Greater Cambridge Local Plan: Proposed Submission

1. Commission a comprehensive visitor capacity study for the city centre that forecasts both day-visitors and overnight stays, establishing safe and pleasant spatial thresholds.
2. Amend Policy J/VA to require specific soft/hard infrastructure, pedestrian management measures, and spatial routing to guide visitors to less congested zones.
3. Commit the Councils to investigating local visitor management funding tools (such as tourist/group-tour levies) to support street curation, signage, and pavement maintenance.
4. Reframe the visitor economy criteria to ensure proposals do not unacceptably harm local residential amenity, city centre liveability, or the overall environment required to attract and retain workers in key innovation sectors.

Policy J/VA fails the statutory tests of soundness set out in national policy.

The policy is unsupported by a robust, proportionate, or rounded strategy and evidence base. It lacks day-visitor forecasts, local carrying capacity evaluations, or a monitoring framework.

It fails to address existing physical congestion or manage the functional transport/infrastructure demands generated by unrestrained visitor volumes.

It fails to balance growth with environment/liveability, risks eroding town centre vitality and safety through unmanaged over-tourism, and fails to adopt a vision-led approach to sustainable transport and infrastructure management.

1. Not Justified: Lack of a Comprehensive Evidence Base & Strategy
Policy J/VA is not underpinned by a rounded tourism strategy or objective monitoring metrics. While future short-let registration data will clarify stay-over accommodation, the plan fails to quantify or model day-visitor numbers.

The plan fails to evaluate the physical and environmental carrying capacity of key central areas to accommodate visitors safely and pleasantly alongside residents. Making provision for tourism without assessing spatial limits makes the policy speculative rather than evidence-based.

2. Not Effective: Failure to Manage Congestion & Protect Quality of Life
Central areas of Cambridge are already unpleasantly congested. Projected sub-regional population growth will amplify these pressures, regardless of containment efforts in new settlements. Unrestrained day-visitor traffic (and the vehicles bringing them) directly threatens urban functionality.

The Local Plan’s economic strategy aims to maintain Cambridge's global reputation for education, research, and innovation. A critical determinant of this reputation is maintaining an exceptionally attractive environment for internationally mobile workers and their families. Unmanaged tourism degrades city centre liveability, actively undermining the plan's broader economic objectives.

Policy J/VA fails to establish mechanisms or spatial guidance to direct visitors to less conflictual parts of the centre, nor does it identify infrastructure mechanisms (e.g., exploring tourist/group tour levies for street curation, signage, and maintenance) to mitigate negative externalities.

3. Inconsistent with National Policy (December 2024 NPPF)
National policy requires plans to promote safe, inclusive, and attractive places that support community well-being and town centre vitality. By failing to manage visitor density, the policy allows conditions that degrade the public realm and user experience.

The NPPF embeds a vision-led approach to transport and infrastructure planning. Policy J/VA fails to integrate transport demand management for coach/visitor traffic or align visitor arrivals with sustainable transport networks.

CPPF strongly endorse the policy’s robust protection of existing public houses across Greater Cambridge. Public houses serve as vital social, historical, and architectural anchors within our urban and rural communities, and securing their retention is essential for preserving local identity and community coherence.
Public houses frequently reflect the historical evolution and land-use history of their sites. Protecting these assets ensures that tangible links to local heritage are retained for future generations.
Public house buildings are often visually prominent or landmark structures that make a distinct contribution to the character, distinctiveness, and scale of the streetscape. Preventing their unjustified loss or insensitive redevelopment safeguards the quality of the built environment.
In addition to their architectural and historical value, public houses provide essential spaces for community interaction. The strict criteria set out in Policy SW/PH ensure that these assets are not lost without rigorous justification and proof of non-viability.

1. Establish a Comprehensive Trip Budget and Monitor & Manage Framework Clause: Insert a new policy clause setting out a standardised framework mechanism for strategic allocations that:
o Defines a clear methodology for calculating vehicular trip budgets.
o Mandates continuous traffic monitoring that explicitly filters out through-traffic.

o Identifies a pre-agreed sequence of scalable mitigations covering a wide range of growth scenarios.
o Establishes a legally sound enforcement mechanism via planning conditions and S106 obligations, including contingency funding for mitigations that go beyond what is agreed to be necessary in planning terms at the point of determining an application, but which may be drawn down if and when Travel Plan monitoring indicates that agreed Travel Plan targets are not being met or if significant adverse impacts of the development are observed that were not anticipated.
2. Define Circumstances for Highway Capacity Increases: Amend the policy to state explicitly that general motor vehicle road or junction capacity increases are an exceptional measure of last resort, permissible only after all realistic, cost-proportionate sustainable transport and background trip mode-shifting interventions have been exhausted.
3. Define Objective Standards & Frameworks: Replace subjective terms with objective metrics (e.g., maximum 400m walking distance to an all-week public transport service operating at least half-hourly during peak times) and formally cite the Healthy Streets Indicators as the baseline design framework for walkable neighbourhoods.
4. Amend Clause 3 Wording: Redraft Clause 3 to ensure syntax clarity, incorporate shared transport, enforce delivery as a combined package, and strengthen implementation requirements: Amend to: "… public AND SHARED transport services, AND behavioural change measures …"
5. Strengthen Implementation Phasing: Strengthen wording to ensure that critical active, public, and shared transport links MUST be operational prior to first occupation UNLESS AGREED OTHERWISE WITH THE RELEVANT LOCAL AUTHORITIES, removing soft phrasing that permits delayed delivery.

Cambridge Past, Present & Future (CPPF) supports the overall intent of Policy I/ST to prioritise active travel and sustainable transport choices. However, CPPF objects to Policy I/ST as currently drafted.

The policy fails the statutory tests of soundness, specifically, Policy I/ST is not effective, not justified, and inconsistent with national policy.

Summary of Soundness Failures
1. Not Effective: The policy mentions vehicular trip budgets as a principle but fails to provide an operational, legally sound framework or enforcement mechanism within Policy I/ST to manage trip budget exceedances over long build-out periods.
2. Not Effective: The policy relies heavily on undefined, subjective terminology ("sufficient", "adequate", "appropriate", "proportionate", "flexible", "optimised", "high quality"). This creates ambiguity, leaving developers unable to ascertain minimum acceptable standards when pricing land values—potentially leading to compromises around viability or appealed decisions, conditions or obligations.
3. Not Effective: The policy lacks a clear priority hierarchy mandating that mode-shifting interventions (including of background trips to release capacity for new vehicular trips generated by the development) must be exhausted before general motor vehicle road or junction capacity upgrades are permitted.
4. Inconsistent with National Policy & Weak Drafting: Clause 3 contains ambiguous drafting regarding transport services, fails to explicitly incorporate shared transport modes, and uses disjunctive phrasing ("or" instead of "and") across measures that are only effective when delivered in combination.

1. Unenforceable & Missing Trip Budget Framework
While Policy I/ST references vehicular trip budgets, it provides no operational mechanics for calculating, monitoring, or enforcing them across strategic sites. A relatively detailed approach is provided in only one site-specific policy, S/NEC §19–24. Policies for other strategic sites include only a brief outline of the requirement, e.g. S/CE §15(b), S/CBC §20(j) and 21, S/NWC §16, S/CBN §42, and S/GF §16, employing the terms “trip budget” and “monitor and manage” without definition (in the Glossary or elsewhere) or reference to a framework set out elsewhere.

Although the Infrastructure Delivery Plan (IDP) references technological measures for monitoring traffic at strategic sites, monitoring does not equal enforcement. Existing highway legislation does not provide direct enforcement powers for vehicular trip budgets, making this strictly a planning control matter.

The policy fails to provide a framework for dealing with wide ranges of uncertainty over multi-phase, long-term site build-outs in a way that is consistent with planning regulations.

2. Subjective Terminology & Viability Risk
Terms such as "sufficient", "adequate", "appropriate", "proportionate", "flexible", and "optimised" are used throughout the policy text without concrete metric definitions or benchmarks.

Because the policy fails to define clear, objective baseline thresholds (such as maximum walking distances to high-frequency public transport services), developers cannot accurately calculate minimum infrastructure requirements when establishing land value. Consequently, undeveloped land is routinely overvalued, often resulting in requirements for sustainable transport infrastructure or affordable housing being pared back later during viability assessments or fought over at appeal.

The policy fails to cite an objective, recognised street design framework (such as the Healthy Streets Indicators) to measure street quality and walkable neighbourhood standards objectively.

3. Failure to Prioritise Mode-Shift Over Road Capacity Expansion
While the policy directs developers to maximise sustainable travel, it fails to specify that mode-shifting interventions must take explicit precedence over general road or junction capacity upgrades.

The policy ignores the ability of developments to offset transport impacts by funding mode-shifts in existing background traffic—a mechanism that frees up existing road capacity under CIL Regulation 122(b) principles and forms the foundation of an effective trip budget approach.

4. Ineffective and Ambiguous Drafting in Clause 3
In Clause 3, the term "services" is syntactically detached, leaving it unclear whether it applies strictly to transport or broader community infrastructure.

The policy omits explicit mention of shared mobility solutions—such as car clubs, bike hire schemes, and lift pooling—which are essential components of modern sustainable development.

Clause 3 treats sustainable transport infrastructure, public/shared transport services, and behavioural change measures disjunctively using "or". These measures are interdependent and only achieve meaningful mode-shift when delivered as a combined package. Using "or" allows applicants to pick and choose individual measures rather than delivering a comprehensive suite.

1. Align Glossary Definition: Update the Glossary definition of "Mobility (travel) hub" to ensure consistency with the policy text, explicitly clarifying the distinction between:
o Local/Neighbourhood Mobility Hubs: Prioritising active travel, shared mobility (car clubs/bike hire), and short-term passenger drop-off ("kiss and ride").
o Strategic Interchanges / Park & Ride Sites: Facilities that incorporate larger-scale strategic vehicle parking.
2. Clarify Drop-Off Terminology: Clarify in the Glossary and policy supporting text whether "car drop off" refers to passenger drop-off/pick-up, shared car-club vehicle returns, or rental car drop-off points.
3. Insert Assessed Need Criteria for Car Parking: Amend Policy I/MH to state explicitly that any private car parking provision at a mobility hub must reflect a rigorously assessed and demonstrated transportation need, setting clear capacity caps appropriate to the hub's specific level in the settlement hierarchy.
4. Prevent Unbounded Parking Expansion: Add explicit policy language clarifying that the inclusion of modal interchange facilities does not justify large-scale car parking provision at local or neighbourhood mobility hubs.
Participation at the Examination Y

Cambridge Past, Present & Future (CPPF) supports the general concept of mobility hubs to facilitate seamless multi-modal travel across Greater Cambridge. However, CPPF objects to Policy I/MH and its accompanying glossary definition as currently drafted.

The policy fails the statutory tests of soundness ,specifically, Policy I/MH is not justified and not effective due to internal policy contradictions, ambiguous parking criteria, and a lack of clear scale limits for private vehicle parking.

Summary of Soundness Failures
1. Not Justified / Internal Contradiction: There is a fundamental conflict between the Glossary definition of a "Mobility (travel) hub" and the supporting text of Policy I/MH regarding private car parking provision and Park & Ride facilities.
2. Not Effective: The policy criteria regarding permitted car parking are so loosely worded ("only as necessary") that they fail to provide any meaningful boundary or limit on parking scale. As drafted, the policy could be used to justify private car parking at virtually any scale under the guise of modal interchange, contradicting the policy's stated objective to discourage journeys entirely by private car.

Detailed Analysis Against Tests of Soundness
1. Inconsistency Between Glossary and Policy Supporting Text
The Glossary definition for "Mobility (travel) hub" explicitly excludes private car parking provision, citing only "car drop off" (which itself is ambiguous, failing to clarify whether it refers to rental/hire car drop-off or passenger drop-off/kiss-and-ride).

In direct contrast, the supporting text to Policy I/MH explicitly conflates mobility hubs with major strategic car parks, stating that mobility hubs "include traditional transport interchanges such as railway stations, bus stations, park and ride sites, as well as smaller local hubs serving district centres and neighbourhoods."

A policy cannot be considered justified or coherent when the primary term defined in the plan's glossary is contradicted by the policy's supporting text.

2. Unbounded Parking Scale and Ambiguous Criteria
The policy attempts to control vehicle parking by stating it will be permitted "only as necessary to support the mobility hub in supporting modal interchange and discourage journeys entirely by private car."

If "necessary... to support modal interchange" is accepted as the justification for parking at the scale of a strategic Park & Ride (thousands of spaces), the policy effectively permits car parking at any scale. It fails to establish clear upper parameters, thresholds, or evidence-based criteria for local vs. strategic hubs.

The policy does not mandate that the number of parking spaces at a proposed mobility hub must be strictly proportionate to, and dictated by, a rigorously assessed local or strategic transportation need. Without an explicit policy requirement linking parking provision to demonstrable need, developments risk delivering excessive surface parking under the label of a "mobility hub."

1. Insert Explicit Policy Support for National Grid Upgrades: Amend Policy I/EI to include explicit policy backing and criteria for identifying and delivering an additional connection to the National Grid within South Cambridgeshire.
2. Recognize R&D & AI Power Demands: Update the supporting text of Policy I/EI to explicitly acknowledge the high power density and security-of-supply requirements of academic R&D, commercial laboratories, and AI-driven tech clusters across the district.

While the general objectives of Policy I/EI regarding energy capacity and net-zero transitions are supported, the policy as drafted is unsound.

Specifically, Policy I/EI is not positively prepared and not effective, as it fails to identify, facilitate, or make adequate spatial provision for the critical high-voltage electricity grid connections required to secure the current and future operational needs of the region's academic and commercial Research & Development (R&D) sector.

Summary of Soundness Failures
1. Not Positively Prepared: The policy fails to plan proactively for the infrastructure required to support objectively assessed growth in Greater Cambridge’s commercial and academic R&D sector—particularly the exponential energy demand driven by Artificial Intelligence (AI) and high-performance computing.
2. Not Effective: Over-reliance on the existing connection to the National Grid at Burwell (in East Cambridgeshire) creates a single-point-of-failure risk and acute network capacity constraints. Policy I/EI lacks specific site allocations, safeguard zones, or proactive framework criteria for an additional National Grid connection point in South Cambridgeshire.

1. Failure to Meet the Energy Needs of Strategic Growth
Both academic institutions and commercial innovation clusters across Greater Cambridge have high baseline electrical power requirements. The rapid adoption and integration of Artificial Intelligence (AI), data centre expansion, and advanced computational laboratories will significantly multiply peak and base-load energy demands over the plan period.

The Local Plan designates Greater Cambridge as a world-leading hub for innovation and commercial R&D. However, Policy I/EI fails to align infrastructure delivery with these growth targets by ignoring the scale of energy security required to keep these facilities operational and internationally competitive.

2. Not Effective: Inadequate Network Security and Spatial Provision
Current strategic power distribution relies heavily on the Burwell sub-station connection in East Cambridgeshire. Relying on a single primary connection point provides insufficient security of supply for mission-critical academic research, clinical trials, and commercial laboratories, where power interruptions or supply rationing cause catastrophic operational losses.

Policy I/EI relies on reactive criteria for energy proposals rather than proactively identifying or safeguarding land for critical infrastructure. To deliver a resilient network, the Plan must explicitly identify and support suitable locations for a new, secondary connection to the National Grid within South Cambridgeshire.

1. Explicitly Safeguard the Mill Pond Mill/Warehouse Building:
Amend Policy S/PRIA/OPML to explicitly identify the historic warehouse/mill building on the eastern side of Mill Pond as a valued non-designated heritage asset requiring retention, conservation, and adaptive reuse.
2. Clarify Clause 1d to Prevent Demolition:
Amend Clause 1d to clarify that the creation of public open space and public realm improvements “must be achieved through the retention, integration, and repurposing of existing historic structures”, explicitly ruling out the demolition of the Mill Pond warehouse/mill building for open space provision.
3. Enhance Heritage and Setting Criteria:
Insert policy text requiring any proposal within the opportunity area to protect and enhance the immediate group value with the Anchor PH and the wider historic setting of Queen’s College, King’s College Chapel, and Coe Fen.

Cambridge Past, Present & Future (CPPF) supports the overarching intention to deliver a high-quality, heritage-led enhancement of the Old Press / Mill Lane Public Realm Improvement Area. However, CPPF objects to Policy S/PRIA/OPML as currently drafted.

The policy fails the statutory tests of soundness specifically, Policy S/PRIA/OPML is not justified and not effective due to internal policy contradictions that leave a significant non-designated heritage asset vulnerable to demolition.

Summary of Soundness Failures
1. Not Effective / Internal Policy Contradiction: There is an explicit conflict between Clauses 1a/1b (which emphasise heritage preservation and enhancement) and Clause 1d. Clause 1d is loosely drafted and could be interpreted by site owners to justify the demolition of the historic warehouse/Mill building on the eastern side of Mill Pond to create new open space.

2. Not Justified / Unevidenced Loss of Heritage: The potential loss of this non-designated heritage asset is unjustified. The warehouse/mill building is an essential, highly visible reminder of Cambridge’s waterborne commercial and trading history, forms a key group with the Anchor Public House, and contributes positively to the historic setting of Queen’s College, King’s College Chapel, and Coe Fen.

Detailed Analysis Against Tests of Soundness
1. Internal Policy Conflict and Ambiguity
Clauses 1a and 1b correctly establish a heritage-led baseline for the area. However, Clause 1d focuses on public realm and open space creation without explicitly safeguarding non-designated heritage assets of local significance.

As drafted, Clause 1d creates an ambiguous policy loophole. Landowners could utilise the requirement for "open space creation" to justify demolishing the historic mill/warehouse building rather than pursuing a sensitive adaptive reuse scheme.

2. Historic Significance and Setting Impact
• The historic mill/warehouse building on the eastern side of Mill Pond is one of the few surviving tangible reminders of Cambridge's historic river-borne trade and industrial riverfront heritage.

• The building possesses strong group value alongside the adjacent Grade II listed Anchor Public House. Furthermore, it forms an integral element of the iconic historic views and setting of Queen’s College, King’s College Chapel, and the open landscape of Coe Fen as experienced from the River Cam and public footpaths.

• Demolishing a structurally sound, character-defining historic building for open space fails to align with national policy directives prioritising the retention, adaptive reuse, and enhancement of heritage assets

Delete sub-clauses b, c, d, and e relating to the astro pitch, tennis courts, MUGA, and school facility mitigation from Policy S/COPM, and ensure the correct site-specific allocation text (focused on historic townscape, university redevelopment, river frontage, and public realm improvements) is inserted.

Policy S/COPM contains, what is assumed to be an erroneous criteria requiring the provision of outdoor sports infrastructure (all-weather astro pitch, 4 tennis courts, MUGA) and school mitigation measures that do not relate to the Old Press / Mill Lane site context or development parameters.

The Old Press / Mill Lane area is a dense, highly sensitive historic urban site located in central Cambridge (bounded by Trumpington Street, Silver Street, Mill Lane, and the River Cam). It consists of compact historic university buildings, narrow lanes, public realm areas, and river frontage. It lacks the physical footprint or open land required to accommodate extensive outdoor sports facilities like a full-scale astro pitch, four tennis courts, and a MUGA.

1. Summary of Support
Cambridge Past, Present & Future (CPPF) strongly supports Policy BG/BG. Specifically, CPPF endorses the requirement for major developments to deliver a minimum of 20% Biodiversity Net Gain (BNG), as well as the crucial implementation principles established in paragraphs 8, 11, and 12 of the policy.

The policy focuses the 20% requirement on major developments capable of delivering strategic habitat creation. It ensures gains reinforce local priority areas identified in the LNRS and links site-level planning directly to Natural England IRZs and Buglife Important Invertebrate Areas. It ensures building designs contribute directly to urban nature recovery through integrated nesting and roosting features. It guarantees long-term management and monitoring regimes, so biodiversity improvements endure over the plan period and beyond.

While the Environment Act 2021 sets a statutory national baseline of 10% BNG, national planning policy enables local planning authorities to secure higher thresholds where locally justified. CPPF considers Policy BG/BG to be sound—it is positively prepared, justified by local ecological needs, effective, and fully consistent with national policy objectives under the National Planning Policy Framework.

A. Positively Prepared
Greater Cambridge is one of the most nature-depleted sub-regions in the UK, characterised by low woodland cover, fragmented habitats, and significant historic biodiversity loss. A 10% gain on major sites is insufficient to halt and reverse this decline alongside rapid economic and housing expansion. Requiring a 20% gain positively seeks to meet local nature recovery objectives and directly supports the delivery of the Cambridgeshire & Peterborough Local Nature Recovery Strategy (LNRS).

B. Justified
The 20% target is supported by robust local evidence, as set out in the Topic Paper: Biodiversity and Green Spaces which references the Cambridge City Biodiversity Strategy 2022-30 and the South Cambridgeshire Climate and Nature Strategy 2026-2030.

Furthermore, the council’s Local Plan Viability Assessment demonstrates that a 20% BNG requirement for major development is viable across strategic site typologies alongside affordable housing and key infrastructure contributions.

C. Effective
Policy BG/BG provides a practical, enforceable mechanism for ecological restoration by combining clear numeric targets with robust implementation mechanisms.

Policy BG/BG provides practical, targeted protection for specific ecological vulnerabilities across Greater Cambridge.

CPPF strongly endorses the explicit requirement to consult and assess developments falling within Natural England’s Impact Risk Zones (IRZs). Safeguarding Sites of Special Scientific Interest (SSSIs) from indirect impacts is essential to protecting our highest-tier nature assets.

CPPF strongly supports the dedicated protection for designated Important Invertebrate Areas (IIAs). Invertebrates are foundational to ecosystem health, and requiring developments within these zones to incorporate tailored habitat creation provides targeted, effective conservation.

CPPF strongly endorses the mandatory inclusion of integrated bird (particularly swift bricks) and bat boxes within the fabric of new buildings. Integrated units are permanent, aesthetically unobtrusive, and critical for supporting declining urban species.

D. Consistent with National Policy
The policy accords with NPPF Paragraphs 187 and 192, which direct planning policies to contribute to and enhance the natural environment by securing measurable net gains for biodiversity, establish coherent ecological networks, and protect designated sites and priority species. The NPPF establishes national BNG requirements as a baseline standard rather than a ceiling; Policy BG/BG appropriately exercises local plan-making discretion to protect vulnerable local assets.

1. Allocate Strategic GI Land: Introduce specific land allocations and spatial policy protections for accessible natural greenspace within the four Cambridge Nature Network priority areas to safeguard land from speculative inflation and secure its long-term delivery.
2. Incorporate Enabling Development Policies: Introduce explicit policy mechanisms that permit and facilitate enabling development in appropriate, non-sensitive locations where it directly secures and finances the acquisition and long-term management of strategic GI land.
3. Ring-Fencing & Strategic Acquisition Fund: Formally integrate strategic GI acquisition into Infrastructure Delivery strategy, establishing a dedicated land acquisition fund that actively supports GI charities and land trusts in securing option agreements and land purchases.
4. Demonstrate Deliverability Evidence: Publish a clear, evidence-based GI Delivery Strategy showing spatial land availability, willing-landowner agreements, and realistic acquisition timelines for all 14 strategic GI initiatives over the plan period.

1. Summary of Objection
Cambridge Past, Present & Future (CPPF) considers Policy BG/GI unsound because it fails the Effectiveness test. The policy relies on delivering 14 strategic green infrastructure (GI) initiatives—including the four core priority areas of the Cambridge Nature Network—without securing the land required to deliver them, either through specific site allocations or spatial planning policy mechanisms.

The Councils’ reliance on developer contributions via Policy BG/EO and the Infrastructure Delivery Plan (IDP) is fundamentally flawed: funding mechanisms cannot deliver green infrastructure if the necessary land cannot be acquired. As a major local conservation charity and land manager that has actively attempted to acquire land for GI south and east of Cambridge, CPPF has found that land is not available on the open market due to speculative development aspirations and hyper-inflated land values. Without land delivery mechanisms, Policy BG/GI is an undeliverable aspiration rather than an effective planning strategy.

2. Soundness Assessment: Failure of the Effectiveness Test
Under national planning policy, a plan is only effective if it is deliverable over its period and based on effective joint working on cross-boundary strategic priorities. Policy BG/GI fails this test on three key grounds:

A. Funding Without Land Availability is Ineffective
The Councils assert that Policy BG/EO will generate off-site financial contributions towards strategic GI projects identified in the IDP (such as the Gog Magog Regional Park and Coton Countryside Reserve). However, financial contributions are meaningless if there is no land available to purchase.

CPPF has direct, firsthand experience attempting to acquire land to expand accessible natural greenspace in the Cambridge Nature Network priority areas (particularly south and east of Cambridge). Landowners are unwilling to sell land for green infrastructure or nature restoration because site allocations and speculative development pressures have inflated land value expectations to residential/commercial levels.

Ring-fencing S106 developer contributions via Policy BG/EO creates a pool of capital with nowhere to spend it. The Plan fails to demonstrate how public, or third-sector GI providers can overcome market land-value barriers without policy intervention.

B. Failure to Demonstrate Deliverability of the 14 Strategic Initiatives
The Plan fails to demonstrate that the 14 strategic GI initiatives identified in Policy BG/GI and the Local Nature Recovery Strategy (LNRS) are deliverable within the plan period.

Aside from selective measures embedded in major site allocations, the Plan contains no specific GI site allocations, spatial designations, or compulsory acquisition frameworks to secure land in the four priority areas of the Cambridge Nature Network.

By allocating rapid population and employment growth (e.g., at Grange Farm) without securing precursor strategic GI, the Plan will actively exacerbate recreational pressure on vulnerable, existing protected sites (including SSSIs, Local Nature Reserves, and country parks) that are already operating at or beyond ecological capacity.

C. Failure of Strategic GI to Keep Pace with Growth
Policy BG/GI operates reactively rather than proactively. Strategic GI must be delivered ahead of or concurrently with population growth to prevent irreversible ecological damage. Relying on piecemeal, post-development off-site contributions through Policy BG/EO guarantees a lag between population growth and GI provision, failing the core principles of sustainable development.

Remove exemption from clause 1c and where 50% of development site includes accessible greenspace, apply the UGF to the built form.

Cambridge Past, Present & Future (CPPF) supports the principle of incorporating an Urban Greening Factor (UGF) into the Local Plan. However, CPPF objects to Policy BG/UGF in its current form due to the unsound exemption within Clause 1c.

Clause 1c requires major residential developments outside the Cambridge Defined Development Extent to achieve a UGF score of at least 0.5, "except where it can be demonstrated that more than 50% of the site area equates to accessible greenspace."

This exception creates an unevidenced loophole and introduces fundamental ambiguity regarding site baselines. As drafted, the policy fails the Effectiveness and Justification tests of soundness.

Soundness Assessment:
A. Ambiguity and Lack of Clarity
The policy text is inherently ambiguous. It fails to clarify whether the phrase "more than 50% of the site area equates to accessible greenspace" refers to:
1. Pre-existing accessible greenspace present on site prior to development, or
2. Open greenspace delivered as part of the proposed development layout.
In either interpretation, applying a blanket exemption to the UGF target lacks clear justification.

B. Failure of Effectiveness: The "Greenfield Layout" Loophole
The primary objective of an Urban Greening Factor is to integrate nature-based solutions—such as green roofs, rain gardens, permeable paving, wall cladding, and street trees—directly into the built fabric and residential streetscape.

Large, open expanses of accessible greenspace (e.g., retained meadows, sports pitches, or informal parks) serve vital recreational functions under Policy BG/EO, but they do not substitute for greening the built environment.

Under Clause 1c as drafted, a large greenfield site that devotes 50% of its site area to generic open space would be entirely exempt from the 0.5 UGF standard. As a result, the built residential layout could be developed to a very low greening standard—lacking street trees, biodiverse planting, and sustainable drainage features—exacerbating local surface water run-off and urban heat risks where people actually live.

C. Inconsistency with National Policy
The exemption conflicts with Paragraphs 135, 187, and 188 of the NPPF, which require planning policies to optimise environmental gains, embed high-quality green infrastructure within the built environment, and enhance local climate resilience. Allowing built residential areas to bypass basic urban greening standards simply because they adjoin open greenspace undermines these national policy imperatives.