Draft Greater Cambridge Local Plan for consultation

We consider the target for number of new homes should be increased. Please see attached supporting covering letter for details.

The Regulation 18 Draft Local Plan sets out the development needs for Greater Cambridge; aiming to deliver
73,300 additional jobs and a minimum of 48,195 new homes across the period of 2024-2045.

Our client, Pigeon, objects to Draft Policy S/JH as currently proposed on the basis that the development needs
identified do not reflect the major growth ambitions in and around Cambridge, in addition to an insufficient
housing supply buffer that fails to provide flexibility and assurance of delivery.

For many years, Cambridge has proved a nationally and internationally significant intellectual hub centred
around academic excellence, research and innovation. The UK Government has therefore continually
emphasised its strong ambitions for Cambridge, both in terms of housing delivery and economic growth. The
Case for Cambridge (March 2024) sets out that the life sciences and healthcare industry in Cambridge alone
employs nearly 23,000 people with a turnover of £9 billion, and that building 150,000 new homes by 2050 could
add £6.4 billion to the economy.

The national focus on Cambridge is therefore clear. The establishment of the Cambridge Delivery Group in
2023 to drive forward the vision for Cambridge in collaboration with local partners, and the Cambridge Growth
Company in 2024 to address barriers to growth and help unlock the area’s full potential only further demonstrate
the desire for growth in Cambridge.

Despite the strong growth agenda for Cambridge, it is considered that the housing targets proposed, as set out
at Draft Policy S/JH, are not ambitious enough. It is noted that the Standard Method housing scenario is
considered to represent the objectively assessed need in Greater Cambridge, as detailed within the
Development Strategy Topic Paper and the Greater Cambridge Employment and Housing Needs Update
2025. Whilst it is welcomed that the revised Standard Method calculation identifies a significantly higher
number of homes than the previous calculation (2,295 per annum rather than 1,769 per annum), this approach
suggests that Greater Cambridge are content with pursuing only their minimum housing requirement.

Similarly, the Greater Cambridge Employment and Housing Needs Update 2025 identified that a central
scenario is considered the most likely outcome for employment growth, rather than a higher scenario. This
central scenario would see approximately 73,200 additional jobs in Greater Cambridge by 2045, as opposed
to 90,900 additional jobs with the higher scenario. Paragraph 3.74 of the Development Strategy Topic Paper
states that “this alternative was rejected as the higher jobs forecast could be possible, but is not the most likely future scenario. As such we do not consider that it represents our objectively assessed need, and would
therefore not be a reasonable alternative”.

As shown in the table below, when compared to the First Proposals Draft, Greater Cambridge is now proposing
8.7% more homes on an annual basis. This is in the context of a Standard Method which has increased by
almost 30% as outlined in the Consultation Strategy Topic Paper. At the same time, the latest Draft Plan
proposes around 25% more jobs across the plan period, meaning there is an increasing disparity between the
relatively ambitious jobs target and a less ambitious housing target.

See Table 1 in supporting covering letter: Comparison of First Proposals and December 2025 Consultation Draft

Our client, Pigeon, is disappointed to see that both proposed housing delivery and employment growth figures
seem to adopt a safe position in only setting minimum targets despite the significant focus on Cambridge as a
sustainable growth location. Supporting text to Draft Policy S/JH (Paragraph 2.8) even itself acknowledges “the
continuing strength of the nationally important Greater Cambridge economy” which “provides justification for
exploring higher employment and related housing figures”. It is proposed that Greater Cambridge should be
planning for higher numbers of homes beyond the minimum Standard Method, and a higher number of jobs
given the national level significance of Cambridge to the UK Economy.

Further to the need to aim beyond the mandatory housing target, the proposed buffer of 6.5% (excluding the
relocation of the Cambridge Waste Water Treatment Plant) is not deemed sufficient to provide flexibility,
assurance or security over housing delivery.

Specific comments on Appendix E: Housing trajectory and five year housing land supply calculation are detailed
in a separate representation, however, a buffer as small as 6.5% offers little room for unforeseen delays or
non-delivery of allocated sites, and presents the risk of being unable to demonstrate a five year housing land
supply.

In Greater Cambridge, this is particularly prevalent given the strong focus on bringing forward existing
commitments and proposing new strategic sites. The Regulation 18 Draft Local Plan identifies new strategic
allocations including, but not limited to, Cambourne North (13,000 homes and 108,000sqm of employment
space), Cambridge East (Airport site) (8,000 homes and employment land), Grange Farm (A11 / A1307) (6,000
homes and logistics space), and Wellcome Genome Campus (1,500 homes and expanded R&D facilities). This
large dependency and somewhat overreliance on strategic sites could result in significant under delivery in the
face of any challenges, particularly as many of these sites are subject to infrastructure delivery constraints.

To mitigate this approach and provide greater confidence in housing delivery across the district, Pigeon would
suggest that a buffer of over 10% and preferably circa 15-20% above the Standard Method figure. Such a buffer
would provide the authority with increased flexibility decreasing the potential for under delivery in light of any
delays with the delivery of the large number of strategic sites / new settlements. This would therefore reduce
the risk that Greater Cambridge are unable to demonstrate a five year housing land supply or that they would
fail to meet the identified housing requirement for the Plan period in full with the danger that this could further
hold back the local economy.

We consider that the new settlements proposed should be supported by additional smaller scale
allocations across sustainable village locations to create a more balanced housing land supply which mitigates
the risk of delayed delivery from the new settlements and would mean a wider range of housing needs across
the whole area whilst also addressing the inadequate housing supply buffer previously referred to. Please see attached supporting covering letter for details.

Our client, Pigeon, objects to Draft Policy S/DS on the grounds that it is not positively prepared or justified when
considered against the reasonable alternatives and evidence available.

Draft Policy S/DS sets out the proposed strategy for the pattern, scale, and design quality of growth across the
district. The order of preference set out in Draft Policy S/DS is as follows:

a) “Within the Cambridge urban area;
b) On the edge of Cambridge;
c) At an expanded Cambourne;
d) At other new settlements; and
e) In the rural southern cluster and wider rural area at Rural Centres and Minor Rural Centres”

These categories provide a clear structure and a sustainable guide as to where development should be located
within the district, which is generally supported by our client, Pigeon.

This development strategy places significant emphasis on strategic scale allocations for housing delivery, either
carrying forward existing commitments from the adopted Plans or new settlements as identified in the emerging
Local Plan. Of the 48,195 homes to be delivered across the period 2024 to 2045, circa 79% (37,865) are
proposed to be delivered via currently planned development, including adopted allocations, existing
permissions, and windfall allowance; a significant proportion of which comprise large strategic sites. The
Regulation 18 Draft Local Plan also identifies new strategic allocations including, but not limited to, Cambourne
North (13,000 homes and 108,000sqm of employment space), Cambridge East (Airport site) (8,000 homes and
employment land), Grange Farm (A11 / A1307) (6,000 homes and logistics space), and Wellcome Genome
Campus (1,500 homes and expanded R&D facilities).

The identification of new settlements alongside existing commitments highlights the clear approach adopted by
Greater Cambridge to rely on strategic development in order to deliver housing across the district. Particularly,
it is noted that these existing and new strategic scale allocations are proposed at Draft Policy S/DS point 2 to
“meet the majority of the development needs to 2045 and beyond”.

Our client, Pigeon, appreciates that there is a need to identify strategic sites as they are capable of delivering
large numbers of homes and making a meaningful contribution to meeting identified development needs.
However, there appears to be an overreliance on strategic sites within the Draft Local Plan, which is not
sufficiently flexible or sustainable. Placing significant dependence on strategic sites ultimately risks under
delivery in the face of any challenges, particularly as many of these strategic sites are subject to infrastructure
delivery constraints.

Indeed, it is evident from the Draft Plan that a total of 44% of the identified need is proposed to be delivered
through new settlements, up from 23% in the 2018 Plans. The Plan therefore concentrates development on the
New Settlements at the expense of every other location across Greater Cambridge. This position is summarised
in Table 2 below. In contrast, there has been a decrease in the proportion of dwellings proposed to be delivered
within the Rural Area (including through windfalls) – falling from 23% in the 2018 Plans, to just 16% in the
proposed draft.

See Table 2 in covering letter: Table Summarising the Proposed Approach to Allocations

A more appropriate balance must therefore be struck between large strategic sites and smaller scale allocations
across other settlements and existing village locations. It is recognised that Greater Cambridge “did not identify
any additional sites that would not cause a level of harm…considered justified in the context of other available
options” and that they “do not consider villages to be a reasonable option for meeting a substantive amount of
our additional need for homes” (Development Strategy Topic Paper, Paragraph 5.59).

Whilst it is acknowledged that villages are not able to meet a substantive amount of housing numbers, they still
form a fundamental aspect of delivery and should therefore not be overlooked within the development strategy.
As set out at Paragraph 83 of the NPPF (December 2024; as amended February 2025), housing should be
located where it will enhance and maintain rural communities, and planning policies should identify
opportunities where villages can grow and thrive. By seemingly overlooking rural locations for development,
the development strategy risks undermining the vitality and sustainable growth of village settlements.

Supporting text (Paragraph 2.43) to Draft Policy S/DS sets out that 4,820 homes are to be delivered on sites
of up to one hectare, in line with national planning policy which requires at least 10% of the overall housing
requirement to be delivered on sites no larger than one hectare (Paragraph 73, NPPF, December 2024; as
amended February 2025). Of the 48,195 homes to be delivered across 2024 to 2045, only 3.5% (1,694 homes)
have been specifically identified. The remaining 6.5% are proposed to be delivered via windfall development,
which again highlights the significant reliance on large strategic sites.

The role of small-to-medium sites is increasingly recognised by UK Government. In May 2025, the Government
published a ‘Reforming Site Thresholds’ working paper, which proposed a new definition of ‘medium’
development of 10-49 units and up to one hectare. The aim of this proposal was to simplify planning
requirements for smaller scale development and ensure a more targeted and proportionate approach across
different scales of development. This proposal reflects a shift at the national level, which should be better
reflected within local policy to ensure that a range of deliverable sites are identified. It would therefore be
prudent to diversify the housing trajectory to incorporate more small and medium allocations, which could
contribute to ensuring a more robust housing supply across the plan period.

The need to consider rural locations for housing is particularly prevalent given the clear transport ambitions
across the district, including a new travel route between Cambourne and Cambridge and a new travel hub at
Scotland Farm as proposed by the Greater Cambridge Partnership, and continued discussions surrounding East-West Rail. These proposed schemes will enable better connectivity of surrounding settlements to
Cambridge, and will provide sustainable commuting opportunities across the district. The commitment to deliver
these enhanced transport schemes is welcomed, however, the decision not to allocate significant development
in surrounding settlements is considerably misaligned.

From a delivery perspective, the new settlements proposed should be supported by additional smaller scale
allocations across sustainable village locations to create a more balanced housing land supply which mitigates
the risk of delayed delivery from the new settlements and would mean a wider range of housing needs across
the whole area whilst also addressing the inadequate housing supply buffer previously referred to. Ultimately,
this would ensure a more balanced and flexible development strategy that would give greater assurance of
delivery.

Specific limits on housing are deemed overly restrictive and detrimental to affordable housing delivery, and should be reviewed. Please see attached supporting covering letter for details.

Draft Policy S/SH sets out the groupings of settlements into categories that reflect their scale, characteristics,
and sustainability. The settlement hierarchy is proposed to direct housing to the most sustainable locations and
control windfall development in the least sustainable locations, and is as follows:

1. Cambridge
2. Towns
3. Rural centres
4. Minor rural centres
5. Group villages
6. Infill villages

Our client, Pigeon, objects to this draft policy, particularly in relation to the indicative limits on the scale of
housing developments identified, which do not ensure the continued vitality of villages or recognise their
sustainability in contributing to proportionate and controlled housing growth. As a result of the proposed
hierarchy, Draft Policy S/SH is not considered to be positively prepared or justified.

As set out at Paragraph 83 of the NPPF (December 2024; as amended February 2025), housing should be
located where it will enhance and maintain rural communities, and planning policies should identify
opportunities where villages can grow and thrive. However, as currently drafted, Policy S/SH is hugely
restrictive and risks undermining the vitality and sustainable growth of village settlements by placing somewhat
arbitrary limits upon housing development.

In Minor Rural Centres, for example, an ‘indicative’ maximum of 30 dwellings will be supported. Similarly, in
Group Villages, an ‘indicative’ maximum of 8 dwellings will be supported. In Group Villages, development may
exceptionally consist of up to 15 dwellings, but only where this would make the best use of a single brownfield
site. In Infill Villages, an ‘indicative’ maximum of 2 dwellings will be supported, and in very exceptional
circumstances a slightly larger development of no more than ‘about’ 8 dwellings may be permitted.

Whilst all of these indicative housing limits are considered restrictive, the 8 dwelling limit in Group Villages is
deemed particularly detrimental as it would prevent affordable housing delivery, which is typically only secured
through schemes of 10 or more dwellings (as per the adopted Local Plans and Draft Policy H/AH).

Equally, whilst supporting text states that Group Villages are generally less sustainable with fewer services and
facilities than Rural Centres and Minor Rural Centres, they are still able to support the daily requirements of
their residents and as per Paragraph 83 of the NPPF (December 2024; as amended February 2025), provisions
should be made to ensure that these village settlements can continue to grow, thrive, and support local
communities.

As detailed within the Development Strategy Topic Paper, concerns have been raised previously regarding
the overly prescriptive policy approach which limits the potential for growth, especially in Group Villages. It is
considered that these concerns still stand as the ‘indicative’ limits upon development will result in small,
piecemeal development which will fail to ensure the continued vitality of rural communities.

These somewhat arbitrary limits are not justified nor consistent with national planning policy, and only restrict
sustainable growth in villages rather than encouraging it.

The defined settlement limits for Hardwick are considered overly rigid and should be reviewed to better align with the actual built form. We contend that the inset map for Hardwick should identify 'Land South of St Neots Road / West of Howells Way, Hardwick' for residential development. Please see attached supporting covering letter for details.

Draft Policy S/DE defines the boundaries of settlements for planning purposes. Our client, Pigeon, objects to
this policy in its current form as it is not positively prepared or justified due to the lack of flexibility.

Specifically in relation to Hardwick, the defined settlement limits, as illustrated on the Draft Policies Map, are
considered to be overly rigid and do not accurately reflect the built-form. This is contrary to Draft Policy S/DE,
of which supporting Paragraph 2.132 states that “defined development extents define where policies for the
built-up areas of settlements give way to policies for the countryside”. This will be discussed further in relation
to the Draft Policies Map Inset Map for Hardwick below, however to summarise, Pigeon contend that Greater Cambridge should review the defined settlement limits at Hardwick so that they better reflect the built form of the settlement.

Moreover, outside of defined development extents, Part 2 of Draft Policy S/DE states that by default,
development will not be permitted except for:

a) “Allocations made within Made Neighbourhood Plans;
b) Rural Exception sites meeting local need for affordable housing;
c) Development for agriculture, horticulture, forestry, outdoor recreation and other uses which need to
be located in the countryside; or
d) Where development is supported by other policies in this plan.”

It is considered that the wording at Part 2 is fairly restrictive and inflexible, and thus makes it challenging for
windfall sites to come forward. This problem is exacerbated by the lack of residential allocations in village
settlements. In its current form, this policy therefore does not support the sustainable development of well-related
village settlements, such as Hardwick. As such, this policy is contrary to Paragraph 83 of the NPPF
(December 2024; as amended February 2025) which aims to support the continued sustainable growth and
vitality of rural communities.

Hardwick is considered to be a highly sustainable rural location. The settlement benefits from the following
community facilities and services: Hardwick Primary School; Hardwick Play Park; Post Office / Convenience
Store; and a series of local shops, hairdressers, a restaurant, a cafe, and a gym.

In terms of accessibility, Hardwick benefits from suitable access to Cambridge City Centre and the surrounding
area. The village is currently served by a regular bus service, Stagecoach 4. This provides buses every 20
minutes from 6.12am until 8.12pm followed by a hourly evening service through Monday to Saturday running
between Cambourne and Cambridge. There is a reduced service on Sundays. This bus service can be used
for commuting and access to major retail and leisure destinations both in Cambourne and Cambridge. The
Cambridge Rail Station has trains running to London, Ely, Peterborough, and by connection to the rest of the
country.

The Greater Cambridge Partnership are currently proposing a new travel route between Cambourne and
Cambridge, to include a bus route via Hardwick (amongst other locations); a new travel hub at Scotland Farm,
Dry Drayton; and, a new path for walkers, cyclists and horse riders. The Scotland Farm travel hub is located
circa. 450 metres from the site, across the A428. According to the Greater Cambridge Partnership, the Scotland
Farm site will host 2,000 car parking spaces, 300 cycle parking spaces, a small building providing shelter,
seating, passenger information, and toilets, and LED lighting will be integrated throughout the site. There is an existing ‘Local Cycle Route’ to the north of the site, along St Neots Road.

Whilst no application has yet come forward for the East-West Rail, the proposed route is located within close
proximity to the south of the site, and a new East-West Rail Station is proposed at Cambourne, less than 5km
from Hardwick, approximately 15 minute cycle ride from the Site. The proposals for both East-West Rail and
Cambourne to Cambridge will complement each other, providing more travel options for those travelling west
of Cambridge; therefore enhancing existing accessibility of Hardwick.

Hardwick is also well positioned in relation to the existing highway network with links to the A428, and then
beyond to the A1, A10, A14, and M11.

Given that Hardwick has a range of key local services and facilities, is easily accessible to Cambridge to the
east, and is one of the focal locations for forthcoming major transport and infrastructure projects, it is considered
that Hardwick can support additional residential development within the emerging plan period, specifically at
Land South of St Neots Road and West of Howells Way, Hardwick.

Pigeon therefore contend that Greater Cambridge should update the Draft Policy wording to allow for greater
flexibility in terms of development outside of defined boundaries where there is unmet local housing need,
particularly when village settlements such as Hardwick provide suitable and appropriate opportunities for
sustainable development. As a minimum, allowances should be made for development outside of, but adjacent
to, settlement boundaries, to enable the continued sustainable growth and vitality of village settlements, as per
Paragraph 83 (NPPF, December 2024; as amended February 2025).

Draft Greater Cambridge Local Plan Inset Map - Hardwick Harlton Harston:

Our client, Pigeon, objects to the proposed inset map for Hardwick on the basis that it does not allocate Land
South of St Neots Road / West of Howells Way, Hardwick (Site ID: 115234 / HELAA Site ID: 40273) for
residential allocation. Indeed, no residential allocations are proposed in Hardwick, despite the village being a
demonstrably sustainable Group Village.

Equally, the defined settlement boundary, as illustrated on the inset map, is considered to be overly rigid and
does not accurately reflect the built-form of Hardwick. The Draft Local Plan Policies Map is largely similar to
the adopted South Cambridgeshire Policies Map. The main difference is that there is a safeguarded area now
to the south of the Site for the proposed East-West Rail route. The other specific change with regards to the
settlement boundary is the inclusion of the new development at Meridian Fields, at the southern edge of
Hardwick. It is not clear why this development has been included within the defined settlement boundary, whilst
Capstone Fields (immediately adjacent to the Site) and other residential built form along St Neots Road has
been excluded.

This approach is contrary to Draft Policy S/DE, of which supporting Paragraph 2.132 states that “defined
development extents define where policies for the built-up areas of settlements give way to policies for the
countryside”. Pigeon contend that Greater Cambridge should review the defined settlement limits at Hardwick
so that they better reflect the actual built form of the settlement.

We contend that the proposed allocations are overly focused on strategic sites, which risks under delivery. A better balance should be struck between large and smaller-scale developments, and 'Land South of St Neots Road and West of Howells Way, Hardwick' should be included for residential development. Please see attached supporting covering letter for details.

Draft Policy S/RRA allocates specific sites within the rest of the rural area to meet the development needs
across the district. Our client, Pigeon, objects on the basis that the housing allocations identified are insufficient
to meet local housing needs in villages, and further, that it omits ‘Land South of St Neots Road and West of
Howells Way, Hardwick’ for residential development.

It is considered that the housing allocations identified are not aligned with the settlement hierarchy in terms of
distribution and scale of development. As mentioned elsewhere, there is a strong focus within the Draft Local
Plan on the delivery of strategic sites. Whilst it is recognised that strategic sites are capable of delivering large
numbers of homes and making a meaningful contribution to meeting identified development needs, the
proposed allocations are somewhat top-heavy and concentrated at the higher tiers of the settlement hierarchy.
This reliance on large strategic sites is not deemed sufficiently flexible or sustainable and placing significant
dependence on such sites risks under delivery in the face of any challenges, particularly as many of these sites
are subject to infrastructure delivery constraints.

A more appropriate balance must therefore be struck between large strategic sites and smaller scale allocations
across other settlements and existing village locations. It is recognised that Greater Cambridge “did not identify
any additional sites that would not cause a level of harm…considered justified in the context of other available
options” and that they “do not consider villages to be a reasonable option for meeting a substantive amount of
our additional need for homes” (Development Strategy Topic Paper, Paragraph 5.59). Whilst it is
acknowledged that villages are not able to meet a substantive amount of housing numbers, they still form a
fundamental aspect of delivery and should therefore not be overlooked within the development strategy. As set
out at Paragraph 83 of the NPPF (December 2024; as amended February 2025), housing should be located
where it will enhance and maintain rural communities, and planning policies should identify opportunities where
villages can grow and thrive. By seemingly overlooking rural locations for development, the development
strategy risks undermining the vitality and sustainable growth of village settlements.

Land South of St Neots Road and West of Howells Way, Hardwick (The Site) is not allocated and is situated
just outside of the defined development extent of Hardwick, but presents a logical extension to the village of Hardwick that is suitable, available, and deliverable.

The Site has previously been promoted on behalf of Pigeon in response to the Call for Sites exercises in 2019
and 2025. The Site is being promoted again via the Greater Cambridge Local Plan Regulation 18 consultation
to highlight the continued suitability and availability of the site as a whole. In particular, we wish to highlight the
opportunity for further enhancement of Hardwick, especially in the context of the recent development
immediately adjacent to the site to the east, as well as separate proposals for transport enhancements including
East-West Rail and Cambourne to Cambridge travel route.

The Site extends to circa. 6.7 hectares of paddock / scrub land on the western edge of Hardwick, adjoining
Meridian Close and frontage residential development along this length of St Neots Road, approximately 8km
to the west of Cambridge. The Site is situated beyond the Green Belt that surrounds Cambridge, and is well-related
to the existing built form of Hardwick. The Site comprises generally flat land and the Site is well
contained in landscape terms; with mature boundaries comprising hedgerow and belts of deciduous trees to
the south, east, and west.

Immediately adjacent to the east is the Hill Residential scheme of 155 dwellings at Capstone Fields which was
granted outline planning permission in August 2018, and has subsequently been built out. This site is also
located outside of the settlement boundary of Hardwick but was deemed to be an appropriate and sustainable
development by the Council. Given the location of Land South of St Neots Road and West of Howells Way
immediately adjacent to the built form of Hardwick, the existing services and facilities in the village, and the
existing and proposed enhancements to public transport connectivity, it is considered that Hardwick can support
further development to encourage sustainable and natural growth.

The Site is promoted for residential development of approximately 140 dwellings, public open space, and
biodiversity enhancements with associated infrastructure. This Site represents a suitable opportunity to secure
sustainable residential development comprising both market and affordable homes within the settlement of
Hardwick.

The Site is available now and can deliver from Year 1 of the new Local Plan once adopted.

See in supporting covering letter an extract from the 2025 HELAA site assessments demonstrating how Land South of St Neots Road and West of Howells Way, Hardwick was assessed, alongside comments from the promotion team.

Pigeon therefore contend that the omission of Land South of St Neots Road and West of Howells Way fails to
recognise Hardwick’s accessible location, good existing service provision, and both existing and proposed
transport enhancements.

To ensure that Greater Cambridge’s five-year housing land supply upon adoption is secure, the Councils should
allocate further land for development, focusing on sites that do not require significant additional infrastructure
before housing delivery can commence. It is considered that the site at Land South of St Neots Road, and West of Howells Way, Hardwick can deliver early in the Plan period to ensure a robust 5YHLS position.

The Regulation 18 Plan outlines how the Council intends to deliver a minimum of 48,195 new homes between
2024 and 2045. After reviewing the delivery assumptions in Figure E1 (‘Anticipated Completions 2024 - 2025’)
of the Consultation Plan, Pigeon considers the projected delivery rates to be unrealistic.

Savills’ assessment of the current 5YHLS position in Greater Cambridge confirms that the Councils cannot
demonstrate a five-year supply of housing land. The proposed trajectory in Appendix E of the consultation plan
does not materially change this assessment. Accordingly, Savills’ view is that, if adopted as currently proposed,
the Council will be unable to demonstrate a sufficient supply of housing land upon adoption of the new Plan.
Savills estimate that the housing land supply upon adoption would likely be in the region of circa 4 years’,
leaving Greater Cambridge open to speculative development to address the shortfall.

The projected shortfall is primarily due to unrealistic delivery assumptions at several key strategic sites. These
include Northstowe, Waterbeach, and Bourn Airfield, and extend to other large allocations that lack clear
evidence of delivery commencing within the five-year period.

To ensure that Greater Cambridge’s five-year housing land supply upon adoption is secure, the Councils should
allocate further land for development, focusing on sites that do not require significant additional infrastructure
before housing delivery can commence. In practice, this will mean allocating small-to-medium sized sites which
can start to deliver early in the Plan period.

Pigeon considers that the site at Land South of St Neots Road, and West of Howells Way, Hardwick can deliver
early in the Plan period to ensure a robust 5YHLS position.

Pigeon’s view is that the 6.5% housing supply buffer currently proposed on the housing requirement for the
Plan period, upon which the allocations and trajectory are based, will result in Greater Cambridge being unable
to demonstrate a five-year supply of housing land either upon or shortly after adoption and a risk to the delivery
of the Plan’s overall housing requirement. With a limited housing supply buffer being provided, housing delivery
is vulnerable to even minor slowdowns, such that a delayed planning application at a single site could subject Greater Cambridge to the tilted balance in decision-making and affect the achievement of the Plan’s housing
requirement overall.