Draft Greater Cambridge Local Plan for consultation

Richborough supports the vision for Greater Cambridge to be a place where a big decrease in our climate and environmental impacts comes with the continued flourishing of the internationally significant innovation economy, and a big increase in the quality of everyday life for all our communities. It is important that the Vision and the emerging Local Plan is strengthened to refer to the importance of delivery of development within the Ox- Cam Arc and meeting the governments agenda to accelerate both employment and housing growth within the arc.

Achieving this vision is contingent upon the adoption of a sound Local Plan which sets ambitious targets for growth and is positively prepared, justified, effective, and consistent with national policy (in accordance with the tests set out in Paragraph 36 of the National Planning Policy Framework 2024 (NPPF). As acknowledged in the DLP, the plan is still very much a draft. As set out within these representations, in its current form the DLP requires amendments to ensure that the level of growth and housing allocations reflect the Vision for Greater Cambridge as set out in the DLP.

A full copy of our representation has been attached to our submission.

Extend the plan period until a minimum of 2050.

The Local Development Scheme currently envisages Adoption of the plan in 2028 and the plan period will cover a period until 2045.

Paragraph 22 of the NPPF states that strategic policies should look ahead to a minimum of 15 years period from adoption to anticipate and respond to long term requirements and opportunities, such as those arising from infrastructure. Where large scale developments such as new settlements or significant extensions to existing villages or towns form part of the strategy for the area, policies should be set within a vision that looks further ahead (at least 30 years), to take account of the timescale for delivery.

The emerging Local Plan proposes a number of new settlements and significant urban extensions, which make up the vast majority of growth in the plan. Table 2 of the emerging Local Plan sets out a housing trajectory for the draft allocated sites. All the larger strategic draft allocations have a growth trajectory that is well in excess of the plan period.

In October 2025 the Greater Cambridgeshire and Peterborough Combined Authority Board approved the Local Growth Plan which has a core ambition to double the size of the area by 2050. The Local Growth Plan looks ahead to 2050, and the government has also set out a vision for growth in Cambridge between now and 2050.

As part of the reforms to the current planning system, the Greater Cambridgeshire and Peterborough Combined Authority will have to produce a Spatial Development Strategy for their area which will be built on the Local Growth Plan and will include geographical and land-use designations. The mayor has committed to producing a spatial development strategy as a priority and it is anticipated this will be in place in 2028 when this Draft Plan is due to be adopted.

There will be a requirement for the new Local Plan to align with the mayor’s spatial strategy, particularly given they are both due for adoption in 2028.

It is also relevant to note that, as a result of local government reorganisation, it is a distinct possibility that this will be the last Local Plan prepared to guide the growth and development of the Greater Cambridge area, it would seem sensible that the Council take this opportunity to deliver a development strategy which reflects and supports the approach being taken at the regional level and ensures that the District can maximise the benefits and opportunities available at the local level.

Therefore, to align with the Cambridgeshire Local Plan and emerging Spatial Development Strategy, and accounting for the number of large strategic allocations in the plan, it is considered that the plan period should be extended to 2050. A longer plan period is considered to clearly be the most reasonable strategy, when considered against the alternatives. This amendment is required in order for the plan to accord with national policy and for it to be justified.

Substantial increase in housing delivery over the plan period.

Policy S/JH New Jobs and Homes, sets out that development will meet the objectively assessed needs in Greater Cambridge over the period 2024-2045 for: 73,300 additional jobs and a minimum of 48,195 new homes.

The level of employment and housing growth proposed over the plan period is underpinned by the Employment and Housing Evidence Update 2025 (EHEU 2025), which forms an evidence based document published to support the Regulation 18 version of the Local Plan. The two key drivers for the proposed job and housing growth appears to be predicated mainly on how many jobs the government’s mandatory minimum housing need calculation would support, and separately the most likely future forecast for jobs for Greater Cambridge and the homes that this would require.

The Development Strategy Topic Paper includes the below table which sets out the Standard Method, Central and High projected job increases and housing needs (Figure 3 in our attached representation).

For jobs, the EHEU 2025 identifies a “Central” most likely future jobs forecast. The Central forecast assumes growth of around 4,000 additional jobs per annum or more through to 2045. This is set out as a mixture of continuing the recent period of rapid growth seen in Greater Cambridge’s Knowledge Intensive sectors over the last 10 years, but also building in an assumption that there will be slower or contracting periods and unforeseen shocks. The EHEU 2025 also identifies a higher growth forecast, placing greater weight on what is described as ‘rapid growth in the recent past’, particularly in key sectors, and recommended providing flexibility in employment land in case the market delivers more jobs than anticipated.

For homes, the EHEU 2025 identifies that the outcome of the Government’s Standard Method for calculating minimum housing need, which increased significantly in 2024, would support the most likely forecast for future jobs.

It is argued that as the Standard Method figures broadly correlate with the Central (suggested most likely) job and housing projections and that adoption of these figures is appropriate. However, for reasons explained within this representation, the level of growth proposed does not align with either the government’s growth agenda for the region in terms of accelerating growth in the OxCam Arc, or the Cambridgeshire and Peterborough Combined Authorities aspirations for growth within Greater Cambridge. It also does not provide sufficient flexibility to increase housing numbers, should employment growth continue at the pace it has for the last 10 years. In this regard, there is considered to be a very strong case that employment growth in Cambridge will continue at the pace it has for the last 10 years and that this should be the minimum level of growth planned for. Therefore, in accordance with the requirements of the NPPF, this is not considered to be appropriate strategy taking into account reasonable alternatives and other publicly available evidence. As it stands, for reasons explained below, Policy S/JH is not justified and the DLP could not be found sound.

Paragraph 36 a) of the NPPF is clear that to be positively prepared, the Local Plan should as a minimum, seek to meet the areas objectively assessed housing needs.’ Therefore, the standard method housing requirement should be a minimum starting point for housing growth. Therefore, it is unclear why the Development Strategy Topic Paper identifies housing figures that are marginally below the standard method requirements for both housing and job growth as a ‘central growth’ figure. In reality, this is the absolute minimum level of growth that should be planned for and should be identified as the low growth scenario within the topic paper.

The Supporting test for Policy S/HJ states the following:
‘the continuing strength of the nationally important Greater Cambridge economy provides justification for exploring higher employment and related housing figures’.

The EHEU dismisses the higher growth scenario, principally on the basis that it is considered that the standard method level of growth is considered to be the ‘most likely’ growth scenario. This is not considered to be a justified or sound basis for setting the growth targets, which should be plan and evidence base led.

Paragraph 39 ID: 61-039-20190315 of the NPPG is clear that establishing the overall housing need should be conducted using the standard methodology unless specific circumstances justify an alternative. As evidenced by extensive research, over the recent years the level of job growth within the Greater Cambridge Area has been substantially higher than the Adopted Local Plan projections In this regard, it is considered that within Greater Cambridge there is a compelling case that the level of growth should be higher than the minimum level of growth as proposed using the Central level of growth or standard method housing and job figures.

The arguments and evidence for ambitious growth targets for Cambridge have been set out in a multitude of high-profile studies, plans, and government statements, which are set out below.
Cambridgeshire and Peterborough Independent Economic Review

The Cambridgeshire and Peterborough Independent Economic Review September 2018 (CPIER) is referenced in detail within the evidence based documents to support the emerging Local Plan. The CPIER report sought to develop an authoritative evidence base on the economic performance and potential of Cambridgeshire and Peterborough and informed choices on policy priorities and strategic investment. Regarding employment and housing the report sets out:

‘we have reached the clear conclusion that recent employment growth rates have been rather stronger than indicated by official figures, and we believe that the area can continue to deliver rapid growth with the right support’ … ‘growth in employment has not been matched by corresponding house-building, or developments in infrastructure’.

Further to the above, it is explained that:
‘success here is of national significance... but it will only be attained if there is more ambition with regard to the development of new housing, and a careful prioritisation of infrastructure projects’.

The CPIER report is clear that house building has for the last 30 years not kept pace with the level of job growth. This in turn has resulted in a substantial rise of house prices within Cambridge, with demand vastly outstripping supply, which in turn has created substantial affordability issues.

This data is strengthened by further data for example as set out in the Housing Key Facts, evidence based document published by Cambridge City Council (2025). This sets out that the current ratio of medium house price to medium income is 8.8 in Cambridge, which is above the national average of 7.7. For the lowest income quartile, this figure rises to 11.5, putting the city well above national affordability standards. This is further compounded by average rental prices, which are now on average £1,774 per month (based on ONS Housing Prices for Cambridge), which leaves little scope for professionals and workers renting to save money to get onto the housing ladder. Boosting housing supply in and around the City is therefore critical to addressing this acute housing shortfall.

Clearly basing proposed housing growth on employment projections and the standard method alone is too narrow an approach and more ambitious aspirational targets should be set. Particularly given the long history in Greater Cambridge of underestimating the level of employment growth in the past.

The Case for Cambridge

In March 2024 ‘The Case for Cambridge’ was published by the government, which set out ambitious plans for growth in Cambridge noting:

‘population growth is causing problems: pressure on house prices; high levels of congestion… a truly ambitious plan for growing the city and population will bring benefits, as opposed to frustrations, to residents’.

Two illustrative scenarios were put forward:
• Building 100,000 new homes by 2050 has the potential to add approximately £4.3 billion to the economy (between £2.1 billion and £6.4 billion with a central estimate of £4.3 billion). This in turn has the potential to translate in today’s terms into an annual increase of approximately £1.5 billion of additional receipts for the exchequer (income from taxes and other sources), which can be spent on public services.
• Building 150,000 new homes by 2050 has the potential to add approximately £6.4 billion to the economy (between £3.2 billion and £9.7 billion with a central estimate of £6.4 billion). This in turn has the potential to translate in today’s terms into an annual increase of approximately £2 billion of additional receipts for the exchequer (income from taxes and other sources), which can be spent on public services.

The current government subsequently reconfirmed its commitment to growth in Cambridge. In August 2024 Matthew Pennycook MP said the government was "ambitious for Cambridge" and that the city had been "constrained economically by the lack of housing". Again, the importance of setting bold aspirational targets for growth in Cambridge are highlighted at the highest levels of government. Whilst the current government has not provided a specific figure on housing growth, the government has set up the Cambridge Growth Company to accelerate growth in Greater Cambridge.

The emerging Local Plan covers a plan period to 2045. Table 2 of the plan sets out that the plan will deliver 51,328 dwellings between 2024 and 2045 or 55,328 if North East Cambridge is delivered. If the housing growth in the Local Plan is continued on a pro rata basis using the 2,295 dwellings per annum for another 5 years, this would still only deliver 62,803 homes by 2050, which is still almost 40,000 dwellings lower than the government’s lower of the two Case for Cambridge growth scenarios. Whilst it is acknowledged that the aspiration to deliver 100,000 dwellings by 2050 is optimistic, there is considered to be a strong case to substantially increase the level of housing and employment growth above the standard method figures.

Paragraphs 1.19 to 1.21 of the DLP acknowledge that the government has set up Cambridge Growth Company to accelerate growth, but then conclude that this Local Plan is only based upon the Council’s own evidence base for plan making. Given that Cambridge Growth Company do not have any planning powers, it is not clear how the higher growth aspirations of the government will be achieved unless the DLP is more ambitious.
Cambridgeshire Local Growth Plan

In October 2025 the Greater Cambridgeshire & Peterborough Combined Authority Board approved the Local Cambridgeshire Growth Plan. This growth plan was heavily informed by the CPIER Report and this plan includes three growth scenarios:
• Baseline growth, or ‘business as usual’ would see the size of the economy grow to £42.5bn by 2050 - an annual growth rate of 1.2%.
• Doubling our Economy: our core scenario - would see the economy double in size by 2050 to £62.3bn GVA.
• Aspirational Growth: our growth ambition is to see the economy triple in size by 2050 to £97.1bn GVA, unlocking an economic powerhouse


It is also noted that:
‘these growth scenarios have undergone rigorous modelling and can be deliverable by 2050 with the right levels of support and investment’.

Page 155 of the Cambridgeshire Growth Plan is also clear that, to support a doubling of the economy by 2050, this would require a minimum of 214,760 dwellings to be delivered in the County during this timetable. Whilst the Local Growth Plan does not define a District by District breakdown of housing figures, it is clear that Greater Cambridge, as the focus for growth within the County, should be responsible for a substantial proportion of this growth. On a pro-rata basis, if the 214,760 dwellings were delivered equally between the six local authority areas in Cambridgeshire and Peterborough, this would result in Greater Cambridge having a requirement to deliver a minimum of 71,586 dwellings between now and 2050. In reality, accounting for Cambridge being the International Life-Science and employment driver for the County, in accordance with the government’s Case for Cambridge, the growth within the Cambridge City and South Cambridgeshire administrative areas would be expected to be substantially higher.

As set out above, as part of the reforms to the current planning system, the Greater Cambridgeshire and Peterborough Combined Authority will have to produce a Spatial Development Strategy for their area which will build on the Local Growth Plan and will include geographical and land-use designations. The mayor has committed to producing a spatial development strategy as a priority and it is anticipated this will be in place in 2028.

Paragraph 25 of the NPPF is clear that strategic policy making authorities should collaborate to identify strategic matters, which they need to address in their plans. They should engage with elected Mayors and Combined Authorities. Paragraph 26 of the NPPF then goes on to state that effective and ongoing joint working between strategic plan-making authorities and relevant bodies is integral to the production of a positively prepared and joint strategy.

In accordance with the requirements of paragraphs 25 and 26 of the NPPF, it is critical that the emerging Local Plan is aligned to the Cambridgeshire Local Growth Plan (2025) and the emerging Spatial Development Plan for Cambridgeshire. As a starting point, this should ensure that housing and employment growth is substantially increased to align with the objectives of the Cambridgeshire Local Growth Plan.

Conclusion on Policy SJ/H – Homes and Jobs

Having regard to the clear growth aspirations set out both by the government and the Cambridgeshire Local Growth Plan, it is considered that the emerging Local Plan and Policy SJ/H needs to be revisited to provide a higher level of growth. A higher level of growth would align with both the governments considerable commitment to the region and Mayors Vision for growth. Not aspiring to achieve this is a flaw of the plan and in turn results in the current plan not being positively prepared.

As set out above, delivery of growth in Greater Cambridge is of national significance. In the past, employment growth rates have been stronger than official figures and have outstripped delivery of housebuilding and infrastructure. The government has confirmed its continued support for high levels of growth in Greater Cambridge. This ambitious level of growth is also supported by the Local Growth Plan and will likely be reflected in the Spatial Development Strategy.

Based on this evidence, it is considered that the levels of job and housing growth targeted are not justified and are not an appropriate strategy taking into account the reasonable alternatives. A far more ambitious level of job and housing growth should be planned for. As it stands, Policy S/JH is unsound and requires amendment.

As set out in these representations, sustainable sites which can be delivered early in the plan period, such as Land South of Lower Camborne, would support this ambitious level of growth and should be allocated in the DLP.

Additional allocations are required including land to South of Lower Cambourne, which is a strategic site that can deliver 1700 dwellings and deliverable in the short term without major infrastructure requirements. Please refer to Vision Document and full Regulation 18 representation, which fully sets out that the site would be a sound allocation.

Policy S/DS: Development strategy sets out the proposed strategy for the pattern, scale, and design quality of places created in Greater Cambridge, for the plan period to 2045 and beyond. This is one of the key strategic policies within the plan. The policy is set out in different parts. Part 1 of the policy states the following:
Policy S/DS: Development Strategy, sets out that the need for jobs and homes will be met in the following order of preference, having regard to the purposes of the Cambridge Green Belt:

a) Within the Cambridge Area
b) On the outer edge of Cambridge
c) At an expanded Cambourne
d) At other new settlements
e) In the rural southern cluster and wider rural area at Rural Centres and Minor Rural Centres
…
Part 1 of Policy S/DS

Part 1 of Policy S/DS is strongly supported. It is considered appropriate that development should be focused within Cambridge City and on the outer edge of Cambridge, accounting for the global importance of Cambridge as the focus for growth.

The acknowledgement that Cambourne is a highly sustainable location for growth reflects its connectivity and its current range of services and its position as the preferred location for growth after Cambridge is appropriate and is strongly supported. The sustainability of the settlement is only going to improve further once the East West Rail is delivered, so a strategy of promoting growth here is an entirely logical and appropriate one.

The Emerging Local Plan set out that the significant expansion of Cambourne would leverage its highly connected location within the OxCam Corridor and its integral role in the Greater Cambridge economy. In this regard, being situated to the west of Cambridge, Cambourne is the only town within the District situated centrally within the OxCam corridor. Cambourne is also located outside the Cambridge Green Belt. It also provides an affordable alternative to Cambridge, where house and rental prices are high. For all these reasons, Part 1 of the Spatial Strategy is strongly supported and the hierarchy for growth is positively prepared, justified and sound in planning terms.

The allocation of Land South of Lower Cambourne would strongly align with the strategic policy objectives set out within Policy S/DS. Land to the South of Lower Cambourne offers a unique and strategic opportunity to assist with delivering the core objectives of the emerging Greater Cambridge Local Plan. Critically the site is under the sole control of Richborough and has the ability to be delivered in the short to medium term, without the need for major infrastructure upgrades. In this regard, it is the only site of a strategic scale (1000 units or larger) that can be developed in Cambourne in the shorter term without being reliant on major infrastructure projects, such as East West Rail.

Part 2 of Policy S/DS and Strategic Allocations

Part 2 of Policy S/DS sets out that the vast majority of growth will be met via the following new allocations:
• North East Cambridge – allocated for approximately 8,350 dwellings and 350,000m2 of employment space
• Cambridge East (Marshalls Airport) – allocated for approximately 8,000 dwellings and 20,000m2 employment space
• Cambourne North – allocated for approximately 13,000 dwellings and 108,00m2 employment space
• Grange Farm Little Abington – allocated for approximately 6,000 dwellings and 35,000m2 of employment space

This places a very high level reliance on the delivery of growth across only four sites, all of which are 6,000 dwellings or larger in size and all of which are predicated on significant infrastructure improvements. For reasons explained in this section of this report, this approach results in substantial concerns regarding the likelihood of housing delivery being delayed, which is likely to result in insufficient housing being delivered across the plan period.

Table 2 of the plan sets out a housing supply over the plan period of new sites allocated in the plan, along with Table 4, which provides a total supply over the plan period.

It is set out in the supporting text for table 2, in order to meet the minimum number of homes required by the standard method, it is proposed that once existing allocations and sites with permission are taken into account, a further 10,330 homes needs to be allocated.

Table 4 of the DLP sets out that the Council has identified sites to deliver a further 13,463 homes over the plan period. 9,050 of the new dwellings, (which represents the majority of the 13,463 dwellings) will be met via 3 new urban extensions/new settlements at Cambridge East (Marshalls Airport Allocated under Policy S/CE), Cambourne North (Allocated under Policy S/CBN), and Grange Farm, Little Abington (Allocated under policy S/GF). Due to uncertainty regarding its delivery, North East Cambridge has not been included in the baseline calculation. The plan provides for a 6.5% buffer in housing delivery against the standard method. Accounting for the high reliance on the delivery of growth via only 3 sites, all of which have complicated infrastructure constraints it is considered that a buffer nearer to 20% would be preferable and would assist with providing a robust plan.

Based on the housing trajectory set out in the plan, the housing land supply position does not exceed 5.5 years within the plan period and upon adoption it is estimated to be 5.15 years. This is not considered to align with the growth aspirations for Cambridge and, given the reliance on new settlements and urban extensions (of 6,000 dwellings and larger in size), there is a good prospect that the 5 year housing land supply will drop below 5 years. Figure 11 of the DLP shows the housing trajectory and it is clear that as a result of the vast majority of new growth being planned for within new settlements/urban extensions of more than 6,000 dwellings in size, there is very little growth from new allocations within the early years of the plan period. This does not align with the NPPF’s objectives to significantly boost housing land supply. This should be addressed by the allocation of additional deliverable sites, such as land to the South of Lower Cambourne, which can provide a very substantial contribution to housing supply but it can also be delivered in the shorter to medium term without the need to rely on significant infrastructure improvements.

Further detail on the potential infrastructure and delivery constraints associated with the major new allocations are set out as follows:

North-East Cambridge

Policy S/NEC: North East Cambridge identifies north-east Cambridge will deliver, inter alia, approximately 8,350 new homes (including around 5,500 homes on the existing Cambridge Waste Water Treatment Plant site (CWWTP)), up to 320,000 square metres of additional business floorspace and 27,300 square metres of industrial floorspace.

In August 2025, the Government announced that it will not be funding the relocation of the CWWTP through the Housing Infrastructure Fund, which means there is significant uncertainty as to whether the majority of the residential component of the North-East Cambridge will take place in the time period previously envisaged (including the assumed delivery of a significant amount of housing within the plan period). Delivery of the development is subject to alternative funding being found to enable the relocation of the CWWTP.

As acknowledged within the supporting text for S/NEC as a result of the funding situation, there is now uncertainty in relation the effective delivery of a significant proportion of north-east Cambridge, including the assumed delivery of housing within the plan period. This has resulted in the housing proposed within S/NEC not being included within the housing trajectory. In accordance with paragraph 36 of the NPPF, in order to be effective, sites need to be deliverable over the plan period. Accounting for the substantial uncertainty regarding the deliverability of north-east Cambridge, it cannot currently be considered a deliverable site and it will not deliver housing and job growth in the short term. It is therefore considered that the allocation should either be removed or if it is retained additional allocations on deliverable sites should be added to the plan to ensure that the plan is effective and that the plan provides a suitable buffer for growth. Land to the South of Lower Cambourne would provide a sound and effective alternative allocation and is for a strategic scale to assist with meeting this shortfall.
Cambridge East.

Policy S/CE: Cambridge East is a mixed-use development including 8,000 dwellings at Marshalls Airport. The land at Marshalls Airport was released from the Green Belt and safeguarded for development within the Cambridge Area Action Plan, which was adopted back in 2008, as a major new urban extension at Cambridge East. Since the publication of the Area Action Plan, schemes at Marleigh and Land north of Cherry Hinton have obtained consent and are currently being built out. However, some 17 years after the land was removed from the Green Belt, the development of the airport is still predicated on the relocation of Marshalls Airport to a new location.

Marshall announced in October 2025 that the business will not be moving to Cranfield but that the company is still committed to moving its aerospace business from its Cambridge Airport base by 2030 (with development anticipated to start in 2032). Notwithstanding this aspiration, there is still no certainty that the airport will move within these predicted timescales, particularly given that an alternative site to relocate to has not yet been secured. As a result, development at Cambridge East could be significantly delayed which could result in limited or no housing delivery for a number of years, particularly within the first 15 years of the plan period. In accordance with paragraph 78 of the NPPF, it is considered critical that additional allocations are included in the plan to boost supply within the first 15 years of the plan. This will assist in the Shared Planning Service maintaining a 5 year housing land supply.
Grange Farm, Little Abington.

The delivery of 6,000 dwellings at Grange Farm is predicated to an extent on the delivery of the Cambridge South-East Rapid Busway. This busway has not yet been subject to a Transport for Works Order and it is also not yet fully funded. Without the delivery of the busway the sustainability credentials of Grange Farm will be substantially reduced and it is questionable whether this is the most appropriate location for growth when considered against the alternatives.

Cambourne North

Policy S/CBN: Cambourne North sets out the proposed approach to the further expansion of Cambourne, taking account of the significant planned improvements to public transport in this area. The new settlement would include approximately 13,000 homes, 108,000 square metres of employment floorspace, with a range of supporting services and facilities.

As set out above, Cambourne is a highly sustainable location for growth and its expansion is strongly supported.

The delivery of Cambourne North is predicated on the delivery of a new train line and a new train station as part of East-West Rail. The second and third stages of East West Rail, from Oxford through to Bedford and Bedford to Cambridge are still in planning & feasibility stages, and are dependent on final government funding and approval.  Stage 1 of East-West Rail is currently under construction and services are due to commence between Oxford and Milton Keynes in 2026. Stage 2 will then extend services to Bedford as part of upgrades to the Marston Vale line by 2030. Accounting for the delays to stage 1 of East-West Rail, completion of the upgrades in stage 2 to Bedford by 2030 is considered to be optimistic and it is likely to be delayed. Stage 3, which is between Bedford and Cambridge, has no set timetable for construction works to commence or to be completed and it will be subject to a Development Consent Order. The Bedford to Cambridge stretch of East West Rail requires provision for a new rail line and is likely to be the most costly and complicated stretch of East West Rail to deliver. It is considered very unlikely that this stretch of East-West Rail will be delivered until the late 2030s at the earliest and therefore it is very unlikely that land to the north of Cambourne will be deliverable in the next 15 years at least.

As set out in the Cambourne Growth-Transport Vision and Principles Evidence Base Document, the residential growth in Cambourne North is situated to the north side of the railway. It is also proposed to build 3 road bridges and 2 active travel bridges across the new railway and A428 to connect to Cambourne. This major infrastructure will be complicated to deliver and it is not feasible for Cambourne North to be delivered until such time as the new rail line and station have been completed. The Cambourne Spatial Framework Strategy, prepared as an evidence based document to support the Local Plan, suggests that the First New Neighbourhood will be delivered between 2035–2040, with East-West Rail Station also opening in the same period. Accounting for the substantial uncertainty and major infrastructure required, it is plausible that delivery of the site could slip into the 2040s and the number of dwellings to be delivered as part of this plan period will be very limited. In this regard, the proposed 2,550 dwellings to be delivered in Cambourne North within this plan period is considered to be optimistic.

Conversely, Land to the South of Lower Cambourne can be delivered without the need for any significant infrastructure requirements and it provides a logical and very sustainable extension to the Town that can be delivered in the short to medium term (next 10 years). It would provide for a logical next phase of expansion to Cambourne, to supplement Cambourne West. North Cambourne would then be delivered in the longer term once East-West Rail is delivered.

The expansion of Cambourne is supported, however, due to the likely significant delays associated with the delivery of the East-West Rail station, additional growth should be allocated at Cambourne. Land to the South of Lower Cambourne would provide a natural extension to the settlement and could be delivered in the short term.

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Policy S/SH set out the Settlement Hierarchy. Cambourne is defined as a town in the settlement hierarchy, along with Waterbeach New Town and Northstowe. The settlement hierarchy is supported and it is considered appropriate for the Towns within Greater Cambridge Area to have their own position in the settlement hierarchy, rather than forming part of Rural Centres, which are less sustainable locations, with less services available.

Land to the South of Lower Cambourne should be allocated as part of the emerging Local Plan. It is a sound, sustainable and logical allocation for growth. The site has been supported by a Vision Document, an Access Appraisal, Landscape and Visual Assessment and Heritage Assessment, which demonstrate that is unconstrained in planning terms.

Policy S/CBN: Cambourne North sets out the proposed approach to the further expansion of Cambourne, taking account of the significant planned improvements to public transport in this area. The new settlement would include approximately 13,000 homes, 108,000 square metres of employment floorspace, with a range of supporting services and facilities.

As set out above, Cambourne is a highly sustainable location for growth and its expansion is strongly supported.

The delivery of Cambourne North is predicated on the delivery of a new train line and a new train station as part of East-West Rail. The second and third stages of East West Rail, from Oxford through to Bedford and Bedford to Cambridge are still in planning & feasibility stages, and are dependent on final government funding and approval.  Stage 1 of East-West Rail is currently under construction and services are due to commence between Oxford and Milton Keynes in 2026. Stage 2 will then extend services to Bedford as part of upgrades to the Marston Vale line by 2030. Accounting for the delays to stage 1 of East-West Rail, completion of the upgrades in stage 2 to Bedford by 2030 is considered to be optimistic and it is likely to be delayed. Stage 3, which is between Bedford and Cambridge, has no set timetable for construction works to commence or to be completed and it will be subject to a Development Consent Order. The Bedford to Cambridge stretch of East West Rail requires provision for a new rail line and is likely to be the most costly and complicated stretch of East West Rail to deliver. It is considered very unlikely that this stretch of East-West Rail will be delivered until the late 2030s at the earliest and therefore it is very unlikely that land to the north of Cambourne will be deliverable in the next 15 years at least.

As set out in the Cambourne Growth-Transport Vision and Principles Evidence Base Document, the residential growth in Cambourne North is situated to the north side of the railway. It is also proposed to build 3 road bridges and 2 active travel bridges across the new railway and A428 to connect to Cambourne. This major infrastructure will be complicated to deliver and it is not feasible for Cambourne North to be delivered until such time as the new rail line and station have been completed. The Cambourne Spatial Framework Strategy, prepared as an evidence based document to support the Local Plan, suggests that the First New Neighbourhood will be delivered between 2035–2040, with East-West Rail Station also opening in the same period. Accounting for the substantial uncertainty and major infrastructure required, it is plausible that delivery of the site could slip into the 2040s and the number of dwellings to be delivered as part of this plan period will be very limited. In this regard, the proposed 2,550 dwellings to be delivered in Cambourne North within this plan period is considered to be optimistic.

Conversely, Land to the South of Lower Cambourne can be delivered without the need for any significant infrastructure requirements and it provides a logical and very sustainable extension to the Town that can be delivered in the short to medium term (next 10 years). It would provide for a logical next phase of expansion to Cambourne, to supplement Cambourne West. North Cambourne would then be delivered in the longer term once East-West Rail is delivered.

The expansion of Cambourne is supported, however, due to the likely significant delays associated with the delivery of the East-West Rail station, additional growth should be allocated at Cambourne. Land to the South of Lower Cambourne would provide a natural extension to the settlement and could be delivered in the short term.

Our comments on this policy should be read in conjunction with our detailed comments on the Cambourne Growth Strategy (2025), which is an evidence based document to inform the location of growth, which we have submitted under the evidence base section.

Growth in Cambourne needs to be dispersed to include deliverable sites in the short to medium term. Land to the South of Lower Cambourne is a very sustainable and logical allocation for growth, that can be delivered in the short to medium term.

To support the current Preferred Options Consultation, the Greater Cambridge Shared Planning Service have published the Cambourne Growth Strategy (by Arup dated September 2025). This sets out a bold vision for Cambourne’s transformation into a sustainable, well-connected town of regional significance by 2060, creating a population of approximately 50,000 people. This document sets out that, anchored by the proposed East West Rail (EWR) station and the Cambourne to Cambridge Busway (C2C), it will become one of the best-connected locations in Cambridgeshire, enabling fast links to Cambridge and across the Oxford–Cambridge Arc. This sets out a clear Vision for Cambourne to become the third largest settlement in Cambridgeshire, after Cambridge and Peterborough. As set out above the principle of substantial expansion of Cambourne is strongly supported.

Evidence based documents prepared to support the Growth Strategy include the Cambourne Spatial Framework Strategy. Appendix A of the Spatial Framework Strategy is a Spatial Options Report (June 2025), which was undertaken to consider the most suitable way to expand Cambourne. A long list of appraisal options considered whether Cambourne should be expanded to the North, East, West, South, or combinations thereof. North was chosen as the preferred option.

Each option was subject to a high-level qualitative review against the following key drivers:
1. Alignment with transport connectivity
2. Capacity to accommodate scale of development in the long term
3. Deliverability

Growth to the south of Cambourne included both land within the land south of Lower Cambourne and land adjacent to the east. The option of developing to the south of Cambourne was discounted on two fronts. Firstly, its transport connectivity and secondly that only a limited proportion of growth can be delivered in Cambourne South.

In this regard, it is acknowledged that South of Cambourne cannot deliver 13,000 dwellings and 108,000 square metre of employment land proposed for allocation in the DLP alone. This is not considered to be a suitable reason to discount the option, which can make a valuable contribution to growth in Cambourne, when combined with other options. It is considered that the Spatial Options Paper places insufficient weight on the deliverability of land to the south of Cambourne and, unlike the other options, it can be delivered in the shorter to medium term, without the need for major infrastructure upgrades. In addition, it does not take into account wider spatial concerns raised in paragraphs 5.51 to 5.65 of this statement that the DLP is reliant on a very limited number of new settlements/urban extensions, many of which have deliverability constraints.

The option of delivering growth to both the north and the south of Cambourne was discounted on the basis that growth to the north performs better against the criteria than growth to the south. This conclusion is not considered to be sound and it is considered that the assessment of the suitability of delivering growth to both the north and south needs to be reassessed as the most suitable option for growth in Cambourne.

In respect of the growth option to the north, there is no acknowledgement within the Spatial Options Report assessment regarding the deliverability scoring for Cambourne North, that its implementation relies on the implementation of East-West Rail and substantial infrastructure upgrades associated with the delivery of 5 new bridges between Cambourne North and Cambourne. This is a clear and fundamental constraint to the delivery of housing and employment to the north of Cambourne, particularly given that the route and funding for East-West Rail (including delivery timetable) is not yet secured. In this regard, the benefits of delivering growth to Cambourne North, particularly in relation to its deliverability, are clearly overstated within the document.

Accounting for the deliverability issues associated with Cambourne North it is considered that there is a clear and compelling growth for some dispersal of growth to multiple options. This will reduce the reliance on all the growth being delivered via Cambourne North and substantially increase the prospects of Cambourne growing in the short to medium term (next 10-15 years), which will assist in meeting the aspirations of the Cambourne Growth Strategy.

In deliverability terms, the Spatial Options report appears to discount growth the south of Cambourne on the basis that it concludes there are infrastructure constraints in relation to transport connectivity and flooding need to be overcome. It also references that there is potentially higher heritage sensitivity, and that only a limited amount of growth is supported. It does acknowledge that there is a good opportunity to extend the guided busway into the growth area to the south. In this regard the flood risk constraints relate to land to the east of Land to the South of Lower Cambourne. The site subject to this representation is unconstrained in flood risk terms, and is situated solely within a flood zone 1. In heritage terms, this representation has been supported by a heritage assessment prepared by Iceni, and a Vision Document that demonstrate that the development can be delivered whilst protecting heritage assets, including Bourn Windmill to the south of the site. The Vision Document also demonstrates that suitable separation will be maintained between development in land to the south of Lower Cambourne and Bourn and Caxton.

The Spatial Options Report does not reference that growth to the south of Cambourne can be delivered in the short to medium term without the need for East-West Rail or major infrastructure improvements. This is a substantial benefit of Cambourne South that has not been adequately acknowledged in the deliverability section of Spatial Options Report. Therefore, in order to be sound, it is imperative that the respective deliverability merits of Cambourne North and Cambourne South are reassessed to provide a sound evidence base and a justified conclusion.

In addition, the conclusion of Cambourne South in respect of transport connectivity also needs to be reassessed. It appears that the fundamental reason for discounting Cambourne south is that in the longer term EWR will be likely to be located to the north of the A428. Whilst it is acknowledged that EWR is an important factor, it should not be only determinant for further growth in Cambourne particularly as it is not yet a fully committed scheme. Aside from the deliverability issues set out above, provision for 13,000 dwellings to the north of Cambourne is going to be slow to deliver and multiple allocations around the town will have significant benefits in providing choice and competition for market land and boosting housing supply.

The report concludes that the expansion to the south of Cambourne has ‘poor alignment with sustainable transport connectivity.’ This conclusion is considered to be flawed and it is inconsistent with the remainder of the document, which acknowledges that growth to the south would still have moderate connectivity to EWR and good connectivity to the guided busway.

The report also sets out that there would be a good opportunity to extend the guided busway into the south Cambourne growth area, which would further enhance the sustainability credentials of directing growth to the south of Cambourne.

When considering the merits of dispersing growth, it is also important to recognise that the train station and guided busway will provide connectivity to different locations and areas of Cambridge. New homes to the south of Cambourne would have easier connections to the guided busway than homes in North Cambourne and this could provide more sustainable links for those wanting to access the substantial employment opportunities within West Cambridge Employment Hub and Life-Sciences Campus. The guided busway will provide six trains an hour to Cambridge City and Cambridge West Employment Site, which is a significant benefit in transport connectivity terms. The guided busway will also likely be in place well in advance of any new EWR station. As a result, development to the south of Cambourne is a highly sustainable option.

As set out within the Access Appraisal, prepared by Hub, and the Vision Document that support this representation, the development will have the ability to provide both bus services and cycle routes from the site to Cambourne Town Centre and EWR.

Conclusion on Cambourne Spatial Options Paper

For the reasons set out above, expansion to the south of Cambourne should be planned for, either as a stand-alone extension to the settlement, or in combination with development in another direction. As detailed in the submitted documents and plans, Land South of Lower Cambourne is unconstrained and could provide a highly sustainable extension to Cambourne. As acknowledged in the Spatial Options Report:

‘delivery across two separate areas could create benefits by spreading impacts of phasing and construction if planned correctly and in a coordinated fashion’.

The benefit of developing multiple areas is considered to be underestimated in the document, particularly in the deliverability section and this is considered to clearly be the preferred option for growth. This needs to be reassessed and it is considered that provision of new development both to the north and south of Cambourne, would have substantial benefits in sustainability terms and boosting housing supply in the short term, and that it is clearly the most suitable option when considered against the alternatives.