Draft Greater Cambridge Local Plan for consultation

The higher growth scenario from the Greater Cambridge Employment and Housing Needs Update should be used in future policy revisions. Allocating small and medium sized sites is essential to meet housing requirements, as over-reliance on windfall sites is not a sound planning approach. The proposed residential development at Land at Girton Road, Girton (site ID 115170), is one such site which is well-situated and well-connected to support sustainable transport, aligning with the Local Plan's ambitions for knowledge-intensive sectors.

1. Growth Scenarios
Supporting evidence to the policy titled the ‘Greater Cambridge Employment and Housing Needs Update 2024-2045’ (September 2025) modelled various scenarios for job growth to deduce an economic-led housing need. Of these, the chosen ‘central’ scenario was selected which resulted in the target of 48,195 homes. This conservative approach does not reflect the government ambitions for growth in Cambridge.

There have been recent significant changes in the national and strategic planning policy context that heighten the urgency in increasing job creation and housing supply and result in a step-change in the wider policy framework within which the Draft Local Plan must be considered. On 23rd August 2024, Matthew Pennycook reaffirmed the Government’s commitment to Cambridge stating: “The economic growth of Cambridge has been a phenomenal success and we should seek to maximise the potential contribution that Greater Cambridge could make to the UK economy.” The Cambridge Growth Company was then established in 2024 to address barriers to growth and help unlock Greater Cambridge’s full potential. In terms of approach, in October 2025, the Government announced its intention to consult on the case for a centrally led Development Corporation as one potential route for delivery. This is to be the subject of statutory consultation in early 2026.

Furthermore, Greater Cambridge has been, and continues to be, the location of strategic infrastructure investment that will continue to drive increased need for new jobs and homes. This includes the proposed East West rail station as well as the proposed public transport improvements for the Cambourne to Cambridge corridor and the Cambridge Eastern Access corridor. The Cambridgeshire and Peterborough Local Growth Plan 2025 also identify priority growth sectors, and the need for further skills development.

The ‘Employment and Housing Needs Update’ (September 2025) as part of the Council’s Local Plan evidence base states at 3.62 “It is important to acknowledge that the high scenarios could be achieved or exceeded. For this to take place it is considered that a step change in infrastructure investment and development would be needed to facilitate growth, notably in transport to connect in and move labour, as well as in wider services infrastructure and the expansion of both housing and commercial development programmes”.

This statement is set in the context that there is already a Cambridge Growth Company, set to become a Development Corporation, an unquestionable focus from government on the growth of Cambridge and a rising commitment to infrastructure improvements in and around Greater Cambridge, such as Grafham Water Reservoir and East West Rail. There is every reasonable expectation that the infrastructure delivery will be greater than historic trends and so the upcoming development trajectory is expected to be greater than historic trends. The high scenario must be planned for.

For these reasons, the Local Plan should utilise more optimistic and realistic figures for job and housing numbers and include explicit support for higher-growth scenarios. All housing and employment numbers should be expressed as minimums and certainly not infer any form of cap. Without these changes, Policy S/JH is unsound and inconsistent with national policy objectives to support sustainable economic growth.

2. Neighbourhood Housing Requirements
As part of the requirement for 48,195 new homes, housing requirements for the 27 designated neighbourhood areas within Greater Cambridge have also been identified taking account of the overall housing requirement, the development strategy, existing supply and the proposed additional allocations, and the population of the neighbourhood area.

Accordingly, these housing requirements should reflect the overall strategy for the pattern and scale of development. Appendix D states that the housing requirement for 2024-2045 is 90 homes for the designated neighbourhood area of Girton.

Despite this, there are no site allocations for Girton and instead it is assumed that these 90 homes will be delivered as windfall development. Our concern with this approach is that across Greater Cambridge there has been a general decline in the delivery of windfall sites over the years. The Greater Cambridge Housing Delivery Study Addendum (October 2025), Section 2, considers windfall delivery between 2006 and 2024, and considers a windfall allowance for 425 dwelling per annum to be robust. The section of the report fails to identify why over time there has been a general downward trend on windfall sites.

For instance, it presents a data set as far back as 2006 – 2007 for windfall completions to find an average delivery rate of 470 dwellings per annum. However, this fails to acknowledge that Greater Cambridge has not delivered more than 470 dwellings in a year from windfall since 2016 – 2017. The average delivery over the latest seven years of data was 395 dwellings per annum, consistently falling short of the allowance. The downward trend suggests that the best sites for windfall development have already been built out in the district and therefore a reliance on the same number of windfall sites coming forward during the plan period is unrealistic.

As such, in order to meet housing requirements there needs to be greater certainty injected into small and medium sized sites by allocating these in the emerging Local Plan, recognising that opportunities for brownfield redevelopment or residential sub-division can only continue to deliver so much housing across Greater Cambridge. An over-reliance on windfall sites is not a sound plan and is not a plan-led approach to delivering the right number of homes in the right location.

3. Conclusion
Firstly, the Local Plan should consider utilising more optimistic and realistic figures for job and housing numbers and plan for higher-growth scenarios as a result of national ambitions to ‘supercharge growth’ in the Cambridge region. Secondly, the lack of allocations of small and medium sized sites and especially in designated neighbourhood areas over relies on windfall sites which is unsound in the context of a recorded reduction in the delivery of windfall sites in the district. To provide more housing numbers in a sustainably situated medium sized site on the edge of Cambridge, Land at Girton Road, Girton (site ID 115170) represents a deliverable location for new dwellings.

In paragraph 2.44 of the draft Local Plan the Council suggests that allocations in the Rural Area would result in an overreliance on the private motor vehicle. However, this is a major over generalisation of the varied rural area. For example, the proximity of Girton (in the Rural Area) to the centre of Cambridge and other local amenities and jobs such as at West Cambridge and Eddington reflect the ability in some instances in the Rural Area to avoid reliance on the private motor vehicle. Furthermore, the expansion of rural settlements may potentially lead to increased opportunities to improve sustainable transport opportunities.

Therefore, although allocations in some parts of the Rural Area may represent less sustainable opportunities for development, the residential allocation of Land at Girton Road, Girton is well connected both to the city centre and north west quadrant of Cambridge, including West Cambridge, which aligns with the plan’s ambition to ‘support the continued flourishing of internationally renowned knowledge intensive sectors’ (Paragraph 2.72) and allowing employees to live within cycling distance of their place of work or to access reliable and convenient public transport. Residential development at this location makes benefit of land which is no longer in agricultural use and would have access to local shops, schools and services as well as high-quality sustainable transport links into the city centre.

The strategy needs to rely less on a few large strategic sites and allocate more rural small and medium and sized sites to deliver housing in the early part of the plan period. Part 1e also needs to be amended to better reflect the settlement hierarchy rather than lumping together rural centres and villages. To meet the neighbourhood housing requirement for Girton and provide certainty, Land at Girton Road, Girton (site ID 115170) should be allocated as a sustainable site that could enhance housing delivery and support local transport options.

Wain Estates object to the Development Strategy set out within Policy S/DS. The proposed Development Strategy is focused on a few large strategic sites to accommodate new housing development. While we do not object to the principle of the plan including some strategic scale developments, we consider that this approach sets the Council of on a path of over-reliance on these few strategic sites which is problematic for the following reasons

- Firstly, the speed at which these developments can deliver homes is often far slower than the Council has envisaged historically. A review of historic Annual Monitoring Reports (AMRs) demonstrates that the large strategic sites in the current Development Plan, may now be delivering at an appropriate rate, however they came on stream several years later than anticipated with an average delay in anticipated first deliveries of some 4.125 years (although some have not yet commenced at all). Please refer to the attached note on Greater Cambridge Strategic Housing Anticipated Delivery Rate and Trajectory (January 2026) prepared by Bidwells for more details. To counter over reliance on large scale sites, which threatens the deliverability of the Local Plan, the Council ought to consider allocating additional smaller scale sites which face shorter lead in times and kickstart the delivery of housing in the early years of the plan period in the interim whilst strategic sites progress with the delivery of relevant infrastructure and their delivery in the later stages of the plan.

- Secondly, the Council has not identified any new allocations for housing in the rural area which fails to support the vitality of the rural area and existing settlements. We believe that this decision has been made in part to avoid development in the Green Belt and therefore fails to strike a more balanced approach to housing delivery across the Plan period. Avoiding development in the villages takes away the ability for investment and appropriate funding of local amenities/facilities and forcing people to move to areas of Gretaer Cambridge where there is housing delivery.

- Thirdly, the ‘lumping’ together of rural centres, minor rural centres, group villages and infill villages in Policy S/DS part 1e designates these locations as those with the lowest preference to deliver jobs and homes. This clearly fails to distinguish between what may be highly sustainable locations in the rural area (such as Girton which is a Minor Rural Centre and clearly capable of delivering an appropriate scale of development and with a synergy with Cambridge) and infill villages which are much less sustainable. This appears to contradict the settlement hierarchy (Policy S/SH) and therefore differentiation should be made in the development strategy between these categorisations to ensure that growth is targeted for the most sustainable communities.

Small and Medium Sized Sites
Small and medium sites such as Land at Girton Road, Girton (site ID 115170) are key to a far more balanced approach to housing. Paragraph 73 of the NPPF (December 2024) identifies that small and medium sized sites can make an important contribution to meeting the housing requirement of an area.

The Plan does not propose to allocate any new housing sites to address this requirement, essentially because they consider that it is challenging to identify a large number of small sites to meet the 4,820 homes required to meet the 10% requirement and that it would be considered to undermine the Council’s development strategy and necessitates the release of Green Belt sites. This would conflict with the aim of protecting the Cambridge Green Belt as the larger and better served villages are located within the Green Belt.

Our concern with this approach is that primarily relying upon windfall development to address as much of the 10% requirement as possible is unlikely considering that Greater Cambridge has seen a general decline in the delivery of windfall sites over the years.

The Greater Cambridge Housing Delivery Study Addendum (October 2025), Section 2, considers windfall delivery between 2006 and 2024, and considers a windfall allowance for 425 dwelling per annum to be robust. The section of the report fails to identify why over time there has been a general downward trend on windfall sites.

For instance, it presents a data set as far back as 2006 – 2007 for windfall completions to find an average delivery rate of 470 dwellings per annum. However, this fails to acknowledge that Greater Cambridge has not delivered more than 470 dwellings in a year from windfall since 2016 – 2017. The average delivery over the latest seven years of data was 395 dwellings per annum, consistently falling short of the allowance. The downward trend suggests that the best sites for windfall development have already been built out in the district and therefore a reliance on the same number of windfall sites coming forward during the plan period is unrealistic.

As such, in order to meet housing requirements there needs to be greater certainty injected into small and medium sized sites by allocating these in the emerging Local Plan, recognising that opportunities for brownfield redevelopment or residential sub-division can only continue to deliver so much housing across Greater Cambridge. One such site is Land at Girton Road, Girton (site ID 115170). Such an approach would also be plan-led and placing more housing in planned locations would help to ensure delivery in the early years of the Plan period.
Failing to offer sufficient choice and flexibility

The focus upon large new settlements, urban redevelopment and SUEs fails to properly consider the need to offer sufficient choice and flexibility to prospective homeowners. Not all prospective purchasers will be able to, or wish to buy, in these locations. In particular, the lack of housing allocations in the villages fails to support the delivery of homes to meet the local housing needs of the next generation during the plan period. Instead of being able to live locally, this forces newly forming households to relocate to the main settlements, new settlements, or elsewhere – often away from their existing family, community and support network. This leads to an increased need for travel within Greater Cambridge, often via private cars rather than public transport. It also results in population imbalance, with ageing populations in villages and a falling roll in primary schools – whilst the new settlements have predominantly young populations and significant pressure on services.

Local Housing Need
Appendix D states that the housing requirement for 2024-2045 is 90 homes for the designated neighbourhood area of Girton, yet the village has received no allocations. Rather, it puts the onus entirely on windfall sites and exceptions sites which carry higher risk for developers and therefore are less likely to come forward. Additionally, windfall sites within the settlement not delivering 10 or more dwellings and under the area restriction will not be required to deliver any affordable housing.

Conclusion
The Development Strategy represents an overreliance on large strategic sites, which does not provide for housing in the early parts of the plan period, nor does it enhance the vitality of rural areas. To provide more housing numbers in a sustainably situated medium sized site, Land at Girton Road, Girton (site ID 115170) represents a deliverable location for new dwellings at the edge of Cambridge. In paragraph 2.44 of the draft Local Plan the Council suggests that allocations in the Rural Area would result in an overreliance on the private motor vehicle. However, this is a major over generalisation of the varied rural area. For example. the proximity of Girton to the centre of Cambridge, other local amenities and jobs, and the northwest quadrant of Cambridge, including West Cambridge, reflecting the ability for some parts of the Rural Area to avoid reliance on the private motor vehicle. Furthermore, the expansion of rural settlements may potentially lead to increased opportunities to improve sustainable transport opportunities.

Therefore, although in some cases allocations in the Rural Area represent less sustainable opportunities for development, the residential allocation of Land at Girton Road, Girton is well connected both to the city centre and north west quadrant of Cambridge which aligns with the plan’s ambition to ‘support the continued flourishing of internationally renowned knowledge intensive sectors’ (Paragraph 2.72) by providing homes when employees can sustainably travel to work. Residential development at this location makes benefit of land which is no longer in agricultural use and would have access to local shops, schools and services as well as high-quality sustainable transport links into the city centre.

Maximum scheme sizes for Minor Rural Centres should be removed.

We object to Draft Policy S/SH in respect to the development limit placed on Minor Rural Centres whereby development of up to 30 dwellings will be permitted. We do not consider that the indicative maximum scheme sizes are necessary for Minor Rural Centres, such as Girton. Development that comes forward within these villages should be considered on the basis of the site and its context. Schemes should be encouraged to make an efficient and effective use of land whilst delivering housing development that is appropriate and helps in meeting the needs of the local community. Often small windfall sites (under the thresholds indicated from Minor Rural Centres, Group and Infill Villages) will provide limited or no affordable housing, exacerbating the situation for newly forming households who cannot more fully meet their housing needs locally.

Regardless of whether the Draft Local Plan can meet the identified needs for growth without Green Belt release (which requires further justification), the relevant Plan Policy (S/GB) should include explicit reference to Grey Belt (consistent with the NPPF) and the identification of Grey Belt land within Greater Cambridge. As outlined in the attached Green Belt Study, Land at Girton Road, Girton (site ID 115170) should be identified as Grey Belt.

We object to this policy on two main points:
1. The Development Strategy states that 48,195 new homes can be delivered across the plan period without necessitating the allocation of Green Belt land. However, the ongoing government focus on Cambridge and progress by the Cambridge Growth Company means that GCSP should be planning for a greater level of growth. This triggers one of the exceptional circumstances in which Green Belt boundaries can be altered (Paragraph 146, NPPF, 2024). It is therefore noted that GCSP may require a further Green Belt review and consider the additional release of land from the Green Belt to accommodate a higher growth scenario should the Council not be able to accommodate additional growth on non-Green Belt sites.

2. The Planning Practice Guidance (Para 001 ref.001 64-001-20250225) introduced a clear duty for Grey Belt land to be identified when undertaking Green Belt Assessments for the purposes of determining applications. The direction of travel towards authorities being required to identify Grey Belt land within local plans is further evidenced within the forthcoming Consultation Draft NPPF (2025)(GB2[3]) and at Appendix E where the criteria for undertaking Green Belt Assessments is outlined. Hence, regardless of whether the Draft Local Plan can meet the identified needs for growth without Green Belt release, the relevant Plan Policy (S/GB) should include explicit reference to Grey Belt (consistent with the NPPF) and the identification of Grey Belt land within Greater Cambridge.

Identifying Grey Belt land within the revised Green Belt Assessment and Draft Local Plan is therefore both crucial to ensuring the Local Plan promotes sustainable patterns of growth (as required by the NPPF) and a policy requirement. The Green Belt Assessment which underpins the Council’s evidence base is dated 2021 which pre-dates the introduction of Grey Belt in planning policy.

In relation to this matter, Bidwells has produced a Green Belt Study for Land at Girton Road, Girton, which has been submitted with these representations. It is demonstrated in the attached Green Belt Study that although located within the Cambridge Green Belt, the site at Girton Road, Girton (ID 115170) is not subject to any of the NPPF’s footnote 7 designations and does not contribute strongly to purpose a), b) and d) of the Green Belt (purposes 1, 2 and 3 of the Cambridge Green Belt). The Land at Girton Road, Girton (site ID 115170) should therefore be identified as Grey Belt as part of the Local Plan and its supporting documents.

The Council’s Green Belt review for the larger parcel of land noted as GI18, within which the land at Girton Road is located, already demonstrates that the site and surrounding land does not contribute strongly to purpose a) and d). While it is true that development on the whole of parcel GI18 would fail to maintain the gap between Girton and Histon, the proposed site, which is only a section of parcel GI18, will not cause an impactful loss of Green Belt between the two built-up areas and therefore contribution of the site to purpose b) is also not strong. Therefore, in Green Belt policy terms, the site is considered Grey Belt.

The 2025 HELAA (HELAA Site ID 200759) provides a RAG rating for the suitability of the site in different categories. Land at Girton Road, Girton scores mostly ‘green’ with some ‘amber’ except for landscape, for which it scores red. The HELAA justifies this as it states that the site forms ‘part of the open countryside surrounding Girton’. However, as the visual study shows in the attached Bidwells Green Belt Study, the site is visually enclosed with an existing planting structure on the boundary which provides separation from the adjacent Green Belt Land and open countryside. The site is also not visible from Girton (viewpoint 3), and the lack of public rights of way in the local landscape context also limit the visual receptors that will be affected by development. The RAG assessment also ignores the ability for the layout to mitigate this impact through planting and layout design. The Illustrative Framework Plan provided in the Vison Document for the site (also attached) demonstrates how this could be achieved. It is therefore not considered that the site is ‘part of the open countryside’ and there is even some urban influence to the western side of the site.

Land at Girton Road, Girton (site ID 115170) should be allocated in the Local Plan as a site in the Rural Area with strong connections to both the city centre (within cycling distance along strategic cycle routes) and to the north-west quadrant of Cambridge which aligns with the plan’s ambition to ‘support the continued flourishing of internationally renowned knowledge intensive sectors’ (Paragraph 2.72) to provide homes for employees within sustainable commuting of their place of work.

In paragraph 2.44 of the draft Local Plan the Council suggests that allocations in the Rural Area would result in an overreliance on the private motor vehicle. Similarly, Policy S/RRA states that sites in the rural area have been allocated in locations with very good public transport access.

However, the proximity of Girton and Land at Girton Road (site ID 115170) to the centre of Cambridge and other local amenities and jobs such as at West Cambridge and Eddington demonstrate that not all locations in the vast Rural Area are equal; in some instances there is ability to avoid reliance on the private motor vehicle and provide a foundation for sustainable development. Furthermore, the expansion of settlements in the Rural Area may potentially lead to increased opportunities to improve sustainable transport opportunities.

Therefore, although in some cases allocations in the Rural Area represent less sustainable opportunities for development, the residential allocation of Land at Girton Road, Girton is well connected both to the city centre (within cycling distance along strategic cycle routes) and to the north-west quadrant of Cambridge which aligns with the plan’s ambition to ‘support the continued flourishing of internationally renowned knowledge intensive sectors’ (Paragraph 2.72) to provide homes for employees within sustainable commuting of their place of work. Residential development at this location makes benefit of land which is no longer in agricultural use and would have access to local shops, schools and services as well as high-quality sustainable transport links into the city centre.

Land at Girton Road, Girton (site ID 115170) has previously been submitted to the Greater Cambridge Call for Sites in March 2025 as a new site submission. The attached Vision Document which was submitted as part of the Call for Sites provides an Illustrative Framework Plan which shows sensitively designed development, including green space and drainage basins along the eastern boundary where the urban influence of Girton is weakest, as highlighted by the Green Belt Study submitted with this representation. The site will be sensitively designed to incorporate and supplement existing trees and hedges, as well as a central green space. Pedestrian and cycle routes will permeate through the site and open space to provide attractive journeys through the proposed landscaping and encouraging active travel to the nearby village amenities, city centre, and North-West quadrant of Cambridge. Around 75 homes in a mix of sizes and tenures including affordable homes will revitalise the site and represents an exciting new development opportunity to allocate a grey belt site in a highly sustainable location to meet local housing needs.