Draft Greater Cambridge Local Plan for consultation

The Spatial Strategy

The Spatial Strategy for the plan is articulated at Policy S/DS and goes through a five stage locationally-preferential sequence as set out below which is extracted from the policy.

“1. The need for jobs and homes will be met as far as possible in the following order of preference, having regard to the purposes of the Cambridge Green Belt:
a. Within the Cambridge urban area;
b. On the edge of Cambridge;
c. At an expanded Cambourne;
d. At other new settlements; and
e. In the rural southern cluster and wider rural area at Rural Centres and Minor Rural Centres.”

The area covered by the ‘Rural Southern Cluster’ does not appear to be defined on the plans Policies Map, but the Draft GCLP Figure 91 is a map showing the clustering of policies within this area. The Site (HELAA Site ID 200765) lies centrally within this area, immediately north of the Wellcome Genome Campus extension and adjacent to Whittlesford Parkway rail station. Save for the parcel known as Ricketts Field to the north of the A505, the Site is also not in the Green Belt.

Paragraph 2.55 of the plan states that the preferred option for development does the below:
“a. limit our climate impact and support thriving communities – locate development where active and public transport is the natural choice, with jobs, services and facilities located near to where people live, and responding to opportunities created by existing and proposed major new transport infrastructure;
b. protect and enhance our natural environment – maximise opportunities to use brownfield land, and ensure green infrastructure can be delivered alongside new development;
c. enable our national and global economic employment sectors to flourish – provide employment space of the right type in the right location to meet sector needs;
d. reinforce the distinctive character of our city, towns and villages – protect the Green Belt, and develop sites that can be well-integrated with existing communities, can be developed at densities, and using appropriate forms and patterns of development, which make best use of land while creating well-designed, characterful places; and
e. support all necessary utilities in a sustainable way – ensure that the development strategy can be supported by utilities in a way that protects and enhances the environment.” (Emphasis added)

The Site is not only located in the heart of a spatial strategy location, as a site it is also a very natural fit for the local plan’s aspirations. Its location is central to jobs at the various Campuses (Wellcome, Granta Park, Babraham and over the county/district border in Great Chesterford), services and facilities (both delivered by the Site, and in the Wellcome Campus etc) and most importantly is located close to an existing frequent service train station. Indeed, Policy S/AMC/WHD states in its supporting text that the land immediately a round Whittlesford Parkway Station is “close to the southern cluster research and employment centres”. With the Site being close to both these research and employment centres and the station, it is clearly very well located. It is also noteworthy in the context of the overall spatial strategy that Whittlesford Parkway Station is existing major sustainable transport infrastructure and not a proposed solution which requires significant time and funding before it can come on board, unlike Grange Farm. While we do not necessarily dispute the allocation of Grange Farm, as we can deliver a scheme at the Site in tandem with it if necessary, it is not clear that allocating Grange Farm can be justified against the plan’s strategic objectives. In particular, when compared with the Site as a reasonable alternative, Grange Farm appears less well aligned with the aim of directing development to locations where active and public transport are the natural choice and where there is a strong relationship with existing (and proposed) major transport infrastructure.

The NPPF states (para 86) that policies should seek to address potential barriers to investment such as inadequate housing and (at para 87) refers to the need to recognise and plan for the specific location requirements and make provision for the infrastructure that is needed to support the growth of these industries. The Rural Southern cluster is what the NPPF envisages.

Whittlesford Parkway Station Policy Area Policy S/AMC/WHD

In many ways, the opportunities presented by the development of the Site are similar to the emerging allocation at Grange Farm, with the potential for a travel hub/link into onward sustainable travel. However, the key differentiating feature here is the access to an existing railway station (Whittlesford Parkway Station) which is operational today; it is not awaiting a funding inquiry and years away from being operational. It is of further note that currently, the CSET as proposed terminates before Grange Farm. Whittlesford Parkway Station also offers routes into Central, South and North Cambridge and south towards London, whereas the CSET route only goes to Addenbrookes. The Site has better onward travel and choice in this regard.

The Site, including the parcel of land to the north-west of the McDonald’s roundabout on the A505 which also sits within SmithsonHill’s ownership, offers exceptional opportunities via land, but also financial contributions from the wider development of the Site. Such contributions could enhance not just eastern access to Whittlesford Parkway Station, but also opportunities via this land to significantly improve active travel and enhance highways capacity at the roundabout. The Site is also centrally located within the Rural Southern Cluster and is in the right location to link the cluster together with wider improvements to the A505 corridor. SmithsonHill can effectively work with Councils, the Cambridge Growth Company and other landowners and developers, including the Wellcome Trust who are delivering their own development on the adjacent site, about how we help with those solutions.

It is also of significant relevance to the proposals mentioned above, that while the land parcel to the north-east of the McDonald’s roundabout is in the Green Belt, the NPPF consultation (December 2025) proposes that development (including residential) within a reasonable walking distance of a well-connected train station has a strong presumption in favour of development, regardless of the site’s Green Belt location. Our comprehensive response to Policy S/AMC/WHD: Whittlesford Parkway Station Policy Area addresses this.

Transport evidence

It is noted that whilst GCSP’s preferred option for development is predicated on amongst other things, responding to opportunities created by existing and proposed major new transport infrastructure, the GCLP is progressing without the publication of the Greater Cambridge Transport Strategy (GCTS).

The GCTS is proposed to provide the transport evidence base for the GCLP, yet it is not ready for comment via this consultation. Legal advice sought by the Councils means a ‘Statement of Intent’ has been published at this stage. The statement confirms the GCTS will:
• “Identify infrastructure requirements – confirming the transport infrastructure necessary to support the delivery of strategic development sites proposed within the Greater Cambridge Local Plan.
• Address wider growth and transport challenges and needs – setting out ambitious initiatives and policies to manage the broader transport demands arising from longer term and planned growth but also ensuring a better integrated transport system across Greater Cambridge for business and residents.”

The current timetable for the GCTS means it will not be published in draft until June 2026, before then being consulted upon and approved in November 2026. The Regulation 19 consultation for the GCLP will have to occur over similar timescales if it is to be submitted prior to the 31 December 2026 to ensure it will be examined under the NPPF 2024. It is not clear that the GCLP can be justified as per the local plan tests of soundness if its strategy is not based on proportionate, finalised and published evidence.

Delivery

Not only does the location of the Site lend itself to sustainable travel patterns from day one, it is also promoted by a joint landowner/developer who plans on building out at least part of the scheme, meaning it would be able to commence at pace without the need to sell the Site or seek a development partner. Hill could be delivering an initial few phases while other parcels are disposed of, meaning not just a quick start, but continuous delivery from multiple outlets. Hill has a strong track record of delivery in Cambridge and is committed to future delivery in and around the City. The presence of a developer with an interest in delivering the Site is not typical of all emerging allocations in this plan. In particular, Grange Farm does not appear to be promoted by a developer which inherently pushes back its delivery timescales compared to the Site. We note the Greater Cambridge Housing Delivery Study Addendum 2025 Update states that “Grange Farm is located to the south east of Cambridge in close proximity to Uttlesford District. There are currently no other strategic-scale new community allocations or commitments in close proximity to the proposed site, which should mean there are reduced market absorption risks”. However, we dispute that two strategic sites in close proximity would necessarily lead to market absorption risks. Firstly, as a developer is on board at the Site, it can come forward much quicker, years before Grange Farm, so there could be significant early periods of delivery at the Site where there would be no competition in the market. Secondly, there are a range of site-specific factors set out in Lichfields research Start to Finish which evidence site specific factors which can increase build out rates. This includes sites being in high demand areas (like Greater Cambridge), greenfield sites over brownfield, the number of outlets operating simultaneously and the housing mix with greater variety supporting higher build rates. There are many variables at play which means a blanket assumption that two strategic sites in close proximity would mean reduced market absorption is a blunt and inaccurate conclusion.

Summary

In the context of our comments on Policy S/JH, it is clear that for the draft GCLP to be found sound it needs to allocate more sites for residential development. Both to bring the planned levels of employment growth in line with the housing requirements this will generate, but also to ensure a positively prepared and justified housing trajectory. Our comment on Policy S/DS make clear that the Site is aligned with the spatial strategy of the draft GCLP; is centrally located within the Rural Southern Cluster; and is aligned with a key existing piece of operational sustainable transportation, Whittlesford Parkway Station. It is also unclear why the allocation of Grange Farm would be preferable to the Site, which is aligned with existing rapid sustainable transportation, unlike the CSET extension. Allocation of the Site offers a non-Green Belt option to bolstering the housing trajectory on a site which is aligned with the GCLP’s spatial strategy. It can also come forward in tandem with other large-scale developments, including Grange Farm.

This can be addressed by updating the SA to include alternative, higher, housing and job growth scenarios.

The Spatial Strategy

The Spatial Strategy for the plan is articulated at Policy S/DS and goes through a five stage locationally-preferential sequence as set out below which is extracted from the policy.

“1. The need for jobs and homes will be met as far as possible in the following order of preference, having regard to the purposes of the Cambridge Green Belt:
a. Within the Cambridge urban area;
b. On the edge of Cambridge;
c. At an expanded Cambourne;
d. At other new settlements; and
e. In the rural southern cluster and wider rural area at Rural Centres and Minor Rural Centres.”

The area covered by the ‘Rural Southern Cluster’ does not appear to be defined on the plans Policies Map, but the Draft GCLP Figure 91 is a map showing the clustering of policies within this area. The Site (HELAA Site ID 200765) lies centrally within this area, immediately north of the Wellcome Genome Campus extension and adjacent to Whittlesford Parkway rail station. Save for the parcel known as Ricketts Field to the north of the A505, the Site is also not in the Green Belt.

Paragraph 2.55 of the plan states that the preferred option for development does the below:
“a. limit our climate impact and support thriving communities – locate development where active and public transport is the natural choice, with jobs, services and facilities located near to where people live, and responding to opportunities created by existing and proposed major new transport infrastructure;
b. protect and enhance our natural environment – maximise opportunities to use brownfield land, and ensure green infrastructure can be delivered alongside new development;
c. enable our national and global economic employment sectors to flourish – provide employment space of the right type in the right location to meet sector needs;
d. reinforce the distinctive character of our city, towns and villages – protect the Green Belt, and develop sites that can be well-integrated with existing communities, can be developed at densities, and using appropriate forms and patterns of development, which make best use of land while creating well-designed, characterful places; and
e. support all necessary utilities in a sustainable way – ensure that the development strategy can be supported by utilities in a way that protects and enhances the environment.” (Emphasis added)

The Site is not only located in the heart of a spatial strategy location, as a site it is also a very natural fit for the local plan’s aspirations. Its location is central to jobs at the various Campuses (Wellcome, Granta Park, Babraham and over the county/district border in Great Chesterford), services and facilities (both delivered by the Site, and in the Wellcome Campus etc) and most importantly is located close to an existing frequent service train station. Indeed, Policy S/AMC/WHD states in its supporting text that the land immediately a round Whittlesford Parkway Station is “close to the southern cluster research and employment centres”. With the Site being close to both these research and employment centres and the station, it is clearly very well located. It is also noteworthy in the context of the overall spatial strategy that Whittlesford Parkway Station is existing major sustainable transport infrastructure and not a proposed solution which requires significant time and funding before it can come on board, unlike Grange Farm. While we do not necessarily dispute the allocation of Grange Farm, as we can deliver a scheme at the Site in tandem with it if necessary, it is not clear that allocating Grange Farm can be justified against the plan’s strategic objectives. In particular, when compared with the Site as a reasonable alternative, Grange Farm appears less well aligned with the aim of directing development to locations where active and public transport are the natural choice and where there is a strong relationship with existing (and proposed) major transport infrastructure.

The NPPF states (para 86) that policies should seek to address potential barriers to investment such as inadequate housing and (at para 87) refers to the need to recognise and plan for the specific location requirements and make provision for the infrastructure that is needed to support the growth of these industries. The Rural Southern cluster is what the NPPF envisages.

Whittlesford Parkway Station Policy Area Policy S/AMC/WHD

In many ways, the opportunities presented by the development of the Site are similar to the emerging allocation at Grange Farm, with the potential for a travel hub/link into onward sustainable travel. However, the key differentiating feature here is the access to an existing railway station (Whittlesford Parkway Station) which is operational today; it is not awaiting a funding inquiry and years away from being operational. It is of further note that currently, the CSET as proposed terminates before Grange Farm. Whittlesford Parkway Station also offers routes into Central, South and North Cambridge and south towards London, whereas the CSET route only goes to Addenbrookes. The Site has better onward travel and choice in this regard.

The Site, including the parcel of land to the north-west of the McDonald’s roundabout on the A505 which also sits within SmithsonHill’s ownership, offers exceptional opportunities via land, but also financial contributions from the wider development of the Site. Such contributions could enhance not just eastern access to Whittlesford Parkway Station, but also opportunities via this land to significantly improve active travel and enhance highways capacity at the roundabout. The Site is also centrally located within the Rural Southern Cluster and is in the right location to link the cluster together with wider improvements to the A505 corridor. SmithsonHill can effectively work with Councils, the Cambridge Growth Company and other landowners and developers, including the Wellcome Trust who are delivering their own development on the adjacent site, about how we help with those solutions.

It is also of significant relevance to the proposals mentioned above, that while the land parcel to the north-east of the McDonald’s roundabout is in the Green Belt, the NPPF consultation (December 2025) proposes that development (including residential) within a reasonable walking distance of a well-connected train station has a strong presumption in favour of development, regardless of the site’s Green Belt location. Our comprehensive response to Policy S/AMC/WHD: Whittlesford Parkway Station Policy Area addresses this.

Transport evidence

It is noted that whilst GCSP’s preferred option for development is predicated on amongst other things, responding to opportunities created by existing and proposed major new transport infrastructure, the GCLP is progressing without the publication of the Greater Cambridge Transport Strategy (GCTS).

The GCTS is proposed to provide the transport evidence base for the GCLP, yet it is not ready for comment via this consultation. Legal advice sought by the Councils means a ‘Statement of Intent’ has been published at this stage. The statement confirms the GCTS will:
• “Identify infrastructure requirements – confirming the transport infrastructure necessary to support the delivery of strategic development sites proposed within the Greater Cambridge Local Plan.
• Address wider growth and transport challenges and needs – setting out ambitious initiatives and policies to manage the broader transport demands arising from longer term and planned growth but also ensuring a better integrated transport system across Greater Cambridge for business and residents.”

The current timetable for the GCTS means it will not be published in draft until June 2026, before then being consulted upon and approved in November 2026. The Regulation 19 consultation for the GCLP will have to occur over similar timescales if it is to be submitted prior to the 31 December 2026 to ensure it will be examined under the NPPF 2024. It is not clear that the GCLP can be justified as per the local plan tests of soundness if its strategy is not based on proportionate, finalised and published evidence.

Delivery

Not only does the location of the Site lend itself to sustainable travel patterns from day one, it is also promoted by a joint landowner/developer who plans on building out at least part of the scheme, meaning it would be able to commence at pace without the need to sell the Site or seek a development partner. Hill could be delivering an initial few phases while other parcels are disposed of, meaning not just a quick start, but continuous delivery from multiple outlets. Hill has a strong track record of delivery in Cambridge and is committed to future delivery in and around the City. The presence of a developer with an interest in delivering the Site is not typical of all emerging allocations in this plan. In particular, Grange Farm does not appear to be promoted by a developer which inherently pushes back its delivery timescales compared to the Site. We note the Greater Cambridge Housing Delivery Study Addendum 2025 Update states that “Grange Farm is located to the south east of Cambridge in close proximity to Uttlesford District. There are currently no other strategic-scale new community allocations or commitments in close proximity to the proposed site, which should mean there are reduced market absorption risks”. However, we dispute that two strategic sites in close proximity would necessarily lead to market absorption risks. Firstly, as a developer is on board at the Site, it can come forward much quicker, years before Grange Farm, so there could be significant early periods of delivery at the Site where there would be no competition in the market. Secondly, there are a range of site-specific factors set out in Lichfields research Start to Finish which evidence site specific factors which can increase build out rates. This includes sites being in high demand areas (like Greater Cambridge), greenfield sites over brownfield, the number of outlets operating simultaneously and the housing mix with greater variety supporting higher build rates. There are many variables at play which means a blanket assumption that two strategic sites in close proximity would mean reduced market absorption is a blunt and inaccurate conclusion.

Summary

In the context of our comments on Policy S/JH, it is clear that for the draft GCLP to be found sound it needs to allocate more sites for residential development. Both to bring the planned levels of employment growth in line with the housing requirements this will generate, but also to ensure a positively prepared and justified housing trajectory. Our comment on Policy S/DS make clear that the Site is aligned with the spatial strategy of the draft GCLP; is centrally located within the Rural Southern Cluster; and is aligned with a key existing piece of operational sustainable transportation, Whittlesford Parkway Station. It is also unclear why the allocation of Grange Farm would be preferable to the Site, which is aligned with existing rapid sustainable transportation, unlike the CSET extension. Allocation of the Site offers a non-Green Belt option to bolstering the housing trajectory on a site which is aligned with the GCLP’s spatial strategy. It can also come forward in tandem with other large-scale developments, including Grange Farm.

The Spatial Strategy

The Spatial Strategy for the plan is articulated at Policy S/DS and goes through a five stage locationally-preferential sequence as set out below which is extracted from the policy.

“1. The need for jobs and homes will be met as far as possible in the following order of preference, having regard to the purposes of the Cambridge Green Belt:
a. Within the Cambridge urban area;
b. On the edge of Cambridge;
c. At an expanded Cambourne;
d. At other new settlements; and
e. In the rural southern cluster and wider rural area at Rural Centres and Minor Rural Centres.”

The area covered by the ‘Rural Southern Cluster’ does not appear to be defined on the plans Policies Map, but the Draft GCLP Figure 91 is a map showing the clustering of policies within this area. The Site (HELAA Site ID 200765) lies centrally within this area, immediately north of the Wellcome Genome Campus extension and adjacent to Whittlesford Parkway rail station. Save for the parcel known as Ricketts Field to the north of the A505, the Site is also not in the Green Belt.

Paragraph 2.55 of the plan states that the preferred option for development does the below:
“a. limit our climate impact and support thriving communities – locate development where active and public transport is the natural choice, with jobs, services and facilities located near to where people live, and responding to opportunities created by existing and proposed major new transport infrastructure;
b. protect and enhance our natural environment – maximise opportunities to use brownfield land, and ensure green infrastructure can be delivered alongside new development;
c. enable our national and global economic employment sectors to flourish – provide employment space of the right type in the right location to meet sector needs;
d. reinforce the distinctive character of our city, towns and villages – protect the Green Belt, and develop sites that can be well-integrated with existing communities, can be developed at densities, and using appropriate forms and patterns of development, which make best use of land while creating well-designed, characterful places; and
e. support all necessary utilities in a sustainable way – ensure that the development strategy can be supported by utilities in a way that protects and enhances the environment.” (Emphasis added)

The Site is not only located in the heart of a spatial strategy location, as a site it is also a very natural fit for the local plan’s aspirations. Its location is central to jobs at the various Campuses (Wellcome, Granta Park, Babraham and over the county/district border in Great Chesterford), services and facilities (both delivered by the Site, and in the Wellcome Campus etc) and most importantly is located close to an existing frequent service train station. Indeed, Policy S/AMC/WHD states in its supporting text that the land immediately a round Whittlesford Parkway Station is “close to the southern cluster research and employment centres”. With the Site being close to both these research and employment centres and the station, it is clearly very well located. It is also noteworthy in the context of the overall spatial strategy that Whittlesford Parkway Station is existing major sustainable transport infrastructure and not a proposed solution which requires significant time and funding before it can come on board, unlike Grange Farm. While we do not necessarily dispute the allocation of Grange Farm, as we can deliver a scheme at the Site in tandem with it if necessary, it is not clear that allocating Grange Farm can be justified against the plan’s strategic objectives. In particular, when compared with the Site as a reasonable alternative, Grange Farm appears less well aligned with the aim of directing development to locations where active and public transport are the natural choice and where there is a strong relationship with existing (and proposed) major transport infrastructure.

The NPPF states (para 86) that policies should seek to address potential barriers to investment such as inadequate housing and (at para 87) refers to the need to recognise and plan for the specific location requirements and make provision for the infrastructure that is needed to support the growth of these industries. The Rural Southern cluster is what the NPPF envisages.

Whittlesford Parkway Station Policy Area Policy S/AMC/WHD

In many ways, the opportunities presented by the development of the Site are similar to the emerging allocation at Grange Farm, with the potential for a travel hub/link into onward sustainable travel. However, the key differentiating feature here is the access to an existing railway station (Whittlesford Parkway Station) which is operational today; it is not awaiting a funding inquiry and years away from being operational. It is of further note that currently, the CSET as proposed terminates before Grange Farm. Whittlesford Parkway Station also offers routes into Central, South and North Cambridge and south towards London, whereas the CSET route only goes to Addenbrookes. The Site has better onward travel and choice in this regard.

The Site, including the parcel of land to the north-west of the McDonald’s roundabout on the A505 which also sits within SmithsonHill’s ownership, offers exceptional opportunities via land, but also financial contributions from the wider development of the Site. Such contributions could enhance not just eastern access to Whittlesford Parkway Station, but also opportunities via this land to significantly improve active travel and enhance highways capacity at the roundabout. The Site is also centrally located within the Rural Southern Cluster and is in the right location to link the cluster together with wider improvements to the A505 corridor. SmithsonHill can effectively work with Councils, the Cambridge Growth Company and other landowners and developers, including the Wellcome Trust who are delivering their own development on the adjacent site, about how we help with those solutions.

It is also of significant relevance to the proposals mentioned above, that while the land parcel to the north-east of the McDonald’s roundabout is in the Green Belt, the NPPF consultation (December 2025) proposes that development (including residential) within a reasonable walking distance of a well-connected train station has a strong presumption in favour of development, regardless of the site’s Green Belt location. Our comprehensive response to Policy S/AMC/WHD: Whittlesford Parkway Station Policy Area addresses this.

Transport evidence

It is noted that whilst GCSP’s preferred option for development is predicated on amongst other things, responding to opportunities created by existing and proposed major new transport infrastructure, the GCLP is progressing without the publication of the Greater Cambridge Transport Strategy (GCTS).

The GCTS is proposed to provide the transport evidence base for the GCLP, yet it is not ready for comment via this consultation. Legal advice sought by the Councils means a ‘Statement of Intent’ has been published at this stage. The statement confirms the GCTS will:
• “Identify infrastructure requirements – confirming the transport infrastructure necessary to support the delivery of strategic development sites proposed within the Greater Cambridge Local Plan.
• Address wider growth and transport challenges and needs – setting out ambitious initiatives and policies to manage the broader transport demands arising from longer term and planned growth but also ensuring a better integrated transport system across Greater Cambridge for business and residents.”

The current timetable for the GCTS means it will not be published in draft until June 2026, before then being consulted upon and approved in November 2026. The Regulation 19 consultation for the GCLP will have to occur over similar timescales if it is to be submitted prior to the 31 December 2026 to ensure it will be examined under the NPPF 2024. It is not clear that the GCLP can be justified as per the local plan tests of soundness if its strategy is not based on proportionate, finalised and published evidence.

Delivery

Not only does the location of the Site lend itself to sustainable travel patterns from day one, it is also promoted by a joint landowner/developer who plans on building out at least part of the scheme, meaning it would be able to commence at pace without the need to sell the Site or seek a development partner. Hill could be delivering an initial few phases while other parcels are disposed of, meaning not just a quick start, but continuous delivery from multiple outlets. Hill has a strong track record of delivery in Cambridge and is committed to future delivery in and around the City. The presence of a developer with an interest in delivering the Site is not typical of all emerging allocations in this plan. In particular, Grange Farm does not appear to be promoted by a developer which inherently pushes back its delivery timescales compared to the Site. We note the Greater Cambridge Housing Delivery Study Addendum 2025 Update states that “Grange Farm is located to the south east of Cambridge in close proximity to Uttlesford District. There are currently no other strategic-scale new community allocations or commitments in close proximity to the proposed site, which should mean there are reduced market absorption risks”. However, we dispute that two strategic sites in close proximity would necessarily lead to market absorption risks. Firstly, as a developer is on board at the Site, it can come forward much quicker, years before Grange Farm, so there could be significant early periods of delivery at the Site where there would be no competition in the market. Secondly, there are a range of site-specific factors set out in Lichfields research Start to Finish which evidence site specific factors which can increase build out rates. This includes sites being in high demand areas (like Greater Cambridge), greenfield sites over brownfield, the number of outlets operating simultaneously and the housing mix with greater variety supporting higher build rates. There are many variables at play which means a blanket assumption that two strategic sites in close proximity would mean reduced market absorption is a blunt and inaccurate conclusion.

Summary

In the context of our comments on Policy S/JH, it is clear that for the draft GCLP to be found sound it needs to allocate more sites for residential development. Both to bring the planned levels of employment growth in line with the housing requirements this will generate, but also to ensure a positively prepared and justified housing trajectory. Our comment on Policy S/DS make clear that the Site is aligned with the spatial strategy of the draft GCLP; is centrally located within the Rural Southern Cluster; and is aligned with a key existing piece of operational sustainable transportation, Whittlesford Parkway Station. It is also unclear why the allocation of Grange Farm would be preferable to the Site, which is aligned with existing rapid sustainable transportation, unlike the CSET extension. Allocation of the Site offers a non-Green Belt option to bolstering the housing trajectory on a site which is aligned with the GCLP’s spatial strategy. It can also come forward in tandem with other large-scale developments, including Grange Farm.

The Spatial Strategy

The Spatial Strategy for the plan is articulated at Policy S/DS and goes through a five stage locationally-preferential sequence as set out below which is extracted from the policy.

“1. The need for jobs and homes will be met as far as possible in the following order of preference, having regard to the purposes of the Cambridge Green Belt:
a. Within the Cambridge urban area;
b. On the edge of Cambridge;
c. At an expanded Cambourne;
d. At other new settlements; and
e. In the rural southern cluster and wider rural area at Rural Centres and Minor Rural Centres.”

The area covered by the ‘Rural Southern Cluster’ does not appear to be defined on the plans Policies Map, but the Draft GCLP Figure 91 is a map showing the clustering of policies within this area. The Site (HELAA Site ID 200765) lies centrally within this area, immediately north of the Wellcome Genome Campus extension and adjacent to Whittlesford Parkway rail station. Save for the parcel known as Ricketts Field to the north of the A505, the Site is also not in the Green Belt.

Paragraph 2.55 of the plan states that the preferred option for development does the below:
“a. limit our climate impact and support thriving communities – locate development where active and public transport is the natural choice, with jobs, services and facilities located near to where people live, and responding to opportunities created by existing and proposed major new transport infrastructure;
b. protect and enhance our natural environment – maximise opportunities to use brownfield land, and ensure green infrastructure can be delivered alongside new development;
c. enable our national and global economic employment sectors to flourish – provide employment space of the right type in the right location to meet sector needs;
d. reinforce the distinctive character of our city, towns and villages – protect the Green Belt, and develop sites that can be well-integrated with existing communities, can be developed at densities, and using appropriate forms and patterns of development, which make best use of land while creating well-designed, characterful places; and
e. support all necessary utilities in a sustainable way – ensure that the development strategy can be supported by utilities in a way that protects and enhances the environment.” (Emphasis added)

The Site is not only located in the heart of a spatial strategy location, as a site it is also a very natural fit for the local plan’s aspirations. Its location is central to jobs at the various Campuses (Wellcome, Granta Park, Babraham and over the county/district border in Great Chesterford), services and facilities (both delivered by the Site, and in the Wellcome Campus etc) and most importantly is located close to an existing frequent service train station. Indeed, Policy S/AMC/WHD states in its supporting text that the land immediately a round Whittlesford Parkway Station is “close to the southern cluster research and employment centres”. With the Site being close to both these research and employment centres and the station, it is clearly very well located. It is also noteworthy in the context of the overall spatial strategy that Whittlesford Parkway Station is existing major sustainable transport infrastructure and not a proposed solution which requires significant time and funding before it can come on board, unlike Grange Farm. While we do not necessarily dispute the allocation of Grange Farm, as we can deliver a scheme at the Site in tandem with it if necessary, it is not clear that allocating Grange Farm can be justified against the plan’s strategic objectives. In particular, when compared with the Site as a reasonable alternative, Grange Farm appears less well aligned with the aim of directing development to locations where active and public transport are the natural choice and where there is a strong relationship with existing (and proposed) major transport infrastructure.

The NPPF states (para 86) that policies should seek to address potential barriers to investment such as inadequate housing and (at para 87) refers to the need to recognise and plan for the specific location requirements and make provision for the infrastructure that is needed to support the growth of these industries. The Rural Southern cluster is what the NPPF envisages.

Whittlesford Parkway Station Policy Area Policy S/AMC/WHD

In many ways, the opportunities presented by the development of the Site are similar to the emerging allocation at Grange Farm, with the potential for a travel hub/link into onward sustainable travel. However, the key differentiating feature here is the access to an existing railway station (Whittlesford Parkway Station) which is operational today; it is not awaiting a funding inquiry and years away from being operational. It is of further note that currently, the CSET as proposed terminates before Grange Farm. Whittlesford Parkway Station also offers routes into Central, South and North Cambridge and south towards London, whereas the CSET route only goes to Addenbrookes. The Site has better onward travel and choice in this regard.

The Site, including the parcel of land to the north-west of the McDonald’s roundabout on the A505 which also sits within SmithsonHill’s ownership, offers exceptional opportunities via land, but also financial contributions from the wider development of the Site. Such contributions could enhance not just eastern access to Whittlesford Parkway Station, but also opportunities via this land to significantly improve active travel and enhance highways capacity at the roundabout. The Site is also centrally located within the Rural Southern Cluster and is in the right location to link the cluster together with wider improvements to the A505 corridor. SmithsonHill can effectively work with Councils, the Cambridge Growth Company and other landowners and developers, including the Wellcome Trust who are delivering their own development on the adjacent site, about how we help with those solutions.

It is also of significant relevance to the proposals mentioned above, that while the land parcel to the north-east of the McDonald’s roundabout is in the Green Belt, the NPPF consultation (December 2025) proposes that development (including residential) within a reasonable walking distance of a well-connected train station has a strong presumption in favour of development, regardless of the site’s Green Belt location. Our comprehensive response to Policy S/AMC/WHD: Whittlesford Parkway Station Policy Area addresses this.

Transport evidence

It is noted that whilst GCSP’s preferred option for development is predicated on amongst other things, responding to opportunities created by existing and proposed major new transport infrastructure, the GCLP is progressing without the publication of the Greater Cambridge Transport Strategy (GCTS).

The GCTS is proposed to provide the transport evidence base for the GCLP, yet it is not ready for comment via this consultation. Legal advice sought by the Councils means a ‘Statement of Intent’ has been published at this stage. The statement confirms the GCTS will:
• “Identify infrastructure requirements – confirming the transport infrastructure necessary to support the delivery of strategic development sites proposed within the Greater Cambridge Local Plan.
• Address wider growth and transport challenges and needs – setting out ambitious initiatives and policies to manage the broader transport demands arising from longer term and planned growth but also ensuring a better integrated transport system across Greater Cambridge for business and residents.”

The current timetable for the GCTS means it will not be published in draft until June 2026, before then being consulted upon and approved in November 2026. The Regulation 19 consultation for the GCLP will have to occur over similar timescales if it is to be submitted prior to the 31 December 2026 to ensure it will be examined under the NPPF 2024. It is not clear that the GCLP can be justified as per the local plan tests of soundness if its strategy is not based on proportionate, finalised and published evidence.

Delivery

Not only does the location of the Site lend itself to sustainable travel patterns from day one, it is also promoted by a joint landowner/developer who plans on building out at least part of the scheme, meaning it would be able to commence at pace without the need to sell the Site or seek a development partner. Hill could be delivering an initial few phases while other parcels are disposed of, meaning not just a quick start, but continuous delivery from multiple outlets. Hill has a strong track record of delivery in Cambridge and is committed to future delivery in and around the City. The presence of a developer with an interest in delivering the Site is not typical of all emerging allocations in this plan. In particular, Grange Farm does not appear to be promoted by a developer which inherently pushes back its delivery timescales compared to the Site. We note the Greater Cambridge Housing Delivery Study Addendum 2025 Update states that “Grange Farm is located to the south east of Cambridge in close proximity to Uttlesford District. There are currently no other strategic-scale new community allocations or commitments in close proximity to the proposed site, which should mean there are reduced market absorption risks”. However, we dispute that two strategic sites in close proximity would necessarily lead to market absorption risks. Firstly, as a developer is on board at the Site, it can come forward much quicker, years before Grange Farm, so there could be significant early periods of delivery at the Site where there would be no competition in the market. Secondly, there are a range of site-specific factors set out in Lichfields research Start to Finish which evidence site specific factors which can increase build out rates. This includes sites being in high demand areas (like Greater Cambridge), greenfield sites over brownfield, the number of outlets operating simultaneously and the housing mix with greater variety supporting higher build rates. There are many variables at play which means a blanket assumption that two strategic sites in close proximity would mean reduced market absorption is a blunt and inaccurate conclusion.

Summary

In the context of our comments on Policy S/JH, it is clear that for the draft GCLP to be found sound it needs to allocate more sites for residential development. Both to bring the planned levels of employment growth in line with the housing requirements this will generate, but also to ensure a positively prepared and justified housing trajectory. Our comment on Policy S/DS make clear that the Site is aligned with the spatial strategy of the draft GCLP; is centrally located within the Rural Southern Cluster; and is aligned with a key existing piece of operational sustainable transportation, Whittlesford Parkway Station. It is also unclear why the allocation of Grange Farm would be preferable to the Site, which is aligned with existing rapid sustainable transportation, unlike the CSET extension. Allocation of the Site offers a non-Green Belt option to bolstering the housing trajectory on a site which is aligned with the GCLP’s spatial strategy. It can also come forward in tandem with other large-scale developments, including Grange Farm.

The Spatial Strategy

The Spatial Strategy for the plan is articulated at Policy S/DS and goes through a five stage locationally-preferential sequence as set out below which is extracted from the policy.

“1. The need for jobs and homes will be met as far as possible in the following order of preference, having regard to the purposes of the Cambridge Green Belt:
a. Within the Cambridge urban area;
b. On the edge of Cambridge;
c. At an expanded Cambourne;
d. At other new settlements; and
e. In the rural southern cluster and wider rural area at Rural Centres and Minor Rural Centres.”

The area covered by the ‘Rural Southern Cluster’ does not appear to be defined on the plans Policies Map, but the Draft GCLP Figure 91 is a map showing the clustering of policies within this area. The Site (HELAA Site ID 200765) lies centrally within this area, immediately north of the Wellcome Genome Campus extension and adjacent to Whittlesford Parkway rail station. Save for the parcel known as Ricketts Field to the north of the A505, the Site is also not in the Green Belt.

Paragraph 2.55 of the plan states that the preferred option for development does the below:
“a. limit our climate impact and support thriving communities – locate development where active and public transport is the natural choice, with jobs, services and facilities located near to where people live, and responding to opportunities created by existing and proposed major new transport infrastructure;
b. protect and enhance our natural environment – maximise opportunities to use brownfield land, and ensure green infrastructure can be delivered alongside new development;
c. enable our national and global economic employment sectors to flourish – provide employment space of the right type in the right location to meet sector needs;
d. reinforce the distinctive character of our city, towns and villages – protect the Green Belt, and develop sites that can be well-integrated with existing communities, can be developed at densities, and using appropriate forms and patterns of development, which make best use of land while creating well-designed, characterful places; and
e. support all necessary utilities in a sustainable way – ensure that the development strategy can be supported by utilities in a way that protects and enhances the environment.” (Emphasis added)

The Site is not only located in the heart of a spatial strategy location, as a site it is also a very natural fit for the local plan’s aspirations. Its location is central to jobs at the various Campuses (Wellcome, Granta Park, Babraham and over the county/district border in Great Chesterford), services and facilities (both delivered by the Site, and in the Wellcome Campus etc) and most importantly is located close to an existing frequent service train station. Indeed, Policy S/AMC/WHD states in its supporting text that the land immediately a round Whittlesford Parkway Station is “close to the southern cluster research and employment centres”. With the Site being close to both these research and employment centres and the station, it is clearly very well located. It is also noteworthy in the context of the overall spatial strategy that Whittlesford Parkway Station is existing major sustainable transport infrastructure and not a proposed solution which requires significant time and funding before it can come on board, unlike Grange Farm. While we do not necessarily dispute the allocation of Grange Farm, as we can deliver a scheme at the Site in tandem with it if necessary, it is not clear that allocating Grange Farm can be justified against the plan’s strategic objectives. In particular, when compared with the Site as a reasonable alternative, Grange Farm appears less well aligned with the aim of directing development to locations where active and public transport are the natural choice and where there is a strong relationship with existing (and proposed) major transport infrastructure.

The NPPF states (para 86) that policies should seek to address potential barriers to investment such as inadequate housing and (at para 87) refers to the need to recognise and plan for the specific location requirements and make provision for the infrastructure that is needed to support the growth of these industries. The Rural Southern cluster is what the NPPF envisages.

Whittlesford Parkway Station Policy Area Policy S/AMC/WHD

In many ways, the opportunities presented by the development of the Site are similar to the emerging allocation at Grange Farm, with the potential for a travel hub/link into onward sustainable travel. However, the key differentiating feature here is the access to an existing railway station (Whittlesford Parkway Station) which is operational today; it is not awaiting a funding inquiry and years away from being operational. It is of further note that currently, the CSET as proposed terminates before Grange Farm. Whittlesford Parkway Station also offers routes into Central, South and North Cambridge and south towards London, whereas the CSET route only goes to Addenbrookes. The Site has better onward travel and choice in this regard.

The Site, including the parcel of land to the north-west of the McDonald’s roundabout on the A505 which also sits within SmithsonHill’s ownership, offers exceptional opportunities via land, but also financial contributions from the wider development of the Site. Such contributions could enhance not just eastern access to Whittlesford Parkway Station, but also opportunities via this land to significantly improve active travel and enhance highways capacity at the roundabout. The Site is also centrally located within the Rural Southern Cluster and is in the right location to link the cluster together with wider improvements to the A505 corridor. SmithsonHill can effectively work with Councils, the Cambridge Growth Company and other landowners and developers, including the Wellcome Trust who are delivering their own development on the adjacent site, about how we help with those solutions.

It is also of significant relevance to the proposals mentioned above, that while the land parcel to the north-east of the McDonald’s roundabout is in the Green Belt, the NPPF consultation (December 2025) proposes that development (including residential) within a reasonable walking distance of a well-connected train station has a strong presumption in favour of development, regardless of the site’s Green Belt location. Our comprehensive response to Policy S/AMC/WHD: Whittlesford Parkway Station Policy Area addresses this.

Transport evidence

It is noted that whilst GCSP’s preferred option for development is predicated on amongst other things, responding to opportunities created by existing and proposed major new transport infrastructure, the GCLP is progressing without the publication of the Greater Cambridge Transport Strategy (GCTS).

The GCTS is proposed to provide the transport evidence base for the GCLP, yet it is not ready for comment via this consultation. Legal advice sought by the Councils means a ‘Statement of Intent’ has been published at this stage. The statement confirms the GCTS will:
• “Identify infrastructure requirements – confirming the transport infrastructure necessary to support the delivery of strategic development sites proposed within the Greater Cambridge Local Plan.
• Address wider growth and transport challenges and needs – setting out ambitious initiatives and policies to manage the broader transport demands arising from longer term and planned growth but also ensuring a better integrated transport system across Greater Cambridge for business and residents.”

The current timetable for the GCTS means it will not be published in draft until June 2026, before then being consulted upon and approved in November 2026. The Regulation 19 consultation for the GCLP will have to occur over similar timescales if it is to be submitted prior to the 31 December 2026 to ensure it will be examined under the NPPF 2024. It is not clear that the GCLP can be justified as per the local plan tests of soundness if its strategy is not based on proportionate, finalised and published evidence.

Delivery

Not only does the location of the Site lend itself to sustainable travel patterns from day one, it is also promoted by a joint landowner/developer who plans on building out at least part of the scheme, meaning it would be able to commence at pace without the need to sell the Site or seek a development partner. Hill could be delivering an initial few phases while other parcels are disposed of, meaning not just a quick start, but continuous delivery from multiple outlets. Hill has a strong track record of delivery in Cambridge and is committed to future delivery in and around the City. The presence of a developer with an interest in delivering the Site is not typical of all emerging allocations in this plan. In particular, Grange Farm does not appear to be promoted by a developer which inherently pushes back its delivery timescales compared to the Site. We note the Greater Cambridge Housing Delivery Study Addendum 2025 Update states that “Grange Farm is located to the south east of Cambridge in close proximity to Uttlesford District. There are currently no other strategic-scale new community allocations or commitments in close proximity to the proposed site, which should mean there are reduced market absorption risks”. However, we dispute that two strategic sites in close proximity would necessarily lead to market absorption risks. Firstly, as a developer is on board at the Site, it can come forward much quicker, years before Grange Farm, so there could be significant early periods of delivery at the Site where there would be no competition in the market. Secondly, there are a range of site-specific factors set out in Lichfields research Start to Finish which evidence site specific factors which can increase build out rates. This includes sites being in high demand areas (like Greater Cambridge), greenfield sites over brownfield, the number of outlets operating simultaneously and the housing mix with greater variety supporting higher build rates. There are many variables at play which means a blanket assumption that two strategic sites in close proximity would mean reduced market absorption is a blunt and inaccurate conclusion.

Summary

In the context of our comments on Policy S/JH, it is clear that for the draft GCLP to be found sound it needs to allocate more sites for residential development. Both to bring the planned levels of employment growth in line with the housing requirements this will generate, but also to ensure a positively prepared and justified housing trajectory. Our comment on Policy S/DS make clear that the Site is aligned with the spatial strategy of the draft GCLP; is centrally located within the Rural Southern Cluster; and is aligned with a key existing piece of operational sustainable transportation, Whittlesford Parkway Station. It is also unclear why the allocation of Grange Farm would be preferable to the Site, which is aligned with existing rapid sustainable transportation, unlike the CSET extension. Allocation of the Site offers a non-Green Belt option to bolstering the housing trajectory on a site which is aligned with the GCLP’s spatial strategy. It can also come forward in tandem with other large-scale developments, including Grange Farm.

The Spatial Strategy

The Spatial Strategy for the plan is articulated at Policy S/DS and goes through a five stage locationally-preferential sequence as set out below which is extracted from the policy.

“1. The need for jobs and homes will be met as far as possible in the following order of preference, having regard to the purposes of the Cambridge Green Belt:
a. Within the Cambridge urban area;
b. On the edge of Cambridge;
c. At an expanded Cambourne;
d. At other new settlements; and
e. In the rural southern cluster and wider rural area at Rural Centres and Minor Rural Centres.”

The area covered by the ‘Rural Southern Cluster’ does not appear to be defined on the plans Policies Map, but the Draft GCLP Figure 91 is a map showing the clustering of policies within this area. The Site (HELAA Site ID 200765) lies centrally within this area, immediately north of the Wellcome Genome Campus extension and adjacent to Whittlesford Parkway rail station. Save for the parcel known as Ricketts Field to the north of the A505, the Site is also not in the Green Belt.

Paragraph 2.55 of the plan states that the preferred option for development does the below:
“a. limit our climate impact and support thriving communities – locate development where active and public transport is the natural choice, with jobs, services and facilities located near to where people live, and responding to opportunities created by existing and proposed major new transport infrastructure;
b. protect and enhance our natural environment – maximise opportunities to use brownfield land, and ensure green infrastructure can be delivered alongside new development;
c. enable our national and global economic employment sectors to flourish – provide employment space of the right type in the right location to meet sector needs;
d. reinforce the distinctive character of our city, towns and villages – protect the Green Belt, and develop sites that can be well-integrated with existing communities, can be developed at densities, and using appropriate forms and patterns of development, which make best use of land while creating well-designed, characterful places; and
e. support all necessary utilities in a sustainable way – ensure that the development strategy can be supported by utilities in a way that protects and enhances the environment.” (Emphasis added)

The Site is not only located in the heart of a spatial strategy location, as a site it is also a very natural fit for the local plan’s aspirations. Its location is central to jobs at the various Campuses (Wellcome, Granta Park, Babraham and over the county/district border in Great Chesterford), services and facilities (both delivered by the Site, and in the Wellcome Campus etc) and most importantly is located close to an existing frequent service train station. Indeed, Policy S/AMC/WHD states in its supporting text that the land immediately a round Whittlesford Parkway Station is “close to the southern cluster research and employment centres”. With the Site being close to both these research and employment centres and the station, it is clearly very well located. It is also noteworthy in the context of the overall spatial strategy that Whittlesford Parkway Station is existing major sustainable transport infrastructure and not a proposed solution which requires significant time and funding before it can come on board, unlike Grange Farm. While we do not necessarily dispute the allocation of Grange Farm, as we can deliver a scheme at the Site in tandem with it if necessary, it is not clear that allocating Grange Farm can be justified against the plan’s strategic objectives. In particular, when compared with the Site as a reasonable alternative, Grange Farm appears less well aligned with the aim of directing development to locations where active and public transport are the natural choice and where there is a strong relationship with existing (and proposed) major transport infrastructure.

The NPPF states (para 86) that policies should seek to address potential barriers to investment such as inadequate housing and (at para 87) refers to the need to recognise and plan for the specific location requirements and make provision for the infrastructure that is needed to support the growth of these industries. The Rural Southern cluster is what the NPPF envisages.

Whittlesford Parkway Station Policy Area Policy S/AMC/WHD

In many ways, the opportunities presented by the development of the Site are similar to the emerging allocation at Grange Farm, with the potential for a travel hub/link into onward sustainable travel. However, the key differentiating feature here is the access to an existing railway station (Whittlesford Parkway Station) which is operational today; it is not awaiting a funding inquiry and years away from being operational. It is of further note that currently, the CSET as proposed terminates before Grange Farm. Whittlesford Parkway Station also offers routes into Central, South and North Cambridge and south towards London, whereas the CSET route only goes to Addenbrookes. The Site has better onward travel and choice in this regard.

The Site, including the parcel of land to the north-west of the McDonald’s roundabout on the A505 which also sits within SmithsonHill’s ownership, offers exceptional opportunities via land, but also financial contributions from the wider development of the Site. Such contributions could enhance not just eastern access to Whittlesford Parkway Station, but also opportunities via this land to significantly improve active travel and enhance highways capacity at the roundabout. The Site is also centrally located within the Rural Southern Cluster and is in the right location to link the cluster together with wider improvements to the A505 corridor. SmithsonHill can effectively work with Councils, the Cambridge Growth Company and other landowners and developers, including the Wellcome Trust who are delivering their own development on the adjacent site, about how we help with those solutions.

It is also of significant relevance to the proposals mentioned above, that while the land parcel to the north-east of the McDonald’s roundabout is in the Green Belt, the NPPF consultation (December 2025) proposes that development (including residential) within a reasonable walking distance of a well-connected train station has a strong presumption in favour of development, regardless of the site’s Green Belt location. Our comprehensive response to Policy S/AMC/WHD: Whittlesford Parkway Station Policy Area addresses this.

Transport evidence

It is noted that whilst GCSP’s preferred option for development is predicated on amongst other things, responding to opportunities created by existing and proposed major new transport infrastructure, the GCLP is progressing without the publication of the Greater Cambridge Transport Strategy (GCTS).

The GCTS is proposed to provide the transport evidence base for the GCLP, yet it is not ready for comment via this consultation. Legal advice sought by the Councils means a ‘Statement of Intent’ has been published at this stage. The statement confirms the GCTS will:
• “Identify infrastructure requirements – confirming the transport infrastructure necessary to support the delivery of strategic development sites proposed within the Greater Cambridge Local Plan.
• Address wider growth and transport challenges and needs – setting out ambitious initiatives and policies to manage the broader transport demands arising from longer term and planned growth but also ensuring a better integrated transport system across Greater Cambridge for business and residents.”

The current timetable for the GCTS means it will not be published in draft until June 2026, before then being consulted upon and approved in November 2026. The Regulation 19 consultation for the GCLP will have to occur over similar timescales if it is to be submitted prior to the 31 December 2026 to ensure it will be examined under the NPPF 2024. It is not clear that the GCLP can be justified as per the local plan tests of soundness if its strategy is not based on proportionate, finalised and published evidence.

Delivery

Not only does the location of the Site lend itself to sustainable travel patterns from day one, it is also promoted by a joint landowner/developer who plans on building out at least part of the scheme, meaning it would be able to commence at pace without the need to sell the Site or seek a development partner. Hill could be delivering an initial few phases while other parcels are disposed of, meaning not just a quick start, but continuous delivery from multiple outlets. Hill has a strong track record of delivery in Cambridge and is committed to future delivery in and around the City. The presence of a developer with an interest in delivering the Site is not typical of all emerging allocations in this plan. In particular, Grange Farm does not appear to be promoted by a developer which inherently pushes back its delivery timescales compared to the Site. We note the Greater Cambridge Housing Delivery Study Addendum 2025 Update states that “Grange Farm is located to the south east of Cambridge in close proximity to Uttlesford District. There are currently no other strategic-scale new community allocations or commitments in close proximity to the proposed site, which should mean there are reduced market absorption risks”. However, we dispute that two strategic sites in close proximity would necessarily lead to market absorption risks. Firstly, as a developer is on board at the Site, it can come forward much quicker, years before Grange Farm, so there could be significant early periods of delivery at the Site where there would be no competition in the market. Secondly, there are a range of site-specific factors set out in Lichfields research Start to Finish which evidence site specific factors which can increase build out rates. This includes sites being in high demand areas (like Greater Cambridge), greenfield sites over brownfield, the number of outlets operating simultaneously and the housing mix with greater variety supporting higher build rates. There are many variables at play which means a blanket assumption that two strategic sites in close proximity would mean reduced market absorption is a blunt and inaccurate conclusion.

Summary

In the context of our comments on Policy S/JH, it is clear that for the draft GCLP to be found sound it needs to allocate more sites for residential development. Both to bring the planned levels of employment growth in line with the housing requirements this will generate, but also to ensure a positively prepared and justified housing trajectory. Our comment on Policy S/DS make clear that the Site is aligned with the spatial strategy of the draft GCLP; is centrally located within the Rural Southern Cluster; and is aligned with a key existing piece of operational sustainable transportation, Whittlesford Parkway Station. It is also unclear why the allocation of Grange Farm would be preferable to the Site, which is aligned with existing rapid sustainable transportation, unlike the CSET extension. Allocation of the Site offers a non-Green Belt option to bolstering the housing trajectory on a site which is aligned with the GCLP’s spatial strategy. It can also come forward in tandem with other large-scale developments, including Grange Farm.

The Spatial Strategy

The Spatial Strategy for the plan is articulated at Policy S/DS and goes through a five stage locationally-preferential sequence as set out below which is extracted from the policy.

“1. The need for jobs and homes will be met as far as possible in the following order of preference, having regard to the purposes of the Cambridge Green Belt:
a. Within the Cambridge urban area;
b. On the edge of Cambridge;
c. At an expanded Cambourne;
d. At other new settlements; and
e. In the rural southern cluster and wider rural area at Rural Centres and Minor Rural Centres.”

The area covered by the ‘Rural Southern Cluster’ does not appear to be defined on the plans Policies Map, but the Draft GCLP Figure 91 is a map showing the clustering of policies within this area. The Site (HELAA Site ID 200765) lies centrally within this area, immediately north of the Wellcome Genome Campus extension and adjacent to Whittlesford Parkway rail station. Save for the parcel known as Ricketts Field to the north of the A505, the Site is also not in the Green Belt.

Paragraph 2.55 of the plan states that the preferred option for development does the below:
“a. limit our climate impact and support thriving communities – locate development where active and public transport is the natural choice, with jobs, services and facilities located near to where people live, and responding to opportunities created by existing and proposed major new transport infrastructure;
b. protect and enhance our natural environment – maximise opportunities to use brownfield land, and ensure green infrastructure can be delivered alongside new development;
c. enable our national and global economic employment sectors to flourish – provide employment space of the right type in the right location to meet sector needs;
d. reinforce the distinctive character of our city, towns and villages – protect the Green Belt, and develop sites that can be well-integrated with existing communities, can be developed at densities, and using appropriate forms and patterns of development, which make best use of land while creating well-designed, characterful places; and
e. support all necessary utilities in a sustainable way – ensure that the development strategy can be supported by utilities in a way that protects and enhances the environment.” (Emphasis added)

The Site is not only located in the heart of a spatial strategy location, as a site it is also a very natural fit for the local plan’s aspirations. Its location is central to jobs at the various Campuses (Wellcome, Granta Park, Babraham and over the county/district border in Great Chesterford), services and facilities (both delivered by the Site, and in the Wellcome Campus etc) and most importantly is located close to an existing frequent service train station. Indeed, Policy S/AMC/WHD states in its supporting text that the land immediately a round Whittlesford Parkway Station is “close to the southern cluster research and employment centres”. With the Site being close to both these research and employment centres and the station, it is clearly very well located. It is also noteworthy in the context of the overall spatial strategy that Whittlesford Parkway Station is existing major sustainable transport infrastructure and not a proposed solution which requires significant time and funding before it can come on board, unlike Grange Farm. While we do not necessarily dispute the allocation of Grange Farm, as we can deliver a scheme at the Site in tandem with it if necessary, it is not clear that allocating Grange Farm can be justified against the plan’s strategic objectives. In particular, when compared with the Site as a reasonable alternative, Grange Farm appears less well aligned with the aim of directing development to locations where active and public transport are the natural choice and where there is a strong relationship with existing (and proposed) major transport infrastructure.

The NPPF states (para 86) that policies should seek to address potential barriers to investment such as inadequate housing and (at para 87) refers to the need to recognise and plan for the specific location requirements and make provision for the infrastructure that is needed to support the growth of these industries. The Rural Southern cluster is what the NPPF envisages.

Whittlesford Parkway Station Policy Area Policy S/AMC/WHD

In many ways, the opportunities presented by the development of the Site are similar to the emerging allocation at Grange Farm, with the potential for a travel hub/link into onward sustainable travel. However, the key differentiating feature here is the access to an existing railway station (Whittlesford Parkway Station) which is operational today; it is not awaiting a funding inquiry and years away from being operational. It is of further note that currently, the CSET as proposed terminates before Grange Farm. Whittlesford Parkway Station also offers routes into Central, South and North Cambridge and south towards London, whereas the CSET route only goes to Addenbrookes. The Site has better onward travel and choice in this regard.

The Site, including the parcel of land to the north-west of the McDonald’s roundabout on the A505 which also sits within SmithsonHill’s ownership, offers exceptional opportunities via land, but also financial contributions from the wider development of the Site. Such contributions could enhance not just eastern access to Whittlesford Parkway Station, but also opportunities via this land to significantly improve active travel and enhance highways capacity at the roundabout. The Site is also centrally located within the Rural Southern Cluster and is in the right location to link the cluster together with wider improvements to the A505 corridor. SmithsonHill can effectively work with Councils, the Cambridge Growth Company and other landowners and developers, including the Wellcome Trust who are delivering their own development on the adjacent site, about how we help with those solutions.

It is also of significant relevance to the proposals mentioned above, that while the land parcel to the north-east of the McDonald’s roundabout is in the Green Belt, the NPPF consultation (December 2025) proposes that development (including residential) within a reasonable walking distance of a well-connected train station has a strong presumption in favour of development, regardless of the site’s Green Belt location. Our comprehensive response to Policy S/AMC/WHD: Whittlesford Parkway Station Policy Area addresses this.

Transport evidence

It is noted that whilst GCSP’s preferred option for development is predicated on amongst other things, responding to opportunities created by existing and proposed major new transport infrastructure, the GCLP is progressing without the publication of the Greater Cambridge Transport Strategy (GCTS).

The GCTS is proposed to provide the transport evidence base for the GCLP, yet it is not ready for comment via this consultation. Legal advice sought by the Councils means a ‘Statement of Intent’ has been published at this stage. The statement confirms the GCTS will:
• “Identify infrastructure requirements – confirming the transport infrastructure necessary to support the delivery of strategic development sites proposed within the Greater Cambridge Local Plan.
• Address wider growth and transport challenges and needs – setting out ambitious initiatives and policies to manage the broader transport demands arising from longer term and planned growth but also ensuring a better integrated transport system across Greater Cambridge for business and residents.”

The current timetable for the GCTS means it will not be published in draft until June 2026, before then being consulted upon and approved in November 2026. The Regulation 19 consultation for the GCLP will have to occur over similar timescales if it is to be submitted prior to the 31 December 2026 to ensure it will be examined under the NPPF 2024. It is not clear that the GCLP can be justified as per the local plan tests of soundness if its strategy is not based on proportionate, finalised and published evidence.

Delivery

Not only does the location of the Site lend itself to sustainable travel patterns from day one, it is also promoted by a joint landowner/developer who plans on building out at least part of the scheme, meaning it would be able to commence at pace without the need to sell the Site or seek a development partner. Hill could be delivering an initial few phases while other parcels are disposed of, meaning not just a quick start, but continuous delivery from multiple outlets. Hill has a strong track record of delivery in Cambridge and is committed to future delivery in and around the City. The presence of a developer with an interest in delivering the Site is not typical of all emerging allocations in this plan. In particular, Grange Farm does not appear to be promoted by a developer which inherently pushes back its delivery timescales compared to the Site. We note the Greater Cambridge Housing Delivery Study Addendum 2025 Update states that “Grange Farm is located to the south east of Cambridge in close proximity to Uttlesford District. There are currently no other strategic-scale new community allocations or commitments in close proximity to the proposed site, which should mean there are reduced market absorption risks”. However, we dispute that two strategic sites in close proximity would necessarily lead to market absorption risks. Firstly, as a developer is on board at the Site, it can come forward much quicker, years before Grange Farm, so there could be significant early periods of delivery at the Site where there would be no competition in the market. Secondly, there are a range of site-specific factors set out in Lichfields research Start to Finish which evidence site specific factors which can increase build out rates. This includes sites being in high demand areas (like Greater Cambridge), greenfield sites over brownfield, the number of outlets operating simultaneously and the housing mix with greater variety supporting higher build rates. There are many variables at play which means a blanket assumption that two strategic sites in close proximity would mean reduced market absorption is a blunt and inaccurate conclusion.

Summary

In the context of our comments on Policy S/JH, it is clear that for the draft GCLP to be found sound it needs to allocate more sites for residential development. Both to bring the planned levels of employment growth in line with the housing requirements this will generate, but also to ensure a positively prepared and justified housing trajectory. Our comment on Policy S/DS make clear that the Site is aligned with the spatial strategy of the draft GCLP; is centrally located within the Rural Southern Cluster; and is aligned with a key existing piece of operational sustainable transportation, Whittlesford Parkway Station. It is also unclear why the allocation of Grange Farm would be preferable to the Site, which is aligned with existing rapid sustainable transportation, unlike the CSET extension. Allocation of the Site offers a non-Green Belt option to bolstering the housing trajectory on a site which is aligned with the GCLP’s spatial strategy. It can also come forward in tandem with other large-scale developments, including Grange Farm.

The Spatial Strategy

The Spatial Strategy for the plan is articulated at Policy S/DS and goes through a five stage locationally-preferential sequence as set out below which is extracted from the policy.

“1. The need for jobs and homes will be met as far as possible in the following order of preference, having regard to the purposes of the Cambridge Green Belt:
a. Within the Cambridge urban area;
b. On the edge of Cambridge;
c. At an expanded Cambourne;
d. At other new settlements; and
e. In the rural southern cluster and wider rural area at Rural Centres and Minor Rural Centres.”

The area covered by the ‘Rural Southern Cluster’ does not appear to be defined on the plans Policies Map, but the Draft GCLP Figure 91 is a map showing the clustering of policies within this area. The Site (HELAA Site ID 200765) lies centrally within this area, immediately north of the Wellcome Genome Campus extension and adjacent to Whittlesford Parkway rail station. Save for the parcel known as Ricketts Field to the north of the A505, the Site is also not in the Green Belt.

Paragraph 2.55 of the plan states that the preferred option for development does the below:
“a. limit our climate impact and support thriving communities – locate development where active and public transport is the natural choice, with jobs, services and facilities located near to where people live, and responding to opportunities created by existing and proposed major new transport infrastructure;
b. protect and enhance our natural environment – maximise opportunities to use brownfield land, and ensure green infrastructure can be delivered alongside new development;
c. enable our national and global economic employment sectors to flourish – provide employment space of the right type in the right location to meet sector needs;
d. reinforce the distinctive character of our city, towns and villages – protect the Green Belt, and develop sites that can be well-integrated with existing communities, can be developed at densities, and using appropriate forms and patterns of development, which make best use of land while creating well-designed, characterful places; and
e. support all necessary utilities in a sustainable way – ensure that the development strategy can be supported by utilities in a way that protects and enhances the environment.” (Emphasis added)

The Site is not only located in the heart of a spatial strategy location, as a site it is also a very natural fit for the local plan’s aspirations. Its location is central to jobs at the various Campuses (Wellcome, Granta Park, Babraham and over the county/district border in Great Chesterford), services and facilities (both delivered by the Site, and in the Wellcome Campus etc) and most importantly is located close to an existing frequent service train station. Indeed, Policy S/AMC/WHD states in its supporting text that the land immediately a round Whittlesford Parkway Station is “close to the southern cluster research and employment centres”. With the Site being close to both these research and employment centres and the station, it is clearly very well located. It is also noteworthy in the context of the overall spatial strategy that Whittlesford Parkway Station is existing major sustainable transport infrastructure and not a proposed solution which requires significant time and funding before it can come on board, unlike Grange Farm. While we do not necessarily dispute the allocation of Grange Farm, as we can deliver a scheme at the Site in tandem with it if necessary, it is not clear that allocating Grange Farm can be justified against the plan’s strategic objectives. In particular, when compared with the Site as a reasonable alternative, Grange Farm appears less well aligned with the aim of directing development to locations where active and public transport are the natural choice and where there is a strong relationship with existing (and proposed) major transport infrastructure.

The NPPF states (para 86) that policies should seek to address potential barriers to investment such as inadequate housing and (at para 87) refers to the need to recognise and plan for the specific location requirements and make provision for the infrastructure that is needed to support the growth of these industries. The Rural Southern cluster is what the NPPF envisages.

Whittlesford Parkway Station Policy Area Policy S/AMC/WHD

In many ways, the opportunities presented by the development of the Site are similar to the emerging allocation at Grange Farm, with the potential for a travel hub/link into onward sustainable travel. However, the key differentiating feature here is the access to an existing railway station (Whittlesford Parkway Station) which is operational today; it is not awaiting a funding inquiry and years away from being operational. It is of further note that currently, the CSET as proposed terminates before Grange Farm. Whittlesford Parkway Station also offers routes into Central, South and North Cambridge and south towards London, whereas the CSET route only goes to Addenbrookes. The Site has better onward travel and choice in this regard.

The Site, including the parcel of land to the north-west of the McDonald’s roundabout on the A505 which also sits within SmithsonHill’s ownership, offers exceptional opportunities via land, but also financial contributions from the wider development of the Site. Such contributions could enhance not just eastern access to Whittlesford Parkway Station, but also opportunities via this land to significantly improve active travel and enhance highways capacity at the roundabout. The Site is also centrally located within the Rural Southern Cluster and is in the right location to link the cluster together with wider improvements to the A505 corridor. SmithsonHill can effectively work with Councils, the Cambridge Growth Company and other landowners and developers, including the Wellcome Trust who are delivering their own development on the adjacent site, about how we help with those solutions.

It is also of significant relevance to the proposals mentioned above, that while the land parcel to the north-east of the McDonald’s roundabout is in the Green Belt, the NPPF consultation (December 2025) proposes that development (including residential) within a reasonable walking distance of a well-connected train station has a strong presumption in favour of development, regardless of the site’s Green Belt location. Our comprehensive response to Policy S/AMC/WHD: Whittlesford Parkway Station Policy Area addresses this.

Transport evidence

It is noted that whilst GCSP’s preferred option for development is predicated on amongst other things, responding to opportunities created by existing and proposed major new transport infrastructure, the GCLP is progressing without the publication of the Greater Cambridge Transport Strategy (GCTS).

The GCTS is proposed to provide the transport evidence base for the GCLP, yet it is not ready for comment via this consultation. Legal advice sought by the Councils means a ‘Statement of Intent’ has been published at this stage. The statement confirms the GCTS will:
• “Identify infrastructure requirements – confirming the transport infrastructure necessary to support the delivery of strategic development sites proposed within the Greater Cambridge Local Plan.
• Address wider growth and transport challenges and needs – setting out ambitious initiatives and policies to manage the broader transport demands arising from longer term and planned growth but also ensuring a better integrated transport system across Greater Cambridge for business and residents.”

The current timetable for the GCTS means it will not be published in draft until June 2026, before then being consulted upon and approved in November 2026. The Regulation 19 consultation for the GCLP will have to occur over similar timescales if it is to be submitted prior to the 31 December 2026 to ensure it will be examined under the NPPF 2024. It is not clear that the GCLP can be justified as per the local plan tests of soundness if its strategy is not based on proportionate, finalised and published evidence.

Delivery

Not only does the location of the Site lend itself to sustainable travel patterns from day one, it is also promoted by a joint landowner/developer who plans on building out at least part of the scheme, meaning it would be able to commence at pace without the need to sell the Site or seek a development partner. Hill could be delivering an initial few phases while other parcels are disposed of, meaning not just a quick start, but continuous delivery from multiple outlets. Hill has a strong track record of delivery in Cambridge and is committed to future delivery in and around the City. The presence of a developer with an interest in delivering the Site is not typical of all emerging allocations in this plan. In particular, Grange Farm does not appear to be promoted by a developer which inherently pushes back its delivery timescales compared to the Site. We note the Greater Cambridge Housing Delivery Study Addendum 2025 Update states that “Grange Farm is located to the south east of Cambridge in close proximity to Uttlesford District. There are currently no other strategic-scale new community allocations or commitments in close proximity to the proposed site, which should mean there are reduced market absorption risks”. However, we dispute that two strategic sites in close proximity would necessarily lead to market absorption risks. Firstly, as a developer is on board at the Site, it can come forward much quicker, years before Grange Farm, so there could be significant early periods of delivery at the Site where there would be no competition in the market. Secondly, there are a range of site-specific factors set out in Lichfields research Start to Finish which evidence site specific factors which can increase build out rates. This includes sites being in high demand areas (like Greater Cambridge), greenfield sites over brownfield, the number of outlets operating simultaneously and the housing mix with greater variety supporting higher build rates. There are many variables at play which means a blanket assumption that two strategic sites in close proximity would mean reduced market absorption is a blunt and inaccurate conclusion.

Summary

In the context of our comments on Policy S/JH, it is clear that for the draft GCLP to be found sound it needs to allocate more sites for residential development. Both to bring the planned levels of employment growth in line with the housing requirements this will generate, but also to ensure a positively prepared and justified housing trajectory. Our comment on Policy S/DS make clear that the Site is aligned with the spatial strategy of the draft GCLP; is centrally located within the Rural Southern Cluster; and is aligned with a key existing piece of operational sustainable transportation, Whittlesford Parkway Station. It is also unclear why the allocation of Grange Farm would be preferable to the Site, which is aligned with existing rapid sustainable transportation, unlike the CSET extension. Allocation of the Site offers a non-Green Belt option to bolstering the housing trajectory on a site which is aligned with the GCLP’s spatial strategy. It can also come forward in tandem with other large-scale developments, including Grange Farm.

The Spatial Strategy

The Spatial Strategy for the plan is articulated at Policy S/DS and goes through a five stage locationally-preferential sequence as set out below which is extracted from the policy.

“1. The need for jobs and homes will be met as far as possible in the following order of preference, having regard to the purposes of the Cambridge Green Belt:
a. Within the Cambridge urban area;
b. On the edge of Cambridge;
c. At an expanded Cambourne;
d. At other new settlements; and
e. In the rural southern cluster and wider rural area at Rural Centres and Minor Rural Centres.”

The area covered by the ‘Rural Southern Cluster’ does not appear to be defined on the plans Policies Map, but the Draft GCLP Figure 91 is a map showing the clustering of policies within this area. The Site (HELAA Site ID 200765) lies centrally within this area, immediately north of the Wellcome Genome Campus extension and adjacent to Whittlesford Parkway rail station. Save for the parcel known as Ricketts Field to the north of the A505, the Site is also not in the Green Belt.

Paragraph 2.55 of the plan states that the preferred option for development does the below:
“a. limit our climate impact and support thriving communities – locate development where active and public transport is the natural choice, with jobs, services and facilities located near to where people live, and responding to opportunities created by existing and proposed major new transport infrastructure;
b. protect and enhance our natural environment – maximise opportunities to use brownfield land, and ensure green infrastructure can be delivered alongside new development;
c. enable our national and global economic employment sectors to flourish – provide employment space of the right type in the right location to meet sector needs;
d. reinforce the distinctive character of our city, towns and villages – protect the Green Belt, and develop sites that can be well-integrated with existing communities, can be developed at densities, and using appropriate forms and patterns of development, which make best use of land while creating well-designed, characterful places; and
e. support all necessary utilities in a sustainable way – ensure that the development strategy can be supported by utilities in a way that protects and enhances the environment.” (Emphasis added)

The Site is not only located in the heart of a spatial strategy location, as a site it is also a very natural fit for the local plan’s aspirations. Its location is central to jobs at the various Campuses (Wellcome, Granta Park, Babraham and over the county/district border in Great Chesterford), services and facilities (both delivered by the Site, and in the Wellcome Campus etc) and most importantly is located close to an existing frequent service train station. Indeed, Policy S/AMC/WHD states in its supporting text that the land immediately a round Whittlesford Parkway Station is “close to the southern cluster research and employment centres”. With the Site being close to both these research and employment centres and the station, it is clearly very well located. It is also noteworthy in the context of the overall spatial strategy that Whittlesford Parkway Station is existing major sustainable transport infrastructure and not a proposed solution which requires significant time and funding before it can come on board, unlike Grange Farm. While we do not necessarily dispute the allocation of Grange Farm, as we can deliver a scheme at the Site in tandem with it if necessary, it is not clear that allocating Grange Farm can be justified against the plan’s strategic objectives. In particular, when compared with the Site as a reasonable alternative, Grange Farm appears less well aligned with the aim of directing development to locations where active and public transport are the natural choice and where there is a strong relationship with existing (and proposed) major transport infrastructure.

The NPPF states (para 86) that policies should seek to address potential barriers to investment such as inadequate housing and (at para 87) refers to the need to recognise and plan for the specific location requirements and make provision for the infrastructure that is needed to support the growth of these industries. The Rural Southern cluster is what the NPPF envisages.

Whittlesford Parkway Station Policy Area Policy S/AMC/WHD

In many ways, the opportunities presented by the development of the Site are similar to the emerging allocation at Grange Farm, with the potential for a travel hub/link into onward sustainable travel. However, the key differentiating feature here is the access to an existing railway station (Whittlesford Parkway Station) which is operational today; it is not awaiting a funding inquiry and years away from being operational. It is of further note that currently, the CSET as proposed terminates before Grange Farm. Whittlesford Parkway Station also offers routes into Central, South and North Cambridge and south towards London, whereas the CSET route only goes to Addenbrookes. The Site has better onward travel and choice in this regard.

The Site, including the parcel of land to the north-west of the McDonald’s roundabout on the A505 which also sits within SmithsonHill’s ownership, offers exceptional opportunities via land, but also financial contributions from the wider development of the Site. Such contributions could enhance not just eastern access to Whittlesford Parkway Station, but also opportunities via this land to significantly improve active travel and enhance highways capacity at the roundabout. The Site is also centrally located within the Rural Southern Cluster and is in the right location to link the cluster together with wider improvements to the A505 corridor. SmithsonHill can effectively work with Councils, the Cambridge Growth Company and other landowners and developers, including the Wellcome Trust who are delivering their own development on the adjacent site, about how we help with those solutions.

It is also of significant relevance to the proposals mentioned above, that while the land parcel to the north-east of the McDonald’s roundabout is in the Green Belt, the NPPF consultation (December 2025) proposes that development (including residential) within a reasonable walking distance of a well-connected train station has a strong presumption in favour of development, regardless of the site’s Green Belt location. Our comprehensive response to Policy S/AMC/WHD: Whittlesford Parkway Station Policy Area addresses this.

Transport evidence

It is noted that whilst GCSP’s preferred option for development is predicated on amongst other things, responding to opportunities created by existing and proposed major new transport infrastructure, the GCLP is progressing without the publication of the Greater Cambridge Transport Strategy (GCTS).

The GCTS is proposed to provide the transport evidence base for the GCLP, yet it is not ready for comment via this consultation. Legal advice sought by the Councils means a ‘Statement of Intent’ has been published at this stage. The statement confirms the GCTS will:
• “Identify infrastructure requirements – confirming the transport infrastructure necessary to support the delivery of strategic development sites proposed within the Greater Cambridge Local Plan.
• Address wider growth and transport challenges and needs – setting out ambitious initiatives and policies to manage the broader transport demands arising from longer term and planned growth but also ensuring a better integrated transport system across Greater Cambridge for business and residents.”

The current timetable for the GCTS means it will not be published in draft until June 2026, before then being consulted upon and approved in November 2026. The Regulation 19 consultation for the GCLP will have to occur over similar timescales if it is to be submitted prior to the 31 December 2026 to ensure it will be examined under the NPPF 2024. It is not clear that the GCLP can be justified as per the local plan tests of soundness if its strategy is not based on proportionate, finalised and published evidence.

Delivery

Not only does the location of the Site lend itself to sustainable travel patterns from day one, it is also promoted by a joint landowner/developer who plans on building out at least part of the scheme, meaning it would be able to commence at pace without the need to sell the Site or seek a development partner. Hill could be delivering an initial few phases while other parcels are disposed of, meaning not just a quick start, but continuous delivery from multiple outlets. Hill has a strong track record of delivery in Cambridge and is committed to future delivery in and around the City. The presence of a developer with an interest in delivering the Site is not typical of all emerging allocations in this plan. In particular, Grange Farm does not appear to be promoted by a developer which inherently pushes back its delivery timescales compared to the Site. We note the Greater Cambridge Housing Delivery Study Addendum 2025 Update states that “Grange Farm is located to the south east of Cambridge in close proximity to Uttlesford District. There are currently no other strategic-scale new community allocations or commitments in close proximity to the proposed site, which should mean there are reduced market absorption risks”. However, we dispute that two strategic sites in close proximity would necessarily lead to market absorption risks. Firstly, as a developer is on board at the Site, it can come forward much quicker, years before Grange Farm, so there could be significant early periods of delivery at the Site where there would be no competition in the market. Secondly, there are a range of site-specific factors set out in Lichfields research Start to Finish which evidence site specific factors which can increase build out rates. This includes sites being in high demand areas (like Greater Cambridge), greenfield sites over brownfield, the number of outlets operating simultaneously and the housing mix with greater variety supporting higher build rates. There are many variables at play which means a blanket assumption that two strategic sites in close proximity would mean reduced market absorption is a blunt and inaccurate conclusion.

Summary

In the context of our comments on Policy S/JH, it is clear that for the draft GCLP to be found sound it needs to allocate more sites for residential development. Both to bring the planned levels of employment growth in line with the housing requirements this will generate, but also to ensure a positively prepared and justified housing trajectory. Our comment on Policy S/DS make clear that the Site is aligned with the spatial strategy of the draft GCLP; is centrally located within the Rural Southern Cluster; and is aligned with a key existing piece of operational sustainable transportation, Whittlesford Parkway Station. It is also unclear why the allocation of Grange Farm would be preferable to the Site, which is aligned with existing rapid sustainable transportation, unlike the CSET extension. Allocation of the Site offers a non-Green Belt option to bolstering the housing trajectory on a site which is aligned with the GCLP’s spatial strategy. It can also come forward in tandem with other large-scale developments, including Grange Farm.

The Spatial Strategy

The Spatial Strategy for the plan is articulated at Policy S/DS and goes through a five stage locationally-preferential sequence as set out below which is extracted from the policy.

“1. The need for jobs and homes will be met as far as possible in the following order of preference, having regard to the purposes of the Cambridge Green Belt:
a. Within the Cambridge urban area;
b. On the edge of Cambridge;
c. At an expanded Cambourne;
d. At other new settlements; and
e. In the rural southern cluster and wider rural area at Rural Centres and Minor Rural Centres.”

The area covered by the ‘Rural Southern Cluster’ does not appear to be defined on the plans Policies Map, but the Draft GCLP Figure 91 is a map showing the clustering of policies within this area. The Site (HELAA Site ID 200765) lies centrally within this area, immediately north of the Wellcome Genome Campus extension and adjacent to Whittlesford Parkway rail station. Save for the parcel known as Ricketts Field to the north of the A505, the Site is also not in the Green Belt.

Paragraph 2.55 of the plan states that the preferred option for development does the below:
“a. limit our climate impact and support thriving communities – locate development where active and public transport is the natural choice, with jobs, services and facilities located near to where people live, and responding to opportunities created by existing and proposed major new transport infrastructure;
b. protect and enhance our natural environment – maximise opportunities to use brownfield land, and ensure green infrastructure can be delivered alongside new development;
c. enable our national and global economic employment sectors to flourish – provide employment space of the right type in the right location to meet sector needs;
d. reinforce the distinctive character of our city, towns and villages – protect the Green Belt, and develop sites that can be well-integrated with existing communities, can be developed at densities, and using appropriate forms and patterns of development, which make best use of land while creating well-designed, characterful places; and
e. support all necessary utilities in a sustainable way – ensure that the development strategy can be supported by utilities in a way that protects and enhances the environment.” (Emphasis added)

The Site is not only located in the heart of a spatial strategy location, as a site it is also a very natural fit for the local plan’s aspirations. Its location is central to jobs at the various Campuses (Wellcome, Granta Park, Babraham and over the county/district border in Great Chesterford), services and facilities (both delivered by the Site, and in the Wellcome Campus etc) and most importantly is located close to an existing frequent service train station. Indeed, Policy S/AMC/WHD states in its supporting text that the land immediately a round Whittlesford Parkway Station is “close to the southern cluster research and employment centres”. With the Site being close to both these research and employment centres and the station, it is clearly very well located. It is also noteworthy in the context of the overall spatial strategy that Whittlesford Parkway Station is existing major sustainable transport infrastructure and not a proposed solution which requires significant time and funding before it can come on board, unlike Grange Farm. While we do not necessarily dispute the allocation of Grange Farm, as we can deliver a scheme at the Site in tandem with it if necessary, it is not clear that allocating Grange Farm can be justified against the plan’s strategic objectives. In particular, when compared with the Site as a reasonable alternative, Grange Farm appears less well aligned with the aim of directing development to locations where active and public transport are the natural choice and where there is a strong relationship with existing (and proposed) major transport infrastructure.

The NPPF states (para 86) that policies should seek to address potential barriers to investment such as inadequate housing and (at para 87) refers to the need to recognise and plan for the specific location requirements and make provision for the infrastructure that is needed to support the growth of these industries. The Rural Southern cluster is what the NPPF envisages.

Whittlesford Parkway Station Policy Area Policy S/AMC/WHD

In many ways, the opportunities presented by the development of the Site are similar to the emerging allocation at Grange Farm, with the potential for a travel hub/link into onward sustainable travel. However, the key differentiating feature here is the access to an existing railway station (Whittlesford Parkway Station) which is operational today; it is not awaiting a funding inquiry and years away from being operational. It is of further note that currently, the CSET as proposed terminates before Grange Farm. Whittlesford Parkway Station also offers routes into Central, South and North Cambridge and south towards London, whereas the CSET route only goes to Addenbrookes. The Site has better onward travel and choice in this regard.

The Site, including the parcel of land to the north-west of the McDonald’s roundabout on the A505 which also sits within SmithsonHill’s ownership, offers exceptional opportunities via land, but also financial contributions from the wider development of the Site. Such contributions could enhance not just eastern access to Whittlesford Parkway Station, but also opportunities via this land to significantly improve active travel and enhance highways capacity at the roundabout. The Site is also centrally located within the Rural Southern Cluster and is in the right location to link the cluster together with wider improvements to the A505 corridor. SmithsonHill can effectively work with Councils, the Cambridge Growth Company and other landowners and developers, including the Wellcome Trust who are delivering their own development on the adjacent site, about how we help with those solutions.

It is also of significant relevance to the proposals mentioned above, that while the land parcel to the north-east of the McDonald’s roundabout is in the Green Belt, the NPPF consultation (December 2025) proposes that development (including residential) within a reasonable walking distance of a well-connected train station has a strong presumption in favour of development, regardless of the site’s Green Belt location. Our comprehensive response to Policy S/AMC/WHD: Whittlesford Parkway Station Policy Area addresses this.

Transport evidence

It is noted that whilst GCSP’s preferred option for development is predicated on amongst other things, responding to opportunities created by existing and proposed major new transport infrastructure, the GCLP is progressing without the publication of the Greater Cambridge Transport Strategy (GCTS).

The GCTS is proposed to provide the transport evidence base for the GCLP, yet it is not ready for comment via this consultation. Legal advice sought by the Councils means a ‘Statement of Intent’ has been published at this stage. The statement confirms the GCTS will:
• “Identify infrastructure requirements – confirming the transport infrastructure necessary to support the delivery of strategic development sites proposed within the Greater Cambridge Local Plan.
• Address wider growth and transport challenges and needs – setting out ambitious initiatives and policies to manage the broader transport demands arising from longer term and planned growth but also ensuring a better integrated transport system across Greater Cambridge for business and residents.”

The current timetable for the GCTS means it will not be published in draft until June 2026, before then being consulted upon and approved in November 2026. The Regulation 19 consultation for the GCLP will have to occur over similar timescales if it is to be submitted prior to the 31 December 2026 to ensure it will be examined under the NPPF 2024. It is not clear that the GCLP can be justified as per the local plan tests of soundness if its strategy is not based on proportionate, finalised and published evidence.

Delivery

Not only does the location of the Site lend itself to sustainable travel patterns from day one, it is also promoted by a joint landowner/developer who plans on building out at least part of the scheme, meaning it would be able to commence at pace without the need to sell the Site or seek a development partner. Hill could be delivering an initial few phases while other parcels are disposed of, meaning not just a quick start, but continuous delivery from multiple outlets. Hill has a strong track record of delivery in Cambridge and is committed to future delivery in and around the City. The presence of a developer with an interest in delivering the Site is not typical of all emerging allocations in this plan. In particular, Grange Farm does not appear to be promoted by a developer which inherently pushes back its delivery timescales compared to the Site. We note the Greater Cambridge Housing Delivery Study Addendum 2025 Update states that “Grange Farm is located to the south east of Cambridge in close proximity to Uttlesford District. There are currently no other strategic-scale new community allocations or commitments in close proximity to the proposed site, which should mean there are reduced market absorption risks”. However, we dispute that two strategic sites in close proximity would necessarily lead to market absorption risks. Firstly, as a developer is on board at the Site, it can come forward much quicker, years before Grange Farm, so there could be significant early periods of delivery at the Site where there would be no competition in the market. Secondly, there are a range of site-specific factors set out in Lichfields research Start to Finish which evidence site specific factors which can increase build out rates. This includes sites being in high demand areas (like Greater Cambridge), greenfield sites over brownfield, the number of outlets operating simultaneously and the housing mix with greater variety supporting higher build rates. There are many variables at play which means a blanket assumption that two strategic sites in close proximity would mean reduced market absorption is a blunt and inaccurate conclusion.

Summary

In the context of our comments on Policy S/JH, it is clear that for the draft GCLP to be found sound it needs to allocate more sites for residential development. Both to bring the planned levels of employment growth in line with the housing requirements this will generate, but also to ensure a positively prepared and justified housing trajectory. Our comment on Policy S/DS make clear that the Site is aligned with the spatial strategy of the draft GCLP; is centrally located within the Rural Southern Cluster; and is aligned with a key existing piece of operational sustainable transportation, Whittlesford Parkway Station. It is also unclear why the allocation of Grange Farm would be preferable to the Site, which is aligned with existing rapid sustainable transportation, unlike the CSET extension. Allocation of the Site offers a non-Green Belt option to bolstering the housing trajectory on a site which is aligned with the GCLP’s spatial strategy. It can also come forward in tandem with other large-scale developments, including Grange Farm.