Draft Greater Cambridge Local Plan for consultation

Revise calculation of housing need to take into account Government ambitions for
Greater Cambridge, including the creation of and funding for the Cambridge Growth
Company

Over-Reliance on Major Settlements
The Development Strategy of the draft Local Plan is reliant on high levels of housing delivery in major strategic sites to such an extent that the risk that housing need is not met is excessively high and the draft Local Plan is therefore unsound.
There are fundamental issues with the distribution of housing growth across the Plan Period.
The Councils are distributing 44% of growth across the Plan Period in new settlements, and 29% in major sites on the edge of Cambridge which are similar to new settlements (Figure 12 of the Local Plan). Combined, 73% of growth is allocated to major strategic sites.
The table below sets out the distribution of growth during the Plan Period across these new settlements and whether these have planning permission.
Table 3.1: Delivery of new strategic sites during the emerging Plan Period
Site Number of Homes to be delivered in Plan Period Total number of dwellings Extant permission Percentage of homes delivered during Plan Period
Northstowe* 6,229 10,107 Yes 62%
Waterbeach New Town* 5,727 11,531 Yes 50%
Bourn Airfield 3,500 3,500 Yes 100%
North East Cambridge 3,950 4,925 No 50%
Cambourne North 2,550 13,000 No 20%
Grange Farm New Settlement 2,550 6,000 No 43%
*Northstowe has delivered 1,401 dwellings prior to this emerging Plan Period. Waterbeach New Town has delivered 556 dwellings prior this emerging Plan Period.

The following table sets out the proposed housing trajectory of the new strategic sites which do not currently have extant consent during the emerging Local Plan timeframe.
Table 3.2: Proposed housing trajectory for new strategic sites without extant consent (2024/25-2044/45)
New Settlement 24/25-31/32 32/33 33/34 34/35 35/36 36/37 37/38 38/39 39/40 40/41 41/42 42/43 43/44 44/45
North East Cambridge 0 50 150 250 350 350 350 350 350 350 350 350 350 350
Cambridge East 0 50 150 250 350 350 350 350 350 350 350 350 350 350
Cambourne North 0 0 0 50 100 150 200 250 300 300 300 300 300 300
Grange Farm 0 0 0 50 100 150 200 250 300 300 300 300 300 300
Totals 0 100 300 600 900 1000 1100 1200 1300 1300 1300 1300 1300 1300

It is not considered that the delivery rates for these sites are realistic, particularly with regard to the new sites which are yet to have been granted planning permission:
• North East Cambridge.
• Cambridge East.
• Cambourne West.
• Grange Farm.
In the latest ‘Start to Finish’ Report, undertaken by Lichfields in 2024 , it confirms that sites comprising over 1,000 dwellings will take, on average, five years to obtain detailed planning permission and then a further 1.3-1.6 years to deliver the first dwelling.
Indeed, for sites over 2,000 dwellings, it states that the median timescale from validation of the first planning application to the completion of the first dwelling is 6.7 years.
The Councils’ Local Development Scheme anticipates that the emerging Local Plan will be submitted to the Secretary of State for examination in December 2026. In July 2024 (after their General Election win), the new Minister for Housing, Matthew Pennycook, wrote to the Planning Inspectorate and noted that the average length of time for the completion of examination had increased from 65 weeks on average in 2016 to 134 weeks on average in 2022 (approximately 2 ½ years) .
Therefore, if the Plan were submitted to the Secretary of State in December 2026, then the earliest that the Plan is likely to be adopted is May 2029, using the data above. That would be equivalent to ‘Year 6’ (2029/2030) in the proposed housing trajectory.
If these new sites were to be approved in Year 6 (2029/30), then the earliest that the first house could be delivered according to the Lichfields ‘Start to Finish’ is in Year 12 (2035/2036). It is therefore unrealistic that the first dwellings will be delivered in North East Cambridge and Cambridge East in 2032/33 and in 2034/35 in Cambourne North and Grange Farm.
The current housing trajectory figures are overly ambitious for new strategic sites. There would be a reduction in 3,000 homes across the Plan Period which would not be delivered on new strategic sites.
Therefore, in order to meet this shortfall, the Councils should focus on providing a range of sites including smaller and medium sized sizes in and adjoining existing settlements, especially ones that have a number of services and facilities.
The Councils’ housing trajectory also reliant on the new strategic sites delivering 350 dwellings per annum. This is equivalent to seven plots delivering 50 dwellings per annum, by several housebuilders.
The Lichfields ‘Start to Finish’ document also sets out the housing completions of large sites. The table below sets out the average delivery of sites which are for over 5,000 dwellings across the years.
Table 3.2: Table of average housing delivery on sites larger than 5,000 dwellings
Site Name No of Dwellings No of Years of Delivery Average Delivery (rounded)
Former Alconbury Weald, Huntingdon 5,000 2 208
Priors Hall, Northamptonshire 5,200 11 135
North West Preston 5,300 8 290
East Kettering SUE 5,500 6 133
Sherford, South Hams 5,500 7 119
South Ashford Garden Community 5,750 2 75
Houlton (Rugby Radio Station) 6,200 3 139
The Hamptons (Peterborough) 6,320 25 224
Ebbsfleet 15,000 14 255

Therefore, the table above demonstrates that none of these new settlements achieved, on average, 350 dwellings per annum. Therefore, there should be a greater focus on delivering the required housing across sustainable settlements.
There are also concerns about the principle of the development at North East Cambridge, Cambridge East, Cambourne North and Grange Farm, although it is noted that the Councils acknowledge that North East Cambridge may not be available due to the Government withdrawing funding for the wastewater treatment relocation.
Regarding Cambridge East (the existing Cambridge Airport), in October 2025, Marshall Group confirmed that they were not relocating to Cranfield Airport, in Bedfordshire, as it was considered “no longer affordable ”.
Since then, there has been no public reporting or statements setting out when Marshall Group intends to vacate the Site. Therefore, it is uncertain whether the emerging Local Plan can be reliant on these dwellings during the Local Plan period.
With respect to Cambourne North, the delivery of the settlement extension is principally reliant on the proposed new station that will be delivered as part of East West Rail.
Although it is acknowledged that in June 2025, as part of the spending review, the Government committed a further £2.5 billion for the continued delivery of East West Rail, there is not a certainty that this will be delivered. This Government is fully committed to the delivery of East West Rail but there are no guarantees that a future government would be as committed. Therefore, the emerging Local Plan should focus more growth in Rural/Minor Rural Centres.
Regarding Grange Farm, there is concern that there is currently no infrastructure and none planned, with the scheme wholly reliant on an extension to CSET which is currently not in the project scope. The delivery of CSET is not within the control of the LPA or the site promotors.
The Deliverability Paper that was submitted for Grange Farm as part of the previous ‘call for sites’, confirms that 3,560 dwellings (market and affordable) can be delivered during the emerging Local Plan period with the first dwellings being delivered in 2030.
The Councils’ housing trajectory states that only 2,550 dwellings can be during the Plan Period, so our client would question how accurate these figures are by both the Councils and the promoter for Grange Farm.
There is also a discrepancy between the number in the Housing Trajectory provided by the Council (up to 300 dwellings in 2040) and only 275 dwellings in the Housing Deliverability Note . Therefore, it is not clear that the Council will be able to deliver that number of dwellings across the Plan Period.
In total, as set out in Figure 12 of the emerging Local Plan above, new settlements and edge of Cambridge sites will provide 73% of the total housing supply. Given the timings set out in the Lichfields ‘Start to Finish’ report, there is a severe risk of delay in delivering a significant number of Greater Cambridge’s housing sites, which will mean that the Councils will not be able to meet their housing needs across the Plan Period. If the Councils cannot demonstrate a five-year housing land supply or has a housing delivery percentage of less than 75%, set out in the Government’s Housing Delivery Test, then the Plan would be considered out of date. It would, therefore, be subject to paragraph 11 of the NPPF (2024) and attract speculative development.
In order to avoid this scenario and to ensure as far as possible a plan-led system can be successfully implemented and delivered, sites are needed that can help the Council deliver a consistent and deliverable supply of housing across the Plan Period, reducing the risk of the Council not being able to meet its housing needs, thereby attracting speculative development.
A greater mix of smaller and medium sized sites would help to ensure that in future Greater Cambridge is able to demonstrate a five-year supply of housing land. Smaller and medium sized sites typically come forward quicker that new large strategic sites which require significant infrastructure to support them. A good mix of these smaller sized sites also enables a wider range of house builders to enter the market providing a wider range in product and often leading to an increase in local employment.
Homes in Rural Areas
Policy S/DS takes no account of the sustainability benefits of locating some appropriately-sized development within or adjacent to existing villages in South Cambridgeshire.
Villages of all sizes with South Cambridgeshire benefit from increases in the housing stock: those with links to village can remain or return, new residents can find homes, the usage of local shops, community facilities and schools is increased. This maintains the resilience of established communities.
The Country Landowner’s Association’s report Sustainable Communities: the Role of Housing in Strengthening the Rural Economy (2022) states:
‘For rural areas to thrive, there needs to be an adequate, available, and diverse supply of homes, which includes different tenure types of varying sizes. The existing lack of homes in rural areas prevents young families to continue living in their community, key workers to be based near to their places of work and the elderly to downsize.’
However, the draft Local Plan makes allocations for just 265 homes on four sites adjacent to existing villages (Duxford, Highfields, and Melbourn).
This is the outcome of a fundamental flaw in the framing of the hierarchy of locations within this policy, which states that ‘jobs and homes will be met as far as possible in the following order of preference’. The hierarchy reflects an approach to sustainability that gives predominant weight to environmental factors, notably transport emissions, to the detriment of the social sustainability of existing settlements. Following this sequential hierarch leads the draft Local Plan to maximise allocations in locations in and around Cambridge as well as at new strategic sites. Only a small residual of housing need is allocated to villages, whereas there is localised housing need within almost all communities in the plan area, as regular village-level surveys show.
By failing to allocate new housing to existing villages, and ignoring the social impact of this, the draft Local Plan does not fully achieve sustainable development as defined in the NPPF.
Development of the site at Valley Farm, Meldreth would contribute to the social sustainability of the villages of Meldreth and Melbourn.
Five Year Housing Land Supply and Housing Trajectory
The Development Strategy of the draft Local Plan is underpinned by the Housing Trajectory set out in draft Appendix E. This anticipates that the local housing need (standard method) annual number of 2,309 is not achieved between 2024/25 and 2027/28, in 2032/32 or in the final four years of the plan period. For the years 2028/29 and 2029/30, anticipated completions are significantly higher, at 3,483 and 3,530 respectively. This results in a predicted number of completions for 2028-2033 of 14,427 units, which equates to a five-year supply of 5.32 years.
Analysis of the projected completions for individual sites suggests that the above anticipated completions numbers are based on estimates of completions on strategic sites for 2028/29 and 2029/30 are that are significantly above historic maximums and that do not take into account the planning context of each site.
At North West Cambridge, completion of the final Phase 1 dwellings permitted under the 2013 outline is expected in 2028. The outline application for future phases is currently under consideration and is unlikely to be approved before late 2026, with reserved matters to follow. It is therefore implausible that 305 and 376 dwellings can be delivered in 2028/29 and 2029/30 respectively. A more reasonable assumption might be 100 per year, as the trajectory anticipate for most of the 2030s.
At Northstowe, the historic maximum annual delivery was in 2018/19, when 278 dwellings were completed. Only 92 dwellings were completed in 2023/2024 (on both Phase 1 and Phase 2). Phase 1 is now almost complete and Phase 2 has 706 dwellings permitted. It is therefore implausible that 473 and 467 dwellings can be delivered in 2028/29 and 2029/30 respectively. A more reasonable assumption might be 300 per year, as the trajectory anticipate for 2030 onwards.
At Waterbeach New Town, 263 dwellings were completed in 2022/23, with completions declining since then. It is unlikely that 376 and 368 dwellings can be delivered in 2028/29 and 2029/30 respectively. A more reasonable assumption might be 300 per year, as the trajectory anticipate for 2030 onwards.
If the above reasonable adjustments are made to the housing trajectory in Appendix E, the number of predicted completions is reduced by 965 and the five-year supply for 2028-2033 falls to 4.96
It is also noted that the housing trajectory relies on historically high delivery rates in 2028/29 and 2029/30 for four further major previously allocated strategic sites: North East Cambridge, Darwin Green, Cambridge East (Marleigh and Land north of Cherry Hinton), and Cambourne West.
Given historic experience of both general and site-specific causes of delays and reductions in delivery rates, notably the delivery of major infrastructure, it is not credible to assume that seven major strategic sites will all be able to deliver at historically exceptional rates.
In order to reduce reliance on uncertain major sites and increase the likelihood that overall completion rates will be close to or exceed standard method need over the first 5-10 years of the plan period, the draft Local Plan should make significant additional allocations for smaller developments close to existing settlements and that do not require enabling infrastructure investment.
The site at Valley Farm, Meldreth is available immediately and can deliver housing within the early years of the plan period.
[on behalf of Granta Land Ltd - Land at Valley Farm, Meldreth [130982]]

Combine Melbourn and Meldreth a single settlement for the purposes of this policy. Designate Melbourn and Meldreth as a Rural Centre.

Over-Reliance on Major Settlements
The Development Strategy of the draft Local Plan is reliant on high levels of housing delivery in major strategic sites to such an extent that the risk that housing need is not met is excessively high and the draft Local Plan is therefore unsound.
There are fundamental issues with the distribution of housing growth across the Plan Period.
The Councils are distributing 44% of growth across the Plan Period in new settlements, and 29% in major sites on the edge of Cambridge which are similar to new settlements (Figure 12 of the Local Plan). Combined, 73% of growth is allocated to major strategic sites.
The table below sets out the distribution of growth during the Plan Period across these new settlements and whether these have planning permission.
Table 3.1: Delivery of new strategic sites during the emerging Plan Period
Site Number of Homes to be delivered in Plan Period Total number of dwellings Extant permission Percentage of homes delivered during Plan Period
Northstowe* 6,229 10,107 Yes 62%
Waterbeach New Town* 5,727 11,531 Yes 50%
Bourn Airfield 3,500 3,500 Yes 100%
North East Cambridge 3,950 4,925 No 50%
Cambourne North 2,550 13,000 No 20%
Grange Farm New Settlement 2,550 6,000 No 43%
*Northstowe has delivered 1,401 dwellings prior to this emerging Plan Period. Waterbeach New Town has delivered 556 dwellings prior this emerging Plan Period.

The following table sets out the proposed housing trajectory of the new strategic sites which do not currently have extant consent during the emerging Local Plan timeframe.
Table 3.2: Proposed housing trajectory for new strategic sites without extant consent (2024/25-2044/45)
New Settlement 24/25-31/32 32/33 33/34 34/35 35/36 36/37 37/38 38/39 39/40 40/41 41/42 42/43 43/44 44/45
North East Cambridge 0 50 150 250 350 350 350 350 350 350 350 350 350 350
Cambridge East 0 50 150 250 350 350 350 350 350 350 350 350 350 350
Cambourne North 0 0 0 50 100 150 200 250 300 300 300 300 300 300
Grange Farm 0 0 0 50 100 150 200 250 300 300 300 300 300 300
Totals 0 100 300 600 900 1000 1100 1200 1300 1300 1300 1300 1300 1300

It is not considered that the delivery rates for these sites are realistic, particularly with regard to the new sites which are yet to have been granted planning permission:
• North East Cambridge.
• Cambridge East.
• Cambourne West.
• Grange Farm.
In the latest ‘Start to Finish’ Report, undertaken by Lichfields in 2024 , it confirms that sites comprising over 1,000 dwellings will take, on average, five years to obtain detailed planning permission and then a further 1.3-1.6 years to deliver the first dwelling.
Indeed, for sites over 2,000 dwellings, it states that the median timescale from validation of the first planning application to the completion of the first dwelling is 6.7 years.
The Councils’ Local Development Scheme anticipates that the emerging Local Plan will be submitted to the Secretary of State for examination in December 2026. In July 2024 (after their General Election win), the new Minister for Housing, Matthew Pennycook, wrote to the Planning Inspectorate and noted that the average length of time for the completion of examination had increased from 65 weeks on average in 2016 to 134 weeks on average in 2022 (approximately 2 ½ years) .
Therefore, if the Plan were submitted to the Secretary of State in December 2026, then the earliest that the Plan is likely to be adopted is May 2029, using the data above. That would be equivalent to ‘Year 6’ (2029/2030) in the proposed housing trajectory.
If these new sites were to be approved in Year 6 (2029/30), then the earliest that the first house could be delivered according to the Lichfields ‘Start to Finish’ is in Year 12 (2035/2036). It is therefore unrealistic that the first dwellings will be delivered in North East Cambridge and Cambridge East in 2032/33 and in 2034/35 in Cambourne North and Grange Farm.
The current housing trajectory figures are overly ambitious for new strategic sites. There would be a reduction in 3,000 homes across the Plan Period which would not be delivered on new strategic sites.
Therefore, in order to meet this shortfall, the Councils should focus on providing a range of sites including smaller and medium sized sizes in and adjoining existing settlements, especially ones that have a number of services and facilities.
The Councils’ housing trajectory also reliant on the new strategic sites delivering 350 dwellings per annum. This is equivalent to seven plots delivering 50 dwellings per annum, by several housebuilders.
The Lichfields ‘Start to Finish’ document also sets out the housing completions of large sites. The table below sets out the average delivery of sites which are for over 5,000 dwellings across the years.
Table 3.2: Table of average housing delivery on sites larger than 5,000 dwellings
Site Name No of Dwellings No of Years of Delivery Average Delivery (rounded)
Former Alconbury Weald, Huntingdon 5,000 2 208
Priors Hall, Northamptonshire 5,200 11 135
North West Preston 5,300 8 290
East Kettering SUE 5,500 6 133
Sherford, South Hams 5,500 7 119
South Ashford Garden Community 5,750 2 75
Houlton (Rugby Radio Station) 6,200 3 139
The Hamptons (Peterborough) 6,320 25 224
Ebbsfleet 15,000 14 255

Therefore, the table above demonstrates that none of these new settlements achieved, on average, 350 dwellings per annum. Therefore, there should be a greater focus on delivering the required housing across sustainable settlements.
There are also concerns about the principle of the development at North East Cambridge, Cambridge East, Cambourne North and Grange Farm, although it is noted that the Councils acknowledge that North East Cambridge may not be available due to the Government withdrawing funding for the wastewater treatment relocation.
Regarding Cambridge East (the existing Cambridge Airport), in October 2025, Marshall Group confirmed that they were not relocating to Cranfield Airport, in Bedfordshire, as it was considered “no longer affordable ”.
Since then, there has been no public reporting or statements setting out when Marshall Group intends to vacate the Site. Therefore, it is uncertain whether the emerging Local Plan can be reliant on these dwellings during the Local Plan period.
With respect to Cambourne North, the delivery of the settlement extension is principally reliant on the proposed new station that will be delivered as part of East West Rail.
Although it is acknowledged that in June 2025, as part of the spending review, the Government committed a further £2.5 billion for the continued delivery of East West Rail, there is not a certainty that this will be delivered. This Government is fully committed to the delivery of East West Rail but there are no guarantees that a future government would be as committed. Therefore, the emerging Local Plan should focus more growth in Rural/Minor Rural Centres.
Regarding Grange Farm, there is concern that there is currently no infrastructure and none planned, with the scheme wholly reliant on an extension to CSET which is currently not in the project scope. The delivery of CSET is not within the control of the LPA or the site promotors.
The Deliverability Paper that was submitted for Grange Farm as part of the previous ‘call for sites’, confirms that 3,560 dwellings (market and affordable) can be delivered during the emerging Local Plan period with the first dwellings being delivered in 2030.
The Councils’ housing trajectory states that only 2,550 dwellings can be during the Plan Period, so our client would question how accurate these figures are by both the Councils and the promoter for Grange Farm.
There is also a discrepancy between the number in the Housing Trajectory provided by the Council (up to 300 dwellings in 2040) and only 275 dwellings in the Housing Deliverability Note . Therefore, it is not clear that the Council will be able to deliver that number of dwellings across the Plan Period.
In total, as set out in Figure 12 of the emerging Local Plan above, new settlements and edge of Cambridge sites will provide 73% of the total housing supply. Given the timings set out in the Lichfields ‘Start to Finish’ report, there is a severe risk of delay in delivering a significant number of Greater Cambridge’s housing sites, which will mean that the Councils will not be able to meet their housing needs across the Plan Period. If the Councils cannot demonstrate a five-year housing land supply or has a housing delivery percentage of less than 75%, set out in the Government’s Housing Delivery Test, then the Plan would be considered out of date. It would, therefore, be subject to paragraph 11 of the NPPF (2024) and attract speculative development.
In order to avoid this scenario and to ensure as far as possible a plan-led system can be successfully implemented and delivered, sites are needed that can help the Council deliver a consistent and deliverable supply of housing across the Plan Period, reducing the risk of the Council not being able to meet its housing needs, thereby attracting speculative development.
A greater mix of smaller and medium sized sites would help to ensure that in future Greater Cambridge is able to demonstrate a five-year supply of housing land. Smaller and medium sized sites typically come forward quicker that new large strategic sites which require significant infrastructure to support them. A good mix of these smaller sized sites also enables a wider range of house builders to enter the market providing a wider range in product and often leading to an increase in local employment.
Homes in Rural Areas
Policy S/DS takes no account of the sustainability benefits of locating some appropriately-sized development within or adjacent to existing villages in South Cambridgeshire.
Villages of all sizes with South Cambridgeshire benefit from increases in the housing stock: those with links to village can remain or return, new residents can find homes, the usage of local shops, community facilities and schools is increased. This maintains the resilience of established communities.
The Country Landowner’s Association’s report Sustainable Communities: the Role of Housing in Strengthening the Rural Economy (2022) states:
‘For rural areas to thrive, there needs to be an adequate, available, and diverse supply of homes, which includes different tenure types of varying sizes. The existing lack of homes in rural areas prevents young families to continue living in their community, key workers to be based near to their places of work and the elderly to downsize.’
However, the draft Local Plan makes allocations for just 265 homes on four sites adjacent to existing villages (Duxford, Highfields, and Melbourn).
This is the outcome of a fundamental flaw in the framing of the hierarchy of locations within this policy, which states that ‘jobs and homes will be met as far as possible in the following order of preference’. The hierarchy reflects an approach to sustainability that gives predominant weight to environmental factors, notably transport emissions, to the detriment of the social sustainability of existing settlements. Following this sequential hierarch leads the draft Local Plan to maximise allocations in locations in and around Cambridge as well as at new strategic sites. Only a small residual of housing need is allocated to villages, whereas there is localised housing need within almost all communities in the plan area, as regular village-level surveys show.
By failing to allocate new housing to existing villages, and ignoring the social impact of this, the draft Local Plan does not fully achieve sustainable development as defined in the NPPF.
Development of the site at Valley Farm, Meldreth would contribute to the social sustainability of the villages of Meldreth and Melbourn.
Five Year Housing Land Supply and Housing Trajectory
The Development Strategy of the draft Local Plan is underpinned by the Housing Trajectory set out in draft Appendix E. This anticipates that the local housing need (standard method) annual number of 2,309 is not achieved between 2024/25 and 2027/28, in 2032/32 or in the final four years of the plan period. For the years 2028/29 and 2029/30, anticipated completions are significantly higher, at 3,483 and 3,530 respectively. This results in a predicted number of completions for 2028-2033 of 14,427 units, which equates to a five-year supply of 5.32 years.
Analysis of the projected completions for individual sites suggests that the above anticipated completions numbers are based on estimates of completions on strategic sites for 2028/29 and 2029/30 are that are significantly above historic maximums and that do not take into account the planning context of each site.
At North West Cambridge, completion of the final Phase 1 dwellings permitted under the 2013 outline is expected in 2028. The outline application for future phases is currently under consideration and is unlikely to be approved before late 2026, with reserved matters to follow. It is therefore implausible that 305 and 376 dwellings can be delivered in 2028/29 and 2029/30 respectively. A more reasonable assumption might be 100 per year, as the trajectory anticipate for most of the 2030s.
At Northstowe, the historic maximum annual delivery was in 2018/19, when 278 dwellings were completed. Only 92 dwellings were completed in 2023/2024 (on both Phase 1 and Phase 2). Phase 1 is now almost complete and Phase 2 has 706 dwellings permitted. It is therefore implausible that 473 and 467 dwellings can be delivered in 2028/29 and 2029/30 respectively. A more reasonable assumption might be 300 per year, as the trajectory anticipate for 2030 onwards.
At Waterbeach New Town, 263 dwellings were completed in 2022/23, with completions declining since then. It is unlikely that 376 and 368 dwellings can be delivered in 2028/29 and 2029/30 respectively. A more reasonable assumption might be 300 per year, as the trajectory anticipate for 2030 onwards.
If the above reasonable adjustments are made to the housing trajectory in Appendix E, the number of predicted completions is reduced by 965 and the five-year supply for 2028-2033 falls to 4.96
It is also noted that the housing trajectory relies on historically high delivery rates in 2028/29 and 2029/30 for four further major previously allocated strategic sites: North East Cambridge, Darwin Green, Cambridge East (Marleigh and Land north of Cherry Hinton), and Cambourne West.
Given historic experience of both general and site-specific causes of delays and reductions in delivery rates, notably the delivery of major infrastructure, it is not credible to assume that seven major strategic sites will all be able to deliver at historically exceptional rates.
In order to reduce reliance on uncertain major sites and increase the likelihood that overall completion rates will be close to or exceed standard method need over the first 5-10 years of the plan period, the draft Local Plan should make significant additional allocations for smaller developments close to existing settlements and that do not require enabling infrastructure investment.
The site at Valley Farm, Meldreth is available immediately and can deliver housing within the early years of the plan period.
[on behalf of Granta Land Ltd - Land at Valley Farm, Meldreth [130982]]

An additional exception should be added to paragraph 2 for development close to wellconnected railway stations that refers to the new NPPF following publication of the final
version in summer 2026

Over-Reliance on Major Settlements
The Development Strategy of the draft Local Plan is reliant on high levels of housing delivery in major strategic sites to such an extent that the risk that housing need is not met is excessively high and the draft Local Plan is therefore unsound.
There are fundamental issues with the distribution of housing growth across the Plan Period.
The Councils are distributing 44% of growth across the Plan Period in new settlements, and 29% in major sites on the edge of Cambridge which are similar to new settlements (Figure 12 of the Local Plan). Combined, 73% of growth is allocated to major strategic sites.
The table below sets out the distribution of growth during the Plan Period across these new settlements and whether these have planning permission.
Table 3.1: Delivery of new strategic sites during the emerging Plan Period
Site Number of Homes to be delivered in Plan Period Total number of dwellings Extant permission Percentage of homes delivered during Plan Period
Northstowe* 6,229 10,107 Yes 62%
Waterbeach New Town* 5,727 11,531 Yes 50%
Bourn Airfield 3,500 3,500 Yes 100%
North East Cambridge 3,950 4,925 No 50%
Cambourne North 2,550 13,000 No 20%
Grange Farm New Settlement 2,550 6,000 No 43%
*Northstowe has delivered 1,401 dwellings prior to this emerging Plan Period. Waterbeach New Town has delivered 556 dwellings prior this emerging Plan Period.

The following table sets out the proposed housing trajectory of the new strategic sites which do not currently have extant consent during the emerging Local Plan timeframe.
Table 3.2: Proposed housing trajectory for new strategic sites without extant consent (2024/25-2044/45)
New Settlement 24/25-31/32 32/33 33/34 34/35 35/36 36/37 37/38 38/39 39/40 40/41 41/42 42/43 43/44 44/45
North East Cambridge 0 50 150 250 350 350 350 350 350 350 350 350 350 350
Cambridge East 0 50 150 250 350 350 350 350 350 350 350 350 350 350
Cambourne North 0 0 0 50 100 150 200 250 300 300 300 300 300 300
Grange Farm 0 0 0 50 100 150 200 250 300 300 300 300 300 300
Totals 0 100 300 600 900 1000 1100 1200 1300 1300 1300 1300 1300 1300

It is not considered that the delivery rates for these sites are realistic, particularly with regard to the new sites which are yet to have been granted planning permission:
• North East Cambridge.
• Cambridge East.
• Cambourne West.
• Grange Farm.
In the latest ‘Start to Finish’ Report, undertaken by Lichfields in 2024 , it confirms that sites comprising over 1,000 dwellings will take, on average, five years to obtain detailed planning permission and then a further 1.3-1.6 years to deliver the first dwelling.
Indeed, for sites over 2,000 dwellings, it states that the median timescale from validation of the first planning application to the completion of the first dwelling is 6.7 years.
The Councils’ Local Development Scheme anticipates that the emerging Local Plan will be submitted to the Secretary of State for examination in December 2026. In July 2024 (after their General Election win), the new Minister for Housing, Matthew Pennycook, wrote to the Planning Inspectorate and noted that the average length of time for the completion of examination had increased from 65 weeks on average in 2016 to 134 weeks on average in 2022 (approximately 2 ½ years) .
Therefore, if the Plan were submitted to the Secretary of State in December 2026, then the earliest that the Plan is likely to be adopted is May 2029, using the data above. That would be equivalent to ‘Year 6’ (2029/2030) in the proposed housing trajectory.
If these new sites were to be approved in Year 6 (2029/30), then the earliest that the first house could be delivered according to the Lichfields ‘Start to Finish’ is in Year 12 (2035/2036). It is therefore unrealistic that the first dwellings will be delivered in North East Cambridge and Cambridge East in 2032/33 and in 2034/35 in Cambourne North and Grange Farm.
The current housing trajectory figures are overly ambitious for new strategic sites. There would be a reduction in 3,000 homes across the Plan Period which would not be delivered on new strategic sites.
Therefore, in order to meet this shortfall, the Councils should focus on providing a range of sites including smaller and medium sized sizes in and adjoining existing settlements, especially ones that have a number of services and facilities.
The Councils’ housing trajectory also reliant on the new strategic sites delivering 350 dwellings per annum. This is equivalent to seven plots delivering 50 dwellings per annum, by several housebuilders.
The Lichfields ‘Start to Finish’ document also sets out the housing completions of large sites. The table below sets out the average delivery of sites which are for over 5,000 dwellings across the years.
Table 3.2: Table of average housing delivery on sites larger than 5,000 dwellings
Site Name No of Dwellings No of Years of Delivery Average Delivery (rounded)
Former Alconbury Weald, Huntingdon 5,000 2 208
Priors Hall, Northamptonshire 5,200 11 135
North West Preston 5,300 8 290
East Kettering SUE 5,500 6 133
Sherford, South Hams 5,500 7 119
South Ashford Garden Community 5,750 2 75
Houlton (Rugby Radio Station) 6,200 3 139
The Hamptons (Peterborough) 6,320 25 224
Ebbsfleet 15,000 14 255

Therefore, the table above demonstrates that none of these new settlements achieved, on average, 350 dwellings per annum. Therefore, there should be a greater focus on delivering the required housing across sustainable settlements.
There are also concerns about the principle of the development at North East Cambridge, Cambridge East, Cambourne North and Grange Farm, although it is noted that the Councils acknowledge that North East Cambridge may not be available due to the Government withdrawing funding for the wastewater treatment relocation.
Regarding Cambridge East (the existing Cambridge Airport), in October 2025, Marshall Group confirmed that they were not relocating to Cranfield Airport, in Bedfordshire, as it was considered “no longer affordable ”.
Since then, there has been no public reporting or statements setting out when Marshall Group intends to vacate the Site. Therefore, it is uncertain whether the emerging Local Plan can be reliant on these dwellings during the Local Plan period.
With respect to Cambourne North, the delivery of the settlement extension is principally reliant on the proposed new station that will be delivered as part of East West Rail.
Although it is acknowledged that in June 2025, as part of the spending review, the Government committed a further £2.5 billion for the continued delivery of East West Rail, there is not a certainty that this will be delivered. This Government is fully committed to the delivery of East West Rail but there are no guarantees that a future government would be as committed. Therefore, the emerging Local Plan should focus more growth in Rural/Minor Rural Centres.
Regarding Grange Farm, there is concern that there is currently no infrastructure and none planned, with the scheme wholly reliant on an extension to CSET which is currently not in the project scope. The delivery of CSET is not within the control of the LPA or the site promotors.
The Deliverability Paper that was submitted for Grange Farm as part of the previous ‘call for sites’, confirms that 3,560 dwellings (market and affordable) can be delivered during the emerging Local Plan period with the first dwellings being delivered in 2030.
The Councils’ housing trajectory states that only 2,550 dwellings can be during the Plan Period, so our client would question how accurate these figures are by both the Councils and the promoter for Grange Farm.
There is also a discrepancy between the number in the Housing Trajectory provided by the Council (up to 300 dwellings in 2040) and only 275 dwellings in the Housing Deliverability Note . Therefore, it is not clear that the Council will be able to deliver that number of dwellings across the Plan Period.
In total, as set out in Figure 12 of the emerging Local Plan above, new settlements and edge of Cambridge sites will provide 73% of the total housing supply. Given the timings set out in the Lichfields ‘Start to Finish’ report, there is a severe risk of delay in delivering a significant number of Greater Cambridge’s housing sites, which will mean that the Councils will not be able to meet their housing needs across the Plan Period. If the Councils cannot demonstrate a five-year housing land supply or has a housing delivery percentage of less than 75%, set out in the Government’s Housing Delivery Test, then the Plan would be considered out of date. It would, therefore, be subject to paragraph 11 of the NPPF (2024) and attract speculative development.
In order to avoid this scenario and to ensure as far as possible a plan-led system can be successfully implemented and delivered, sites are needed that can help the Council deliver a consistent and deliverable supply of housing across the Plan Period, reducing the risk of the Council not being able to meet its housing needs, thereby attracting speculative development.
A greater mix of smaller and medium sized sites would help to ensure that in future Greater Cambridge is able to demonstrate a five-year supply of housing land. Smaller and medium sized sites typically come forward quicker that new large strategic sites which require significant infrastructure to support them. A good mix of these smaller sized sites also enables a wider range of house builders to enter the market providing a wider range in product and often leading to an increase in local employment.
Homes in Rural Areas
Policy S/DS takes no account of the sustainability benefits of locating some appropriately-sized development within or adjacent to existing villages in South Cambridgeshire.
Villages of all sizes with South Cambridgeshire benefit from increases in the housing stock: those with links to village can remain or return, new residents can find homes, the usage of local shops, community facilities and schools is increased. This maintains the resilience of established communities.
The Country Landowner’s Association’s report Sustainable Communities: the Role of Housing in Strengthening the Rural Economy (2022) states:
‘For rural areas to thrive, there needs to be an adequate, available, and diverse supply of homes, which includes different tenure types of varying sizes. The existing lack of homes in rural areas prevents young families to continue living in their community, key workers to be based near to their places of work and the elderly to downsize.’
However, the draft Local Plan makes allocations for just 265 homes on four sites adjacent to existing villages (Duxford, Highfields, and Melbourn).
This is the outcome of a fundamental flaw in the framing of the hierarchy of locations within this policy, which states that ‘jobs and homes will be met as far as possible in the following order of preference’. The hierarchy reflects an approach to sustainability that gives predominant weight to environmental factors, notably transport emissions, to the detriment of the social sustainability of existing settlements. Following this sequential hierarch leads the draft Local Plan to maximise allocations in locations in and around Cambridge as well as at new strategic sites. Only a small residual of housing need is allocated to villages, whereas there is localised housing need within almost all communities in the plan area, as regular village-level surveys show.
By failing to allocate new housing to existing villages, and ignoring the social impact of this, the draft Local Plan does not fully achieve sustainable development as defined in the NPPF.
Development of the site at Valley Farm, Meldreth would contribute to the social sustainability of the villages of Meldreth and Melbourn.
Five Year Housing Land Supply and Housing Trajectory
The Development Strategy of the draft Local Plan is underpinned by the Housing Trajectory set out in draft Appendix E. This anticipates that the local housing need (standard method) annual number of 2,309 is not achieved between 2024/25 and 2027/28, in 2032/32 or in the final four years of the plan period. For the years 2028/29 and 2029/30, anticipated completions are significantly higher, at 3,483 and 3,530 respectively. This results in a predicted number of completions for 2028-2033 of 14,427 units, which equates to a five-year supply of 5.32 years.
Analysis of the projected completions for individual sites suggests that the above anticipated completions numbers are based on estimates of completions on strategic sites for 2028/29 and 2029/30 are that are significantly above historic maximums and that do not take into account the planning context of each site.
At North West Cambridge, completion of the final Phase 1 dwellings permitted under the 2013 outline is expected in 2028. The outline application for future phases is currently under consideration and is unlikely to be approved before late 2026, with reserved matters to follow. It is therefore implausible that 305 and 376 dwellings can be delivered in 2028/29 and 2029/30 respectively. A more reasonable assumption might be 100 per year, as the trajectory anticipate for most of the 2030s.
At Northstowe, the historic maximum annual delivery was in 2018/19, when 278 dwellings were completed. Only 92 dwellings were completed in 2023/2024 (on both Phase 1 and Phase 2). Phase 1 is now almost complete and Phase 2 has 706 dwellings permitted. It is therefore implausible that 473 and 467 dwellings can be delivered in 2028/29 and 2029/30 respectively. A more reasonable assumption might be 300 per year, as the trajectory anticipate for 2030 onwards.
At Waterbeach New Town, 263 dwellings were completed in 2022/23, with completions declining since then. It is unlikely that 376 and 368 dwellings can be delivered in 2028/29 and 2029/30 respectively. A more reasonable assumption might be 300 per year, as the trajectory anticipate for 2030 onwards.
If the above reasonable adjustments are made to the housing trajectory in Appendix E, the number of predicted completions is reduced by 965 and the five-year supply for 2028-2033 falls to 4.96
It is also noted that the housing trajectory relies on historically high delivery rates in 2028/29 and 2029/30 for four further major previously allocated strategic sites: North East Cambridge, Darwin Green, Cambridge East (Marleigh and Land north of Cherry Hinton), and Cambourne West.
Given historic experience of both general and site-specific causes of delays and reductions in delivery rates, notably the delivery of major infrastructure, it is not credible to assume that seven major strategic sites will all be able to deliver at historically exceptional rates.
In order to reduce reliance on uncertain major sites and increase the likelihood that overall completion rates will be close to or exceed standard method need over the first 5-10 years of the plan period, the draft Local Plan should make significant additional allocations for smaller developments close to existing settlements and that do not require enabling infrastructure investment.
The site at Valley Farm, Meldreth is available immediately and can deliver housing within the early years of the plan period.
[on behalf of Granta Land Ltd - Land at Valley Farm, Meldreth [130982]]

Over-Reliance on Major Settlements
The Development Strategy of the draft Local Plan is reliant on high levels of housing delivery in major strategic sites to such an extent that the risk that housing need is not met is excessively high and the draft Local Plan is therefore unsound.
There are fundamental issues with the distribution of housing growth across the Plan Period.
The Councils are distributing 44% of growth across the Plan Period in new settlements, and 29% in major sites on the edge of Cambridge which are similar to new settlements (Figure 12 of the Local Plan). Combined, 73% of growth is allocated to major strategic sites.
The table below sets out the distribution of growth during the Plan Period across these new settlements and whether these have planning permission.
Table 3.1: Delivery of new strategic sites during the emerging Plan Period
Site Number of Homes to be delivered in Plan Period Total number of dwellings Extant permission Percentage of homes delivered during Plan Period
Northstowe* 6,229 10,107 Yes 62%
Waterbeach New Town* 5,727 11,531 Yes 50%
Bourn Airfield 3,500 3,500 Yes 100%
North East Cambridge 3,950 4,925 No 50%
Cambourne North 2,550 13,000 No 20%
Grange Farm New Settlement 2,550 6,000 No 43%
*Northstowe has delivered 1,401 dwellings prior to this emerging Plan Period. Waterbeach New Town has delivered 556 dwellings prior this emerging Plan Period.

The following table sets out the proposed housing trajectory of the new strategic sites which do not currently have extant consent during the emerging Local Plan timeframe.
Table 3.2: Proposed housing trajectory for new strategic sites without extant consent (2024/25-2044/45)
New Settlement 24/25-31/32 32/33 33/34 34/35 35/36 36/37 37/38 38/39 39/40 40/41 41/42 42/43 43/44 44/45
North East Cambridge 0 50 150 250 350 350 350 350 350 350 350 350 350 350
Cambridge East 0 50 150 250 350 350 350 350 350 350 350 350 350 350
Cambourne North 0 0 0 50 100 150 200 250 300 300 300 300 300 300
Grange Farm 0 0 0 50 100 150 200 250 300 300 300 300 300 300
Totals 0 100 300 600 900 1000 1100 1200 1300 1300 1300 1300 1300 1300

It is not considered that the delivery rates for these sites are realistic, particularly with regard to the new sites which are yet to have been granted planning permission:
• North East Cambridge.
• Cambridge East.
• Cambourne West.
• Grange Farm.
In the latest ‘Start to Finish’ Report, undertaken by Lichfields in 2024 , it confirms that sites comprising over 1,000 dwellings will take, on average, five years to obtain detailed planning permission and then a further 1.3-1.6 years to deliver the first dwelling.
Indeed, for sites over 2,000 dwellings, it states that the median timescale from validation of the first planning application to the completion of the first dwelling is 6.7 years.
The Councils’ Local Development Scheme anticipates that the emerging Local Plan will be submitted to the Secretary of State for examination in December 2026. In July 2024 (after their General Election win), the new Minister for Housing, Matthew Pennycook, wrote to the Planning Inspectorate and noted that the average length of time for the completion of examination had increased from 65 weeks on average in 2016 to 134 weeks on average in 2022 (approximately 2 ½ years) .
Therefore, if the Plan were submitted to the Secretary of State in December 2026, then the earliest that the Plan is likely to be adopted is May 2029, using the data above. That would be equivalent to ‘Year 6’ (2029/2030) in the proposed housing trajectory.
If these new sites were to be approved in Year 6 (2029/30), then the earliest that the first house could be delivered according to the Lichfields ‘Start to Finish’ is in Year 12 (2035/2036). It is therefore unrealistic that the first dwellings will be delivered in North East Cambridge and Cambridge East in 2032/33 and in 2034/35 in Cambourne North and Grange Farm.
The current housing trajectory figures are overly ambitious for new strategic sites. There would be a reduction in 3,000 homes across the Plan Period which would not be delivered on new strategic sites.
Therefore, in order to meet this shortfall, the Councils should focus on providing a range of sites including smaller and medium sized sizes in and adjoining existing settlements, especially ones that have a number of services and facilities.
The Councils’ housing trajectory also reliant on the new strategic sites delivering 350 dwellings per annum. This is equivalent to seven plots delivering 50 dwellings per annum, by several housebuilders.
The Lichfields ‘Start to Finish’ document also sets out the housing completions of large sites. The table below sets out the average delivery of sites which are for over 5,000 dwellings across the years.
Table 3.2: Table of average housing delivery on sites larger than 5,000 dwellings
Site Name No of Dwellings No of Years of Delivery Average Delivery (rounded)
Former Alconbury Weald, Huntingdon 5,000 2 208
Priors Hall, Northamptonshire 5,200 11 135
North West Preston 5,300 8 290
East Kettering SUE 5,500 6 133
Sherford, South Hams 5,500 7 119
South Ashford Garden Community 5,750 2 75
Houlton (Rugby Radio Station) 6,200 3 139
The Hamptons (Peterborough) 6,320 25 224
Ebbsfleet 15,000 14 255

Therefore, the table above demonstrates that none of these new settlements achieved, on average, 350 dwellings per annum. Therefore, there should be a greater focus on delivering the required housing across sustainable settlements.
There are also concerns about the principle of the development at North East Cambridge, Cambridge East, Cambourne North and Grange Farm, although it is noted that the Councils acknowledge that North East Cambridge may not be available due to the Government withdrawing funding for the wastewater treatment relocation.
Regarding Cambridge East (the existing Cambridge Airport), in October 2025, Marshall Group confirmed that they were not relocating to Cranfield Airport, in Bedfordshire, as it was considered “no longer affordable ”.
Since then, there has been no public reporting or statements setting out when Marshall Group intends to vacate the Site. Therefore, it is uncertain whether the emerging Local Plan can be reliant on these dwellings during the Local Plan period.
With respect to Cambourne North, the delivery of the settlement extension is principally reliant on the proposed new station that will be delivered as part of East West Rail.
Although it is acknowledged that in June 2025, as part of the spending review, the Government committed a further £2.5 billion for the continued delivery of East West Rail, there is not a certainty that this will be delivered. This Government is fully committed to the delivery of East West Rail but there are no guarantees that a future government would be as committed. Therefore, the emerging Local Plan should focus more growth in Rural/Minor Rural Centres.
Regarding Grange Farm, there is concern that there is currently no infrastructure and none planned, with the scheme wholly reliant on an extension to CSET which is currently not in the project scope. The delivery of CSET is not within the control of the LPA or the site promotors.
The Deliverability Paper that was submitted for Grange Farm as part of the previous ‘call for sites’, confirms that 3,560 dwellings (market and affordable) can be delivered during the emerging Local Plan period with the first dwellings being delivered in 2030.
The Councils’ housing trajectory states that only 2,550 dwellings can be during the Plan Period, so our client would question how accurate these figures are by both the Councils and the promoter for Grange Farm.
There is also a discrepancy between the number in the Housing Trajectory provided by the Council (up to 300 dwellings in 2040) and only 275 dwellings in the Housing Deliverability Note . Therefore, it is not clear that the Council will be able to deliver that number of dwellings across the Plan Period.
In total, as set out in Figure 12 of the emerging Local Plan above, new settlements and edge of Cambridge sites will provide 73% of the total housing supply. Given the timings set out in the Lichfields ‘Start to Finish’ report, there is a severe risk of delay in delivering a significant number of Greater Cambridge’s housing sites, which will mean that the Councils will not be able to meet their housing needs across the Plan Period. If the Councils cannot demonstrate a five-year housing land supply or has a housing delivery percentage of less than 75%, set out in the Government’s Housing Delivery Test, then the Plan would be considered out of date. It would, therefore, be subject to paragraph 11 of the NPPF (2024) and attract speculative development.
In order to avoid this scenario and to ensure as far as possible a plan-led system can be successfully implemented and delivered, sites are needed that can help the Council deliver a consistent and deliverable supply of housing across the Plan Period, reducing the risk of the Council not being able to meet its housing needs, thereby attracting speculative development.
A greater mix of smaller and medium sized sites would help to ensure that in future Greater Cambridge is able to demonstrate a five-year supply of housing land. Smaller and medium sized sites typically come forward quicker that new large strategic sites which require significant infrastructure to support them. A good mix of these smaller sized sites also enables a wider range of house builders to enter the market providing a wider range in product and often leading to an increase in local employment.
Homes in Rural Areas
Policy S/DS takes no account of the sustainability benefits of locating some appropriately-sized development within or adjacent to existing villages in South Cambridgeshire.
Villages of all sizes with South Cambridgeshire benefit from increases in the housing stock: those with links to village can remain or return, new residents can find homes, the usage of local shops, community facilities and schools is increased. This maintains the resilience of established communities.
The Country Landowner’s Association’s report Sustainable Communities: the Role of Housing in Strengthening the Rural Economy (2022) states:
‘For rural areas to thrive, there needs to be an adequate, available, and diverse supply of homes, which includes different tenure types of varying sizes. The existing lack of homes in rural areas prevents young families to continue living in their community, key workers to be based near to their places of work and the elderly to downsize.’
However, the draft Local Plan makes allocations for just 265 homes on four sites adjacent to existing villages (Duxford, Highfields, and Melbourn).
This is the outcome of a fundamental flaw in the framing of the hierarchy of locations within this policy, which states that ‘jobs and homes will be met as far as possible in the following order of preference’. The hierarchy reflects an approach to sustainability that gives predominant weight to environmental factors, notably transport emissions, to the detriment of the social sustainability of existing settlements. Following this sequential hierarch leads the draft Local Plan to maximise allocations in locations in and around Cambridge as well as at new strategic sites. Only a small residual of housing need is allocated to villages, whereas there is localised housing need within almost all communities in the plan area, as regular village-level surveys show.
By failing to allocate new housing to existing villages, and ignoring the social impact of this, the draft Local Plan does not fully achieve sustainable development as defined in the NPPF.
Development of the site at Valley Farm, Meldreth would contribute to the social sustainability of the villages of Meldreth and Melbourn.
Five Year Housing Land Supply and Housing Trajectory
The Development Strategy of the draft Local Plan is underpinned by the Housing Trajectory set out in draft Appendix E. This anticipates that the local housing need (standard method) annual number of 2,309 is not achieved between 2024/25 and 2027/28, in 2032/32 or in the final four years of the plan period. For the years 2028/29 and 2029/30, anticipated completions are significantly higher, at 3,483 and 3,530 respectively. This results in a predicted number of completions for 2028-2033 of 14,427 units, which equates to a five-year supply of 5.32 years.
Analysis of the projected completions for individual sites suggests that the above anticipated completions numbers are based on estimates of completions on strategic sites for 2028/29 and 2029/30 are that are significantly above historic maximums and that do not take into account the planning context of each site.
At North West Cambridge, completion of the final Phase 1 dwellings permitted under the 2013 outline is expected in 2028. The outline application for future phases is currently under consideration and is unlikely to be approved before late 2026, with reserved matters to follow. It is therefore implausible that 305 and 376 dwellings can be delivered in 2028/29 and 2029/30 respectively. A more reasonable assumption might be 100 per year, as the trajectory anticipate for most of the 2030s.
At Northstowe, the historic maximum annual delivery was in 2018/19, when 278 dwellings were completed. Only 92 dwellings were completed in 2023/2024 (on both Phase 1 and Phase 2). Phase 1 is now almost complete and Phase 2 has 706 dwellings permitted. It is therefore implausible that 473 and 467 dwellings can be delivered in 2028/29 and 2029/30 respectively. A more reasonable assumption might be 300 per year, as the trajectory anticipate for 2030 onwards.
At Waterbeach New Town, 263 dwellings were completed in 2022/23, with completions declining since then. It is unlikely that 376 and 368 dwellings can be delivered in 2028/29 and 2029/30 respectively. A more reasonable assumption might be 300 per year, as the trajectory anticipate for 2030 onwards.
If the above reasonable adjustments are made to the housing trajectory in Appendix E, the number of predicted completions is reduced by 965 and the five-year supply for 2028-2033 falls to 4.96
It is also noted that the housing trajectory relies on historically high delivery rates in 2028/29 and 2029/30 for four further major previously allocated strategic sites: North East Cambridge, Darwin Green, Cambridge East (Marleigh and Land north of Cherry Hinton), and Cambourne West.
Given historic experience of both general and site-specific causes of delays and reductions in delivery rates, notably the delivery of major infrastructure, it is not credible to assume that seven major strategic sites will all be able to deliver at historically exceptional rates.
In order to reduce reliance on uncertain major sites and increase the likelihood that overall completion rates will be close to or exceed standard method need over the first 5-10 years of the plan period, the draft Local Plan should make significant additional allocations for smaller developments close to existing settlements and that do not require enabling infrastructure investment.
The site at Valley Farm, Meldreth is available immediately and can deliver housing within the early years of the plan period.
[on behalf of Granta Land Ltd - Land at Valley Farm, Meldreth [130982]]

Over-Reliance on Major Settlements
The Development Strategy of the draft Local Plan is reliant on high levels of housing delivery in major strategic sites to such an extent that the risk that housing need is not met is excessively high and the draft Local Plan is therefore unsound.
There are fundamental issues with the distribution of housing growth across the Plan Period.
The Councils are distributing 44% of growth across the Plan Period in new settlements, and 29% in major sites on the edge of Cambridge which are similar to new settlements (Figure 12 of the Local Plan). Combined, 73% of growth is allocated to major strategic sites.
The table below sets out the distribution of growth during the Plan Period across these new settlements and whether these have planning permission.
Table 3.1: Delivery of new strategic sites during the emerging Plan Period
Site Number of Homes to be delivered in Plan Period Total number of dwellings Extant permission Percentage of homes delivered during Plan Period
Northstowe* 6,229 10,107 Yes 62%
Waterbeach New Town* 5,727 11,531 Yes 50%
Bourn Airfield 3,500 3,500 Yes 100%
North East Cambridge 3,950 4,925 No 50%
Cambourne North 2,550 13,000 No 20%
Grange Farm New Settlement 2,550 6,000 No 43%
*Northstowe has delivered 1,401 dwellings prior to this emerging Plan Period. Waterbeach New Town has delivered 556 dwellings prior this emerging Plan Period.

The following table sets out the proposed housing trajectory of the new strategic sites which do not currently have extant consent during the emerging Local Plan timeframe.
Table 3.2: Proposed housing trajectory for new strategic sites without extant consent (2024/25-2044/45)
New Settlement 24/25-31/32 32/33 33/34 34/35 35/36 36/37 37/38 38/39 39/40 40/41 41/42 42/43 43/44 44/45
North East Cambridge 0 50 150 250 350 350 350 350 350 350 350 350 350 350
Cambridge East 0 50 150 250 350 350 350 350 350 350 350 350 350 350
Cambourne North 0 0 0 50 100 150 200 250 300 300 300 300 300 300
Grange Farm 0 0 0 50 100 150 200 250 300 300 300 300 300 300
Totals 0 100 300 600 900 1000 1100 1200 1300 1300 1300 1300 1300 1300

It is not considered that the delivery rates for these sites are realistic, particularly with regard to the new sites which are yet to have been granted planning permission:
• North East Cambridge.
• Cambridge East.
• Cambourne West.
• Grange Farm.
In the latest ‘Start to Finish’ Report, undertaken by Lichfields in 2024 , it confirms that sites comprising over 1,000 dwellings will take, on average, five years to obtain detailed planning permission and then a further 1.3-1.6 years to deliver the first dwelling.
Indeed, for sites over 2,000 dwellings, it states that the median timescale from validation of the first planning application to the completion of the first dwelling is 6.7 years.
The Councils’ Local Development Scheme anticipates that the emerging Local Plan will be submitted to the Secretary of State for examination in December 2026. In July 2024 (after their General Election win), the new Minister for Housing, Matthew Pennycook, wrote to the Planning Inspectorate and noted that the average length of time for the completion of examination had increased from 65 weeks on average in 2016 to 134 weeks on average in 2022 (approximately 2 ½ years) .
Therefore, if the Plan were submitted to the Secretary of State in December 2026, then the earliest that the Plan is likely to be adopted is May 2029, using the data above. That would be equivalent to ‘Year 6’ (2029/2030) in the proposed housing trajectory.
If these new sites were to be approved in Year 6 (2029/30), then the earliest that the first house could be delivered according to the Lichfields ‘Start to Finish’ is in Year 12 (2035/2036). It is therefore unrealistic that the first dwellings will be delivered in North East Cambridge and Cambridge East in 2032/33 and in 2034/35 in Cambourne North and Grange Farm.
The current housing trajectory figures are overly ambitious for new strategic sites. There would be a reduction in 3,000 homes across the Plan Period which would not be delivered on new strategic sites.
Therefore, in order to meet this shortfall, the Councils should focus on providing a range of sites including smaller and medium sized sizes in and adjoining existing settlements, especially ones that have a number of services and facilities.
The Councils’ housing trajectory also reliant on the new strategic sites delivering 350 dwellings per annum. This is equivalent to seven plots delivering 50 dwellings per annum, by several housebuilders.
The Lichfields ‘Start to Finish’ document also sets out the housing completions of large sites. The table below sets out the average delivery of sites which are for over 5,000 dwellings across the years.
Table 3.2: Table of average housing delivery on sites larger than 5,000 dwellings
Site Name No of Dwellings No of Years of Delivery Average Delivery (rounded)
Former Alconbury Weald, Huntingdon 5,000 2 208
Priors Hall, Northamptonshire 5,200 11 135
North West Preston 5,300 8 290
East Kettering SUE 5,500 6 133
Sherford, South Hams 5,500 7 119
South Ashford Garden Community 5,750 2 75
Houlton (Rugby Radio Station) 6,200 3 139
The Hamptons (Peterborough) 6,320 25 224
Ebbsfleet 15,000 14 255

Therefore, the table above demonstrates that none of these new settlements achieved, on average, 350 dwellings per annum. Therefore, there should be a greater focus on delivering the required housing across sustainable settlements.
There are also concerns about the principle of the development at North East Cambridge, Cambridge East, Cambourne North and Grange Farm, although it is noted that the Councils acknowledge that North East Cambridge may not be available due to the Government withdrawing funding for the wastewater treatment relocation.
Regarding Cambridge East (the existing Cambridge Airport), in October 2025, Marshall Group confirmed that they were not relocating to Cranfield Airport, in Bedfordshire, as it was considered “no longer affordable ”.
Since then, there has been no public reporting or statements setting out when Marshall Group intends to vacate the Site. Therefore, it is uncertain whether the emerging Local Plan can be reliant on these dwellings during the Local Plan period.
With respect to Cambourne North, the delivery of the settlement extension is principally reliant on the proposed new station that will be delivered as part of East West Rail.
Although it is acknowledged that in June 2025, as part of the spending review, the Government committed a further £2.5 billion for the continued delivery of East West Rail, there is not a certainty that this will be delivered. This Government is fully committed to the delivery of East West Rail but there are no guarantees that a future government would be as committed. Therefore, the emerging Local Plan should focus more growth in Rural/Minor Rural Centres.
Regarding Grange Farm, there is concern that there is currently no infrastructure and none planned, with the scheme wholly reliant on an extension to CSET which is currently not in the project scope. The delivery of CSET is not within the control of the LPA or the site promotors.
The Deliverability Paper that was submitted for Grange Farm as part of the previous ‘call for sites’, confirms that 3,560 dwellings (market and affordable) can be delivered during the emerging Local Plan period with the first dwellings being delivered in 2030.
The Councils’ housing trajectory states that only 2,550 dwellings can be during the Plan Period, so our client would question how accurate these figures are by both the Councils and the promoter for Grange Farm.
There is also a discrepancy between the number in the Housing Trajectory provided by the Council (up to 300 dwellings in 2040) and only 275 dwellings in the Housing Deliverability Note . Therefore, it is not clear that the Council will be able to deliver that number of dwellings across the Plan Period.
In total, as set out in Figure 12 of the emerging Local Plan above, new settlements and edge of Cambridge sites will provide 73% of the total housing supply. Given the timings set out in the Lichfields ‘Start to Finish’ report, there is a severe risk of delay in delivering a significant number of Greater Cambridge’s housing sites, which will mean that the Councils will not be able to meet their housing needs across the Plan Period. If the Councils cannot demonstrate a five-year housing land supply or has a housing delivery percentage of less than 75%, set out in the Government’s Housing Delivery Test, then the Plan would be considered out of date. It would, therefore, be subject to paragraph 11 of the NPPF (2024) and attract speculative development.
In order to avoid this scenario and to ensure as far as possible a plan-led system can be successfully implemented and delivered, sites are needed that can help the Council deliver a consistent and deliverable supply of housing across the Plan Period, reducing the risk of the Council not being able to meet its housing needs, thereby attracting speculative development.
A greater mix of smaller and medium sized sites would help to ensure that in future Greater Cambridge is able to demonstrate a five-year supply of housing land. Smaller and medium sized sites typically come forward quicker that new large strategic sites which require significant infrastructure to support them. A good mix of these smaller sized sites also enables a wider range of house builders to enter the market providing a wider range in product and often leading to an increase in local employment.
Homes in Rural Areas
Policy S/DS takes no account of the sustainability benefits of locating some appropriately-sized development within or adjacent to existing villages in South Cambridgeshire.
Villages of all sizes with South Cambridgeshire benefit from increases in the housing stock: those with links to village can remain or return, new residents can find homes, the usage of local shops, community facilities and schools is increased. This maintains the resilience of established communities.
The Country Landowner’s Association’s report Sustainable Communities: the Role of Housing in Strengthening the Rural Economy (2022) states:
‘For rural areas to thrive, there needs to be an adequate, available, and diverse supply of homes, which includes different tenure types of varying sizes. The existing lack of homes in rural areas prevents young families to continue living in their community, key workers to be based near to their places of work and the elderly to downsize.’
However, the draft Local Plan makes allocations for just 265 homes on four sites adjacent to existing villages (Duxford, Highfields, and Melbourn).
This is the outcome of a fundamental flaw in the framing of the hierarchy of locations within this policy, which states that ‘jobs and homes will be met as far as possible in the following order of preference’. The hierarchy reflects an approach to sustainability that gives predominant weight to environmental factors, notably transport emissions, to the detriment of the social sustainability of existing settlements. Following this sequential hierarch leads the draft Local Plan to maximise allocations in locations in and around Cambridge as well as at new strategic sites. Only a small residual of housing need is allocated to villages, whereas there is localised housing need within almost all communities in the plan area, as regular village-level surveys show.
By failing to allocate new housing to existing villages, and ignoring the social impact of this, the draft Local Plan does not fully achieve sustainable development as defined in the NPPF.
Development of the site at Valley Farm, Meldreth would contribute to the social sustainability of the villages of Meldreth and Melbourn.
Five Year Housing Land Supply and Housing Trajectory
The Development Strategy of the draft Local Plan is underpinned by the Housing Trajectory set out in draft Appendix E. This anticipates that the local housing need (standard method) annual number of 2,309 is not achieved between 2024/25 and 2027/28, in 2032/32 or in the final four years of the plan period. For the years 2028/29 and 2029/30, anticipated completions are significantly higher, at 3,483 and 3,530 respectively. This results in a predicted number of completions for 2028-2033 of 14,427 units, which equates to a five-year supply of 5.32 years.
Analysis of the projected completions for individual sites suggests that the above anticipated completions numbers are based on estimates of completions on strategic sites for 2028/29 and 2029/30 are that are significantly above historic maximums and that do not take into account the planning context of each site.
At North West Cambridge, completion of the final Phase 1 dwellings permitted under the 2013 outline is expected in 2028. The outline application for future phases is currently under consideration and is unlikely to be approved before late 2026, with reserved matters to follow. It is therefore implausible that 305 and 376 dwellings can be delivered in 2028/29 and 2029/30 respectively. A more reasonable assumption might be 100 per year, as the trajectory anticipate for most of the 2030s.
At Northstowe, the historic maximum annual delivery was in 2018/19, when 278 dwellings were completed. Only 92 dwellings were completed in 2023/2024 (on both Phase 1 and Phase 2). Phase 1 is now almost complete and Phase 2 has 706 dwellings permitted. It is therefore implausible that 473 and 467 dwellings can be delivered in 2028/29 and 2029/30 respectively. A more reasonable assumption might be 300 per year, as the trajectory anticipate for 2030 onwards.
At Waterbeach New Town, 263 dwellings were completed in 2022/23, with completions declining since then. It is unlikely that 376 and 368 dwellings can be delivered in 2028/29 and 2029/30 respectively. A more reasonable assumption might be 300 per year, as the trajectory anticipate for 2030 onwards.
If the above reasonable adjustments are made to the housing trajectory in Appendix E, the number of predicted completions is reduced by 965 and the five-year supply for 2028-2033 falls to 4.96
It is also noted that the housing trajectory relies on historically high delivery rates in 2028/29 and 2029/30 for four further major previously allocated strategic sites: North East Cambridge, Darwin Green, Cambridge East (Marleigh and Land north of Cherry Hinton), and Cambourne West.
Given historic experience of both general and site-specific causes of delays and reductions in delivery rates, notably the delivery of major infrastructure, it is not credible to assume that seven major strategic sites will all be able to deliver at historically exceptional rates.
In order to reduce reliance on uncertain major sites and increase the likelihood that overall completion rates will be close to or exceed standard method need over the first 5-10 years of the plan period, the draft Local Plan should make significant additional allocations for smaller developments close to existing settlements and that do not require enabling infrastructure investment.
The site at Valley Farm, Meldreth is available immediately and can deliver housing within the early years of the plan period.
[on behalf of Granta Land Ltd - Land at Valley Farm, Meldreth [130982]]

Over-Reliance on Major Settlements
The Development Strategy of the draft Local Plan is reliant on high levels of housing delivery in major strategic sites to such an extent that the risk that housing need is not met is excessively high and the draft Local Plan is therefore unsound.
There are fundamental issues with the distribution of housing growth across the Plan Period.
The Councils are distributing 44% of growth across the Plan Period in new settlements, and 29% in major sites on the edge of Cambridge which are similar to new settlements (Figure 12 of the Local Plan). Combined, 73% of growth is allocated to major strategic sites.
The table below sets out the distribution of growth during the Plan Period across these new settlements and whether these have planning permission.
Table 3.1: Delivery of new strategic sites during the emerging Plan Period
Site Number of Homes to be delivered in Plan Period Total number of dwellings Extant permission Percentage of homes delivered during Plan Period
Northstowe* 6,229 10,107 Yes 62%
Waterbeach New Town* 5,727 11,531 Yes 50%
Bourn Airfield 3,500 3,500 Yes 100%
North East Cambridge 3,950 4,925 No 50%
Cambourne North 2,550 13,000 No 20%
Grange Farm New Settlement 2,550 6,000 No 43%
*Northstowe has delivered 1,401 dwellings prior to this emerging Plan Period. Waterbeach New Town has delivered 556 dwellings prior this emerging Plan Period.

The following table sets out the proposed housing trajectory of the new strategic sites which do not currently have extant consent during the emerging Local Plan timeframe.
Table 3.2: Proposed housing trajectory for new strategic sites without extant consent (2024/25-2044/45)
New Settlement 24/25-31/32 32/33 33/34 34/35 35/36 36/37 37/38 38/39 39/40 40/41 41/42 42/43 43/44 44/45
North East Cambridge 0 50 150 250 350 350 350 350 350 350 350 350 350 350
Cambridge East 0 50 150 250 350 350 350 350 350 350 350 350 350 350
Cambourne North 0 0 0 50 100 150 200 250 300 300 300 300 300 300
Grange Farm 0 0 0 50 100 150 200 250 300 300 300 300 300 300
Totals 0 100 300 600 900 1000 1100 1200 1300 1300 1300 1300 1300 1300

It is not considered that the delivery rates for these sites are realistic, particularly with regard to the new sites which are yet to have been granted planning permission:
• North East Cambridge.
• Cambridge East.
• Cambourne West.
• Grange Farm.
In the latest ‘Start to Finish’ Report, undertaken by Lichfields in 2024 , it confirms that sites comprising over 1,000 dwellings will take, on average, five years to obtain detailed planning permission and then a further 1.3-1.6 years to deliver the first dwelling.
Indeed, for sites over 2,000 dwellings, it states that the median timescale from validation of the first planning application to the completion of the first dwelling is 6.7 years.
The Councils’ Local Development Scheme anticipates that the emerging Local Plan will be submitted to the Secretary of State for examination in December 2026. In July 2024 (after their General Election win), the new Minister for Housing, Matthew Pennycook, wrote to the Planning Inspectorate and noted that the average length of time for the completion of examination had increased from 65 weeks on average in 2016 to 134 weeks on average in 2022 (approximately 2 ½ years) .
Therefore, if the Plan were submitted to the Secretary of State in December 2026, then the earliest that the Plan is likely to be adopted is May 2029, using the data above. That would be equivalent to ‘Year 6’ (2029/2030) in the proposed housing trajectory.
If these new sites were to be approved in Year 6 (2029/30), then the earliest that the first house could be delivered according to the Lichfields ‘Start to Finish’ is in Year 12 (2035/2036). It is therefore unrealistic that the first dwellings will be delivered in North East Cambridge and Cambridge East in 2032/33 and in 2034/35 in Cambourne North and Grange Farm.
The current housing trajectory figures are overly ambitious for new strategic sites. There would be a reduction in 3,000 homes across the Plan Period which would not be delivered on new strategic sites.
Therefore, in order to meet this shortfall, the Councils should focus on providing a range of sites including smaller and medium sized sizes in and adjoining existing settlements, especially ones that have a number of services and facilities.
The Councils’ housing trajectory also reliant on the new strategic sites delivering 350 dwellings per annum. This is equivalent to seven plots delivering 50 dwellings per annum, by several housebuilders.
The Lichfields ‘Start to Finish’ document also sets out the housing completions of large sites. The table below sets out the average delivery of sites which are for over 5,000 dwellings across the years.
Table 3.2: Table of average housing delivery on sites larger than 5,000 dwellings
Site Name No of Dwellings No of Years of Delivery Average Delivery (rounded)
Former Alconbury Weald, Huntingdon 5,000 2 208
Priors Hall, Northamptonshire 5,200 11 135
North West Preston 5,300 8 290
East Kettering SUE 5,500 6 133
Sherford, South Hams 5,500 7 119
South Ashford Garden Community 5,750 2 75
Houlton (Rugby Radio Station) 6,200 3 139
The Hamptons (Peterborough) 6,320 25 224
Ebbsfleet 15,000 14 255

Therefore, the table above demonstrates that none of these new settlements achieved, on average, 350 dwellings per annum. Therefore, there should be a greater focus on delivering the required housing across sustainable settlements.
There are also concerns about the principle of the development at North East Cambridge, Cambridge East, Cambourne North and Grange Farm, although it is noted that the Councils acknowledge that North East Cambridge may not be available due to the Government withdrawing funding for the wastewater treatment relocation.
Regarding Cambridge East (the existing Cambridge Airport), in October 2025, Marshall Group confirmed that they were not relocating to Cranfield Airport, in Bedfordshire, as it was considered “no longer affordable ”.
Since then, there has been no public reporting or statements setting out when Marshall Group intends to vacate the Site. Therefore, it is uncertain whether the emerging Local Plan can be reliant on these dwellings during the Local Plan period.
With respect to Cambourne North, the delivery of the settlement extension is principally reliant on the proposed new station that will be delivered as part of East West Rail.
Although it is acknowledged that in June 2025, as part of the spending review, the Government committed a further £2.5 billion for the continued delivery of East West Rail, there is not a certainty that this will be delivered. This Government is fully committed to the delivery of East West Rail but there are no guarantees that a future government would be as committed. Therefore, the emerging Local Plan should focus more growth in Rural/Minor Rural Centres.
Regarding Grange Farm, there is concern that there is currently no infrastructure and none planned, with the scheme wholly reliant on an extension to CSET which is currently not in the project scope. The delivery of CSET is not within the control of the LPA or the site promotors.
The Deliverability Paper that was submitted for Grange Farm as part of the previous ‘call for sites’, confirms that 3,560 dwellings (market and affordable) can be delivered during the emerging Local Plan period with the first dwellings being delivered in 2030.
The Councils’ housing trajectory states that only 2,550 dwellings can be during the Plan Period, so our client would question how accurate these figures are by both the Councils and the promoter for Grange Farm.
There is also a discrepancy between the number in the Housing Trajectory provided by the Council (up to 300 dwellings in 2040) and only 275 dwellings in the Housing Deliverability Note . Therefore, it is not clear that the Council will be able to deliver that number of dwellings across the Plan Period.
In total, as set out in Figure 12 of the emerging Local Plan above, new settlements and edge of Cambridge sites will provide 73% of the total housing supply. Given the timings set out in the Lichfields ‘Start to Finish’ report, there is a severe risk of delay in delivering a significant number of Greater Cambridge’s housing sites, which will mean that the Councils will not be able to meet their housing needs across the Plan Period. If the Councils cannot demonstrate a five-year housing land supply or has a housing delivery percentage of less than 75%, set out in the Government’s Housing Delivery Test, then the Plan would be considered out of date. It would, therefore, be subject to paragraph 11 of the NPPF (2024) and attract speculative development.
In order to avoid this scenario and to ensure as far as possible a plan-led system can be successfully implemented and delivered, sites are needed that can help the Council deliver a consistent and deliverable supply of housing across the Plan Period, reducing the risk of the Council not being able to meet its housing needs, thereby attracting speculative development.
A greater mix of smaller and medium sized sites would help to ensure that in future Greater Cambridge is able to demonstrate a five-year supply of housing land. Smaller and medium sized sites typically come forward quicker that new large strategic sites which require significant infrastructure to support them. A good mix of these smaller sized sites also enables a wider range of house builders to enter the market providing a wider range in product and often leading to an increase in local employment.
Homes in Rural Areas
Policy S/DS takes no account of the sustainability benefits of locating some appropriately-sized development within or adjacent to existing villages in South Cambridgeshire.
Villages of all sizes with South Cambridgeshire benefit from increases in the housing stock: those with links to village can remain or return, new residents can find homes, the usage of local shops, community facilities and schools is increased. This maintains the resilience of established communities.
The Country Landowner’s Association’s report Sustainable Communities: the Role of Housing in Strengthening the Rural Economy (2022) states:
‘For rural areas to thrive, there needs to be an adequate, available, and diverse supply of homes, which includes different tenure types of varying sizes. The existing lack of homes in rural areas prevents young families to continue living in their community, key workers to be based near to their places of work and the elderly to downsize.’
However, the draft Local Plan makes allocations for just 265 homes on four sites adjacent to existing villages (Duxford, Highfields, and Melbourn).
This is the outcome of a fundamental flaw in the framing of the hierarchy of locations within this policy, which states that ‘jobs and homes will be met as far as possible in the following order of preference’. The hierarchy reflects an approach to sustainability that gives predominant weight to environmental factors, notably transport emissions, to the detriment of the social sustainability of existing settlements. Following this sequential hierarch leads the draft Local Plan to maximise allocations in locations in and around Cambridge as well as at new strategic sites. Only a small residual of housing need is allocated to villages, whereas there is localised housing need within almost all communities in the plan area, as regular village-level surveys show.
By failing to allocate new housing to existing villages, and ignoring the social impact of this, the draft Local Plan does not fully achieve sustainable development as defined in the NPPF.
Development of the site at Valley Farm, Meldreth would contribute to the social sustainability of the villages of Meldreth and Melbourn.
Five Year Housing Land Supply and Housing Trajectory
The Development Strategy of the draft Local Plan is underpinned by the Housing Trajectory set out in draft Appendix E. This anticipates that the local housing need (standard method) annual number of 2,309 is not achieved between 2024/25 and 2027/28, in 2032/32 or in the final four years of the plan period. For the years 2028/29 and 2029/30, anticipated completions are significantly higher, at 3,483 and 3,530 respectively. This results in a predicted number of completions for 2028-2033 of 14,427 units, which equates to a five-year supply of 5.32 years.
Analysis of the projected completions for individual sites suggests that the above anticipated completions numbers are based on estimates of completions on strategic sites for 2028/29 and 2029/30 are that are significantly above historic maximums and that do not take into account the planning context of each site.
At North West Cambridge, completion of the final Phase 1 dwellings permitted under the 2013 outline is expected in 2028. The outline application for future phases is currently under consideration and is unlikely to be approved before late 2026, with reserved matters to follow. It is therefore implausible that 305 and 376 dwellings can be delivered in 2028/29 and 2029/30 respectively. A more reasonable assumption might be 100 per year, as the trajectory anticipate for most of the 2030s.
At Northstowe, the historic maximum annual delivery was in 2018/19, when 278 dwellings were completed. Only 92 dwellings were completed in 2023/2024 (on both Phase 1 and Phase 2). Phase 1 is now almost complete and Phase 2 has 706 dwellings permitted. It is therefore implausible that 473 and 467 dwellings can be delivered in 2028/29 and 2029/30 respectively. A more reasonable assumption might be 300 per year, as the trajectory anticipate for 2030 onwards.
At Waterbeach New Town, 263 dwellings were completed in 2022/23, with completions declining since then. It is unlikely that 376 and 368 dwellings can be delivered in 2028/29 and 2029/30 respectively. A more reasonable assumption might be 300 per year, as the trajectory anticipate for 2030 onwards.
If the above reasonable adjustments are made to the housing trajectory in Appendix E, the number of predicted completions is reduced by 965 and the five-year supply for 2028-2033 falls to 4.96
It is also noted that the housing trajectory relies on historically high delivery rates in 2028/29 and 2029/30 for four further major previously allocated strategic sites: North East Cambridge, Darwin Green, Cambridge East (Marleigh and Land north of Cherry Hinton), and Cambourne West.
Given historic experience of both general and site-specific causes of delays and reductions in delivery rates, notably the delivery of major infrastructure, it is not credible to assume that seven major strategic sites will all be able to deliver at historically exceptional rates.
In order to reduce reliance on uncertain major sites and increase the likelihood that overall completion rates will be close to or exceed standard method need over the first 5-10 years of the plan period, the draft Local Plan should make significant additional allocations for smaller developments close to existing settlements and that do not require enabling infrastructure investment.
The site at Valley Farm, Meldreth is available immediately and can deliver housing within the early years of the plan period.
[on behalf of Granta Land Ltd - Land at Valley Farm, Meldreth [130982]]

Over-Reliance on Major Settlements
The Development Strategy of the draft Local Plan is reliant on high levels of housing delivery in major strategic sites to such an extent that the risk that housing need is not met is excessively high and the draft Local Plan is therefore unsound.
There are fundamental issues with the distribution of housing growth across the Plan Period.
The Councils are distributing 44% of growth across the Plan Period in new settlements, and 29% in major sites on the edge of Cambridge which are similar to new settlements (Figure 12 of the Local Plan). Combined, 73% of growth is allocated to major strategic sites.
The table below sets out the distribution of growth during the Plan Period across these new settlements and whether these have planning permission.
Table 3.1: Delivery of new strategic sites during the emerging Plan Period
Site Number of Homes to be delivered in Plan Period Total number of dwellings Extant permission Percentage of homes delivered during Plan Period
Northstowe* 6,229 10,107 Yes 62%
Waterbeach New Town* 5,727 11,531 Yes 50%
Bourn Airfield 3,500 3,500 Yes 100%
North East Cambridge 3,950 4,925 No 50%
Cambourne North 2,550 13,000 No 20%
Grange Farm New Settlement 2,550 6,000 No 43%
*Northstowe has delivered 1,401 dwellings prior to this emerging Plan Period. Waterbeach New Town has delivered 556 dwellings prior this emerging Plan Period.

The following table sets out the proposed housing trajectory of the new strategic sites which do not currently have extant consent during the emerging Local Plan timeframe.
Table 3.2: Proposed housing trajectory for new strategic sites without extant consent (2024/25-2044/45)
New Settlement 24/25-31/32 32/33 33/34 34/35 35/36 36/37 37/38 38/39 39/40 40/41 41/42 42/43 43/44 44/45
North East Cambridge 0 50 150 250 350 350 350 350 350 350 350 350 350 350
Cambridge East 0 50 150 250 350 350 350 350 350 350 350 350 350 350
Cambourne North 0 0 0 50 100 150 200 250 300 300 300 300 300 300
Grange Farm 0 0 0 50 100 150 200 250 300 300 300 300 300 300
Totals 0 100 300 600 900 1000 1100 1200 1300 1300 1300 1300 1300 1300

It is not considered that the delivery rates for these sites are realistic, particularly with regard to the new sites which are yet to have been granted planning permission:
• North East Cambridge.
• Cambridge East.
• Cambourne West.
• Grange Farm.
In the latest ‘Start to Finish’ Report, undertaken by Lichfields in 2024 , it confirms that sites comprising over 1,000 dwellings will take, on average, five years to obtain detailed planning permission and then a further 1.3-1.6 years to deliver the first dwelling.
Indeed, for sites over 2,000 dwellings, it states that the median timescale from validation of the first planning application to the completion of the first dwelling is 6.7 years.
The Councils’ Local Development Scheme anticipates that the emerging Local Plan will be submitted to the Secretary of State for examination in December 2026. In July 2024 (after their General Election win), the new Minister for Housing, Matthew Pennycook, wrote to the Planning Inspectorate and noted that the average length of time for the completion of examination had increased from 65 weeks on average in 2016 to 134 weeks on average in 2022 (approximately 2 ½ years) .
Therefore, if the Plan were submitted to the Secretary of State in December 2026, then the earliest that the Plan is likely to be adopted is May 2029, using the data above. That would be equivalent to ‘Year 6’ (2029/2030) in the proposed housing trajectory.
If these new sites were to be approved in Year 6 (2029/30), then the earliest that the first house could be delivered according to the Lichfields ‘Start to Finish’ is in Year 12 (2035/2036). It is therefore unrealistic that the first dwellings will be delivered in North East Cambridge and Cambridge East in 2032/33 and in 2034/35 in Cambourne North and Grange Farm.
The current housing trajectory figures are overly ambitious for new strategic sites. There would be a reduction in 3,000 homes across the Plan Period which would not be delivered on new strategic sites.
Therefore, in order to meet this shortfall, the Councils should focus on providing a range of sites including smaller and medium sized sizes in and adjoining existing settlements, especially ones that have a number of services and facilities.
The Councils’ housing trajectory also reliant on the new strategic sites delivering 350 dwellings per annum. This is equivalent to seven plots delivering 50 dwellings per annum, by several housebuilders.
The Lichfields ‘Start to Finish’ document also sets out the housing completions of large sites. The table below sets out the average delivery of sites which are for over 5,000 dwellings across the years.
Table 3.2: Table of average housing delivery on sites larger than 5,000 dwellings
Site Name No of Dwellings No of Years of Delivery Average Delivery (rounded)
Former Alconbury Weald, Huntingdon 5,000 2 208
Priors Hall, Northamptonshire 5,200 11 135
North West Preston 5,300 8 290
East Kettering SUE 5,500 6 133
Sherford, South Hams 5,500 7 119
South Ashford Garden Community 5,750 2 75
Houlton (Rugby Radio Station) 6,200 3 139
The Hamptons (Peterborough) 6,320 25 224
Ebbsfleet 15,000 14 255

Therefore, the table above demonstrates that none of these new settlements achieved, on average, 350 dwellings per annum. Therefore, there should be a greater focus on delivering the required housing across sustainable settlements.
There are also concerns about the principle of the development at North East Cambridge, Cambridge East, Cambourne North and Grange Farm, although it is noted that the Councils acknowledge that North East Cambridge may not be available due to the Government withdrawing funding for the wastewater treatment relocation.
Regarding Cambridge East (the existing Cambridge Airport), in October 2025, Marshall Group confirmed that they were not relocating to Cranfield Airport, in Bedfordshire, as it was considered “no longer affordable ”.
Since then, there has been no public reporting or statements setting out when Marshall Group intends to vacate the Site. Therefore, it is uncertain whether the emerging Local Plan can be reliant on these dwellings during the Local Plan period.
With respect to Cambourne North, the delivery of the settlement extension is principally reliant on the proposed new station that will be delivered as part of East West Rail.
Although it is acknowledged that in June 2025, as part of the spending review, the Government committed a further £2.5 billion for the continued delivery of East West Rail, there is not a certainty that this will be delivered. This Government is fully committed to the delivery of East West Rail but there are no guarantees that a future government would be as committed. Therefore, the emerging Local Plan should focus more growth in Rural/Minor Rural Centres.
Regarding Grange Farm, there is concern that there is currently no infrastructure and none planned, with the scheme wholly reliant on an extension to CSET which is currently not in the project scope. The delivery of CSET is not within the control of the LPA or the site promotors.
The Deliverability Paper that was submitted for Grange Farm as part of the previous ‘call for sites’, confirms that 3,560 dwellings (market and affordable) can be delivered during the emerging Local Plan period with the first dwellings being delivered in 2030.
The Councils’ housing trajectory states that only 2,550 dwellings can be during the Plan Period, so our client would question how accurate these figures are by both the Councils and the promoter for Grange Farm.
There is also a discrepancy between the number in the Housing Trajectory provided by the Council (up to 300 dwellings in 2040) and only 275 dwellings in the Housing Deliverability Note . Therefore, it is not clear that the Council will be able to deliver that number of dwellings across the Plan Period.
In total, as set out in Figure 12 of the emerging Local Plan above, new settlements and edge of Cambridge sites will provide 73% of the total housing supply. Given the timings set out in the Lichfields ‘Start to Finish’ report, there is a severe risk of delay in delivering a significant number of Greater Cambridge’s housing sites, which will mean that the Councils will not be able to meet their housing needs across the Plan Period. If the Councils cannot demonstrate a five-year housing land supply or has a housing delivery percentage of less than 75%, set out in the Government’s Housing Delivery Test, then the Plan would be considered out of date. It would, therefore, be subject to paragraph 11 of the NPPF (2024) and attract speculative development.
In order to avoid this scenario and to ensure as far as possible a plan-led system can be successfully implemented and delivered, sites are needed that can help the Council deliver a consistent and deliverable supply of housing across the Plan Period, reducing the risk of the Council not being able to meet its housing needs, thereby attracting speculative development.
A greater mix of smaller and medium sized sites would help to ensure that in future Greater Cambridge is able to demonstrate a five-year supply of housing land. Smaller and medium sized sites typically come forward quicker that new large strategic sites which require significant infrastructure to support them. A good mix of these smaller sized sites also enables a wider range of house builders to enter the market providing a wider range in product and often leading to an increase in local employment.
Homes in Rural Areas
Policy S/DS takes no account of the sustainability benefits of locating some appropriately-sized development within or adjacent to existing villages in South Cambridgeshire.
Villages of all sizes with South Cambridgeshire benefit from increases in the housing stock: those with links to village can remain or return, new residents can find homes, the usage of local shops, community facilities and schools is increased. This maintains the resilience of established communities.
The Country Landowner’s Association’s report Sustainable Communities: the Role of Housing in Strengthening the Rural Economy (2022) states:
‘For rural areas to thrive, there needs to be an adequate, available, and diverse supply of homes, which includes different tenure types of varying sizes. The existing lack of homes in rural areas prevents young families to continue living in their community, key workers to be based near to their places of work and the elderly to downsize.’
However, the draft Local Plan makes allocations for just 265 homes on four sites adjacent to existing villages (Duxford, Highfields, and Melbourn).
This is the outcome of a fundamental flaw in the framing of the hierarchy of locations within this policy, which states that ‘jobs and homes will be met as far as possible in the following order of preference’. The hierarchy reflects an approach to sustainability that gives predominant weight to environmental factors, notably transport emissions, to the detriment of the social sustainability of existing settlements. Following this sequential hierarch leads the draft Local Plan to maximise allocations in locations in and around Cambridge as well as at new strategic sites. Only a small residual of housing need is allocated to villages, whereas there is localised housing need within almost all communities in the plan area, as regular village-level surveys show.
By failing to allocate new housing to existing villages, and ignoring the social impact of this, the draft Local Plan does not fully achieve sustainable development as defined in the NPPF.
Development of the site at Valley Farm, Meldreth would contribute to the social sustainability of the villages of Meldreth and Melbourn.
Five Year Housing Land Supply and Housing Trajectory
The Development Strategy of the draft Local Plan is underpinned by the Housing Trajectory set out in draft Appendix E. This anticipates that the local housing need (standard method) annual number of 2,309 is not achieved between 2024/25 and 2027/28, in 2032/32 or in the final four years of the plan period. For the years 2028/29 and 2029/30, anticipated completions are significantly higher, at 3,483 and 3,530 respectively. This results in a predicted number of completions for 2028-2033 of 14,427 units, which equates to a five-year supply of 5.32 years.
Analysis of the projected completions for individual sites suggests that the above anticipated completions numbers are based on estimates of completions on strategic sites for 2028/29 and 2029/30 are that are significantly above historic maximums and that do not take into account the planning context of each site.
At North West Cambridge, completion of the final Phase 1 dwellings permitted under the 2013 outline is expected in 2028. The outline application for future phases is currently under consideration and is unlikely to be approved before late 2026, with reserved matters to follow. It is therefore implausible that 305 and 376 dwellings can be delivered in 2028/29 and 2029/30 respectively. A more reasonable assumption might be 100 per year, as the trajectory anticipate for most of the 2030s.
At Northstowe, the historic maximum annual delivery was in 2018/19, when 278 dwellings were completed. Only 92 dwellings were completed in 2023/2024 (on both Phase 1 and Phase 2). Phase 1 is now almost complete and Phase 2 has 706 dwellings permitted. It is therefore implausible that 473 and 467 dwellings can be delivered in 2028/29 and 2029/30 respectively. A more reasonable assumption might be 300 per year, as the trajectory anticipate for 2030 onwards.
At Waterbeach New Town, 263 dwellings were completed in 2022/23, with completions declining since then. It is unlikely that 376 and 368 dwellings can be delivered in 2028/29 and 2029/30 respectively. A more reasonable assumption might be 300 per year, as the trajectory anticipate for 2030 onwards.
If the above reasonable adjustments are made to the housing trajectory in Appendix E, the number of predicted completions is reduced by 965 and the five-year supply for 2028-2033 falls to 4.96
It is also noted that the housing trajectory relies on historically high delivery rates in 2028/29 and 2029/30 for four further major previously allocated strategic sites: North East Cambridge, Darwin Green, Cambridge East (Marleigh and Land north of Cherry Hinton), and Cambourne West.
Given historic experience of both general and site-specific causes of delays and reductions in delivery rates, notably the delivery of major infrastructure, it is not credible to assume that seven major strategic sites will all be able to deliver at historically exceptional rates.
In order to reduce reliance on uncertain major sites and increase the likelihood that overall completion rates will be close to or exceed standard method need over the first 5-10 years of the plan period, the draft Local Plan should make significant additional allocations for smaller developments close to existing settlements and that do not require enabling infrastructure investment.
The site at Valley Farm, Meldreth is available immediately and can deliver housing within the early years of the plan period.
[on behalf of Granta Land Ltd - Land at Valley Farm, Meldreth [130982]]

Over-Reliance on Major Settlements
The Development Strategy of the draft Local Plan is reliant on high levels of housing delivery in major strategic sites to such an extent that the risk that housing need is not met is excessively high and the draft Local Plan is therefore unsound.
There are fundamental issues with the distribution of housing growth across the Plan Period.
The Councils are distributing 44% of growth across the Plan Period in new settlements, and 29% in major sites on the edge of Cambridge which are similar to new settlements (Figure 12 of the Local Plan). Combined, 73% of growth is allocated to major strategic sites.
The table below sets out the distribution of growth during the Plan Period across these new settlements and whether these have planning permission.
Table 3.1: Delivery of new strategic sites during the emerging Plan Period
Site Number of Homes to be delivered in Plan Period Total number of dwellings Extant permission Percentage of homes delivered during Plan Period
Northstowe* 6,229 10,107 Yes 62%
Waterbeach New Town* 5,727 11,531 Yes 50%
Bourn Airfield 3,500 3,500 Yes 100%
North East Cambridge 3,950 4,925 No 50%
Cambourne North 2,550 13,000 No 20%
Grange Farm New Settlement 2,550 6,000 No 43%
*Northstowe has delivered 1,401 dwellings prior to this emerging Plan Period. Waterbeach New Town has delivered 556 dwellings prior this emerging Plan Period.

The following table sets out the proposed housing trajectory of the new strategic sites which do not currently have extant consent during the emerging Local Plan timeframe.
Table 3.2: Proposed housing trajectory for new strategic sites without extant consent (2024/25-2044/45)
New Settlement 24/25-31/32 32/33 33/34 34/35 35/36 36/37 37/38 38/39 39/40 40/41 41/42 42/43 43/44 44/45
North East Cambridge 0 50 150 250 350 350 350 350 350 350 350 350 350 350
Cambridge East 0 50 150 250 350 350 350 350 350 350 350 350 350 350
Cambourne North 0 0 0 50 100 150 200 250 300 300 300 300 300 300
Grange Farm 0 0 0 50 100 150 200 250 300 300 300 300 300 300
Totals 0 100 300 600 900 1000 1100 1200 1300 1300 1300 1300 1300 1300

It is not considered that the delivery rates for these sites are realistic, particularly with regard to the new sites which are yet to have been granted planning permission:
• North East Cambridge.
• Cambridge East.
• Cambourne West.
• Grange Farm.
In the latest ‘Start to Finish’ Report, undertaken by Lichfields in 2024 , it confirms that sites comprising over 1,000 dwellings will take, on average, five years to obtain detailed planning permission and then a further 1.3-1.6 years to deliver the first dwelling.
Indeed, for sites over 2,000 dwellings, it states that the median timescale from validation of the first planning application to the completion of the first dwelling is 6.7 years.
The Councils’ Local Development Scheme anticipates that the emerging Local Plan will be submitted to the Secretary of State for examination in December 2026. In July 2024 (after their General Election win), the new Minister for Housing, Matthew Pennycook, wrote to the Planning Inspectorate and noted that the average length of time for the completion of examination had increased from 65 weeks on average in 2016 to 134 weeks on average in 2022 (approximately 2 ½ years) .
Therefore, if the Plan were submitted to the Secretary of State in December 2026, then the earliest that the Plan is likely to be adopted is May 2029, using the data above. That would be equivalent to ‘Year 6’ (2029/2030) in the proposed housing trajectory.
If these new sites were to be approved in Year 6 (2029/30), then the earliest that the first house could be delivered according to the Lichfields ‘Start to Finish’ is in Year 12 (2035/2036). It is therefore unrealistic that the first dwellings will be delivered in North East Cambridge and Cambridge East in 2032/33 and in 2034/35 in Cambourne North and Grange Farm.
The current housing trajectory figures are overly ambitious for new strategic sites. There would be a reduction in 3,000 homes across the Plan Period which would not be delivered on new strategic sites.
Therefore, in order to meet this shortfall, the Councils should focus on providing a range of sites including smaller and medium sized sizes in and adjoining existing settlements, especially ones that have a number of services and facilities.
The Councils’ housing trajectory also reliant on the new strategic sites delivering 350 dwellings per annum. This is equivalent to seven plots delivering 50 dwellings per annum, by several housebuilders.
The Lichfields ‘Start to Finish’ document also sets out the housing completions of large sites. The table below sets out the average delivery of sites which are for over 5,000 dwellings across the years.
Table 3.2: Table of average housing delivery on sites larger than 5,000 dwellings
Site Name No of Dwellings No of Years of Delivery Average Delivery (rounded)
Former Alconbury Weald, Huntingdon 5,000 2 208
Priors Hall, Northamptonshire 5,200 11 135
North West Preston 5,300 8 290
East Kettering SUE 5,500 6 133
Sherford, South Hams 5,500 7 119
South Ashford Garden Community 5,750 2 75
Houlton (Rugby Radio Station) 6,200 3 139
The Hamptons (Peterborough) 6,320 25 224
Ebbsfleet 15,000 14 255

Therefore, the table above demonstrates that none of these new settlements achieved, on average, 350 dwellings per annum. Therefore, there should be a greater focus on delivering the required housing across sustainable settlements.
There are also concerns about the principle of the development at North East Cambridge, Cambridge East, Cambourne North and Grange Farm, although it is noted that the Councils acknowledge that North East Cambridge may not be available due to the Government withdrawing funding for the wastewater treatment relocation.
Regarding Cambridge East (the existing Cambridge Airport), in October 2025, Marshall Group confirmed that they were not relocating to Cranfield Airport, in Bedfordshire, as it was considered “no longer affordable ”.
Since then, there has been no public reporting or statements setting out when Marshall Group intends to vacate the Site. Therefore, it is uncertain whether the emerging Local Plan can be reliant on these dwellings during the Local Plan period.
With respect to Cambourne North, the delivery of the settlement extension is principally reliant on the proposed new station that will be delivered as part of East West Rail.
Although it is acknowledged that in June 2025, as part of the spending review, the Government committed a further £2.5 billion for the continued delivery of East West Rail, there is not a certainty that this will be delivered. This Government is fully committed to the delivery of East West Rail but there are no guarantees that a future government would be as committed. Therefore, the emerging Local Plan should focus more growth in Rural/Minor Rural Centres.
Regarding Grange Farm, there is concern that there is currently no infrastructure and none planned, with the scheme wholly reliant on an extension to CSET which is currently not in the project scope. The delivery of CSET is not within the control of the LPA or the site promotors.
The Deliverability Paper that was submitted for Grange Farm as part of the previous ‘call for sites’, confirms that 3,560 dwellings (market and affordable) can be delivered during the emerging Local Plan period with the first dwellings being delivered in 2030.
The Councils’ housing trajectory states that only 2,550 dwellings can be during the Plan Period, so our client would question how accurate these figures are by both the Councils and the promoter for Grange Farm.
There is also a discrepancy between the number in the Housing Trajectory provided by the Council (up to 300 dwellings in 2040) and only 275 dwellings in the Housing Deliverability Note . Therefore, it is not clear that the Council will be able to deliver that number of dwellings across the Plan Period.
In total, as set out in Figure 12 of the emerging Local Plan above, new settlements and edge of Cambridge sites will provide 73% of the total housing supply. Given the timings set out in the Lichfields ‘Start to Finish’ report, there is a severe risk of delay in delivering a significant number of Greater Cambridge’s housing sites, which will mean that the Councils will not be able to meet their housing needs across the Plan Period. If the Councils cannot demonstrate a five-year housing land supply or has a housing delivery percentage of less than 75%, set out in the Government’s Housing Delivery Test, then the Plan would be considered out of date. It would, therefore, be subject to paragraph 11 of the NPPF (2024) and attract speculative development.
In order to avoid this scenario and to ensure as far as possible a plan-led system can be successfully implemented and delivered, sites are needed that can help the Council deliver a consistent and deliverable supply of housing across the Plan Period, reducing the risk of the Council not being able to meet its housing needs, thereby attracting speculative development.
A greater mix of smaller and medium sized sites would help to ensure that in future Greater Cambridge is able to demonstrate a five-year supply of housing land. Smaller and medium sized sites typically come forward quicker that new large strategic sites which require significant infrastructure to support them. A good mix of these smaller sized sites also enables a wider range of house builders to enter the market providing a wider range in product and often leading to an increase in local employment.
Homes in Rural Areas
Policy S/DS takes no account of the sustainability benefits of locating some appropriately-sized development within or adjacent to existing villages in South Cambridgeshire.
Villages of all sizes with South Cambridgeshire benefit from increases in the housing stock: those with links to village can remain or return, new residents can find homes, the usage of local shops, community facilities and schools is increased. This maintains the resilience of established communities.
The Country Landowner’s Association’s report Sustainable Communities: the Role of Housing in Strengthening the Rural Economy (2022) states:
‘For rural areas to thrive, there needs to be an adequate, available, and diverse supply of homes, which includes different tenure types of varying sizes. The existing lack of homes in rural areas prevents young families to continue living in their community, key workers to be based near to their places of work and the elderly to downsize.’
However, the draft Local Plan makes allocations for just 265 homes on four sites adjacent to existing villages (Duxford, Highfields, and Melbourn).
This is the outcome of a fundamental flaw in the framing of the hierarchy of locations within this policy, which states that ‘jobs and homes will be met as far as possible in the following order of preference’. The hierarchy reflects an approach to sustainability that gives predominant weight to environmental factors, notably transport emissions, to the detriment of the social sustainability of existing settlements. Following this sequential hierarch leads the draft Local Plan to maximise allocations in locations in and around Cambridge as well as at new strategic sites. Only a small residual of housing need is allocated to villages, whereas there is localised housing need within almost all communities in the plan area, as regular village-level surveys show.
By failing to allocate new housing to existing villages, and ignoring the social impact of this, the draft Local Plan does not fully achieve sustainable development as defined in the NPPF.
Development of the site at Valley Farm, Meldreth would contribute to the social sustainability of the villages of Meldreth and Melbourn.
Five Year Housing Land Supply and Housing Trajectory
The Development Strategy of the draft Local Plan is underpinned by the Housing Trajectory set out in draft Appendix E. This anticipates that the local housing need (standard method) annual number of 2,309 is not achieved between 2024/25 and 2027/28, in 2032/32 or in the final four years of the plan period. For the years 2028/29 and 2029/30, anticipated completions are significantly higher, at 3,483 and 3,530 respectively. This results in a predicted number of completions for 2028-2033 of 14,427 units, which equates to a five-year supply of 5.32 years.
Analysis of the projected completions for individual sites suggests that the above anticipated completions numbers are based on estimates of completions on strategic sites for 2028/29 and 2029/30 are that are significantly above historic maximums and that do not take into account the planning context of each site.
At North West Cambridge, completion of the final Phase 1 dwellings permitted under the 2013 outline is expected in 2028. The outline application for future phases is currently under consideration and is unlikely to be approved before late 2026, with reserved matters to follow. It is therefore implausible that 305 and 376 dwellings can be delivered in 2028/29 and 2029/30 respectively. A more reasonable assumption might be 100 per year, as the trajectory anticipate for most of the 2030s.
At Northstowe, the historic maximum annual delivery was in 2018/19, when 278 dwellings were completed. Only 92 dwellings were completed in 2023/2024 (on both Phase 1 and Phase 2). Phase 1 is now almost complete and Phase 2 has 706 dwellings permitted. It is therefore implausible that 473 and 467 dwellings can be delivered in 2028/29 and 2029/30 respectively. A more reasonable assumption might be 300 per year, as the trajectory anticipate for 2030 onwards.
At Waterbeach New Town, 263 dwellings were completed in 2022/23, with completions declining since then. It is unlikely that 376 and 368 dwellings can be delivered in 2028/29 and 2029/30 respectively. A more reasonable assumption might be 300 per year, as the trajectory anticipate for 2030 onwards.
If the above reasonable adjustments are made to the housing trajectory in Appendix E, the number of predicted completions is reduced by 965 and the five-year supply for 2028-2033 falls to 4.96
It is also noted that the housing trajectory relies on historically high delivery rates in 2028/29 and 2029/30 for four further major previously allocated strategic sites: North East Cambridge, Darwin Green, Cambridge East (Marleigh and Land north of Cherry Hinton), and Cambourne West.
Given historic experience of both general and site-specific causes of delays and reductions in delivery rates, notably the delivery of major infrastructure, it is not credible to assume that seven major strategic sites will all be able to deliver at historically exceptional rates.
In order to reduce reliance on uncertain major sites and increase the likelihood that overall completion rates will be close to or exceed standard method need over the first 5-10 years of the plan period, the draft Local Plan should make significant additional allocations for smaller developments close to existing settlements and that do not require enabling infrastructure investment.
The site at Valley Farm, Meldreth is available immediately and can deliver housing within the early years of the plan period.
[on behalf of Granta Land Ltd - Land at Valley Farm, Meldreth [130982]]

Over-Reliance on Major Settlements
The Development Strategy of the draft Local Plan is reliant on high levels of housing delivery in major strategic sites to such an extent that the risk that housing need is not met is excessively high and the draft Local Plan is therefore unsound.
There are fundamental issues with the distribution of housing growth across the Plan Period.
The Councils are distributing 44% of growth across the Plan Period in new settlements, and 29% in major sites on the edge of Cambridge which are similar to new settlements (Figure 12 of the Local Plan). Combined, 73% of growth is allocated to major strategic sites.
The table below sets out the distribution of growth during the Plan Period across these new settlements and whether these have planning permission.
Table 3.1: Delivery of new strategic sites during the emerging Plan Period
Site Number of Homes to be delivered in Plan Period Total number of dwellings Extant permission Percentage of homes delivered during Plan Period
Northstowe* 6,229 10,107 Yes 62%
Waterbeach New Town* 5,727 11,531 Yes 50%
Bourn Airfield 3,500 3,500 Yes 100%
North East Cambridge 3,950 4,925 No 50%
Cambourne North 2,550 13,000 No 20%
Grange Farm New Settlement 2,550 6,000 No 43%
*Northstowe has delivered 1,401 dwellings prior to this emerging Plan Period. Waterbeach New Town has delivered 556 dwellings prior this emerging Plan Period.

The following table sets out the proposed housing trajectory of the new strategic sites which do not currently have extant consent during the emerging Local Plan timeframe.
Table 3.2: Proposed housing trajectory for new strategic sites without extant consent (2024/25-2044/45)
New Settlement 24/25-31/32 32/33 33/34 34/35 35/36 36/37 37/38 38/39 39/40 40/41 41/42 42/43 43/44 44/45
North East Cambridge 0 50 150 250 350 350 350 350 350 350 350 350 350 350
Cambridge East 0 50 150 250 350 350 350 350 350 350 350 350 350 350
Cambourne North 0 0 0 50 100 150 200 250 300 300 300 300 300 300
Grange Farm 0 0 0 50 100 150 200 250 300 300 300 300 300 300
Totals 0 100 300 600 900 1000 1100 1200 1300 1300 1300 1300 1300 1300

It is not considered that the delivery rates for these sites are realistic, particularly with regard to the new sites which are yet to have been granted planning permission:
• North East Cambridge.
• Cambridge East.
• Cambourne West.
• Grange Farm.
In the latest ‘Start to Finish’ Report, undertaken by Lichfields in 2024 , it confirms that sites comprising over 1,000 dwellings will take, on average, five years to obtain detailed planning permission and then a further 1.3-1.6 years to deliver the first dwelling.
Indeed, for sites over 2,000 dwellings, it states that the median timescale from validation of the first planning application to the completion of the first dwelling is 6.7 years.
The Councils’ Local Development Scheme anticipates that the emerging Local Plan will be submitted to the Secretary of State for examination in December 2026. In July 2024 (after their General Election win), the new Minister for Housing, Matthew Pennycook, wrote to the Planning Inspectorate and noted that the average length of time for the completion of examination had increased from 65 weeks on average in 2016 to 134 weeks on average in 2022 (approximately 2 ½ years) .
Therefore, if the Plan were submitted to the Secretary of State in December 2026, then the earliest that the Plan is likely to be adopted is May 2029, using the data above. That would be equivalent to ‘Year 6’ (2029/2030) in the proposed housing trajectory.
If these new sites were to be approved in Year 6 (2029/30), then the earliest that the first house could be delivered according to the Lichfields ‘Start to Finish’ is in Year 12 (2035/2036). It is therefore unrealistic that the first dwellings will be delivered in North East Cambridge and Cambridge East in 2032/33 and in 2034/35 in Cambourne North and Grange Farm.
The current housing trajectory figures are overly ambitious for new strategic sites. There would be a reduction in 3,000 homes across the Plan Period which would not be delivered on new strategic sites.
Therefore, in order to meet this shortfall, the Councils should focus on providing a range of sites including smaller and medium sized sizes in and adjoining existing settlements, especially ones that have a number of services and facilities.
The Councils’ housing trajectory also reliant on the new strategic sites delivering 350 dwellings per annum. This is equivalent to seven plots delivering 50 dwellings per annum, by several housebuilders.
The Lichfields ‘Start to Finish’ document also sets out the housing completions of large sites. The table below sets out the average delivery of sites which are for over 5,000 dwellings across the years.
Table 3.2: Table of average housing delivery on sites larger than 5,000 dwellings
Site Name No of Dwellings No of Years of Delivery Average Delivery (rounded)
Former Alconbury Weald, Huntingdon 5,000 2 208
Priors Hall, Northamptonshire 5,200 11 135
North West Preston 5,300 8 290
East Kettering SUE 5,500 6 133
Sherford, South Hams 5,500 7 119
South Ashford Garden Community 5,750 2 75
Houlton (Rugby Radio Station) 6,200 3 139
The Hamptons (Peterborough) 6,320 25 224
Ebbsfleet 15,000 14 255

Therefore, the table above demonstrates that none of these new settlements achieved, on average, 350 dwellings per annum. Therefore, there should be a greater focus on delivering the required housing across sustainable settlements.
There are also concerns about the principle of the development at North East Cambridge, Cambridge East, Cambourne North and Grange Farm, although it is noted that the Councils acknowledge that North East Cambridge may not be available due to the Government withdrawing funding for the wastewater treatment relocation.
Regarding Cambridge East (the existing Cambridge Airport), in October 2025, Marshall Group confirmed that they were not relocating to Cranfield Airport, in Bedfordshire, as it was considered “no longer affordable ”.
Since then, there has been no public reporting or statements setting out when Marshall Group intends to vacate the Site. Therefore, it is uncertain whether the emerging Local Plan can be reliant on these dwellings during the Local Plan period.
With respect to Cambourne North, the delivery of the settlement extension is principally reliant on the proposed new station that will be delivered as part of East West Rail.
Although it is acknowledged that in June 2025, as part of the spending review, the Government committed a further £2.5 billion for the continued delivery of East West Rail, there is not a certainty that this will be delivered. This Government is fully committed to the delivery of East West Rail but there are no guarantees that a future government would be as committed. Therefore, the emerging Local Plan should focus more growth in Rural/Minor Rural Centres.
Regarding Grange Farm, there is concern that there is currently no infrastructure and none planned, with the scheme wholly reliant on an extension to CSET which is currently not in the project scope. The delivery of CSET is not within the control of the LPA or the site promotors.
The Deliverability Paper that was submitted for Grange Farm as part of the previous ‘call for sites’, confirms that 3,560 dwellings (market and affordable) can be delivered during the emerging Local Plan period with the first dwellings being delivered in 2030.
The Councils’ housing trajectory states that only 2,550 dwellings can be during the Plan Period, so our client would question how accurate these figures are by both the Councils and the promoter for Grange Farm.
There is also a discrepancy between the number in the Housing Trajectory provided by the Council (up to 300 dwellings in 2040) and only 275 dwellings in the Housing Deliverability Note . Therefore, it is not clear that the Council will be able to deliver that number of dwellings across the Plan Period.
In total, as set out in Figure 12 of the emerging Local Plan above, new settlements and edge of Cambridge sites will provide 73% of the total housing supply. Given the timings set out in the Lichfields ‘Start to Finish’ report, there is a severe risk of delay in delivering a significant number of Greater Cambridge’s housing sites, which will mean that the Councils will not be able to meet their housing needs across the Plan Period. If the Councils cannot demonstrate a five-year housing land supply or has a housing delivery percentage of less than 75%, set out in the Government’s Housing Delivery Test, then the Plan would be considered out of date. It would, therefore, be subject to paragraph 11 of the NPPF (2024) and attract speculative development.
In order to avoid this scenario and to ensure as far as possible a plan-led system can be successfully implemented and delivered, sites are needed that can help the Council deliver a consistent and deliverable supply of housing across the Plan Period, reducing the risk of the Council not being able to meet its housing needs, thereby attracting speculative development.
A greater mix of smaller and medium sized sites would help to ensure that in future Greater Cambridge is able to demonstrate a five-year supply of housing land. Smaller and medium sized sites typically come forward quicker that new large strategic sites which require significant infrastructure to support them. A good mix of these smaller sized sites also enables a wider range of house builders to enter the market providing a wider range in product and often leading to an increase in local employment.
Homes in Rural Areas
Policy S/DS takes no account of the sustainability benefits of locating some appropriately-sized development within or adjacent to existing villages in South Cambridgeshire.
Villages of all sizes with South Cambridgeshire benefit from increases in the housing stock: those with links to village can remain or return, new residents can find homes, the usage of local shops, community facilities and schools is increased. This maintains the resilience of established communities.
The Country Landowner’s Association’s report Sustainable Communities: the Role of Housing in Strengthening the Rural Economy (2022) states:
‘For rural areas to thrive, there needs to be an adequate, available, and diverse supply of homes, which includes different tenure types of varying sizes. The existing lack of homes in rural areas prevents young families to continue living in their community, key workers to be based near to their places of work and the elderly to downsize.’
However, the draft Local Plan makes allocations for just 265 homes on four sites adjacent to existing villages (Duxford, Highfields, and Melbourn).
This is the outcome of a fundamental flaw in the framing of the hierarchy of locations within this policy, which states that ‘jobs and homes will be met as far as possible in the following order of preference’. The hierarchy reflects an approach to sustainability that gives predominant weight to environmental factors, notably transport emissions, to the detriment of the social sustainability of existing settlements. Following this sequential hierarch leads the draft Local Plan to maximise allocations in locations in and around Cambridge as well as at new strategic sites. Only a small residual of housing need is allocated to villages, whereas there is localised housing need within almost all communities in the plan area, as regular village-level surveys show.
By failing to allocate new housing to existing villages, and ignoring the social impact of this, the draft Local Plan does not fully achieve sustainable development as defined in the NPPF.
Development of the site at Valley Farm, Meldreth would contribute to the social sustainability of the villages of Meldreth and Melbourn.
Five Year Housing Land Supply and Housing Trajectory
The Development Strategy of the draft Local Plan is underpinned by the Housing Trajectory set out in draft Appendix E. This anticipates that the local housing need (standard method) annual number of 2,309 is not achieved between 2024/25 and 2027/28, in 2032/32 or in the final four years of the plan period. For the years 2028/29 and 2029/30, anticipated completions are significantly higher, at 3,483 and 3,530 respectively. This results in a predicted number of completions for 2028-2033 of 14,427 units, which equates to a five-year supply of 5.32 years.
Analysis of the projected completions for individual sites suggests that the above anticipated completions numbers are based on estimates of completions on strategic sites for 2028/29 and 2029/30 are that are significantly above historic maximums and that do not take into account the planning context of each site.
At North West Cambridge, completion of the final Phase 1 dwellings permitted under the 2013 outline is expected in 2028. The outline application for future phases is currently under consideration and is unlikely to be approved before late 2026, with reserved matters to follow. It is therefore implausible that 305 and 376 dwellings can be delivered in 2028/29 and 2029/30 respectively. A more reasonable assumption might be 100 per year, as the trajectory anticipate for most of the 2030s.
At Northstowe, the historic maximum annual delivery was in 2018/19, when 278 dwellings were completed. Only 92 dwellings were completed in 2023/2024 (on both Phase 1 and Phase 2). Phase 1 is now almost complete and Phase 2 has 706 dwellings permitted. It is therefore implausible that 473 and 467 dwellings can be delivered in 2028/29 and 2029/30 respectively. A more reasonable assumption might be 300 per year, as the trajectory anticipate for 2030 onwards.
At Waterbeach New Town, 263 dwellings were completed in 2022/23, with completions declining since then. It is unlikely that 376 and 368 dwellings can be delivered in 2028/29 and 2029/30 respectively. A more reasonable assumption might be 300 per year, as the trajectory anticipate for 2030 onwards.
If the above reasonable adjustments are made to the housing trajectory in Appendix E, the number of predicted completions is reduced by 965 and the five-year supply for 2028-2033 falls to 4.96
It is also noted that the housing trajectory relies on historically high delivery rates in 2028/29 and 2029/30 for four further major previously allocated strategic sites: North East Cambridge, Darwin Green, Cambridge East (Marleigh and Land north of Cherry Hinton), and Cambourne West.
Given historic experience of both general and site-specific causes of delays and reductions in delivery rates, notably the delivery of major infrastructure, it is not credible to assume that seven major strategic sites will all be able to deliver at historically exceptional rates.
In order to reduce reliance on uncertain major sites and increase the likelihood that overall completion rates will be close to or exceed standard method need over the first 5-10 years of the plan period, the draft Local Plan should make significant additional allocations for smaller developments close to existing settlements and that do not require enabling infrastructure investment.
The site at Valley Farm, Meldreth is available immediately and can deliver housing within the early years of the plan period.
[on behalf of Granta Land Ltd - Land at Valley Farm, Meldreth [130982]]