Draft Greater Cambridge Local Plan for consultation
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Draft Greater Cambridge Local Plan for consultation
Policy S/DS: Development strategy
Respondent: Northwest Biotherapeutics Capital Limited
Representation Summary:
Whilst we do not object to the principle of allocating large new housing developments, we object strongly
to the failure to balance this approach with a more diverse approach to housing delivery across Greater
Cambridge in the emerging Local Plan. Allocating sites for housing developments in sustainable locations
such as Sawston would:
• Deliver homes more quickly and in the first half of the plan period;
• Provide certainty to smaller housebuilders;
• Support the vitality of the rural area;
• Delivery affordable housing in areas with pressing need; and
• Offer greater flexibility for house buyers.
The draft plan is currently placing a lot of risk for housing delivery in a limited number of very large pots,
and in particular the proposed large new allocations at Cambourne North and Grange Farm require the delivery of infrastructure at scale which is likely to delay their delivery. These delays have been
experienced across many of the large strategic sites in Greater Cambridge in recent decades.
Instead, we suggest a more blended approach, with a more rational approach to sustainable rural
development is considered, alongside a review by the Council of potential Grey Belt sites.
Bidwells has prepared a report on the on the issues with delivery of large scale housing sites. Please see
this attached to this representation in support.
Change suggested by respondent:
The Councils have not identified any new allocations for housing in the rural area which fails to
support the vitality of the rural area and existing settlements. We believe that this decision, has
been made in part, to avoid development in the Green Belt, and therefore fails to strike a more
balanced approach to housing delivery across the Plan period.
The local plan should allocate sites for housing developments in sustainable locations such as Sawston.
Full text:
Bidwells has a long history of promoting development proposal sites for clients through Local Plans in
Cambridge and South Cambridgeshire. Given this experience we are very concerned that the draft strategy
for the Plan (Policy S/DS) relies very heavily on allocating significant dwelling numbers on a small number
of very large sites. These sites rely on the timely provision of strategic scale infrastructure which must be
in place before these sites can be delivered.
The proposed new strategic scale allocations we are particularly concerned about are the Cambourne
North new settlement (13,000 dwellings) relying on a new railway station associated with East West Rail
(hereafter “EWR”) and complicated works to the A428. Grange Farm (6,000 dwellings) relies on works to
the A505 and the complication of providing new residents with safe access to the proposed Cambridge
South East Transport (hereafter “CSET”) Phase 2 Guided Busway Travel Hub on the adjacent side of the
A505.
The draft Plan requires these two sites to deliver 5,100 dwellings between them by 2045. We believe this
is highly unlikely for reasons set out in our full representation.
Whilst in principle we do not object to the principle of seeking to deliver a large number of new homes at
scale, we consider that this approach sets the draft local plan on a path of over-reliance on these sites
which is problematic for the following reasons:
1. The speed at which these developments can deliver homes is often far slower than the Councils
have envisaged historically. A review of historic Annual Monitoring Reports demonstrates that the
large strategic sites in the current Development Plan, may now be delivering at an appropriate
rate, however they came on stream several years later than anticipated.
2. The Councils have not identified any new allocations for housing in the rural area which fails to
support the vitality of the rural area and existing settlements. We believe that this decision, has
been made in part, to avoid development in the Green Belt, and therefore fails to strike a more
balanced approach to housing delivery across the Plan period.
3. The ‘lumping’ together of rural centres, minor rural centres, group villages and infill villages from
the settlement hierarchy (taken from Policy S/SH), effectively as the locations with the lowest
preference to deliver jobs and homes, clearly fails to distinguish between what may be highly
sustainable locations in the rural area (ie: Sawston) a Rural Centre the highest of these categories
(where there will be no limit on scheme size), and which is clearly capable of delivering an
appropriate scale of development.
The Councils have not committed to undertake a review of potential Grey Belt sites and their development
potential as an alternative spatial strategy, which is apparent in the October 2025 Sustainability Appraisal.
Whilst there is no absolute requirement to review Grey Belt sites in the NPPF 2024 as part of plan-making,
it would be prudent to consider this as an alternative, as it may not be as simple in policy terms to assign
the same importance to all Green Belt given the biggest policy change to it in several decades.
Bidwells understand that GCSP’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).
Draft Greater Cambridge Local Plan for consultation
The Rural Southern Cluster
Respondent: Northwest Biotherapeutics Capital Limited
Representation Summary:
Whilst we do not object to the principle of allocating large new housing developments, we object strongly
to the failure to balance this approach with a more diverse approach to housing delivery across Greater
Cambridge in the emerging Local Plan. Allocating sites for housing developments in sustainable locations
such as Sawston would:
• Deliver homes more quickly and in the first half of the plan period;
• Provide certainty to smaller housebuilders;
• Support the vitality of the rural area;
• Delivery affordable housing in areas with pressing need; and
• Offer greater flexibility for house buyers.
The draft plan is currently placing a lot of risk for housing delivery in a limited number of very large pots,
and in particular the proposed large new allocations at Cambourne North and Grange Farm require the delivery of infrastructure at scale which is likely to delay their delivery. These delays have been experienced across many of the large strategic sites in Greater Cambridge in recent decades.
Instead, we suggest a more blended approach, with a more rational approach to sustainable rural
development is considered, alongside a review by the Council of potential Grey Belt sites.
Bidwells has prepared a report on the on the issues with delivery of large scale housing sites. Please see
this attached to this representation in support.
Change suggested by respondent:
The Councils have not identified any new allocations for housing in the rural area which fails to
support the vitality of the rural area and existing settlements. We believe that this decision, has
been made in part, to avoid development in the Green Belt, and therefore fails to strike a more
balanced approach to housing delivery across the Plan period.
The site at Land North of Mill Lane Sawston should be allocated for development under draft policy S/RSC.
Full text:
The Councils have not identified any new housing allocations within the Rural Southern Cluster. This
approach fails to support the vitality, resilience and long-term sustainability of rural centres such as
Sawston, despite their recognised role in the settlement hierarchy.
The Development Strategy appears to rely disproportionately on large-scale strategic allocations while
excluding sustainable, edge-of-settlement opportunities in highly accessible Rural Centres. This
unbalanced approach reduces flexibility and choice in housing delivery and increases reliance on a limited
number of complex sites coming forward as anticipated.
Whilst we do not object in principle to the allocation of large new housing developments, it strongly objects
to the absence of a more diversified spatial strategy that allows sustainable growth within Rural Centres to
complement strategic scale development. The failure to do so undermines the effectiveness and resilience
of the Plan over the plan period.
A separate representation on behalf of NWBio has been submitted in respect of draft Policy S/DS, setting
out concerns with the overall Development Strategy in greater detail. This objection should be read in
conjunction with that submission.
An updated Call for Sites (CfS) submission has been prepared and submitted to the Council alongside this representation as part of the Draft GCLP consultation for Land North of Mill Lane Sawston. The updated Call for Sites submission demonstrates that the Site is suitable, available and deliverable, representing a sustainable Grey Belt opportunity adjacent to a highly accessible Rural Centre supported by a comprehensive range of services, facilities and employment opportunities.
By failing to allocate this land, the Plan misses an opportunity to deliver sustainable growth in an appropriate location. Allocation under Policy S/RSC would ensure a more balanced, flexible and effective Development Strategy. Our full detailed representation is attached.
Draft Greater Cambridge Local Plan for consultation
Policy S/RSC: Other site allocations in the Rural Southern Cluster
Respondent: Northwest Biotherapeutics Capital Limited
Representation Summary:
An updated Call for Sites (CfS) submission has been prepared and submitted to the Council alongside this representation as part of the Draft GCLP consultation. This submission relates to Land North of Mill Lane, Sawston, CB22 3BY (HELAA Ref. 40341).
The submission provides a comprehensive and robust package of supporting information to assist the Council in its assessment of the site’s suitability, availability and deliverability.
Change suggested by respondent:
Allocate Land North of Mill Lane, Sawston, CB22 3BY (HELAA Ref. 40341) for development as part of the Greater Cambridge Local Plan.
Full text:
Bidwells has a long history of promoting development proposal sites for clients through Local Plans in
Cambridge and South Cambridgeshire. Given this experience we are very concerned that the draft strategy
for the Plan (Policy S/DS) relies very heavily on allocating significant dwelling numbers on a small number
of very large sites. These sites rely on the timely provision of strategic scale infrastructure which must be
in place before these sites can be delivered.
The proposed new strategic scale allocations we are particularly concerned about are the Cambourne
North new settlement (13,000 dwellings) relying on a new railway station associated with East West Rail
(hereafter “EWR”) and complicated works to the A428. Grange Farm (6,000 dwellings) relies on works to
the A505 and the complication of providing new residents with safe access to the proposed Cambridge
South East Transport (hereafter “CSET”) Phase 2 Guided Busway Travel Hub on the adjacent side of the
A505.
The draft Plan requires these two sites to deliver 5,100 dwellings between them by 2045. We believe this
is highly unlikely for reasons set out in our full representation.
Whilst in principle we do not object to the principle of seeking to deliver a large number of new homes at
scale, we consider that this approach sets the draft local plan on a path of over-reliance on these sites
which is problematic for the following reasons:
1. The speed at which these developments can deliver homes is often far slower than the Councils
have envisaged historically. A review of historic Annual Monitoring Reports demonstrates that the
large strategic sites in the current Development Plan, may now be delivering at an appropriate
rate, however they came on stream several years later than anticipated.
2. The Councils have not identified any new allocations for housing in the rural area which fails to
support the vitality of the rural area and existing settlements. We believe that this decision, has
been made in part, to avoid development in the Green Belt, and therefore fails to strike a more
balanced approach to housing delivery across the Plan period.
3. The ‘lumping’ together of rural centres, minor rural centres, group villages and infill villages from
the settlement hierarchy (taken from Policy S/SH), effectively as the locations with the lowest
preference to deliver jobs and homes, clearly fails to distinguish between what may be highly
sustainable locations in the rural area (ie: Sawston) a Rural Centre the highest of these categories
(where there will be no limit on scheme size), and which is clearly capable of delivering an
appropriate scale of development.
The Councils have not committed to undertake a review of potential Grey Belt sites and their development
potential as an alternative spatial strategy, which is apparent in the October 2025 Sustainability Appraisal.
Whilst there is no absolute requirement to review Grey Belt sites in the NPPF 2024 as part of plan-making,
it would be prudent to consider this as an alternative, as it may not be as simple in policy terms to assign
the same importance to all Green Belt given the biggest policy change to it in several decades.
Bidwells understand that GCSP’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).
Draft Greater Cambridge Local Plan for consultation
Policy S/GB: The Cambridge Green Belt
Respondent: Northwest Biotherapeutics Capital Limited
Representation Summary:
Paragraph 146 (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. It is therefore noted that GCSP may require a further Green Belt review and consider the additional release of land from the Green Belt to accommodate a higher growth scenario should the Council not be able to accommodate additional growth on non-Green Belt sites.
It is understood that GCSP’s consultants 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 the Councils 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).
Change suggested by respondent:
Publish the Grey Belt review for Greater Cambridge and consider the impacts that this would have for the wider development strategy.
Full text:
Bidwells has a long history of promoting development proposal sites for clients through Local Plans in
Cambridge and South Cambridgeshire. Given this experience we are very concerned that the draft strategy
for the Plan (Policy S/DS) relies very heavily on allocating significant dwelling numbers on a small number
of very large sites. These sites rely on the timely provision of strategic scale infrastructure which must be
in place before these sites can be delivered.
The proposed new strategic scale allocations we are particularly concerned about are the Cambourne
North new settlement (13,000 dwellings) relying on a new railway station associated with East West Rail
(hereafter “EWR”) and complicated works to the A428. Grange Farm (6,000 dwellings) relies on works to
the A505 and the complication of providing new residents with safe access to the proposed Cambridge
South East Transport (hereafter “CSET”) Phase 2 Guided Busway Travel Hub on the adjacent side of the
A505.
The draft Plan requires these two sites to deliver 5,100 dwellings between them by 2045. We believe this
is highly unlikely for reasons set out in our full representation.
Whilst in principle we do not object to the principle of seeking to deliver a large number of new homes at
scale, we consider that this approach sets the draft local plan on a path of over-reliance on these sites
which is problematic for the following reasons:
1. The speed at which these developments can deliver homes is often far slower than the Councils
have envisaged historically. A review of historic Annual Monitoring Reports demonstrates that the
large strategic sites in the current Development Plan, may now be delivering at an appropriate
rate, however they came on stream several years later than anticipated.
2. The Councils have not identified any new allocations for housing in the rural area which fails to
support the vitality of the rural area and existing settlements. We believe that this decision, has
been made in part, to avoid development in the Green Belt, and therefore fails to strike a more
balanced approach to housing delivery across the Plan period.
3. The ‘lumping’ together of rural centres, minor rural centres, group villages and infill villages from
the settlement hierarchy (taken from Policy S/SH), effectively as the locations with the lowest
preference to deliver jobs and homes, clearly fails to distinguish between what may be highly
sustainable locations in the rural area (ie: Sawston) a Rural Centre the highest of these categories
(where there will be no limit on scheme size), and which is clearly capable of delivering an
appropriate scale of development.
The Councils have not committed to undertake a review of potential Grey Belt sites and their development
potential as an alternative spatial strategy, which is apparent in the October 2025 Sustainability Appraisal.
Whilst there is no absolute requirement to review Grey Belt sites in the NPPF 2024 as part of plan-making,
it would be prudent to consider this as an alternative, as it may not be as simple in policy terms to assign
the same importance to all Green Belt given the biggest policy change to it in several decades.
Bidwells understand that GCSP’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).
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