Greater Cambridge Local Plan: Proposed Submission

We have provided some high-level comments below in relation to landscape across several policies proposed within the Greater Cambridge Local Plan which we hope will be useful. To ensure consistency and robustness across the Local Plan, consideration should be given to incorporating landscape mitigation requirements within Policies J/NE, J/RE, J/VA, H/DC and H/GT where development may affect the Green Belt or wider countryside. In particular, policies should require landscaping measures that mitigate adverse landscape and visual effects whilst reflecting and respecting local landscape character. This would help ensure that development proposals contribute positively to the landscape and maintain the distinctive qualities of the surrounding environment.

We have provided some high-level comments below in relation to landscape across several policies proposed within the Greater Cambridge Local Plan which we hope will be useful.

To ensure consistency and robustness across the Local Plan, consideration should be given to incorporating landscape mitigation requirements within Policies J/NE, J/RE, J/VA, H/DC and H/GT where development may affect the Green Belt or wider countryside. In particular, policies should require landscaping measures that mitigate adverse landscape and visual effects whilst reflecting and respecting local landscape character. This would help ensure that development proposals contribute positively to the landscape and maintain the distinctive qualities of the surrounding environment.

Central Bedfordshire Council considers that criterion (d) of policy S/AMC/GT: Optimisation of Gypsy and Traveller Sites could benefit from stronger emphasis on landscape mitigation and local character. Whilst the current wording refers to improving the appearance and quality of the environment and minimising visual intrusion, it does not explicitly require landscaping to respond positively to local landscape character.

To provide greater clarity regarding expectations for site design and integration within the surrounding environment, it is suggested that the policy is amended to require landscaping that mitigates adverse landscape and visual effects whilst reflecting and respecting local landscape character.

A logical place to involve neighbouring authorities would be to include them on the list of consultees under section 39 of the policy, to aid collaboration on the strategic and local transport mitigation plan. CBC would suggest the additional wording to part 39 of Policy S/CBN Camborne North:
39. To support delivery of the agreed masterplan, a strategic and local transport mitigation plan, supported by other studies as necessary, must be prepared by the developer in collaboration with local transport partners, East West Rail Company, and National Highways and neighbouring Local Authorities, for agreement with the Local Highways Authority and Local Planning Authority.

As documented in our response to the Regulation 18 plan, our main comments relate to the potential cross boundary impact cumulatively of the retained polices for Cambourne (S/CB) and Bourne Airfield (S/BN), alongside the new allocation at Cambourne North detailed under policy
(S/CBN).

Whilst we support in principle the approach to allocated growth being heavily informed and supported by the location of existing and committed public transport schemes, the vision led approach to transport planning and associated approach to mitigation, we expect there to be impact from these sites from longer distance, car based trips, with particular concern being the volume and distribution of these trips towards cross boundary routes such as the A428 (for the A1) and more rural routes towards Potton and Sandy.

Policy S/CBN Camborne North
Whilst it is recognised that only 2,550 of the 13,000 new homes proposed at Cambourne North will come forward within the plan period, it is essential that the existing and future growth, and the implications on the wider area, are taken into consideration, with any required mitigation
identified and planned for from the outset.

We have previously raised concern about the expected traffic flows on routes towards the CBC boundary in the context of our own committed growth and known capacity constraints on the A1 at Biggleswade and Sandy, and have requested additional information on traffic flows to
allow us to take a more informed position on the likely impact of this large allocation within Central Bedfordshire.

Whilst appreciating this has no formal status in modelling terms for inclusion in a core scenario, we expressed the above concern and request for more information, also in the context of emerging proposals for Tempsford New Town, which will create further demands on the highway network in the area.

The submitted SoCGs identify CBC’s request at Regulation 18 stage: ‘Central Bedfordshire Council, similarly, sought a greater understanding of work undertaken to date to identify impacts of the proposed Cambourne North allocation on the local and
strategic road network outside of the Greater Cambridge area, and the mitigation identified to combat these impacts. Their representations noted that however, it is considered there an inevitable impact of the proposed allocation on the A1 corridor and local road network within
Central Bedfordshire, which does not appear to be reflected within the impact assessment or Infrastructure Delivery Plan (IDP).’

Having reviewed the documentation submitted in support of this allocation (namely the Cambourne North Addendum Transport Strategy Report) there is no clear representation of the expected flows on our sensitive routes within Central Bedfordshire, that has been expanded upon for us to review and comment on.

We note that the report states that Increased traffic flows and delays are primarily concentrated on the internal development network and key nearby junctions, with limited additional impact on the surrounding local highway network. It would be helpful if evidence of this ‘limited
additional impact’ was provided to inform our position.
Whilst there is clear refinement to the modelling to identify impacts and mitigation in proximity to the site, the information presented to date, in our view does not yet satisfy the commitment
made in the SoCG:
‘11.16 There is agreement between the Councils, Bedford Borough Council, Central Bedfordshire and Huntingdonshire District Council of the potential for substantive cross-boundary transport impacts as a result of Cambourne North. To manage this and address this potential impacts, neighbouring authorities (Huntingdonshire, Central Bedfordshire and Bedford Borough), Cambridgeshire County Council and National Highways have been invited to take part in ongoing
workshops / meetings with the Councils’ consultants around the transport modelling and strategy work, prepared by the Councils to support the allocation and demonstrate that transport impacts can be mitigated. Input has been sought on both the approach and the
outputs produced at various stages. Refinement of this work will take place ahead of the submission of the Local Plan, involving the aforementioned parties, to ensure this (wherever possible, based on the information available) reflects anticipated impacts at the strategic scale
and how these could be mitigated.’

The IDP does not make any reference to the potential for cross boundary mitigation to be considered as plans emerge, and the policy wording of S/CBN as proposed does not offer a commitment to delivering further, cross boundary infrastructure if identified, for example if the
trip budget is breached, which could make this more difficult to secure at planning application stage.

A logical place to involve neighbouring authorities would be to include them on the list of consultees under section 39 of the policy, to aid collaboration on the strategic and local transport mitigation plan. CBC would suggest the additional wording to part 39 of Policy S/CBN Camborne North:

39. To support delivery of the agreed masterplan, a strategic and local transport mitigation plan, supported by other studies as necessary, must be prepared by the developer in collaboration with local transport partners, East West Rail Company, and National Highways
and neighbouring Local Authorities, for agreement with the Local Highways Authority and Local Planning Authority.

We welcome the ongoing involvement in the development of the scheme via the established Transport Officers Group and look forward to the continuation of this.

The Submission Local Plan identifies the need for 73,300 jobs anticipated over the plan period, of which around 35,000 are identified to be office, R&D and industrial jobs.

The EHEU converted these jobs into employment floorspace needs of almost 1,220,000sqm. The
rest of the jobs forecast are in services and support uses such as shops, schools and healthcare.
The draft plan proposes to meet the jobs need through the delivery of:
• 302,600 sqm offices and 600,000 sqm of Research and Development (R&D) space; and
• 317,000 sqm of industrial / warehousing (Use Classes B2/B8).

The EHEU also recommends that to ensure a flexible employment land supply for office, R&D and industrial jobs, and encouraging growth in existing businesses and attracting inward investment, that a greater amount of employment floorspace is planned for than that associated
with identified need, taking into account the needs of different employment sectors.

We note that the requirement for 1,220,000sqm of employment land does not correspond with the proposed employment land identified through the mixed use allocations, which equate to approximately 1,860,000 sq metres. We also note that Policy S/DS: Development Strategy omits in part 2.b.iii to include the amount of employment floorspace at Eddington, which the
subsequent allocation policy sets out as 100,000sqm. Clarification is sought that this apparent over-provision of 640,000 sqm, is to accommodate the flexible employment land supply as mentioned above.

The above proposals have not deviated from those published and consulted upon in December 2025 and CBC would therefore reiterate our previous comments that whilst we recognise the desire for the Greater Cambridge area to capitalise on its strong growth sectors, and welcomes economic growth of neighbouring authority areas, particularly where there are opportunities
for complementary economic growth within our own administrative area, we would have concerns about a level of growth that could detrimentally impact upon the ability of neighbouring authorities, such as Central Bedfordshire, to meet and deliver their own economic ambitions and growth aspirations.

The Draft Plan helpfully sets out clearly how much and where new housing growth will be delivered across the Greater Cambridge area in Table 2, but as mentioned in our Regulation 18 response, there does not appear to be the equivalent level of detail for where employment
needs will be met.

No specific modification provided as this requires a calculation of a number, but would suggest for clarity that the policy clearly includes the number of market homes to be provided alongside all the other accommodation types.

We note that proposed Policy S/JH: New Jobs and Homes sets out the requirement for 48,069 new homes to meet the needs for the total population, reflecting the annual requirement for 2,289 dwellings. The policy continues to then specifically identify the number of pitches and
plots required to accommodation needs of Gypsies, Travellers and Travelling Showpeople over the period 2024-2045, as well as the specialist accommodation needs for older people and people with disabilities and the number of units to meet the accommodation needs of students over the same period but does not explicitly state how many new market and affordable homes are to be delivered within the plan period. It is unclear why the breakdown includes some, but not all forms of accommodation that is to be provided, which makes it difficult to draw any comparison through the policy, of the relationship between the number of new homes and the
number of new jobs to be provided across Greater Cambridge within the plan period.

Of the 48,069 overall number of new homes, once you take off the G&T requirement, as well as the specialist accommodation needs for older people and people with disabilities and the number of units to meet the accommodation needs of students - how many market homes are actually proposed to be delivered within the plan period.

It is suggested that criterion 1(g) is amended to state that Greater Cambridge will "undertake cooperation with other local authorities" rather than "consider undertaking cooperation".

Central Bedfordshire Council suggests that the wording of criterion 1(g) of Policy S/MO Monitoring is strengthened to ensure a clear commitment to ongoing cross-boundary
engagement. The current wording states that Greater Cambridge will "consider undertaking cooperation with other local authorities, including through duty to cooperate". Given the importance of strategic planning matters that extend beyond administrative boundaries, and
the requirement within the NPPF for effective engagement, the policy would benefit from requiring, rather than merely considering, cooperation with neighbouring authorities.

This amendment would provide greater certainty regarding the Council's commitment to collaborative working on strategic planning issues.

It is suggested that criterion 1(g) is amended to state that Greater Cambridge will "undertake cooperation with other local authorities" rather than "consider undertaking cooperation".

To better reflect the potential for environmental impacts to extend beyond local authority boundaries, criterion (d) of the policy should be amended to acknowledge adjoining authorities. The policy could also helpfully recognise that wildlife, nature conservation interests and landscape character may be affected both within Greater Cambridge and in neighbouring areas. Incorporating this wider geographical perspective would support a more comprehensive assessment of development impacts.

To better reflect the potential for environmental impacts to extend beyond local authority boundaries, criterion (d) of the policy should be amended to acknowledge adjoining authorities. The policy could also helpfully recognise that wildlife, nature conservation interests and landscape character may be affected both within Greater Cambridge and in neighbouring areas. Incorporating this wider geographical perspective would support a more comprehensive assessment of development impacts.

We generally support the vision and the seven strategic priorities for the plan, with the ultimate aim of a big increase in the quality of everyday life for all your communities. We particularly welcome the aims to meet your housing and economic needs alongside decreasing climate and environmental impacts by minimising carbon emissions and the reliance on the private car, creating thriving neighbourhoods, delivering infrastructure and green spaces; and safeguarding local heritage and landscapes.

We have provided some high-level comments below in relation to the Housing policies proposed within the Greater Cambridge Local Plan which we hope will be useful.

Whilst the policy H/AH: Affordable Housing clearly sets out affordable housing requirements, it could benefit from stronger links to Policy H/HM: Housing Mix, which contains more detailed requirements relating to dwelling size, tenure and housing mix. Without a direct reference,
users of the plan may not immediately recognise the relationship between the affordable housing requirements and the associated housing mix provisions.

Central Bedfordshire Council notes that the recently published National Planning Policy Framework has removed references to First Homes and First Homes Exception Sites. As a result, references to First Homes Exception Sites within policy H/ES: Exception Sites for Affordable Housing are no longer necessary and could be removed.

The policy could also benefit from greater clarity regarding the proportion of market housing that may be permitted on rural exception sites. Whilst it is recognised that a limited amount of market housing may be necessary to support viability, the policy could specify an upper threshold in order to maintain the primary purpose of rural exception sites as predominantly affordable housing developments.