Draft Greater Cambridge Local Plan for consultation

Comment

Representation ID: 208668

Received: 30/01/2026

Respondent: Guilden Morden Developments Ltd

Agent: JMS Planning & Development

JMS and GMD have previously been involved in the Local Plan-making process for Greater Cambridge, with a HELAA submission for Land South of New Road, Guilden Morden (site reference 40563), made as part of the consultations in March 2025 and in 2021. We also take this opportunity to comment on the updated, albeit incomplete, 2025 GCSP for the site (See attachment). The site should be deemed suitable, available and achievable for the preferred development type.

Comment

Representation ID: 208669

Received: 30/01/2026

Respondent: Guilden Morden Developments Ltd

Agent: JMS Planning & Development

JMS Planning strongly recommends that the engagement referred to on page 5 of the Spatial Strategy is recorded via a Statement of Common Ground (‘SoCG’) to evidence effective joint working on cross boundary strategic matters (as per the NPPF at paragraph 36(c). The SoCG does not require agreement between the parties, but does require evidence of constructive, active, and ongoing engagement.

Comment

Representation ID: 208670

Received: 30/01/2026

Respondent: Guilden Morden Developments Ltd

Agent: JMS Planning & Development

JMS Planning notes that production of a Sustainability Appraisal is a live and ongoing process throughout the production of an emerging Local Plan. With this in mind, JMS Planning would like to underline the importance of the Council considering ‘reasonable alternatives’ at all consultation stages in order to comply with Article 5(1) of the Directive.

JMS Planning recommends that further information be provided to substantiate the consultation draft SA regarding the assessment of reasonable alternatives, and specifically the role that the rural areas surrounding Group Village settlements and above can have in enabling sustainable development.

Comment

Representation ID: 208671

Received: 30/01/2026

Respondent: Guilden Morden Developments Ltd

Agent: JMS Planning & Development

Should a Local Plan be likely to have significant effects on European habitats or species, the LPA should undertake a Habitats Regulation Assessment as per the Conservation of Habitats and Species Regulations 2010 (as amended). The Sustainability Appraisal should also take the findings of the HRA into account (as per the PPG, paragraph 11, ID11-011-20140306).

Comment

Representation ID: 208672

Received: 30/01/2026

Respondent: Guilden Morden Developments Ltd

Agent: JMS Planning & Development

GMD and JMS Planning note that the LPA states, from the outset, the local housing need figure for Greater Cambridge, based on the application of the standard method formula as prescribed by MHCLG for South Cambridgeshire and Cambridge. JMS Planning supports the identification of a target of 2,295 dwellings per annum or circa 48,195 homes with a 5% buffer over the plan period. It should be noted that the commuting assumptions show a need for 2,422 dwellings per annum, and clarification as to why this figure has not been adopted is required (as per the Housing Needs Assessment in the evidence base). JMS Planning & Development would suggest that Policy S/JH be altered to accommodate the increased figure.

Comment

Representation ID: 208673

Received: 30/01/2026

Respondent: Guilden Morden Developments Ltd

Agent: JMS Planning & Development

Local Plan Vision:

JMS Planning generally supports the Local Plan Vision; however, we question why the Vision does not rely on the mix of development strategies outlined in the Spatial
Strategy as a whole. There is no specific reference to the type of development or its location. GMD and JMS Planning recommend that the Local Plan Vision be updated to explicitly clarify the range of development locations to be utilised to meet demand for housing and other types of development.

Comment

Representation ID: 208674

Received: 30/01/2026

Respondent: Guilden Morden Developments Ltd

Agent: JMS Planning & Development

Local Plan Spatial Strategy:

JMS Planning wholly supports the identification of the four strategies set out on page 16; however, we ask that the feasibility of the strategies, as demonstrated in the SA, be tested after the assessment of all sites in both Call for Sites consultations. There is also an inherent weakness in not including increased development at the Group Village
scale, given the sustainability of the settlements within this tier is referenced throughout the evidence base and is not dependent on the presence of a train station (as per the
SA).

JMS Planning would recommend that Policy S/DS be revised at part e, insofar as development in the wider rural area should be inclusive of all sustainable locations,
regardless of being beyond the ‘Rural Centre’ or ‘Minor Rural Centre’ Tiers.

Comment

Representation ID: 208680

Received: 30/01/2026

Respondent: Guilden Morden Developments Ltd

Agent: JMS Planning & Development

JMS Planning agrees with the settlement hierarchy as set out by the aforementioned policy. JMS Planning suggests, however, that the sustainability credentials of the Group Villages should not be undermined by the imposition of arbitrary development quantums, specifically 8 dwellings within the development extents and 15 where it would make best use of a brownfield site. JMS Planning would argue that the quantum that is acceptable is dependent on the characteristics of a specific site in question, and
would also raise that the limit to 8 dwellings also results in the Council not bringing forward much-needed affordable housing.

There should also be a reference to Policy
S/DE (Defined Development Extents) and the circumstances in which development is
justified beyond the boundary of a settlement.

Comment

Representation ID: 208682

Received: 30/01/2026

Respondent: Guilden Morden Developments Ltd

Agent: JMS Planning & Development

This policy is not sufficiently flexible to allow for unallocated development that is located beyond the settlement boundary when there is a specific need for the
development type. In terms of reference to development types (such as rural exception sites), a cross-reference should be made to the specific governing policy (e.g. H/ES). There should be further flexibility included to underline how this policy will be interpreted by the LPA in times of no housing land supply or shortfall in other development.

Comment

Representation ID: 208684

Received: 30/01/2026

Respondent: Guilden Morden Developments Ltd

Agent: JMS Planning & Development

The policy does not include any wording on how the delivery of affordable housing can be altered should there be material viability considerations; therefore, GMD and JMS Planning encourage its inclusion, or as a standalone policy as per many other Authorities. JMS Planning recommends that explanatory text be provided to explain
why the affordable housing tenures change depending on whether the quanta are 10,14 or 15+ units.