Greater Cambridge Local Plan: Proposed Submission

Reintroduce an explicit, measurable requirement of 30% tree canopy cover for major development schemes, or include a target in Appendix E Monitoring Framework
Redraft Clause 2 to specify that where tree loss is unavoidable, replacement requirements must be calculated based on the canopy area and amenity value that the lost trees would have provided at maturity, rather than simple numerical or footprint replacement.

Cambridge Past, Present & Future (CPPF) objects to Policy BG/TC as currently drafted because it fails the statutory tests of soundness, specifically, the policy is not positively prepared, not effective, and not justified.

The policy suffers from two critical structural deficiencies:
1. Removal of Quantitative Canopy Target: The omission of the quantitative 30% tree canopy cover target previously contained in the Regulation 18 draft creates a policy vacuum that fails to guarantee long-term canopy delivery or align with the local authority's own environmental strategies.
2. Flawed "No Net Loss" Definition: Clause 2 defines tree replacement in terms of raw tree count or surface footprint rather than mature canopy volume and ecological value, allowing high-value mature trees to be replaced by juvenile saplings without adequate long-term mitigation.

1. Removal of 30% Canopy Target
The removal of the explicit, quantitative 30% tree canopy cover target previously contained in the Regulation 18 draft is an unjustified departure from an established, evidence-based benchmark.

Relying solely on the Urban Greening Factor (UGF) and general non-net-loss ambitions fails to provide a mechanism to guarantee canopy delivery. UGF and Biodiversity Net Gain (BNG) metrics measure broad green surface types and habitat units, not long-term tree canopy structure.

Replacing a binding target with general aims directly undermines the delivery of the Council’s own Cambridge Urban Forest Strategy. A local plan policy that fails to support or actively conflicts with the authority's core environmental strategies cannot be considered effective or positively prepared.

2. Ambiguity and Ineffectiveness of Clause 2
Clause 2 defines the "no net loss" test strictly in terms of raw tree cover (or count/area) rather than overall canopy volume, area, or amenity and ecological value.

As written, the policy allows a developer to fell high-value mature trees with significant canopy spread and replace them with young saplings or whips while technically meeting the "no net loss of cover" requirement on day one.

This structural flaw causes an immediate and long-term net loss of carbon sequestration, microclimate cooling, and visual amenity. To be sound and effective, mitigation must account for temporal loss and mature canopy replacement.

CPPF welcomes the policy’s explicit recognition of the historic and cultural significance of river corridors, as well as the clarification in the supporting text that access improvements—specifically the continuous Cam Valley Trail—will be carefully routed to avoid sensitive wildlife habitats along the riverbank and floodplain.
We strongly support the confirmation in Paragraph 5.74 that the proposed Cam Valley Trail will not follow the riverbank or floodplain along its entire length. Striking the right balance between public access and nature conservation is critical, and this commitment ensures that high-value river and floodplain habitats are protected from excessive recreational disturbance.
We welcome the policy text acknowledging the historic value of river corridors across Greater Cambridge. The River Cam—particularly the historic stretch from Byron’s Pool to Baits Bite Lock—is a defining landscape and cultural asset that requires clear protection within the planning framework.
The policy successfully aligns public access ambitions with environmental safeguards, ensuring that green infrastructure delivery does not come at the expense of fragile ecosystems.

1. Insert Definition into Appendix A (Glossary): Define "Accessible Greenspace" explicitly as public open land accessible at nil cost at all reasonable times, excluding SuDS, green roofs, and private farmland with revocable paths.
2. Update Network Analysis & Correct Site Data: Complete actual walking network distance analysis and reclassify Coton Countryside Reserve in the evidence base to accurately reflect true accessible habitat areas (~17 ha).
3. Reframe Per Capita Target: Amend Paragraph 5.88 to set an explicit aim of achieving a net gain in per capita accessible greenspace provision across the plan period to address existing baseline deficits.
4. Amend Clause 7 (Recreational Mitigation): Name key receptor spaces (including Wandlebury Country Park, Magog Down, and Roman Road SSSI); explicitly allow developer contributions to fund long-term site management; and mandate that on-site mitigation adequacy be determined by the LPA using a standardised pressure assessment.
5. Amend Clause 14 (Long-Term Stewardship): Require third-party land transfers to include management funding in perpetuity calculated on a capitalised endowment basis, incorporating land acquisition costs into strategic calculations.
6. Clarify Policy Thresholds & Exclusions: Reconcile Clause 4 employment thresholds with major development definitions; clarify that play (Clause 8) and food growing (Clause 11) space sit in addition to accessible greenspace standards; and explicitly state that SuDS land cannot count toward accessible greenspace targets.

Cambridge Past, Present & Future (CPPF) supports the overall direction of Policy BG/EO—particularly the introduction of quantified accessible greenspace standards, prioritising off-site contributions toward Strategic Green Infrastructure Initiatives (Clause 6), and Clause 7 (mitigating recreational pressure on sensitive SSSIs). As a landowner and manager of key receptor sites, CPPF views Clause 7 as a critical provision.

However, the policy fails the statutory tests of soundness, specifically, Policy BG/EO is not justified, not positively prepared, and not effective.

Summary of Soundness Failures
1. Not Justified: Key policy terms ("Accessible Greenspace") are undefined within the Plan. Furthermore, the underlying spatial deficiency evidence relies on provisional straight-line distance mapping and contains major factual errors regarding land access and site areas (notably at Coton Countryside Reserve).
2. Not Positively Prepared:The policy sets an objective to merely maintain per capita provision levels, effectively entrenching existing, documented greenspace deficits across Greater Cambridge without meeting objectively assessed needs.
3. Not Effective: Time-limiting management obligations to 30 years (Clause 14) makes third-party charity stewardship undeliverable. Additionally, Clause 7 lacks precise metrics, site definitions, or clear assessment tests, preventing consistent implementation.
Detailed Analysis Against Tests of Soundness
1. Undefined Policy Terms & Flawed Technical Evidence
Clause 3 sets a standard of 7.0 ha of accessible greenspace per 1,000 population. Paragraph 5.88 directs readers to the Glossary, but Appendix A contains no definition for "Accessible Greenspace"—only "Green Infrastructure," a much broader term that includes inaccessible features like SuDS, green roofs, and swales. A numeric policy target cannot be legally enforced using evidence-base definitions external to the adopted Plan.

The distance mapping in Appendix D of the Green Infrastructure Strategy Vol. 2 uses straight-line measurements rather than actual walking route network analysis. This systematically overstates accessibility by ignoring physical barriers such as the M11, railway lines, rivers, and private farmland.

As landowner, CPPF notes that the evidence base falsely relies on Coton Countryside Reserve to satisfy the 100 ha District Natural Greenspace threshold for West Cambridge and South Cambridgeshire. In reality, only ~17 ha (~42 acres) comprises accessible natural habitat; the remainder is active arable farmland crossed by revocable permissive paths. Permissive paths across working crops do not constitute 121 ha of publicly accessible natural greenspace. Please see attached Plan showing the extend of land let for arable farming under tenancy and land which is publicly accessible at Coton

2. Entrenching Existing Deficits
Paragraph 5.88 aims to merely maintain per capita access levels. The evidence base records severe existing sub-regional gaps (e.g., zero provision at the 500 ha / 10 km scale) and local ward deficits across Cambridge. Adopting an aim that maintains current per capita levels during a period of rapid growth explicitly entrenches known deficiencies rather than seeking net gains.

The accessible greenspace standard was reduced from 8.7 ha/1,000 population (at Regulation 18 stage) to 7.0 ha/1,000 population without justification in the evidence base.

3. Unviable Stewardship & Imprecise Policy Criteria
Requiring a 30-year management plan/commuted sum fails for public open spaces. Unlike finite schemes, public greenspace transferred to charities (like CPPF) exists in perpetuity. A 30-year commuted sum leaves receiving trusts with un-funded long-term liabilities, leading to site deterioration or rejection of land transfers. Long-term funding must be secured via capitalised endowments in perpetuity.

Clause 7 fails to name the specific sites to which it applies, omitting key non-SSSI regional receptor sites under severe pressure (such as Wandlebury Country Park and Magog Down). Furthermore, it provides no objective test or standard methodology to determine what constitutes a "significant proportion" of daily recreational need, leaving mitigation requirements uncertain and unenforceable at application stage (e.g., Policy S/GF Grange Farm).

4. Minor Drafting Matters Affecting Clarity and Effectiveness
To ensure Policy BG/EO is effective and unambiguous in implementation, CPPF requests the following specific clarifications and corrections:

1. Reconcile Employment Development Thresholds (Clause 4): Clause 4 applies open space requirements to employment schemes of 2,000 sq m GIA or more, whereas the Glossary defines major non-residential development at 1,000 sq m. This creates an unintended policy vacuum for schemes between 1,000 and 1,999 sq m. The threshold in Clause 4 should be updated to align with the Glossary definition.

2. Clarify Relationship Between Open Space Standards: The policy must explicitly state whether play/youth space (Clause 8: 0.6 ha/1,000) and food growing space (Clause 11: 0.4 ha/1,000) sit within or in addition to the overarching 7.0 ha accessible greenspace standard in Clause 3. To prevent under-provision, the policy should clarify that specialised play and food space standards are additive and distinct from accessible greenspace.

3. Exclude Sustainable Drainage Systems (SuDS): The policy should state explicitly that land dedicated to SuDS features (such as attenuation basins, swales, and rain gardens) does not count toward the Accessible Greenspace standard. While SuDS contribute to general Green Infrastructure, they frequently fail to provide the unhindered, year-round public recreational utility that accessible greenspace targets are designed to deliver.

4. Incorporate Ward-Level Deficiency Targets: Unlike the 2018 Cambridge Local Plan (Appendix I), this draft omits localised baseline standards. The ward-level accessibility gaps identified in Appendix D of the Green Infrastructure Strategy Vol. 2 should be set out in a clear monitoring table (e.g., within Appendix E) to ensure developers and decision-makers address documented local deficits.

Amend Policy to remove requirements for contributions toward the off-road CSET busway and replace them with traffic management and bus priority measures on the A1307 to ensure that travel by bus to the Campus from either direction is as convenient and reliable as possible.
1. A bus lane along the A1307 westbound to Hinton Way roundabout and busway between the roundabout and into CBC.
2. Signals controls and lead-in bus lanes at the Babraham Research Park access roundabout
3. Priority measures at the A11 interchange or a new bus and active travel bridge over the A11, linking the A1307 and Newmarket Road

Cambridge Past, Present & Future (CPPF) objects to the policy, specifically clause 19c which requiring development to contribute to the proposed off-road Cambridge South East Transport Schemes (CSETs). CSET1 is A1307 corridor work: road safety, walking, cycling and bus priority between Haverhill and Cambridge. CSET2 is the segregated busway from the A11 travel hub to the Biomedical Campus. Clause 19(c) does not distinguish between the phases. CSET2 does not have consent, making it neither justified nor effective.

Transport interventions should focus on delivering targeted traffic management, bus priority measures, and active travel improvements along and across the existing A1307 corridor.

By tying development contributions to an unsustainable, off-road busway rather than effective A1307 highway interventions, Policy S/BRC is unsound as it is neither justified, effective, nor positively prepared.

1. Lack of Justified Transport Strategy
Requiring contributions toward an off-road busway is unjustified when reliable, efficient bus access to the Babraham Research Campus can be achieved far more effectively through targeted highway management along the A1307.

The policy fails to demonstrate that an off-road busway scheme, which does not directly serve the campus, represents the most effective or proportionate transport solution for the campus compared to incremental, targeted bus priority measures along the existing road network.

2. Ineffective Infrastructure Delivery
To ensure travel by bus to the campus from either direction is as convenient, direct, and reliable as possible, transport policy must focus on the real-everyday bottlenecks along the A1307. Tying campus growth to the off-road busway scheme fails to address critical local transport priorities, including:
• Addressing westbound flow toward the Hinton Way roundabout.
• Access and signalisation issues at the Babraham Research Campus access roundabout.
• Severance and priority issues across the A11 interchange.

1. Delete Clause 22c Reliance on Unconsented Schemes: Remove the explicit requirement to contribute to CSET Phase 2 in Clause 22c. Replace it with a requirement for flexible, deliverable contributions toward verified sustainable transport and highway network mitigation along established corridors.
2. Mandate Robust Transport Modelling: Insert explicit policy text requiring any masterplan or strategic Transport Assessment to test granular, realistic sustainable mode shares based on up-to-date empirical baseline data rather than unevidenced car usage assumptions.
3. Require Access Controls on the Southern Gateway: Amend paragraph 22(d)(iv) to read ‘A new Southern Gateway access road to provide direct, safe and uncongested movement for active travel, buses and emergency service vehicles between the site and the A1307/Babraham Road Park & Ride. The design and function of the Southern Gateway, including the extent of its use by general motor traffic, will be subjected to options testing as part of the whole Campus masterplan, required at paragraph 30.

Cambridge Past, Present & Future (CPPF) objects to the policy regarding the transport and movement criteria, the supporting evidence base, and the requirement for financial/infrastructure contributions towards an unconsented scheme.

Policy S/CBC relies on flawed baseline transport assumptions, fails to mandate essential traffic management controls to safeguard emergency and bus access, and improperly requires development contributions toward the Greater Cambridge Partnership (GCP) Cambridge South East Transport (CSET) Phase 2 scheme.

Consequently, Policy S/CBC is unsound as it is neither justified nor effective.

1. Unjustified & Unsound Transport Strategy
The supporting evidence base (the third-party KMC Transport Planning strategy) relies on an assumed baseline "person car" mode share of 69% without empirical justification or testing. This figure directly contradicts actual operational data for the campus, where the 2023 non-vehicular mode share was 36.4% and the combined car driver/passenger share was 55%.

Despite explicit acknowledgment on page 31 of the KMC strategy that "the feasibility from a mode share must also be considered," the strategy fails to breakdown, model, or test realistic future sustainable mode shares (walking, cycling, e-scooter, bus/CSET, and rail). Assuming a static car mode share ignores existing capacity constraints on access roads and car parks.

2. Premature Policy Reliance on Unconsented Infrastructure
Clause 22c requires development to contribute directly to the GCP CSET Phase 2 scheme.

The CSET Phase 2 scheme does not have an approved Transport and Works Act Order (TWAO). Tying site delivery, viability, and transport mitigation to an unconsented scheme that may not be delivered in its current form is neither justified by evidence nor effective as a reliable mechanism to manage development impacts.

3. Ineffective Access and Severe Risk to Emergency/Bus Routes
The policy fails to test or mandate general vehicle access restrictions via the proposed new southern gateway.

Traffic queueing to turn right into the new southern access road will back up to the main roundabout. This will introduce severe delays to public transport and emergency blue-light vehicles (ambulances) accessing Addenbrookes, Rosie and future hospitals.

The strategy and policy fail to incorporate access controls—such as a bus gate at the entrance or along the access road—to limit general vehicle volumes and preserve a congestion-free route for buses and emergency services.

• Amend Figure 53 so that it does not indicate or imply a fixed location for the railway station.
• Explicitly mandate relevant rail industry bodies (e.g., Network Rail, GBR, Department for Transport) as formal stakeholders in co-developing the site-wide masterplan.
• Insert explicit text stating that the final alignment of the railway and location of the station will be determined through a comprehensive options assessment process as an integral part of the Masterplanning stage.
• Re-draft Paragraph 20 to establish that the site masterplan holds primary authority in determining the optimal location, spatial integration, and design criteria for Cambridge East Railway Station, ensuring infrastructure options are evaluated against local spatial, density, and active-travel objectives.

Cambridge Past, Present & Future (CPPF) objects to Policy S/CE (Cambridge East) regarding the premature spatial fixing and governance structure for the proposed Cambridge East Railway Station.

By referencing Figure 53 in Paragraph 2 and delegating the station design and alignment predominantly to rail industry bodies in Paragraph 20, Policy S/CE effectively locks in a station location on or close to the existing railway line prior to comprehensive spatial and Masterplanning evaluation.

This approach makes local spatial planning subservient to rail infrastructure engineering—likely resulting in a line-of-least-resistance approach—rather than allowing place-making objectives to shape the infrastructure. Consequently, Policy S/CE is unsound as it is not justified, not effective, and inconsistent with national policy.

Key Grounds of Objection
1. Inconsistent with National Planning Policy
Policy S/CE fails to satisfy core principles of national planning policy:

Section 12 (Achieving Well-Designed): Fails to set clear, site-specific spatial objectives that shape key infrastructure to create sustainable, well-integrated places.

Section 11 (Making Effective Use of Land): Risks sub-optimising land use around the strategic transport hub by failing to ensure the station is located where it can support the highest density of development and maximum catchment.

Section 9 / Paragraph 111(a) (Promoting Sustainable Transport): Fails to proactively minimise the need to travel and distance travelled by car by optimising station catchment and first/last-mile active travel connectivity.

In the absence of a wider Spatial Development Strategy for the region, Policy S/CE must set strong spatial objectives that shape the rail infrastructure, rather than allowing rail infrastructure constraints to dictate the masterplan.

2. Lack of Justified Evidence Base
The policy prematurely fixes the station location via Figure 53 without robust spatial evidence, site-specific trade-off analyses, or comprehensive options assessments.

The plan lacks evidence testing whether an alternative alignment or station position would yield greater transport, density, or environmental benefits for the site and surrounding communities.

3. Ineffective Masterplanning Delivery
Paragraph 20 delegates station delivery in a manner that makes the site-wide masterplan subservient to Network Rail or Great British Railways (GBR). Rail operators are incentivised to choose low-cost engineering solutions (e.g., placing the station on the immediate existing alignment) rather than maximising long-term social, environmental, and financial returns through optimal place-making.

A station positioned strictly for engineering convenience risks compromising patronage, reducing active-travel catchment, and weakening the long-term revenue model required to cover operational costs.

Key Spatial Objectives for Policy S/CE
To comply with the NPPF and ensure a sound site allocation, Policy S/CE must explicitly set place-making objectives that shape rail infrastructure, including:
1. Maximising Station Catchment: Expanding the walkable and active-travel catchment area for origin and destination trips within and surrounding the site.
2. Efficient Land Use: Supporting the greatest possible area of high-density, mixed-use development in close proximity to the station.
3. Maximising Rail Mode-Share: Leveraging high-capacity rail infrastructure to capture maximum trip demand away from private vehicles.
4. First/Last-Mile Capacity: Ensuring walking and cycling networks have the capacity to feed the station effectively in the absence of a connecting light rail or tram system.

1. Draft and Incorporate Formal Policy Criteria: Draft and insert explicit policy text into the Local Plan for Policy Areas S/SEA/CBN, S/SEA/GF, and S/SEA/WNT setting out clear objectives, land use controls, and enhancement requirements for these areas, and update the Indicative Spatial Framework diagrams accordingly.
2. Remove Unbacked Designations: If no formal policy criteria exist, remove the S/SEA/CBN, S/SEA/GF, and S/SEA/WNT designations entirely from the Policies Map to eliminate legal ambiguity.
3. Fix Policies Map Infrastructure: Ensure all interactive mapping layers, legend links, and supporting technical document hyperlinks are fully functional and accessible.

Cambridge Past, Present & Future (CPPF) objects to the lack of policy relating to Strategic Enhancement Policy Areas (S/SEA/CBN, S/SEA/GF, and S/SEA/WNT) within the Local Plan and on the interactive Policies Map.

While these strategic policy designations are formally mapped on the Policies Map and Figure 65 showing the proposed development for new settlement, there is a complete absence of accompanying policy text, criteria, or guidance within the written Plan document. Furthermore, the interactive Policies Map relies on broken hyperlinks for these designations, leaving the planning status of these areas entirely unexplainable.

Consequently, the Local Plan is unsound as it is not effective, nor justified.

Key Grounds of Objection
1. Total Absence of Policy Text and Guidance
Strategic Enhancement Policy Areas (S/SEA/CBN for Cambourne North, S/SEA/GF for Grange Farm, and S/SEA/WNT for Waterbeach New Town) are designated on the Policies Map, yet no corresponding policy wording exists within the written Local Plan document.

Although mentioned in the respective policies, these Strategic Enhancement Policy areas are omitted from the Indicative Spatial Framework diagrams within the respective site allocation policies (e.g., Policy S/CBN, Policy S/GF, Policy S/WNT). In fact, they lie beyond the site allocation.

Applicants, decision-makers, and local communities are left with no indication of what development, land use restrictions, enhancement expectations, or planning obligations apply within these mapped areas. A spatial designation without written policy criteria is meaningless and unenforceable.

2. Deficient and Non-Functional Evidence/Policies Map
Clicking on the S/SEA designations on the Regulation 19 interactive Policies Map directs users to broken/non-functional hyperlinks, preventing statutory consultees and the public from inspecting the underlying policy intent or evidence base during the formal consultation period.

Development plan policies must be clear, unambiguous, and accessible. In accordance with national planning guidance, the Policies Map cannot create standalone spatial designations that lack supporting policy text.

1. Specify Crossing Infrastructure Requirements: Amend the movement criteria of Policy S/CBN to explicitly define active travel and public transport A428 crossings, requiring wide, landscape-led green bridges or covered deck structures that incorporate landform, active uses, and public realm to physically and visually unite existing Cambourne and Cambourne North.
2. Reintroduce Explicit Employment Targets: Amend Policy S/CBN to include a minimum employment land allocation and strategic criteria supporting high-level sub-regional economic and civic uses to achieve a balanced jobs-to-homes ratio.
3. Strengthen the "Place Book" Scope: Update the policy text governing the "Place Book" to state that it must formally cover the functional, physical, and civic integration between existing Cambourne and Cambourne North, and be structured around TCPA Garden Town Principles, with commitments to community-beneficial land value capture, visionary leadership, and long-term community land stewardship mechanisms.

While CPPF recognises the strategic opportunity presented by the Cambourne North allocation, the policy as currently drafted fails to address severe risks of physical and social severance across the A428, omits specific employment allocations, and lacks binding requirements for true settlement integration and Garden Town governance.

Consequently, Policy S/CBN is unsound as it is not effective, not justified, and not positively prepared

Key Grounds of Objection
1. Inadequate Integration Mechanisms Across the A428
The A428 dual carriageway forms a major physical barrier. Without exceptional, landscape-led engineering interventions, Cambourne North risks becoming an isolated satellite extension rather than an integrated part of a unified town.

While Policy S/CBN references public transport and active travel crossings across the A428, it provides no concrete specification beyond aspirational terms like "high quality."

To create a genuinely unified urban fabric, policy wording must move beyond standard transit bridges. Policy S/CBN fails to mandate green, wide, landform-integrated crossings—such as wide green bridges or cut-and-fill tunnel decks incorporating commercial uses, active frontages, and landscaping (similar to successful motorway capping models like Hatfield)—that transform crossings from mere transit corridors into active, developable spaces.

2. Omission of Employment Allocations and Economic Ambition
Policy S/CBN no longer includes a specific employment specification (in terms of minimum hectarage or job density targets).

Omitting dedicated, non-residential employment targets risks creating a car-dependent commuter extension rather than a self-sustaining, balanced settlement. The policy fails to position Cambourne North as a sub-regional employment and high-level facilities hub that can reduce the need for out-commuting towards Cambridge.

3. Unenforceable Framework for "Place Book" and Masterplanning
While CPPF welcomes the requirement for a site-wide "Place Book" to precede the Masterplan and Design Codes, the policy fails to mandate that the Place Book explicitly evaluate and deliver spatial and functional integration with existing Cambourne, rather than focusing internally on Cambourne North alone.

The policy fails to formally anchor the Place Book and Masterplan in TCPA Garden Town Principles. Crucially, it lacks binding policy requirements securing long-term community land stewardship, land value capture for public benefit, strong visionary governance, and high-quality civic infrastructure.

1. Re-test Viability & Re-evaluate Transport:
• Commission a realistic Viability Appraisal reflecting actual IDP, SEND, inflation, and utility costs.
• Test the feasibility and viability of Policy S/GF without CSET2.
• Test the feasibility and viability of Policy S/GF with localised bus priority and traffic management within the existing A1307 highway land and via the proposed southern gateway to the Cambridge Biomedical Campus.
• Amend Paragraph 23.c.v to explicitly include bus services and to Whittlesford Parkway station and key A11/A505 employment hubs, with any necessary infrastructure to prioritise buses on the A505.

2. Resolve Water Infrastructure Prerequisites:
• Provide robust evidence verifying water supply deliverability before allocating the site, and apply water availability restrictions consistently across both residential and employment development.

3. Mandate Strict Landscape & Height Controls:
• Amend policy text to restrict all development to low-rise built form across the elevated site topography.
• Mandate heavy landscape screening and substantial native tree planting to soften built profiles against the skyline.
• Insert policy wording stating that all ancillary infrastructure (including the A11 bridge) must satisfy strict Green Belt, landscape, heritage, and ecological protection criteria.

4. Mitigate Recreational Impact on Gog Magog Hills:
• Amend Paragraphs 21a.v and 29 to explicitly include Wandlebury Country Park, Magog Down, the Roman Road, and adjacent SSSIs within required recreational pressure mitigation strategies, regardless of the 2km distance threshold.

The policy fails to satisfy the tests of soundness. Specifically, the policy is:

1. Not Justified: The allocation relies on unevidenced incomplete viability assumptions, an unconsented and unfunded public transport scheme (CSET2), and a fundamental contradiction regarding water availability in an area actively undergoing water abstraction curtailment to protect local chalk streams.

2. Not Effective: The policy lacks enforceable mechanisms to prevent visually intrusive tall buildings on elevated topography, fails to secure necessary funding and mitigation for severe recreational pressures on nearby heritage and ecological sites, and relies on active travel connections hampered by severe land ownership barriers.

3. Inconsistent with National Policy: The policy fails to protect sensitive landscape settings, designated sites (SSSIs), and local chalk stream habitats, and fails to demonstrate deliverability over the plan period in accordance with national policy.


1. Fundamental Financial Unviability & Infrastructure Funding Gap
The Viability Appraisal supporting Policy S/GF significantly undercounts essential infrastructure obligations.

The Viability Appraisal assumes uniform per-dwelling developer contributions that, for this site, total £198.7m (£14.4m CIL + £184.3m S106). However, costed items in the site-specific Infrastructure Delivery Plan (IDP) total £252.6m, or £53.9m more. Once other critical uncosted items, primary substation upgrades, wastewater treatment upgrades, mobility hubs, parking barns, and local active travel connections, the difference will be even greater.

The education costs also appear to have been significantly underestimated compared with the guide costs in the Cambridgeshire County Council’s official guidance (which are in 2016 prices). SEND provision and inflation potentially adds £35m to the education costs.
Once all planning obligations are accounted for, the total bill is likely to be well over £100 million higher than the figure used in the Council’s viability calculations.

This would translate to S106 contributions increasing from £45,500 to over £71,000 per dwelling. According to the viability sensitivity test on page 644, if the S106 contributions reaches £80,000 per dwelling, the Net Land Value (Residual minus Benchmark) would turn negative It is therefore imperative that the viability assessment is re-run with a complete and accurate set of planning obligations.


The IDP relies on the Greater Cambridge Partnership (GCP) to part-fund the CSET2 extension, despite GCP lacking secured funding for the core CSET scheme. Homes England funding is currently structured as a recoverable loan with no identified repayment mechanism. Though it is not proposed, if Grange Farm were to absorb the full cost of CSET2 (in addition to the A11 bridge) at an estimated cost of £161m in Q4 2022 prices or £177m in Q3 2026 prices, the approximate additional S106 obligations would be £40,000 per dwelling plus £300/sq. m of commercial space.

2. Unsound Transport Strategy & Reliance on Unconsented Schemes
CSET2 is critical to the policy's transport strategy, yet it lacks transport order consent and secured funding, rendering the policy's transport framework delivery mechanism unsound.

The policy should provide bus links to destinations along the A11 and A505 because, even with good cycling infrastructure in place, the distances and terrain will not be attractive to most people. For people travelling towards London, a bus connection to Whittlesford Parkway would be more convenient, quicker and cheaper than travelling by bus to Cambridge South station. 23.c.v. should include Whittlesford Parkway.

3. Water Stress, Deliverability & Environmental Contradiction
Local boreholes are actively being shut down to protect the flow of the River Granta (a rare chalk stream habitat). Allocating 4,500+ homes in an area where abstraction is actively being curtailed represents a direct environmental contradiction.

Policy S/GF makes the delivery of 4,500 homes explicitly conditional on "the necessary water infrastructure being available" (Paragraphs 1 and 11a). This creates acute uncertainty over when—or even if—the residential element of the allocation can be delivered. By contrast, the policy imposes no equivalent water infrastructure restrictions on the site's commercial development. A policy that hinges site deliverability on an unresolved, uncoordinated external prerequisite without clear trajectory triggers is fundamentally ineffective and fails to demonstrate a deliverable housing trajectory over the plan period.

4. Landscape Impact, Elevated Topography & Built Form
The topography of the Grange Farm site is particularly sensitive, as the land rises relatively sharply from the A1307. We object to the lack of clarity regarding the proposed density and the potential for tall buildings on this elevated ground (for example the inclusion of a last mile distribution centre and taller buildings in the town centre). To avoid a detrimental impact on the wider landscape and the setting of the city, it is essential that any development remains low-rise. Current wording in Paragraphs 12a and 13b is overly generic and fails to protect this sensitive rural skyline.

The proposed A11 bus/active travel bridge sits in a sensitive Green Belt setting near Babraham Village. The policy fails to explicitly clarify that ancillary infrastructure is subject to the same landscape, heritage, and ecological requirements as the main site.

5. Recreational Pressures on the Gog Magog Hills
The impact of 9,000+ new residents on existing local infrastructure is a primary concern. While the policy may include the provision of new open space, such assets take considerable time to mature and become functional for the public and are less attractive than established places nearby. In both the interim and long-term, this development will inevitably place significant pressure on nearby wildlife and heritage sites such as Wandlebury Country Park, where the car park is already operating at capacity during weekends, Magog Down and the Roman Road.

The Policy (Paragraphs 21a.v and 29) fails to acknowledge these assets due to a rigid 2km radius threshold.

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.

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.