Draft Greater Cambridge Local Plan for consultation

Wimpole Associates Ltd object to Policy S/DS.

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

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

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

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

A combination of approaches to the distribution of spatial growth are considered likely to be necessary in order to allow for sufficient flexibility when considering the locations and scale of new housing and employment development in the Greater Cambridge area. This should include for proportionate growth and expansion of existing settlements. Development is also best suited to being located along transport corridors, in accordance with national planning policy and guidance which encourages development to be focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes.

Wimpole Associates Ltd object to Policy S/DS.

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

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

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

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

A combination of approaches to the distribution of spatial growth are considered likely to be necessary in order to allow for sufficient flexibility when considering the locations and scale of new housing and employment development in the Greater Cambridge area. This should include for proportionate growth and expansion of existing settlements. Development is also best suited to being located along transport corridors, in accordance with national planning policy and guidance which encourages development to be focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes.

Wimpole Associates Ltd object to Policy S/DS.

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

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

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

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

A combination of approaches to the distribution of spatial growth are considered likely to be necessary in order to allow for sufficient flexibility when considering the locations and scale of new housing and employment development in the Greater Cambridge area. This should include for proportionate growth and expansion of existing settlements. Development is also best suited to being located along transport corridors, in accordance with national planning policy and guidance which encourages development to be focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes.

Wimpole Associates Ltd object to Policy S/DS.

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

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

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

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

A combination of approaches to the distribution of spatial growth are considered likely to be necessary in order to allow for sufficient flexibility when considering the locations and scale of new housing and employment development in the Greater Cambridge area. This should include for proportionate growth and expansion of existing settlements. Development is also best suited to being located along transport corridors, in accordance with national planning policy and guidance which encourages development to be focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes.

Wimpole Associates Ltd object to Policy S/DS.

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

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

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

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

A combination of approaches to the distribution of spatial growth are considered likely to be necessary in order to allow for sufficient flexibility when considering the locations and scale of new housing and employment development in the Greater Cambridge area. This should include for proportionate growth and expansion of existing settlements. Development is also best suited to being located along transport corridors, in accordance with national planning policy and guidance which encourages development to be focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes.

Wimpole Associates Ltd object to Policy S/GB.

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

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

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

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

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

● The publication of a revised Green Belt Assessment to support the Local Plan
● A consideration of higher growth targets and subsequent review of the Green Belt / Grey Belt where necessary
● The identification and inclusion of the Cambridge Grey Belt within the Local Plan to guide development to sustainable Grey Belt sites.

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

Wimpole Associates Ltd object to Policy S/GB.

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

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

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

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

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

● The publication of a revised Green Belt Assessment to support the Local Plan
● A consideration of higher growth targets and subsequent review of the Green Belt / Grey Belt where necessary
● The identification and inclusion of the Cambridge Grey Belt within the Local Plan to guide development to sustainable Grey Belt sites.

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

Wimpole Associates Ltd object to Policy S/GB.

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

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

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

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

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

● The publication of a revised Green Belt Assessment to support the Local Plan
● A consideration of higher growth targets and subsequent review of the Green Belt / Grey Belt where necessary
● The identification and inclusion of the Cambridge Grey Belt within the Local Plan to guide development to sustainable Grey Belt sites.

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

Wimpole Associates Ltd object to Policy S/GB.

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

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

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

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

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

● The publication of a revised Green Belt Assessment to support the Local Plan
● A consideration of higher growth targets and subsequent review of the Green Belt / Grey Belt where necessary
● The identification and inclusion of the Cambridge Grey Belt within the Local Plan to guide development to sustainable Grey Belt sites.

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

Revise the housing and employment targets for Greater Cambridge and allocate additional sites in Greater Cambridge to directly respond to the higher growth potential and to increase the diversity of allocated sites to optimise delivery and growth potential.

Wimpole Associates Ltd object to Policy S/GB.

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

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

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

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

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

● The publication of a revised Green Belt Assessment to support the Local Plan
● A consideration of higher growth targets and subsequent review of the Green Belt / Grey Belt where necessary
● The identification and inclusion of the Cambridge Grey Belt within the Local Plan to guide development to sustainable Grey Belt sites.

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