Draft Greater Cambridge Local Plan for consultation

Identify site ref. 115443 as Grey Belt and allocate for residential development.

See attached representations

These representations have been prepared by Bidwells on behalf of Christ’s College, Cambridge in
response to the Greater Cambridge Local Plan Regulation 18 Consultation (2026). These
representations relate to land at Oakington Road, Cottenham (hereafter “the Site”) which is within
Christ’s College ownership.
The Site was originally submitted in the Call for Sites exercise held in 2019 with subsequent
representations submitted pursuant to the Regulation Issues and Options Consultation (2020) and the
Regulation 19 Preferred Options Consultation (2021) and through the Council’s Housing and Economic
Land Availability Assessment (HELAA) was given the site reference 115443. The Site was referenced as
CH10 within the Greater Cambridge Green Belt Assessment (2021). Documents submitted in support of
previous submissions were:
• Vision Document (Bidwells UDS);
• Drainage Assessment (EAS);
• Highway Appraisal (EAS);
• Heritage Appraisal (Bidwells Heritage);
• Ecology Appraisal (Ecology Solutions).
The earlier submissions outlined above made by Christ’s College in support of the site remain up to date
and relevant. Further the suite of technical documents set out above have demonstrated the Site has
been appropriately assessed and collectively demonstrate a deliverable site. This representation adds to
the suite of submission material previously submitted which demonstrates the Site as deliverable and
free from any overriding technical considerations and accounts for changes to the context of the Site, the
emerging Greater Cambridge Local Plan and updated to national policy, notably the National Planning
Policy Framework.
Benefits
Allocation and in turn development of the Site would bring numerous social, economic and environmental
benefits including:
• Effective use of sustainable Grey Belt land;
• The opportunity to deliver a substantial amount of affordable housing to address the acute need
for affordable housing within Cottenham and Greater Cambridge;
• Locating residential development within one of the largest and most sustainable villages within
South Cambridgeshire;
Opportunity to enhance the biodiversity of the site retaining existing hedgerow and increasing the
natural capital of the Site;
• Support existing facilities, services and business ensuring the continued and enhanced vitality of
Cottenham;
• Delivering development on Grey Belt land providing a natural extension to the existing settlement
and will sit in a context defined by residential development on Oakington Road, Rampton Road
and Elis Close and Histon Road, representing an organic extension to the existing urban grain.
The Site is highly sustainable and remains suitable, available and achievable for residential development
to meet the growing housing needs of Cottenham and Greater Cambridge and represents a suitable,
sustainable and deliverable Grey Belt site which should be prioritised for allocation Council require to
provide a more diverse spatial strategy and/or properly meet the higher growth potential of the area.
Development would represent a logical extension to the existing settlement and round off the boundary
of Cottenham appropriately. Regardless it is noted the Site should be clearly identified as Grey Belt
within the Local Plan.

As per attached letter, consider the need to plan for a greater level growth and consider additional allocations to meet this need.

Bidwells raise concern over 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. 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” (September 2025)
(hereafter the “EHNU”) prepared by Iceni Projects. The Report concludes at paragraph 3.55 that various
scenarios modelled indicate a need between 67,600 – 90,900 additional jobs between across the plan
period. This compares to between 66,600 – 75,800 additional jobs modelled under the previous 2023
results. This significant increase in the upper end of the modelling that economic growth expectations
have strengthened exponentially, not diminished.
Rightly the EHNU draws a relationship between job growth 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.
‘Supercharged growth’ in Cambridge remains a priority for the incumbent Labour 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. On
23rd August 2024 Matthew Pennycook reaffirmed the Government’s commitment to Cambridge stating:
“The economic growth of Cambridge has been a phenomenal success and we should seek to maximise
the potential contribution that Greater Cambridge could make to the UK economy.” Pennycook goes on
to say; “Greater Cambridge has a vital role to play in this Government’s mission to kickstart economic
growth”. Pennycook’s commitment to Cambridge was further reinforced on 23rd 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 Easter 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 own 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.
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 is 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.
It is requested that GCSP 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. Land at Oakington Road, Cottenham can soundly assist in realising a greater and more
appropriate level of growth in a sustainable way.

As per attached letter, consider additional allocations in sustainable rural areas

We object to the Development Strategy set out within Policy S/DS. Fundamentally planning for only
10,330 homes through new allocations between 2024 – 2045 is insufficient. Significantly more land for
housing should be allocated to ensure a plan led approach to the sustainable growth of Cambridge.
The proposed Development Strategy is focused on a few large strategic sites to accommodate new
housing development. Bidwells consider this problematic given such sites will rely on the timely delivery
of major infrastructure to be in place before these sites can be delivered. Further, a review of historic
Annual Monitoring Reports (AMRs) indicates the speed at which these sites can deliver housing is often
far slower than the Council typically envision. A Housing Delivery Report prepared by Bidwells
interrogates recent delivery of housing at 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 take longer to deliver their first dwelling than
the Council originally anticipated, often a lot later;
• Once homes are delivered more often than not homes are delivered at a slower rate than the
Council had anticipated;
• Some sites have been in the pipeline for many years with no certainty yet on when applications
and delivery will actually commence, notably North East Cambridge and Cambridge East
following Marshall’s cancelled move to Cranfield Airport.
Overall, the appended Report identifies by virtue of the complex nature of strategic sites their delivery is
often significantly delayed when compared to the Council’s anticipated trajectory for these sites.
It is therefore considered further over reliance on large scale sites threatens the deliverability of the Local
Plan, particularly in the early years of the Plan, should these sites (notably Cambourne North and
Grange Farm) face delays in delivery as anticipated given the above commentary. As such the Council
must allocate additional smaller sites which face shorter lead-in times and will kickstart the delivery of
housing in the early years of the plan period whilst strategic sites progress with the delivery of relevant
infrastructure to support their delivery later in the plan period.
The near absence of allocating smaller (non-strategic) sites in the Rural Area risks imposing a constraint
on the sustainable development of many settlements and their communities. In particular, the lack of
housing allocations in the 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 wide range of housing
sites to be allocated – in terms of size and location. 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 and the wider rural economy and make
planned provision for them.
In many villages, there is a lack of brownfield land available within the ‘defined development
extents’ to facilitate housing delivery in accordance with the approach set out in Draft Policy S/SH
(Settlement hierarchy). Also, small windfall sites provide limited affordable housing to meet local needs.
Hence, there should be specific land allocations for housing development in some of the rural villages, to promote genuinely sustainable growth and development – supporting the rural economy, promoting
mixed and inclusive communities and ensuring the vitality and viability of local services.
Bidwells advocate that sites, such as the Oakington Road, Cottenham, must be allocated to meet the
acute need for additional housing within villages in Greater Cambridge. In doing so would ensure the
Local Plan is positively prepared, justified and consistent with national policy.

Remove the development limit on Minor Rural Centres to adopt a case by case basis

We object to Draft Policy S/SH in respect to the development limit placed on Minor Rural Centres
whereby development of up to 30 dwellings will be permitted. We do not consider that the
indicative maximum scheme sizes are necessary for Minor Rural Centres, such as Cottenham.
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 Minor Rural Centres, Group
and Infill Villages) will provide limited or no affordable housing, exacerbating the situation for newly
forming households who cannot more fully meet their housing needs locally.

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
The identification and inclusion of the Cambridge Grey Belt within the Local Plan to guide
development to sustainable Grey Belt sites.

The Development Strategy Topic Paper (2025) states 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, though given the fundamental changes to national
policy and guidance 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 the Regulation 18 Consultation
It is considered the identified needs outlined above are too conservative and do not reflect the growth
agenda in national, regional and local contexts mandated by the incumbent Labour government. In line
with the Written Ministerial Statement made by Matthew Pennycook (Minister of State for Housing and
Planning) on 23 October 2025 the ambition remains to ‘supercharge growth’ within the Oxford-
Cambridge Corridor and realise the full potential of Greater Cambridge. Further it is anticipated that
Cambridge Growth Company (CGC) will publish its own evidence base ahead of the formation of a
centrally-led Development Corporation (backed by £400m funding announced in October 2025), which
whilst yet unknown it is expected an ambitious growth target will be identified; likely to exceed that
currently envisioned by GCSP. Collectively it remains apparent the government have a continued
agenda to deliver high levels of growth within Greater Cambridge and as such it is considered that GCSP
will need to plan for a greater level of growth as the Local Plan progresses.
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. Whilst GCSP, drawing on their current evidence base, do not
consider that their development needs alone provide the exceptional circumstances required to justify
removing land from the Green Belt, the further evidence referred to above may well change the context
within which the Councils need to consider the Plan and the potential release of Green Belt land.
The omission of any reference to ‘Grey Belt’ within the Draft Policy S/GB is challenged. 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 Local Plan 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 with regard to Appendix E of the NPPF 2025.
Further, 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).
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 ‘supercharged growth’ mandated for the Greater Cambridge by Government.
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
• The identification and inclusion of the Cambridge Grey Belt within the Local Plan to guide
development to sustainable Grey Belt sites.
The Council must take a positive approach to the preparation of the Plan. Its failure to engage properly
with the Green Belt has not led the plan to an effective spatial strategy. There is a superior sustainable
plan to be formed by properly considering Green Belt (Grey Belt) sites that can better underpin
sustainable development.
The Council needs to properly consider the inclusion of well-performing sites in the Grey Belt. For
example, the land South of Oakington Road, Cottenham (ref: 115443) Site was assessed within the
Council’s Green Belt Assessment (2021) which supported First Proposals (2021) Draft Local Plan (parcel
CH10). The Site is the only parcel of Green Belt land bordering Cottenham where the harm of release is
assessed as ‘low’ when assessed against the three purposes of the Cambridge Green Belt. The Council
need to release additional Green Belt sites in line with the hierarchy set out in paragraph 148 of the
NPPF (2024) to lead to a sustainable spatial strategy.