Draft Greater Cambridge Local Plan for consultation

Comment on Vision for Greater Cambridge: Neutral

The Strategic Vision for Greater Cambridge is broadly aligned with the economic, social and environmental objectives of sustainable development set out in Paragraph 8 of the NPPF. The seven strategic priorities identified at section 2.4 are supported. However, it is essential that the policies and site allocations in the emerging Plan translate these aspirations into practical, deliverable outcomes.

In particular, the current development allocation policy:
• Does not support equality of access and opportunities or ensure everyone can benefit from development of new homes and jobs. The current strategy seeks to concentrate development in large strategic sites, which does not account for rural housing and employment needs.

• Does not plan for enough housing. In particular, government targets should be treated as a minimum, not a maximum. Delivery of homes in rural locations and sustainable villages will provide a pipeline of small and medium sized sites, which can be quicker to deliver, support smaller housebuilders, and ensure provision of affordable housing in rural locations. The lack of allocations in villages means that any new development will inevitably be smaller sale and ad-hoc, will not provide affordable housing, and will not allow for transport and community facility upgrades that would make rural communities more sustainable.

As set out in these representations from Redrow, the preferred housing target, development strategy and proposed allocations in the draft GCLP are unlikely to deliver the Vision for Greater Cambridge. The housing requirement is not aligned with forecast jobs growth, which is likely to increase in commuting—predominantly by car.

The strategy is overly reliant on large strategic sites, including an expanded Cambourne, existing new settlements at Northstowe, Waterbeach and Bourn Airfield, and a proposed new settlement at Grange Farm with 44% reliance on new settlements. The timing of necessary infrastructure to support growth at Cambourne and Grange Farm is uncertain. Predicted delivery rates across these sites are unrealistically high, and many are struggling to provide policy compliant levels of affordable housing.

The strategy also actively avoids directing development towards the more sustainable villages—such as Hauxton —regardless of their strong sustainability credentials, existing services and facilities, good accessibility by sustainable transport, and clear affordable housing needs.

To fully deliver the Vision for Greater Cambridge, a higher housing requirement, a revised development strategy, and additional allocations in sustainable villages are necessary.

Redrow is promoting land south of High Street, Hauxton, for a development of up to 150 homes. This was given the site reference 40283 in the HELAA 2021 Appendix 1. A scheme of this scale would meet Hauxton’s affordable housing needs, deliver new public open space, and provide appropriate contributions towards local infrastructure including transport, education and cultural facilities. It will also be deliverable in the very short-term helping to meet the housing needs.

As set out previously, Redrow is broadly supportive of the Strategic Priorities of the Local Plan. However, these priorities are unlikely to be addressed unless the allocation strategy is more dispersed across the plan area.

Redrow is promoting a site on the edge of Hauxton for up to 150 dwellings at Land East of Hauxton (HELAA reference 40283). The site is located east of Hauxton Primary School, west of the M11 and south of High Street.

The draft GCLP sets out seven strategic priorities covering climate change, biodiversity and green spaces, wellbeing and social inclusion, great places, jobs, homes, and connectivity and infrastructure. However, as outlined in these representations, the preferred housing target, development strategy, and selected site allocations are unlikely to deliver these priorities in full.

The proposed housing requirement is not aligned with anticipated jobs growth, which risks increasing in commuting to Cambridge, predominantly by car, directly conflicting with the climate change priority. The development strategy is overly reliant on large strategic sites, many of which face uncertain infrastructure delivery timetables, unrealistic housing build out rates, and challenges in achieving policy compliant levels of affordable housing. As a result, both housing and affordable housing needs are unlikely to be met, undermining the strategic priority for homes.

Furthermore, the strategy avoids directing development to accessible villages, such as Hauxton, despite their strong sustainability credentials, existing facilities, public transport accessibility, proximity to jobs and clear affordable housing needs.

This approach does not support village communities or sustain local services and fails to meet the strategic priorities related to great places, homes, connectivity and infrastructure.

Overall, it is considered that the strategic priorities of the draft GCLP can only be fully achieved through a higher housing requirement, a revised development strategy, and additional allocations in the sustainable villages, including Hauxton that has excellent links into Cambridge city and the train station at Great Shelford.

Redrow requests that:

1. The housing requirement in Policy S/JH is reassessed to include a commuting adjustment.
2. An economic uplift is applied to reflect growth ambitions and infrastructure investment.
3. The housing target is increased to help address affordable housing need.
4. Additional deliverable sites, including land east of Hauxton (HELAA reference 40283), are allocated to support housing delivery and plan flexibility.

Object

These representations are submitted by Redrow in its capacity as a site promoter with regards to Land East of Hauxton (HELAA reference 40283), whereby they are seeking an allocation. The site is located east of Hauxton Primary School, west of the M11 and south of High Street.

Policy S/JH of the draft GCLP sets out the jobs and housing targets for the plan period 2024–2045. The plan identifies a jobs target of 73,300 additional jobs and a minimum housing requirement of 48,195 dwellings. The proposed housing requirement is based on the national standard method for calculating local housing need, which for Greater Cambridge equates to 2,295 dwellings per annum.

Redrow strongly objects to the overall housing numbers proposed within the plan and believes these should be revised upwards. There are two key limbs to our objection.

Firstly, the jobs and housing targets in the draft Plan are not aligned. A higher jobs target relative to housing provision will necessitate increased in commuting to meet labour demands. Earlier evidence, specifically the 2023 Greater Cambridge Employment and Housing Evidence Update, derived its housing target using a Central Growth Scenario, preferred 2011 Census commuting data, and a 1:1 commuting adjustment to ensure closer alignment between job growth and housing need. However, the 2025 Greater Cambridge Employment and Housing Needs Update does not apply any equivalent adjustment.

While the 2025 Strategy Topic Paper acknowledges the importance of commuting patterns in understanding the jobs–housing relationship, it similarly fails to apply a commuting adjustment to the housing requirement. Consequently, despite recognising commuter dynamics, the Topic Paper and the updated evidence base do not translate this into the housing target. This omission results in a housing requirement that remains too low to support the proposed jobs growth, exacerbates the risk of increased in commuting, and undermines the effectiveness and soundness of Policy S/JH.

Secondly, paragraph 62 of the NPPF confirms that the standard method provides the minimum number of homes needed. Paragraph 69 further notes that the housing requirement may exceed this minimum where justified, including to support economic growth or infrastructure investment. The housing target in Policy S/JH relies solely on the standard method and does not include any uplift to reflect Greater Cambridge’s economic ambitions or major infrastructure investment, despite both being highly relevant in this context. Given Greater Cambridge’s national economic role, Government’s establishment of the Cambridge Growth Company, and significant infrastructure investment (including East West Rail, Cambridge South Station and the Greenways network), an economic uplift should be applied to the housing target.

The Greater Cambridge City Deal recognised the strong relationship between housing supply and economic performance, noting that constrained housing availability and affordability have influenced house prices, commuting patterns, and employers’ ability to attract and retain staff. The Cambridgeshire and Peterborough Devolution Deal similarly committed to substantial economic growth, including a target to double economic output over 25 years. In 2024, Government established the Cambridge Growth Company to help maximise Cambridge’s economic potential and deliver nationally significant growth.

In addition, there are also several planned and proposed infrastructure projects that should inform how the housing target should be adjusted. These include East West Rail, the Cambourne to Cambridge Busway, the Cambridge South East Transport project, the Waterbeach to Cambridge Busway, Cambridge Eastern Access, and Cambridge South Station. In addition, the Greater Cambridge Partnership is progressing a network of greenways to improve active travel connections between surrounding villages and Cambridge.

Given this context and taking all of the above into account, Redrow strongly believes that the housing target in Policy S/JH should be reassessed, with an upward adjustment applied to ensure that the Local Plan is sound and meets its duty to support economic growth ambitions and planned infrastructure investment.

Finally, the 2025 Housing Needs of Specific Groups in Cambridge and South Cambridgeshire Report provides an assessment of the housing requirements of various groups, including the need for affordable housing. Chapter 7 focuses specifically on affordable housing need and identifies a significant shortfall across Greater Cambridge.

The Report estimates that 1,083 affordable homes are needed each year for households unable to buy or rent on the open market across Greater Cambridge, excluding those who can afford to rent but not buy (Paragraph 7.62). It also presents an alternative scenario that removes households who are already housed from the calculation. Under this approach, the annual requirement would be 425 affordable homes in Cambridge and 318 in South Cambridgeshire (Paragraph 7.63), giving a combined figure of 743 affordable homes per year.

The Report acknowledges the complexity of assessing affordable housing needs, including the fact that needs change over time, and therefore advises that these annual figures should not be multiplied to produce a total for the entire plan period. Nevertheless, the Report concludes that no adjustment to the draft GCLP housing target is required to address affordable housing need. This conclusion is not justified.

Annual monitoring data shows that affordable housing delivery in Greater Cambridge fluctuates but averages around 500 affordable homes per year—below both of the identified needs (743 and 1,083 homes respectively). Furthermore, several existing strategic sites have been unable to deliver policy compliant levels of affordable housing due to the substantial infrastructure costs they must accommodate. This includes Northstowe and Waterbeach new settlements. It is likely that the same viability challenges will arise at the proposed strategic sites at North Cambourne and Grange Farm.

If Greater Cambridge is to meet its affordable housing needs, the draft GCLP must include a higher overall housing requirement and identify additional allocations to compensate for the affordable housing shortfall from both existing and proposed strategic sites. It is therefore considered that the housing requirement in Policy S/JH should be increased to include an upward adjustment specifically to address affordable housing needs and additional allocation on the edge of Hauxton be provided.

The 2025 Strategy Topic Paper highlights the importance of flexibility and reducing reliance on large strategic sites. Deliverable, sustainable village edge sites such as land east of Hauxton can support early housing delivery and help meet the revised requirement.


Requested Change

The following changes should be considered for Policy S/JH.

The housing target should be reassessed to include a commuting patterns adjustment and to account for the Greater Cambridge growth ambitions linked to economic development and infrastructure investment.

Redrow requests that:

1. The housing requirement in Policy S/JH is reassessed to include a commuting adjustment.
2. An economic uplift is applied to reflect growth ambitions and infrastructure investment.
3. The housing target is increased to help address affordable housing need.
4. Additional deliverable sites, including land east of Hauxton (HELAA reference 40283), are allocated to support housing delivery and plan flexibility.

The requested changes to the development strategy in Policy S/DS are as follows.

• Housing delivery assumptions for all of the strategic sites should be reassessed, taking into account realistic annual housing delivery rates and the delivery of critical infrastructure required for those sites (also considering the need to increase the overall housing target).

• Land be released from the Green Belt to meet development needs.

• Additional allocations be made in sustainable villages to improve delivery lead in times with specific regard to the Redrow site at Hauxton (HELAA reference 40283).

Policy S/DS: Development Strategy


Object

Redrow objects to the preferred development strategy set out in Policy S/DS on the basis that it places disproportionate reliance on an expanded Cambourne and a series of new settlements, despite significant uncertainty about the delivery timetable for the infrastructure required to support them, the unrealistic nature of the assumed housing delivery rates, and repeated evidence that these locations are unable to achieve policy compliant levels of affordable housing.

Although the development strategy includes Rural Centres, Minor Rural Centres and Group Villages—such as Hauxton—it does not allocate any additional housing to these sustainable settlements. A more balanced and resilient development strategy should be adopted which requires additional allocations in these locations. Furthermore, exceptional circumstances exist to justify the release of certain land from the Green Belt, including acute market and affordable housing needs, employment growth pressures, and the requirement to direct development to the most sustainable and well connected areas.

Redrow is particularly concerned that the draft Local Plan relies heavily on both existing and newly proposed strategic allocations, while ruling out Green Belt release in sustainable locations and failing to allocate sites within the most accessible village settlements. Although strategic sites such as Eddington, Cambourne West, Northstowe, Waterbeach, Bourn Airfield and Cambridge East benefit from an established planning position, the draft GCLP also introduces new strategic proposals at Cambourne North and Grange Farm. Cambourne North is dependent on the emerging East West Rail scheme, and Grange Farm is tied to a potential stop on the Cambridge South East Transport route, yet both schemes lack confirmed approvals and secured funding.

The draft Plan’s housing delivery assumptions across these strategic locations are overly ambitious and are not supported by historic build out rates in Greater Cambridge or comparable large scale developments nationally. Policy S/DS assumes that 44% of the housing requirement will be delivered at new settlements and anticipates delivery rates of up to 300 dwellings per annum on some sites—figures that have not been achieved or sustained locally or in comparable national contexts. This is particularly concerning given that existing new settlements have consistently delivered below the policy required 40% affordable housing due to the substantial infrastructure liabilities they must absorb early in the development process, making it highly likely that Cambourne North and Grange Farm will face similar viability constraints.

Redrow therefore considers that the delivery assumptions for all strategic sites must be reassessed to ensure they are credible and evidence based. In addition, the draft strategy contradicts its own settlement hierarchy by acknowledging the role of Rural Centres and Minor Rural Centres while failing to allocate any new housing to them. Sustainable villages such as Hauxton—where good local services, strong transport accessibility and clear local affordable housing needs are present—should play a meaningful role in accommodating growth. The policy as worded clearly fails to meet local need across the plan area and does not allow for the homes required in rural areas.

Redrow’s promoted site at land east of Hauxton (HELAA reference 40283) represents a deliverable, medium sized opportunity that would reinforce the vitality of local facilities, support local schools, deliver affordable homes to meet the identified needs of households with a local connection, and come forward early in the Plan period without requiring major new infrastructure. As this land forms part of the “grey belt,” with limited contribution to Green Belt purposes, Redrow considers that its release is justified to support a more balanced, flexible and deliverable development strategy.

Requested Change

The requested changes to the development strategy in Policy S/DS are as follows.

• Housing delivery assumptions for all of the strategic sites should be reassessed, taking into account realistic annual housing delivery rates and the delivery of critical infrastructure required for those sites (also considering the need to increase the overall housing target).

• Land be released from the Green Belt to meet development needs.

• Additional allocations be made in sustainable villages to improve delivery lead in times with specific regard to the Redrow site at Hauxton (HELAA reference 40283).

Redrow requests that the settlement hierarchy be reviewed following an assessment of the sustainability credentials of each settlement in the District.

Redrow also requests that the GCLP undertake a review of the capacity of the most sustainable villages in South Cambridgeshire—including Group Villages located close to Cambridge with strong transport links—to determine whether additional development can be accommodated within existing development framework boundaries. Where the assessment identifies no suitable internal sites to meet identified housing and affordable housing needs, the Local Plan should allocate additional land at the edges of these settlements to ensure that growth is appropriately directed, sustainably delivered, and consistent with the Plan’s stated objectives.

Object
Redrow objects to the approach taken in Policy S/SH: Settlement Hierarchy on the grounds that the draft Local Plan has not assessed the capacity of individual settlements—including Hauxton—to accommodate additional growth, nor has it reviewed whether the existing development threshold limits remain appropriate in circumstances where no suitable sites exist within the defined development frameworks.

While the policy identifies Rural Centres, Minor Rural Centres and Group Villages as part of the development strategy, it does not allocate any new development in these settlements, including those—such as Hauxton—that are demonstrably highly sustainable. The absence of such an assessment means the settlement hierarchy is applied rigidly rather than being evidence led, with no consideration given to whether directing growth to sustainable villages could support the Local Plan’s wider objectives relating to housing delivery, affordable housing provision, service retention, and reduced commuting distances.

In Hauxton’s case, there has been no evaluation of whether land within its existing development framework could reasonably accommodate additional development. Based on local analysis, there appear to be no significant opportunities for major residential development within the current boundary; most land is already developed, protected, or too limited in scale to offer any meaningful contribution to housing supply. Any future development that might come forward within the village boundary would likely consist of small, infill schemes incapable of delivering affordable housing or generating the investment required to support local services, facilities or infrastructure.

Despite being classed as a Group Village, Hauxton is, in reality, a demonstrably sustainable settlement whose context has changed substantially since the existing hierarchy was first established. The village benefits from excellent access to a full range of services and facilities, including schools, employment opportunities, convenience and non food retail, leisure uses and healthcare. These are all accessible on foot (within 2km), by cycle (within 8km), and by public transport. The village has established pavements and safe pedestrian routes connecting into Hauxton and towards Great and Little Shelford. Street lit cycle routes, including a 3m shared pedestrian–cycle path along the A10, connect the site to the wider active travel network. Frequent bus services operate from stops just 75m away at Jackson Close, providing connections to Cambridge, Royston, Trumpington and the Shelfords. The Trumpington Park & Ride lies within 4km, offering frequent 10 minute services into Cambridge and future enhanced access through the South West Travel Hub. Rail connectivity is strong: Shelford Station is reachable within a 9 minute cycle and provides services to Cambridge, London Liverpool Street and Ely, while Foxton Station is accessible in around 30 minutes by bike.

These factors demonstrate that Hauxton is a highly sustainable settlement capable of supporting further planned growth. The failure of the draft GCLP to revisit settlement capacities, update the settlement hierarchy, or allocate new development in such well connected villages means that Policy S/SH does not reflect the current sustainability profile of these locations and risks directing disproportionate growth to less deliverable strategic sites. It also fails to deliver homes, particularly affordable homes, across the District in places where there is identified need, such as Hauxton.

A proper evaluation of the development potential of more sustainable settlements should be undertaken as part of the evidence base for the draft GCLP. Where this demonstrates limited capacity within settlement boundaries—as is the case for Hauxton—the Plan should allocate suitable land on the edge of such villages to ensure growth is directed to the most sustainable locations, supports local services and facilities, and meets identified local affordable housing needs. Redrow’s site east of Hauxton (HELAA reference 40283) represents precisely such an opportunity: a medium sized, early delivery site requiring no major infrastructure, capable of reinforcing the vitality of the village and meeting established needs, particularly for affordable housing for those with a local connection.

Requested Change:

Redrow requests that the settlement hierarchy be reviewed following an assessment of the sustainability credentials of each settlement in the District.

Redrow also requests that the GCLP undertake a review of the capacity of the most sustainable villages in South Cambridgeshire—including Group Villages located close to Cambridge with strong transport links—to determine whether additional development can be accommodated within existing development framework boundaries. Where the assessment identifies no suitable internal sites to meet identified housing and affordable housing needs, the Local Plan should allocate additional land at the edges of these settlements to ensure that growth is appropriately directed, sustainably delivered, and consistent with the Plan’s stated objectives.

Requested Change:

Redrow requests that the Council undertake a review of the capacity of the more sustainable settlements—including Group Villages close to Cambridge with strong transport accessibility—to determine whether additional development can be accommodated within the current development framework boundaries. Where no suitable capacity exists, the Local Plan should allocate appropriate village edge sites to ensure future housing and affordable housing needs can be met in sustainable locations such as Hauxton.

Redrow have produced a vision statement for their site located on the edge (east) of Hauxton, with a scheme suitable for development for up to 150 dwellings. This is submitted alongside these representations, and demonstrates that the site is suitable, available and achievable.

Object

Redrow notes that Policy S/DE relies heavily on long established defined development extents, yet no review has been undertaken to consider whether these boundaries remain appropriate or capable of accommodating the future development needs of individual settlements. This is particularly relevant to Group Villages such as Hauxton. The defined development limits across much of South Cambridgeshire have remained largely unchanged since the 2004 Local Plan, with only minor adjustments in 2010 and 2018 to allow for specific allocations. As a result, the boundaries do not reflect updated evidence on settlement sustainability, changes in service provision, or the increased urgency of meeting both market and affordable housing needs. Because areas immediately beyond these boundaries are also constrained by the Green Belt, the current approach effectively prevents any meaningful outward expansion, even in highly sustainable locations.

In Hauxton, this means that almost no opportunities exist within the existing development framework to deliver new housing at a scale capable of supporting the village’s identified needs. Remaining land within the boundary is either already developed, constrained by existing uses, or too small to make a meaningful contribution to housing supply, particularly affordable housing. Any development that might come forward would likely be limited to minor infill plots, which would not deliver affordable housing, assist in providing new community facilities, or secure meaningful investment in local services. This is despite Hauxton being a demonstrably sustainable village with strong accessibility credentials. The settlement benefits from proximity to local employment, retail, leisure, healthcare and education, all accessible on foot or by cycle. The promoted site east of Hauxton sits immediately adjacent to the High Street and is linked via safe pedestrian and cycle routes to local schools—including Hauxton Primary School, which currently operates below capacity and would directly benefit from new pupils living within walking distance. Public transport access is excellent, with bus stops 75m away and easy cycling links to Shelford and Foxton railway stations, as well as the Trumpington Park & Ride and the future South West Travel Hub.

Given these characteristics, it is clear that retaining Hauxton’s development extent in its current form severely limits the ability of the village to meet housing and affordable housing needs, to support local services, and to deliver wider community benefits. While Redrow does not seek a direct amendment to the wording of Policy S/DE itself, these representations emphasise that defined development extents should be subject to a full review to ensure they accurately reflect the development potential and sustainability of individual settlements. Where that review concludes—as in Hauxton—that there is no capacity within existing boundaries, the Local Plan should allocate appropriate village edge sites in the most sustainable locations. Doing so would enable planned growth to be directed where it can be sustainably accommodated, support the vitality of rural communities, and help deliver the affordable housing that smaller infill schemes cannot provide.

Requested Change:

Redrow requests that the Council undertake a review of the capacity of the more sustainable settlements—including Group Villages close to Cambridge with strong transport accessibility—to determine whether additional development can be accommodated within the current development framework boundaries. Where no suitable capacity exists, the Local Plan should allocate appropriate village edge sites to ensure future housing and affordable housing needs can be met in sustainable locations such as Hauxton.

Redrow have produced a vision statement for their site located on the edge (east) of Hauxton, with a scheme suitable for development for up to 150 dwellings. This is submitted alongside these representations, and demonstrates that the site is suitable, available and achievable.

Redrow requests that Purpose 1c in Policy S/GB be amended to read:

“prevent towns in the environs of Cambridge from merging into one another and with the city”

This revised wording aligns directly with the NPPF, ensures consistency with national policy, removes ambiguity arising from the current term “communities,” and provides a clearer basis for assessing potential Green Belt release where justified.

The Green Belt and its purposes should be subject to review around Hauxton.

Object

Redrow objects to Policy S/GB on the basis that its wording is inconsistent with national Green Belt policy and risks misapplication of Green Belt purposes at both plan making and decision making stages.

Paragraph 143 of the National Planning Policy Framework (NPPF) identifies five purposes of Green Belts, including the requirement “to prevent neighbouring towns merging into one another.” However, Criterion 1c of Policy S/GB instead seeks to “prevent communities in the environs of Cambridge from merging into one another and with the city.” This localised purpose departs from the terminology of the NPPF by substituting “towns” with the broader and less defined term “communities.”

Given that alignment with national policy is central to the soundness tests for Local Plans, this inconsistency is of great concern and the policy is unsound. The use of “communities” unacceptably broadens the interpretation of Green Belt purposes beyond national policy, making it more difficult to assess proposals appropriately and potentially constraining opportunities for sustainable development in locations that do not materially contribute to the core Green Belt function of preventing the merging of towns. To ensure clarity and compliance with the NPPF, Criterion 1c should be amended to replace “communities” with “towns.”

Redrow is promoting land east of Hauxton, which lies just outside the village framework and within the Green Belt. The site is not allocated in the draft GCLP; however, as set out elsewhere in these representations, Redrow is seeking the allocation of this land supported by necessary changes to relevant policies. The land east of Hauxton falls within “grey belt,” as recognised in Chapter 13 and Annex 2 of the NPPF and Section ID:64 of the Planning Practice Guidance. Further detail on the site’s accordance with grey belt legislation was submitted as part of the Call for Sites in March 2025 (“Landscape and Visual Appraisal and Green Belt Review”, The Landscape Partnership).

Redrow considers that the land east of Hauxton should be released from the Green Belt to support the deliverability, flexibility and soundness of the emerging GCLP. The site lies immediately beyond the Hauxton village framework and is correctly categorised as “grey belt” in accordance with paragraph 143 of the NPPF and supporting PPG, as it makes only a limited contribution to Green Belt purposes. The land does not contribute to preventing the sprawl of a town, does not play a role in maintaining the separation of towns, and does not form part of the setting of a historic town. Its weak functional performance, combined with the absence of other environmental constraints, places it clearly within the category of land that national policy expects to be prioritised for release where justified.

Releasing this site accords with the NPPF’s “Golden Rules” for Green Belt development (paragraphs 155–157). The allocation would focus growth on grey belt land, address the significant unmet market and affordable housing needs across Greater Cambridge, and enable a sustainable, well-connected extension to an existing village. The site benefits from strong active travel connections, proximity to services and schools, and access to strategic transport corridors. It is also capable of delivering the level of affordable housing, green infrastructure, biodiversity enhancements and open space sought by national and local policy. These attributes mean the site satisfies the criteria to which paragraph 158 directs significant weight.

Landscape evidence confirms that the land performs very weakly against Green Belt purposes and that its development would not harm the countryside setting or long-term settlement separation. Redrow’s emerging masterplan proposes a landscape-led scheme with more than 60% of the land retained as open space, strengthened field patterns, enhanced green infrastructure and a softened settlement edge. The allocation would therefore improve, rather than erode, the transition between Hauxton and the surrounding countryside.

The site is also deliverable early in the plan period and provides a medium-scale development opportunity that can support local facilities, including Hauxton Primary School, which is operating below capacity and would benefit from a modest uplift in local pupil numbers. The site offers a realistic opportunity to meet local affordable housing needs that cannot be met within the existing village boundary.

A robust evidence base can underpin the allocation, supported at planning application stage by detailed assessments of flood risk, drainage, landscape, ecology, heritage, transport and other technical matters. The site can therefore be brought forward responsibly and in full accordance with Policy S/RRA and wider GCLP requirements.

For these reasons, Redrow considers that releasing land east of Hauxton from the Green Belt and allocating it within Policy S/RRA is essential to secure a sound Local Plan—one that is positively prepared, justified, effective and consistent with national policy.

The present wording of Policy S/GB risks preventing consideration of sustainable opportunities such as this, even where the site does not undermine Green Belt purposes as set out in national policy. Ensuring clarity in the definition of Green Belt purposes is therefore essential to enable the Local Plan to respond appropriately to development pressures while maintaining the integrity of the Cambridge Green Belt.

Redrow is promoting this site, located immediately beyond the Hauxton village framework and within the Green Belt, as an additional allocation necessary to support the deliverability, flexibility and soundness of the emerging GCLP. As demonstrated throughout these representations, the overall housing requirement should be increased, greater emphasis should be placed on distributing growth to the most sustainable villages, and the Plan should release appropriate areas of Green Belt, including “grey belt” land, to address significant housing and affordable housing needs.

Requested Change

Redrow requests that Purpose 1c in Policy S/GB be amended to read:

“prevent towns in the environs of Cambridge from merging into one another and with the city”

This revised wording aligns directly with the NPPF, ensures consistency with national policy, removes ambiguity arising from the current term “communities,” and provides a clearer basis for assessing potential Green Belt release where justified.

The Green Belt and its purposes should be subject to review around Hauxton.

Redrow requests that land east of Hauxton (HELAA reference 40283) be allocated in the Local Plan with the following requirements:
• Site area: 12.44 hectares
• Indicative capacity: up to approximately 150 dwellings, including a policy compliant proportion of affordable housing and provision for self/custom build plots

This submission is supported by a Vision Document. The Connectivity/Transport and Framework Masterplan diagrams demonstrate that land east of Hauxton is physically contained by durable features, benefits from direct and safe pedestrian, cycle and public transport links to local services, and can be delivered through a landscape led masterplan that retains and strengthens green corridors, integrates SuDS, and provides extensive public open space. These attributes confirm a “grey belt” context with very limited contribution to Green Belt purposes (sprawl, coalescence, or historic setting), and show that harm can be avoided and, in places, positively remedied by creating a permanent, defensible and greener settlement edge. The scheme is immediately deliverable, supports early housing and affordable housing supply, and improves access to local facilities, thereby satisfying the NPPF’s “golden rules” for Green Belt release. On this basis, the site should be released from the Green Belt and allocated in Policy S/RRA.

Object

Redrow is advancing proposals for land to the east of Hauxton, situated immediately beyond the defined village framework. Although the site lies within the Green Belt and is not identified for development in the draft Greater Cambridge Local Plan (GCLP), its promotion highlights important strategic considerations.

Redrow objects to Policy S/RRA on the basis that the draft Local Plan fails to allocate sufficient land within the rural area to meet the uplifted housing needs identified elsewhere in these representations, and that the policy does not provide a mechanism for including additional sustainable village edge sites such as land east of Hauxton.

Redrow is promoting this site (HELAA reference 40283) located immediately beyond the Hauxton village framework and within the Green Belt, as an additional allocation necessary to support the deliverability, flexibility and soundness of the emerging GCLP. As demonstrated throughout these representations, the overall housing requirement should be increased, greater emphasis should be placed on distributing growth to the most sustainable villages, and the Plan should release appropriate areas of Green Belt, including “grey belt” land, to address significant housing and affordable housing needs. Reflecting these overarching principles, Policy S/RRA should be amended to include the land east of Hauxton as an additional allocation in the rest of the rural area.

The promoted site is appropriately categorised as grey belt, in accordance with paragraph 143 of the NPPF and the accompanying Planning Practice Guidance, which define grey belt as Green Belt land that does not strongly contribute to purposes (a), (b) and (d).

The Hauxton site makes only a very limited contribution to these purposes. It does not facilitate unrestricted sprawl of a large built-up area (purpose a); it plays no role in preventing neighbouring towns from merging (purpose b), as it is physically and visually separated from Cambridge by significant landscape buffers, strategic infrastructure and established field patterns; and it does not contribute to the setting of a historic town (purpose d). In addition, the site carries no other designations that would inhibit its development. Its classification as grey belt therefore aligns directly with national policy, including the NPPF’s requirement (paragraph 148) that, where Green Belt release is necessary, previously developed land and grey belt should be prioritised.

The development of the Hauxton site also satisfies the “Golden Rules” for Green Belt development set out in paragraphs 155–157 of the NPPF.

First, it proposes development on grey belt, rather than land performing essential Green Belt functions. Second, there is clear unmet need for both market and affordable housing in Greater Cambridge, including the significant shortfall identified in the 2025 Housing Needs Report. Third, the site is demonstrably sustainable: it benefits from excellent walking, cycling and public transport links, offers direct and safe access to schools, services and employment, and sits in close proximity to major transport corridors and rail connections.

Fourth, the scheme is capable of delivering the high levels of affordable housing and green infrastructure expected under paragraph 157, including extensive new public open space, landscape restoration, biodiversity enhancements and active travel routes. In line with paragraph 158, developments that satisfy these criteria should be given significant weight.

In landscape terms, the site performs extremely weakly against the Green Belt purposes, and its development would not harm the open countryside setting or long term settlement separation. On the contrary, Redrow’s emerging framework masterplan proposes strengthening local landscape character, restoring field patterns, integrating substantial green infrastructure and retaining more than 60% of the land as open space. Far from weakening the edge of Hauxton, the scheme would provide a managed and softened settlement boundary that enhances the transition between the village and open countryside.

Importantly, land east of Hauxton also represents an early delivery, medium sized site capable of supporting local services, schools and community facilities at a time when the Plan relies heavily—and precariously—on large, infrastructure dependent strategic sites to deliver its housing trajectory. Hauxton Primary School, for example, is operating significantly under capacity, with 30 spare places, and would benefit from nearby pupil growth that can be safely accessed on foot. The site is well located to contribute to local vitality and to meet specific local affordable housing needs that cannot realistically be met through small infill plots within the existing settlement boundary.

In addition to its physical suitability, the site is fully capable of being supported by a robust evidence base. At the planning application stage, comprehensive assessments—including Flood Risk, Drainage, Landscape & Visual Impact, Ecology, Archaeology, Heritage, Contamination and Transport—would be provided to demonstrate that development can be delivered responsibly, sustainably and in accordance with both national and local planning requirements, as expected by Policy S/RRA’s clauses on mitigation, infrastructure contributions and site specific design.

For these reasons, Redrow considers that the allocation of the land east of Hauxton is necessary to secure a sound Local Plan—one that is positively prepared, justified, effective and consistent with national policy. The site represents an opportunity to deliver sustainable, landscape led development in a location that aligns with the NPPF, contributes to identified housing and affordable housing needs, and strengthens the resilience of the Plan’s housing trajectory. The site should therefore be identified within Policy S/RRA as an allocation in the rest of the rural area.

Requested Change

Redrow requests that land east of Hauxton (HELAA reference 40283) be allocated in the Local Plan with the following requirements:
• Site area: 12.44 hectares
• Indicative capacity: up to approximately 150 dwellings, including a policy compliant proportion of affordable housing and provision for self/custom build plots

This submission is supported by a Vision Document. The Connectivity/Transport and Framework Masterplan diagrams demonstrate that land east of Hauxton is physically contained by durable features, benefits from direct and safe pedestrian, cycle and public transport links to local services, and can be delivered through a landscape led masterplan that retains and strengthens green corridors, integrates SuDS, and provides extensive public open space. These attributes confirm a “grey belt” context with very limited contribution to Green Belt purposes (sprawl, coalescence, or historic setting), and show that harm can be avoided and, in places, positively remedied by creating a permanent, defensible and greener settlement edge. The scheme is immediately deliverable, supports early housing and affordable housing supply, and improves access to local facilities, thereby satisfying the NPPF’s “golden rules” for Green Belt release. On this basis, the site should be released from the Green Belt and allocated in Policy S/RRA.

Redrow requests that Policy CC/SD be revised as follows:
1. Remove the requirement for a standalone Sustainability Statement for all non householder development.
2. Specify that major developments may include the required sustainability information and evidence within an existing Planning Statement or Design and Access Statement, rather than requiring a separate document.
3. Ensure the policy is supported by robust local evidence and full whole plan viability testing prior to submission of the next draft.
4. Clarify the relationship between CC/SD and the other climate policies (CC/NZ, CC/IW, CC/CE, CC/DC) to avoid duplication and ensure applicants are not providing multiple overlapping assessments.

Object

Redrow objects to Policy CC/SD on the basis that its requirements are overly prescriptive, insufficiently justified, and risk undermining deliverability. While Redrow supports the principle of integrating climate mitigation and adaptation into new development, the policy as drafted is not proportionate, not justified by the evidence base, and duplicates other climate related policies, resulting in uncertainty for applicants.

Policy CC/SD requires a Sustainability Statement for all planning applications other than householder proposals. This requirement is excessive and unnecessary, particularly for minor development. For major applications, many of the matters listed—including climate adaptation, carbon, water, materials and waste—can be and are typically addressed within a Planning Statement or a Design and Access Statement, rather than through an additional standalone document. Requiring this for every non householder application adds administrative burden without clear justification.

The Climate Change Topic Paper (2025) does not provide the detailed, locally specific evidence needed to support such a wide ranging and open ended policy. The Topic Paper relies largely on narrative description rather than robust analysis of:

• local carbon reduction data,
• local climate risk modelling,
• water consumption trends,
• design feasibility in different settlement typologies, and
• infrastructure capacity to support the listed requirements.

As such, the Topic Paper does not demonstrate why all minor development should respond to up to nine broad sustainability themes, nor does it justify why these requirements should apply regardless of scale, site context, building type or viability considerations.

Furthermore, the Topic Paper is not supported by whole plan viability testing, despite the potentially significant cost implications of net zero carbon construction, high performance building materials, circular economy design, carbon sequestration requirements and advanced water efficiency measures. Without clear viability assessment, the policy risks imposing cost burdens that could compromise deliverability, contrary to the NPPF requirement for local plans to be both justified and effective.

Policy CC/SD also duplicates requirements contained in several other draft climate and sustainability policies, including:

• CC/NZ (Net Zero Carbon),
• CC/IW (Integrated Water Management),
• CC/CE (Circular Economy), and
• CC/DC (Designing for a Changing Climate).

This overlapping policy framework creates uncertainty for applicants about what evidence is required, what standards must be met, and how compliance will be assessed. The additional expectation to “embed” climate principles is undefined, further risking inconsistent interpretation at decision making stage.

For these reasons, Policy CC/SD fails the soundness tests:
• Not justified – insufficient evidence and no viability testing
• Not effective – unclear, duplicative, and administratively burdensome
• Not consistent with national policy – contrary to NPPF requirements for proportionality and viability

A redrafted policy is required to ensure clarity, proportionality and proper alignment with the wider climate policy suite.

Requested Change

Redrow requests that Policy CC/SD be revised as follows:
1. Remove the requirement for a standalone Sustainability Statement for all non householder development.
2. Specify that major developments may include the required sustainability information and evidence within an existing Planning Statement or Design and Access Statement, rather than requiring a separate document.
3. Ensure the policy is supported by robust local evidence and full whole plan viability testing prior to submission of the next draft.
4. Clarify the relationship between CC/SD and the other climate policies (CC/NZ, CC/IW, CC/CE, CC/DC) to avoid duplication and ensure applicants are not providing multiple overlapping assessments.

Redrow requests that Policy CC/NZ be amended as follows:
1. Introduce flexibility by replacing fixed space heating and EUI thresholds with performance targets “where technically feasible and demonstrated to be viable”, supported by site specific evidence.
2. Align targets with national policy, including the Future Homes Standard, and avoid imposing Passivhaus equivalent requirements unless justified by robust local evidence.
3. Allow compliance through multiple routes, not solely Passivhaus style modelling tools (e.g. TM54, PHPP), to accommodate a wider range of building types and construction approaches.
4. Remove the requirement for onsite renewable generation to meet all energy demand; instead require developments to maximise feasible onsite generation and supplement through local low carbon energy sources.
5. The proposed offsetting fund should be removed as it is beyond the remit of planning policy and should be left to the Building Regulations regime.
6. Ensure whole plan viability testing is carried out, and the results shared and consulted upon to enable full review of the policies in that context. This would confirm that CC/NZ can be implemented without compromising housing delivery or affordable housing provision.
7. Avoid duplication by clarifying how CC/NZ interacts with CC/SD, CC/IW, CC/DC and CC/CE, ensuring applicants only submit one coordinated set of climate related evidence.

Object

Redrow supports the overarching ambition of delivering low carbon, high performance buildings and acknowledges the important role of the construction sector in addressing the climate emergency. However, Policy CC/NZ as drafted is not justified, not proportionate, and not demonstrably deliverable, and therefore fails the NPPF tests of soundness. The policy goes significantly beyond national Building Regulations and the forthcoming Future Homes Standard and, in practice, effectively mandates Passivhaus level performance without the supporting evidence, viability testing, or technical feasibility analysis required to justify such stringent requirements.

The policy requires all new buildings to achieve specific space heating demands of 15–20 kWh/m²/yr, an Energy Use Intensity (EUI) of no more than 35 kWh/m²/yr for homes, and whole life carbon assessments for all major development. These performance levels align directly with the Passivhaus standard and are well beyond what current UK volume housebuilding supply chains, skills profiles, and typical construction methodologies are designed to deliver. Achieving these metrics would require radical changes in fabric specification, airtightness, heat recovery systems and onsite renewable energy generation, together with substantial increases in upfront construction cost—costs which would ultimately be passed on to consumers.

Crucially, the Climate Change Topic Paper (2025) does not justify the selected thresholds. It does not provide locally specific evidence demonstrating that:
• the Passivhaus level space heating targets can be met across the full range of local site conditions and housing typologies;
• the very low EUI thresholds are deliverable for dense development, apartments or homes on constrained urban sites;
• the requirements are technically feasible for complex non domestic buildings (e.g. laboratories, research facilities, healthcare and mixed use commercial units) which have fundamentally different load profiles; or
• the cumulative implications (fabric, systems, renewables and embodied carbon) have been tested through a robust whole plan viability assessment.

The Net Zero Carbon Evidence Base (2021) provides only broad recommendations and does not test the fixed Passivhaus equivalent thresholds now proposed. The 2025 Carbon Budget Assessment also does not include viability or detailed deliverability analysis of these standards. This significantly weakens the evidential foundation for the policy.

Furthermore, CC/NZ requires all heating to be provided through low carbon fuels, prohibits new gas connections, and requires developments to meet all energy demand through onsite renewable generation wherever possible. On constrained or higher density sites with limited roof space, achieving the required renewable energy output is often technically impossible, meaning many otherwise sustainable development proposals would be incapable of complying. The policy attempts to address this through an open ended energy offsetting mechanism, but the governance, accountability, cost structure and delivery mechanisms for this offsetting fund are not defined—contrary to the NPPF requirement for clear, unambiguous policy requirements—and moreover it goes beyond the remit of the planning system.

The policy also duplicates other climate related policies in the draft plan—CC/SD (Sustainable Development), CC/IW (Integrated Water Management), CC/CE (Circular Economy) and CC/DC (Designing for a Changing Climate)—resulting in overlapping requirements and uncertainty for applicants regarding what documentation is needed and what standards take precedence.

Given these concerns, Policy CC/NZ is not sound because:

• Not justified – the evidence base does not demonstrate that the proposed performance thresholds are achievable across all building types and site contexts.
• Not effective – the policy imposes requirements that are not technically or commercially deliverable for standard UK housebuilding, complex non domestic uses, or constrained sites.
• Not consistent with national policy – the policy exceeds national standards without viability evidence, contrary to the NPPF requirement for proportionate, deliverable policy burdens.
• Not positively prepared – the cumulative impacts have not been accounted for, raising risks to housing viability, affordable housing delivery and overall development rates.

For these reasons, the policy should be redrafted to ensure that net zero requirements are evidence based, feasible, proportionate and flexible, while still supporting the transition to low carbon development.

Recommended Wording Changes
Redrow requests that Policy CC/NZ be amended as follows:
1. Introduce flexibility by replacing fixed space heating and EUI thresholds with performance targets “where technically feasible and demonstrated to be viable”, supported by site specific evidence.
2. Align targets with national policy, including the Future Homes Standard, and avoid imposing Passivhaus equivalent requirements unless justified by robust local evidence.
3. Allow compliance through multiple routes, not solely Passivhaus style modelling tools (e.g. TM54, PHPP), to accommodate a wider range of building types and construction approaches.
4. Remove the requirement for onsite renewable generation to meet all energy demand; instead require developments to maximise feasible onsite generation and supplement through local low carbon energy sources.
5. The proposed offsetting fund should be removed as it is beyond the remit of planning policy and should be left to the Building Regulations regime.
6. Ensure whole plan viability testing is carried out, and the results shared and consulted upon to enable full review of the policies in that context. This would confirm that CC/NZ can be implemented without compromising housing delivery or affordable housing provision.
7. Avoid duplication by clarifying how CC/NZ interacts with CC/SD, CC/IW, CC/DC and CC/CE, ensuring applicants only submit one coordinated set of climate related evidence.