Draft Greater Cambridge Local Plan for consultation

Comments submitted on behalf of R2 developments.

The ‘Greater Cambridge Employment and Housing Needs Updated 2024-2025 (September 2025)’ has informed the housing needs for Greater Cambridge for the period 2024-2045. These needs and the assessment, which broadly aligns with the standard methodology, result in a strategy of 2,295 new homes being delivered per annum to achieve a minimum of 48,195 new homes over the plan period. Of these new homes the Councils’ adopted Local Plans (2018) are anticipated to deliver around 37,865 homes by 2045. The additional 13,460 new homes are to be delivered through proposed allocations, heavily predicated on strategic sites, and windfalls sites. Whilst the projected figures would provide an appropriate buffer, there are concerns about the strategy that is being proposed to meet the identified needs and whether it is truly deliverable. There are also concerns about the location of new development and the fact that the majority of the new homes would be delivered by way of new settlements to the north and west of Cambridge. This strategy ignores the employment growth along the A10 corridor and the need to ensure that new homes are located near to sites where new employment opportunities are planned.

The government’s growth aspirations for Greater Cambridge are well documented with the Cambridge Growth Company (CGC) being set up to promote and accelerate growth in the area. The CGC is yet to publish any plans for how it will deliver the government’s growth aspirations and what levels of growth it is seeking to promote. It is clear that in order to deliver the growth needs for Greater Cambridge a balance is needed to ensure that delivery rates do not stall due to issues related to specific sites being delayed in their planning or build out phases. This has happened with a number of the sites identified in the 2018 Local Plans, which have failed to deliver the new homes anticipated when they were allocated. It is also clear that given the government’s aspirations for Greater Cambridge there is a strong justification for adopting a higher growth scenario than envisioned in the emerging Local Plan. This would also have an implication for the number of new homes proposed to support this growth in locations where new jobs would be created.

Whilst the proposed allocations would deliver a five-year supply of housing, there should be aspiration for a more ambitious target to meet the government’s growth targets. This can be achieved through the allocation of further sites on locations where changes to the NPPF make it inevitable that they will otherwise come forward as speculative applications.

Our client, R2 Developments, supports the principle of focussing development in the most sustainable locations and note that this is identified ‘as far as possible’ in draft Policy S/DS (Development strategy). Due to site specific issues that may presently be unknown, it may not always be possible for sites allocated for being in the most sustainable locations to come forward. Therefore, the ability to accommodate the growth needs of the Greater Cambridge area around and within Cambridge itself and at the new settlements must be treated with a degree of caution. Moreover, the geographical distribution of new homes ignores the growth in jobs that will take place along the A10 corridor. The emerging Local Plan needs to allow for greater flexibility for interim growth needs to be located on sites well-located to established travel hubs, such as at our client’s site at Foxton. Without a more balanced approach to meeting future housing needs, both in terms of interim delivery and geographical locations, there is a risk that Greater Cambridge will fail to deliver the homes it needs within the plan period. Homes that it is essential are located near to the employment sites that will support the economic growth aspirations of Greater Cambridge.

Paragraph 23 of the NPPF requires strategic policies to provide a clear strategy for bringing sufficient land forward, and at a sufficient rate, to address objectively assessed needs over the plan period. In accordance with paragraph 77 d) of the NPPF, the Councils must make a realistic assessment of likely rates of delivery and take into account the lead-in times for large scale sites. Based on uncertainties surrounding the delivery of Cambridge East and the rate at which Eddington can be delivered, our client is concerned about the rate at which new homes can come forward in the short to medium term. This therefore leads our client to question the development strategy set out in the emerging Local Plan.

The strategy for growth in the emerging Local Plan is predicated on a higher percentage of new homes being delivered through new settlements and urban extensions than was the case with previous Local Plans (44% presently proposed compared to 23% in the adopted Local Plans and 18% in the previous Structure Plan). The withdrawal of funding to relocate the CWWTP and allow North East Cambridge to come forward highlights the risks with this strategy. Whilst the Councils’ projections are not reliant on North East Cambridge, the strategy still relies on other strategic sites that have histories of failing to deliver. Given the significant number of homes to be delivered on larger sites, towards the end of the plan period, the proposed contingency should be higher to ensure that any delays in homes coming forward on larger sites do not stall growth.

Cambridge East is another site where any further development opportunities are predicated on a third party vacating the site. However, in this case the Councils are taking less of a precautionary approach. Given the well documented history of Marshalls’ attempts to relocate their aerospace operations, and the recent announcement that they will not be moving to Cranfield, the projections for further homes on Cambridge East coming forward cannot be relied upon. The development of Marleigh and the land north of Cherry Hinton (Springstead Village) represent the maximum number of homes that can be delivered whilst the airport remains operational. The determination of the outline application for Marleigh (then known as Wing) highlighted the complexities of Marshall relocating its various businesses. Importantly, the cost implications of works to facilitate the relocation of Marhsall Group businesses triggered a viability review that reduced the percentage of affordable housing and prolonged the planning process. Until plans for the development of Cambridge East align with the commercial needs of Marshalls, the company is unlikely to relocate the airport.

Whilst further development at Eddington would maximise the development potential of the site, housing delivery has lagged behind other fringe sites. Outline planning permission was granted for North West Cambridge in February 2013 for a mixed use development including 3,000 homes. By the time the period had expired for the submission of reserved matters applications for residential development, detailed plans for approximately 1,800 of these homes had been approved. Therefore, projections for increased housing delivery through the intensification of the site must be realistic and be based on empirical evidence of historic build out rates.

The significant delays in the grant of outline planning permission for Bourn Airfield demonstrates the complexities of strategic sites and the length of time they take to go through planning. The outline application was submitted in September 2018 but not approved until July 2024. Whilst this delay was not foreseen, it highlights the complexities of strategic sites in securing planning permissions. Which further highlights the need for more sites that can add to the vitality and housing needs of villages to be allocated for development to meet the interim housing needs of Greater Cambridge. Sites, such as our client’s, that do not have the complexities of strategic sites.

Of the 13,463 homes identified for the period 2024-2045 only 205 of these would be accommodated in the rural area outside the southern cluster. Given the availability of sites such as our client’s, which can be delivered without the need for major infrastructure upgrades, more flexibility needs to be provided through further allocations to mitigate delays that are inevitable with strategic sites.

In January 2026 the Office for National Statistics released the quarterly figures for the monthly construction output statistics for Great Britian. Total construction output is estimated to have fallen by 1.1% in the three months to November 2025; this is the largest fall since March 2023 (1.4% fall). This latest report highlights the precarious situation that the construction industry is in with increasing material prices and decreasing numbers of people entering the industry. This adds further weight to the argument that a greater range of development sites are needed to meet future housing needs. Rather than relying on larger sites that may face more challenges in getting the volumes of materials and staff needed to maintain projected build out rates.

Without more flexibility and a greater balance between strategic and medium sized sites, the Councils risk failing to maintain a sufficient supply of new homes in the early years of the Local Plan. That could result in the inability to defend appeals for sites in less desirable and less sustainable locations than our client’s site at Foxton.

Recommended change: part 5 of Policy S/SH needs to be amended to read “Residential development and redevelopment without any limit on individual scheme size will be permitted within the defined development extents, and on land well-related to defined development extents and within reasonable walking distance of well-connected rail stations, as defined on the Policies Map, provided that adequate services, facilities and infrastructure are available or can be made available as a result of the development.”

Submitted on behalf of R2 Developments

Focusing development only within the defined development extents of settlements is inconsistent with the proposed changes to the NPPF by way of draft Policy S5. The changes propose a more flexible approach to the location of development with weight given to sites that are well-related to existing settlements and well-connected rail stations. If the Councils were to adopt a more flexible approach to the development of sites well related to defined development extents and well-connected rail stations, it would result in greater opportunities for the 6,976 new homes identified to come through on windfall sites to be delivered.

Defined development extents do not necessarily guard against incremental growth in unsustainable locations. Indeed, new homes in demonstrably sustainable locations can be restricted from coming forward due to locations being just outside defined development extents of highly sustainable settlements. Or where they are within reasonable walking distances of established public transport routes. Such as Foxton rail station. Where any harm to the countryside can be mitigated through landscaping and design, such sites should not be restricted in coming forward if they can demonstrate sustainable development. The Councils’ approach is not consistent with the proposed changes to the NPPF, which takes a more pragmatic approach to allowing appropriate development where it is well located to existing settlements and public transport infrastructure. This is clearly the direction of travel that the government is taking to significantly boost the supply of new homes in accordance with paragraph 61 of the NPPF.

Recommended change: part 1 of Policy S/DE needs to be amended to read “Development and redevelopment of unallocated land and buildings within defined development extents, and on land well-related to the defined development extents and within reasonable walking distance of well-connected rail stations, (as shown on the Policies Map) will be permitted provided that:”

On behalf of R2 Developments.

Focusing development only within the defined development extents of settlements is inconsistent with the proposed changes to the NPPF by way of draft Policy S5. The changes propose a more flexible approach to the location of development with weight given to sites that are well-related to existing settlements and well-connected rail stations. If the Councils were to adopt a more flexible approach to the development of sites well related to defined development extents and well-connected rail stations, it would result in greater opportunities for the 6,976 new homes identified to come through on windfall sites to be delivered.

Defined development extents do not necessarily guard against incremental growth in unsustainable locations. Indeed, new homes in demonstrably sustainable locations can be restricted from coming forward due to locations being just outside defined development extents of highly sustainable settlements. Or where they are within reasonable walking distances of established public transport routes. Such as Foxton rail station. Where any harm to the countryside can be mitigated through landscaping and design, such sites should not be restricted in coming forward if they can demonstrate sustainable development. The Councils’ approach is not consistent with the proposed changes to the NPPF, which takes a more pragmatic approach to allowing appropriate development where it is well located to existing settlements and public transport infrastructure. This is clearly the direction of travel that the government is taking to significantly boost the supply of new homes in accordance with paragraph 61 of the NPPF.

On behalf of R2 Developments.

The government’s initial reforms of the NPPF in December 2024 included a modernisation of the way the green belt works. This included the consideration of development being permitted on low-quality green belt land that is identified as ‘grey belt’. An initial assessment of our client’s site at Foxton indicates that it is likely to be classed as grey belt, as it performs poorly against the purposes of green belt in the NPPF.

Given the importance of grey belt land in the government achieving its aim of significantly boosting the supply of new homes, greater flexibility is needed for more homes to come forward on sites that are well related to well-connected rail stations. Our client’s site meets these criteria, as well as having excellent cycle connectivity with existing and proposed employment sites along the A10 corridor and at Cambridge.

In light of the significant changes to national policy with regards to development within the green belt, there is the need for the Councils to undertake a thorough green belt review as part of the Local Plan process. This is essential to ensure that the development strategy for Greater Cambridge is based on a sound assessment of the strategy allocating more sites nearer to Cambridge and new jobs. It is inconceivable that the development strategy for an area so tightly constrained by green belt is not supported by an up to date review of the green belt, and the contributions that land parcels within it make to its purposes.

Whilst Policy S/GB follows the themes of the NPPF there is one clear area of divergence. That is in criterion c), which seeks to “prevent communities in the environs of Cambridge from merging into one another and with the city”. Criterion b) of paragraph 143 of the NPPF relates to preventing neighbouring ‘towns’ merging into one another. As the environs surrounding Cambridge are villages, draft Policy S/GB needs to be consistent with the NPPF.

Recommended change: criterion c), of Policy S/GB needs to be amended to read “prevent communities in the environs of Cambridge from merging with the city.”

Further recommendation: That a comprehensive review of the green belt be carried out to identify further sites for development in sustainable locations that can be delivered without harm to the purposes of land being designated as green belt.

Comments submitted on behalf of R2 developments.

The ‘Greater Cambridge Employment and Housing Needs Updated 2024-2025 (September 2025)’ has informed the housing needs for Greater Cambridge for the period 2024-2045. These needs and the assessment, which broadly aligns with the standard methodology, result in a strategy of 2,295 new homes being delivered per annum to achieve a minimum of 48,195 new homes over the plan period. Of these new homes the Councils’ adopted Local Plans (2018) are anticipated to deliver around 37,865 homes by 2045. The additional 13,460 new homes are to be delivered through proposed allocations, heavily predicated on strategic sites, and windfalls sites. Whilst the projected figures would provide an appropriate buffer, there are concerns about the strategy that is being proposed to meet the identified needs and whether it is truly deliverable. There are also concerns about the location of new development and the fact that the majority of the new homes would be delivered by way of new settlements to the north and west of Cambridge. This strategy ignores the employment growth along the A10 corridor and the need to ensure that new homes are located near to sites where new employment opportunities are planned.

The government’s growth aspirations for Greater Cambridge are well documented with the Cambridge Growth Company (CGC) being set up to promote and accelerate growth in the area. The CGC is yet to publish any plans for how it will deliver the government’s growth aspirations and what levels of growth it is seeking to promote. It is clear that in order to deliver the growth needs for Greater Cambridge a balance is needed to ensure that delivery rates do not stall due to issues related to specific sites being delayed in their planning or build out phases. This has happened with a number of the sites identified in the 2018 Local Plans, which have failed to deliver the new homes anticipated when they were allocated. It is also clear that given the government’s aspirations for Greater Cambridge there is a strong justification for adopting a higher growth scenario than envisioned in the emerging Local Plan. This would also have an implication for the number of new homes proposed to support this growth in locations where new jobs would be created.

Whilst the proposed allocations would deliver a five-year supply of housing, there should be aspiration for a more ambitious target to meet the government’s growth targets. This can be achieved through the allocation of further sites on locations where changes to the NPPF make it inevitable that they will otherwise come forward as speculative applications.