Draft Greater Cambridge Local Plan for consultation

A higher number of new homes is necessary to meet the needs of the existing population and support future economic growth, aligning with the Strategic Priority in the Draft GCLP.

Draft Policy S/JH sets out the level of objectively assessed needs in Greater Cambridge over the period 2024-2045 for jobs and homes. It states that 73,300 additional jobs and a minimum of 48,195 new homes are required to meet the needs for the total population.
The provision of 73,300 additional jobs and 48,195 new homes across the plan period should be regarded as the very minimum rather than a maximum or constraining target. Supporting evidence to the policy titled the ‘Greater Cambridge Employment and Housing Needs Update 2024-2045’ (September 2025) (EHN), states at 3.55 that the various scenarios modelled indicate a need of 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.
As set out in the EHN, during the strongest phase of growth (2010–2020), the Greater Cambridge economy expanded by almost 4,000 jobs per year. The conclusion of the EHN is then based on the ‘Central growth’ scenario of 73,200 jobs across the plan period, representing sustained annual growth of around 3,500 jobs. Crucially, the Central growth scenario builds in assumptions of slower periods, contractions, and economic shocks, and is therefore inherently conservative rather than reflective of the full growth capacity of the Cambridge economy.
The Employment and Housing Needs Update 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.
For these reasons, the Local Plan should consider utilising a more optimistic and realistic figure 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.
It is requested that the Plan allocates additional sites in Greater Cambridge to directly respond to the higher growth potential and to increase the diversity of allocated sites to optimise delivery and growth potential. E W Pepper’s Sites in the villages of Guilden Morden, Steeple Morden, Arrington and Kneesworth are available and can assist in delivering new housing development in a sustainable way.
A higher number of new homes is required to ensure that the Local Plan meets the needs of the existing population of the Greater Cambridge area, in addition to supporting economic growth (new jobs) during the period 2024-2045. This is needed to support the housing needs of existing communities across the wider area, in addition to supporting future economic growth. This aligns with the Strategic Priority set out in the Draft GCLP (page 25, emphasis added), to:
“Plan for enough housing to meet our need, including significant quantities of housing that is affordable to rent and buy, and different kinds of homes to suit our diverse communities.”

Significantly more housing land should be allocated.
More small and medium size housing sites allocated in the Rural Area.
Housing in the Rural Area should be located in sustainable village locations where it will enhance and maintain the vitality of rural communities.

We object to the proposed development strategy set out in Policy S/DS.
Fundamentally, planning for only 10,330 homes through new allocations between 2024 and 2045 is insufficient. Significantly more housing land should be allocated to ensure a plan-led approach to the sustainable growth of Greater Cambridge.
Secondly, the proposed development strategy is focused on a few strategic sites for new housing development, particularly in the Rural Area. There are very few small and medium size housing sites allocated in the Rural Area.
Thirdly, the policy approach does not promote sustainable development in rural areas by locating housing where it will enhance or maintain the vitality of rural communities, as required by the NPPF.
Fundamentally, planning for only 10,330 homes through new allocations between 2024 and 2045 is inadequate to support the sustainable growth and development of Greater Cambridge. Significantly more housing sites should be allocated, in accordance with paragraph 72 of the National Planning Policy Framework (NPPF) which states that planning policies should identify a sufficient supply and mix of sites, taking into account their availability, suitability and likely economic viability.
Secondly, the proposed development strategy is focused on a few large, strategic-scale sites for new housing development. There are very few small and medium size housing sites among the draft allocations, particularly in the Rural Area. We consider that there is an over-reliance on too few strategic sites, particularly those that require significant, costly infrastructure to unlock and deliver them. Indeed, it is considered that Policy S/DS sets out such a strategy and relies too heavily on allocating significant levels of growth on just a small number of very large sites. A number of these large sites rely on the timely provision of strategic scale infrastructure which must be in place before they can be constructed. For example, the Cambourne North new settlement (13,000 dwellings and 108,000 sqm employment floorspace) relies upon a new railway station and complicated works to the A428, and Land adjacent to A11 and A1307 at Grange Farm (6,000 dwellings and 35,000 sqm employment floorspace) relying on works to the A505. The draft Plan requires the two sites to deliver 5,100 dwellings between them by 2045. We believe this is highly unlikely.
The Councils’ approach to small sites is set out in supporting text paragraphs 2.43-45, which states that approximately 3.5% of the 48,195-dwelling housing requirement are on specific, identified small sites (up to one hectare). This compares with the national policy set out at NPPF (2024) Paragraph 73, which requires at least 10% of the housing requirement to be on sites of up to 1ha:
“Small and medium sized sites can make an important contribution to meeting the housing requirement of an area, are essential for Small and Medium Enterprise housebuilders to deliver new homes, and are often built-out relatively quickly. To promote the development of a good mix of sites local planning authorities should:
a) identify, through the development plan and brownfield registers, land to accommodate at least 10% of their housing requirement on sites no larger than one hectare; unless it can be shown, through the preparation of relevant plan policies, that there are strong reasons why this 10% target cannot be achieved;
b) seek opportunities, through policies and decisions, to support small sites to come forward for community-led development for housing and self-build and custom build housing…”
In accordance with the requirements of the NPPF (2024), the Council cannot rely on assumed levels of windfall delivery on small sites to meet the 10% small sites expectation. These sites must be identified either via allocations or on the brownfield register.
Additionally, the Consultation Draft NPPF (December 2025) sets out a proposed new policy approach regarding medium size sites. Whilst we acknowledge that this is currently in draft, Policy HO6(1a) states that,
“to support a diverse mix of sites, local plans should allocate land to accommodate at least 10% of the housing requirement on sites no larger than one hectare, and a further 10% on sites between one and two and half hectares unless there are strong reasons why these targets cannot be achieved’
Set within this policy and emerging policy context, we do not consider that the Councils’ approach to small and medium sites is appropriate, and hence the development strategy is not sound. Our view is that the GCLP should be identifying a minimum of 10% small sites plus a minimum of 10% medium sites.
In terms of the spatial distribution of housing development across the Greater Cambridge area, the Councils acknowledge that the Rural Area has a decreasing share of development. From almost one-third of dwellings under the Structure Plan, the proportion in the Rural Area would drop to one-sixth under the approach in the Draft GCLP. This is acknowledged in the supporting text at paragraphs 2.75-2.78 of the Draft GCLP and is illustrated clearly in Figure 12.
The Rural Area of Greater Cambridge is extensive, including around 100 villages and making up the substantial part of South Cambridgeshire District. In this context, we are of the view that there is insufficient growth allocated to the Rural Areas as required by NPPF (2024) Paragraph 83:
“To promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities. Planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services. Where there are groups of smaller settlements, development in one village may support services in a village nearby.”
NPPF Paragraph 83 makes clear that policy makers have an obligation to allocate sites in villages for planned growth and development. By comparison, the policy approach set out in the Draft GCLP depends almost exclusively on village growth via windfall development. Hence, there is the allowance under Draft Policy S/SH (Settlement hierarchy) that allows for certain sizes of scheme, based on a threshold relating to the status of the settlement in the hierarchy. In many villages, however, there is a lack of available brownfield land within the ‘defined development extents’ to facilitate housing delivery via this windfall approach. Additionally, small windfall sites typically provide limited affordable housing to meet local needs.
The proposed development strategy would form a constraint on the sustainable development of many village settlements and their rural communities. In particular, the lack of housing allocations in the smaller villages fails to support the delivery of homes to meet the local housing needs of the next generation during the plan period. Instead of being able to live locally, this forces newly forming households to relocate to the main settlements, new settlements, or elsewhere – often away from their existing family, community and support network. This leads to an increased need for travel within Greater Cambridge, often via private cars rather than public transport. It also results in population imbalance, with ageing populations in villages and a falling roll in primary schools – whilst the new settlements have predominantly young populations and significant pressure on services.
A more balanced approach is required in respect to the Rural Area, including a wider range of housing sites being allocated – in terms of both site sizes and locations. This is necessary to ensure that the Local Plan supports sustainable communities and sustainable patterns of growth. In addition to providing housing to support new jobs in Cambridge and the key employment growth sectors, the development strategy should take account of the needs and vitality of existing villages; make planned provision for them; and support the rural economy.
The GCLP should identify site allocations for housing development in a wider range of the South Cambridgeshire’s rural villages, to promote genuinely sustainable growth and development – supporting the rural economy, promoting mixed and inclusive communities and ensuring their vitality and the viability of local services.
Fundamentally, planning for only 10,330 homes through new allocations between 2024 and 2045 is inadequate to support the sustainable growth and development of Greater Cambridge. Significantly more housing sites should be allocated, in accordance with paragraph 72 of the National Planning Policy Framework (NPPF) which states that planning policies should identify a sufficient supply and mix of sites, taking into account their availability, suitability and likely economic viability.
Secondly, the proposed development strategy is focused on a few large, strategic-scale sites for new housing development. There are very few small and medium size housing sites among the draft allocations, particularly in the Rural Area. We consider that there is an over-reliance on too few strategic sites, particularly those that require significant, costly infrastructure to unlock and deliver them. Indeed, it is considered that Policy S/DS sets out such a strategy and relies too heavily on allocating significant levels of growth on just a small number of very large sites. A number of these large sites rely on the timely provision of strategic scale infrastructure which must be in place before they can be constructed. For example, the Cambourne North new settlement (13,000 dwellings and 108,000 sqm employment floorspace) relies upon a new railway station and complicated works to the A428, and Land adjacent to A11 and A1307 at Grange Farm (6,000 dwellings and 35,000 sqm employment floorspace) relying on works to the A505. The draft Plan requires the two sites to deliver 5,100 dwellings between them by 2045. We believe this is highly unlikely.
The Councils’ approach to small sites is set out in supporting text paragraphs 2.43-45, which states that approximately 3.5% of the 48,195-dwelling housing requirement are on specific, identified small sites (up to one hectare). This compares with the national policy set out at NPPF (2024) Paragraph 73, which requires at least 10% of the housing requirement to be on sites of up to 1ha:
“Small and medium sized sites can make an important contribution to meeting the housing requirement of an area, are essential for Small and Medium Enterprise housebuilders to deliver new homes, and are often built-out relatively quickly. To promote the development of a good mix of sites local planning authorities should:
a) identify, through the development plan and brownfield registers, land to accommodate at least 10% of their housing requirement on sites no larger than one hectare; unless it can be shown, through the preparation of relevant plan policies, that there are strong reasons why this 10% target cannot be achieved;
b) seek opportunities, through policies and decisions, to support small sites to come forward for community-led development for housing and self-build and custom build housing…”
In accordance with the requirements of the NPPF (2024), the Council cannot rely on assumed levels of windfall delivery on small sites to meet the 10% small sites expectation. These sites must be identified either via allocations or on the brownfield register.
Additionally, the Consultation Draft NPPF (December 2025) sets out a proposed new policy approach regarding medium size sites. Whilst we acknowledge that this is currently in draft, Policy HO6(1a) states that,
“to support a diverse mix of sites, local plans should allocate land to accommodate at least 10% of the housing requirement on sites no larger than one hectare, and a further 10% on sites between one and two and half hectares unless there are strong reasons why these targets cannot be achieved’
Set within this policy and emerging policy context, we do not consider that the Councils’ approach to small and medium sites is appropriate, and hence the development strategy is not sound. Our view is that the GCLP should be identifying a minimum of 10% small sites plus a minimum of 10% medium sites.
In terms of the spatial distribution of housing development across the Greater Cambridge area, the Councils acknowledge that the Rural Area has a decreasing share of development. From almost one-third of dwellings under the Structure Plan, the proportion in the Rural Area would drop to one-sixth under the approach in the Draft GCLP. This is acknowledged in the supporting text at paragraphs 2.75-2.78 of the Draft GCLP and is illustrated clearly in Figure 12.

The Rural Area of Greater Cambridge is extensive, including around 100 villages and making up the substantial part of South Cambridgeshire District. In this context, we are of the view that there is insufficient growth allocated to the Rural Areas as required by NPPF (2024) Paragraph 83:
“To promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities. Planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services. Where there are groups of smaller settlements, development in one village may support services in a village nearby.”
NPPF Paragraph 83 makes clear that policy makers have an obligation to allocate sites in villages for planned growth and development. By comparison, the policy approach set out in the Draft GCLP depends almost exclusively on village growth via windfall development. Hence, there is the allowance under Draft Policy S/SH (Settlement hierarchy) that allows for certain sizes of scheme, based on a threshold relating to the status of the settlement in the hierarchy. In many villages, however, there is a lack of available brownfield land within the ‘defined development extents’ to facilitate housing delivery via this windfall approach. Additionally, small windfall sites typically provide limited affordable housing to meet local needs.
The proposed development strategy would form a constraint on the sustainable development of many village settlements and their rural communities. In particular, the lack of housing allocations in the smaller villages fails to support the delivery of homes to meet the local housing needs of the next generation during the plan period. Instead of being able to live locally, this forces newly forming households to relocate to the main settlements, new settlements, or elsewhere – often away from their existing family, community and support network. This leads to an increased need for travel within Greater Cambridge, often via private cars rather than public transport. It also results in population imbalance, with ageing populations in villages and a falling roll in primary schools – whilst the new settlements have predominantly young populations and significant pressure on services.
A more balanced approach is required in respect to the Rural Area, including a wider range of housing sites being allocated – in terms of both site sizes and locations. This is necessary to ensure that the Local Plan supports sustainable communities and sustainable patterns of growth. In addition to providing housing to support new jobs in Cambridge and the key employment growth sectors, the development strategy should take account of the needs and vitality of existing villages; make planned provision for them; and support the rural economy.
The GCLP should identify site allocations for housing development in a wider range of the South Cambridgeshire’s rural villages, to promote genuinely sustainable growth and development – supporting the rural economy, promoting mixed and inclusive communities and ensuring their vitality and the viability of local services.

Indicative maximum scheme sizes for Group and Infill Villages should be removed from the Policy.

E W Pepper objects to Draft Policy S/SH.
Specifically, we do not consider that the indicative maximum scheme sizes are necessary for the Group and Infill Villages. Windfall development that comes forward within these villages should be considered on the basis of the site and its context. 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. 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.

On the Policies Map, the defined development extent at the following villages should be amended to include the following new site allocations within the settlement envelopes:

Guilden Morden – HELAA Refs. 40300 (Land south of Church Street, east of High Street) and 40304 (Land off Swan Lane) and 40315 (Land at Town Farm)

Steeple Morden – HELAA Ref. 40294 (Land to the west of Brook End)

Arrington – HELAA Ref. 40292 (Land to the southwest of Ermine Way)

Kneesworth – HELAA Ref. 40299 (Land to the east of Old North Road)

E W Pepper objects to Draft Policy S/DE.
The current settlement envelopes for many of the villages are so tightly drawn around the existing built-form that there is little room for villages to grow and thrive. Greater consideration needs to be given in identifying suitable land within and adjacent the village boundaries to accommodate sustainable growth, especially in non-Green Belt locations. New development which could enhance the sustainability of the community, through the provision of additional footfall and potential for new community facilities, amenities, transport improvements to be delivered alongside housing to provide a betterment to the wider community, would contribute to a sound and sustainable spatial strategy for the new Local Plan.

The following sites should be allocated for housing development, in the following settlements:

Guilden Morden – HELAA Refs. 40300 (Land south of Church Street, east of High Street) and 40304 (Land off Swan Lane), which have been submitted for consideration as a consolidated proposal.

Guilden Morden – HELAA Ref. 40315 (Land at Town Farm)

Steeple Morden – HELAA Ref. 40294 (Land to the west of Brook End)

Arrington – HELAA Ref. 40292 (Land to the southwest of Ermine Way)

Kneesworth – HELAA Ref. 40299 (Land to the east of Old North Road)

E W Pepper objects to Draft Policy S/RRA on the basis that there are insufficient site allocations in the Rest of the Rural Area. The following sites should be allocated for housing development, in the following settlements:

Guilden Morden – HELAA Refs. 40300 (Land south of Church Street, east of High Street) and 40304 (Land off Swan Lane)

Guilden Morden – HELAA Ref. 40315 (Land at Town Farm)

Steeple Morden – HELAA Ref. 40294 (Land to the west of Brook End)

Arrington – HELAA Ref. 40292 (Land to the southwest of Ermine Way)

Kneesworth – HELAA Ref. 40299 (Land to the east of Old North Road)

We request the addition of the words “where appropriate” when listing the range of issues to address in sustainability statements, to provide the flexibility intended here.

We support the intent of Draft Policy CC/SD. We support CC/SD(2) which applies a proportionate approach to sustainability statements.
However, we request the addition of the words “where appropriate” when listing the range of issues to address in sustainability statements, to provide the flexibility intended here.

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

We support the intent of Draft Policy CC/DC.
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.

There needs to be greater flexibility within the policy wording.

We object to Draft Policy CC/NZ.
The Draft Policy goes beyond existing sustainability standards for planning, without consideration for impacts on viability and deliverability.
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.

The word “must” within the Policy ought to be replaced by “should”. The internal water-use requirement should be revised or removed from the Policy.

We object to the proposed wording of 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. As drafted, the Policy risks being arbitrary and may fail the tests of justification and effectiveness. It should either apply a consistent, evidence-based standard across all residential development or provide clear evidence explaining why a higher requirement is appropriate only for larger schemes.

The BNG target should reflect the mandatory requirement of 10%. Anything additional should be expressed as aspirational.

We object to 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.