Draft Greater Cambridge Local Plan for consultation

Policy S/JH should have higher job and housing figures and to explicitly support higher-growth scenarios to align with national policy objectives.

Bellway objects to Draft Policy S/JH.
We are concerned that the quantum of jobs and homes proposed to be delivered across the plan period is too conservative and does not reflect the aspirational targets for growth in Cambridge mandated by national, regional and local government.
In the first instance, planning for only 10,330 homes through new allocations across the plan period (2024-2045) is insufficient (remaining balance consisting of existing allocations / permissions). Significantly more housing land should be allocated to ensure a plan-led approach to the sustainable growth of Greater Cambridge.
The identified overall need of 48,195 new homes across the plan period (2024 – 2045) is underpinned by the ‘Greater Cambridge Employment and Housing Needs Update 2024 – 2045’ (“EHNU”) (September 2025). The Report concludes at paragraph 3.55 that various scenarios modelled indicate a need between 67,600 and 90,900 additional jobs over the plan period. This compares to between 66,600 and 75,800 additional jobs modelled under the previous 2023 results. This significant increase in the upper end of the modelling indicates that economic growth expectations have strengthened exponentially, not diminished.
Rightly the EHNU draws a relationship between job growth and housing need, on the basis that greater job growth in the region will generate a derived demand for housing, creating an interdependency between the two. The adoption of the preferred ‘central growth scenario’ for job growth (73,300 additional jobs) gives an output need for 48,132 dwellings across the plan period which translates a ‘central scenario’ for an annual need of 2,292 dwellings per annum (almost identical to the Standard Method requirement of 2,295). This is considered problematic.
The ‘central growth scenario,’ as outlined within the EHNU, builds in assumptions of slower periods of growth, contractions, and economic shocks. Inherently both the number of jobs and homes proposed within the Draft Local Plan are conservative rather than reflective of the full growth potential of the Greater Cambridge economy.
Growth in Cambridge remains a priority for the Government, heightening the urgency for increasing job creation and housing supply and result in a step-change in the wider policy framework within which the Draft Local Plan must be considered and must respond to. The Government’s commitment to Cambridge was reinforced on 23 October 2025 where the ambition to ‘supercharge growth’ within the Oxford-Cambridge Corridor and realise the full potential of Greater Cambridge was set out. This statement was accompanied by the announcement of £400 million worth of funding for the Cambridge Growth Company (CGC) to establish a centrally-led development corporation which will be informed by its own evidence base, which whilst unknown at present, is anticipated to exceed that currently envisioned by GCSP.
Furthermore, Greater Cambridge has been, and continues to be, the location of strategic infrastructure investment that will continue to drive upwards increases in the need for new jobs and homes. This includes the proposed East West rail station as well as the proposed public transport improvements for the Cambourne to Cambridge Corridor (C2C) and the Cambridge Eastern Access Corridor.
When considering the above, the decision to use the ‘central growth scenario’ for the identification of jobs and homes which, by Iceni’s admission, builds in assumptions of periods of slower growth, contractions and economic shocks, and is hence a conservative approach, is not considered to respect the growth agenda envisioned for Cambridge.
Specifically with regards to housing, an annual requirement that is almost identical to the Standard Method figure (which does not take into account the unique circumstances and growth envisioned for Cambridge) is condemning of the Draft Local Plan’s lack of ambition in this regard.
The EHNU acknowledges a ‘High’ and ‘High Sensitivity’ scenario, whereby growth would meet or exceed the 2010–2020 trajectory. This high level of growth is feasible in Cambridge and would support the Government’s direction of travel. It is therefore important to recognise that higher-growth outcomes remain credible and should not be ruled out by policy. This requires revision to the proposed policy wording. Should the ‘central growth scenario’ be progressed it considered these must be identified as a minimum level of growth, not a ceiling.
For these reasons, the Local Plan should consider utilising more optimistic and realistic figures for job and housing numbers and include explicit support for higher-growth scenarios. Without these changes, Policy S/JH risks being unsound and inconsistent with national policy objectives to support sustainable economic growth and productivity. As discussed below, GCSP should consider the allocation of additional sites in Greater Cambridge, particularly in sustainable village locations such as Land south of West Street and west of South Street, Comberton, to assist in realising a greater level of growth.

Policy S/JH should include higher job and housing figures to support the growth of Greater Cambridge.

Bellway objects to Draft Policy S/JH.
We are concerned that the quantum of jobs and homes proposed to be delivered across the plan period is too conservative and does not reflect the aspirational targets for growth in Cambridge mandated by national, regional and local government.
In the first instance, planning for only 10,330 homes through new allocations across the plan period (2024-2045) is insufficient (remaining balance consisting of existing allocations / permissions). Significantly more housing land should be allocated to ensure a plan-led approach to the sustainable growth of Greater Cambridge.
The identified overall need of 48,195 new homes across the plan period (2024 – 2045) is underpinned by the ‘Greater Cambridge Employment and Housing Needs Update 2024 – 2045’ (“EHNU”) (September 2025). The Report concludes at paragraph 3.55 that various scenarios modelled indicate a need between 67,600 and 90,900 additional jobs over the plan period. This compares to between 66,600 and 75,800 additional jobs modelled under the previous 2023 results. This significant increase in the upper end of the modelling indicates that economic growth expectations have strengthened exponentially, not diminished.
Rightly the EHNU draws a relationship between job growth and housing need, on the basis that greater job growth in the region will generate a derived demand for housing, creating an interdependency between the two. The adoption of the preferred ‘central growth scenario’ for job growth (73,300 additional jobs) gives an output need for 48,132 dwellings across the plan period which translates a ‘central scenario’ for an annual need of 2,292 dwellings per annum (almost identical to the Standard Method requirement of 2,295). This is considered problematic.
The ‘central growth scenario,’ as outlined within the EHNU, builds in assumptions of slower periods of growth, contractions, and economic shocks. Inherently both the number of jobs and homes proposed within the Draft Local Plan are conservative rather than reflective of the full growth potential of the Greater Cambridge economy.
Growth in Cambridge remains a priority for the Government, heightening the urgency for increasing job creation and housing supply and result in a step-change in the wider policy framework within which the Draft Local Plan must be considered and must respond to. The Government’s commitment to Cambridge was reinforced on 23 October 2025 where the ambition to ‘supercharge growth’ within the Oxford-Cambridge Corridor and realise the full potential of Greater Cambridge was set out. This statement was accompanied by the announcement of £400 million worth of funding for the Cambridge Growth Company (CGC) to establish a centrally-led development corporation which will be informed by its own evidence base, which whilst unknown at present, is anticipated to exceed that currently envisioned by GCSP.
Furthermore, Greater Cambridge has been, and continues to be, the location of strategic infrastructure investment that will continue to drive upwards increases in the need for new jobs and homes. This includes the proposed East West rail station as well as the proposed public transport improvements for the Cambourne to Cambridge Corridor (C2C) and the Cambridge Eastern Access Corridor.
When considering the above, the decision to use the ‘central growth scenario’ for the identification of jobs and homes which, by Iceni’s admission, builds in assumptions of periods of slower growth, contractions and economic shocks, and is hence a conservative approach, is not considered to respect the growth agenda envisioned for Cambridge.
Specifically with regards to housing, an annual requirement that is almost identical to the Standard Method figure (which does not take into account the unique circumstances and growth envisioned for Cambridge) is condemning of the Draft Local Plan’s lack of ambition in this regard.
The EHNU acknowledges a ‘High’ and ‘High Sensitivity’ scenario, whereby growth would meet or exceed the 2010–2020 trajectory. This high level of growth is feasible in Cambridge and would support the Government’s direction of travel. It is therefore important to recognise that higher-growth outcomes remain credible and should not be ruled out by policy. This requires revision to the proposed policy wording. Should the ‘central growth scenario’ be progressed it considered these must be identified as a minimum level of growth, not a ceiling.
For these reasons, the Local Plan should consider utilising more optimistic and realistic figures for job and housing numbers and include explicit support for higher-growth scenarios. Without these changes, Policy S/JH risks being unsound and inconsistent with national policy objectives to support sustainable economic growth and productivity. As discussed below, GCSP should consider the allocation of additional sites in Greater Cambridge, particularly in sustainable village locations such as Land west of South Street, Comberton, to assist in realising a greater level of growth.

Policy S/DS should allocate more non-strategic sites in sustainable locations, such as Comberton, to enhance housing delivery and resilience.

Bellway objects to Draft Policy S/DS.
Draft Policy S/DS relies heavily on allocating a significant majority of dwellings to meet the identified housing needs across the plan period within a few large-scale strategic sites. These sites rely on the timely provision of strategic scale infrastructure which often leads to significant lead in times to deliver and often delays when reviewed against the Council’s delivery trajectories.
The proposed new strategic allocations at Cambourne North new settlement (13,000 dwellings) and Grange Farm (6,000) dwellings raise particular concern with regards to their deliverability, relying on a new railway station with East West Rail and significant improvement works to the A505 and delivery of South East Transport (CSET) Phase 2 Guided Busway on the adjacent side of the A505 respectively.
Whilst we do not object to the principle of seeking to deliver a large number of new homes at scale, it is considered that this approach sets the Council on a path of over-reliance on these sites to deliver and does not embed resilience into the Local Plan should these sites stall in delivery.
A review of historic Annual Monitoring (AMR) Reports indicates that large strategic sites allocated within the adopted Development Plan, whilst some may now be delivering at anticipated rates, faced considerable delays to delivery at first; in some cases, several years later than originally envisioned and did not deliver quickly once first completions were achieved.
A Housing Delivery Study has been prepared by Bidwells (Appendix A). The study interrogates recent delivery of housing at strategic sites across Greater Cambridge against the Council’s delivery assumptions, the key findings of this report are below:
• With the exception of Waterbeach, strategic sites have taken longer to deliver their first dwelling than the Council anticipated, often considerably later;
• Once homes are delivered, often, homes are delivered at a slower rate than anticipated;
• Some sites have been in the pipeline for with no indication on when applications and delivery will commence, notably North East Cambridge and Cambridge East following Marshall’s cancelled move to Cranfield Airport.
Overall, the Report identifies by virtue of the complex nature of strategic sites delivery is often significantly delayed when compared to the Council’s anticipated trajectory for these sites.
It is therefore considered an over reliance on large scale sites threatens the deliverability of the Local Plan, particularly should these sites (notably Cambourne North and Grange Farm) face delays in delivery as anticipated give the above commentary. As such, the Council ought to consider allocating additional smaller sites which face shorter lead in times, kickstart the delivery of housing in the early years of the plan period in the interim whilst strategic sites progress with the delivery of relevant infrastructure and provide greater resilience to the delivery of new homes.
We are of the view that additional sites ought to be considered to address the concerns outlined above. To ensure the Local Plan is effective, justified and positively prepared we recommend additional non-strategic sites are allocated in sustainable locations. Such sustainable locations are likely to be on the edge of existing settlements, with strong transport links and proximity to transport nodes where new sites can be developed to contribute to and enhance the existing offer. For instance, and as set out in the following section, Comberton is a sustainable settlement to facilitate appropriate levels of growth.
The Site represents an opportunity to locate sensitively designed and considered development on the edge of an existing settlement with good public transport connections and services and facilities.

Policy S/DS should include for a significant increase in the number of non-strategic sites in villages in the Rural Area, to ensure delivery early in the plan period and ensure the GCLP is effective.

Bellway objects to Draft Policy S/DS.
Draft Policy S/DS relies heavily on allocating a significant majority of dwellings to meet the identified housing needs across the plan period within a few large-scale strategic sites. These sites rely on the timely provision of strategic scale infrastructure which often leads to significant lead-in times to deliver and often delays when reviewed against the Council’s delivery trajectories.
The proposed new strategic allocations at Cambourne North new settlement (13,000 dwellings) and Grange Farm (6,000) dwellings raise particular concern with regards to their deliverability, relying on a new railway station with East West Rail and significant improvement works to the A505 and delivery of South East Transport (CSET) Phase 2 Guided Busway on the adjacent side of the A505 respectively.
Whilst we do not object to the principle of seeking to deliver a large number of new homes at scale, it is considered that this approach sets the Council on a path of over-reliance on these sites to deliver and does not embed resilience into the Local Plan should these sites stall in delivery.
A review of historic Annual Monitoring (AMR) Reports indicates that large strategic sites allocated within the adopted Development Plan, whilst some may now be delivering at anticipated rates, faced considerable delays to delivery at first; in some cases, several years later than originally envisioned and did not deliver quickly once first completions were achieved.
A Housing Delivery Study has been prepared by Bidwells (Appendix A). The study interrogates recent delivery of housing at strategic sites across Greater Cambridge against the Council’s delivery assumptions, the key findings of this report are below:
• With the exception of Waterbeach, strategic sites have taken longer to deliver their first dwelling than the Council anticipated, often considerably later;
• Once homes are delivered, often, homes are delivered at a slower rate than anticipated;
• Some sites have been in the pipeline for with no indication on when applications and delivery will commence, notably North East Cambridge and Cambridge East following Marshall’s cancelled move to Cranfield Airport.
Overall, the Report identifies by virtue of the complex nature of strategic sites delivery is often significantly delayed when compared to the Council’s anticipated trajectory for these sites.
It is therefore considered an over-reliance on large scale sites threatens the deliverability of the Local Plan, particularly should these sites (notably Cambourne North and Grange Farm) face delays in delivery as anticipated given the above commentary. As such, the Council ought to consider allocating additional smaller sites which face shorter lead in times, kickstart the delivery of housing in the early years of the plan period in the interim whilst strategic sites progress with the delivery of relevant infrastructure and provide greater resilience to the delivery of new homes.
We are of the view that additional sites ought to be considered to address the concerns outlined above. To ensure the Local Plan is effective, justified and positively prepared we recommend additional non-strategic sites are allocated in sustainable locations. Such sustainable locations are likely to be on the edge of existing settlements, with strong transport links and proximity to transport nodes where new sites can be developed to contribute to and enhance the existing offer. For instance, and as set out in the following section, Comberton is a sustainable settlement to facilitate appropriate levels of growth.
The Site represents an opportunity to locate sensitively designed and considered development on the edge of an existing settlement with good public transport connections, services and facilities.

Policy S/SH should not include an indicative maximum scheme size limit for Minor Rural Centres. Windfall sites should be assessed on the basis of their context and making efficient use of land.

Bellway objects to Draft Policy S/SH.
Comberton village is identified as a Minor Rural Centre, which is considered appropriate.
However, we object to the use of indicative maximum scheme sizes for each settlement typology (for example, 30 dwellings for Minor Rural Centres). Windfall development that comes forward within villages should be considered on the basis of the site and its context. Often small windfall sites (under the thresholds indicated from Group and Infill Villages) will provide limited or no affordable housing, exacerbating the situation for newly forming households who cannot meet their housing needs locally. Schemes should be encouraged to make an efficient and effective use of land whilst delivering housing development that is appropriate and helps in meeting the needs of the local community.

Policy S/GB should be comprehensively reviewed in the context of NPPF (2024) and the appropriate approach to Grey Belt.

Bellway objects to Draft Policy S/GB.
The Development Strategy Topic Paper (2025) states that GCSP consider the identified need for 73,300 jobs and 48,195 new homes across the plan period can be delivered without necessitating the allocation or release of Green Belt land within the authority area. However, given the largest change to Green Belt policy in several generations in the form of Grey Belt was introduced in the NPPF 2024, and fundamental changes regarding the Green Belt since the LUC Green Belt Assessment (2021) we now understand that a revised Green Belt Assessment will be completed and published after the Regulation 18 Consultation closes. It is argued the revised Green Belt Assessment should have informed the Draft Local Plan and been published as part of and the Regulation 18 Consultation. It is noted, 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’. Nonetheless a consideration of Grey Belt within the Local Plan is supported and needs to form one of the considered development scenarios in the Sustainability Appraisal.
As outlined above, we consider that GCSP are not planning for sufficient levels of growth and as such require additional allocations to meet a more aspirational level of growth for housing and jobs. In turn it is argued full weight cannot be given to the Green Belt and the possibility that the Council cannot meet its needs without Green Belt release must be considered. In such event in accordance with the sequential approach set out paragraph 148 of the NPPF the release of Grey Belt land will need to be prioritised for release. It is advised the potential for Grey Belt release needs to be considered via the Sustainability Appraisal that accompanies the Regulation 19 Consultation.
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.
We object to the omission of any reference to ‘Grey Belt’ within Draft Policy S/GB. The NPPF (2024) introduced a clear duty for Grey Belt land to be identified when undertaking Green Belt Assessments for the purposes of determining applications; reinforced within the Planning Practice Guidance (PPG) (Para 001 ref.001 64-001-20250225).
The direction of travel towards authorities being required to identify Grey Belt land within local plans is further evidenced within the forthcoming Consultation Draft NPPF (2025) (GB2[3]) and at Appendix E where the criteria for undertaking Green Belt Assessments is outlined. Hence, regardless of whether the Draft GCLP can meet the identified needs for growth without Green Belt release, the relevant Plan Policy (S/GB) should include explicit reference to Grey Belt (consistent with the NPPF) and the identification of Grey Belt land within Greater Cambridge. To ensure the longevity of the Local Plan, it is recommended the revised Green Belt Assessment is undertaken regarding Appendix E of the NPPF 2025.
Identifying Grey Belt land within the revised Green Belt Assessment and Draft Local Plan is hence both a policy requirement and crucial to ensuring the Local Plan promotes sustainable patterns of growth (as required by the NPPF) and is robust and flexible in providing a sufficient supply of suitable land in order to meet the growth potential of Greater Cambridge.
Overall, it is considered that Draft Policy S/GB is not consistent with national policy, does not reflect a positively prepared plan and is not justified. Pertinent to ensuring the Plan is sound will require:
• The publication of a revised Green Belt Assessment to support the Local Plan,
• A consideration of higher growth targets and subsequent review of the Green Belt / Grey Belt where necessary, and
• The identification and inclusion of the Cambridge Grey Belt within the Local Plan to guide development to sustainable Grey Belt sites.

The word “must” at CC/DC(1) ought to be replaced with the word “should”.

Bellway objects to Draft Policy CC/DC.
We support the intent of the Draft Policy, seeking high quality, sustainable and inclusive places in order to respond to the climate crisis. However, we object to the word “must” at CC/DC(1) as this creates a requirement leaving little to no discretion for decision makers. The word “should” would be more appropriate, setting out an expectation unless justified otherwise, which aids decision makers in reaching a balanced judgement. The requirements regarding these matters are addressed through the Building Regulations and planning policies should not duplicate this legislation.

Policy CC/NZ should not duplicate Building Regulations.

Bellway objects to Draft Policy CC/NZ.
The policy goes above and beyond existing sustainability benchmarks without proper consideration for impacts on viability and deliverability. This impact is considered within the Local Plan Viability Report (2025) which states construction requirements that exceed Part L 2021 of the Building Regulations will have a direct impact on construction costs.
Whilst we welcome the ambition to ensure that all buildings help to meet zero-carbon targets, there needs to be greater flexibility within the policy wording. There should also be clarity regarding what is required and what is aspirational.
With regard to CC/NZ(A), all new dwellings are expected to achieve a space heating demand of 15-20 kwH per metre squared per year. This figure is in line with Climate Change Committee, LETI Net Zero definition and Passivhaus standard, which are higher than other national standards and therefore placing unrealistic expectations on developers. With regard to CC/NZ(B), the EUI targets are split between uses. For residential dwellings, the targets are set at 35 kWh per metre squared per year which is aligned with LETI Net Zero definition and the National Grid Future Energy Scenarios. Again, the policy goes above and beyond national standards.
The requirements regarding these matters are most appropriately addressed through the Building Regulations and planning policies should not duplicate this legislation.

Policy CC/WE should use the word 'should' (rather than 'must') to allow discretion for decision makers. Any target for internal water use should be be applied consistently, rather than reflecting the size of site. 100 litres is more realistic than 80 litres.

Bellway objects to Draft Policy CC/WE.
Draft Policy CC/WE goes beyond national and industry guidance, mandating rainwater or greywater harvesting on all major developments, which will not always be appropriate or deliverable. National policy promotes proportionate, context-led approaches to water efficiency.
We question the use if the word “must” within the Policy as this creates a requirement leaving little to no discretion for decision makers. The word “should” would be more appropriate, setting out an expectation unless justified otherwise, which aids decision makers in reaching a balanced judgement.
With regard to potable water, the policy applies a stricter internal water-use requirement to developments of over 100 dwellings. While the aim of reducing water consumption is supported, it is unclear why development size alone justifies a higher standard. Internal water use is largely determined by occupant behaviour and individual dwelling specifications, rather than the overall scale of a development. Residents cannot reasonably be expected to use less water simply because they live in a larger scheme. The wording of the Policy should be amended to delete any reference to development size. A 100 litre per day target is more realistic for all developments.

Policy BG/BG should reflect the national mandated requirement for 10% BNG. Anything additional should be aspirational and considered to represent an additional benefit, above the requirement.

Bellway objects to Draft Policy BG/BG.
The national statutory requirement to deliver a minimum 10% Biodiversity Net Gain (BNG) already provides a robust, outcome-based mechanism for securing ecological enhancement. Draft Policy BG/BG seeks to uplift the mandatory minimum to 20% BNG for major development in Greater Cambridge. This is considered unsound, as it is not adequately justified and is inconsistent with national legislation and guidance.
The national BNG framework provides clarity and certainty for plan-making and decision-taking. Any local requirement exceeding the statutory minimum must therefore be clearly justified, flexible, and grounded in site-specific ecological capacity and viability. The approach set out is not supported by a robust evidence base and does not sufficiently demonstrate that it is proportionate or deliverable.
A drafted, Policy BG/BG risks undermining policy certainty by imposing a fixed uplift beyond the national framework without adequate justification. Any additional BNG delivered above the mandatory 10% requirement should be treated as a material benefit in the planning balance, rather than being expected a mandatory policy requirement.