Draft Greater Cambridge Local Plan for consultation

This policy needs to be proportionate to the scale of development proposed and should recognise the differences between Transport Statements and Transport Assessments.

The production of the plan needs to be delayed to allow the advice contained within the most up to date NPPF to be included. As a consequence of the timescales associated with this Plan, it is inconceivable that a new version of the NPPF will have been published. This will render many elements of this Local Plan out of date. Of particular relevance is the need to identify 20% of your allocations on small sites. These should be dispersed across the district thereby meeting the needs of the whole population thereby not just focussing on the growth of Cambridge.

There are concerns that this plan fails to have due regard to the draft for consultation NPPF. This is likely to be adopted in June/July 2026 and the Local Plan must accord with it. Failure to properly address this document, even if this means a short delay in the preparation of the Local Plan, will prevent abortive work being undertaken and ensure the plan is based on the most up to date guidance. It will also avoid the plan needing to be immediately reviewed.
The following parts of the Draft NPPF should be taken into account:
Draft NPPF PM6: General principles for plan-making
1. All plan-makers should, in preparing plans:
a. Only address matters, and include policies, that are necessary and relevant to the plan being prepared, and which avoid unnecessary duplication of other parts of the development plan;
b. Only include policies which extend beyond site or location-specific requirements where these are necessary and where plan makers consider there is a clear and justified reason for inclusion;
c. Not duplicate, substantively restate or modify the content of national decision-making policies unless directed by other policies in this Framework
It is contended that the Plan is too detailed and is currently duplicating the content of national decision making policies. This emphasises the need for the policies to be updated having due regard to the requirements of the emerging NPPF. As the Plan is written, it will be rendered out of date as soon as the draft NPPF is adopted.
Draft NPPF PM8: Evidence for plan-making
1. All plans should be informed by a baseline understanding of the needs, opportunities, constraints and wider context of the area to which they relate. The preparation of plans should then be shaped and underpinned by information and data that is: relevant to the matters being considered in the plan; proportionate, so that it is focused and not unnecessarily extensive; and drawn from suitable and reliable sources that are sufficiently up-to-date…
It is clear that the information being submitted in support of the Plan is not proportionate and is unnecessarily extensive. This is emphasised by numerous subsidiary documents being referred to in addition to the already extensive content of the draft Plan.
Draft NPPF PM13: Setting standards
1. Quantitative standards set through development plan policies should be limited to infrastructure provision, affordable housing requirements, parking and design and placemaking, and where this will provide clarity and a high degree of certainty about the requirements that relevant development proposals are expected to meet. Such standards should:
a. Be justified, drawing upon relevant evidence of local characteristics and needs, while utilising or adapting relevant national standards where it is appropriate to do so (such as in relation to green infrastructure). Evidence in support of standards should be proportionate, in accordance with policy PM8, especially where relevant national standards already exist;
Comment as above reference Draft NPPF PM8.
Draft NPPF PM14: Examining spatial development strategies - d. Consistent with national policy – the strategy accords with the policies for plan making in this Framework and other statements of national planning policy, where relevant, and does not duplicate, substantively restate or modify the content of national policies for decision-making.
It is contended that the Plan duplicates and also modifies the content of national policies for decision making, i.e. the BNG requirement.
Draft NPPF HO6: Planning for a diverse mix of sites:
1. To support the provision of a diverse mix of sites, local plans should:
a. Allocate land to accommodate at least 10% of the housing requirement on sites no larger than one hectare, and a further 10% on sites of between one and two and a half hectares, unless there are strong reasons why these targets cannot be achieved; and
b. Allocate sites which will support and enhance the vitality of rural communities and enable villages to grow and thrive, especially where this will support local services.
The Plan fails to have any regard to this, with very few sites of circa 1 -2.5ha allocated for development. There is too greater focus on large, urban sites. This may address the needs of Cambridge, but not the wider plan area. An example being that whilst significant areas of commercial development are proposed adjacent to the A14, there is limited residential development to provide for the potential employee’s needs.

A more detailed assessment should be undertaken of the smaller sites, including North of Willingham Road, Over, HELAA reference 40323, should be undertaken and proper reasoning be given as to why such sites have or have not been taken forward for inclusion in the plan. This should form the basis of a smaller sites assessment document which ensures that at least 20% of the allocations in the Local Plans are on sites of between one and two and a half hectares.
Following this assessment, the plan should be expanded to include further allocations on smaller sites.

The Plan has a dearth of residential sites to the west of Cambridge, with particularly limited residential allocations within the northwestern quadrant. The plan fails to recognise that residents not only reside in and travel to Cambridge, but also work to the west.
There is too great a focus on very large developments - failing to recognise that smaller developments in Group Villages, such as Over, can be quickly delivered, maintaining the Councils delivery of housing and assisting in sustaining the services and facilities of Group Village. Such sites also recognise that not all residents wish to live in large, high density developments.
An appropriate example would be the land submitted at North of Willingham Road, Over, HELAA reference 40323. Sites such as this need to be reviewed to ensure that the smaller sites are appropriately represented. It is clear at this stage that they are not and this could potentially render the Plan unsound.
Better distribution of new housing would also allow the objective of the Local Plan to be achieved which states that “As well as planning to meet the overall need in terms of the number of new homes, our policies seek to ensure that the right mix of house types and tenure is delivered. We want homes to be of a high quality, we therefore set minimum sizes for rooms and outdoor space. We also require homes to be adaptable, so they can meet need through people’s lives”. After tenure it is recommended that in the right places is included.
Due regard needs to be given Draft NPPF HO6: Planning for a diverse mix of sites which seeks to
a. Allocate land to accommodate at least 10% of the housing requirement on sites no larger than one hectare, and a further 10% on sites of between one and two and a half hectares, unless there are strong reasons why these targets cannot be achieved.
The site North of Willingham Road, Over (HELAA reference 40323) is 1.94 hectares in area and would clearly fall within the requirement that 10% of allocated sites should be between one and two and a half hectares. The plan does not provide strong reasons as to why this target cannot be achieved and not considering smaller sites demonstrates a failure of the plan to address the needs of the plan area.
As a consequence of the above a more detailed assessment of the smaller sites, including North of Willingham Road, Over, HELAA reference 40323, should be undertaken and proper reasoning be given as to why such sites have or have not been taken forward for inclusion in the plan. This should form the basis of a smaller sites assessment document which ensures that at least 20% of the allocations in the Local Plans are on sites of between one and two and a half hectares.

The development strategy needs to be reconsidered and recognition be given to the potential for smaller sites to come forward. These can be brought forward more quickly and will also ensure that there is a balanced distribution of housing across the whole district. Such an approach will help to maintain the viability of services and facilities within villages, which is equally important for social cohesion.

Having reviewed the draft plan policies and supporting evidence base, our view is that the chosen strategy is seriously flawed in respect of the appropriate distribution of residential development as it relies heavily on a few large, strategic allocations. For example, the Cambourne North and Grange Farm allocations are required to deliver 5,100 dwellings between them by 2045 out of the 19,000 dwellings for these two sites combined. In reality, these two sites coming forward for development rely on major infrastructure delivery, e:g Cambourne’s new East West Rail Station. There is clear that large sites typically take many years to deliver completions on the ground.


Another significant flaw in the Development Strategy is that it does not allocate more than a handful of housing sites in the existing settlements that make up the majority of South Cambs District. This has two significant implications – firstly, allocating a range of small to medium sized sites would be beneficial to the trajectory in terms of speed of delivery; and secondly, facilitating the growth of the villages promotes the vitality of existing settlements and viability of their services, supporting sustainable communities within the district. The Councils need to rethink the Development Strategy and allocate new sites in sustainable village locations which can deliver local benefits to local communities, including affordable housing to meet local needs, supporting existing services and promoting sustainable growth.
For example the village of Over falls within the Group Village Category where an indicative maximum scheme size of eight dwellings, or exceptionally 15 dwellings where making best use of a single brownfield site would be appropriate. Such figures are too low and fail to recognise sustainability of Over and its suitability to accommodate further housing.

The development strategy needs to be reconsidered and recognition be given to the potential for smaller sites to come forward. These can be brought forward more quickly and will also ensure that there is a balanced distribution of housing across the whole district. Such an approach will help to maintain the viability of services and facilities within villages, which is equally important for social cohesion.

Having reviewed the draft plan policies and supporting evidence base, our view is that the chosen strategy is seriously flawed in respect of the appropriate distribution of residential development as it relies heavily on a few large, strategic allocations. For example, the Cambourne North and Grange Farm allocations are required to deliver 5,100 dwellings between them by 2045 out of the 19,000 dwellings for these two sites combined. In reality, these two sites coming forward for development rely on major infrastructure delivery, e:g Cambourne’s new East West Rail Station. There is clear that large sites typically take many years to deliver completions on the ground.


Another significant flaw in the Development Strategy is that it does not allocate more than a handful of housing sites in the existing settlements that make up the majority of South Cambs District. This has two significant implications – firstly, allocating a range of small to medium sized sites would be beneficial to the trajectory in terms of speed of delivery; and secondly, facilitating the growth of the villages promotes the vitality of existing settlements and viability of their services, supporting sustainable communities within the district. The Councils need to rethink the Development Strategy and allocate new sites in sustainable village locations which can deliver local benefits to local communities, including affordable housing to meet local needs, supporting existing services and promoting sustainable growth.
For example the village of Over falls within the Group Village Category where an indicative maximum scheme size of eight dwellings, or exceptionally 15 dwellings where making best use of a single brownfield site would be appropriate. Such figures are too low and fail to recognise sustainability of Over and its suitability to accommodate further housing.

The development strategy needs to be reconsidered and recognition be given to the potential for smaller sites to come forward. These can be brought forward more quickly and will also ensure that there is a balanced distribution of housing across the whole district. Such an approach will help to maintain the viability of services and facilities within villages, which is equally important for social cohesion.

Having reviewed the draft plan policies and supporting evidence base, our view is that the chosen strategy is seriously flawed in respect of the appropriate distribution of residential development as it relies heavily on a few large, strategic allocations. For example, the Cambourne North and Grange Farm allocations are required to deliver 5,100 dwellings between them by 2045 out of the 19,000 dwellings for these two sites combined. In reality, these two sites coming forward for development rely on major infrastructure delivery, e:g Cambourne’s new East West Rail Station. There is clear that large sites typically take many years to deliver completions on the ground.


Another significant flaw in the Development Strategy is that it does not allocate more than a handful of housing sites in the existing settlements that make up the majority of South Cambs District. This has two significant implications – firstly, allocating a range of small to medium sized sites would be beneficial to the trajectory in terms of speed of delivery; and secondly, facilitating the growth of the villages promotes the vitality of existing settlements and viability of their services, supporting sustainable communities within the district. The Councils need to rethink the Development Strategy and allocate new sites in sustainable village locations which can deliver local benefits to local communities, including affordable housing to meet local needs, supporting existing services and promoting sustainable growth.
For example the village of Over falls within the Group Village Category where an indicative maximum scheme size of eight dwellings, or exceptionally 15 dwellings where making best use of a single brownfield site would be appropriate. Such figures are too low and fail to recognise sustainability of Over and its suitability to accommodate further housing.