Draft Greater Cambridge Local Plan for consultation

These representations have been prepared by Pegasus Group on behalf of Cemex UK Properties Ltd in respect of their interests at Land west of Malton Road, Orwell, Cambridgeshire (‘the site’). The site is recorded under ‘Site ID: SCB2035’ within the Greater Cambridge Housing and Economic Land Availability Assessment (2022) which previously promoted a larger parcel of land for up to 150 dwellings.

These representations are submitted in response to the current Greater Cambridge Local Plan (GCLP) Regulation 18 consultation which sets out the emerging approach to accommodating growth across the shared Local Planning Authority areas of Cambridge City Council (CDC) and South Cambridgeshire District Council (SCDC) over the next plan period (2024-2045).

The purpose of these representations is primarily to respond to the relevant emerging Vision; Development Strategy; and Draft Allocations proposed by the consultation and to reaffirm the deliverability (suitability, availability and viability) of the above site alongside the provision of a site-specific policy that allocates the site for residential-led development in the emerging Local Plan.

These representations are accompanied by an Opportunities & Constraints Plan (Appendix 1), a Development Framework Plan (Appendix 2), an emerging Access Strategy (Appendix 3) and a baseline BNG assessment (Appendix 4) for the site. The Development Framework Plan has been informed by technical surveys which identify the local constraints and illustrates the opportunities presented to deliver a high-quality and sustainable residential-led development capable of contributing positively towards addressing identified housing needs and complementing the economic ambitions for Greater Cambridge.

The Vision for Greater Cambridge is to be supported and clearly sets out the ambition for a sustainable and prosperous future for the area.

The Government is clear on the importance of Cambridge internationally and to the UK economy, with successive Government’s promoting the ‘Case for Cambridge’ and the current Government reigniting plans to deliver the Oxford-Cambridge Growth Corridor. The Government has subsequently established the Cambridge Growth Company to seek to address barriers to growth and help unlock Cambridge’s full potential by 2050, including through the proposed establishment of a centrally led Development Corporation.

The level of growth proposed by the Case for Cambridge is unprecedented and it is therefore critical that the anticipated growth comes forward in a sustainable manner and delivers exemplar place-making, combining good design and sustainable transport with new employment and housing that benefits everyone.

However, as highlighted within our representations the proposed Development Strategy for achieving these goals is misguided and places too much reliance on new settlements and complex major development sites, which are in turn reliant on significant infrastructure projects to serve these new places. New infrastructure projects take time to deliver and the delays in delivery of new settlements in the Greater Cambridge area, along with the necessary strategic infrastructure are well documented, indeed necessitating the Government intervention above. It is considered that the GCLP is overly optimistic regarding the delivery timescales of many of the proposed draft allocations which represents a real risk that Greater Cambridge will fail to deliver the homes it needs within the plan period to support its economic ambitions.

As expanded on below, a more balanced approach to the spatial distribution of growth is required - one that recognises the role of villages in contributing to the overall sustainable growth of the region. The restriction of growth opportunities in villages; many of which are sustainable location such as Orwell is not in line with the guidance in the emerging NPPF and fails to recognise Group villages as being capable of playing an important role in contributing to the success of Greater Cambridge.

A more balanced approach should be taken by recognising the potential of existing Group villages, particularly those in non-Green Belt locations, to meet housing needs.

The general ambition of Draft Policy S/JH/: New Jobs and Homes is supported.

The National Planning Policy Framework (2024) seeks to significantly boost the supply of new homes (paragraph 61) informed by a local housing need assessment using the standard method in national planning guidance. Moreover, the National Planning Guidance highlights there will be circumstances where it is appropriate to consider whether actual housing need is higher than that indicated by the standard method. As highlighted within the ‘Greater Cambridge Employment and Housing Needs Updated 2024-2025 (September 2025)’, the economic-led housing need for Greater Cambridge broadly aligns with the standard method. The GCLP therefore appropriately identifies its housing needs for the period 2024-2045 based on the Government’s standard method as 2,295 net new homes per annum totalling 48,195 homes over the plan period. The GCLP anticipates that the existing allocations within the adopted 2018 plan will deliver around 37,865 homes by 2045 and as such identifies new sites to deliver the shortfall of around 13,460 new homes and provide a buffer.

It is worth noting that the ‘Case for Cambridge’ envisaged growth scenarios of between 100,000-150,000 new homes for Cambridge by 2050 – potentially doubling or even tripling the number of homes currently being planned for in the GCLP. Whilst further details are yet to be published, there is clearly a potential misalignment of the growth scenarios being planned for in GCLP. Until the Cambridge Growth Company’s plans are made public, the current approach of seeking to meet objectively assessed local housing needs in full and ensuring a buffer to overall housing provision is welcome to ensure flexibility and resilience in delivery. However, some of the sites relied upon to deliver new homes and the anticipated rate of housing delivery are challenged, as explored below under Draft Policy S/DS: Development Strategy. As highlighted below, it is critical that housing need and delivery keeps pace with anticipated jobs growth in order to deliver the economic ambitions for Greater Cambridge and the Mayor for Cambridgeshire & Peterborough’s target of tripling the size of the local economy by 2050 as set out within the Local Growth Plan (2025) .

Whilst the overall provision of housing is supported, it is noted that the supporting text to Draft Policy S/JH: New jobs and homes, provides housing requirements for neighbourhood areas as set out in Appendix D. Appendix D identifies a need for just c.23 net new homes for Orwell. Accordingly, there is an anticipation in the GCLP that some new growth will be directed to Orwell, which is supported. However, the level of anticipated growth (c. 23 net new homes) significantly underplays the role of Group villages and the potential they can play towards delivering the Vision for Greater Cambridge, as further explored under Draft Policy S/DS: Development Strategy.

The potential for villages to accommodate larger schemes can be evidenced in Orwell and other Group villages across the local plan area. In 2017 an Inspector allowed an appeal for 49 dwellings. Appeal Reference: APP/W0530/W/16/3157596 (Application Ref: S/3190/15/OL). The implications of this decision are explored in section 6 of these representations.

The Development Strategy for the Greater Cambridge Local Plan states on page 16:

“Our development strategy aims to direct development to where active and public transport is the natural choice, where green infrastructure can be delivered alongside new development, and where jobs, services and facilities can be located near to where people live.”

However, most of the proposed allocations, both existing and proposed, are in locations where the required public transport does not currently exist and the delivery of which is outside the control of the Greater Cambridge authorities. For instance, Cambourne North is reliant on the delivery of East-West Rail; Bourn Airfield is reliant on the delivery of the Cambourne to Cambridge Busway; Waterbeach is reliant on the delivery of a new railway station; and Cambridge East is reliant on the Cambridge Eastern Access busway and a potential new railway station.

Whilst there is no objection in principle to the inclusion of these particular allocations, the GCLP evidently underestimates the time involved to deliver the necessary public transport infrastructure to serve the draft allocations and overestimates the delivery rates for the associated new homes.

In respect of the first point, the GCLP states (para 2.88) that the proposed strategy is ‘heavily informed by the location of existing and committed public transport schemes’, however as highlighted above, in many instances, the funding and necessary approvals for the supporting infrastructure are still unconfirmed and therefore uncertain. The reliance on such locations for growth in favour of directing proportionate growth to established sustainable settlements is therefore unsound.

Delays to the delivery of new infrastructure and the knock-on effects for the delivery of new housing is well documented in the Greater Cambridge area. Appendix E of the Greater Cambridge Local Plan highlights a reliance on a spike in housing delivery in 2028-2030 from strategic sites such as Northstowe, which assumes some very ambitious delivery rates of up to 300 dwellings per annum (dpa) for individual parcels. However as reported by Lichfield, the mean annual build-out rates on large sites have continued to fall and now stands at c.100-188 dpa due to persistent challenging market conditions, particularly for new settlements where demand can be more muted given the absence of established communities and the slow pace of delivering supporting infrastructure.

Figure 12 of the GCLP illustrates the over-reliance now placed on new settlements in meeting housing needs. 44% of the proposed distribution in housing growth in the Greater Cambridge Local Plan is now anticipated to come forward at the new settlements, compared to 23% in the adopted Local Plan and 18% in the previous Structure Plan. The previous more balanced approach to the distribution of development is considered to be the key to Greater Cambridge’s success to date, providing inherent flexibility and resilience to ensure housing delivery continued to come forward across the Greater Cambridge area, even where

unexpected delays have been experienced at some key sites. In this context, the GCLP is considered to be overly dependent on a limited number of large and complex sites to achieve its stated strategic objective of meeting identified development needs in the plan period.

Furthermore, whilst the proposed allocation of major sites within the Cambridge Urban Area is supported in principle given the inherent sustainability of these locations, the GCLP recognises the challenges in delivering sites such as North East Cambridge in light of recent Government announcements that it will not be funding the relocation of the Cambridge Waste Water Treatment Plan (CWWTP). This has created significant uncertainty and whilst North East Cambridge is retained as a potential allocation at this Regulation 18 stage, it is considered that should no alternative funding become available ahead of the Regulation 19 stage later in 2026, it would be unsound to continue to include the site for allocation in the Plan.

With regard to the proposed allocations on the edge of Cambridge, it is also questioned whether the assumptions in the GCLP for Cambridge East are realistic given recent announcements that Marshalls has cancelled its planned move from Cambridge Airport to Cranfield. Whilst it is understood that Marshalls still aims to vacate the site by 2030 to enable the new neighbourhood at Cambridge East to come forward, this is predicated on now identifying and relocating to a new premises for its aerospace operations. Such sensitive commercial negotiations take time and accordingly the delivery trajectory for Cambridge East is considered to be similarly uncertain.

The above remarks do not seek to object in principle to the inclusion of these particular draft allocations but seek to highlight the inherent uncertainty associated with the presumed delivery rates for these major development sites which are heavily reliant on new public transport infrastructure provision to serve them; or are subject to unresolved viability constraints; or subject to factors outside the control of the planning system, all of which take time to resolve. These draft allocations will undoubtedly take longer to deliver than anticipated and it is therefore essential for the GCLP to allocate additional suitable and sustainable sites to ensure identified housing needs are addressed now and to support the ambitious economic growth objectives for the Greater Cambridge area.

Cumulatively Group villages can play a crucial role in ensuring an achievable level of growth through the plan period as they do not have the infrastructure and delivery uncertainties associated with urban extensions.

Proposed Alternative Development Strategy – Role of Sustainable Group Villages

The above demonstrates the uncertainties associated with the proposed Development Strategy and the need to allocate additional suitable and sustainable sites to make up the anticipated shortfall in housing delivery within the plan period.

As highlighted at paragraph 2.26 of the GCLP, meeting the requirement for new homes and jobs brings the need to support development with the right infrastructure. However, the GCLP is currently overly reliant on potential new public transport infrastructure which will take time to deliver (if approved). A more balanced approach would be to recognise the role of existing Group villages which have sustainable credentials. Such locations are evidently capable of contributing positively to the development needs for Greater Cambridge.

The Development Strategy is driven by the stated objective to protect the Green Belt. Whilst this approach is now floored given the identification of Grey Belt in the Dec 2024 and emerging NPPFs the strategy should have a focus in identifying Group villages especially if they are located in non-Green Belt locations such as Orwell. These non-green belt Group villages should be given a greater scope for larger development given this advantage.

The GCLP is not planning positively to meet its identified needs as required by national planning policy (para 36) and has failed to consider all reasonable options for meeting its identified needs in a sustainable way, including directing growth to the villages especially in non Green Belt Locations. It is our view therefore that directing appropriate growth towards sustainable villages such as Orwell which also benefits from a non-Green Belt location, aligns with the national planning policy objective to promote sustainable patterns of development.

The previous Local Plan adopted a similar approach with an emphasis on growth at the major settlements. Subsequently, our interrogation of the supply suggests the authority has not maintained a 5 YHLS during the plan period to date. At the time of writing this report we consider that the authority would not be able to evidence a 5-year supply for based on the latest evidence and applications.

The previous local plan's restrictions on housing numbers in Group villages should be reconsidered, as many larger developments have been approved to enhance village vitality.

Group villages not in the green belt should be elevated in the hierarchy, considering the need for development opportunities outside protected areas.

The proposed Settlement Hierarchy is generally supported in terms of the settlements identified in each level however the level of development identified for each tier of the hierarchy is not supported.

As set out earlier in these representations there is an over reliance in the strategy on placing the majority of new housing growth at major urban extensions and new settlements which potentially take years to come forward. A more balanced approach to development would accord with the emerging NPPF (2025). Emerging NPPF Policies S5 and HO6 are relevant in this context. The relevant policy references to allowing development outside of development frameworks and encouraging local plans to deliver a diverse range of sites are set out below:
S5: Principle of Development outside settlements

Only certain forms of development should be approved outside settlements, as set out in the following list. These should be approved, unless the benefits of doing so would be substantially outweighed by any adverse effects, when assessed against the national decision-making policies in this Framework:

i. The development of land allocated for that purpose in the development plan (where this lies outside settlements); and
j. Development which would address an evidenced unmet need (including, but not limited to, development proposals involving the provision of housing where the local planning authority cannot demonstrate a five year supply of deliverable housing sites or scores below 75% in the most recent Housing Delivery Test and where the development would:
i. be well related to an existing settlement (unless the nature of the development would make this inappropriate) and be of a scale which can be accommodated taking into account the existing or proposed availability of infrastructure.
HO6: Planning for a diverse mix of sites

1. To support the provision of a diverse mix of sites, local plans should:
a. Allocate land to accommodate at least 10% of the housing requirement on sites no larger than one hectare, and a further 10% on sites of between one and two and a half hectares, unless there are strong reasons why these targets cannot be achieved; and
b. Allocate sites which will support and enhance the vitality of rural communities and enable villages to grow and thrive, especially where this will support local services.
(our underlining)

The emerging NPPF seeks to ensure Local Authorities have a balanced approach to new housing delivery including the allocation of sites outside of development frameworks at villages to support local services, meet local housing needs and to help villages thrive. Subsequently there should be no development restriction placed on Group villages.

Development proposals should be assessed on their merits including the suitability of the site and the villages’ sustainable credentials. The emerging NPPF does not reference the need to set restrictive development caps in rural areas.

It is more than likely that this Local Plan will be assessed under the emerging NPPF including the new development control policies therefore this consultation needs to apply the Government’s approach as set out in the consultation draft.

The previous local plan has a similar restriction of 8 dwellings (15 on brownfield) on sites located inside the framework of the group village. However, there are numerous examples across all the Group Villages of where developments have exceeded this level of growth and a wide number of larger sites approved which adjoining the village outside of the framework. Many of these developments including the scheme allowed in Orwell for 49 units were approved at appeal with Inspectors placing the delivery of housing and improvement of the vitality of villages and their services as a key justification for allowing the appeal. This approach now fully aligns with he aims of the emerging NPPF and notably Policy HO6.

The settlement hierarchy should also reflect the importance of meeting local housing needs in rural locations. Housing growth is important for maintaining village communities. Villages development provided opportunities to meet local housing needs for local people and allows people to be able to stay in their communities. Spreading growth through the hierarchy helps all areas to deliver a balanced regional development which helps all parts of the Local Authority area to thrive – not just urban centres.

Without appropriate scale new housing rural villages can also experience population decline as younger people move away in seek of affordable housing (The average house price in Orwell is over £600,000 which emphasises the need for a better choice of housing in the village). This leaves behind an aging population.

Housing growth also sustains services such as schools, shops, post offices, pubs etc. New population keeps these services viable. Growth also assists in the local economy through the construction period and beyond. It allows people to work from home or run rural enterprises and work in the rural area.

There may also need to be development in villages to support community developments for new village facilities such as football pitches, a village hall, new open space, allotments and other much needed facilities. If development is restricted, it is unlikely this would be sufficient to make any such development viable. Suitable allocations should be made in Group villages to address this need and restrictions of development inside the framework should be removed.

We would also argue that Group villages not located in the green belt should sit one stage higher in the hierarchy. With the emphasis on the plan to protect the green belt (although a review of Grey Belt land now being required as part of the site assessment) the opportunities to develop in villages outside the green belt should be considered within the hierarchy.

A more balanced delivery approach is required which also meets the requirements of the emerging NPPF which requires authorities plan for a diverse mix of sites across the Local Plan region. This is likely to be the framework which will be in place by the time this Plan reaches Public Examination

Orwell represents a viable option for a housing allocation of a suitable scale. The previous assessment of the site through the SHLAA process identified the site had no constraints to its development and would be available to develop in the short term. The village is also located in a non-green belt location.

Allocation of Land west of Malton Road, Orwell

Given our desire to see a more balanced approach to housing delivery we are seeking the allocation of last to the west of Malton Road Orwell with a fully policy complaint scheme of up to 75 dwellings with associated over provision of open space; play area and the potential to deliver a football pitch for the village given that Orwell FC currently play their home matches in Royston.

The proposed site is accessed from Malton Road (See Appendix 3) and is well related to the village and a short walking distance from the High Street where many of the villages’ services are found. In terms of constraints there is nothing really that impacts on a potential development of the site:

• The land is in ownership of Cemex and is ready to be developed immediately.
• Orwell is a non-Green Belt location.
• The entire site if flat agricultural land and is entirely in Flood Zone 1.
• The site is not constrained by any heritage or ecology designations or assets.
• The site is well related to the village opposite existing employment use and can be easily lined to the High Street via a new footpath/cycleway
• The site is a mix of Grade 2 & 3 Agricultural Land
• Reduction in site area (from previous SHLAA promotion) to 5.23ha/75 units had reduced its overall scale to one more appropriate for a village of this size and services.
• There is a lack of high-quality habitats on site (See Appendix 4)

The previous site promotion to the HELAA identified are larger area for potential development (8.78 ha) over two phases. The overall assessment of the site scored very well as a residential site identifying that it has no constraints to development, could be delivered early in the plan period and would be attractive to the market. Despite these positive assessments ratings which can also be applied to this latest submission scheme, the site was not considered as a potential allocation due to the overall scale of the development.

This latest promotion scheme significantly reduces the sites development potential to a maximum of 75 dwellings by reducing a large proportion of the western part of the site which will be retained in agriculture. This represents a more realistic scale of development for the village whilst retaining an overprovision of open space along the lines of the scheme which was approved in the village at Hurdleditch Road for 49 dwellings.

Whilst it is recognised at the time of the appeal that SCDC could not demonstrate a 5-year supply of houses it is still relevant how the Inspector assessed the suitability of this scheme of development in the village based on its sustainability. In allowing the appeal the Inspector confirmed the sustainable credentials of the site:

• There is no conflict with Policy ST/6 limiting residential development to 8 dwelling within village frameworks as the site was located outside the framework. (at Para. 14)
• ‘In terms of shops and services, Orwell contains a village store (including post office), a public house, a hairdresser, a village hall, church hall, some recreation facilities and a mobile library service. Whilst located just outside of the village framework, the proposal would be within reasonable walking distance of facilities within the village. Such facilities would be unlikely to fully cater for the day-to-day needs of residents of the village including those of the proposed development. Nevertheless, whilst being limited I consider that they provide a reasonable level of facilities providing residents with the opportunity for some day to day needs to be met without needing to travel by car.’ (Para. 16)
• ‘….the site is located adjacent to Petersfield Primary School which has capacity to accommodate the primary school needs of the proposed development. There is a secondary school in nearby Bassingbourn which also has sufficient capacity and is accessible from the village via a school bus service operating from the village. Access to early years and sixth form education provision would be more limited, but overall, the site has reasonably good access to local education provision.’
• ‘In terms of the opportunity to access other facilities by public transport, the proposal includes provision for two new bus stops to be provided on Hurdleditch Road close to the site. This would provide access via bus to Cambridge, though such provision would be constrained by the limited frequency of buses. Other bus services to nearby centres would also be available but their use would also be constrained by the infrequency of services.’ (Para. 20)
• ‘Further opportunities for travel by rail would be available from the nearby railway station at Shepreth with reasonably regular services on the Cambridge to London line, including stops at Royston, Hitchin and Stevenage….’ (Para. 21)

The proposed site offers the opportunity to deliver a similar scheme in a village location, which the Inspector considered would allow for some travel by public transport and within the village to local services.

The proposed scheme lies outside the village framework so the restriction on capacity of development is not relevant albeit we are seeking the site to be allocated in any instance.

The allocation would meet the requirements of the emerging NPPF in respect of Policy HO6 (b) Planning for a diverse mix of sites as referenced earlier. It also is located in a non-Green Belt location therefore not caught by Policy GB6: Control of development in the Green Belt.

The site has been subject to several preliminary studies to support this representation:

Design/Landscape

The indicative masterplan which accompanies these representations provides an indication of how the site could be delivered for the proposed 75 dwellings. The built form would be located closest to the existing village framework boundary and front onto Malton Road.

The layout will be served off a single spine road served off a new access from Malton Road. The site will benefit from landscaping around the whole site and a significant over provision of landscaping; play space and potential formal sports pitch (or pitches) to the south of the proposed residential layout.

The scheme will be relatively low density and provide a high-quality residential environment.

Highways

The proposed access to the site has been positioned after a full engineering review taking into account existing access points nearby. The junction is sufficient to serve the development.

A new footpath/cycle path will be delivered from the site along Malton Road to the High Street to allow pedestrian and cycle access to the local facilities.

Ecology/BNG

An initial assessment has identified that the site does not contain any primary habitats. It contains hedgerows, trees and arable farmland.

These findings indicate that the 10% BNG requirement will be fully delivered on site rather than through offsite credits.

The site in Orwell to be allocated for 75 dwellings

Further to information already provided I am providing additional informaiton for the site we are promoting off Malton Road, Orwell.