We question the approach taken to the distribution of growth within Greater Cambridge, and whether it will meet the objectively assessed housing need. We do not consider this to be the case, predominantly due to the uncertainty surrounding delivery of several of the proposed site allocations. We question how 1,950 homes within the new settlement at Cambourne could be included within the supply, given no specific site has been identified for allocation, and that delivery within this region is wholly dependent upon the East West Rail route and proposed Station at Cambourne, the route and location of which are as yet unconfirmed, as is the anticipated delivery date.

Paragraph 4.26 of the Sustainability Appraisal (SA) quotes the commentary of the Housing Delivery Study (2021), which highlights a risk of relying on delivery from North East Cambridge and Cambridge Airport towards the end of the Plan period, given the uncertainties relating to the relocation of the wastewater treatment works and the relocation of Marshall’s operations respectively. Whilst the Plan provides confirmation as to the likelihood of the site being available from 2030, it is anticipated that the site will be capable of delivering 2,850 dwellings by 2041. We question what evidence exists to support such an ambitious assumption, particularly in light of the conclusions within the Housing Delivery Study (2021) that a traditional market-led approach would be unlikely to exceed an average of 300dpa over the duration of the build-out period. Furthermore, the Study also notes that delivery increases over time to a ‘peak’ in the middle before decelerating. As such, even with an optimistic assumption of completions within 2030, a minimum annual delivery rate of 259 dwellings would be required, including at year 1, which is not realistic.

Whilst we do not dispute the proposed allocation at Cambridge Airport, we do not consider there is sufficient evidence to support the delivery of 2,850 dwellings within the Plan period. As such, the Plan should identify additional sites for allocation to ensure the Plan is capable of meeting the objectively assessed housing need, and to ensure there is sufficient flexibility within the supply should any sites not deliver as expected.

The proposed strategy includes a heavy reliance upon large, strategic sites. The table on pages 77 and 78 of the Development Strategy Topic Paper calculates that the number of additional homes to be identified through the Plan, in addition to existing commitments, is 11,642. The additional sources of supply identified through the Plan include accelerated delivery rates at existing strategic sites, as well as a number of additional large sites. Of the total additional sources of supply identified, which we note is marginally below the identified requirement, 396 homes of the total 11,596 are on small-medium sites, equating to 3.4% of the total supply. Paragraph 68 of the NPPF requires planning policies to identify a sufficient supply and mix of sites, including specific, deliverable sites for years 1-5 of the Plan period and specific, developable sites or broad locations for growth for years 6-10 and where possible, years 11-15 of the Plan. We consider the strategy is focussed on delivery within the latter part of the Plan period, with insufficient small and medium sites allocated to ensure the housing need is met during the short-medium term. Paragraph 69 of the NPPF confirms the important contribution that small and medium sites can make to meeting the housing requirement of an area.

As set out in our comments on the Sustainability Appraisal (SA), Option 5 – dispersal – villages was subject to a number of broad assumptions which we consider resulted in an overly negative score and unduly influenced the limited distribution of growth to village locations. Our concerns are set out in full in our comments on the SA.