Draft Greater Cambridge Local Plan for consultation

The Plan should plan for the higher jobs and homes figures as set out in the corresponding evidence base rather than the mid-range it currently plans for. This would be more consistent with the aspiration of growth in Cambridge as set out by the Government, and reflective of the significant proposed investment in the region.

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

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

As set out in the Employment and Housing Needs Update, during the strongest phase of growth (2010–
2020), the Greater Cambridge economy expanded by almost 4,000 jobs per year. The evidence identifies a
‘Central growth’ scenario of 73,200 jobs across the plan period, representing sustained annual growth of
around 3,500 jobs. Crucially, the Central growth scenario builds in assumptions of slower periods,
contractions, and economic shocks, and is therefore inherently conservative rather than reflective of the
full growth capacity of the Cambridge economy and its resilience to riding these shocks.

However, there have been recent significant changes in the national and strategic planning policy
context that heighten the urgency in increasing job creation and housing supply and result in a stepchange
in the wider policy framework within which the Draft Local Plan must be considered.

On 23rd August 2024, Matthew Pennycook reaffirmed the Government’s commitment to
Cambridge stating; “The economic growth of Cambridge has been a phenomenal success and we should
seek to maximise the potential contribution that Greater Cambridge could make to the UK economy.”
Pennycook goes on to say; “Greater Cambridge has a vital role to play in this Government’s mission to
kickstart economic growth.” The Cambridge Growth Company was then established in 2024 to address
barriers to growth and help unlock Greater Cambridge’s full potential. In terms of approach, in October
2025, the Government announced its intention to consult on the case for a centrally led Development
Corporation as one potential route for delivery. This is to be the subject of statutory consultation in 2026.

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

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

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

- Greater recognition of the importance of delivering homes in the rural area.

- Allocation of smaller sites to ensure robustness of delivery, choice and vitality of the rural area.

Whilst in principle we do not object to the principle of seeking to deliver a large number of new homes at
scale as set out in Policy S/DS. We consider that this approach sets the Council on a path of over-reliance
on these sites which is problematic for the following reasons:

- The speed at which these developments can deliver homes is often far slower than the Council
has envisaged historically. A review of historic Annual Monitoring Reports demonstrates that whilst
some of the large strategic sites in the current Development Plan, may now be delivering at an
appropriate rate, most sites came on stream several years later than anticipated, did not deliver
as quickly once the first completions were achieved, and many still deliver less homes year on
year than planned for.

- The Council has not identified any new allocations for housing in the rural area which fails to
support the vitality of the rural area and existing settlements. We believe that this decision, has
been made in part, to avoid development in the Green Belt, and therefore fails to strike a more
balanced approach to housing delivery and mix of housing across the Plan period.

- The ‘lumping’ together of rural centres, minor rural centres, group villages and infill villages from
the settlement hierarchy (taken from Policy S/SH), effectively as the locations with the lowest
preference to deliver jobs and homes, clearly fails to distinguish between what may be highly
sustainable locations in the rural area (ie: Histon and Impington) a Rural Centre-the highest of
these categories (where there will be no limit on scheme size), and which is clearly capable of
delivering an appropriate scale of development (ie: up to 50 dwelling sized sites as encouraged in
the adopted Neighbourhood Plan).

Small and Medium Sized Sites

Small and medium sites such as this Site are key to a far more balance approach to housing. Paragraph
73 of the NPPF (December 2024) identifies that small and medium sized sites can make an important
contribution to meeting the housing requirement of an area. They are also essential for small and medium
enterprise housebuilders to deliver new homes whilst being built out relatively quickly.

The Plan does not propose to allocate any new housing sites to address this requirement, essentially
because they consider:

- It is challenging to identify a large number of small sites to meet the 4,820 homes required to meet
the 10% requirement.

- It would be considered to undermine the Council’s development strategy and necessitates the
release of Green Belt sites conflicting with the aim of protecting the Cambridge Green Belt as the
larger and better served villages are located within the Green Belt.

We have two concerns with this approach which need to be considered and addressed by the next iteration
of the plan.

Green Belt / Grey Belt

Firstly, the Green Belt Assessment which underpins the Council’s evidence base is dated 2021 which predates
the introduction of Grey Belt in planning policy.

The Council has not publicly committed to undertake a review of potential Grey Belt sites and their
development potential as an alternative spatial strategy, which is apparent in the October 2025
Sustainability Appraisal.

However, Bidwells understands that consultants on behalf of Greater Cambridge are currently considering
the process of examining Grey Belt issues and possibly sites across the joint local plan area. Officers have
stated at various committees that grey belt sites are not required to accommodate housing allocations and
the ‘Plan is not configured for this’. However, the fact that LDA are looking Grey Belt suggests the draft
Plan does need to cover this important issue given the increasing importance of Grey Belt policy in the
draft NPPF currently being consulted on.

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

It is important the Council does not assign the same importance to all Green Belt given the biggest policy
change to Green Belt it in several decades.

Windfall

Secondly, primarily relying upon windfall development to address as much of the 10% requirement as
possible, does not help provide small and medium enterprise housebuilders with the certainty required to
invest in delivering sites. Across Greater Cambridge there has also been a general decline in the delivery
of windfall sites over the years.

The Greater Cambridge Housing Delivery Study Addendum2 in section 2 considers windfall delivery
between 2006 and 2024 and consider a windfall allowance for 425 dwelling per annum would be robust.

This section of the report sets out what it considers the favourable policy which may assist the delivery of
windfall sites in the future. However, it fails to identify why over time there has been a general trend downward on windfall sites, and whether in reality, particularly in the South Cambridgeshire area there is now a lack of available sites to continue to deliver windfall at scale across the plan period.

For instance, it presents a data set as far back as 2006 – 2007 for windfall completions to find an average
delivery rate of 470 dwellings per annum, fails to realise that Greater Cambridge has not delivered more
that 470 dwellings in a year from windfall since 2016 – 2017. Even if the Council uses 425 dwelling per
annum for windfall over the previous seven years of data the average delivery has been 395 dwellings per
annum.

As such, there needs to be greater certainty injected into small and medium sized sites by allocating these
in the emerging Local Plan, to aid with confidence of being able to deliver such sites but also recognising
that opportunities for brownfield redevelopment or residential sub-division can only continue to deliver so
much housing across Greater Cambridge.

A final point of note; whilst the Site is larger than 2.5ha and therefore exceeds the 2.5ha site area set in
the NPPF for small sites, the Site area can easily be reduced slightly to meet the threshold without
undermining the ability to deliver housing in this location.

Vitality of the Rural Area

The Council suggests at 2.44 that allocations in the Rural Area would result in an overreliance on the
private motor vehicle. However, this position overlooks several important factors:

- The spatial strategy proposed by the Council does not consider the unique characteristic of each
of the settlements in the rural area individually, and their ability to grow to support the vitality of
settlements and the viability of their services. This is a consequence of effectively grouping the
whole rural area into one pot within Policy S/DS.

- Expanding the rural settlements may potentially lead to increased viability / opportunities to
improve sustainable transport opportunities.

- Whilst the Council does not readily allocate any new developments at the rural settlements, it is
clear that the Council does not view all settlements in the rural area as being unsustainable. For
instance, Policy S/SH – Settlement Hierarchy does not set a limit of the size of residential
development within the defined extent of Rural Centres such as Histon and Impington subject to
demonstrating adequate services and facilities exist.

- Some Rural Centres such as Impington and Histon are actually closer and as well served as the
city in terms of access to large employment centres (ie: Science Park).

Policy S/SH effectively creates a juxtaposition whereby it is recognised that growth within Histon and
Impington need not be constrained as it benefits from a high level of services, facilities and accessibility to
the main urban area; yet in failing to allocate any sites, growth is basically constrained to the settlement
boundaries where windfall opportunities are restricted.

Failing to offer sufficient choice and flexibility

The focus upon large new settlements, urban redevelopment and SUEs fails to properly consider the need
to offer sufficient choice and flexibility to perspective homeowners. Not all perspective purchasers will be
able to, or wish to buy, in these locations. For instance, existing young residents of Histon and Impington
may wish to buy a home in the settlement to be close to existing family for childcare which may not be
possible should they have to move to other proposed allocations.

Local Housing Need

The adopted neighbourhood plan encourages sites of up to 50 dwellings and finds:

• That the third most important matter to local residents was the affordability of housing.

• The supply of affordable housing was considered the second most important in terms of need for
improvement.

Despite this both the neighbourhood plan and emerging Local Plan fail to identify housing sites to meet
the identified local need. Rather, it puts the onus entirely on windfall sites and exceptions sites which carry
high risk for developers and therefore are not likely to come forward at scale. Additionally, windfall sites
within the settlement not delivering 10 or more dwellings and under the area restriction will not be required
to deliver any affordable housing.

The proposed development strategy will only exacerbate the affordability issue in Histon and Impington,
likely pushing young people out of their local communities away from their support networks. This may
also exacerbate the car dependence concerns the Council has by pushing these people further from
Cambridge to seek cheaper housing in less well served areas (ie: rural East Cambridgeshire).

A more robust hierarchy which supports housing delivery in the rural area, of which many of the locations are highly sustainable.

The ‘lumping’ together of rural centres, minor rural centres, group villages and infill villages from
the settlement hierarchy (taken from Policy S/SH), effectively as the locations with the lowest
preference to deliver jobs and homes, clearly fails to distinguish between what may be highly
sustainable locations in the rural area (ie: Histon and Impington) a Rural Centre-the highest of
these categories (where there will be no limit on scheme size), and which is clearly capable of
delivering an appropriate scale of development (ie: up to 50 dwelling sized sites as encouraged in
the adopted Neighbourhood Plan).

- Undertake a grey belt assessment

- Consider grey belt in the SA

- Provide text on grey belt within policy wording.

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

The Site should be allocated for development.

Comments are made in relation to HELAA site ID: 115090 - Woodcock Close, Impington and is omission as an allocated site.

The majority of the Site is within the Cambridgeshire Green Belt and is predominately undeveloped land.
The Site is well contained by dense boundary vegetation to the east providing screening between existing
and proposed properties and the wider Green Belt.

Greater Cambridge’s Green Belt Assessment (2021) identifies variations in openness and the extent to
which land contributes to the purpose of Green Belt and uses this information to determine the potential
harm to those purposes of releasing Green Belt land. The approach to the assessment differs from that
in the NPPF Green Belt purposes (though we note that this has previously been accepted by Inspectors),
the ‘Cambridge Purposes’ are:

• Cambridge Purpose 1: Preserved the unique character of Cambridge as a compact, dynamic city
with thriving historic centre (NPPF purpose 1).

• Cambridge Purpose 2: Maintain and enhance the quality of its setting (NPPF purpose 4, and
closely related to purpose 3).

• Cambridge Purpose 3: Prevent communities in the environs of Cambridge from merging into one
another and with the city (NPPF purpose 2).

The assessment rates sites against the expected harm to the Green Belt, should it be released for
development, using a 5-point scale.

Whilst we note the assessment has been accepted before, and that this Plan will be assessed under the
December 2024 NPPF, the Council may wish to consider the direction of travel in the emerging NPPF.
The current NPPF consultation includes a requirement to assess Green Belt boundaries in Local Plans in
accordance with the process contained at Annex E (see policy GB2: Assessing existing Green Belt Land).

Within the 2021 study, the Site was assessed under parcel HI12 and was found to have the following
contributions to the Cambridge Purposes:

• Purpose 1: A relatively limited contribution to preserving Cambridge’s character;

• Purpose 2: A relatively limited contribution to maintaining and enhancing the quality of
Cambridge’s setting;

• Purpose 3: Limited to no contribution to preventing merging of communities with one another and
with the city.

It was concluded that the additional impact on the Green Belt from the release of the parcel would be
negligible and the harm resulting from its release would be low.

Since the 2021 study, the Government introduced the concept of Grey Belt in the December 2024 NPPF
with the purpose of allowing development on poorly performing pieces of Green Belt, which otherwise
would have been restricted to demonstrating very special circumstances.

The Site is considered to have the potential to qualify intrinsically as Grey Belt land. Based upon the
Council’s own Green Belt evidence base, the Site clearly does not strongly contribute to NPPF Green Belt
purposes a), b) and d), nor does it have any footnote 7 policies that would form a strong reason for refusing
development. Development would also clearly not fundamentally undermine the purposes (taken together)
of the remaining Green Belt across the Plan area.

Histon and Impington is defined as a rural centre and the Site being adjacent to it means it is clearly in a
sustainable location, a key cog of demonstrating the Site can qualify as Grey Belt.

The Site has been assigned 115090 in the latest HELAA. We have the following comments to make:

• Flood Risk: Whilst the Site has pockets of surface water flood risk these can easily be designed
out through the development process remove any risk on or off site. As such, there is no reason
why the Site could not score green in this regard.

• Landscape: There are no updated 2025 comments in this regard. It is disappointing there is no
consideration of Grey Belt potential on this Site and across the wider council area.

• Site Access: The score should be upgraded to green as the proposals would clearly not have a
detrimental impact on local or trunk roads given the scale of development, this follows the provision
of additional information March 2025 demonstrating access to the public highway.

• Transport and Roads: The Site is still assigned an amber from 2021 with no update. The
methodology does not address this matter, and it is clear that a development in this location and
scale could be delivered without adverse effect.

• Available: The Site has been scored amber despite the Council agreeing there are no issues
around landownership or delivery period. As such, the score should be updated to green.

Greater recognition of the importance of delivering homes to address local affordability issues.

Whilst in principle we do not object to the principle of seeking to deliver a large number of new homes at
scale as set out in Policy S/DS. We consider that this approach sets the Council on a path of over-reliance
on these sites which is problematic for the following reasons:

- The speed at which these developments can deliver homes is often far slower than the Council
has envisaged historically. A review of historic Annual Monitoring Reports demonstrates that whilst
some of the large strategic sites in the current Development Plan, may now be delivering at an
appropriate rate, most sites came on stream several years later than anticipated, did not deliver
as quickly once the first completions were achieved, and many still deliver less homes year on
year than planned for.

- The Council has not identified any new allocations for housing in the rural area which fails to
support the vitality of the rural area and existing settlements. We believe that this decision, has
been made in part, to avoid development in the Green Belt, and therefore fails to strike a more
balanced approach to housing delivery and mix of housing across the Plan period.

- The ‘lumping’ together of rural centres, minor rural centres, group villages and infill villages from
the settlement hierarchy (taken from Policy S/SH), effectively as the locations with the lowest
preference to deliver jobs and homes, clearly fails to distinguish between what may be highly
sustainable locations in the rural area (ie: Histon and Impington) a Rural Centre-the highest of
these categories (where there will be no limit on scheme size), and which is clearly capable of
delivering an appropriate scale of development (ie: up to 50 dwelling sized sites as encouraged in
the adopted Neighbourhood Plan).

Small and Medium Sized Sites

Small and medium sites such as this Site are key to a far more balance approach to housing. Paragraph
73 of the NPPF (December 2024) identifies that small and medium sized sites can make an important
contribution to meeting the housing requirement of an area. They are also essential for small and medium
enterprise housebuilders to deliver new homes whilst being built out relatively quickly.

The Plan does not propose to allocate any new housing sites to address this requirement, essentially
because they consider:

- It is challenging to identify a large number of small sites to meet the 4,820 homes required to meet
the 10% requirement.

- It would be considered to undermine the Council’s development strategy and necessitates the
release of Green Belt sites conflicting with the aim of protecting the Cambridge Green Belt as the
larger and better served villages are located within the Green Belt.

We have two concerns with this approach which need to be considered and addressed by the next iteration
of the plan.

Green Belt / Grey Belt

Firstly, the Green Belt Assessment which underpins the Council’s evidence base is dated 2021 which predates
the introduction of Grey Belt in planning policy.

The Council has not publicly committed to undertake a review of potential Grey Belt sites and their
development potential as an alternative spatial strategy, which is apparent in the October 2025
Sustainability Appraisal.

However, Bidwells understands that consultants on behalf of Greater Cambridge are currently considering
the process of examining Grey Belt issues and possibly sites across the joint local plan area. Officers have
stated at various committees that grey belt sites are not required to accommodate housing allocations and
the ‘Plan is not configured for this’. However, the fact that LDA are looking Grey Belt suggests the draft
Plan does need to cover this important issue given the increasing importance of Grey Belt policy in the
draft NPPF currently being consulted on.

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

It is important the Council does not assign the same importance to all Green Belt given the biggest policy
change to Green Belt it in several decades.

Windfall

Secondly, primarily relying upon windfall development to address as much of the 10% requirement as
possible, does not help provide small and medium enterprise housebuilders with the certainty required to
invest in delivering sites. Across Greater Cambridge there has also been a general decline in the delivery
of windfall sites over the years.

The Greater Cambridge Housing Delivery Study Addendum2 in section 2 considers windfall delivery
between 2006 and 2024 and consider a windfall allowance for 425 dwelling per annum would be robust.

This section of the report sets out what it considers the favourable policy which may assist the delivery of
windfall sites in the future. However, it fails to identify why over time there has been a general trend downward on windfall sites, and whether in reality, particularly in the South Cambridgeshire area there is now a lack of available sites to continue to deliver windfall at scale across the plan period.

For instance, it presents a data set as far back as 2006 – 2007 for windfall completions to find an average
delivery rate of 470 dwellings per annum, fails to realise that Greater Cambridge has not delivered more
that 470 dwellings in a year from windfall since 2016 – 2017. Even if the Council uses 425 dwelling per
annum for windfall over the previous seven years of data the average delivery has been 395 dwellings per
annum.

As such, there needs to be greater certainty injected into small and medium sized sites by allocating these
in the emerging Local Plan, to aid with confidence of being able to deliver such sites but also recognising
that opportunities for brownfield redevelopment or residential sub-division can only continue to deliver so
much housing across Greater Cambridge.

A final point of note; whilst the Site is larger than 2.5ha and therefore exceeds the 2.5ha site area set in
the NPPF for small sites, the Site area can easily be reduced slightly to meet the threshold without
undermining the ability to deliver housing in this location.

Vitality of the Rural Area

The Council suggests at 2.44 that allocations in the Rural Area would result in an overreliance on the
private motor vehicle. However, this position overlooks several important factors:

- The spatial strategy proposed by the Council does not consider the unique characteristic of each
of the settlements in the rural area individually, and their ability to grow to support the vitality of
settlements and the viability of their services. This is a consequence of effectively grouping the
whole rural area into one pot within Policy S/DS.

- Expanding the rural settlements may potentially lead to increased viability / opportunities to
improve sustainable transport opportunities.

- Whilst the Council does not readily allocate any new developments at the rural settlements, it is
clear that the Council does not view all settlements in the rural area as being unsustainable. For
instance, Policy S/SH – Settlement Hierarchy does not set a limit of the size of residential
development within the defined extent of Rural Centres such as Histon and Impington subject to
demonstrating adequate services and facilities exist.

- Some Rural Centres such as Impington and Histon are actually closer and as well served as the
city in terms of access to large employment centres (ie: Science Park).

Policy S/SH effectively creates a juxtaposition whereby it is recognised that growth within Histon and
Impington need not be constrained as it benefits from a high level of services, facilities and accessibility to
the main urban area; yet in failing to allocate any sites, growth is basically constrained to the settlement
boundaries where windfall opportunities are restricted.

Failing to offer sufficient choice and flexibility

The focus upon large new settlements, urban redevelopment and SUEs fails to properly consider the need
to offer sufficient choice and flexibility to perspective homeowners. Not all perspective purchasers will be
able to, or wish to buy, in these locations. For instance, existing young residents of Histon and Impington
may wish to buy a home in the settlement to be close to existing family for childcare which may not be
possible should they have to move to other proposed allocations.

Local Housing Need

The adopted neighbourhood plan encourages sites of up to 50 dwellings and finds:

• That the third most important matter to local residents was the affordability of housing.

• The supply of affordable housing was considered the second most important in terms of need for
improvement.

Despite this both the neighbourhood plan and emerging Local Plan fail to identify housing sites to meet
the identified local need. Rather, it puts the onus entirely on windfall sites and exceptions sites which carry
high risk for developers and therefore are not likely to come forward at scale. Additionally, windfall sites
within the settlement not delivering 10 or more dwellings and under the area restriction will not be required
to deliver any affordable housing.

The proposed development strategy will only exacerbate the affordability issue in Histon and Impington,
likely pushing young people out of their local communities away from their support networks. This may
also exacerbate the car dependence concerns the Council has by pushing these people further from
Cambridge to seek cheaper housing in less well served areas (ie: rural East Cambridgeshire).