Draft Greater Cambridge Local Plan for consultation

Acknowledge more smaller sites are required to support and accelerate growth

Response to Development Strategy
Relevant Policies
• Policy S/DS – Development Strategy
• Policy S/JH – New jobs and homes
GSTA generally supports the vision and objectives of the draft plan. However, given the reliance on large-scale development allocations and new communities at strategic locations such as Cambourne which pace of growth will be reliant on key infrastructure delivery, and new locations such as Grange Farm, to the south of Cambridge, the spatial strategy should ensure that development targets can be met and sustained through the plan period to 2045. The spatial strategy relies heavily on growth options that are potentially prone to issues around viability, complex land ownerships and enabling infrastructure – all matters that affect the pace of delivery. The addition of smaller sites to support and strengthen the overall development strategy is critical to support a plan-led system throughout the entire period to meet the housing needs in full.
The draft plan housing trajectory set out in the Housing Delivery Study: Further Addendum 2025 states that the strategy and housing trajectory set out in the draft plan to meet the Standard Method for calculating housing need as at 2025 (including providing a five-year housing land supply at plan adoption and throughout the plan period) only assumes a 5% buffer. GSTA understand this is assumed to be consistent throughout the plan period to 2045 as the evidence does not support a stepped annual housing requirement. The reliance on extensive infrastructure improvements and the Councils past lead-in times for new communities suggests that a 5% buffer is not reliable. The potential for slippage is extremely high. A strong buffer is important to ensure that there is flexibility should sites deliver homes slower than expected. GSTA consider a minimum 10% should be included and based on the spatial strategy and emphasis on larger sites in the Regulation 18 draft, 20% would be more appropriate.
The matter of housing need and affordability has worsened in the time spent preparing a replacement Local Plan. The recent years ‘cost of living crisis’ and increased interest rates have hit young adults in particular looking to buy their own homes. This has also affected the opportunity to provide older persons housing or adaptive homes and purpose-built housing to meet specific needs of local businesses and in particular the bio-medical industry. For homes, the objectively assessed need of 2,295 homes per year (considering Greater Cambridge as one area), or 48,195 homes over a 21-year period, represents a 36% increase on the average level of annual completions over the period 2011/12 to 2023/24 of 1,683 homes as calculated in the Housing Delivery Study for Greater Cambridge: Further Addendum (AECOM, 2025). The Councils advisors, AECOM, note that there has been a reduction in housing market activity nationally since 2020/21 due to challenging market conditions, and that the overall fall in annual completions is almost entirely due to a drop in new-build completions. Additionally, the number of housing starts on site continues to lag behind the volume of permissions granted. Despite this, AECOM consider that this recent fall in annual housing completions is a short-term impact within Greater Cambridge and will not be a permanent reduction over the plan period as planning reforms and interventions from the Government are aimed at restoring confidence and certainty to the development industry. GSTA recognises the changes to the planning system and the proposed changes at the national policy level are designed to support and accelerate growth but these changes will still take time to come through and there is still no guarantee they will happen at all and a cautionary approach is essential in these circumstances. The slow-down must be considered and the housing trajectory be kept under review whilst the Regulation 19 plan is being prepared and examined.

Increase the 5% buffer to a minimum 10% and potentially 20%.

The draft plan housing trajectory set out in the Housing Delivery Study: Further Addendum 2025 states that the strategy and housing trajectory set out in the draft plan to meet the Standard Method for calculating housing need as at 2025 (including providing a five-year housing land supply at plan adoption and throughout the plan period) only assumes a 5% buffer. GSTA understand this is assumed to be consistent throughout the plan period to 2045 as the evidence does not support a stepped annual housing requirement. The reliance on extensive infrastructure improvements and the Councils past lead-in times for new communities suggests that a 5% buffer is not reliable. The potential for slippage is extremely high. A strong buffer is important to ensure that there is flexibility should sites deliver homes slower than expected. GSTA consider a minimum 10% should be included and based on the spatial strategy and emphasis on larger sites in the Regulation 18 draft, 20% would be more appropriate.
The matter of housing need and affordability has worsened in the time spent preparing a replacement Local Plan. The recent years ‘cost of living crisis’ and increased interest rates have hit young adults in particular looking to buy their own homes. This has also affected the opportunity to provide older persons housing or adaptive homes and purpose-built housing to meet specific needs of local businesses and in particular the bio-medical industry. For homes, the objectively assessed need of 2,295 homes per year (considering Greater Cambridge as one area), or 48,195 homes over a 21-year period, represents a 36% increase on the average level of annual completions over the period 2011/12 to 2023/24 of 1,683 homes as calculated in the Housing Delivery Study for Greater Cambridge: Further Addendum (AECOM, 2025). The Councils advisors, AECOM, note that there has been a reduction in housing market activity nationally since 2020/21 due to challenging market conditions, and that the overall fall in annual completions is almost entirely due to a drop in new-build completions. Additionally, the number of housing starts on site continues to lag behind the volume of permissions granted. Despite this, AECOM consider that this recent fall in annual housing completions is a short-term impact within Greater Cambridge and will not be a permanent reduction over the plan period as planning reforms and interventions from the Government are aimed at restoring confidence and certainty to the development industry. GSTA recognises the changes to the planning system and the proposed changes at the national policy level are designed to support and accelerate growth but these changes will still take time to come through and there is still no guarantee they will happen at all and a cautionary approach is essential in these circumstances. The slow-down must be considered and the housing trajectory be kept under review whilst the Regulation 19 plan is being prepared and examined.

Publish the Green Belt review asap

Revisit Exceptional Circumstances for smaller sites including at Gt Shelford, specifically HELAA Site Assessment reference 115766 for Land at Cambridge Road, Gt Shelford

Relevant policies:
• Policy S/DS – The Development Strategy
• Policy S/GB - The Cambridge Green Belt
One objective of the draft spatial strategy is to protect the historic core of Cambridge city, and the city centre to be supported by active, compact neighbourhoods. Gt Shelford village is close to the urban area of the city and is one of the best-connected locations at the urban edge. It benefits from being highly accessible to the city centre via local bus links and active travel modes, including dedicated cycleways. It is close to the employment opportunities at the biomedical campus and key shopping and leisure hubs whilst also being well, placed to offer choice for new residents who may want to benefit from a village environment for schools and local facilities. GSTA had supported the Rural Southern Cluster approach to include consideration of sites at Gt Shelford, however the draft plan has drawn back from that approach and opted to favour the expansion of villages beyond the outer Green Belt in less sustainable locations - citing a change in the approach to ‘exceptional circumstances’ at/around Gt Shelford & Stapleford. GSTA disagrees with this approach. In addressing the scale of the buffer and delivering the necessary additional homes/sites on non-strategic sites (under 200 homes) in the most sustainable locations, this would meet the exceptional circumstances test previously advanced.
In terms of character, the GTSA site (HELAA reference 115766) can provide additional homes quickly and in the early years of the plan. It would help accelerate the delivery of homes in a sustainable and accessible location and is on a scale that would also support small-medium sized builders.
In terms of the approach to assessing sites within the Rural Southern Cluster on an individual basis, this methodology is generally supported. However, the failure to update the HELAA assessments for site 115766 at Cambridge Road, Gt Shelford has artificially constrained the process and as a result, the site opportunity has not been correctly tested. The site should have been ‘sifted in’ from the 2021/2023 assessment processes as a matter of principle. The Development Strategy Topic Paper (Appendix 7) shows that sites that were not considered suitable, achievable have not been subject to re-appraisal as they were not considered reasonable options.
Accordingly, there has been no additional consideration of alternative approaches (Paragraph 6.42 Site Allocations Topic Paper Dec 2025). The preferred growth strategy needs to ensure ample buffer is provided so that the Councils can deliver against the Local Housing Need to 2045. Greater certainty is required at the Regulation 19 stage to provide the necessary confidence that the housing requirement will be met in full by 2045.
This raises concerns about compliance with NPPF paragraph 23 and suggests that additional sites are required which are capable of delivery within the first five years of the Plan period to ensure that sufficient homes are delivered.
There are also substantial ‘secondary benefits’ that could be realised from a higher buffer, including supporting local jobs and economic prosperity for the most sustainably located villages, and better meeting specialist and older person’s housing needs (all of which is in line with the draft Local Plan Vision). The Interim Sustainability Appraisal recognises these and other benefits of a robust growth strategy as well, such as for health and wellbeing and the vitality of communities.
In considering a more appropriate buffer, GSTA urge the Councils to revisit the ‘Exceptional Circumstances’ case to ensure that any additional sites in the most sustainable locations are not overlooked.
Notwithstanding the Councils conclusions to date, GSTA welcome the commitment to an updated Green Belt Study which takes into consideration the revised Planning Practice Guidance on Green Belt and grey belt. However, the supporting information states that “an update to the 2021 Green Belt Study will be undertaken to respond to recently introduced NPPF Grey Belt policy and subsequent relevant PPG updates” but this will be published after the draft plan consultation. This further work should be made available asap and not wat until the Regulation 19 consultation.
The Development Strategy Topic paper Appendix 1 states at 4.1 that “As there are no strategic exceptional circumstances for Green Belt release, the Councils have not identified grey belt land although there is an intention to do so in due course”. Again, this is welcomed.

Publish the grey belt land assessment asap
Publish the GB review asap
Revisit the smaller sites at Gt Shelford to strengthen the buffer (uplift from 5% to a minimum 10%) to ensure the housing requirements are capable of being met in full

Relevant policies:
• Policy S/DS – The Development Strategy
• Policy S/GB - The Cambridge Green Belt
One objective of the draft spatial strategy is to protect the historic core of Cambridge city, and the city centre to be supported by active, compact neighbourhoods. Gt Shelford village is close to the urban area of the city and is one of the best-connected locations at the urban edge. It benefits from being highly accessible to the city centre via local bus links and active travel modes, including dedicated cycleways. It is close to the employment opportunities at the biomedical campus and key shopping and leisure hubs whilst also being well, placed to offer choice for new residents who may want to benefit from a village environment for schools and local facilities. GSTA had supported the Rural Southern Cluster approach to include consideration of sites at Gt Shelford, however the draft plan has drawn back from that approach and opted to favour the expansion of villages beyond the outer Green Belt in less sustainable locations - citing a change in the approach to ‘exceptional circumstances’ at/around Gt Shelford & Stapleford. GSTA disagrees with this approach. In addressing the scale of the buffer and delivering the necessary additional homes/sites on non-strategic sites (under 200 homes) in the most sustainable locations, this would meet the exceptional circumstances test previously advanced.
In terms of character, the GTSA site (HELAA reference 115766) can provide additional homes quickly and in the early years of the plan. It would help accelerate the delivery of homes in a sustainable and accessible location and is on a scale that would also support small-medium sized builders.
In terms of the approach to assessing sites within the Rural Southern Cluster on an individual basis, this methodology is generally supported. However, the failure to update the HELAA assessments for site 115766 at Cambridge Road, Gt Shelford has artificially constrained the process and as a result, the site opportunity has not been correctly tested. The site should have been ‘sifted in’ from the 2021/2023 assessment processes as a matter of principle. The Development Strategy Topic Paper (Appendix 7) shows that sites that were not considered suitable, achievable have not been subject to re-appraisal as they were not considered reasonable options.
Accordingly, there has been no additional consideration of alternative approaches (Paragraph 6.42 Site Allocations Topic Paper Dec 2025). The preferred growth strategy needs to ensure ample buffer is provided so that the Councils can deliver against the Local Housing Need to 2045. Greater certainty is required at the Regulation 19 stage to provide the necessary confidence that the housing requirement will be met in full by 2045.
This raises concerns about compliance with NPPF paragraph 23 and suggests that additional sites are required which are capable of delivery within the first five years of the Plan period to ensure that sufficient homes are delivered.
There are also substantial ‘secondary benefits’ that could be realised from a higher buffer, including supporting local jobs and economic prosperity for the most sustainably located villages, and better meeting specialist and older person’s housing needs (all of which is in line with the draft Local Plan Vision). The Interim Sustainability Appraisal recognises these and other benefits of a robust growth strategy as well, such as for health and wellbeing and the vitality of communities.
In considering a more appropriate buffer, GSTA urge the Councils to revisit the ‘Exceptional Circumstances’ case to ensure that any additional sites in the most sustainable locations are not overlooked.
Notwithstanding the Councils conclusions to date, GSTA welcome the commitment to an updated Green Belt Study which takes into consideration the revised Planning Practice Guidance on Green Belt and grey belt. However, the supporting information states that “an update to the 2021 Green Belt Study will be undertaken to respond to recently introduced NPPF Grey Belt policy and subsequent relevant PPG updates” but this will be published after the draft plan consultation. This further work should be made available asap and not wat until the Regulation 19 consultation.
The Development Strategy Topic paper Appendix 1 states at 4.1 that “As there are no strategic exceptional circumstances for Green Belt release, the Councils have not identified grey belt land although there is an intention to do so in due course”. Again, this is welcomed.

Update the HELAA for Site 115766 to support any requirement for additional sites to be identified

Response to HELAA:
Regarding the latest HELAA Site Assessment reference 115766 for Land at Cambridge Road, Gt Shelford (previous HELAA Site ID -2023- 40413), we comment as follows:
Site Access - RAG Rating RED - 2023 - Based on the new information provided, the site access assessment remains unchanged. The proposed site is unacceptable. The access link to the public highway is unsuitable to serve the number of units that are being proposed.
GSTA fundamentally disagrees. The Site Access has not been revisited despite further information being made available during the First Proposals consultation in 2021. A full transport assessment has been carried out for the site and is summarised in the additional information under the ‘Sites Form’. Access is not a constraint to development, and the RAG rating should have been re-assessed in 2025 and upgraded to Green. This change in status enables the site to be considered for allocation to support/accelerate housing delivery.
Fire Services – RAG Rating Red 2021 – GSTA has received feedback from CCC Highways as submitted in the Call for Sites, demonstrating that the access is suitable for emergency services including fire and rescue. In any event, the HELAA acknowledges that up to 100 homes is supportable from one point of access and having assessed the site for 96 homes, the RAG rating should be GREEN.

Accessibility – RAG Rating AMBER – 2025 - Adequate accessibility to key local services, transport, and employment opportunities. Whilst GSTA welcome the updated assessment to acknowledge the site is in an accessible location, the general location for sites at Gt Shelford were considered ‘highly sustainable’ at the First Proposals stage. GSTA notes that the Greater Cambridge Partnership has changed its approach to releasing land in the outer green belt boundary as a strategy for the Regulation 18 stage, in favour of development in the southern corridor beyond the outer green belt boundary (at Grange Farm), but this decision should not affect the principle of whether this site is located in a ‘highly sustainable’ location. It should be treated the same as other sites, such as land at Hinton way/Mingle Lane for assessment purposes which all scored good on ‘accessibility’. Accordingly, the rating should be recorded as GREEN for consistency and fairness.
Landscape – RAG Rating Amber – 2021. GSTA notes that the landscape assessment has not been revisited since the 2021 assessment. The previous rating of amber reflected a higher density option. The summary guides that a reduction in residential units would lessen the harm. Accordingly, as the HELAA has assessed the site for 96 homes – a reduced amount – the Landscape assessment should have been updated from Amber to GREEN. Further landscape assessment work has been carried out by GSTA and is summarised in the ‘Sites Form’. The RAG rating should be adjusted to reflect the latest position.
Archaeology – RAG Rating AMBER – 2021 – The 2021 HELAA assessment scored amber due to the site location to the south of the nationally important Roman settlement at White Hill Farm, designated as a Scheduled Monument. GSTA has commissioned an archaeological assessment and based on its findings, there would be no harm to nearby heritage assets. The additional information is included in the ‘Sites Form’. The RAG rating should be re-assessed as GREEN.
Flood Risk – RAG Rating AMBER – 2025. The Amber rating from 2021 arose from an incorrect assessment that the site was within FZ2 and/or in an area at risk from surface water flooding. The Flood Risk Officer has updated the assessment and correctly reported the site is wholly in FZ1 and low risk of surface water flooding. GSTA do not understand why the RAG rating has not improved to GREEN as a result. This should be corrected.
The overall ‘Suitability Score’ is Red. This is incorrect and must be updated. The site access is not a constraint to development and has been misrepresented. The other Amber ratings have been assessed and the evidence submitted to the ‘Sites Form’ demonstrates that a GREEN score is more appropriate in 2025. Please see our response and additional information submitted via the dedicated Sites Form.
It is also highly relevant that this site is standalone. It does not form any part of Site ID 115146 which is being promoted separately for 4,000-4500 homes and should not be linked in any assessments for the emerging plan.

Update the HELAA evidence base where there are out of date assumptions. Include in the revised SA (i.e. to include a buffer as per the other GSTA responses to Development Strategy and Green Belt

Response to HELAA:
Regarding the latest HELAA Site Assessment reference 115766 for Land at Cambridge Road, Gt Shelford (previous HELAA Site ID -2023- 40413), we comment as follows:
Site Access - RAG Rating RED - 2023 - Based on the new information provided, the site access assessment remains unchanged. The proposed site is unacceptable. The access link to the public highway is unsuitable to serve the number of units that are being proposed.
GSTA fundamentally disagrees. The Site Access has not been revisited despite further information being made available during the First Proposals consultation in 2021. A full transport assessment has been carried out for the site and is summarised in the additional information under the ‘Sites Form’. Access is not a constraint to development, and the RAG rating should have been re-assessed in 2025 and upgraded to Green. This change in status enables the site to be considered for allocation to support/accelerate housing delivery.
Fire Services – RAG Rating Red 2021 – GSTA has received feedback from CCC Highways as submitted in the Call for Sites, demonstrating that the access is suitable for emergency services including fire and rescue. In any event, the HELAA acknowledges that up to 100 homes is supportable from one point of access and having assessed the site for 96 homes, the RAG rating should be GREEN.

Accessibility – RAG Rating AMBER – 2025 - Adequate accessibility to key local services, transport, and employment opportunities. Whilst GSTA welcome the updated assessment to acknowledge the site is in an accessible location, the general location for sites at Gt Shelford were considered ‘highly sustainable’ at the First Proposals stage. GSTA notes that the Greater Cambridge Partnership has changed its approach to releasing land in the outer green belt boundary as a strategy for the Regulation 18 stage, in favour of development in the southern corridor beyond the outer green belt boundary (at Grange Farm), but this decision should not affect the principle of whether this site is located in a ‘highly sustainable’ location. It should be treated the same as other sites, such as land at Hinton way/Mingle Lane for assessment purposes which all scored good on ‘accessibility’. Accordingly, the rating should be recorded as GREEN for consistency and fairness.
Landscape – RAG Rating Amber – 2021. GSTA notes that the landscape assessment has not been revisited since the 2021 assessment. The previous rating of amber reflected a higher density option. The summary guides that a reduction in residential units would lessen the harm. Accordingly, as the HELAA has assessed the site for 96 homes – a reduced amount – the Landscape assessment should have been updated from Amber to GREEN. Further landscape assessment work has been carried out by GSTA and is summarised in the ‘Sites Form’. The RAG rating should be adjusted to reflect the latest position.
Archaeology – RAG Rating AMBER – 2021 – The 2021 HELAA assessment scored amber due to the site location to the south of the nationally important Roman settlement at White Hill Farm, designated as a Scheduled Monument. GSTA has commissioned an archaeological assessment and based on its findings, there would be no harm to nearby heritage assets. The additional information is included in the ‘Sites Form’. The RAG rating should be re-assessed as GREEN.
Flood Risk – RAG Rating AMBER – 2025. The Amber rating from 2021 arose from an incorrect assessment that the site was within FZ2 and/or in an area at risk from surface water flooding. The Flood Risk Officer has updated the assessment and correctly reported the site is wholly in FZ1 and low risk of surface water flooding. GSTA do not understand why the RAG rating has not improved to GREEN as a result. This should be corrected.
The overall ‘Suitability Score’ is Red. This is incorrect and must be updated. The site access is not a constraint to development and has been misrepresented. The other Amber ratings have been assessed and the evidence submitted to the ‘Sites Form’ demonstrates that a GREEN score is more appropriate in 2025. Please see our response and additional information submitted via the dedicated Sites Form.
It is also highly relevant that this site is standalone. It does not form any part of Site ID 115146 which is being promoted separately for 4,000-4500 homes and should not be linked in any assessments for the emerging plan.