Greater Cambridge Local Plan: Proposed Submission

1. Insert an explicit policy clause and supporting text recognising the global heritage value of Greater Cambridge as a cohesive whole.
2. Shift the policy requirement from purely site-specific HIAs to requiring Cumulative Heritage Impact Assessments for major developments and strategic allocations, using Conservation Area Appraisals as a mandatory baseline.
3. Amend Policy GP/HE and cross-reference Green Infrastructure policies to explicitly recognise visitor pressure as a threat to heritage assets (e.g., Wimpole, Wandlebury) and mandate the delivery of expanded/new strategic parklands to absorb recreational demand.
4. Transform Figure 112 into a dynamic, proactive strategy, which start with a baseline assessment, which should highlight the heritage importance of the City as whole and its hinterland with reference to Outstanding Universal Value criteria, as well as designated assets within it, its skyline character, and impacts of recent development .Then look at pressures for change, and capacity for change, identifying key challenges and choices, and developing policies to manage these as positively as possible. Ongoing monitoring should be through regular Conservation Area Appraisals. The strategy must evaluate the city’s historic culture holistically rather than just listing existing planning tools.
5. Add explicit policy commitments to complete and adopt the ‘Making Space for People’ SPD and the ’Historic Core Conservation Area Management Strategy’ to guide development and public realm interventions within the historic core.

While CPPF acknowledges the minor drafting revisions made following the Regulation 18 consultation—specifically the inclusion of general references to cultural identity, placemaking, and a single bullet point in the Strategy diagram acknowledging Cambridge's global significance—these changes remain superficial.

The Plan fundamentally fails to address our primary structural concerns. The policy remains a reactive, building-by-building control mechanism rather than a proactive, landscape-scale framework. Most critically, the plan fails to recognise the overarching international significance of Cambridge’s heritage as a cohesive whole and completely ignores the cumulative and indirect impacts that an added population of 100,000+ will exert on the historic environment, the historic core, and sensitive rural heritage landscapes. Consequently, Policy GP/HE is unsound as it is neither effective, justified, nor consistent with national policy.

1. Failure to Recognise Overarching, Landscape-Scale Significance
Cambridge possesses a world-class built environment and historic landscape attracting over 8 million annual visitors and driving global investment. Despite its Outstanding Universal Value being recognised since its 1980s World Heritage Site nomination, the plan lacks an overarching Statement of Significance.

The plan continues to treat heritage as isolated assets rather than recognising the world-heritage significance of the city and its setting as an interconnected whole—particularly along the vital river corridor extending from Byron’s Pool through Grantchester Meadows to Baitsbite Lock.

Simply inserting a bullet point referencing "global significance" into Figure 112 (Historic Environment Strategy Diagram) does not constitute a meaningful strategic framework. Figure 112 remains overly static, listing existing administrative tools rather than providing a dynamic strategy.

A dynamic Strategy should start with a baseline assessment, which should highlight the heritage importance of the City as whole and its hinterland with reference to Outstanding Universal Value criteria, as well as designated assets within it, its skyline character, and impacts of recent development .Then look at pressures for change, and capacity for change, identifying key challenges and choices, and developing policies to manage these as positively as possible. Ongoing monitoring should be through regular Conservation Area Appraisals. The strategy must evaluate the city’s historic culture holistically rather than just listing existing planning tools.

2. Failure to Assess or Mitigate Cumulative and Indirect Growth Impacts
The policy relies almost exclusively on site-specific Heritage Impact Assessments (HIAs). Individual HIAs are inherently too narrow in scope to capture or mitigate the incremental, city-wide degradation caused by multiple development schemes over time.

Adding 100,000+ residents will inevitably force physical and operational changes to the layout, transport networks, public realm, and fabric of the historic city centre. The plan fails to recognise that this population growth drives these indirect spatial pressures, leaving the historic core highly vulnerable to piecemeal adaptation.

The 2021 Strategic Heritage Impact Assessment failed to provide a holistic baseline for growth, focusing narrowly on isolated site options while ignoring Conservation Area Appraisals as a core mechanism for assessing cumulative impact.

3. Unaddressed Visitor Pressures on Countryside Heritage
The plan fails to acknowledge that massive population growth will severely exacerbate visitor pressure on sensitive historic landscapes in the surrounding countryside, such as Wimpole and Wandlebury.

While visitor pressure is referenced in the plan regarding nature reserves, it is entirely omitted as a threat to heritage significance. The policy fails to mandate strategic Green Infrastructure solutions—such as the expansion of existing historic parks and the creation of large strategic green spaces—specifically designed to absorb recreational pressure and protect sensitive heritage assets.

4. Abandonment of Critical Planning Frameworks
The Councils’ refusal to commit to supplementary planning frameworks undermines the delivery of Policy GP/HE.

The failure to complete and commit to the Making Space for People SPD and the Historic Core Conservation Area Management Strategy leaves the Councils without an effective framework to reconcile competing spatial pressures in the historic core—pressures that are already acutely evident in schemes such as the Civic Quarter proposals.

1. Establish a Local Grade II Buildings at Risk Register: Amend Policy GP/HA to commit the Greater Cambridge Shared Planning Service to creating, maintaining, and regularly updating a local Greater Cambridge Grade II Buildings at Risk Register.
2. Formalise Early Intervention Measures: Expressly state in the policy text that the Councils will use statutory where Grade II buildings on the local register suffer from deliberate neglect or severe structural decay.
3. Embed Community & Local Survey Partnerships: Partner with local civic societies, parish councils, and heritage charities to monitor, survey, and report on the condition of Grade II assets across both urban and rural areas.
4. Tie At-Risk Status to Adaptive Reuse Support: Include supporting policy text confirming that proposals bringing assets on the local At-Risk register back into viable, sensitive use will be given positive weight in the planning balance.

Cambridge Past, Present & Future (CPPF) objects to Policy GP/HA regarding the conservation and enhancement of heritage assets.

While the policy rightly commits the Councils to taking a proactive approach towards heritage assets on the Heritage at Risk Register, the mechanism as currently structured is fundamentally flawed. Historic England’s national Heritage at Risk Register excludes Grade II listed buildings outside London. Because Grade II structures constitute approximately 90–92% of all listed buildings across Greater Cambridge, the current draft leaves the vast majority of designated heritage assets without a proactive baseline monitoring or intervention framework.

As drafted, Policy GP/HA fails the statutory tests of soundness. Specifically, the policy is not effective and inconsistent with national policy.

Summary of Soundness Failures
Not Effective: By relying exclusively on a register that omits Grade II structures outside London, the policy creates a critical monitoring blind spot. It fails to provide a workable strategy or legal/enforcement mechanism to prevent the incremental decay, neglect, or loss of over nine-tenths of Greater Cambridge's statutory heritage assets.

Inconsistent with National Policy: NPPF Paragraph 203 mandates that local planning authorities set out a positive strategy for the conservation and enjoyment of the historic environment, explicitly taking into account the desirability of sustaining and enhancing heritage assets. Paragraph 203 requires local authorities to assess the risk to heritage assets from neglect or decay. Excluding Grade II assets directly conflicts with these national policy directives.

Detailed Analysis against Tests of Soundness
Historic England only compiles Buildings at Risk data for Grade I and Grade II* listed buildings, Scheduled Monuments, and Conservation Areas outside London. It does not monitor Grade II listed buildings.

Grade II buildings form the vast backbone of Greater Cambridge’s historic environment—encompassing traditional rural farmsteads, timber-framed cottages, historic shopfronts, and civic structures. Because these buildings are often held by private owners, small businesses, or institutions without dedicated conservation budgets, they face equal or greater risks of physical decay, vacancy, and unpermitted alteration than Grade I or II* assets.

A local plan strategy cannot be considered "positive" if it systematically turns a blind eye to 90%+ of its statutory heritage stock. Proactive planning requires identifying vulnerable buildings before decay becomes irreversible or requires costly Urgent Works Notices.

The NPPF places clear responsibility on local authorities to monitor and mitigate risks to designated assets. Omitting Grade II structures prevents early intervention, leading to avoidable heritage loss or prolonged enforcement disputes.

Without a local Grade II At-Risk Register, the Councils are forced into a purely reactive enforcement posture—responding only after public complaints or severe structural failures occur.

Proactive identification allows the Councils to work alongside property owners, building preservation trusts, and local charities to find viable, sustainable new uses before severe timber rot, roof failure, or water ingress drastically inflates restoration costs.

Cambridge Past, Present & Future (CPPF) strongly supports Policy GP/ND (Non-Designated Heritage Assets) and its accompanying explanatory text at Paragraph 7.81.
We particularly welcome the Councils' commitment in Paragraph 7.81 to maintaining, updating, and expanding the Local List across Greater Cambridge. Non-designated heritage assets form a vital, character-defining layer of the area's rich built and natural landscape.
Policy GP/ND and Paragraph 7.81 are sound because they are positively prepared, justified, effective, and fully consistent with national planning policy

Key Grounds of Support
1. Consistency with National Policy (December 2024 NPPF Paragraphs 192, 203 & 209)
• Positive Heritage Strategy (NPPF Para 203): The NPPF mandates that local planning authorities set out a positive strategy for the conservation and enjoyment of the historic environment. Protecting non-designated assets through a clear local policy framework operationalises this directive at the community level.
• Balanced Decision-Making (NPPF Para 216): NPPF Paragraph 216 explicitly requires a balanced judgment when assessing applications affecting non-designated heritage assets, having regard to the scale of any harm or loss and the significance of the asset. Policy GP/ND provides a clear, structured mechanism to weigh significance against public benefits in development management decisions.
• Conserving Heritage Settings (NPPF Para 203): Local list assets often form the immediate context and setting for statutory designated assets (such as Grade I or II* listed buildings and Conservation Areas). Protecting Non Designated Heritage Assets helps maintain local distinctiveness and historic spatial cohesion.
Greater Cambridge contains hundreds of unlisted historic buildings, agricultural structures, 19th-century village schoolhouses, and distinctive boundary walls that do not meet national listing criteria but hold immense local historic, architectural, or social significance

We strongly support Paragraph 7.81 and the ongoing work to review and expand the Local List. Establishing clear selection criteria and maintaining an up-to-date register gives property owners, developers, and local communities early certainty regarding what features are valued and should be retained or sensitively converted.

Without a specific policy on NDHAs, locally valued buildings are highly vulnerable to unsympathetic alteration or total demolition prior to planning consideration. Policy GP/ND ensures that significance is identified early in the pre-application and design processes.

Encouraging the sensitive reuse, repair, and retrofitting of locally listed buildings preserves embodied carbon and supports sustainable development goals while retaining local historic identity.

Conclusion
Policy GP/ND and Paragraph 7.81 strike the correct balance between protecting locally valued historic character and enabling appropriate, high-quality development.

Cambridge Past, Present and Future support the policy, and specifically the reference to BS EN 16883, ensuring the policy is sound.
Standard modern retrofit techniques often fail when applied to historic and traditional buildings due to differences in moisture movement and material breathability. BS EN 16883 provides an internationally recognised, step-by-step risk assessment methodology that identifies tailored, building-specific energy efficiency measures.
Incorporating this standard into Policy GP/CC provides clear technical guidance for applicants and officers, facilitating the necessary retrofitting of heritage assets to combat climate change while preventing technical failure, material damage, or loss of historic significance."

Cambridge Past, Present & Future (CPPF) strongly supports Policy GP/SF (Shopfronts).

High-quality, historic, and well-designed shopfronts are vital components of the streetscape, character, and visual amenity of Greater Cambridge’s historic city centre, market towns, and village conservation areas. We particularly welcome the explicit safeguards established within Policy GP/SF for listed buildings and designated Conservation Areas.

Policy GP/SF is sound because it is positively prepared, justified, effective, and fully consistent with national planning policy

Key Grounds of Support
Traditional shopfronts on listed buildings—and those contributing positively to Conservation Areas—frequently incorporate rare historic features, timber joinery, pilasters, hand-painted fascia boards, and historic stallrisers. Policy GP/SF correctly establishes a firm presumption against the removal or unsympathetic alteration of these historic elements, aligning directly with NPPF Paragraph 203 (conserving heritage assets in a manner appropriate to their significance).

Unsympathetic, standardised corporate retail shopfronts, oversised fascia boxes, or inappropriate materials severely degrade the setting and significance of listed buildings and the special character of Conservation Areas. Policy GP/SF ensures that new shopfront proposals respect the scale, proportions, materials, and architectural integrity of the host building and surrounding streetscape, in line with NPPF Paragraph 135 (ensuring developments are sympathetic to local character and historic context).

The visual quality of shopfronts directly affects pedestrian experience, civic pride, and the economic vitality of town centres and village hubs. Protecting historic shopfronts while setting clear, high-quality design criteria for replacement or modern shopfronts ensures that high streets across Greater Cambridge remain attractive, distinctive, and vibrant destinations.

The policy provides clear control over intrusive modern additions preventing cumulative visual harm to historic streetscapes.

By setting out clear design parameters early, Policy GP/SF gives applicants and the community, certainty regarding design expectations for alterations or replacement shopfronts in sensitive historic locations.

The policy provides a workable mechanism that allows shopfronts to be updated for modern commercial accessibility, security, and energy efficiency without sacrificing historic significance or visual character.

Conclusion
Policy GP/SF provides an essential, well-balanced design and heritage control mechanism that safeguards the historic built environment while supporting commercial vitality.

Cambridge Past, Present & Future (CPPF) strongly supports Clause 8 of Policy J/NE (New Employment Proposals), which restricts large-scale strategic warehousing and logistics developments across Greater Cambridge.

Clause 8 is sound because it is justified, effective, and consistent with national policy (NPPF Paragraphs 85 and 86). Restricting large-scale distribution centres ensures that employment land is prioritised for high-value local employment, research, and manufacturing that directly serves the sub-regional economy, while protecting the sensitive landscape character, countryside setting, and historic village environments of Greater Cambridge from sprawling, visually intrusive built form.

Key Grounds of Support
1. Protection of Landscape Character and Rural Heritage
Large-scale strategic warehousing (big-box logistics) requires vast, tall, single-volume structures and extensive hardstanding for heavy goods vehicles. Across the rural and gently undulating countryside surrounding Cambridge, such developments exert a disproportionate and detrimental visual impact on the skyline, rural setting, and setting of historic villages.

Clause 8 aligns directly with national policy requirements to conserve and enhance the natural environment and local landscape character. Restricting inappropriate large-scale distribution units prevents the cumulative erosion of non-designated countryside and rural village settings.

2. Aligning Employment Land with Sub-Regional Needs
Greater Cambridge’s economic strength relies on innovation, research and development, high-tech manufacturing, and specialised local services. Restricting regional/national-scale logistics ensures that scarce employment land is preserved for uses that directly support Greater Cambridge's sub-regional economy and local job creation.

Warehousing provision should be strictly scaled to meet local operational demand—serving local business supply chains, manufacturing, and local doorstep delivery—rather than functioning as a strategic regional/national freight hub that draws heavy traffic through the local road network without providing proportionate local economic or employment benefits.

Conclusion
Clause 8 of Policy J/NE provides an essential and robust planning control that balances economic growth with environmental and landscape stewardship.

Policy J/AL is sound because it is positively prepared, justified, effective, and fully consistent with national policy.

Consistency with National Policy (December 2024 NPPF Paragraphs 180b & 181):
NPPF Paragraph 187(b) mandates that planning policies and decisions must contribute to and enhance the natural and local environment by recognising the wider benefits from natural capital and ecosystem services, including the economic and other benefits of the best and most versatile agricultural land.

NPPF Paragraph 188 footnote 65 explicitly directs that where significant development on agricultural land is demonstrated to be necessary, local planning authorities should seek to use areas of poorer quality land in preference to that of higher quality. Policy J/AL directly operationalises this requirement across Greater Cambridge.

Justified by Local Evidence & Natural Capital Value:
Greater Cambridge contains a finite, non-renewable resource of high-grade soils (with over 72,000 hectares of farmed land across the sub-region).

Protecting BMV land is critical not only for domestic food security and rural economic resilience, but also for soil health, carbon sequestration, and local biodiversity networks. Given the intense development pressures surrounding Cambridge and its satellite settlements, a firm policy framework is necessary to prevent incremental, irreversible loss of prime soil.

Balanced and Effective Framework:
Policy J/AL is not an absolute bar on development; rather, it establishes a clear, criteria-based mechanism. It allows strategic growth, where planned through Local or Neighbourhood Plan allocations, while preventing speculative, unsustainable development on high-grade farmland where alternative, lower-grade sites or brownfield options exist.

Policy J/PB is sound because it is positively prepared, justified, effective, and fully consistent with national policy

1. Consistency with National Policy (December 2024 NPPF Paragraphs 85 & 86):
The NPPF mandates that planning policies should help create conditions in which businesses can invest, expand, and adapt, while supporting a strong, sustainable, and inclusive economy.

Policy J/PB directly aligns with national guidance by ensuring a sufficient supply and diversity of employment locations. It guards against the premature or speculative conversion of viable business premises while maintaining clear criteria-based exceptions (including stringent marketing thresholds of 12 to 24 months) where land is genuinely redundant or unsuitable.

2. Justified by Local Economic Pressures & Inclusive Economy Goals:
High land values and demand for offices/life science labs in Greater Cambridge create extreme pressure on industrial and servicing premises. Policy J/PB explicitly protects Strategic Industrial Estates from being squeezed out, ensuring the city retains space for essential local trades, repair services, storage, and light manufacturing.

Protecting diverse, accessible industrial and local commercial premises supports low-to-mid-skilled jobs and vocational employment close to where people live, preventing displacement and supporting a well-rounded local economy.

Retaining employment spaces within villages and urban edge locations maintains local jobs, reducing the need for out-commuting and mitigating traffic congestion across Greater Cambridge.

3. Effective and Practical Implementation:
The policy avoids rigidity by establishing robust, evidence-based mechanisms (such as comprehensive viability testing, active marketing requirements, and community benefit assessments) before a site can transition to alternative uses.

Amend Clause 1(c) to allow the facilities to serve local communities where appropriate provided they do not attract significant levels of unmanaged external visitor traffic or unacceptably impact nearby centres.

The suggested wording retains strict protection for town and local centres by ensuring facilities must still be "scaled accordingly" and must not generate unmanaged traffic or undermine established high streets (supported by Clause 1b).

Whilst Cambridge Past, Present & Future (CPPF) supports the intent of Policy J/EP, we object to Clause 1(c) to ensure the policy is fully sound.

While preventing over-commercialisation or traffic congestion is a legitimate objective, this rigid restriction fails to account for spatial variations across Greater Cambridge. In certain locations—particularly edge-of-settlement employment hubs, rural science parks, or areas with nearby residential communities lacking local services—it is highly desirable for employment parks to provide facilities that can be shared with and scaled for local residents.

Many existing employment parks open their facilities to non-workers, and it is commonly promoted in planning applications. The Policy needs to reflect the current and emerging situation.

Allowing employment parks to open shared amenities—such as nurseries, sports/leisure facilities, cafes, co-working hubs, or green spaces—to local residents breaks down barriers between isolated commercial enclaves and surrounding neighbourhoods.

In rural or suburban locations where local community infrastructure may be constrained, scaled facilities within a business park can provide vital everyday services for nearby households without requiring standalone public expenditure.

Shared local facilities enable nearby residents to walk or cycle to employment hubs for leisure, childcare, or daily services rather than driving further afield to larger urban centres.

Combining worker and resident journeys optimises multi-modal trip patterns and maximises the viability of public transport routes serving the employment park.

Restricting facilities strictly to workers often leads to underutilisation during evenings, weekends, or off-peak hours. Allowing appropriately scaled access for local residents improves the financial viability of on-site amenities (such as cafes or nurseries), ensuring they remain sustainable in the long term for workers and the community alike.

This approach is consistent with national policy
NPPF Paragraph 85: Supporting flexible economic environments that integrate with and benefit the wider local area.
NPPF Paragraph 96: Promoting social interaction and healthy, inclusive communities through shared, accessible community facilities and active local hubs.
NPPF Paragraph 109: Supporting sustainable growth patterns and minimising unnecessary long-distance travel.

Amend the first paragraph of the supporting information to acknowledge the historic legacy of Cambridge’s traditional markets as stated in the Jobs Topic Paper

Paragraph 11.6 of the Jobs Topic Paper states that “The first paragraph of the supporting information has been amended to acknowledge the historic legacy of Cambridge’s traditional market.”
This change has not been implemented.
Cambridge’s traditional market possesses a unique historical legacy, having served as a vital community hub since before the founding of the University. The daily and Sunday stalls providing fresh food and produce represent a living connection to the city's medieval heritage and its enduring relationship with the surrounding agricultural landscape, as well as a sustainable low carbon economy. This must be recognised in the policy.