF) commends the inclusion of a climate-led vision for the Greater Cambridge Local Plan, we consider the current Vision unsound. The Plan fails to demonstrate how it will resolve the fundamental, inherent conflict between ambitious economic growth targets and the mandatory objectives of transitioning to net-zero carbon, protecting historic character, and achieving nature recovery. Most critically, the Vision fails as an overarching headline statement because it ignores the central challenge facing Greater Cambridge: how (or if) the massive quantum of proposed growth can be accommodated without causing irreparable harm to the physical capacity limits of Cambridge’s historic environment, its skyline, its streets and public spaces, and its landscape setting.
The policy fails the statutory tests of soundness, specifically, the Vision is not justified, not effective, and inconsistent with national policy.
Summary of Soundness Failures
1. Failure to Address Overarching Cumulative Impacts: The Vision operates under an unproven assumption that unlimited economic and spatial expansion can be absorbed without exceeding the finite physical capacity of Cambridge. It omits an overarching statement acknowledging that the cumulative scale of proposed growth directly threatens the historic townscape, fragile skyline, narrow street network, and green setting.
2. Unequal Status for Heritage and Landscape Assets: While the Vision explicitly highlights the region's "internationally significant economy," it omits equal strategic recognition of Greater Cambridge's internationally valued historic, cultural, architectural, and landscape assets.
3. Omission of Environmental and Infrastructure Capacity Limits: The Vision fails to acknowledge acute physical and environmental constraints—including severe water scarcity, overstretched healthcare systems, and deficiencies in strategic green infrastructure—making no provision for managing the trade-offs of growth.
4. Risk of Unsustainable Development: Promoting rapid employment and housing expansion without reconciling growth with physical and environmental capacity limits risks delivering economic growth at the direct expense of natural capital, heritage, and social wellbeing, violating the core NPPF definition of sustainable development.

1. Failure to Recognise Internationally Valued Heritage and Landscape Assets
While the current Vision explicitly highlights the region's "internationally significant economy," it omits equal recognition of Greater Cambridge's internationally valued historic, cultural, and landscape assets. A sound spatial vision must place equal weight on preserving the unique character, setting, and historic integrity of Cambridge and its surrounding rural hinterland.
The Plan assumes the historic city of Cambridge, its public realm, streets, sky spaces, and surrounding countryside can absorb unprecedented growth volumes. Without an explicit commitment in the Vision to test and reconcile cumulative growth against physical tipping points—such as street congestion, height inflation, loss of landscape views, and urban overcrowding—the Plan risks triggering irreversible harm.
2. Omission of Environmental and Infrastructure Capacity Constraints
The Vision operates under an unproven assumption that unlimited economic expansion can be accommodated without exceeding environmental limits. It fails to acknowledge the severe physical, environmental, and social capacity limits of the area—including critical water scarcity, overstretched healthcare systems, and deficiencies in strategic green infrastructure.
3. Lack of an Explicit Policy Mechanism to Manage Trade-Offs
Rather than ignoring conflicts between growth and capacity, the Vision must explicitly commit to managing and mitigating growth trade-offs. Major strategic infrastructure required to absorb growth cannot be delivered solely through private developer contributions (S106/CIL); it depends on significant, uncertain external investment from national government and utility providers.
4. Risk of Unsustainable Development
Delivering rapid employment and population expansion without securing prerequisite utility, water, healthcare, and green infrastructure risks delivering economic growth at the direct expense of social wellbeing and natural capital. This fails the core NPPF definition of sustainable development.

The Plan must explicitly track housing completions and employment build-outs against the physical construction milestones of essential water supply measures (including the Fens Reservoir and bulk transfer pipelines) and wastewater network upgrades.

Stipulate that if annual monitoring demonstrates that strategic water supply infrastructure is lagging behind the build-out rate, subsequent phases of strategic allocations must be paused until adequate, environmentally sustainable water supply capacity is formally secured and operational.

Insert explicit policy text stipulating that site allocations dependent on major strategic transport schemes cannot be released or approved for delivery until the associated strategic transport infrastructure (and the CPCA LTP) is formally adopted, fully funded, and committed.

Amend Policy S/DS and the spatial strategy trajectory to re-phase and reduce early plan-period delivery targets at Cambourne North, reallocating that quantum to sustainable, station-led growth along established railway corridors with existing public transport capacity (e.g., Foxton, Shepreth, Meldreth, Ashwell & Morden), in accordance with national objectives to maximise growth along sustainable transport corridors.

Amend the Policy S/DS justification text to mandate a comprehensive Environmental and Spatial Capacity Assessment for the historic city and its immediate hinterland to establish clear tipping points for traffic density, tall building impacts, and landscape protection before future allocation phases are triggered.

Add a binding commitment that the spatial strategy will undergo an immediate formal review if the finalised Transport Strategy identifies infrastructure funding deficits or transport capacity constraints that contradict the Local Plan's spatial assumptions.

Amend Policy S/DS and its supporting delivery text to explicitly identify the completion of a functional, all-ways orbital route around Cambridge as a key infrastructure prerequisite. Specifically, require local planning authorities and strategic transport partners to secure all-ways junction capacity at the Girton Interchange (Junction 31/14), A14/A11 Interchange, and M11 Junction 9 ahead of or alongside major strategic housing and employment allocations.

Minor Modifications
It would be useful to have a graphic of the spatial distribution of proposed employment development.
Figure 9 needs to explain what the percentages refer to – Is it number of dwellings or hectarage?

While Cambridge Past, Present & Future (CPPF) supports directing major growth to a limited number of larger settlements beyond the Green Belt to foster self-sufficiency, we consider Policy S/DS unsound as drafted. The proposed spatial strategy presents significant strategic risks regarding deliverability, infrastructure timing, and environmental limits.

1. Physical and Environmental Capacity Limits
The Plan assumes the historic city of Cambridge, its public realm, streets, and rural hinterland can absorb these proposed growth volumes without severe degradation. There is a lack of rigorous, evidence-based capacity testing to prove that the historic townscape, landscape corridors, and urban framework can sustain this scale of development without irreversible harm.

2. Unmitigated Water Supply Vulnerabilities
The Policy is unsound regarding water security, environmental protection, and infrastructure delivery timing.

The Plan’s ambitious spatial strategy and accelerated housing trajectory rely completely on the timely delivery of medium- and long-term bulk water transfer infrastructure—specifically the proposed Fens Reservoir and Grafham to Cambridge pipeline.

So much growth across Greater Cambridge is predicated on these major water supply projects that if unexpected technical, legal, or planning delays occur, the Plan will reach a threshold of being "too big to fail." Once strategic sites are allocated and outline planning permissions are granted, there is immense structural and commercial pressure to keep delivering housing regardless of infrastructure delays. In practice, local planning authorities will find it politically and legally impossible to pause development mid-construction. Proceeding with growth ahead of water infrastructure delivery presents a catastrophic risk of severe, irreversible environmental degradation—exacerbating chalk stream abstractions, damaging rare groundwater ecosystems, and worsening regional water stress.

Plan currently lacks a binding, annual monitoring framework that dynamically pairs housing completions with verified water supply and wastewater treatment capacity. Pushing ahead with spatial allocation targets without a formal "stop/go" tracking mechanism violates national planning directives that require growth to be kept strictly within environmental capacity limits.

3. Failure to Align with National Policy on Station-Led Development
The strategy fails to properly align with national planning principles established in the December 2024 NPPF, which emphasise directing growth to sustainable locations with existing public transport capacity and making effective use of well-connected land. Growth will inevitably gravitate toward existing travel hubs; the Local Plan must proactively shape this spatial pattern rather than reacting to ad-hoc development pressures later.

Allocating appropriately scaled, station-proximate growth at existing rural rail hubs (e.g., Foxton, Shepreth, Meldreth, and Ashwell & Morden) would de-risk the Local Plan against major project delays, such as East-West Rail (EWR). Reallocating a portion of housing capacity to these existing transport corridors during the current plan period would allow for a safer, phased reduction of early delivery targets at Cambourne North.

Station-led sites utilise established rail assets and existing capacity, eliminating reliance on uncommitted or delayed public transport schemes. Furthermore, because developers on these sites are not required to forward-fund major new transit corridors, developer contributions can be redirected to deliver higher levels of affordable housing and vital community facilities in rural settlements.

4. Test of Soundness: Absence of an Adopted Transport Strategy
Site allocations in Policy S/DS rely completely on sustainable transport delivery to avoid network gridlock. Submitting the Local Plan without an adopted, fully costed Cambridgeshire & Peterborough Combined Authority (CPCA) Transport Strategy breaks national soundness tests: the spatial strategy relies on unverified delivery assumptions. Without an adopted Transport Strategy, major allocations risk defaulting to private car reliance, directly undermining the Plan's zero-carbon objectives.

5. Over-Reliance on Strategic Interventions
The growth model assumes major projects—such as East-West Rail and Greater Cambridge Partnership (GCP) rapid transit corridors—will be delivered on schedule. Planning around unfinalised schemes exposes critical site allocations to severe delay and unsustainable outcomes if transport infrastructure lags behind housing delivery.

Without an enforceable Transport Strategy, peripheral site growth threatens green corridors and surrounding countryside. Firming up transport commitments first helps enforce the physical and environmental limits of the historic city.

6. Strategic Infrastructure Deficits and the Need for an Orbital Road Network
A coherent spatial strategy proposing growth at this scale must directly address the long-term capacity, resilience, and functionality of the strategic road network surrounding Cambridge. Policy S/DS is unsound as drafted because it fails to mandate the necessary junction upgrades required to form a fully functional, all-ways orbital routing network around the city.

To prevent systemic gridlock, reduce severe divertive traffic, and protect rural communities, Policy S/DS must explicitly require the creation of all-ways movements at three critical strategic interchanges:

• Girton Interchange (Junction 31/14, A14/A428): Completing missing movements to allow seamless traffic movement between key strategic corridors without forcing vehicles onto local urban roads.
• A14 / A11 Interchange: Upgrading connections to enable smooth orbital flow between the east and south-east strategic corridors.
• Junction 9, M11: Delivering full directional access to complete the southern and western strategic loop.
Collectively, these junction improvements would create a continuous outer orbital network, enabling cross-county and peripheral traffic to circulate around Cambridge rather than cutting through urban streets and rural village centres. This would significantly enhance road safety, air quality, and local residential amenity.

A fully connected orbital route provides vital diversionary capacity during incidents or road closures on the strategic road network, minimising severe regional gridlock, reducing transport delays, and supporting economic productivity.

CPPF supports this policy as establishing a clear, evidence-based settlement hierarchy is an essential spatial planning mechanism for managing growth sustainably, preventing urban sprawl, and ensuring development remains within physical, environmental, and infrastructure limits.
A structured settlement hierarchy establishes a clear framework that directs the vast majority of growth toward established urban areas and major transport nodes. This spatial discipline is critical to preventing unplanned urban sprawl, preserving the distinct setting and scale of Cambridge, and safeguarding the surrounding rural hinterlands and Green Belt.
Defining clear tiers across the settlement hierarchy—from Strategic Urban Extensions down to Infill Villages—provides vital protection for rural communities. It prevents ad-hoc, speculative expansion in smaller settlements that lack appropriate service capacity, thereby protecting local village character and preventing the physical coalescence of settlements.
Aligning development scale directly with service availability and existing or committed public transport capacity is essential for climate mitigation. Restricting high-density development in isolated or poorly served locations minimises forced car dependence and supports wider net-zero objectives.
Focusing strategic growth on higher-tier settlements enables development to achieve higher levels of self-sufficiency. This ensures that new housing and employment are matched with prerequisite civic, commercial, and green infrastructure rather than over-burdening smaller rural communities.

1. Re-evaluate the Green Belt Evidence Base: Commission an updated, comprehensive addendum to the Green Belt Assessment 2026 that fully models the cumulative impact of all proposed releases/potential development in the Grey Belt and explicitly evaluates the exceptional circumstances for Green Belt extensions.
2. Incorporate Policy Mechanisms for Green Belt Extensions (NPPF Para 144): Amend Policy S/GB to include explicit policy text and mapping that extends the Green Belt boundary around designated new settlements and critical strategic gap locations to prevent long-term coalescence and sprawl.
3. Commit to Early Review Safeguards: Insert a policy mechanism requiring an immediate formal review of Policy S/GB if monitoring demonstrates that Grey Belt releases or site allocations are eroding the setting and special character of the historic city or nearby rural settlements.

While Cambridge Past, Present & Future (CPPF) strongly supports the statutory principle of protecting the Cambridge Green Belt and its historic purposes, Policy S/GB is unsound as drafted. Specifically, Policy S/GB is not justified, not effective, and inconsistent with national policy (December 2024 NPPF, Paragraphs 142, 143, and 144). It lacks a robust evidence base, fails to account for the cumulative loss of Green Belt land, and omits the strategic policy mechanisms required to address long-term growth pressures up to and beyond 2045, leaving the historic city’s unique setting and satellite villages vulnerable to piecemeal erosion.
Key Grounds of Objection
1. Inadequate Evidence Base & Flawed Technical Assessment
Green Belt Assessment 2026 supporting this part of the policy work is incomplete and unsound. It fails to comprehensively assess the cumulative spatial, visual, and environmental impacts of the total quantum of proposed Green Belt boundary amendments, new site allocations, and potential released "Grey Belt" land across Greater Cambridge.

The 2026 technical evidence base fails to evaluate whether exceptional circumstances exist to extend the Green Belt boundary. By considering Green Belt land solely through the lens of release rather than strategic designation, the evidence base is unbalanced and fundamentally flawed.

2. Absence of Policy Provision for New Green Belt Designations
Paragraph 144 of the December 2024 NPPF explicitly sets out the national criteria allowing local planning authorities to establish or extend Green Belt boundaries in exceptional circumstances. The unprecedented long-term growth trajectory envisaged for Greater Cambridge to 2045 and beyond constitutes these exceptional circumstances.

It is a major strategic failure that the Plan does not utilise NPPF Paragraph 144 to extend Green Belt protections around major new allocations and new settlements. Establishing statutory Green Belt buffers around new settlement boundaries is essential to maintaining the character of the historic university city within its physical and cultural historic landscape setting by prevent future unmanaged urban sprawl, prevent coalescence with neighbouring historic villages, and provide permanent spatial certainty.

3. Lack of a Strategic Long-Term Vision & Incremental Erosion
Over the last 20 years, successive local plans have incrementally eroded the Cambridge Green Belt without establishing compensatory strategic land protections or permanent green buffers.

Policy S/GB fails to establish a proactive spatial vision to manage regional land sustainably. It fails to integrate strategic green infrastructure outside the existing boundary or safeguard permanent green wedges between Cambridge, its satellite villages, and new growth hubs.

Soundness Summary
Policy S/GB is unsound because omitting a mechanism for Green Belt extension—and relying on a non-comprehensive technical assessment—means the Plan cannot be considered justified or effective. Without extending Green Belt protections to new settlements and strategic corridors, the policy will trigger an early, forced review of Green Belt boundaries as speculative growth pressures mount.

Either reinstate the 30% requirement in Policy BG/TC or:
To mitigate the removal of the 30% requirement in Policy BG/TC and ensure the Local Plan remains sound and aligned with wider council strategies, Policy S/MO must be amended to include a specific Monitoring Indicator for Policy BG/TC:
Indicator descriptor: Net change and percentage increase in overall tree canopy cover across major development sites, measured against the 20% canopy target set in the Cambridge Urban Forest Strategy.
Metric: percentage tree cover
Target: increasing the canopy cover by 2.4% by 2050 (98 hectares in total, 4 hectares per year).
Trigger: Inability to meet additional 4ha per year tree cover
Action: review of Policy BG/TC and the application of mandatory minimum tree canopy standards.

Cambridge Past Present & Future (CPPF) object to the monitoring framework regarding Policy BG/TC (Tree Cover).
Following the removal of the specific, measurable 30% tree canopy cover target previously contained in Regulation 18, the policy relies on the Urban Greening Factor and general non-net-loss ambitions to manage tree provision. However, replacing a quantitative, binding target with general aims creates a significant policy gap that threatens to undermine the delivery of the council's own Cambridge Urban Forest Strategy target of 20% tree canopy cover by 2050.
As currently drafted, Policy S/MO lacks a dedicated, robust monitoring mechanism to evaluate whether Policy GB/TC and GB/UGF and associated development policies are actually delivering the required canopy cover in practice. Without explicit monitoring, there is no mechanism to guarantee outcomes or hold delivery to account, rendering the approach unsound.

Cambridge Past, Present & Future (CPPF) strongly supports the explicit requirements for resource efficiency, building retention, and whole-lifecycle carbon reduction, vital to reconciling the region's development with its commitment to Net Zero carbon by 2050.
CPPF strongly supports the prioritising of retrofit and reuse, whole life cycle carbon reduction, and waste minimisation and local supply chains.
The policy is informed by the urgent need to meet local and national Net Zero commitments while accommodating development. By requiring major proposals to embed circular economy principles from the design stage, it ensures that growth is planned sustainably without compromising future resource capacity or social wellbeing.
Policy CC/CE represents an appropriate, evidence-based strategy for managing resource consumption and embodied carbon across Greater Cambridge. The requirement to prioritise the retention, retrofit, and adaptive reuse of existing buildings before considering demolition is directly justified by local environmental constraints and the imperative to minimise upfront carbon expenditure.
The policy sets clear, actionable requirements—such as mandatory Circular Economy Statements for major developments—making it practical and deliverable.
Policy CC/CE directly aligns with national policy objectives to transition to a low-carbon economy, encourage the prudent use of natural resources, and minimise waste.

Cambridge Past, Present & Future (CPPF) supports the policy because retrofitting existing building stock is one of the most vital strategies for reducing operational carbon, preventing unnecessary demolition, and protecting embedded carbon across Greater Cambridge.
The policy will safeguard heritage and local character.
Facilitating householder retrofits improves thermal efficiency, decreases local energy demand, and protects residents from rising energy costs.
By encouraging long-term adaptation, Policy CC/SR complements circular economy principles by extending the functional lifespan of existing buildings and preserving their embodied carbon.
The policy proactively supports retrofitting existing residential and commercial properties to improve energy efficiency, lower carbon emissions, and reduce energy bills. Given the amount of existing building stock compared to new build, a dedicated policy offering a supportive planning framework for sensitive adaptation is fully justified. The policy directly aligns with the NPPF’s requirement to support climate change mitigation, transition to a low-carbon economy, and reuse existing resources sustainably.

1. Clarify Primacy Over Legacy Masterplans: Insert an explicit policy requirement stating that Policy GP/ST and Appendix H apply to all new, revised, or detailed planning applications, and that non-statutory or legacy masterplan parameters do not set a binding baseline or precedent.
2. Mandate Updated Masterplans for Strategic Allocations: Add a policy requirement ensuring that strategic allocations must produce updated masterplans fully aligned with the June 2026 Skyline and Tall Buildings Strategy.
3. Strengthen Architectural Guidance in Appendix H (Criterion 4): Add explicit design requirements covering massing limits, slender proportions, and detailed roofscape articulation for all proposed tall and landmark buildings.
4. Insert Mandatory Refusal Clause: Add a clear enforcement clause to Policy GP/ST stating:
"Proposals for tall buildings that fail to demonstrate exceptional architectural quality, elegance of proportion, or a positive contribution to the skyline will be refused in accordance with national policy."
5. Factual Typographical Correction: Correct the spelling of "Redmeadow Hill" to "Red Meadow Hill" in Appendix H and throughout the Plan.

Cambridge Past, Present & Future (CPPF) welcomes the publication of the Skyline and Tall Buildings Baseline, Strategy and Guidance Study (June 2026) as a useful baseline context. However, CPPF objects to Policy GP/ST as currently drafted.
The policy fails the statutory tests of soundness, specifically, Policy GP/ST is not justified, not effective, and inconsistent with national policy.
Summary of Soundness Failures
1. Not Effective: Policy GP/ST fails to provide a legal or procedural mechanism to enforce the findings of the June 2026 Study against established, emerging, or legacy masterplans. This creates policy ambiguity and risks establishing height precedents that bypass the strategy entirely.
2. Not Justified: Carrying forward legacy height ceilings into Policy GP/ST lacks a sound evidential basis. The evidence base fails to evaluate whether legacy maximums were set to meet specific functional needs or were driven strictly by density optimization.
3. Inconsistent with National Policy: The policy relies on descriptive, aspirational phrasing rather than binding, enforceable design criteria. It lacks explicit wording requiring the refusal of mediocre or poorly designed tall buildings, contrary to Paragraph 139 of the December 2024 NPPF.
Detailed Analysis Against Tests of Soundness
1. Not Effective: Unenforceable Against Legacy Masterplans & Precedent Inflation
Near-complete developments (e.g., Vitrium at ~36.3m AOD) and emerging proposals in North East Cambridge reaching up to 45m threaten to establish baseline expectations that completely bypass the updated 2026 Study.

The West Cambridge outline masterplan permits maximum heights up to 41m, and up to 45m for landmark buildings. Allowing legacy parameters to take precedence automatically creates an expectation of acceptability, directly undermining the 2026 Study's baseline and encouraging city-wide height inflation through "permission by precedent".

Major strategic allocations—including Clifton Road Industrial Estate and Leisure Park, Newmarket Road Retail Park, East Cambridge/Cambridge Airport, Marleigh, and the Cambridge Biomedical Campus—face this exact ambiguity. The Plan fails to clarify whether these sites require updated masterplans strictly aligned with the June 2026 Study or if legacy parameters will override new policy.

2. Not Justified: Unevidenced Carry-Forward of Legacy Height Ceilings
The presence of the June 2026 Study in the evidence base does not automatically justify carrying legacy height parameters forward.

The evidence base fails to evaluate whether established maximums (such as the 41m and 45m limits at West Cambridge) were set to meet specific functional, technical, or operational needs, or were driven strictly by density optimisation. Without explicit justification distinguishing functional necessity from arbitrary density targets, carrying these figures forward lacks an evidential basis.

3. Inconsistent with National Policy: Inadequate Design Controls & Vague Criteria
While Appendix H identifies existing landmark structures, it offers insufficient policy controls for evaluating new tall buildings or enforcing design quality.

Policy GP/ST (1d) references a "well-articulated skyline" and Criterion 3 of Appendix H refers to "slender incidents punctuating the skyline". These rely on descriptive, subjective language rather than binding, actionable design criteria.

Paragraph 139 of the NPPF mandates that development that is not well designed should be refused. Relying on aspirational terms like "high quality" is insufficient. Policy GP/ST lacks explicit wording committing the Councils to refuse proposals of poor or mediocre architectural design.

Water features – there are several references to interactive water features such as splashpads. In a drought prone area and with a lack of funding for maintenance, is it wise to include a specific idea for water features/splash pads?

Remove Para 1.a.v. on lighting as already covered more appropriately in 1.e.iv.

Para 1.b v. drafting error leading to ambiguity - suggest – “Integrate car parking into the existing landscape setting, retaining existing trees, hedges and other landscape features, incorporating parking into the site design, and using low, soft landscaping to subdivide and screen car parking whilst ensuring sight lines and safety.”

Para 1.b.vi drafting error leading to ambiguity - suggest – “Parking should not reduce the functionality of open spaces. Where on-street parking is provided, parking bays should be inset and adjacent footways widened to ensure that pedestrian movement is not obstructed.”

Para 1.b.vii drafting error leading to ambiguity - suggest – “Create streets that respond to their anticipated levels of use while prioritising pedestrians and cyclists over vehicular traffic.”

Para 1.c.ii Suggest clearer more concise wording – “Use permeable materials for front gardens and demonstrate that paving will not adversely affect surface water run-off, particularly in flood-prone areas, or result in a net loss of biodiversity.”

Para 1.c.iv Following the recent heat waves it is obvious that the benefits of larger street trees than usually found in new development must take priority to create shade and flash flood uptake - suggest clearer, stronger wording – “Every opportunity should be taken to plant street trees of sufficient stature to provide shade, shelter and biodiversity, including large-scale trees at street corners to provide additional shade and help soften the urban environment.”

Para 1.e.iv Lighting – suggest adding safety factor – “Provide adequate lighting to ensure safety during hours of darkness, with lamp columns and lanterns carefully designed and appropriately located. Lighting should be directional to minimise intrusion, reduce light pollution and avoid harm to the natural environment.”

Para 1.f.i drafting error leading to ambiguity - suggest – “Design open spaces to be adaptable for activities such as allotments, concerts, performances, exercise classes, events and fetes that provide physical and mental health benefits. Flexible open spaces, or meanwhile uses, should provide appropriate access to power and water. Open space design should incorporate appropriate counter-terrorism protective security measures.”

Introduces a specific financial mechanism to address the resource gap for monitoring and enforcing landscape conditions relating to the delivery and management of new landscape and public realm areas.

While we welcome the evolution of this policy and its supporting information—particularly the expansion of guidance on the public realm—the draft policy as currently presented is unsound. It suffers from drafting ambiguities, unnecessary repetition, and a critical failure to establish a financial mechanism to resource long-term monitoring and enforcement. As a result, the policy is neither effective nor positively prepared

Given that the successful design, delivery, and ongoing management of new landscapes and public realm spaces will become increasingly essential in tackling climate change and delivering nature recovery across Greater Cambridge, the policy must be made as clear, focused, and robust as possible.

Several paragraphs within Policy GP/QP and its supporting text remain poorly drafted, repetitive, and ambiguous.

This lack of clarity introduces uncertainty into the decision-making process, making the policy difficult to apply consistently and ultimately undermining its credibility and practical effectiveness.

CPPF is extremely disappointed that the recommendation for the Local Plan to introduce a specific financial mechanism to address the resource gap for monitoring and enforcing landscape conditions has not been adopted.

There has long been a systemic problem with the lack of resources dedicated to monitoring whether approved landscape schemes, public realm areas, and tree planting are actually delivered and maintained as conditioned.

Failing to address this resource gap is a significant shortcoming. Without secured resources for monitoring and enforcement, there is a severe risk that newly planted trees and landscape areas will fail to establish or be properly managed, directly undermining the policy’s core objectives regarding climate change mitigation and biodiversity recovery.

Suggested amendments to text shown in capitals
1.a. protect, conserve and enhance the local landscape character, DIVERSITY AND NATURAL BEAUTY as set out….

Insert new 1b SEEK TO ENSURE THAT CHANGE IS APPROPRIATE TO THE RELEVANT LANDSCAPE CHARACTER TYPE AND AREA, AND THE FEATURES AND CHARACTERISTICS THAT DEFINE THEIR LOCAL DISTINCTIVENESS.

Insert new subsection to part 1 IDENTIFY OPPORTUNITIES TO INTRODUCE NEW AND APPROPRIATE LANDSCAPE FEATURES TO COMPENSATE FOR NEARBY LOSS OR DEGRADATION;

Explicitly reference key baseline evidence documents within the policy or supporting information, including the ‘Greater Cambridge Landscape Character Assessment’, the ‘Skyline and Tall Buildings Baseline, Strategy and Guidance’, and relevant townscape studies.

Strengthen the policy and supporting text to require applicants to submit clear evidence showing how the ‘Greater Cambridge Landscape Character Assessment’ and related studies have directly informed scheme design at the pre-application and feasibility stage, rather than as late-stage documentation.

Policy GP/LC is unsound because it is neither effective nor consistent with national policy. It fails to provide robust safeguards for Cambridgeshire’s non-designated working countryside or ensure that landscape character is adequately captured or informs development at the earliest design stage.

Developers frequently underestimate the value, complexity and subtle beauty of Cambridgeshire’s agricultural landscape and how it interacts with the historic built environment. Its intrinsic value must not be judged solely by formal designation. The policy should require development to respond specifically to the relevant Landscape Character Type and Area, preventing generic schemes that erode local distinctiveness.

While the Council’s supporting text refers to pre-application discussions for major developments, this is insufficient. Landscape assessments are often submitted retrospectively to justify largely finalised proposals, when meaningful changes to layout, scale and massing are difficult. The policy must require landscape character evidence at the pre-application and feasibility stages.

It should also require developers to identify opportunities for introducing contextually appropriate landscape features that compensate for nearby landscape loss or degradation.