Draft Greater Cambridge Local Plan for consultation

This letter and the accompanying schedule of comments represents the written response of the Cambridge Growth Company to the Regulation 18 consultation for the Draft Greater Cambridge Local Plan. This covering letter sets out CGC’s overall summary with specific comments on policy and site allocations set out in the accompanying schedule.
In summary, CGC supports the growth ambition and strategic direction of the Draft Greater Cambridge Local Plan. The Plan’s positive approach to growth, innovation, and long‑term sustainability is welcomed. The recognition of the requirement for additional growth in employment and housing to meet assessed need is supported as is the overall Development Strategy proposed to deliver this growth within the Plan period. The inclusion of additional headroom in both jobs and housing projections is a welcome acknowledgement of Greater Cambridge’s growth potential and aligns with CGC’s own objectives and activity as it continues to develop its evidence base for longer term strategic growth in the area.
Economy
The Plan’s commitment to accommodating employment growth and supporting the clustered nature of the Cambridge innovation economy is supported. CGC acknowledges that the draft Plan’s employment growth projections are based on a ‘central scenario’ and are reflective of identified constraints. However, we would like the draft Plan to be clear that subject to resolution of those constraints, employment growth exceeding the Local Plan central scenario could be delivered within the Plan period and that policy wording should include sufficient flexibility to accommodate higher and accelerated levels of growth prior to 2045.
CGC would like to see the Plan more explicitly recognise the value of intensifying and expanding the identified innovation clusters to fully realise growth potential and agglomeration benefits. Enabling an intensification/densification of cluster sites should where appropriate incorporate an element of housing, including innovative housing typologies, to help support their function.
CGC also welcomes the draft Plan’s support for a diverse range of commercial space to accommodate different stages of business and employment growth.
CGC also supports the draft Plan’s approach to meanwhile uses, circular economy principles and low‑carbon development.
Housing
The Plan’s focus on delivering a diverse mix of housing types and tenures, including affordable housing, is supported as is recognition of models such as build‑to‑rent, Community Land Trusts, co‑living and employer‑led housing. Achieving a greater diversity of housing than historically delivered by the market should be a clear objective of the Plan and as appropriate made explicit for site allocations.
As per our comments above regarding employment growth, CGC would encourage a degree of flexibility within both policy and allocations to allow for housing growth beyond the levels currently identified in the draft Plan and encourage the acceleration of delivery where the identified infrastructure constraints on growth can be alleviated. This would be responsive to changing market conditions and the implementation of measures to alleviate infrastructure constraints that both CGC, GCSP and CPCA is jointly developing and which should be included in the Regulation 19 draft Local Plan.
Infrastructure
The infrastructure‑first, vision‑led approach to transport is supported, given transport constraints remain one of the key limitations on growth. CGC welcomes the transport and other infrastructure identified in the Plan to support growth. CGC’s work in developing longer term growth scenarios is as you know, wholly dependent on identifying the new and enhanced infrastructure necessary to support ambitious growth. It is acknowledged that the Greater Cambridge Transport Strategy will inform later stages of the Plan and CGC is committed to support its production, where able, in time to meet the timetable for Local Plan submission for examination. CGC supports development near well connected existing and planned train stations in Cambridge, and supports the Plan’s ambitions to that these locations deliver a mix of land uses at higher development density.
CGC supports the draft Plan’s strengthening of the nature network and approach to biodiversity gains and accessible green infrastructure.
Design Quality
CGC strongly supports optimising density in the sustainable, well‑connected allocations in the draft Plan. Where there are planned transport enhancements, such as CSET or those identified as part of East West Rail, CGC would welcome the opportunity to work jointly with GCSP to develop frameworks or similar which would support higher density development being delivered on allocated sites which benefit from high quality transport connections. Given the careful balance which underpins the Development Strategy in the Plan, it is only right, in CGC’s view, that sites allocated for growth really do optimise their development potential. High quality densification is considered to be an essential element of the draft Local Plan delivery strategy.
CGC supports the commitment to high-quality, well-designed places and buildings as set out in relevant placemaking polices in the draft Plan. Well-designed and well-built places are essential components of the good growth which CGC supports.
Green Belt
The confirmation of green belt release for strategic site allocations is welcomed, but CGC considers that it would be beneficial to further review whether grey belt opportunities in sustainable locations may provide opportunities for additional site allocations which could accommodate future growth.

Yours sincerely
Anthony Hollingsworth
Director of Planning & Place

The plan provides for an additional 73,300 jobs over 21 years, a growth rate of 1.3% pa. This is the central scenario considered by Iceni in their evidence base, compared with a high scenario of 1.6% pa. This high scenario is lower than historic growth rates of 1.8% between 2010 and 2023 and 2.1% between 2010 and 2020.
The 73K additional jobs is consistent with the additional jobs supported by the standard method of assessing housing need, based on population growth and affordability uplift, adding in workers who commute into Greater Cambridge. However, the analysis uses 2011 levels of in-commuting, the most recent comprehensive data, so it is very likely to be undercounting current levels of in-commuting and therefore undercounting the jobs that would be supported by the standard method. However, it is acknowledged that there are no more up to date published data sources to evidence.
The supporting Iceni Employment and Housing Needs Update acknowledges that the high growth scenario could be achieved or exceeded.
For this to take place a step change in infrastructure investment and development would be needed to facilitate growth, notably in transport to connect in and move labour, as well as in wider services infrastructure and the expansion of both housing and commercial development programmes.

Assuming infrastructure constraints can be addressed employment and housing growth exceeding the Local Plan growth scenario could be delivered within the Plan period. It is recommended that the policy wording should acknowledge this and include sufficient flexibility to accommodate higher levels of growth prior to 2045/beyond the Local Plan High Growth assumptions.

The plan provides for a minimum of 48,195 new homes over 21 years, 2,295 homes pa. This is 37% higher than the existing plan target of 1,675 homes pa and 29% higher than the 10 year average (to 2024) of 1,781 homes pa.

This historic rate is relatively high in a national context - the housing stock of Greater Cambridge grew by an average of 1.5% per annum over the 10 years between March 2014 and 2024, compared with 0.9% across England over the same period. However, it has not kept pace with employment growth of more than 2.0% pa over 10 years, leading to more in-commuting and additional pressure on transport and other infrastructure


In order to enable the Plan to be responsive to changing market conditions and planned or new measures to alleviate infrastructure constraints it is suggested that the policy wording allows for housing growth beyond the Local Plan High Growth trajectory.

Current pipeline supply of 37,865 homes including adopted allocations, sites with planning permission or resolution to grant planning, and windfall allowance, 10,330 additional homes from new allocations will be provided. 3,133 (6.5%) additional homes above the identified housing need have been identified. CGC is supportive of the Development Strategy identified in the draft Plan but recommends that the planned allocations and the housing and employment growth identified in each, are treated as the minimum requirements and that the allocations are flexible enough to allow for optimised levels of growth. Identification of options for future expansion and extensions of these allocations where these can be supported in transport, landscape, and in green and other infrastructure terms is supported by CGC.

CGC supports this policy and the allocation for expansion through release of land from the Green Belt for future phases to support the future development of the Biomedical Campus. It is also supportive of the recognition of the campus as being a globally significant centre for healthcare, research and innovation. The strategic importance of CBC has been stated in the Written Ministerial Statement 8th May 2024, including support for the accelerated delivery of any associated housing development and the provision of appropriate levels of affordable housing to meet the housing needs of those working at the campus.


CGC recommends that further consideration is given to the boundary of this allocation in relation to the proposed access. The access as shown on the Spatial Framework plan figure 63 appears not to be deliverable due to the consented scheme to the north of Babraham Road. Therefore an alternative redline for the proposal allocation should be considered to allow for alternative access arrangements.

This policy is supported by CGC but it recommends that the overall approach to BTR should be strengthened in relation to allocations for strategic sites and in relation to promoting BTR in accessible locations and close to key employment centres such as CBC.

This letter and the accompanying schedule of comments represents the written response of the Cambridge Growth Company to the Regulation 18 consultation for the Draft Greater Cambridge Local Plan. This covering letter sets out CGC’s overall summary with specific comments on policy and site allocations set out in the accompanying schedule.
In summary, CGC supports the growth ambition and strategic direction of the Draft Greater Cambridge Local Plan. The Plan’s positive approach to growth, innovation, and long‑term sustainability is welcomed. The recognition of the requirement for additional growth in employment and housing to meet assessed need is supported as is the overall Development Strategy proposed to deliver this growth within the Plan period. The inclusion of additional headroom in both jobs and housing projections is a welcome acknowledgement of Greater Cambridge’s growth potential and aligns with CGC’s own objectives and activity as it continues to develop its evidence base for longer term strategic growth in the area.
Economy
The Plan’s commitment to accommodating employment growth and supporting the clustered nature of the Cambridge innovation economy is supported. CGC acknowledges that the draft Plan’s employment growth projections are based on a ‘central scenario’ and are reflective of identified constraints. However, we would like the draft Plan to be clear that subject to resolution of those constraints, employment growth exceeding the Local Plan central scenario could be delivered within the Plan period and that policy wording should include sufficient flexibility to accommodate higher and accelerated levels of growth prior to 2045.
CGC would like to see the Plan more explicitly recognise the value of intensifying and expanding the identified innovation clusters to fully realise growth potential and agglomeration benefits. Enabling an intensification/densification of cluster sites should where appropriate incorporate an element of housing, including innovative housing typologies, to help support their function.
CGC also welcomes the draft Plan’s support for a diverse range of commercial space to accommodate different stages of business and employment growth.
CGC also supports the draft Plan’s approach to meanwhile uses, circular economy principles and low‑carbon development.
Housing
The Plan’s focus on delivering a diverse mix of housing types and tenures, including affordable housing, is supported as is recognition of models such as build‑to‑rent, Community Land Trusts, co‑living and employer‑led housing. Achieving a greater diversity of housing than historically delivered by the market should be a clear objective of the Plan and as appropriate made explicit for site allocations.
As per our comments above regarding employment growth, CGC would encourage a degree of flexibility within both policy and allocations to allow for housing growth beyond the levels currently identified in the draft Plan and encourage the acceleration of delivery where the identified infrastructure constraints on growth can be alleviated. This would be responsive to changing market conditions and the implementation of measures to alleviate infrastructure constraints that both CGC, GCSP and CPCA is jointly developing and which should be included in the Regulation 19 draft Local Plan.
Infrastructure
The infrastructure‑first, vision‑led approach to transport is supported, given transport constraints remain one of the key limitations on growth. CGC welcomes the transport and other infrastructure identified in the Plan to support growth. CGC’s work in developing longer term growth scenarios is as you know, wholly dependent on identifying the new and enhanced infrastructure necessary to support ambitious growth. It is acknowledged that the Greater Cambridge Transport Strategy will inform later stages of the Plan and CGC is committed to support its production, where able, in time to meet the timetable for Local Plan submission for examination. CGC supports development near well connected existing and planned train stations in Cambridge, and supports the Plan’s ambitions to that these locations deliver a mix of land uses at higher development density.
CGC supports the draft Plan’s strengthening of the nature network and approach to biodiversity gains and accessible green infrastructure.
Design Quality
CGC strongly supports optimising density in the sustainable, well‑connected allocations in the draft Plan. Where there are planned transport enhancements, such as CSET or those identified as part of East West Rail, CGC would welcome the opportunity to work jointly with GCSP to develop frameworks or similar which would support higher density development being delivered on allocated sites which benefit from high quality transport connections. Given the careful balance which underpins the Development Strategy in the Plan, it is only right, in CGC’s view, that sites allocated for growth really do optimise their development potential. High quality densification is considered to be an essential element of the draft Local Plan delivery strategy.
CGC supports the commitment to high-quality, well-designed places and buildings as set out in relevant placemaking polices in the draft Plan. Well-designed and well-built places are essential components of the good growth which CGC supports.
Green Belt
The confirmation of green belt release for strategic site allocations is welcomed, but CGC considers that it would be beneficial to further review whether grey belt opportunities in sustainable locations may provide opportunities for additional site allocations which could accommodate future growth.

Yours sincerely
Anthony Hollingsworth
Director of Planning & Place

This letter and the accompanying schedule of comments represents the written response of the Cambridge Growth Company to the Regulation 18 consultation for the Draft Greater Cambridge Local Plan. This covering letter sets out CGC’s overall summary with specific comments on policy and site allocations set out in the accompanying schedule.
In summary, CGC supports the growth ambition and strategic direction of the Draft Greater Cambridge Local Plan. The Plan’s positive approach to growth, innovation, and long‑term sustainability is welcomed. The recognition of the requirement for additional growth in employment and housing to meet assessed need is supported as is the overall Development Strategy proposed to deliver this growth within the Plan period. The inclusion of additional headroom in both jobs and housing projections is a welcome acknowledgement of Greater Cambridge’s growth potential and aligns with CGC’s own objectives and activity as it continues to develop its evidence base for longer term strategic growth in the area.
Economy
The Plan’s commitment to accommodating employment growth and supporting the clustered nature of the Cambridge innovation economy is supported. CGC acknowledges that the draft Plan’s employment growth projections are based on a ‘central scenario’ and are reflective of identified constraints. However, we would like the draft Plan to be clear that subject to resolution of those constraints, employment growth exceeding the Local Plan central scenario could be delivered within the Plan period and that policy wording should include sufficient flexibility to accommodate higher and accelerated levels of growth prior to 2045.
CGC would like to see the Plan more explicitly recognise the value of intensifying and expanding the identified innovation clusters to fully realise growth potential and agglomeration benefits. Enabling an intensification/densification of cluster sites should where appropriate incorporate an element of housing, including innovative housing typologies, to help support their function.
CGC also welcomes the draft Plan’s support for a diverse range of commercial space to accommodate different stages of business and employment growth.
CGC also supports the draft Plan’s approach to meanwhile uses, circular economy principles and low‑carbon development.
Housing
The Plan’s focus on delivering a diverse mix of housing types and tenures, including affordable housing, is supported as is recognition of models such as build‑to‑rent, Community Land Trusts, co‑living and employer‑led housing. Achieving a greater diversity of housing than historically delivered by the market should be a clear objective of the Plan and as appropriate made explicit for site allocations.
As per our comments above regarding employment growth, CGC would encourage a degree of flexibility within both policy and allocations to allow for housing growth beyond the levels currently identified in the draft Plan and encourage the acceleration of delivery where the identified infrastructure constraints on growth can be alleviated. This would be responsive to changing market conditions and the implementation of measures to alleviate infrastructure constraints that both CGC, GCSP and CPCA is jointly developing and which should be included in the Regulation 19 draft Local Plan.
Infrastructure
The infrastructure‑first, vision‑led approach to transport is supported, given transport constraints remain one of the key limitations on growth. CGC welcomes the transport and other infrastructure identified in the Plan to support growth. CGC’s work in developing longer term growth scenarios is as you know, wholly dependent on identifying the new and enhanced infrastructure necessary to support ambitious growth. It is acknowledged that the Greater Cambridge Transport Strategy will inform later stages of the Plan and CGC is committed to support its production, where able, in time to meet the timetable for Local Plan submission for examination. CGC supports development near well connected existing and planned train stations in Cambridge, and supports the Plan’s ambitions to that these locations deliver a mix of land uses at higher development density.
CGC supports the draft Plan’s strengthening of the nature network and approach to biodiversity gains and accessible green infrastructure.
Design Quality
CGC strongly supports optimising density in the sustainable, well‑connected allocations in the draft Plan. Where there are planned transport enhancements, such as CSET or those identified as part of East West Rail, CGC would welcome the opportunity to work jointly with GCSP to develop frameworks or similar which would support higher density development being delivered on allocated sites which benefit from high quality transport connections. Given the careful balance which underpins the Development Strategy in the Plan, it is only right, in CGC’s view, that sites allocated for growth really do optimise their development potential. High quality densification is considered to be an essential element of the draft Local Plan delivery strategy.
CGC supports the commitment to high-quality, well-designed places and buildings as set out in relevant placemaking polices in the draft Plan. Well-designed and well-built places are essential components of the good growth which CGC supports.
Green Belt
The confirmation of green belt release for strategic site allocations is welcomed, but CGC considers that it would be beneficial to further review whether grey belt opportunities in sustainable locations may provide opportunities for additional site allocations which could accommodate future growth.

Yours sincerely
Anthony Hollingsworth
Director of Planning & Place

This letter and the accompanying schedule of comments represents the written response of the Cambridge Growth Company to the Regulation 18 consultation for the Draft Greater Cambridge Local Plan. This covering letter sets out CGC’s overall summary with specific comments on policy and site allocations set out in the accompanying schedule.
In summary, CGC supports the growth ambition and strategic direction of the Draft Greater Cambridge Local Plan. The Plan’s positive approach to growth, innovation, and long‑term sustainability is welcomed. The recognition of the requirement for additional growth in employment and housing to meet assessed need is supported as is the overall Development Strategy proposed to deliver this growth within the Plan period. The inclusion of additional headroom in both jobs and housing projections is a welcome acknowledgement of Greater Cambridge’s growth potential and aligns with CGC’s own objectives and activity as it continues to develop its evidence base for longer term strategic growth in the area.
Economy
The Plan’s commitment to accommodating employment growth and supporting the clustered nature of the Cambridge innovation economy is supported. CGC acknowledges that the draft Plan’s employment growth projections are based on a ‘central scenario’ and are reflective of identified constraints. However, we would like the draft Plan to be clear that subject to resolution of those constraints, employment growth exceeding the Local Plan central scenario could be delivered within the Plan period and that policy wording should include sufficient flexibility to accommodate higher and accelerated levels of growth prior to 2045.
CGC would like to see the Plan more explicitly recognise the value of intensifying and expanding the identified innovation clusters to fully realise growth potential and agglomeration benefits. Enabling an intensification/densification of cluster sites should where appropriate incorporate an element of housing, including innovative housing typologies, to help support their function.
CGC also welcomes the draft Plan’s support for a diverse range of commercial space to accommodate different stages of business and employment growth.
CGC also supports the draft Plan’s approach to meanwhile uses, circular economy principles and low‑carbon development.
Housing
The Plan’s focus on delivering a diverse mix of housing types and tenures, including affordable housing, is supported as is recognition of models such as build‑to‑rent, Community Land Trusts, co‑living and employer‑led housing. Achieving a greater diversity of housing than historically delivered by the market should be a clear objective of the Plan and as appropriate made explicit for site allocations.
As per our comments above regarding employment growth, CGC would encourage a degree of flexibility within both policy and allocations to allow for housing growth beyond the levels currently identified in the draft Plan and encourage the acceleration of delivery where the identified infrastructure constraints on growth can be alleviated. This would be responsive to changing market conditions and the implementation of measures to alleviate infrastructure constraints that both CGC, GCSP and CPCA is jointly developing and which should be included in the Regulation 19 draft Local Plan.
Infrastructure
The infrastructure‑first, vision‑led approach to transport is supported, given transport constraints remain one of the key limitations on growth. CGC welcomes the transport and other infrastructure identified in the Plan to support growth. CGC’s work in developing longer term growth scenarios is as you know, wholly dependent on identifying the new and enhanced infrastructure necessary to support ambitious growth. It is acknowledged that the Greater Cambridge Transport Strategy will inform later stages of the Plan and CGC is committed to support its production, where able, in time to meet the timetable for Local Plan submission for examination. CGC supports development near well connected existing and planned train stations in Cambridge, and supports the Plan’s ambitions to that these locations deliver a mix of land uses at higher development density.
CGC supports the draft Plan’s strengthening of the nature network and approach to biodiversity gains and accessible green infrastructure.
Design Quality
CGC strongly supports optimising density in the sustainable, well‑connected allocations in the draft Plan. Where there are planned transport enhancements, such as CSET or those identified as part of East West Rail, CGC would welcome the opportunity to work jointly with GCSP to develop frameworks or similar which would support higher density development being delivered on allocated sites which benefit from high quality transport connections. Given the careful balance which underpins the Development Strategy in the Plan, it is only right, in CGC’s view, that sites allocated for growth really do optimise their development potential. High quality densification is considered to be an essential element of the draft Local Plan delivery strategy.
CGC supports the commitment to high-quality, well-designed places and buildings as set out in relevant placemaking polices in the draft Plan. Well-designed and well-built places are essential components of the good growth which CGC supports.
Green Belt
The confirmation of green belt release for strategic site allocations is welcomed, but CGC considers that it would be beneficial to further review whether grey belt opportunities in sustainable locations may provide opportunities for additional site allocations which could accommodate future growth.

Yours sincerely
Anthony Hollingsworth
Director of Planning & Place

This letter and the accompanying schedule of comments represents the written response of the Cambridge Growth Company to the Regulation 18 consultation for the Draft Greater Cambridge Local Plan. This covering letter sets out CGC’s overall summary with specific comments on policy and site allocations set out in the accompanying schedule.
In summary, CGC supports the growth ambition and strategic direction of the Draft Greater Cambridge Local Plan. The Plan’s positive approach to growth, innovation, and long‑term sustainability is welcomed. The recognition of the requirement for additional growth in employment and housing to meet assessed need is supported as is the overall Development Strategy proposed to deliver this growth within the Plan period. The inclusion of additional headroom in both jobs and housing projections is a welcome acknowledgement of Greater Cambridge’s growth potential and aligns with CGC’s own objectives and activity as it continues to develop its evidence base for longer term strategic growth in the area.
Economy
The Plan’s commitment to accommodating employment growth and supporting the clustered nature of the Cambridge innovation economy is supported. CGC acknowledges that the draft Plan’s employment growth projections are based on a ‘central scenario’ and are reflective of identified constraints. However, we would like the draft Plan to be clear that subject to resolution of those constraints, employment growth exceeding the Local Plan central scenario could be delivered within the Plan period and that policy wording should include sufficient flexibility to accommodate higher and accelerated levels of growth prior to 2045.
CGC would like to see the Plan more explicitly recognise the value of intensifying and expanding the identified innovation clusters to fully realise growth potential and agglomeration benefits. Enabling an intensification/densification of cluster sites should where appropriate incorporate an element of housing, including innovative housing typologies, to help support their function.
CGC also welcomes the draft Plan’s support for a diverse range of commercial space to accommodate different stages of business and employment growth.
CGC also supports the draft Plan’s approach to meanwhile uses, circular economy principles and low‑carbon development.
Housing
The Plan’s focus on delivering a diverse mix of housing types and tenures, including affordable housing, is supported as is recognition of models such as build‑to‑rent, Community Land Trusts, co‑living and employer‑led housing. Achieving a greater diversity of housing than historically delivered by the market should be a clear objective of the Plan and as appropriate made explicit for site allocations.
As per our comments above regarding employment growth, CGC would encourage a degree of flexibility within both policy and allocations to allow for housing growth beyond the levels currently identified in the draft Plan and encourage the acceleration of delivery where the identified infrastructure constraints on growth can be alleviated. This would be responsive to changing market conditions and the implementation of measures to alleviate infrastructure constraints that both CGC, GCSP and CPCA is jointly developing and which should be included in the Regulation 19 draft Local Plan.
Infrastructure
The infrastructure‑first, vision‑led approach to transport is supported, given transport constraints remain one of the key limitations on growth. CGC welcomes the transport and other infrastructure identified in the Plan to support growth. CGC’s work in developing longer term growth scenarios is as you know, wholly dependent on identifying the new and enhanced infrastructure necessary to support ambitious growth. It is acknowledged that the Greater Cambridge Transport Strategy will inform later stages of the Plan and CGC is committed to support its production, where able, in time to meet the timetable for Local Plan submission for examination. CGC supports development near well connected existing and planned train stations in Cambridge, and supports the Plan’s ambitions to that these locations deliver a mix of land uses at higher development density.
CGC supports the draft Plan’s strengthening of the nature network and approach to biodiversity gains and accessible green infrastructure.
Design Quality
CGC strongly supports optimising density in the sustainable, well‑connected allocations in the draft Plan. Where there are planned transport enhancements, such as CSET or those identified as part of East West Rail, CGC would welcome the opportunity to work jointly with GCSP to develop frameworks or similar which would support higher density development being delivered on allocated sites which benefit from high quality transport connections. Given the careful balance which underpins the Development Strategy in the Plan, it is only right, in CGC’s view, that sites allocated for growth really do optimise their development potential. High quality densification is considered to be an essential element of the draft Local Plan delivery strategy.
CGC supports the commitment to high-quality, well-designed places and buildings as set out in relevant placemaking polices in the draft Plan. Well-designed and well-built places are essential components of the good growth which CGC supports.
Green Belt
The confirmation of green belt release for strategic site allocations is welcomed, but CGC considers that it would be beneficial to further review whether grey belt opportunities in sustainable locations may provide opportunities for additional site allocations which could accommodate future growth.

Yours sincerely
Anthony Hollingsworth
Director of Planning & Place

This letter and the accompanying schedule of comments represents the written response of the Cambridge Growth Company to the Regulation 18 consultation for the Draft Greater Cambridge Local Plan. This covering letter sets out CGC’s overall summary with specific comments on policy and site allocations set out in the accompanying schedule.
In summary, CGC supports the growth ambition and strategic direction of the Draft Greater Cambridge Local Plan. The Plan’s positive approach to growth, innovation, and long‑term sustainability is welcomed. The recognition of the requirement for additional growth in employment and housing to meet assessed need is supported as is the overall Development Strategy proposed to deliver this growth within the Plan period. The inclusion of additional headroom in both jobs and housing projections is a welcome acknowledgement of Greater Cambridge’s growth potential and aligns with CGC’s own objectives and activity as it continues to develop its evidence base for longer term strategic growth in the area.
Economy
The Plan’s commitment to accommodating employment growth and supporting the clustered nature of the Cambridge innovation economy is supported. CGC acknowledges that the draft Plan’s employment growth projections are based on a ‘central scenario’ and are reflective of identified constraints. However, we would like the draft Plan to be clear that subject to resolution of those constraints, employment growth exceeding the Local Plan central scenario could be delivered within the Plan period and that policy wording should include sufficient flexibility to accommodate higher and accelerated levels of growth prior to 2045.
CGC would like to see the Plan more explicitly recognise the value of intensifying and expanding the identified innovation clusters to fully realise growth potential and agglomeration benefits. Enabling an intensification/densification of cluster sites should where appropriate incorporate an element of housing, including innovative housing typologies, to help support their function.
CGC also welcomes the draft Plan’s support for a diverse range of commercial space to accommodate different stages of business and employment growth.
CGC also supports the draft Plan’s approach to meanwhile uses, circular economy principles and low‑carbon development.
Housing
The Plan’s focus on delivering a diverse mix of housing types and tenures, including affordable housing, is supported as is recognition of models such as build‑to‑rent, Community Land Trusts, co‑living and employer‑led housing. Achieving a greater diversity of housing than historically delivered by the market should be a clear objective of the Plan and as appropriate made explicit for site allocations.
As per our comments above regarding employment growth, CGC would encourage a degree of flexibility within both policy and allocations to allow for housing growth beyond the levels currently identified in the draft Plan and encourage the acceleration of delivery where the identified infrastructure constraints on growth can be alleviated. This would be responsive to changing market conditions and the implementation of measures to alleviate infrastructure constraints that both CGC, GCSP and CPCA is jointly developing and which should be included in the Regulation 19 draft Local Plan.
Infrastructure
The infrastructure‑first, vision‑led approach to transport is supported, given transport constraints remain one of the key limitations on growth. CGC welcomes the transport and other infrastructure identified in the Plan to support growth. CGC’s work in developing longer term growth scenarios is as you know, wholly dependent on identifying the new and enhanced infrastructure necessary to support ambitious growth. It is acknowledged that the Greater Cambridge Transport Strategy will inform later stages of the Plan and CGC is committed to support its production, where able, in time to meet the timetable for Local Plan submission for examination. CGC supports development near well connected existing and planned train stations in Cambridge, and supports the Plan’s ambitions to that these locations deliver a mix of land uses at higher development density.
CGC supports the draft Plan’s strengthening of the nature network and approach to biodiversity gains and accessible green infrastructure.
Design Quality
CGC strongly supports optimising density in the sustainable, well‑connected allocations in the draft Plan. Where there are planned transport enhancements, such as CSET or those identified as part of East West Rail, CGC would welcome the opportunity to work jointly with GCSP to develop frameworks or similar which would support higher density development being delivered on allocated sites which benefit from high quality transport connections. Given the careful balance which underpins the Development Strategy in the Plan, it is only right, in CGC’s view, that sites allocated for growth really do optimise their development potential. High quality densification is considered to be an essential element of the draft Local Plan delivery strategy.
CGC supports the commitment to high-quality, well-designed places and buildings as set out in relevant placemaking polices in the draft Plan. Well-designed and well-built places are essential components of the good growth which CGC supports.
Green Belt
The confirmation of green belt release for strategic site allocations is welcomed, but CGC considers that it would be beneficial to further review whether grey belt opportunities in sustainable locations may provide opportunities for additional site allocations which could accommodate future growth.

Yours sincerely
Anthony Hollingsworth
Director of Planning & Place