Draft Greater Cambridge Local Plan for consultation

Places for People 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.

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. It is important that level of growth and housing allocations reflect the Vision for Greater Cambridge as set out in the DLP.

PfP supports a vision focused on:
• A net‑zero future through low‑carbon, climate‑responsive development.
• Nature‑rich places delivering strong biodiversity gains.
• Compact, well‑connected communities focused on sustainable travel.
• Healthy, high‑quality neighbourhoods with excellent design and green space.
• A balanced housing mix meeting diverse local needs.
• A thriving innovation economy supported by homes and infrastructure.
• Resilient water systems addressing scarcity and integrating SuDS.
• Protected landscapes and heritage shaping high‑quality growth.
• Infrastructure aligned with growth, including transport and community facilities.
• Vibrant villages and centres strengthened by improved services and access.

Land to the north and west of Wilbraham Road, Fulbourn aligns with these objectives and can deliver a development that reflects the distinctive character of Fulbourn while contributing to the wider needs of Greater Cambridge.

Substantially higher growth is required to align with the governments and the CA growth aspirations for Cambridge and accounting for the substantial employment and job growth.

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 2 in the attached document).



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, 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 National Planning Policy Guidance 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 and within sustainable village such as Fulbourn 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 currently 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
4.44 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.

Part 1 of the policy should be revised to refer to 'Well Connected Minor Rural Centres' and include the allocation of land to the north and west of Wilbraham Road, Fulbourn as a sustainable mixed use allocation to delivery over 2,500 dwellings.

Policy S/DS and Policy S/SH need to be considered in conjunction in that Policy S/SH sets out the proposed settlement hierarchy for the plan, which then informs the locations for growth as set out in Policy S/DS.

Draft Policy S/SH identifies Fulbourn is identified as a Minor Rural Centre, along with the settlements of Bar Hill, Bassingbourn, Comberton, Cottenham, Gamlingay, Girton, Linton, Melbourn, Milton, Papworth Everard, Swavesey, Waterbeach and Willingham.

Minor Rural Centres are described as follows:
‘Minor rural service centres have a lower level of services and facilities and employment than rural centres, but a greater level than most other settlements in Greater Cambridge and often perform a role in terms of providing services and facilities for a small rural hinterland’

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 and Policy S/SH

No objection is raised to the five suggested locations for growth in the District as set out in Policy S/DS. However, it is not considered necessary to put them in an order of preference, given that different development in different locations will all contribute to meet the housing and development needs for the area. For example, growth in Cambourne and within Rural Centres and Minor Rural Centres will be particularly important to ensure choice and competition for market land and it will provide in many instances more affordable private housing for those unable to afford to live in Cambridge City or those that would prefer a village location. In this regard, it is considered important for sustainable and well connected villages such as Fulbourn to accommodate a suitable proportion of growth.

In terms of the size, the proposed minor rural service centres are logical, however this is considered to provide an over- simplistic approach and does not take into account the location of each settlement, which have contrasting sustainability and connectivity credentials. For example, Fulbourn benefits from being situated in very close proximity to Cambridge City and it is accessible both by cycle and a short bus journey to the city and to the major employment opportunities at Capital Park and Peterhouse Technology Park and Cambridge Bio- Medical Campus.

Land to the north and west of Wilbraham Road, Fulbourn also provides a unique opportunity to facilitate the re- opening of Fulbourn Train Station, which would have substantial benefits in terms of reducing car trips into Cambridge both for existing and new residents in the area and it will ensure a coordinated approach between housing and infrastructure delivery. It would also align with the objectives of the Cambridgeshire Local Growth Plan (2025), which refers to the aspiration to increase capacity along the line to the east of Cambridge (between Cambridge and Newmarket). This could include provision for the introduction of the Snailwell Loop around Newmarket, which would increase the capacity and frequency of train provision.

The settlements of Gamlingay, Bassingbourn and Papworth Everard are situated in relatively remote locations with relatively poor transport connectivity and they are clearly not as a sustainable option for growth when compared to settlements such as Fulbourn.

It is therefore considered that the settlement hierarchy and development strategy needs to be reassessed and additional sub-category should be added to include ‘Well Connected Minor Rural Centres. Settlements such as Fulbourn, Milton, Melbourn and Waterbeach would be appropriate settlements for this category and they should clearly be preferable to the less sustainable minor rural centres, such as Gamlingay, Bassingbourn and Papworth Everard.

The following re- wording of Policy S/DS is suggested:
Policy S/DS: Development Strategy, sets out that the vast majority of jobs and homes will be met in the following locations:
f) Within the Cambridge Area
g) On the outer edge of Cambridge
h) At an expanded Cambourne
i) At other new settlements
j) In Rural Centres and Well Connected Minor Rural Centres
More limited level of growth will be facilitated in other Minor Rural Centres and in the southern rural cluster

Policy S/SH should be amended to identify Fulbourn, Milton, Melbourn and Waterbeach as well connected Minor Rural Centres. These amendments are required to ensure that the plan adequately responds to the sustainability credentials of well-connected minor rural services and would provide the most appropriate strategy when considered against the alternatives. This approach would be sound and in accordance with national policy.

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 8,350 dwellings and 350,000m2 of employment space
• Cambridge East (Marshalls Airport) – allocated for 8,000 dwellings and 20,000m2 employment space
• Cambourne North – allocated for 13,000 dwellings and 108,00m2 employment space
• Grange Farm Little Abington – allocated for 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. Whilst no objection is raised to delivering growth via larger strategic sites in principle, for reasons explained in this section of this report, the very limited number of sites allocated 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.
4.67 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, if even one of these sites is delayed it will result in the Shared Planning Service being unable to maintain a 5 year housing land supply. This does not align with the NPPF’s objectives to significantly boost housing land supply. This should be addressed by the allocation of deliverable sites, such as land to the land to the north and west of Wilbraham Road, Fulbourn, which is of a strategic scale and can provide a very substantial contribution to housing supply and it will also provide choice and competition for market land, in a location not currently allocated for growth.

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 north and west of Wilbraham Road, Fulbourn, 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.

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.

The lack of certainty regarding the delivery of Cambourne North, further strengthens arguments as set out above that additional strategic sites such as land to the north and west of Wilbraham Road, Fulbourn should be allocated to boost housing supply and safeguard against the delay to delivery of the proposed allocated sites.

Overall, it is clear that allocation of land to the north and west of Wilbraham Road, Fulbourn will provide a number of benefits in terms of boosting housing supply, providing additional choice and competition of allocated sites to safeguard against slow delivery and to ensure that development is directed to the most sustainable locations. Its allocation is required in order for the plan to be positively prepared, justified, and effective having regard to the tests of soundness as set out within the NPPF.

Policy S/SH should be amended to introduce a new category in the settlement of Well Connected Minor Rural Centres to include Fulbourn, Milton, Melbourn and Waterbeach, which should be higher in the settlement hierarchy than the other Minor Rural Centres.

Policy S/DS and Policy S/SH need to be considered in conjunction in that Policy S/SH sets out the proposed settlement hierarchy for the plan, which then informs the locations for growth as set out in Policy S/DS.

Draft Policy S/SH identifies Fulbourn is identified as a Minor Rural Centre, along with the settlements of Bar Hill, Bassingbourn, Comberton, Cottenham, Gamlingay, Girton, Linton, Melbourn, Milton, Papworth Everard, Swavesey, Waterbeach and Willingham.

Minor Rural Centres are described as follows:

‘Minor rural service centres have a lower level of services and facilities and employment than rural centres, but a greater level than most other settlements in Greater Cambridge and often perform a role in terms of providing services and facilities for a small rural hinterland’

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 and Policy S/SH

No objection is raised to the five suggested locations for growth in the District as set out in Policy S/DS. However, it is not considered necessary to put them in an order of preference, given that different development in different locations will all contribute to meet the housing and development needs for the area. For example, growth in Cambourne and within Rural Centres and Minor Rural Centres will be particularly important to ensure choice and competition for market land and it will provide in many instances more affordable private housing for those unable to afford to live in Cambridge City or those that would prefer a village location. In this regard, it is considered important for sustainable and well connected villages such as Fulbourn to accommodate a suitable proportion of growth.

In terms of the size, the proposed minor rural service centres are logical, however this is considered to provide an over- simplistic approach and does not take into account the location of each settlement, which have contrasting sustainability and connectivity credentials. For example, Fulbourn benefits from being situated in very close proximity to Cambridge City and it is accessible both by cycle and a short bus journey to the city and to the major employment opportunities at Capital Park and Peterhouse Technology Park and Cambridge Bio- Medical Campus.
4.59 Land to the north and west of Wilbraham Road, Fulbourn also provides a unique opportunity to facilitate the re- opening of Fulbourn Train Station, which would have substantial benefits in terms of reducing car trips into Cambridge both for existing and new residents in the area and it will ensure a coordinated approach between housing and infrastructure delivery. It would also align with the objectives of the Cambridgeshire Local Growth Plan (2025), which refers to the aspiration to increase capacity along the line to the east of Cambridge (between Cambridge and Newmarket). This could include provision for the introduction of the Snailwell Loop around Newmarket, which would increase the capacity and frequency of train provision.

The settlements of Gamlingay, Bassingbourn and Papworth Everard are situated in relatively remote locations with relatively poor transport connectivity and they are clearly not as a sustainable option for growth when compared to settlements such as Fulbourn.

It is therefore considered that the settlement hierarchy and development strategy needs to be reassessed and additional sub-category should be added to include ‘Well Connected Minor Rural Centres. Settlements such as Fulbourn, Milton, Melbourn and Waterbeach would be appropriate settlements for this category and they should clearly be preferable to the less sustainable minor rural centres, such as Gamlingay, Bassingbourn and Papworth Everard.

The following re- wording of Policy S/DS is suggested:
Policy S/DS: Development Strategy, sets out that the vast majority of jobs and homes will be met in the following locations:
f) Within the Cambridge Area
g) On the outer edge of Cambridge
h) At an expanded Cambourne
i) At other new settlements
j) In Rural Centres and Well Connected Minor Rural Centres
More limited level of growth will be facilitated in other Minor Rural Centres and in the southern rural cluster

Policy S/SH should be amended to identify Fulbourn, Milton, Melbourn and Waterbeach as well connected Minor Rural Centres. These amendments are required to ensure that the plan adequately responds to the sustainability credentials of well-connected minor rural services and would provide the most appropriate strategy when considered against the alternatives. This approach would be sound and in accordance with national policy.

Remove NEC as an allocation from the Local Plan or make revisions to the policy as suggested.

Policy S/DS and Policy S/SH need to be considered in conjunction in that Policy S/SH sets out the proposed settlement hierarchy for the plan, which then informs the locations for growth as set out in Policy S/DS.

Draft Policy S/SH identifies Fulbourn is identified as a Minor Rural Centre, along with the settlements of Bar Hill, Bassingbourn, Comberton, Cottenham, Gamlingay, Girton, Linton, Melbourn, Milton, Papworth Everard, Swavesey, Waterbeach and Willingham.

Minor Rural Centres are described as follows:
‘Minor rural service centres have a lower level of services and facilities and employment than rural centres, but a greater level than most other settlements in Greater Cambridge and often perform a role in terms of providing services and facilities for a small rural hinterland’

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 and Policy S/SH

No objection is raised to the five suggested locations for growth in the District as set out in Policy S/DS. However, it is not considered necessary to put them in an order of preference, given that different development in different locations will all contribute to meet the housing and development needs for the area. For example, growth in Cambourne and within Rural Centres and Minor Rural Centres will be particularly important to ensure choice and competition for market land and it will provide in many instances more affordable private housing for those unable to afford to live in Cambridge City or those that would prefer a village location. In this regard, it is considered important for sustainable and well connected villages such as Fulbourn to accommodate a suitable proportion of growth.

In terms of the size, the proposed minor rural service centres are logical, however this is considered to provide an over- simplistic approach and does not take into account the location of each settlement, which have contrasting sustainability and connectivity credentials. For example, Fulbourn benefits from being situated in very close proximity to Cambridge City and it is accessible both by cycle and a short bus journey to the city and to the major employment opportunities at Capital Park and Peterhouse Technology Park and Cambridge Bio- Medical Campus.

Land to the north and west of Wilbraham Road, Fulbourn also provides a unique opportunity to facilitate the re- opening of Fulbourn Train Station, which would have substantial benefits in terms of reducing car trips into Cambridge both for existing and new residents in the area and it will ensure a coordinated approach between housing and infrastructure delivery. It would also align with the objectives of the Cambridgeshire Local Growth Plan (2025), which refers to the aspiration to increase capacity along the line to the east of Cambridge (between Cambridge and Newmarket). This could include provision for the introduction of the Snailwell Loop around Newmarket, which would increase the capacity and frequency of train provision.

The settlements of Gamlingay, Bassingbourn and Papworth Everard are situated in relatively remote locations with relatively poor transport connectivity and they are clearly not as a sustainable option for growth when compared to settlements such as Fulbourn.

It is therefore considered that the settlement hierarchy and development strategy needs to be reassessed and additional sub-category should be added to include ‘Well Connected Minor Rural Centres. Settlements such as Fulbourn, Milton, Melbourn and Waterbeach would be appropriate settlements for this category and they should clearly be preferable to the less sustainable minor rural centres, such as Gamlingay, Bassingbourn and Papworth Everard.

The following re- wording of Policy S/DS is suggested:
Policy S/DS: Development Strategy, sets out that the vast majority of jobs and homes will be met in the following locations:
f) Within the Cambridge Area
g) On the outer edge of Cambridge
h) At an expanded Cambourne
i) At other new settlements
j) In Rural Centres and Well Connected Minor Rural Centres
More limited level of growth will be facilitated in other Minor Rural Centres and in the southern rural cluster

Policy S/SH should be amended to identify Fulbourn, Milton, Melbourn and Waterbeach as well connected Minor Rural Centres. These amendments are required to ensure that the plan adequately responds to the sustainability credentials of well-connected minor rural services and would provide the most appropriate strategy when considered against the alternatives. This approach would be sound and in accordance with national policy.

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 8,350 dwellings and 350,000m2 of employment space
• Cambridge East (Marshalls Airport) – allocated for 8,000 dwellings and 20,000m2 employment space
• Cambourne North – allocated for 13,000 dwellings and 108,00m2 employment space
• Grange Farm Little Abington – allocated for 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. Whilst no objection is raised to delivering growth via larger strategic sites in principle, for reasons explained in this section of this report, the very limited number of sites allocated 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.
4.67 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, if even one of these sites is delayed it will result in the Shared Planning Service being unable to maintain a 5 year housing land supply. This does not align with the NPPF’s objectives to significantly boost housing land supply. This should be addressed by the allocation of deliverable sites, such as land to the land to the north and west of Wilbraham Road, Fulbourn, which is of a strategic scale and can provide a very substantial contribution to housing supply and it will also provide choice and competition for market land, in a location not currently allocated for growth.

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 north and west of Wilbraham Road, Fulbourn, 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.

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.

The lack of certainty regarding the delivery of Cambourne North, further strengthens arguments as set out above that additional strategic sites such as land to the north and west of Wilbraham Road, Fulbourn should be allocated to boost housing supply and safeguard against the delay to delivery of the proposed allocated sites.

Overall, it is clear that allocation of land to the north and west of Wilbraham Road, Fulbourn will provide a number of benefits in terms of boosting housing supply, providing additional choice and competition of allocated sites to safeguard against slow delivery and to ensure that development is directed to the most sustainable locations. Its allocation is required in order for the plan to be positively prepared, justified, and effective having regard to the tests of soundness as set out within the NPPF.

Include additional small-to-medium allocations in the Local Plan to offset any delivery issues for Cambridge East.

Policy S/DS and Policy S/SH need to be considered in conjunction in that Policy S/SH sets out the proposed settlement hierarchy for the plan, which then informs the locations for growth as set out in Policy S/DS.

Draft Policy S/SH identifies Fulbourn is identified as a Minor Rural Centre, along with the settlements of Bar Hill, Bassingbourn, Comberton, Cottenham, Gamlingay, Girton, Linton, Melbourn, Milton, Papworth Everard, Swavesey, Waterbeach and Willingham.

Minor Rural Centres are described as follows:
‘Minor rural service centres have a lower level of services and facilities and employment than rural centres, but a greater level than most other settlements in Greater Cambridge and often perform a role in terms of providing services and facilities for a small rural hinterland’

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 and Policy S/SH

No objection is raised to the five suggested locations for growth in the District as set out in Policy S/DS. However, it is not considered necessary to put them in an order of preference, given that different development in different locations will all contribute to meet the housing and development needs for the area. For example, growth in Cambourne and within Rural Centres and Minor Rural Centres will be particularly important to ensure choice and competition for market land and it will provide in many instances more affordable private housing for those unable to afford to live in Cambridge City or those that would prefer a village location. In this regard, it is considered important for sustainable and well connected villages such as Fulbourn to accommodate a suitable proportion of growth.

In terms of the size, the proposed minor rural service centres are logical, however this is considered to provide an over- simplistic approach and does not take into account the location of each settlement, which have contrasting sustainability and connectivity credentials. For example, Fulbourn benefits from being situated in very close proximity to Cambridge City and it is accessible both by cycle and a short bus journey to the city and to the major employment opportunities at Capital Park and Peterhouse Technology Park and Cambridge Bio- Medical Campus.

Land to the north and west of Wilbraham Road, Fulbourn also provides a unique opportunity to facilitate the re- opening of Fulbourn Train Station, which would have substantial benefits in terms of reducing car trips into Cambridge both for existing and new residents in the area and it will ensure a coordinated approach between housing and infrastructure delivery. It would also align with the objectives of the Cambridgeshire Local Growth Plan (2025), which refers to the aspiration to increase capacity along the line to the east of Cambridge (between Cambridge and Newmarket). This could include provision for the introduction of the Snailwell Loop around Newmarket, which would increase the capacity and frequency of train provision.

The settlements of Gamlingay, Bassingbourn and Papworth Everard are situated in relatively remote locations with relatively poor transport connectivity and they are clearly not as a sustainable option for growth when compared to settlements such as Fulbourn.

It is therefore considered that the settlement hierarchy and development strategy needs to be reassessed and additional sub-category should be added to include ‘Well Connected Minor Rural Centres. Settlements such as Fulbourn, Milton, Melbourn and Waterbeach would be appropriate settlements for this category and they should clearly be preferable to the less sustainable minor rural centres, such as Gamlingay, Bassingbourn and Papworth Everard.

The following re- wording of Policy S/DS is suggested:
Policy S/DS: Development Strategy, sets out that the vast majority of jobs and homes will be met in the following locations:
f) Within the Cambridge Area
g) On the outer edge of Cambridge
h) At an expanded Cambourne
i) At other new settlements
j) In Rural Centres and Well Connected Minor Rural Centres
More limited level of growth will be facilitated in other Minor Rural Centres and in the southern rural cluster

Policy S/SH should be amended to identify Fulbourn, Milton, Melbourn and Waterbeach as well connected Minor Rural Centres. These amendments are required to ensure that the plan adequately responds to the sustainability credentials of well-connected minor rural services and would provide the most appropriate strategy when considered against the alternatives. This approach would be sound and in accordance with national policy.

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 8,350 dwellings and 350,000m2 of employment space
• Cambridge East (Marshalls Airport) – allocated for 8,000 dwellings and 20,000m2 employment space
• Cambourne North – allocated for 13,000 dwellings and 108,00m2 employment space
• Grange Farm Little Abington – allocated for 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. Whilst no objection is raised to delivering growth via larger strategic sites in principle, for reasons explained in this section of this report, the very limited number of sites allocated 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.
4.67 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, if even one of these sites is delayed it will result in the Shared Planning Service being unable to maintain a 5 year housing land supply. This does not align with the NPPF’s objectives to significantly boost housing land supply. This should be addressed by the allocation of deliverable sites, such as land to the land to the north and west of Wilbraham Road, Fulbourn, which is of a strategic scale and can provide a very substantial contribution to housing supply and it will also provide choice and competition for market land, in a location not currently allocated for growth.

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 north and west of Wilbraham Road, Fulbourn, 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.

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.

The lack of certainty regarding the delivery of Cambourne North, further strengthens arguments as set out above that additional strategic sites such as land to the north and west of Wilbraham Road, Fulbourn should be allocated to boost housing supply and safeguard against the delay to delivery of the proposed allocated sites.

Overall, it is clear that allocation of land to the north and west of Wilbraham Road, Fulbourn will provide a number of benefits in terms of boosting housing supply, providing additional choice and competition of allocated sites to safeguard against slow delivery and to ensure that development is directed to the most sustainable locations. Its allocation is required in order for the plan to be positively prepared, justified, and effective having regard to the tests of soundness as set out within the NPPF.

Policy S/DS and Policy S/SH need to be considered in conjunction in that Policy S/SH sets out the proposed settlement hierarchy for the plan, which then informs the locations for growth as set out in Policy S/DS.

Draft Policy S/SH identifies Fulbourn is identified as a Minor Rural Centre, along with the settlements of Bar Hill, Bassingbourn, Comberton, Cottenham, Gamlingay, Girton, Linton, Melbourn, Milton, Papworth Everard, Swavesey, Waterbeach and Willingham.

Minor Rural Centres are described as follows:
‘Minor rural service centres have a lower level of services and facilities and employment than rural centres, but a greater level than most other settlements in Greater Cambridge and often perform a role in terms of providing services and facilities for a small rural hinterland’

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 and Policy S/SH

No objection is raised to the five suggested locations for growth in the District as set out in Policy S/DS. However, it is not considered necessary to put them in an order of preference, given that different development in different locations will all contribute to meet the housing and development needs for the area. For example, growth in Cambourne and within Rural Centres and Minor Rural Centres will be particularly important to ensure choice and competition for market land and it will provide in many instances more affordable private housing for those unable to afford to live in Cambridge City or those that would prefer a village location. In this regard, it is considered important for sustainable and well connected villages such as Fulbourn to accommodate a suitable proportion of growth.

In terms of the size, the proposed minor rural service centres are logical, however this is considered to provide an over- simplistic approach and does not take into account the location of each settlement, which have contrasting sustainability and connectivity credentials. For example, Fulbourn benefits from being situated in very close proximity to Cambridge City and it is accessible both by cycle and a short bus journey to the city and to the major employment opportunities at Capital Park and Peterhouse Technology Park and Cambridge Bio- Medical Campus.

Land to the north and west of Wilbraham Road, Fulbourn also provides a unique opportunity to facilitate the re- opening of Fulbourn Train Station, which would have substantial benefits in terms of reducing car trips into Cambridge both for existing and new residents in the area and it will ensure a coordinated approach between housing and infrastructure delivery. It would also align with the objectives of the Cambridgeshire Local Growth Plan (2025), which refers to the aspiration to increase capacity along the line to the east of Cambridge (between Cambridge and Newmarket). This could include provision for the introduction of the Snailwell Loop around Newmarket, which would increase the capacity and frequency of train provision.

The settlements of Gamlingay, Bassingbourn and Papworth Everard are situated in relatively remote locations with relatively poor transport connectivity and they are clearly not as a sustainable option for growth when compared to settlements such as Fulbourn.

It is therefore considered that the settlement hierarchy and development strategy needs to be reassessed and additional sub-category should be added to include ‘Well Connected Minor Rural Centres. Settlements such as Fulbourn, Milton, Melbourn and Waterbeach would be appropriate settlements for this category and they should clearly be preferable to the less sustainable minor rural centres, such as Gamlingay, Bassingbourn and Papworth Everard.

The following re- wording of Policy S/DS is suggested:
Policy S/DS: Development Strategy, sets out that the vast majority of jobs and homes will be met in the following locations:
f) Within the Cambridge Area
g) On the outer edge of Cambridge
h) At an expanded Cambourne
i) At other new settlements
j) In Rural Centres and Well Connected Minor Rural Centres
More limited level of growth will be facilitated in other Minor Rural Centres and in the southern rural cluster

Policy S/SH should be amended to identify Fulbourn, Milton, Melbourn and Waterbeach as well connected Minor Rural Centres. These amendments are required to ensure that the plan adequately responds to the sustainability credentials of well-connected minor rural services and would provide the most appropriate strategy when considered against the alternatives. This approach would be sound and in accordance with national policy.

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 8,350 dwellings and 350,000m2 of employment space
• Cambridge East (Marshalls Airport) – allocated for 8,000 dwellings and 20,000m2 employment space
• Cambourne North – allocated for 13,000 dwellings and 108,00m2 employment space
• Grange Farm Little Abington – allocated for 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. Whilst no objection is raised to delivering growth via larger strategic sites in principle, for reasons explained in this section of this report, the very limited number of sites allocated 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.
4.67 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, if even one of these sites is delayed it will result in the Shared Planning Service being unable to maintain a 5 year housing land supply. This does not align with the NPPF’s objectives to significantly boost housing land supply. This should be addressed by the allocation of deliverable sites, such as land to the land to the north and west of Wilbraham Road, Fulbourn, which is of a strategic scale and can provide a very substantial contribution to housing supply and it will also provide choice and competition for market land, in a location not currently allocated for growth.

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 north and west of Wilbraham Road, Fulbourn, 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.

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.

The lack of certainty regarding the delivery of Cambourne North, further strengthens arguments as set out above that additional strategic sites such as land to the north and west of Wilbraham Road, Fulbourn should be allocated to boost housing supply and safeguard against the delay to delivery of the proposed allocated sites.

Overall, it is clear that allocation of land to the north and west of Wilbraham Road, Fulbourn will provide a number of benefits in terms of boosting housing supply, providing additional choice and competition of allocated sites to safeguard against slow delivery and to ensure that development is directed to the most sustainable locations. Its allocation is required in order for the plan to be positively prepared, justified, and effective having regard to the tests of soundness as set out within the NPPF.

Policy S/DS and Policy S/SH need to be considered in conjunction in that Policy S/SH sets out the proposed settlement hierarchy for the plan, which then informs the locations for growth as set out in Policy S/DS.

Draft Policy S/SH identifies Fulbourn is identified as a Minor Rural Centre, along with the settlements of Bar Hill, Bassingbourn, Comberton, Cottenham, Gamlingay, Girton, Linton, Melbourn, Milton, Papworth Everard, Swavesey, Waterbeach and Willingham.

Minor Rural Centres are described as follows:
‘Minor rural service centres have a lower level of services and facilities and employment than rural centres, but a greater level than most other settlements in Greater Cambridge and often perform a role in terms of providing services and facilities for a small rural hinterland’

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 and Policy S/SH

No objection is raised to the five suggested locations for growth in the District as set out in Policy S/DS. However, it is not considered necessary to put them in an order of preference, given that different development in different locations will all contribute to meet the housing and development needs for the area. For example, growth in Cambourne and within Rural Centres and Minor Rural Centres will be particularly important to ensure choice and competition for market land and it will provide in many instances more affordable private housing for those unable to afford to live in Cambridge City or those that would prefer a village location. In this regard, it is considered important for sustainable and well connected villages such as Fulbourn to accommodate a suitable proportion of growth.

In terms of the size, the proposed minor rural service centres are logical, however this is considered to provide an over- simplistic approach and does not take into account the location of each settlement, which have contrasting sustainability and connectivity credentials. For example, Fulbourn benefits from being situated in very close proximity to Cambridge City and it is accessible both by cycle and a short bus journey to the city and to the major employment opportunities at Capital Park and Peterhouse Technology Park and Cambridge Bio- Medical Campus.

Land to the north and west of Wilbraham Road, Fulbourn also provides a unique opportunity to facilitate the re- opening of Fulbourn Train Station, which would have substantial benefits in terms of reducing car trips into Cambridge both for existing and new residents in the area and it will ensure a coordinated approach between housing and infrastructure delivery. It would also align with the objectives of the Cambridgeshire Local Growth Plan (2025), which refers to the aspiration to increase capacity along the line to the east of Cambridge (between Cambridge and Newmarket). This could include provision for the introduction of the Snailwell Loop around Newmarket, which would increase the capacity and frequency of train provision.

The settlements of Gamlingay, Bassingbourn and Papworth Everard are situated in relatively remote locations with relatively poor transport connectivity and they are clearly not as a sustainable option for growth when compared to settlements such as Fulbourn.

It is therefore considered that the settlement hierarchy and development strategy needs to be reassessed and additional sub-category should be added to include ‘Well Connected Minor Rural Centres. Settlements such as Fulbourn, Milton, Melbourn and Waterbeach would be appropriate settlements for this category and they should clearly be preferable to the less sustainable minor rural centres, such as Gamlingay, Bassingbourn and Papworth Everard.

The following re- wording of Policy S/DS is suggested:
Policy S/DS: Development Strategy, sets out that the vast majority of jobs and homes will be met in the following locations:
f) Within the Cambridge Area
g) On the outer edge of Cambridge
h) At an expanded Cambourne
i) At other new settlements
j) In Rural Centres and Well Connected Minor Rural Centres
More limited level of growth will be facilitated in other Minor Rural Centres and in the southern rural cluster

Policy S/SH should be amended to identify Fulbourn, Milton, Melbourn and Waterbeach as well connected Minor Rural Centres. These amendments are required to ensure that the plan adequately responds to the sustainability credentials of well-connected minor rural services and would provide the most appropriate strategy when considered against the alternatives. This approach would be sound and in accordance with national policy.

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 8,350 dwellings and 350,000m2 of employment space
• Cambridge East (Marshalls Airport) – allocated for 8,000 dwellings and 20,000m2 employment space
• Cambourne North – allocated for 13,000 dwellings and 108,00m2 employment space
• Grange Farm Little Abington – allocated for 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. Whilst no objection is raised to delivering growth via larger strategic sites in principle, for reasons explained in this section of this report, the very limited number of sites allocated 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.
4.67 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, if even one of these sites is delayed it will result in the Shared Planning Service being unable to maintain a 5 year housing land supply. This does not align with the NPPF’s objectives to significantly boost housing land supply. This should be addressed by the allocation of deliverable sites, such as land to the land to the north and west of Wilbraham Road, Fulbourn, which is of a strategic scale and can provide a very substantial contribution to housing supply and it will also provide choice and competition for market land, in a location not currently allocated for growth.

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 north and west of Wilbraham Road, Fulbourn, 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.

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.

The lack of certainty regarding the delivery of Cambourne North, further strengthens arguments as set out above that additional strategic sites such as land to the north and west of Wilbraham Road, Fulbourn should be allocated to boost housing supply and safeguard against the delay to delivery of the proposed allocated sites.

Overall, it is clear that allocation of land to the north and west of Wilbraham Road, Fulbourn will provide a number of benefits in terms of boosting housing supply, providing additional choice and competition of allocated sites to safeguard against slow delivery and to ensure that development is directed to the most sustainable locations. Its allocation is required in order for the plan to be positively prepared, justified, and effective having regard to the tests of soundness as set out within the NPPF.

Places for People 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.

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. It is important that level of growth and housing allocations reflect the Vision for Greater Cambridge as set out in the DLP.

PfP supports a vision focused on:
• A net‑zero future through low‑carbon, climate‑responsive development.
• Nature‑rich places delivering strong biodiversity gains.
• Compact, well‑connected communities focused on sustainable travel.
• Healthy, high‑quality neighbourhoods with excellent design and green space.
• A balanced housing mix meeting diverse local needs.
• A thriving innovation economy supported by homes and infrastructure.
• Resilient water systems addressing scarcity and integrating SuDS.
• Protected landscapes and heritage shaping high‑quality growth.
• Infrastructure aligned with growth, including transport and community facilities.
• Vibrant villages and centres strengthened by improved services and access.

Land to the north and west of Wilbraham Road, Fulbourn aligns with these objectives and can deliver a development that reflects the distinctive character of Fulbourn while contributing to the wider needs of Greater Cambridge.

Places for People 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.

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. It is important that level of growth and housing allocations reflect the Vision for Greater Cambridge as set out in the DLP.

PfP supports a vision focused on:
• A net‑zero future through low‑carbon, climate‑responsive development.
• Nature‑rich places delivering strong biodiversity gains.
• Compact, well‑connected communities focused on sustainable travel.
• Healthy, high‑quality neighbourhoods with excellent design and green space.
• A balanced housing mix meeting diverse local needs.
• A thriving innovation economy supported by homes and infrastructure.
• Resilient water systems addressing scarcity and integrating SuDS.
• Protected landscapes and heritage shaping high‑quality growth.
• Infrastructure aligned with growth, including transport and community facilities.
• Vibrant villages and centres strengthened by improved services and access.

Land to the north and west of Wilbraham Road, Fulbourn aligns with these objectives and can deliver a development that reflects the distinctive character of Fulbourn while contributing to the wider needs of Greater Cambridge.