Draft Greater Cambridge Local Plan for consultation

Policy S/JH: New Jobs and Homes

Comment

This response is submitted by Cambridgeshire County Council as landowner only. The County Council has promoted sites for residential and employment development to the Reg.18 Draft Greater Cambridge Local Plan (draft GCLP). A number of those promoted sites are identified as preferred allocations, which the County Council supports. As set out in these representations, the County Council has requested that an additional allocation is made for a site it has promoted in Histon, and has requested policy changes relevant to the promoted development at this site.

Policy S/JH of draft GCLP sets out the targets for jobs and housing during the plan period from 2024 to 2045. The jobs target is 73,300 additional jobs, and the housing target is a minimum of 48,195 dwellings. The proposed housing target is derived from the national standard method figure for calculating local housing needs, which for Greater Cambridge is 2,295 dwellings per annum.

It is noted that the job target is not aligned with the housing target. A job target that is higher than the housing target would require potential employees to commute into Greater Cambridge to fill those jobs. The housing target identified in the 2023 ‘Greater Cambridge Employment and Housing Evidence Update Employment Land, Economic Development and Relationship with Housing’ Report was based on a Central Growth Scenario, the preferred 2011 Census commuting data, and included a 1:1 commuting patterns adjustment. This previous approach sought to better align the job and housing targets. The 2025 Greater Cambridge Employment and Housing Needs Update 2024-2045 Report does not include a similar commuting patterns adjustment. It is suggested that the housing target in Policy S/JH is reassessed to determine whether a commuting patterns adjustment should be made.

Paragraph 62 of the NPPF expects the standard method to be used to determine the minimum number of houses needed. Paragraph 69 states in part that “The requirement may be higher than the identified housing need if, for example, it includes provision for neighbouring areas, or reflects growth ambitions linked to economic development or infrastructure investment”. The housing target in Policy S/JH is based on the standard method only, with no adjustments for growth linked to economic development and infrastructure investment, both of which are relevant to Greater Cambridge.

The Greater Cambridge City Deal recognised the relationship between housing and economic growth, and that the shortage of available and affordable housing within Greater Cambridge has had an impact on house prices, commuting patterns, and recruitment and retention of employees. The Cambridgeshire and Peterborough Devolution Deal included a commitment to deliver substantial economic growth and to double economic output during the next 25 years. In 2024 the Government established a Cambridge Growth Company to maximise Cambridge’s full economic potential and to deliver nationally significant growth.

There are a number of proposed and planned infrastructure projects in Greater Cambridge that should have been taken into account in deciding whether adjustments should be made to the housing target in Policy S/JH. The list of infrastructure projects includes East West Rail, Cambourne to Cambridge Busway, Cambridge South East Transport project, Waterbeach to Cambridge Busway, Cambridge Eastern Access project, and Cambridge South Station. In addition, the Greater Cambridge Partnership is delivering greenways to connect surrounding villages to Cambridge by walking and cycling.

It is suggested that the housing target in Policy S/JH is reassessed to determine whether upward adjustments should be made for growth ambitions linked to economic development and infrastructure investment.

The representations to Appendix D deal with the part of Policy S/JH that relates to the housing requirements for neighbourhood plan areas.

Requested Change

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

It is suggested that the housing target is reassessed to determine whether it should include a commuting patterns adjustment.

It is suggested that the housing target in Policy S/JH is reassessed to determine whether upward adjustments should be made for growth ambitions linked to economic development and infrastructure investment.

Consistent with the representations to Appendix D, a new policy is required in draft GCLP to ensure that the housing requirements for neighbourhood plan areas are delivered.

Policy S/DS: Development Strategy

Comment

This response is submitted by Cambridgeshire County Council as landowner only. The County Council has promoted sites for residential and employment development to the draft GCLP. A number of those promoted sites are identified as preferred allocations, which the County Council supports. As set out in these representations, the County Council has requested that an additional allocation is made for a site it has promoted in Histon, and has requested policy changes relevant to the promoted development at this site.

Policy S/DS of draft GCLP sets out the development strategy. The development strategy directs development to the following locations in order of priority: within the Cambridge urban area; on the edge of Cambridge; at an expanded Cambourne; at other new settlements; and in the rural southern cluster and wider rural area at Rural Centres and Minor Rural Centres.

Cambridgeshire County Council as landowner has promoted sites that are allocated for residential or employment development, including at redevelopment sites within the Cambridge urban area, at land within the Rural Southern Cluster, and at land adjacent to established employment areas. These allocations are consistent with the development strategy, and the development strategy is supported in respect of those locations.

Cambridgeshire County Council as landowner has some concerns with parts of the development strategy, in terms of the reliance on the delivery of existing and proposed strategic allocations, the decision to not consider releasing land from the Green Belt at sustainable locations, and that there are no allocations at the sustainable settlements.

It is acknowledged that the principle of development at most of the strategic sites is already established through adopted development plan documents e.g. Eddington, Cambourne West, Northstowe, Waterbeach, Bourn Airfield, and Cambridge East. The proposed strategic sites at Cambourne North (related to the proposed East West Rail and new station for Cambourne) and proposed new settlement at Grange Farm (related to a new stop on the proposed Cambridge South East Transport project) are new strategic allocations for draft GCLP. The assumptions about housing delivery rates appear to be optimistic for the strategic sites, and not consistent with past delivery at these locations or with similar developments elsewhere. The delivery of some of the new strategic allocations require transport infrastructure projects to be delivered in advance, but those projects and the funding for them have not yet been approved. It is suggested that the delivery assumptions for all of the strategic sites are reassessed to ensure they are robust.

It is considered that exceptional circumstances do exist to release land from the Green Belt, which are related to the significant need for housing and affordable housing in Greater Cambridge, the need to support economic growth, and to direct development to sustainable locations. It is requested that land is released from the Green Belt to meet development needs, particularly at the more sustainable settlements. Cambridgeshire County Council as landowner has promoted land east of Glebe Way in Histon (Ref. 40192) for residential development, which is located within the Green Belt. It is considered that this site would fall within the definition of grey belt land, and should be released from the Green Belt to meet development needs.

The Rural Centres, including Histon and Impington, are referred to as part of the development strategy but there are no allocations in this category of settlement. It is considered that the growth of the more sustainable villages should be part of the development strategy for draft GCLP, and particularly those villages that contain a very good range of services and facilities, are accessible by a range of modes of transport, and where there is an identified need for affordable housing for those with a local connection to the villages. Histon and Impington are sustainable locations for additional development.

The promoted development by Cambridgeshire County Council as landowner at land east of Glebe Way in Histon would support the existing services and facilities in the villages. It is a medium sized sites that does not require significant new infrastructure. It could be delivered relatively quickly. The site is accessible by sustainable modes of transport. The sites would deliver affordable housing to meet the identified needs for Histon and Impington.

Requested Change

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

It is suggested that the housing delivery assumptions for all of the strategic sites are reassessed, taking into account realistic annual housing delivery rates and the delivery of critical infrastructure required for those sites.

It is requested that land is released from the Green Belt to meet development needs.

It is requested that additional allocations are made in the more sustainable villages, including at Rural Centres such as Histon and Impington.

Policy S/SH: Settlement Hierarchy

Comment

Policy S/SH of draft GCLP defines the settlement hierarchy. The hierarchy has Cambridge at the top, followed by the Towns, Rural Centres, Minor Rural Centres, Group Villages and finally the Infill Villages.

Cambridgeshire County Council as landowner has promoted sites that are identified as proposed allocations for residential or employment development. The redevelopment sites within the Cambridge urban area are promoted for residential development, and would be in a location at the top of the settlement hierarchy. The promoted development at Whittlesford relates to the redevelopment of the highways depot, and this site is located in the Rural Southern Cluster and is covered by a site specific policy for the comprehensive redevelopment of the Whittlesford Parkway Area. The promoted developments adjacent to Norman Way Industrial Estate in Over and at Buckingway Business Park in Swavesey are for employment uses adjacent to established employment areas. The allocations of Cambridgeshire County Council’s land at these locations would be consistent with the settlement hierarchy.

Cambridgeshire County Council as landowner has also promoted land east of Glebe Way in Histon (Ref. 40192) for residential development. The site is located on the edge of Histon, which is defined as a Rural Centre in the settlement hierarchy. Histon and Impington contain a very good range of services and facilities and employment opportunities. They contain supermarkets and other convenience stores, a village college, primary schools, nurseries and early years facilities, doctors surgery, a post office, banks, a library, indoor and outdoor sports and recreation facilities, and public houses and restaurants. There is a stop on the Cambridgeshire Guided Busway at Histon, and there are other bus services through Histon and Impington that provide connections into Cambridge. It is appropriate that Histon and Impington are defined as a Rural Centre.

However, there has been no review of the capacity of settlements, including Histon and Impington, to determine whether land is available within the development framework boundary to accommodate additional development for draft GCLP. There appears to be no major residential development opportunities within the development framework boundary of Histon and Impington. The made Histon and Impington Neighbourhood Plan seeks to protect some existing employment and education buildings for employment and community uses only. It is likely that any development opportunities that do exist within Histon and Impington would be small scale, and would not deliver affordable housing or provide any meaningful support to existing services and facilities. There are no allocations for residential development at Histon and Impington in draft GCLP, despite them being defined as a Rural Centre and being sustainable settlements. The capacity of the more sustainable settlements to accommodate additional development should be undertaken for draft GCLP, and if the capacity is limited then additional allocations should be made on the edge of those settlements.

As set out in these representations, amendments should be made to the development strategy for draft GCLP, which directs development to the more sustainable villages including Histon and Impington to support existing services and facilities, deliver additional facilities, and meets identified affordable needs of villages.

Requested Change

It is requested that a review is undertaken of the capacity of the more sustainable settlements in South Cambridgeshire, including Rural Centres such as Histon and Impington, to determine whether additional development can be accommodated within the existing development framework boundary.

If the capacity assessment identifies no suitable sites to meet identified housing and affordable housing needs then additional allocations should be made on the edge of those villages.

Policy S/DE: Defined Development Extents

Comment

Policy S/DE of draft GCLP set out the approach to development within and outside the defined development extents of villages.

Cambridgeshire County Council as landowner has promoted sites that are identified as proposed allocations for residential or employment development. Those redevelopment site allocations within the Cambridge urban area, for residential development, are located with the development extents of the City and would be consistent with Policy S/DE. The promoted development at Whittlesford relates to the redevelopment of the highways depot, and is covered by a site specific policy for the comprehensive redevelopment of the Whittlesford Parkway Area. The promoted developments adjacent to Norman Way Industrial Estate in Over and at Buckingway Business Park in Swavesey are for employment uses adjacent to established employment areas.

Cambridgeshire County Council as landowner has also promoted land east of Glebe Way in Histon (Ref. 40192) for residential development. This site is not allocated in draft GCLP. It is located on the edge of Histon, adjacent to but outside of the settlement framework boundary for the village.

The existing defined settlement boundaries for most villages in South Cambridgeshire, including Histon and Impington, have remained largely unchanged since the Local Plan 2004. The settlement boundaries were adjusted in some cases to take into account allocations at some villages through the Site Specific Allocations DPD 2010 and the South Cambridgeshire Local Plan 2018. In Histon and Impington heritage assets, local green space, protected village amenity areas, and important countryside frontages designations would restrict development opportunities within the settlement boundary, and the Green Belt restricts development outside the settlement boundary. The made Histon and Impington Neighbourhood Plan (May 2021) does not allocate any land for development, and could not allocate land on the edge of the villages because the adopted South Cambridgeshire Local Plan 2018 did not support the release of land from the Green Belt through the neighbourhood plan process.

The currently defined development framework boundary for Histon and Impington means that limited development would take place in these villages. The housing and affordable housing needs would not be met. There would be no support for existing services and facilities, or the delivery of additional facilities. The policy requests and community aspirations referred to in the made Histon and Impington Neighbourhood Plan for open space, and improvements to health and community facilities would not be met.

No changes are requested to Policy S/DE. However, as set out elsewhere in these representations, amendments should be made to the development strategy for draft GCLP, which directs development to the more sustainable villages including Histon and Impington to support existing services and facilities, deliver additional facilities, and meets identified affordable needs of villages.

Requested Change

It is requested that Purpose 1c in Policy S/GB is amended to refer to towns and not communities. The amended text should be as follows: prevent towns in the environs of Cambridge from merging into one another and with the city.

Policy S/GB: The Cambridge Green Belt

Object

Cambridgeshire County Council as landowner has also promoted land east of Glebe Way in Histon (Ref. 40192) for residential development. This site is located in the Green Belt, and is not allocated in draft GCLP. As set out elsewhere in these representations, the County Council has requested that an additional allocation is made for the site it has promoted in Histon, and has requested policy changes relevant to the promoted development at this site.

Policy S/GB of draft GCLP sets out the Green Belt policy for Cambridge. Paragraph 143 of the NPPF sets out the five national purposes for Green Belts. The second purpose listed in Paragraph 143 states “b) to prevent neighbouring towns merging into one another;”. The third purpose for the Cambridge Green Belt in Policy S/GB states “1c. prevent communities in the environs of Cambridge from merging into one another and with the city”. Purpose 1c in Policy S/GB is inconsistent with the second purpose in NPPG Paragraph 143 i.e. it refers to communities and not towns. Consistency with national policy is one of the soundness tests for local plan policies. The reference to communities rather than towns could have implications for how inappropriate development in the Green Belt is assessed and the implementation of grey belt policy at planning application stage. It is requested that Purpose 1c in Policy S/GB is amended to refer to towns and not communities.

In addition, as outlined in the March 2025 update to the call for sites submission, it is considered that the land east of Glebe Way in Histon would meet the definition for grey belt land, as set out in Chapter 13 and Annex 2 of the NPPF and in Section Id.64: Green Belts of the Planning Practice Guidance. The site does not strongly contribute towards Green Belt purposes (a), (b), or (d) i.e. it would not lead to the unrestricted sprawl of a large built-up area, it would not result in the coalescence of neighbouring towns, and it would not affect the setting and special character of a historic town. The site is not designated as a protected area, other than being within the Green Belt. Histon and Impington provide a range of services and facilities and employment opportunities, and are accessible by sustainable modes of transport.

Requested Change

It is requested that Purpose 1c in Policy S/GB is amended to refer to towns and not communities. The amended text should be as follows: prevent towns in the environs of Cambridge from merging into one another and with the city.

Land at North Cambridge Academy, Cambridge – Ref. S/C/NCA

Support

Cambridgeshire County Council as landowner has promoted land at North Cambridge Academy for a mixed-use sporting hub and residential development, and supports this proposed allocation. The site has been assessed against suitability, availability, achievability and deliverability criteria in the HELAA. The findings of the site assessment has informed the decision to identify the site as a proposed allocation in draft GCLP.

There are no significant constraints to development at the site. The policy requirements in Policy S/C/NCA seek to ensure that any identified constraints would be addressed at planning application stage. Criteria (a) and (b) specifies the mix and type of sport and recreation uses for the site, and criteria (c) would ensure that these uses are made available for public use, all of which would compensate for the loss of existing open space from the site. Criteria (d) would require a noise assessment to be submitted to address potential impacts on residential amenity from the school and sports/recreation uses. Criteria (e) seeks to ensure that the design and layout of the promoted development would avoid overlooking of the school from the proposed adjacent residential development. Criteria (f) would require an archaeological impact assessment to be undertaken to determine the archaeological interest at the site and identify mitigation measures if required. Criteria (g) seeks to ensure that building heights are appropriate, taking into account the surrounding uses and views of the site.

The preferred allocation at land at North Cambridge Academy and the associated policy requirements are supported, and no changes are required. It is requested that this allocation is retained in draft GCLP.

Cambridge Professional Development Centre, Foster Road – Ref. S/C/PDC

Support

Cambridgeshire County Council as landowner has promoted land at Cambridge Professional Development Centre on Foster Road for residential development, and supports this proposed allocation subject to an amendment to the site capacity. The site has been assessed against suitability, availability, achievability and deliverability criteria in the HELAA. The findings of the site assessment have informed the decision to identify the site as a proposed allocation in draft GCLP.

The site is allocated in the adopted Cambridge Local Plan 2018 for approximately 67 dwellings, on the basis of a density of 45 dwellings per hectare (Site Ref. R16). It is not explained in draft GCLP why the site capacity has been reduced from 67 to 40 dwellings. The quantum of development would be informed by an assessment of site and building, design matters, and the policy requirements of Policy S/C/PDC. It is requested that the site capacity is increased to approximately 67 dwellings, consistent with the current adopted site allocation.

There are no significant constraints to development at the site. The policy requirements in Policy S/C/PDC seeks to ensure that any identified constraints would be addressed at planning application stage. Criteria (a) seeks to ensure that the design of the promoted development including the design of the buildings and the use of materials is appropriate, and takes into account the potential impact on the setting of Trumpington Conservation Area. Criteria (b) seeks to ensure that a landscape buffer is provided between the promoted development and the adjacent playing fields. Criteria (c) seeks to ensure that the promoted development delivers open space, and that the adjacent area of open space is retained. Criteria (d) seeks to retain the existing public right of way through the site, and to incorporate it into the promoted development. Criteria (e) would require an archaeological impact assessment to be undertaken to determine the archaeological interest at the site and identify mitigation measures if required.

The preferred allocation at land at Cambridge Professional Development Centre on Foster Road and the associated policy requirements are supported. It is requested that this allocation is retained in draft GCLP, but with an increased capacity of approximately 67 dwellings.

Requested Change

It is requested that the site capacity for land at Cambridge Professional Development Centre on Foster Road (Site Ref. S/C/PDC) is increased to approximately 67 dwellings, consistent with the current adopted site allocation (Site Ref. R16).

Horizon Resource Centre, 285 Coldham’s Lane – Ref. S/C/HRC

Support

Cambridgeshire County Council as landowner has promoted land at the Horizon Resource Centre on Coldham’s Lane for residential development, and supports this proposed allocation. The site has been assessed against suitability, availability, achievability and deliverability criteria in the HELAA. The findings of the site assessment has informed the decision to identify the site as a proposed allocation in draft GCLP.

There are no significant constraints to development at the site. The policy requirements in Policy S/C/HRC seeks to ensure that any identified constraints would be addressed at planning application stage. Criteria (a) seeks to ensure that the design of the promoted development including the design of the buildings and the use of materials is appropriate, and takes into account the potential impact on the setting of Coldham’s Common. Criteria (b) seeks to ensure that the existing trees and hedgerows at the site boundary are retained and incorporated into the promoted development. Criteria (c) would require an archaeological impact assessment to be undertaken to determine the archaeological interest at the site and identify mitigation measures if required. Criteria (d) would require an assessment of the flood risk from surface water drainage for the promoted development.

The preferred allocation at land at Horizon Resource Centre on Coldham’s Lane and the associated policy requirements are supported, and no changes are required. It is requested that this allocation is retained in draft GCLP.

Policy S/AMC/WHD: Whittlesford Parkway Station Policy Area, Whittlesford Bridge

Support

Cambridgeshire County Council as landowner has promoted land at Whittlesford Highways Depot for development. The land is included within the Whittlesford Parkway Station Policy Area for the comprehensive redevelopment of the area for transport improvements relating to Whittlesford Parkway Station and for employment and residential uses. Cambridgeshire County Council supports the policy area and the redevelopment of the land at the highway depot. The land at the highways depot has been assessed against suitability, availability, achievability and deliverability criteria in the HELAA, which has identified no significant constraints to development at this site. The comprehensive masterplan for the Whittlesford Parkway Station Policy Area would ensure that any impacts from the redevelopment of the area are addressed through appropriate mitigation measures.

The land at Whittlesford Highway Depot falls within Flood Zone 1 and is not at risk of flooding. The design and layout of development at the site would take into account the surrounding uses and would seek to protect the setting of heritage assets (the Scheduled Monument at the Chapel of the Hospital of St John at Whittlesford Bridge, and the Grade II Listed Red Lion Hotel). The existing vegetation at the eastern boundary of the site would be retained and enhanced. An ecological assessment would be undertaken to determine the ecological value of the hedgerows and trees at the site, and any mitigation measures required for these features. A noise assessment would be undertaken to determine whether any noise mitigation measures are required for the proposed use of the site. An assessment of contamination risk associated with the current use of the site would be undertaken. The existing highways depot is available for development.

The comprehensive redevelopment of the Whittlesford Parkway Station Policy Area and development at the Whittlesford Highways Depot are both supported.

Land at Norman Way, Over – Ref. S/RRA/NW

Support

Cambridgeshire County Council as landowner has promoted land at Norman Way in Over for employment development. The site is located adjacent to Norman Way Industrial Estate. Cambridgeshire County Council supports this proposed allocation. The site has been assessed against suitability, availability, achievability and deliverability criteria in the HELAA. The findings of the site assessment has informed the decision to identify the site as a proposed allocation in draft GCLP.

There are no significant constraints to development at the site. The policy requirements in Policy S/RRA/NW seeks to ensure that any identified constraints would be addressed at planning application stage. Criteria (a) seeks to ensure that the design of the promoted development is appropriate to the location of the site and the surrounding area, and takes into account the potential impact on the setting of nearby heritage assets (Scheduled Monument at Over Windmill and Grade II Listed Over Mill). Criteria (b) seeks to ensure that the existing tree buffers at the site boundaries are retained. Criteria (c) requires the site access to be from Norman Way. Criteria (d) would require an archaeological impact assessment to be undertaken to determine the archaeological interest at the site and identify mitigation measures if required.

The preferred allocation at land at land at Norman Way in Over and the associated policy requirements are supported, and no changes are required. It is requested that this allocation is retained in draft GCLP.