Draft Greater Cambridge Local Plan for consultation

The higher growth scenario as acknowledged in the Employment and Housing Needs Update should be used in policy revisions. It is requested that the Plan allocates additional sites in Greater Cambridge to directly respond to the higher growth potential and to increase the diversity of allocated sites to optimise delivery and growth potential. Land to the south of Rectory Farm, Harston (HEELA 2025 site ID: 115184) can soundly assist in realising a greater and more appropriate level of growth in a sustainable way.

Jesus College object to Policy S/JH.

Policy S/JH sets out the level of objectively assessed needs in Greater Cambridge over the period 2024-2045 for jobs and homes. It states that 73,300 additional jobs and a minimum of 48,195 new homes are required to meet the needs for the total population.

The provision of 73,300 additional jobs and 48,195 new homes across the plan period should be regarded as the very minimum rather than a maximum or constraining target. Supporting evidence to the policy titled the ‘Greater Cambridge Employment and Housing Needs Update 2024-2045’ (September 2025) (EHN), states at 3.55 that the various scenarios modelled indicate a need of between 67,600 and 90,900 additional jobs over the plan period. This compares to between 66,600 and 75,800 additional jobs modelled under the previous 2023 results. This significant increase in the upper end of the modelling indicates that economic growth expectations have strengthened exponentially, not diminished.

As set out in the EHN, during the strongest phase of growth (2010–2020), the Greater Cambridge economy expanded by almost 4,000 jobs per year. The conclusion of the EHN is then based on the ‘Central growth’ scenario of 73,200 jobs across the plan period, representing sustained annual growth of around 3,500 jobs. Crucially, the Central growth scenario builds in assumptions of slower periods, contractions, and economic shocks, and is therefore inherently conservative rather than reflective of the full growth capacity of the Cambridge economy. It is also worth noting, at paragraph 3.62 of the EHN, it is acknowledged that the ‘high’ scenarios could be achieved or exceeded if there is a step change in infrastructure investment.

Greater Cambridge is one such location where there has indeed been a step change in infrastructure investment which heightens the urgency in increasing job creation and housing supply and justifies adopting a higher growth scenario. On 23rd August 2024, Matthew Pennycook reaffirmed the Government’s commitment to Cambridge stating; “The economic growth of Cambridge has been a phenomenal success and we should seek to maximise the potential contribution that Greater Cambridge could make to the UK economy.” Pennycook goes on to say; “Greater Cambridge has a vital role to play in this Government’s mission to kickstart economic growth.” Furthermore, the Cambridge Growth Company was established in 2024 to address barriers to growth and help unlock Greater Cambridge’s full potential. In terms of approach, in October 2025, the Government announced its intention to consult on the case for a centrally led Development Corporation as one potential route for delivery (backed by £400m funding). This is to be the subject of statutory consultation in 2026. It is anticipated that Cambridge Growth Company (CGC) will publish its own evidence base ahead of the formation of the Development Corporation, which whilst yet unknown it is expected that an ambitious growth target will be identified; likely to exceed that currently envisioned by the Councils for the Greater Cambridge Local Plan.

Furthermore, Greater Cambridgeshire has been, and continues to be, the location of strategic infrastructure investment that will continue to drive upwards increases in the need for new jobs and homes. This includes the proposed East West rail station as well as the proposed public transport improvements for the Cambourne to Cambridge corridor and the Cambridge Eastern Access corridor. The Cambridgeshire and Peterborough Local Growth Plan 2025 also identify priority growth sectors, and the need for further skills development.

The Employment and Housing Needs Update acknowledges a ‘High’ and ‘High Sensitivity’ scenario, whereby growth would meet or exceed the 2010–2020 trajectory. This high level of growth is feasible in Cambridge and would support the Government’s direction of travel. It is therefore important to recognise that higher-growth outcomes remain credible and should not be ruled out by policy. This requires revision to the proposed policy wording.

For these reasons, the Local Plan should consider utilising a more optimistic and realistic figure for job and housing numbers and include explicit support for higher-growth scenarios. Without these changes, Policy S/JH risks being unsound and inconsistent with national policy objectives to support sustainable economic growth and productivity.

It is requested that the Plan allocates additional sites in Greater Cambridge to directly respond to the higher growth potential and to increase the diversity of allocated sites to optimise delivery and growth potential. Land to the south of Rectory Farm, Harston (HEELA 2025 Site ID: 115184) can soundly assist in realising a greater and more appropriate level of growth in a sustainable way.

Therefore there is the need for the allocation of small and medium-sized sites and sites in rural locations in the early years post-adoption of the Plan to ensure flexibility and maintain an up-to-date housing supply including provision for affordable housing needs. Land to the south of Rectory Farm, Harston (HEELA 2025 site ID: 115184) can soundly assist in realising a greater and more appropriate level of growth in a sustainable way.

Jesus College object to Policy S/DS.

Policy S/DS sets out the proposed strategy for the pattern, scale and design quality of places created in Greater Cambridge and sets out where the homes and jobs identified in Policy S/JH should be provided to meet the vision and strategic priorities of the Plan.

Firstly, as referred to in representations to Policy S/JH, the identified needs in the Plan are considered too conservative and do not reflect the growth agenda in national, regional and local contexts mandated by the incumbent Labour Government. In line with the Written Ministerial Statement made by Matthew Pennycook (Minister of State for Housing and Planning) on 23 October 2025 the ambition remains to ‘supercharge growth’ within the Oxford-Cambridge Corridor and realise the full potential of Greater Cambridge. Further it is anticipated that the Cambridge Growth Company (CGC) will publish its own evidence base ahead of the formation of a centrally-led Development Corporation (backed by £400m funding announced in October 2025), which, whilst yet unknown, it is expected that an ambitious growth target will be identified; likely to exceed that currently envisioned by the Councils. Collectively it remains apparent therefore that the Government have a continued agenda to deliver high levels of growth within Greater Cambridge and as such more optimistic and realistic figures for job and housing numbers are needed to support sustainable economic growth and productivity.

Secondly, the supporting text to Policy S/DS states, at paragraph 2.64, that ‘drawing on our evidence and consultation feedback, we do not consider that our development needs alone provide the ‘exceptional circumstances’ required in national policy to justify removing land from the Green Belt in this Local Plan, having regard to the identification of other sources of land supply that can meet needs sustainably without the need for Green Belt release’. Paragraph 146 of the NPPF (2024) identifies that one of the exceptional circumstances in which Green Belt boundaries can be altered is where an authority cannot meet its identified need for homes, commercial or other development through other means. Therefore whilst the Councils, drawing on their current evidence base, do not consider that their development needs alone provide the exceptional circumstances required to justify removing land from the Green Belt, the further evidence referred to above may well change the context within which the Councils need to consider the Plan and the potential release of Green Belt land.

Thirdly, whilst in principle a strategy of seeking to deliver a large number of new jobs and homes at scale within the Plan is supported, an over reliance on too few strategic sites, particularly those that require significant, costly infrastructure to unlock and deliver them, is not supported. Indeed, it is considered that Policy S/DS sets out such a strategy and relies too heavily on allocating significant levels of growth on just a small number of very large sites. A number of these large sites rely on the timely provision of strategic scale infrastructure which must be in place before they can be constructed. For example, the Cambourne North new settlement (13,000 dwellings and 108,000 sqm employment floorspace) relies upon a new railway station and complicated works to the A428, and Land adjacent to A11 and A1307 at Grange Farm (6,000 dwellings and 35,000 sqm employment floorspace) relying on works to the A505. The draft Plan requires the two sites to deliver 5,100 dwellings between them by 2045. We believe this is highly unlikely.

In particular, the lack of housing allocations in the villages fails to support the delivery of homes to meet the local housing needs of the next generation during the plan period. Instead of being able to live locally, this forces newly forming households to relocate to the main settlements, new settlements, or elsewhere – often away from their existing family, community and support network. This leads to an increased need for travel within Greater Cambridge, often via private cars rather than public transport. It also results in population imbalance, with ageing populations in villages and a falling roll in primary schools – whilst the new settlements have predominantly young populations and significant pressure on services.

A combination of approaches to the distribution of spatial growth are considered likely to be necessary in order to allow for sufficient flexibility when considering the locations and scale of new housing and employment development in the Greater Cambridge area. This is necessary to ensure that the Local Plan supports sustainable communities and sustainable patterns of growth. In addition to providing housing to support new jobs in Cambridge and the key employment growth sectors, the development strategy should take account of the needs and vitality of existing villages and the wider rural economy and make planned provision for them.

In many villages, there is a lack of brownfield land available within the ‘defined development extents’ to facilitate housing delivery in accordance with the approach set out in Draft Policy S/SH (Settlement hierarchy). Also, small windfall sites provide limited affordable housing to meet local needs. Hence, there should be specific land allocations for housing development in some of the rural villages, to promote genuinely sustainable growth and development – supporting the rural economy, promoting mixed and inclusive communities and ensuring the vitality and viability of local services. Additional small and medium sized sites coming forward in the first five years post adoption of the Plan would also provide the necessary flexibility and breadth of supply in the early stages of the plan period and ensure the Plan remains up to date. This is particularly important in light of the fact that the housing land supply across the plan period does not exceed 5.5 years.

It is requested that the Plan allocates additional sites in Greater Cambridge to directly respond to the higher growth potential and to increase the diversity of allocated sites to optimise delivery and growth potential. Land to the south of Rectory Farm, Harston can soundly assist in realising a greater and more appropriate level of growth in a sustainable way.

Windfall development that comes forward within villages should be considered on the basis of the site and its context rather than be limited by an indicative maximum scheme size.

Jesus College object to Policy S/SH.

The indicative maximum scheme sizes are not considered to be necessary for the Group villages. Windfall development that comes forward within these villages should be considered on the basis of the site and its context. Schemes should be encouraged to make an efficient and effective use of land whilst delivering housing development that is appropriate and helps in meeting the needs of the local community. Often small windfall sites (under the thresholds indicated from Group and Infill Villages) will provide limited or no affordable housing, exacerbating the situation for newly forming households who cannot meet their housing needs locally.

To ensure that the Plan is sound will require:

The publication of a revised Green Belt Assessment to support the Local Plan

A consideration of higher growth targets and subsequent review of the Green Belt / Grey Belt where necessary

The identification and inclusion of the Cambridge Grey Belt within the Local Plan to guide development to sustainable Grey Belt sites.

Jesus College object to Policy S/GB.

Although the Policy states that supporting evidence studies include the Greater Cambridge Green Belt Assessment (2021), it is understood that a revised Green Belt Assessment will be completed and published after the Regulation 18 Consultation closes. It is argued the revised Green Belt Assessment should have informed the Draft Local Plan and been published as part of the Regulation 18 Consultation.

Overall, it is considered that Draft Policy S/GB is not consistent with national policy, does not reflect a positively prepared plan and is not justified. Pertinent to ensuring the Plan is sound will require:

The publication of a revised Green Belt Assessment to support the Local Plan

A consideration of higher growth targets and subsequent review of the Green Belt / Grey Belt where necessary

The identification and inclusion of the Cambridge Grey Belt within the Local Plan to guide development to sustainable Grey Belt sites.

To fully support the rural area and develop a sound spatial strategy with a mixture of deliverable and suitable rural allocations to retain village vitality, more rural allocations are required. Land to the south of Rectory Farm, Harston (HEELA 2025 site ID: 115184) should be identified as an allocation for residential development in the Plan, under Policy S/RRA.

Jesus College object to Policy S/RRA.

Whilst Jesus College support the principle of policy S/RRA in allocating sites for housing and employment in the rural area, the Draft Plan makes very few additional allocations in the rural area and Jesus College objects to this approach. This approach threatens the vitality of villages within the rural area and on the edge of Cambridge and stifles opportunities for further growth and supporting local services. As such, as referred to in representations to Policy S/DS, the Development Strategy should include for further allocations in the rural area to ensure that a sound spatial strategy is developed and delivered.

Sustainable development in rural areas makes an important contribution to ensuring the vitality of villages and supporting existing rural services and facilities. This approach is supported by the National Planning Policy Framework (NPPF), which at paragraph 83 states that to promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities. Planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services.

Notwithstanding this clear direction in national policy, the Draft Local Plan makes very few additional allocations in the rural area. This approach threatens the vitality of villages within the rural area and stifles opportunities for further growth and supporting local services. The allocation of additional small sites in the rural area will also help to ensure that the housing supply for the Local Plan is balanced and robust, reducing the reliance on strategic sites and the limited allocations in villages.

The ability of new development to support rural communities is especially important given the loss of rural services experienced in recent years. The impact of these service losses on rural communities is accentuated when considering pre-existing low service levels compared to better served, urban areas.

The approach of directing some growth to the villages should also take account of existing and proposed public transport improvements. With reference to Harston, whilst it is a relatively small village, it benefits from being within the A10 corridor, plus close proximity to further facilities and services available in nearby villages.

To fully support the rural area and develop a sound spatial strategy with a mixture of deliverable and suitable rural allocations, Land to the south of Rectory Farm, Harston should be identified as an allocation for residential development in the Plan, under Policy S/RRA.

Harston is considered a suitable location for further residential development to support an existing rural community. The site is considered to represent a sustainable location for development which will help to meet the housing needs of Greater Cambridge in the next Local Plan period. With the right design, including a suitable layout and design concept, the proposed development on the site could be accommodated without having a significant impact on the surrounding landscape setting.

The higher growth scenario as acknowledged in the Employment and Housing Needs Update should be used in policy revisions. It is requested that the Plan allocates additional sites in Greater Cambridge to directly respond to the higher growth potential and to increase the diversity of allocated sites to optimise delivery and growth potential. Land to the south of Station Road, Harston (HEELA 2025 site ID: 115742) can soundly assist in realising a greater and more appropriate level of growth in a sustainable way.

Jesus College object to Policy S/JH.

Policy S/JH sets out the level of objectively assessed needs in Greater Cambridge over the period 2024-2045 for jobs and homes. It states that 73,300 additional jobs and a minimum of 48,195 new homes are required to meet the needs for the total population.

The provision of 73,300 additional jobs and 48,195 new homes across the plan period should be regarded as the very minimum rather than a maximum or constraining target. Supporting evidence to the policy titled the ‘Greater Cambridge Employment and Housing Needs Update 2024-2045’ (September 2025) (EHN), states at 3.55 that the various scenarios modelled indicate a need of between 67,600 and 90,900 additional jobs over the plan period. This compares to between 66,600 and 75,800 additional jobs modelled under the previous 2023 results. This significant increase in the upper end of the modelling indicates that economic growth expectations have strengthened exponentially, not diminished.

As set out in the EHN, during the strongest phase of growth (2010–2020), the Greater Cambridge economy expanded by almost 4,000 jobs per year. The conclusion of the EHN is then based on the ‘Central growth’ scenario of 73,200 jobs across the plan period, representing sustained annual growth of around 3,500 jobs. Crucially, the Central growth scenario builds in assumptions of slower periods, contractions, and economic shocks, and is therefore inherently conservative rather than reflective of the full growth capacity of the Cambridge economy. It is also worth noting, at paragraph 3.62 of the EHN, it is acknowledged that the ‘high’ scenarios could be achieved or exceeded if there is a step change in infrastructure investment.

Greater Cambridge is one such location where there has indeed been a step change in infrastructure investment which heightens the urgency in increasing job creation and housing supply and justifies adopting a higher growth scenario. On 23rd August 2024, Matthew Pennycook reaffirmed the Government’s commitment to Cambridge stating; “The economic growth of Cambridge has been a phenomenal success and we should seek to maximise the potential contribution that Greater Cambridge could make to the UK economy.” Pennycook goes on to say; “Greater Cambridge has a vital role to play in this Government’s mission to kickstart economic growth.” Furthermore, the Cambridge Growth Company was established in 2024 to address barriers to growth and help unlock Greater Cambridge’s full potential. In terms of approach, in October 2025, the Government announced its intention to consult on the case for a centrally led Development Corporation as one potential route for delivery (backed by £400m funding). This is to be the subject of statutory consultation in 2026. It is anticipated that Cambridge Growth Company (CGC) will publish its own evidence base ahead of the formation of the Development Corporation, which whilst yet unknown it is expected that an ambitious growth target will be identified; likely to exceed that currently envisioned by the Councils for the Greater Cambridge Local Plan.

Furthermore, Greater Cambridgeshire has been, and continues to be, the location of strategic infrastructure investment that will continue to drive upwards increases in the need for new jobs and homes. This includes the proposed East West rail station as well as the proposed public transport improvements for the Cambourne to Cambridge corridor and the Cambridge Eastern Access corridor. The Cambridgeshire and Peterborough Local Growth Plan 2025 also identify priority growth sectors, and the need for further skills development.

The Employment and Housing Needs Update acknowledges a ‘High’ and ‘High Sensitivity’ scenario, whereby growth would meet or exceed the 2010–2020 trajectory. This high level of growth is feasible in Cambridge and would support the Government’s direction of travel. It is therefore important to recognise that higher-growth outcomes remain credible and should not be ruled out by policy. This requires revision to the proposed policy wording.

For these reasons, the Local Plan should consider utilising a more optimistic and realistic figure for job and housing numbers and include explicit support for higher-growth scenarios. Without these changes, Policy S/JH risks being unsound and inconsistent with national policy objectives to support sustainable economic growth and productivity.

It is requested that the Plan allocates additional sites in Greater Cambridge to directly respond to the higher growth potential and to increase the diversity of allocated sites to optimise delivery and growth potential. Land to the south of Station Road, Harston (HEELA 2025 Site ID: 115742) can soundly assist in realising a greater and more appropriate level of growth in a sustainable way.

There is the need for the allocation of small and medium-sized sites and sites in rural locations in the early years post-adoption of the Plan to ensure flexibility and maintain an up-to-date housing supply including provision for affordable housing needs. Furthermore, those sites in locations that are defined as grey belt should be strongly considered in order to increase the supply of homes. Land to the south of Station Road, Harston (HEELA 2025 Site ID: 115742) is one such grey belt site and can soundly assist in realising a greater and more appropriate level of growth in a sustainable way.

Jesus College object to Policy S/DS.

Policy S/DS sets out the proposed strategy for the pattern, scale and design quality of places created in Greater Cambridge and sets out where the homes and jobs identified in Policy S/JH should be provided to meet the vision and strategic priorities of the Plan.

Firstly, as referred to in representations to Policy S/JH, the identified needs in the Plan are considered too conservative and do not reflect the growth agenda in national, regional and local contexts mandated by the incumbent Labour Government. In line with the Written Ministerial Statement made by Matthew Pennycook (Minister of State for Housing and Planning) on 23 October 2025 the ambition remains to ‘supercharge growth’ within the Oxford-Cambridge Corridor and realise the full potential of Greater Cambridge. Further it is anticipated that the Cambridge Growth Company (CGC) will publish its own evidence base ahead of the formation of a centrally-led Development Corporation (backed by £400m funding announced in October 2025), which, whilst yet unknown, it is expected that an ambitious growth target will be identified; likely to exceed that currently envisioned by the Councils. Collectively it remains apparent therefore that the Government have a continued agenda to deliver high levels of growth within Greater Cambridge and as such more optimistic and realistic figures for job and housing numbers are needed to support sustainable economic growth and productivity.

Secondly, the supporting text to Policy S/DS states, at paragraph 2.64, that ‘drawing on our evidence and consultation feedback, we do not consider that our development needs alone provide the ‘exceptional circumstances’ required in national policy to justify removing land from the Green Belt in this Local Plan, having regard to the identification of other sources of land supply that can meet needs sustainably without the need for Green Belt release’. Paragraph 146 of the NPPF (2024) identifies that one of the exceptional circumstances in which Green Belt boundaries can be altered is where an authority cannot meet its identified need for homes, commercial or other development through other means. Therefore whilst the Councils, drawing on their current evidence base, do not consider that their development needs alone provide the exceptional circumstances required to justify removing land from the Green Belt, the further evidence referred to above may well change the context within which the Councils need to consider the Plan and the potential release of Green Belt land. Those sites in locations that are defined as grey belt should be strongly considered in order to increase the supply of homes.

Thirdly, whilst in principle a strategy of seeking to deliver a large number of new jobs and homes at scale within the Plan is supported, an over reliance on too few strategic sites, particularly those that require significant, costly infrastructure to unlock and deliver them, is not supported. Indeed, it is considered that Policy S/DS sets out such a strategy and relies too heavily on allocating significant levels of growth on just a small number of very large sites. A number of these large sites rely on the timely provision of strategic scale infrastructure which must be in place before they can be constructed. For example, the Cambourne North new settlement (13,000 dwellings and 108,000 sqm employment floorspace) relies upon a new railway station and complicated works to the A428, and Land adjacent to A11 and A1307 at Grange Farm (6,000 dwellings and 35,000 sqm employment floorspace) relying on works to the A505. The draft Plan requires the two sites to deliver 5,100 dwellings between them by 2045. We believe this is highly unlikely.

In particular, the lack of housing allocations in the villages fails to support the delivery of homes to meet the local housing needs of the next generation during the plan period. Instead of being able to live locally, this forces newly forming households to relocate to the main settlements, new settlements, or elsewhere – often away from their existing family, community and support network. This leads to an increased need for travel within Greater Cambridge, often via private cars rather than public transport. It also results in population imbalance, with ageing populations in villages and a falling roll in primary schools – whilst the new settlements have predominantly young populations and significant pressure on services.

A combination of approaches to the distribution of spatial growth are considered likely to be necessary in order to allow for sufficient flexibility when considering the locations and scale of new housing and employment development in the Greater Cambridge area. This is necessary to ensure that the Local Plan supports sustainable communities and sustainable patterns of growth. In addition to providing housing to support new jobs in Cambridge and the key employment growth sectors, the development strategy should take account of the needs and vitality of existing villages and the wider rural economy and make planned provision for them.

In many villages, there is a lack of brownfield land available within the ‘defined development extents’ to facilitate housing delivery in accordance with the approach set out in Draft Policy S/SH (Settlement hierarchy). Also, small windfall sites provide limited affordable housing to meet local needs. Hence, there should be specific land allocations for housing development in some of the rural villages, to promote genuinely sustainable growth and development – supporting the rural economy, promoting mixed and inclusive communities and ensuring the vitality and viability of local services. Additional small and medium sized sites coming forward in the first five years post adoption of the Plan would also provide the necessary flexibility and breadth of supply in the early stages of the plan period and ensure the Plan remains up to date. This is particularly important in light of the fact that the housing land supply across the plan period does not exceed 5.5 years.

It is requested that the Plan allocates additional sites in Greater Cambridge to directly respond to the higher growth potential and to increase the diversity of allocated sites to optimise delivery and growth potential. Land to the south of Station Road, Harston (HEELA 2025 Site ID: 115742) can soundly assist in realising a greater and more appropriate level of growth in a sustainable way.

Windfall development that comes forward within the villages should be considered on the basis of the site and its context, rather than having an indicative maximum scheme size.

Jesus College object to Policy S/SH.

The indicative maximum scheme sizes are not considered to be necessary for the Group villages. Windfall development that comes forward within these villages should be considered on the basis of the site and its context. Schemes should be encouraged to make an efficient and effective use of land whilst delivering housing development that is appropriate and helps in meeting the needs of the local community. Often small windfall sites (under the thresholds indicated from Group and Infill Villages) will provide limited or no affordable housing, exacerbating the situation for newly forming households who cannot meet their housing needs locally.

Policy S/DE should equally be clear on the forms of development that would not constitute inappropriate development in the Green Belt. Alternatively, this could be made clear under Policy S/GB: The Cambridge Green Belt. The Councils needs to properly consider the inclusion of well-performing sites that constitute limited infilling in the Green Belt. For example, Land to the land South of Station Road, Harston (HELAA (2025) ref: 115742).

Jesus College object to Policy S/DE.

At part 2 of the Policy it states that outside defined development extents, development will not be permitted except for:

a. allocations within Made Neighbourhood Plans;

b. Rural Exception sites meeting local need for affordable housing;

c. development for agriculture, horticulture, forestry, outdoor recreation and other uses which need to be located in the countryside; or

d. where development is supported by other policies in this plan.

The supporting text to Policy S/DE then states, at paragraph 2.136 that, “It should be noted that case law has established that the National Planning Policy Framework's (NPPF) exception to Green Belt development being inappropriate if it comprises ‘limited infilling in villages’ is not restricted to sites that fall within defined policy extents for villages established by local plans. As such, consideration of Green Belt policy is therefore a separate consideration to the application of the defined development extent policy, which still applies in Green Belt areas.”

The text then continues at paragraph 2.137 in advising that, “Where a village's form extends beyond a defined development extent and is situated within the Green Belt, the Local Planning Authority will need to assess whether or not the proposal site could be understood as falling within the wider understanding of the village extent, and thus subject to the limited infilling exception.”

Policy NH/9 : Redevelopment of Previously Developed Sites and Infilling in the Green Belt of the adopted South Cambridgeshire Local Plan (2018), at limb (d), specifically recognises that infilling in the Green Belt could be considered appropriate development, as follows:

“1. Redevelopment of Previously Developed Sites and Infilling in the Green Belt will be inappropriate development except for:

…

d. Limited infilling, where infilling is defined as the filling of small gaps between existing built development (excluding temporary buildings). Such infilling should have no greater impact upon the openness of the Green Belt and the purpose of including land within it than the existing development. The cumulative impact of infilling proposals will be taken into account;”

Policy S/DE should equally be clear on the forms of development that would not constitute inappropriate development in the Green Belt. Alternatively, this could be made clear under Policy S/GB: The Cambridge Green Belt.

The Councils needs to properly consider the inclusion of well-performing sites that constitute limited infilling in the Green Belt. For example, Land to the land South of Station Road, Harston (HELAA (2025) ref: 115742).

Grey belt should be referenced within Policy S/GB and suitable sites should be identified as required by the NPPF and PPG. The Council needs to properly consider the inclusion of well-performing sites in the Grey Belt. For example, Land to the South of Station Road, Harston (ref: 115742)

Jesus College object to Policy S/GB.

Firstly, the supporting text to Policy S/DE: Defined Development Extents states, at paragraph 2.136 that, “It should be noted that case law has established that the National Planning Policy Framework's (NPPF) exception to Green Belt development being inappropriate if it comprises ‘limited infilling in villages’ is not restricted to sites that fall within defined policy extents for villages established by local plans. As such, consideration of Green Belt policy is therefore a separate consideration to the application of the defined development extent policy, which still applies in Green Belt areas.”

The text then continues at paragraph 2.137 in advising that, “Where a village's form extends beyond a defined development extent and is situated within the Green Belt, the Local Planning Authority will need to assess whether or not the proposal site could be understood as falling within the wider understanding of the village extent, and thus subject to the limited infilling exception.”

Policy NH/9 : Redevelopment of Previously Developed Sites and Infilling in the Green Belt of the adopted South Cambridgeshire Local Plan (2018), at limb (d), specifically recognises that infilling in the Green Belt could be considered appropriate development, as follows:

“1. Redevelopment of Previously Developed Sites and Infilling in the Green Belt will be inappropriate development except for:

…

d. Limited infilling, where infilling is defined as the filling of small gaps between existing built development (excluding temporary buildings). Such infilling should have no greater impact upon the openness of the Green Belt and the purpose of including land within it than the existing development. The cumulative impact of infilling proposals will be taken into account;”

Policy S/GB should equally be clear on the forms of development that would not constitute inappropriate development in the Green Belt.

Secondly, although the Policy states that supporting evidence studies include the Greater Cambridge Green Belt Assessment (2021), it is understood that a revised Green Belt Assessment will be completed and published after the Regulation 18 Consultation closes. It is argued the revised Green Belt Assessment should have informed the Draft Local Plan and been published as part of and the Regulation 18 Consultation.

Thirdly, the omission of any reference to ‘Grey Belt’ within the Draft Policy S/GB is challenged. The NPPF (2024) introduced a clear duty for Grey Belt land to be identified when undertaking Green Belt Assessments for the purposes of determining applications; reinforced within the Planning Practice Guidance (PPG) (Para 001 ref.001 64-001-20250225). The direction of travel towards authorities being required to identify Grey Belt land within local plans is further evidenced within the forthcoming Consultation Draft NPPF (2025) (GB2[3]) and at Appendix E where the criteria for undertaking Green Belt Assessments is outlined). Hence, regardless of whether the Draft Local Plan can meet the identified needs for growth without Green Belt release, the relevant Plan Policy (S/GB) should include explicit reference to Grey Belt (consistent with the NPPF) and the identification of Grey Belt land within Greater Cambridge. To ensure the longevity of the Local Plan, it is recommended the revised Green Belt Assessment is undertaken with regard to Appendix E of the NPPF 2025.

Lastly, Bidwells understand that the Council’s consultants (LDA) are currently considering the process of examining Grey Belt issues and possibly Grey Belt sites across Greater Cambridge. Officers have stated at various committees that Grey Belt sites are not required to accommodate housing allocations and the Draft Local Plan ‘is not configured for this’. However, the fact LDA are considering an assessment of Grey Belt suggests the Draft Local Plan does need to cover this important issue given the increasing importance of Grey Belt policy in the current NPPF (2024) and the Consultation Draft (2025).

Identifying Grey Belt land within the revised Green Belt Assessment and Draft Local Plan is hence both a policy requirement and crucial to ensuring the Local Plan promotes sustainable patterns of growth (as required by the NPPF) and is robust and flexible in providing a sufficient supply of suitable land in order to meet the ‘supercharged growth’ mandated for the Greater Cambridge by Government.

Overall, it is considered that Draft Policy S/GB is not consistent with national policy, does not reflect a positively prepared plan and is not justified. Pertinent to ensuring the Plan is sound will require:

The publication of a revised Green Belt Assessment to support the Local Plan

A consideration of higher growth targets and subsequent review of the Green Belt / Grey Belt where necessary

The identification and inclusion of the Cambridge Grey Belt within the Local Plan to guide development to sustainable Grey Belt sites.

The Council must take a positive approach to the preparation of the Plan. Its failure to engage properly with the Green Belt has not led the plan to an effective spatial strategy. There is a superior sustainable plan to be formed by properly considering Green Belt (Grey Belt) sites that can better underpin sustainable development.

The Council needs to properly consider the inclusion of well-performing sites in the Grey Belt. For example, Land to the South of Station Road, Harston (ref: 115742) was assessed within the Council’s Green Belt Assessment (2021) which supported First Proposals (2021) Draft Local Plan (Parcel HS9). The Council need to release additional Green Belt sites in line with the hierarchy set out in paragraph 148 of the NPPF (2024) to lead to a sustainable spatial strategy.