(or ‘you can’t discharge your own statutory duty by outsourcing it to someone else’s unpublished document’)..
Executive Summary
Greater Cambridge is consulting on its new Local Plan, which includes major housing development north of Cambourne linked to the proposed East West Rail connection to Cambridge. Close to the proposed development is Eversden and Wimpole Woods, an internationally protected nature site containing a rare Barbastelle bat maternity colony. We argue that Greater Cambridge has not properly assessed the combined impact of the proposed housing development and East West Rail on this protected site. While a revised environmental assessment now mentions East West Rail, it still does not properly assess the two projects taken together.
This matters because the Local Plan depends, in part, on East West Rail going ahead, yet the railway’s own detailed environmental assessment has not yet established that it will not harm the protected site. Our argument is therefore that Greater Cambridge cannot simply leave the railway’s impact to be assessed later: the combined effects should be considered now, before the Local Plan is approved. If the assessment is inadequate, this could affect whether the Local Plan is considered legally sound by the government-appointed Planning Inspector.
Residents are being encouraged to raise this issue in the current Local Plan consultation, which provides an opportunity to challenge the plan before it moves to the next stage.
How to raise the issue:
• Go to https://consultations.greatercambridgeplanning.org/proposed-submission-greater-cambridge-local-plan/habitats-regulations-assessment
• You will need to create an account to comment if you don’t have one already.
• The first question is about whether you think the plan is legally compliant and sound – yes or no.
• The next question asks for comment and how the Plan should be changed. The blog post provides background information arguing that the Local Plan should include the Appropriate Assessment relating to East West Rail, which it does not. It is therefore, in our view, not legally compliant, and should not proceed to approval without this crucial information.
Background
- Greater Cambridge Shared Planning (GCSP) are currently running their Proposed Submission Local Plan (Local Plan) consultation which ends at 5pm on 25 September 2026.[1] This consultation is different from earlier ones. All comments received will be submitted to government alongside the Local Plan for independent examination. A Planning Inspector, appointed by government, will consider them as part of the approval process. The plan must be submitted by the end of 2026 to be examined under the current system before a new plan-making framework comes into force.[2] The plan includes housing development requirements north of Cambourne which are predicated on the approval of East West Rail’s proposed connection to Cambridge, and this is stated in several ways in their current consultation.[3] The consultation guidance states: ‘Your comments should focus on whether the Local Plan complies with relevant legislation’. Well, I am sorry, but it doesn’t and here’s why.
The Problem
- The Eversden and Wimpole Woods Special Area of Conservation (E&WW SAC) is designated for its maternity roost of the rare Barbastelle Bat. The site and its functionally linked land are protected by the Habitats and Species Regulations 2017 (H&SR) and is a ‘European site’ for those purposes.[4] Regulation 105(1) of the H&SR reads as follows (emphasis added): ‘Where a land use plan— (a) is likely to have a significant effect on a European site … (either alone or in combination with other plans or projects), … the plan-making authority for that plan must, before the plan is given effect, make an appropriate assessment of the implications for the site in view of that site’s conservation objectives.’
- The relevant standards for such appropriate assessments (AAs) are defined in H&SR Regulation 105(4) of the same legislation as follows: ‘In the light of the conclusions of the assessment… the plan-making authority must give effect to the land use plan only after having ascertained that it will not adversely affect the integrity of the European site …’.[5]
- In order to meet their obligation under H&SR §105, GCSP circulated a draft Habitats Regulations Assessment (HRA) for consultation in January 2026. But it made no reference to the effects of EWR on this European Site. Several responses to their January consultation pointed out their obligation to address this.[6] An updated version of their HRA has been published and is being consulted on alongside the Proposed Submission Local Plan. It now names EWR several times, but the Appropriate Assessment itself – the part of the document that actually reaches conclusions – still does not address the in-combination issue at all. See below.[7]
- ‘In combination’ in the context of this Local Plan means the effect of all land use including housing and the effect of the railway together on the E&WW SAC (Figure 1). It should also include other known projects that contribute to the cumulative effect on the E&WW SAC.
- EWRCo have a separate obligation to demonstrate no adverse effect on the integrity of the E&WW SAC and, despite working on it for six years, have yet to publish their own AA. At this stage there is reasonable scientific doubt that they will be able to demonstrate no adverse effect on the E&WW SAC (to put it mildly). See here.[8]
- The fact that EWRCo have not yet published an AA and are not due to do so for some time is a problem for GCSP and the Local Plan. However, it is not a problem they can ignore. GCSP can’t discharge its statutory duty under the H&SR by reference to an unpublished future document. It needs to make its own assessment now of the in-combination effects.
Some Specific Comments on the Revised HRA
- The above interpretation of a fundamental flaw in the Local Plan draws on the following key numbered statements in the GCSP’s Revised HRA accompanying the Proposed Submission Local Plan.[9] Para. F.11 of its Appendix F summarizes the comments from Cambridge Approaches and other respondents to their January Local Plan Consultation. The respondents flag the need to consider in-combination effects with EWR. Para. F.13 is the GCSP response which says that the Local Plan alone is enough to trigger an AA. Then (encouragingly) it points to para. 4.16 in the screening chapter: ‘The likely significant effect, if it occurs, would be significant due to the Local Plan alone (although there could be additional impacts in-combination, for example with East-West Rail…. Therefore, this effect is considered further at the Appropriate Assessment stage to determine the potential impacts of these site allocations in relation to offsite functional habitat damage or loss, and whether mitigation measures are required.’
- The AA for the E&WW SAC is in §§ 5.11-5.23 of the updated HRA and it makes no mention of the in combination effects with EWR.
- This is a misreading of H&SR §105 and goes to the soundness of the Local Plan. The trigger for the AA is either alone or in combination, but the scope of the AA is ‘the implications for the site in view of that site’s conservation objectives’. The scope of the AA is therefore the effects of The Plan taken together with the in-combination effects of other plans or projects and not just the effects of The Plan itself, even if the housing alone in The Plan is likely to have a significant effect. The E&WW SAC does not ‘know’ (or care) about the internal structure of all the plans and projects, it just gets their cumulative impact. There is plenty of case law and common sense to support this interpretation.
Call To Action
- Please respond to the Local Plan pointing out this error and the potentially disastrous impact on our only local European Site – the E&WW SAC. You can do so here.[10]

Figure 1 Illustration of In Combination Effects
[1] https://consultations.greatercambridgeplanning.org/proposed-submission-greater-cambridge-local-plan
[2] https://www.greatercambridgeplanning.org/media/ck4laej4/greater-cambridge-local-development-scheme-local-plan-timetable.pdf
[3] https://consultations.greatercambridgeplanning.org/proposed-submission-greater-cambridge-local-plan
[4] https://www.legislation.gov.uk/uksi/2017/1012/regulation/105
[5] https://www.legislation.gov.uk/uksi/2017/1012/regulation/105
[6] https://www.greatercambridgeplanning.org/media/3zdjqdus/habitats-regulations-assessment-of-greater-cambridge-local-plan.pdf Appendix F11 (around p.223 of the PDF)
[7] https://www.greatercambridgeplanning.org/media/3zdjqdus/habitats-regulations-assessment-of-greater-cambridge-local-plan.pdf – see paragraph 4.16 (around p.43) and the Appropriate Assessment for Eversden and Wimpole Woods SAC at paragraphs 5.11–5.23 (around pp.84–88)
[8] https://cambridgeapproaches.org/wp-content/uploads/2026/06/Cambridge-Approaches-Consultation-2026-Response-Bourn-Airfield-To-Harston-Environmental-Issues-3-of-7.pdf
[9] https://www.greatercambridgeplanning.org/media/3zdjqdus/habitats-regulations-assessment-of-greater-cambridge-local-plan.pdf
[10] https://consultations.greatercambridgeplanning.org/proposed-submission-greater-cambridge-local-plan/habitats-regulations-assessment








