Draft Greater Cambridge Local Plan for consultation

If the policy is to retain a section setting out the housing requirement for neighbourhood areas, then an additional section should be added to include provision for housing in areas that are not neighbourhood plan areas. This could set out projected growth in other villages within the hierarchy and offer a greater structure to growth across the district.

We would request that the policy includes for growth in the village of Great Abington, a location that Is not a designated neighbourhood area, and that the level of growth is proportionate to the existing settlement and responds to the availability of suitable sites.

We are writing on behalf of our client, Rosconn Group, with regard to Site: 115179 (HELAA Site: 40256) known as Land North of Pampisford Road, Great Abington. Our client wishes to OBJECT to Policy S/JH for the following reasons:

Firstly, policy S/JH should be read in conjunction with Policy S/DS, to which our clients have also raised an objection. The two policies are clearly interlinked and provide the overarching policy structure for future growth in the Greater Cambridge area.

While there is support for the objectives of the policy to deliver the objectively assessed housing need, given the scale of the new homes required at a minimum of 48,195 new homes, the proposed distribution of this growth and the over reliance on large sites, will undoubtedly result in a failure to deliver the step change in housing supply required by the NPPF, particularly in the short and medium term. This continues a trend within Greater Cambridgeshire that has stifled growth across the wider district to the detriment of those communities.

The draft plan seeks to address this matter through identifying levels of growth to be delivered within designated Neighbourhood Plan Areas. However, this is a superficial concession to the need to bring forward a range of sites include smaller and medium sized sites under para 73 of the NPPF.

We would contend that the plan should not rely upon Neighbourhood Plans coming forward as set in S/JH (5), as this limits growth to those areas that have been designated and are bringing forward, or are reviewing an existing Neighbourhood Plan. This therefore limits the geographical location and range of sites that can be delivered through this approach. We would argue the plan fails to tackle this issue directly by leading through example and would recommend that the plan directly allocate more smaller and medium sized sites, especially where there is no Neighbourhood Plan.

Furthermore, as set out in the policy commentary at paragraph 2.22, the Planning Practice Guidance makes clear that housing requirements for designated neighbourhood areas cannot be binding, as Neighbourhood Plans are not required to plan for housing. Therefore, whilst the LPA has assessed housing requirements for the 27 designated Neighbourhood Plan areas, there is no mechanism to ensure that this identified need will be met.

We would encourage the LPA to revisit the Housing and Employment Land Availability Assessment and examine the availability of deliverable sites adjoining existing sustainable settlements. Such sites can make a positive contribution to the proportional growth of villages which will help to maintain the viability of existing services.

For example, Great Abington is a sustainable settlement, sitting at the heart of the Rural Southern Cluster adjacent to major business park and employment area of Granta Park, but it is not designated a Neighbourhood Plan Area and therefore does not have a Neighbourhood Plan in place, nor has one been advanced. The Former Land Settlement Association Estate is designated and has an adopted Neighbourhood Plan, and the housing requirement in Appendix D is only for 5 dwellings. The key issue is that there is no mechanism for growth which is essential for maintaining the vitality and viability of the existing settlement.

A Housing Affordability & Productivity report (June 2025) was undertaken by Homes England to assess the role of housing affordability in the context of economic growth and productivity. The report concludes that industrial clusters are important for driving productivity growth, however these clusters rely on local conditions. It was found that the industrial clusters which are responsible for driving productivity growth of a region, such as life sciences in Cambridge are place-based. They require the right local conditions to grow, which includes having access to the right talent which in turn requires affordable housing to be available to workers. The case study analysis also found that building houses in locations where there are growing industrial clusters that benefit from agglomeration effects is important. Analysis showed that productivity growth of key sectors is linked to increased inward migration, which leads to greater housing demand and a reduction in affordability.

The lack of availability for affordable housing could constrain the future expansion of the sectors and future productivity growth. Within the case study analysis, it was highlighted by stakeholders that the level of availability of housing was a key factor in whether businesses decided to relocate or stay in the area. It was noted that when housing availability was low, it was difficult to recruit skilled workers which could constrain future growth. It was concluded that building more homes in areas with growing sectors benefitting from agglomeration effects could support future growth. There therefore needs to be the delivery of affordable housing within close proximity to employment hubs.

The Greater Cambridge Growth Sectors Study (September 2024) prepared by Iceni identifies that Greater Cambridge has one of the least affordable housing markets in the country. The delivery of new housing is perceived as not keeping pace with employment growth – demand for housing is outstripping supply. The report highlights the requirement for affordable housing within easy access to workplaces is important to attract and retain workers across all sectors. Although workers in high paying roles can achieve home ownership, there are a diverse range of roles across the sectors including technical and entry level which need to be catered for.

The allocation of Grange Farm New Settlement will no doubt be argued as addressing the needs of the neighbouring settlements, but that is the long term prognosis, not the short or medium term, with the new settlement likely to take 7 to 10 years to start delivering the new homes needed to support the continued growth of employment at places like Granta Park and the Babraham research Campus.

The LPA should take a more proportionate approach to growth and directly allocate a greater number and range of small and medium sites, particularly around areas of planned employment growth.

Our client’s site at Land North of Pampisford Road is situated on the edge of Great Abington (Site Id: 115179) is an ideal candidate for allocation to meet this need in the short term. This is a medium sized greenfield site which can accommodate approximately 40 dwellings and is in a sustainable location on the edge of the settlement. The HELAA Site Assessment (Site 40256) identified that the “Development of the site has some potential policy constraints, but these could be overcome through the planning application process.” The assessment also acknowledged that there is “Adequate accessibility to key local services, transport, and employment opportunities. Proposed development would not require delivery of accompanying key services.”

The HELAA supports our contention that this site is suitable, available, and achievable, and therefore deliverable. We contend that the site should be allocated to assist the LPA with meeting the aims of Policy S/JH. The site also has the benefit of being able to be built out quickly and so can make an early contribution towards meeting the housing needs of Greater Cambridgeshire.

The site is also in close proximity to the Granta Park life sciences development, and would provide much needed housing, including affordable housing, for employees working at Granta Park in a range of occupations.

In conclusion, Policy S/JH will exacerbate the delays in the delivery of housing and for that reason this policy is not justified, as it is not the appropriate strategy taking into account the alternatives, and will not be effective, failing to deliver the minimum level of growth over the plan period. The plan is therefore not sound, contrary to para 36 of the NPPF.

Under point 2 e, In the rest of the rural area, the policy could be amended to recognise the role that villages play in close proximity to key employment centres such as Granta Park, and introduce a policy supporting growth in these locations to support the growth of these important employment areas; villages such as Great Abington that adjoins Granta Park.

Alternatively, under point 3, the policy could be amended, or an entirely new policy could be added to include for growth in Group Villages, or allocate development to support the economic growth of those areas not covered by the current strategy. If this policy is amended to facilitate growth in Group Villages, the Settlement Hierarchy policy and Development Extents policy, need to be altered to facilitate growth.

As we have highlighted, our clients’ site at Land North of Pampisford Road is situated on the edge of Great Abington (Site Id: 115179) and is an ideal candidate for allocation through a change in policy.

We are writing on behalf of our client, Rosconn Group, with regard to Site: 115179 (HELAA Site: 40256) known as Land North of Pampisford Road, Great Abington. Our client wishes to OBJECT to Policy S/DS for the following reasons:

Firstly, policy S/DS should be read in conjunction with Policy S/JH, to which our clients have also raised an objection. The two policies are clearly interlinked and provide the overarching policy structure for future growth in the Greater Cambridge area.

The proposed Development Strategy is over reliant on large scale allocations. There is a failure to consider the need to distribute growth more proportionally across a range of sites throughout Greater Cambridge. The significant reliance on large scale allocations to deliver housing numbers is a risky strategy when compared to the alternatives, because such sites take longer to set up and start delivering new homes. Should this occur, it will be very difficult to maintain the delivery rates as set out in the LPAs housing trajectory in the short to medium term where there is already an over reliance on the existing new settlements delivering housing at the very optimum level every single year without fail. As recognised in paragraph 73 of the NPPF small and medium sized sites can make an important contribution to meeting the housing requirement of an area, are essential for Small and Medium Enterprise housebuilders to deliver new homes and are often built out relatively quickly.

By including a greater number of small and medium size sites in the development strategy there is a better chance of the strategy meeting the housing needs, particularly in the short to medium term, and reducing the risk of the LPA falling below its’s 5-year land supply requirement. We would contend that the Development Strategy should be amended to support a more proportional distribution of growth across Greater Cambridgeshire so that all areas can benefit from growth which will contribute towards the vitality and viability of existing services.

For example, Great Abington is a sustainable settlement, sitting at the heart of the Rural Southern Cluster adjacent to major business park and employment area of Granta Park, but it is not designated a Neighbourhood Plan Area and therefore does not have a Neighbourhood Plan in place, nor has one been advanced. The Former Land Settlement Association Estate is designated and has an adopted Neighbourhood Plan, and the housing requirement in Appendix D is only for 5 dwellings. The key issue is that there is no mechanism for growth which is essential for maintaining the vitality and viability of the existing settlement.

The allocation of Grange Farm New Settlement will no doubt be argued as addressing the needs of the neighbouring settlements, but that is the long term prognosis, not the short or medium term, with the new settlement likely to take 7 to 10 years to start delivering the new homes needed to support the continued growth of employment at places like Granta Park and the Babraham research Campus.

NPPF Paragraph 85 states that significant weight should be placed on the need to support economic growth and productivity, taking into account both local business needs and wider opportunities for development. NPPF Paragraph 86 states that planning policies should seek to address potential barriers to investment, such as inadequate infrastructure, services or housing. Therefore, if the Plan does not address the inadequate provision of housing around the employment sites it will not be consistent with the NPPF.

A Housing Affordability & Productivity report (June 2025) was undertaken by Homes England to assess the role of housing affordability in the context of economic growth and productivity. The report concludes that industrial clusters are important for driving productivity growth, however these clusters rely on local conditions. It was found that the industrial clusters which are responsible for driving productivity growth of a region, such as life sciences in Cambridge are place-based. They require the right local conditions to grow, which includes having access to the right talent which in turn requires affordable housing to be available to workers. The case study analysis also found that building houses in locations where there are growing industrial clusters that benefit from agglomeration effects is important. Analysis showed that productivity growth of key sectors is linked to increased inward migration, which leads to greater housing demand and a reduction in affordability.

The lack of availability for affordable housing could constrain the future expansion of the sectors and future productivity growth. Within the case study analysis, it was highlighted by stakeholders that the level of availability of housing was a key factor in whether businesses decided to relocate or stay in the area. It was noted that when housing availability was low, it was difficult to recruit skilled workers which could constrain future growth. It was concluded that building more homes in areas with growing sectors benefitting from agglomeration effects could support future growth. There therefore needs to be the delivery of affordable housing within close proximity to employment hubs.

The Greater Cambridge Growth Sectors Study (September 2024) prepared by Iceni identifies that Greater Cambridge has one of the least affordable housing markets in the country. The delivery of new housing is perceived as not keeping pace with employment growth – demand for housing is outstripping supply. The report highlights the requirement for affordable housing within easy access to workplaces is important to attract and retain workers across all sectors. Although workers in high paying roles can achieve home ownership, there are a diverse range of roles across the sectors including technical and entry level which need to be catered for.

The LPA should take a more proportionate approach to growth and directly allocate a greater number and range of small and medium sites, particularly around areas of planned employment growth.

Our client’s site at Land North of Pampisford Road is situated on the edge of Great Abington (Site Id: 115179) is an ideal candidate for allocation to meet this need in the short term. This is a medium sized greenfield site which can accommodate approximately 40 dwellings and is in a sustainable location on the edge of the settlement. The HELAA Site Assessment (Site 40256) identified that the “Development of the site has some potential policy constraints, but these could be overcome through the planning application process.” The assessment also acknowledged that there is “Adequate accessibility to key local services, transport, and employment opportunities. Proposed development would not require delivery of accompanying key services.”

The HELAA supports our contention that this site is suitable, available, and achievable, and therefore deliverable. We contend that the site should be allocated to assist the LPA with meeting the aims of the Development Strategy. The site also has the benefit of being able to be built out quickly and so can make an early contribution towards meeting the housing needs of Greater Cambridgeshire.

The site is also in close proximity to the Granta Park life sciences development, and would provide much needed housing, including affordable housing, for employees working at Granta Park in a range of occupations.

In conclusion, Policy S/DS will exacerbate the delays in the delivery of housing and for that reason this policy is not justified, as it is not the appropriate strategy taking into account the alternatives, and will not be effective, failing to deliver the minimum level of growth over the plan period. The plan is therefore not sound, contrary to para 36 of the NPPF.

The Council is encouraged to revisit the assessment of Development Extents and to consider adjustment to facilitate growth, or preferably to allocate additional development. As we have highlighted this policy is designed to constrain growth, contrary to the objectives of the Settlement Hierarchy polices which infer growth is possible.

We would recommend that the Council amend the policy to accord with the emerging NPPF policy S5, as set out above. Or provide an independent policy structure that allows for sustainable growth beyond the Development Extents, where a site adjoins the settlement.

Please also see our comments on policy S/SH.

We are writing on behalf of our client, Rosconn Group, with regard to Site: 115179 (HELAA Site: 40256) known as Land North of Pampisford Road, Great Abington. Our client wishes to OBJECT to Policy S/DE for the following reasons:

Objection is raised to this policy in conjunction with our client’s objection to policy S/JH. As the policy does not facilitate development outside of a Defined Development Extent unless it is allocated within a Neighbourhood Plan or meets a very narrow range of exceptions.

As we stated in our objections to policy S/JH, we would contend that the plan should not rely upon Neighbourhood Plans coming forward as this limits growth to those areas that have been designated and are bringing forward or are reviewing an existing Neighbourhood Plan. This limits the geographical location and range of sites that can be delivered through this approach. We would argue the plan fails to tackle this issue directly by leading through example and would recommend that the plan directly allocate more smaller and medium sized sites, especially where there is no Neighbourhood Plan. Furthermore, the Planning Practice Guidance makes clear that housing requirements for designated neighbourhood areas cannot be binding, as Neighbourhood Plans are not required to plan for housing.

Development Extents are usually very tightly drawn around existing settlements, leaving very little room for growth within the settlement itself, so when coupled with the limitations of growth within the Settlement Hierarchy under Policy S/SH, the policy leaves little scope for development on suitable small and medium sized sites on the edge of existing settlements. This constraint undermines the positive contribution such sites can make to the proportional growth of villages, which will help to maintain the viability of existing services.

Mindful of the changing landscape of national policy, we would argue that this policy is not consistent with emerging Policy S5 (Principle of Development Outside Settlements) that is proposed in the revised National Planning policy Framework. The revised text has a much more holistic set of criteria for facilitating development outside of defined development frameworks, particularly where there is a shortfall in supply. We would encourage the LPA to adopt this approach and amend Policy S/DE so that it is in line with emerging Policy S5 rather than simply relying on the NPPF as being a material consideration.

In particular, the LPA should consider adopting the criteria of Policy S5 paragraph j which relates to addressing evidenced unmet need (including where an LPA cannot demonstrate a five year supply of deliverable housing sites) by supporting development which would be well related to an existing settlement and of an appropriate scale. This would be a more proactive approach which would enable the Development Plan to be more responsive in addressing unmet need, which is something the current Local Plan is failing to achieve.

In conclusion, Policy S/DE is not justified, as it is not the appropriate strategy taking into account the alternatives, and will not be effective, failing to deliver the minimum level of growth over the plan period. The plan is therefore not sound, contrary to para 36 of the NPPF.

The Council is encouraged to remove the arbitrary limitations for the scale of development that might take place in Group Villages. If they are to be maintained then they should be greatly increased, as a limitation of 8 dwellings in a village such as Great Abington is not justified.

We would argue that the limitations applied to other settlements in the hierarchy should also be removed. As all sites should be evaluated on their own merit against an assessment of site sustainability and the capacity of existing facilities and services to accommodate growth. Arbitrary limits on development are inconsistent with Government policy on promoting a step change in growth.

Furthermore, please see our comments on policy S/DE. If limits are to be retained, subject to their justification, then the spatial limitations placed on settlements by the Development Extents effectively make the policy redundant, as if there is no space to grow inside the defined extent of the settlement, then the village will stagnate. Harming its long-term vitality and viability.

It remains our preference, that the Local Plan should tackle growth in a more proportionate manner, and we would suggest that where there is no neighbourhood area, the plan properly examines growth in those villages and directly allocates sites for development. Great Abington is a Group Village but not a Neighbourhood Area, and yet it sits adjacent to Granta Park, a major employment area, and is a sustainable location for development that can support economic growth at this important employment site. As we have highlighted, our clients’ site at Land North of Pampisford Road is situated on the edge of Great Abington (Site Id: 115179) and is an ideal candidate for allocation through a change in policy.

We are writing on behalf of our client, Rosconn Group, with regard to Site: 115179 (HELAA Site: 40256) known as Land North of Pampisford Road, Great Abington. Our client wishes to OBJECT to Policy S/SH for the following reasons:

While there is a need for policies that set out and inform the appropriate level of growth within a defined settlement hierarchy, our client objects to the limitations of growth placed on the village of Great Abington under S/SH (9) and (10). This policy does not positively support growth in sustainable locations. The range of services and facilities across the ‘Group Villages@ varies, particularly in respect of access jobs and employment. Great Abington has the benefit of close proximity to Granta Park, as well as sustainable transport links to a secondary school and medical facilities. The limitation being applied is too generalised and does not recognise the unique individual merits of certain locations.

Furthermore, to limit the number of homes deliverable within the ‘development extent’ of the village is largely irrelevant if the defined ‘extent’ is so tightly drawn as to leave nothing within that village that could be developed. This approach is argued as a positively framed policy but in practice will continue to constrain growth in a village like Great Abington, that is highly sustainable, to the detriment of its vitality and viability and the contribution and support it could offer in the short term to the growth of Granta Park.

In conclusion, Policy S/SH is not justified, as it is not the appropriate strategy taking into account the alternatives, and will not be effective, failing to deliver the minimum level of growth over the plan period. The plan is therefore not sound, contrary to para 36 of the NPPF.