Draft Greater Cambridge Local Plan for consultation

1.1 These representations have been prepared by Stantec on behalf of Martin Grant Land Limited (formerly Martin Grant Homes) pursuant to their land interests at Silverdale Close, Coton. The site has been assessed within the Housing and Economic Land Availability Assessment 2025 (HELAA). The Site ID is 115148 and the HELAA Site ID is 40079.

1.2. These representations provide updated information regarding the site, and should be read in conjunction with the following submissions:
• Call for Sites March 2019
• Regulation 18 Issues and Options February 2020
• Regulation 18 First Proposals December 2021
• Call for Sites Submission Update March 2025

1.3. Policy S/JH sets out the requirements within the proposed 21-year plan period of 2024-2045. Regarding housing need, it sets out the need for a ‘minimum of 48,195 new homes’ within this plan period. Paragraph 62 of the National Planning Policy Framework (NPPF) seeks strategic policies to be informed by a local housing assessment conducted using the standard method in national planning practice guidance.

1.4. The latest standard method figures following the update in June 2025 seeks an annual requirement of 1,103 dwellings per annum within Cambridge City and 1,193 dwellings per annum within South Cambridgeshire District. Combined, this results in 2,296 dwellings per annum for the Greater Cambridge authority. Based on a 21-year plan period, the housing need total should therefore be a minimum of 48,216 dwellings. The Local Plan should therefore be updated accordingly to reflect this figure.

1.5. The acknowledgement that the housing need figure is a minimum figure is supported. The Greater Cambridge authority (Cambridge City and South Cambridgeshire District) should seek opportunities to support further development within sustainable locations.

1.6. There are concerns regarding the Local Plan’s ability to deliver appropriate levels of affordable housing within the plan period. Table 7.16 of the Housing Needs of Specific Groups in Cambridge and South Cambridgeshire Report (August 2025) sets out the net need for affordable housing as per the figures below:
• Cambridge City – 928 affordable dwellings per annum
• South Cambridgeshire District – 708 affordable dwellings per annum

1.7. This creates a total need of 1,636 affordable dwellings per annum. This represents 71% of the total housing need of 2,296 dwellings per annum. Recent levels of affordable housing delivery are set out in the table below (as noted within the Greater Cambridge Authority Monitoring Report 1 April 2023-31 March 2024):


Year South Cambridgeshire District Affordable Housing Delivery Cambridge City Affordable Housing Delivery Total Affordable Housing Delivery
2023/24 503 20 523
2022/23 468 316 784
2021/22 357 147 504
2020/21 303 65 368
2019/20 344 199 543
2018/19 341 345 686
Total 2,316 1,092 3,408

1.8. Current affordable housing delivery rates for the Greater Cambridge authority as a whole, therefore, have an average delivery rate of 568 affordable dwellings per annum over the period 2018/19-2023/24, which represents the most up to date information published by the Councils. These delivery rates are significantly below the identified affordable housing need required for the proposed plan period.

1.9. It is also noted that South Cambridgeshire District has a relatively settled affordable housing delivery. However, Cambridge City has a more sporadic delivery, resulting in only 20 affordable dwellings being delivered in 2023/24. South Cambridgeshire has delivered over twice as many affordable dwellings than Cambridge City, suggesting it is a more viable place for affordable dwellings to come forward.

1.10. The spatial strategy within the emerging Local Plan is based on delivery of large-scale sites. Whilst the need for strategic allocations is accepted, if any of these are subject to a delay, then affordable housing delivery will suffer. For example, Bourn Airfield has yet to deliver any affordable housing. Affordable housing therefore provides strong justification for utilising a higher housing need number, thus stimulating more affordable housing delivery. This is supported by Paragraph 024 (Ref:ID:2a-024-20190220) of the ‘Housing and Economic Needs Assessment’ section of the Planning Practice Guidance, which states the following:

‘An increase in the total housing figures included in the plan may need to be considered where it could help deliver the required number of affordable homes’

1.11. Within Appendix A of the Greater Cambridge Authority Monitoring report 2023 to 2024, it is noted that between 2011 and 2024, affordable housing constituted 34% of all housing completions within Cambridge City. If such levels were to continue in the upcoming proposed plan period, then Cambridge City could be expected to deliver 375 affordable dwellings per annum (34% of the standard method figure of 1,103 dwellings per annum). For South Cambridgeshire District, it confirms that for schemes eligible to provide affordable housing, 36% were affordable. Whilst this does not provide a true representation given the number of small-scale schemes that are not eligible, it would lead to an optimistic figure of 429 affordable dwellings per annum (36% of the standard method figure of 1,193 dwellings per annum).

1.12. Therefore, at current rates, only 804 affordable dwellings per annum would be delivered, a figure which in itself is a big increase on current delivery rates. The figure is significantly below the identified need within the Housing Needs of Specific Groups in Cambridge and South Cambridgeshire Report (August 2025).

1.13. It is considered there is clear justification to increase housing need in order to meet more of the identified affordable housing need. This is especially the case within South Cambridgeshire District where provision is more consistent. Failure to increase housing numbers would result in increasing affordable housing demands within the authority area.

1.1. These representations have been prepared by Stantec on behalf of Martin Grant Land Limited (formerly Martin Grant Homes) pursuant to their land interests at Silverdale Close, Coton. The site has been assessed within the Housing and Economic Land Availability Assessment 2025 (HELAA). The Site ID is 115148 and the HELAA Site ID is 40079.

1.2. These representations provide updated information regarding the site, and should be read in conjunction with the following submissions:
• Call for Sites March 2019
• Regulation 18 Issues and Options February 2020
• Regulation 18 First Proposals December 2021
• Call for Sites Submission Update March 2025

1.3. Policy S/DS sets out the main strategic development sites for both residential and employment development through to 2045. This includes carrying over previous sites, whilst also introducing two new large scale housing allocations, with 13,000 homes at Cambourne North and 6,000 homes at Grange Farm proposed (although not all to be delivered in the plan period).

1.4. There has been a history of the Council relying upon large scale development in order to meet the necessary housing numbers. This is particularly the case within South Cambridgeshire District Council, where sites such as Northstowe, Waterbeach, and Bourn Airfield were all allocated within the 2018 Local Plan if not earlier.

1.5. Whilst the principle of further strategic allocations (at Cambourne North and Grange Farm) is accepted, it is imperative these sites are appropriately supplemented by a sufficient number of smaller allocations to ensure housing delivery rates are in line with housing need.

1.6. The table below sets out some of the difficulties in reliance upon strategic sites allocated in the adopted 2018 Local Plans, and shows the timelines involved in getting planning permission and completions. The information is taken from the Greater Housing Trajectory and Housing Land Supply Report (April 2025).

Site No. of Dwellings Original App Reference Valid Date for Outline Date of Outline Permission No. of Completions at March 24
Bourn Airfield 3,500 S/3440/18/OL 10-9-18 30-7-24 0
Cambourne West 2,350 S/2903/14/OL 22-12-14 29-12-17 556
Darwin Green 1 1,593 07/0003/OUT 19-12-06 18-12-13 331
Eddington 3,000 11/1114/OUT & S/1886/11 22-9-11 22-2-13 1,121
Northstowe Phase 1 1,500 S/0388/12/OL 27-2-12 22-4-14 1,401
Northstowe Phase 2 3,500 S/2011/14/OL 29-8-14 9-1-17 79
Northstowe Phase 3a 4,000 20/02171/OUT 18-5-20 25-3-22 0
Northstowe phase 3b 1,000 20/02142/OUT 7-5-20 25-3-22 0
Waterbeach New Town - West 6,500 S/0559/17/OL 17-2-17 27-9-19 25
Waterbeach New Town - East 4,500 S/2075/18/OL 30-5-18 17-12-24 0

1.7. The table shows the difficulty and time required for strategic sites to deliver homes within Greater Cambridge. Northstowe Phase 1 for example was validated at outline stage in February 2012. By March 2024 (a period of 12 years), it had only delivered 1,401 of the 1,500 expected. At Eddington (Phase 1), 13 years after the outline was validated, only 1,121 out of 3,000 dwellings have been completed and the outline application has now lapsed. At Bourn Airfield, no reserved matters application for residential development have been submitted as yet, over 7 years after the validation of the original outline.

1.8. The result of this is that the Council face the danger of not being able to demonstrate a five-year housing land supply through the plan period. Following the publication of the Greater Cambridge Housing Trajectory and Housing Land Supply Report April 2025, the Greater Cambridge authority claim to have a combined 5.5 year supply of housing. However, an analysis of the evidence suggests this figure is likely to be below 5 years.

1.9. The development strategy should therefore include smaller sites to supplement the strategic allocations and guarantee delivery in the early part of the plan period. Sites such as Silverdale Close, Coton can provide 80 dwellings in a sustainable location to be delivered fully within the first five years of the plan. The site remains suitable, immediately available and achievable.

1.10. Paragraph 83 of the NPPF (2024) confirms that housing should be located where it will enhance or maintain the vitality of rural communities and policies should identify opportunities for villages to grow and thrive. The lack of allocations within villages, relying on low levels of windfall within settlements, again fails this requirement of the NPPF. Only the village of Melbourn (two sites) and Sawston (on a site that already benefits from planning permission) have smaller scale draft allocations outside of the city or major strategic sites.

1.11. South Cambridgeshire is a rural district with over 100 villages. Of these, only two villages stand to benefit from a housing allocation. Paragraph 2.70 of the draft Local Plan states that villages ‘should play only a limited role in meeting future development needs’. It is suggested that three sites within over 100 villages is significantly less than a limited role. The aims and objectives of NPPF paragraph 83 are clearly not therefore being met, to the detriment of the villages.

1.12. Paragraph 2.41 of the draft Local Plan confirms that the proposed North East Cambridge development that requires the relocation of the Waste Water Treatment Plant (WWTP) does not form part of the housing requirement, and if it were to come forward, then it would provide additional ‘headroom’ beyond the minimum housing figure. At present, the project to relocate the WWTP does not benefit from the required funding given the Governments decision in August 2025 to not commit the additional funding required. The draft Local Plan at paragraph 2.85 sets out what needs to be in terms of waste water capacity given the new facility not coming forward. The Council cannot therefore be reliant upon housing development at North East Cambridge, and any potential headroom at this stage shall be afforded little weight given the uncertainty as to whether the site will ever come forward. As such, table 3 within the policy seems unnecessary and should be deleted accordingly.

1.1. These representations have been prepared by Stantec on behalf of Martin Grant Land Limited (formerly Martin Grant Homes) pursuant to their land interests at Silverdale Close, Coton. The site has been assessed within the Housing and Economic Land Availability Assessment 2025 (HELAA). The Site ID is 115148 and the HELAA Site ID is 40079.

1.2. These representations provide updated information regarding the site, and should be read in conjunction with the following submissions:
• Call for Sites March 2019
• Regulation 18 Issues and Options February 2020
• Regulation 18 First Proposals December 2021
• Call for Sites Submission Update March 2025

1.3. These representations will firstly look at the current status of the site at Silverdale Close, Coton within the Council’s evidence base, before looking at the Green Belt status of the site and highlighting the benefits that development at Coton would bring.

Housing and Economic Land Availability Assessment

1.4. The first area of concern regarding the Council’s consideration of the site relates to the scoring of the site within the HELAA. This relates specifically to the assessment rating for site access, where the site scores ‘red’ and is erroneously deemed inaccessible: ‘the site does not link to the adopted public highway and is therefore inaccessible to highway users’.

1.5. Within the Regulation 18 representations dated December 2021 and the Call for Sites information submitted in March 2025, it was confirmed that Martin Grant Land Limited has full unencumbered rights of access across Pendrick Close to the site access for all modes of transport. However, the 2025 assessment retains the ‘red’ rating.

1.6. It is therefore requested that the site is re-assessed within the HELAA in line with the revised red line site boundary as shown below and as per the attached plan. It is suggested the confirmation above and the revised red line will result in a RAG rating of ‘green’ in terms of site access.

1.7. Within the HELAA, there are also concerns regarding the assessment for availability. Martin Grant Land Limited has constantly confirmed the site remains available for development, with an appropriate land agreement in place. This is confirmed within the HELAA text. The previous Assessment Proforma for the site also scored a ‘Green’ for Availability. However, the assessment score is now only ‘amber’. It is unclear why this aspect of the site assessment has changed to the negative. This score should remain as ‘Green’ given the site firmly remains available.

1.8. In line with the findings of the HELAA and the additional information provided above, the site assessment should be as below:
Criteria Assessment as per 2025 HELAA Assessment following additional information
Suitable Red Amber
Available Amber Green
Achievable Green Green

1.9. The current HELAA assessment is not considered to represent a fair assessment of the site. As such, the site should therefore be reconsidered in line with the updated HELAA assessment, which will score it more favourably than currently.

Green Belt Assessment

1.10. Martin Grant Land Limited acknowledges and supports the Errata sheet published to update the Greater Cambridge Green Belt Assessment 2021. This relates to Green Belt parcel CT12 which includes the site, the dwellings that form Pendrick Close to the north, and the parcel of land to the west.

1.11. The Errata sheet effectively splits this parcel into two, with parcel CT12 area 2 consisting of the site and Pendrick Close only. The assessment therefore confirms that the harm rating for map area 2 changed from ‘moderate’ to ‘low’. The supporting text states the following:

‘This part of parcel CT12 is well contained, by a woodland belt to the west and by the tree-lined Bin Brook to the south, so it’s release would have a ‘negligible’ impact on adjacent 2 Green Belt land, rather than the ‘minor’ impact that was reported in the GBGBA (Greater Cambridge Green Belt Assessment)’

Grey Belt

1.12. What the Council’s current Green Belt evidence base does not do is assess land in terms of whether it meets the criteria for Grey Belt in line with the December 2024 National Planning Policy Framework. The NPPF defines Grey Belt as the following:

‘For the purposes of plan-making and decision-making, ‘grey belt’ is defined as land in the Green Belt comprising previously developed land and/or any other land that, in either case, does not strongly contribute to any of purposes (a), (b), or (d) in paragraph 143. ‘Grey belt’ excludes land where the application of the policies relating to the areas or assets in footnote 7 (other than Green Belt) would provide a strong reason for refusing or restricting development’

1.13. The Council is reliant upon the 2021 Green Belt Assessment (subject to the Errata sheet described above). The table below sets out how the results of the Green Belt Assessment for the parcel CT12 (prior to its split):
Purpose Notes Contribution
1. To preserve the unique character of Cambridge as a compact, dynamic city with a thriving historic centre Land is not close enough to the main urban area of Cambridge to be associated with it; the land is closely associated with the settlement of Coton. It therefore makes no contribution to Cambridge Purpose 1. Limited/No contribution
2. To maintain and enhance the quality of Cambridge’s setting Land has a moderate distinction from the edge of Coton, meaning it has some relationship with the inset area. It is also open and land use is not associated with the inset area, meaning it has some rural character. When viewed from the elevated clay ridge to the north, northwest and west (including from Madingley Road and Long Road) it allows an appreciation of the scale, separate identity (from Cambridge) and rural setting of Coton, as well as the wider rural setting of Cambridge. Overall the parcel makes a moderate contribution to Cambridge Purpose 2 Moderate
3. To prevent communities in the environs of Cambridge from merging into one another and with the City Land is open and lies in a wide gap between Comberton and Coton, with elevated land between the two acting as a significant separating feature. The parcel has some relationship with the inset area, but also has a degree of distinction from it. Overall, the parcel makes a relatively limited contribution to Cambridge Purpose 3. Relatively Limited
Overall harm of Green Belt release Parcel CT12 makes a moderate contribution to maintaining and enhancing the quality of Cambridge's setting, and a relatively limited contribution to preventing communities in the environs of Cambridge from merging with each other. The additional impact on the adjacent Green Belt of the release of the parcel would be minor. Therefore, the harm resulting from its release, as an expansion of Coton, would be moderate. Moderate

1.14. It is acknowledged that the specific assessment criteria in the Council’s Green Belt Assessment do not directly match the purposes as set out within the NPPF. However, purpose 3 above has clear comparison to Green Belt purpose b) within the NPPF, and purpose 2 is similar to the test within purpose d) of the NPPF.

1.15. Martin Grant Land Limited has instructed an independent assessment of the site when considered against the Green Belt purposes. The results of that assessment are set out in the table below:
Green Belt Purpose Independent Green Belt Assessment for Site
a) To check the unrestricted sprawl of large built-up areas Contribution to purpose is considered ‘None’, with regards to the illustrative features set out within the Green Belt PPG Methodology: ‘…adjacent to or near to a large built-up area, but containing or being largely enclosed by significant existing development’.
The site is adjacent to the residential built-up area of Coton, which is a village. It is not adjacent to the large built-up area of Cambridge to which this purpose relates.
The Site is considered to have no contribution to purpose a)
b) To prevent neighbouring towns merging into one another Contribution to purpose is considered ‘None’, with regards to the illustrative features set out within the Green Belt PPG Methodology: ‘…part of a gap between towns, but only a very small part of this gap, without making a contribution to visual separation’.
The site is on the western flank of Coton, however, the purpose specifically relates to the merging of town, not villages. Furthermore, the nearest other settlement is Comberton (another village), 2km southwest. The site does not make a physical or visual separation to this gap.
The Site is considered to have no contribution to purpose b)
c) To assist in safeguarding the countryside from encroachment This is an undeveloped greenfield Site which is considered to be countryside, although there are urban influences from the surrounding houses and local roads. The Site contributes less (both in terms of its undeveloped nature and rural qualities) to the wider Green Belt as it is cut-off from the wider rural landscape by settlement to the north and east, the woodland block to the west and the Bin Brook and associated vegetation to the south.
Encroachment of development into the countryside would be limited to the infill of the site and is unlikely to affect the rural open land beyond the site due to the presence of strong physical boundary features
The Site is considered to have a weak contribution to purpose c)
d) To preserve the setting and special character of historic towns Contribution to purpose is considered None’, with regards to the illustrative features set out within the Green Belt PPG Methodology: ‘…do not form part of the setting of a historic town’.
Coton is not considered to be a historic town and is situated over 3km from the historic centre of Cambridge. There is no physical or visual relationship between the site or Cambridge, thus, the Site does not form part of the setting of a historic town.
The Site is considered to have a no contribution to purpose d)
e) To assist in urban regeneration, by encouraging the recycling of derelict and other urban land. N/a – All sites are considered to contribute equally.

1.16. The independent assessment therefore considers the site to have no contribution to purposes a), b) and d) and a weak contribution to purpose c). The site is not considered to make a Strong contribution to any of the Green Belt purposes.

1.17. Land which is considered to be Grey Belt excludes land where the application of the policies relating to the areas or assets in NPPF Footnote 7 (other than Green Belt) would provide a strong reason for refusing of restricting development (it is noted the emerging NPPF seeks to remove Footnote 7). The table below summarises the site’s position in terms of the Footnote 7 criteria:

Footnote 7 Criteria Response
Habitats sites and/or designates SSSI There is no formal designation on the land.
Local Green Space The land is not designated as Local Green Space.
National Landscape The site is not located within a National Landscape.
National Park or defined Heritage Coast The site is not located within a National Park or defined Heritage Coast.
Irreplaceable Habitats There are no known irreplaceable habitats on the site.
Designated Heritage Assets The site has been assessed in terms of archaeological potential, and any findings are considered to be of negligible to low heritage significance. No impacts upon built heritage would result.
Areas at risk of flooding or coastal change A small portion of the site along the southern boundary is located within flood zone 3 given the proximity of Bin Brook. However, this area is not considered spatially appropriate for development. There are small areas of surface water drainage that can be designed around through an appropriate FRA and drainage strategy.

1.18. In line with NPPF Paragraph 155 a), the site is considered to be Grey Belt. NPPF Paragraph 155 b) relates to a demonstrable need. Housing need has been covered in other parts of these representations.

1.19. NPPF Paragraph 155 c) of the NPPF relates to demonstrating the site is located within a sustainable location with specific reference to NPPF paragraphs 110 and 115 of the Framework. These paragraphs include limiting the need to travel, offering a genuine choice of transport modes, maximising sustainable transport solutions and providing safe and suitable access.

1.20. Coton is served by the 8 bus service between Cambridge and Bar Hill, Hilton and Papworth Everard. More regular services are also available along Madingley Road, including 20 minute Citi 4 services between Cambourne and Cambridge and the X3 between Huntingdon and Cambridge.

1.21. Coton benefits from an existing sustainable transport route into Cambridge. The route eastwards along The Footpath includes a recently upgraded path and cycle/pedestrian bridge over the M11. The path passes through the West Cambridge employment site which is a key strategic employment area within the City and is also within 2 miles from the access of the site.

1.22. This transport link will also benefit from the Comberton Greenway, which seek to provide further sustainable upgrades in the area, including the conversion of Adams Road in Cambridge into England’s first cyclist priority road. Grange Road in Cambridge is 2.7 miles from the site entrance, the majority of which will be off road. The Greenway works are underway and also provide links westwards towards Comberton and Hardwick through upgrades to the footpath through the countryside, which will be widened and resurfaced to allow for cycle use.

1.23. Coton may also benefit in the future from the proposed Cambridge to Cambourne Busway. This will provide bus services combining a route that runs along existing roads and on designated on-road lanes. Passing Coton, the route would be on a designated track, with the proposed stop on Cambridge Road proposed 0.7 miles from the site entrance.

1.24. Coton provides genuine alternatives to the car to access day to day services, emphasised by its proximity to Cambridge. It therefore meets the terms of part (c) of the NPPF paragraph 155.

1.25. Regarding Golden Rules, the site is capable of providing 50% affordable housing. It will allow for upgrades to the pedestrian network within the village, and would provide 1.32 hectares of public open space including play equipment on site.

1.26. The site has been subject to a pre-application request to South Cambridgeshire District Council. In their response date 26 September 2025, the Council stated ‘Officers are in broad agreement that in terms of this assessment, this land would not make a strong contribution to the purposes of a, b and c of paragraph 143’. It is assumed this should refer to purpose d) given it was written in response to whether the site should be considered Grey Belt. The pre-application response does conclude that ‘it is acknowledged the site is likely to be considered grey belt’.

1.27. In line with the relevant tests within the NPPF, the site is considered to meet the definition of Grey Belt and should be considered as such through this Local Plan process.

Comparison with Draft Allocations

1.28. The draft Greater Cambridge Local Plan 2024-2045 includes only two small-scale residential allocations outside of the City or its immediate environs. Both of these allocations are located at Melbourn, a village situated 7 miles from the edge of Cambridge and 9.9 miles from the City Centre. Whilst Meldreth railway station is in close proximity to Melbourn, both draft allocated sites are located over a mile from this station and require use of an unlit countryside path.

1.29. The Melbourn sites have been assessed through the HELAA and the table below sets out their results, and compares them to the Coton site assessment following its re-assessment as set out above:

Site Suitable Available Achievable
40490a – Land West of Cambridge Road, Melbourn Amber Green Green
40215 – The Moor, Moor Lane Amber Green Green
40079 - Silverdale Close, Coton Amber Green Green

1.30. When based on the assessment of suitability, availability and achievability, the Coton site is considered to be sequentially equal to the two sites in Melbourn. However, it benefits from being Grey Belt land within 2 miles of the City of Cambridge. Given the transport options, potentially increased in the Cambourne to Cambridge Busway is approved, the Coton site will no doubt place less reliance upon the car and would provide sustainable transport options.

The Benefits of Silverdale Close, Coton

1.31. The development of up to 80 dwellings on the proposed site at Silverdale Close in Coton would bring with it significant benefits as set out in the table below:

Benefit Comment
Delivery of up to 80 dwellings Brings development to a settlement that had had limited growth in the recent past. It prevents the stagnation of the settlement and meets the aims of paragraph 83 of the NPPF which seeks growth in rural areas to allow settlements to thrive.
Use of underperforming Green Belt land The site has been independently assessed against the purposes of the Green Belt and is considered to make a weak or no contribution to these purposes. Given its location and sustainable transport options, Coton is an in-demand settlement to reside within.
Provision of 50% affordable housing In line with the Golden Rules for development for sites currently in the Green Belt, any development on the site would provide 50% affordable housing.
Support existing services and facilities Development within the settlement will assist in supported existing village services, including the public house, sports teams, the garden centre, the school and day nursery, and the church.
Sustainable transport options Coton is located just to the west of Cambridge and has excellent sustainable transport links into Cambridge, particularly being on the Comberton Greenway which allows a direct route across the M11 and into the West Cambridge employment area. The Greenway will continue into Cambridge centre and will include the conversion of Adams Road into the country’s first bicycle priority road. The settlement may also benefit from the Cambourne to Cambridge Guided Busway should that be approved.
Provision of public open space In line with the current masterplan, the site would bring forward 1.32 hectares of public open space, including play equipment
Benefits to Bin Brook The site runs to the bank of Bin Brook. The proposal creates an opportunity to enhance the watercourse through some thinning of plants, allowing increased light levels to the water.
Off-site highway works The technical work has highlighted the opportunity to enhance some of the existing footway crossing points to ensure safer walking for the village as a whole.
Other infrastructure contributions A development of 80 dwellings would expect to contribute to education and healthcare.

1.32. The site at Silverdale Close, Coton, remains suitable, immediately available and achievable. The Greater Cambridge Authority should consider allocating smaller sites that can be delivered within the first 5 years of the Local Plan, to complement those large-scale allocations.

1.33. To assist the Council of the consideration of the site, these representations are accompanied by the following documents, which should be assessed accordingly:

• Appendix A: (Revised) Site Boundary Plan – STN-GEN-SW-DR-MP-01E
• Appendix B: Illustrative Masterplan – STN-GEN-SW-DR-MP-07E
• Appendix C: Illustrative Landscape Masterplan – 929.12/05
• Appendix D: Green Belt Assessment by Hankinson Duckett Associates

1.1. These representations have been prepared by Stantec on behalf of Martin Grant Land Limited (formerly Martin Grant Homes) pursuant to their land interests at Silverdale Close, Coton. The site has been assessed within the Housing and Economic Land Availability Assessment 2025 (HELAA). The Site ID is 115148 and the HELAA Site ID is 40079.

1.2. These representations provide updated information regarding the site, and should be read in conjunction with the following submissions:

• Call for Sites March 2019
• Regulation 18 Issues and Options February 2020
• Regulation 18 First Proposals December 2021
• Call for Sites Submission Update March 2025

1.3. Point 1 of policy CC/WE states that development proposals must demonstrate that there will be an adequate water supply available to serve that development.

1.4. There appears a clear conflict between this and paragraph 20 of the NPPF 2024. This states that strategic policies should set out an overall strategy for the pattern, scale and design quality of places and make sufficient provision for infrastructure for water supply (amongst others). The NPPF therefore confirms that the supply of water is not normally a matter for individual planning applications because they are strategic in nature. The Planning Practice Guidance (Water supply, wastewater and water quality Paragraph 016 Ref ID: 34-016-20140306) confirms that planning for the necessary water supply would normally be addressed through authorities’ strategic policies and adds that ‘water supply is therefore unlikely to be a consideration for most planning applications’.

1.5. Point 1 should not therefore be a requirement to fall for applicants. As such, it is recommended it is deleted.

1.1. These representations have been prepared by Stantec on behalf of Martin Grant Land Limited (formerly Martin Grant Homes) pursuant to their land interests at Silverdale Close, Coton. The site has been assessed within the Housing and Economic Land Availability Assessment 2025 (HELAA). The Site ID is 115148 and the HELAA Site ID is 40079.

1.2. These representations provide updated information regarding the site, and should be read in conjunction with the following submissions:

• Call for Sites March 2019
• Regulation 18 Issues and Options February 2020
• Regulation 18 First Proposals December 2021
• Call for Sites Submission Update March 2025

1.3. Martin Grant Land has concerns regarding points 1 and 2 of proposed policy BG/BG.

Biodiversity Net Gain Point 1

1.4. Point 1 of policy BG/BG states that the 10% biodiversity net gain should be provided on-site. However, and as noted within point 2 of the same policy, the biodiversity net gain policy should retain flexibility in order to allow off-site provision where it cannot be provided on site. The Planning Practice Guidance, in paragraph:001 Reference ID:74-001-20240214 Biodiversity Net Gain states the following:

‘This objective is for development to deliver at least a 10% increase in biodiversity value relative to the pre-development biodiversity value of the onsite habitat. This increase can be achieved through onsite biodiversity gains, registered offsite biodiversity gains or statutory biodiversity credits’

1.5. Failure to add this flexibility will prevent some sites in sustainable locations being built given this clear restriction. It is therefore suggested that policy BG/BG point 1 is amended as below:

‘1. All development must deliver statutory biodiversity net gain (BNG), providing a minimum of 10% BNG against the baseline, unless exempt under the Environment Act 2021, to be provided on-site where this is feasible and effective’’

Biodiversity Net Gain Point 2

1.6. Point 2 requires major development to provide a minimum of 20% biodiversity net gain to be provided on site where feasible and effective. There are serious concerns regarding the required provision of 20% biodiversity net gain, rather than the 10% set out within the Environment Act. Such mandatory increases will have significant impacts upon layout and viability, with the potential to prevent suitable sites coming forwards. Given the spatial strategy is fully reliant upon major developments, the risk of delay or failure of some sites to contribute to delivery is high.

1.7. Paragraph: 006 Reference ID:74-006-20240214 of the Planning Practice Guidance Biodiversity Net Gain provides clear guidance that the 10% figure set out within the Environment Act should not be exceeded within Local Plans. The PPG states:

‘Plan-makers should not seek a higher percentage than the statutory objective of 10% biodiversity net gain, either on an area-wide basis or for specific allocations for development unless justified. To justify such policies they will need to be evidenced including as to local need for a higher percentage, local opportunities for a higher percentage and any impacts on viability for development. Consideration will also need to be given to how the policy will be implemented’

1.8. The Government also published a draft NPPF for consultation in December 2025, which shows the current direction of travel for emerging Government policy. In line with the above paragraph of the PPG, emerging policy N1 of the NPPF states the following:

‘Development plans should only set local standards for biodiversity net gain which are in excess of the statutory net gain requirement where this is for specific site allocations, and is fully justified and deliverable’

1.9. In light of this, it is suggested that point 2 of policy BG/BG be deleted or only added to policies supporting the relevant allocations.

1.1. These representations have been prepared by Stantec on behalf of Martin Grant Land Limited (formerly Martin Grant Homes) pursuant to their land interests at Silverdale Close, Coton. The site has been assessed within the Housing and Economic Land Availability Assessment 2025 (HELAA). The Site ID is 115148 and the HELAA Site ID is 40079.

1.2. These representations provide updated information regarding the site, and should be read in conjunction with the following submissions:

• Call for Sites March 2019
• Regulation 18 Issues and Options February 2020
• Regulation 18 First Proposals December 2021
• Call for Sites Submission Update March 2025

1.3. Policy BG/TC confirms that major development must demonstrate how it will achieve a minimum future tree canopy cover of 30% on site unless otherwise justified. There are serious concerns regarding how this may impact layouts and the viability of sites given the need to include additional tree planting and the necessary space needed to accommodate this.

1.4. Within major developments, there are several competing aspects needed on site including open space, outdoor sports, areas to achieve biodiversity net gain (which draft policy BG/BG suggests is needed on site) etc. Placing a mandatory requirement that 30% of a site area is to be planted will squeeze sites, resulting in poorer quality open space (they will all be treed) and a likely result of higher densities on available building areas.

1.5. There is also a clear conflict between this policy and biodiversity net gain. There are certain land uses that it is beneficial to replace on site as part of a wider layout, for example, wildflower meadow or grassland. These areas would benefit from a lack of tree shading. However, if developers are under pressure to plant further trees, there is a clear danger these will either replace or significantly affect other biodiversity net gain areas.

1.6. Paragraph 5.44 of the emerging Local Plan notes the Councils may also explore implications of applying an alternative policy approach of requiring a canopy cover percentage increase. This approach, subject to appropriate wording, is likely to provide developers more flexibility and would guarantee tree planting without potentially conflicting with other land uses as noted above. It is therefore suggested that points 1 and 2 of policy BG/TC is amended to the following:

‘Major development proposals must demonstrate, via a Tree Canopy Cover Assessment, how it will provide additional tree cover compared to the existing provision’

Our client, Martin Grant Land, supports the principle of focussing development in the most sustainable locations and note that this is identified ‘as far as possible’ in draft Policy S/DS (Development strategy). The emerging Local Plan needs to allow for greater flexibility for interim growth needs to be located on sites well-located to Rural Centres. Such as at our client’s site at Ambrose Way, Histon. Without a balanced approach to meeting future housing needs there is a risk that Greater Cambridge will fail to deliver the homes it needs within the plan period. Homes that are essential to support the economic growth aspirations of Greater Cambridge.

Paragraph 23 of the NPPF requires strategic policies to provide a clear strategy for bringing sufficient land forward, and at a sufficient rate, to address objectively assessed needs over the plan period. In accordance with paragraph 77 d) of the NPPF, the Councils must make a realistic assessment of likely rates of delivery and take into account the lead-in times for large scale sites.

Of the 13,463 homes identified for the period 2024-2045 only 205 of these would be accommodated in the rural area outside the southern cluster. Given the availability of sites such as our client’s, which can be delivered without the need for major infrastructure upgrade, more flexibility needs to be provided through further allocations to mitigate delays that are inevitable with strategic sites.
In January 2026 the Office for National Statistics released the quarterly figures for the monthly construction output statistics for Great Britian. Total construction output is estimated to have fallen by 1.1% in the three months to November 2025; this is the largest fall since March 2023 (1.4% fall). This latest report highlights the precarious situation that the construction industry is in with increasing material prices and decreasing numbers of people entering the industry. This adds further weight to the argument that a greater range of development sites are needed to meet future housing needs. Rather than relying on larger sites that may face more challenges in getting the volumes of materials and staff needed to maintain projected build out rates.

Without more flexibility and a greater balance between strategic and medium sized sites, the Councils risk failing to maintain a sufficient supply of new homes in the early years of the Local Plan. That could result in the inability to defend appeals for sites in less desirable and less sustainable locations that our client’s site at Ambrose Way.

On behalf of Martin Grant Land.

Focusing development only within the defined development extents of settlements is inconsistent with the proposed changes to the NPPF. The changes proposes a more flexible approach to the location of development with weight given to sites that are well-related to existing settlements. If the Councils were to adopt a more flexible approach to the development of sites well-related to defined development extents, it would result in greater opportunities for the new homes identified to come through on windfall sites to be delivered.

Defined development extents do not necessarily guard against incremental growth in unsustainable locations. Indeed, new homes in demonstrably sustainable locations can be restricted from coming forward due to locations being just outside defined development extents of highly sustainable settlements. Such as on the edges of Rural Centres. Where any harm to the countryside can be mitigated through landscaping and design, such sites should not be restricted in coming forward if they can demonstrate sustainable development. The Councils’ approach is not consistent with the proposed changes to the NPPF, which takes a more pragmatic approach to allowing appropriate development where it is well located to existing settlements. This is clearly the direction of travel that the government is taking to significantly boost the supply of new homes in accordance with paragraph 61 of the NPPF.

Recommended change: part 5 of Policy S/SH needs to be amended to read “Residential development and redevelopment without any limit on individual scheme size will be permitted within the defined development extents of Rural centres, and on land well-related to the defined development extents of Rural centres, as defined on the Policies Map, provided that adequate services, facilities and infrastructure are available or can be made available as a result of the development.”

On behalf of Martin Grant Land.

Focusing development only within the defined development extents of settlements is inconsistent with the proposed changes to the NPPF. The changes proposes a more flexible approach to the location of development with weight given to sites that are well-related to existing settlements. If the Councils were to adopt a more flexible approach to the development of sites well-related to defined development extents, it would result in greater opportunities for the new homes identified to come through on windfall sites to be delivered.

Defined development extents do not necessarily guard against incremental growth in unsustainable locations. Indeed, new homes in demonstrably sustainable locations can be restricted from coming forward due to locations being just outside defined development extents of highly sustainable settlements. Such as on the edges of Rural Centres. Where any harm to the countryside can be mitigated through landscaping and design, such sites should not be restricted in coming forward if they can demonstrate sustainable development. The Councils’ approach is not consistent with the proposed changes to the NPPF, which takes a more pragmatic approach to allowing appropriate development where it is well located to existing settlements. This is clearly the direction of travel that the government is taking to significantly boost the supply of new homes in accordance with paragraph 61 of the NPPF.

Recommended change: part 1 of Policy S/DE needs to be amended to read “Development and redevelopment of unallocated land and buildings within defined development extents, and on land well-related to the defined development extents, (as shown on the Policies Map) will be permitted provided that:”

On behalf of Martin Grant Land.

The government’s initial reforms of the NPPF in December 2024 included a modernisation of the way the green belt works. This included the consideration of development being permitted on low-quality green belt land that is identified as ‘grey belt’. An initial appraisal confirms that our client’s site is likely to be seen as grey belt as it performs poorly against the purposes of green belt in the NPPF.

Given the importance of grey belt land in the government achieving its aim of significantly boosting the supply of new homes, greater flexibility is needed for more sites to come forward on land well-related to the development frameworks. Of all the Rural Centres, Histon and Impington is one of the most sustainable with excellent public transport and cycle connectivity with Cambridge.

In previous representations we have highlighted the need for the Councils to undertake a thorough green belt review as part of the Local Plan process. With the 2024 changes to the NPPF this review is even more essential to ensure that the development strategy for Greater Cambridge is based on a sound assessment of the strategy allocating more sites nearer to Cambridge. It is inconceivable that the development strategy for an area so tightly constrained by green belt is not supported by an up to date review of the green belt, and the contributions that land parcels within it make to its purposes.

Whilst Policy S/GB follows the themes of the NPPF there is one clear area of divergence. That is in criterion c), which seeks to “prevent communities in the environs of Cambridge from merging into one another and with the city”. Criterion b) of paragraph 143 of the NPPF relates to preventing neighbouring ‘towns’ merging into one another. As the environs surrounding Cambridge are villages, draft Policy S/GB needs to be consistent with the NPPF.

Recommended change: criterion c), of Policy S/GB needs to be amended to read “prevent communities in the environs of Cambridge from merging into one another and with the city.”

Further recommendation: That a comprehensive review of the green belt be carried out to identify further sites for development in sustainable locations that can be delivered without harm to the purposes of land being designated as green belt.