Draft Greater Cambridge Local Plan for consultation

1. The following representations are made in response to the Draft Greater Cambridge Local Plan Regulation 18 Consultation (December 2025 – January 2026) on behalf of Miller Homes. These representations are made in respect of their land interest at Land South of Shelford Road, Fulbourn which is referenced as site 40501 / 115137 in the Greater Cambridge Strategic Housing and Economic Land Availability Assessment (HELAA) – October 2025.

2. The Vision for Greater Cambridge places emphasis on decreasing impact on the climate and environment, through reducing reliance on the private car to create thriving neighbourhoods with a variety of jobs and homes and supporting infrastructure that is needed.

3. It is considered that the Plan as it is currently presented does not fully meet the Vision. This is due to the over reliance of housing allocations that are strategic sites, totalling 12,550 dwellings (93%) whilst smaller sites total 913 (7%) of the 13,463 new allocations. The over-reliance on such large site leads to potential risk of having greater impacts on the environment due to the levels of land that are required to deliver them. In addition to this, through delivering housing on mainly larger strategic sites, there is a risk that the aim to provide a variety of housing will be missed, meaning a lack of choice of housing across the Greater Cambridge area.

4. Furthermore, as per the National Planning Policy Framework (NPPF 2024) paragraph 11a and 110, all plans should promote a sustainable pattern of development, in locations which are or can be made sustainable. It is considered that the allocation of new housing on strategic sites that are outside Cambridge Centre and beyond the green belt, is not sustainable. This is due to the potential over reliance on the private vehicle to be able to access services, facilities and employment opportunities. The Sustainability Appraisal 2025 identifies this a potential for concern of development ‘jumping’ the green belt, meaning some elements of development will be provided in locations that are less well related to existing services, facilities and jobs, which may result in increases in vehicle travel. Therefore, the Development strategy as proposed is not considered to meet the Plan’s Vision and the NPPF’s central premise of a sustainable pattern of development.

5. Sites such as that at Land South of Shelford Road, Fulbourn, which would deliver 150-160 dwellings should be allocated within the Plan in order to help provide a variety and choice of housing. This is in a sustainable location, due to being within a 12-minute walk to local facilities in Fulbourn village centre including pre-schools, primary school, pharmacy, heath centre, public houses, community centre and library. Fulbourn also benefits from an existing cycle path and frequent buses to Cambridge city centre. Miller Homes are aiming for a high level of sustainability, to reduce impacts on climate change. Creating a benchmark project for adopting to climate change and carbon neutrality by 2050, directly in line with the Council’s vision. The Site is also technically unconstrainted, deliverable and developable. Overall, supporting the delivery of the Vision for the local plan.

6. In addition to this, the land adjoining the site to the east, running along Cambridge Road, could also be identified within the plan to deliver further housing in Fulbourn with the option for the two parcels to link together to provide comprehensive development. This would further support creating a more natural edge to Fulbourn in a sustainable location.

1. The following representations are made in response to the Draft Greater Cambridge Local Plan Regulation 18 Consultation (December 2025 – January 2026) on behalf of Miller Homes. These representations are made in respect of their land interest at Land South of Shelford Road, Fulbourn which is referenced as site 40501 / 115137 in the Greater Cambridge Strategic Housing and Economic Land Availability Assessment (HELAA) – October 2025.

2. Policy S/DS sets out the proposed strategy for the pattern, scale and design quality of places. Setting out where the homes identified should be provided.

3. 48,195 new homes are to be provided within the plan period of 2024-2045. Of these 37,865 homes are from the existing adopted plan, with a minimum of a further 10,330 to be identified in the new plan to meet need.

4. 13,460 new homes have been identified to be delivered by 2045, with a further 17,950 delivered post 2045. The housing supply does not include North East Cambridge allocation (3,950 dwellings) due to funding for the Cambridge Waste Water Treatment Plant being removed.

5. With the exclusion of the North East Cambridge allocation the total supply of housing equates to 51,328 new dwellings with a head room of 6.5% in relation to housing need.

6. Of these allocations, small sites, including existing commitments, proposed new allocations and windfall allowance is anticipated to deliver 6,976 dwellings. Of these only 1,694 homes are allocated, meaning 5,282 are not allocated or identified at this point.

Windfalls

7. Paragraph 75 of the NPPF states that “where an allowance is to be made for windfall sites as part of anticipated supply, there should be compelling evidence that they will provide a reliable source of supply”. Yet the evidence in the Greater Cambridge Housing Delivery Study Addendum (2025), historic data from 2006-2024 is used to base future prediction. This has identified a delivery of 425 windfall dwellings per annum. In the review of expected future trends national policy changes in relation to developing brownfield sites has been identified to highlight how it will be easier to bring brownfield sites forward. However, the assumption that windfall sites will be delivered on mainly brownfield sites is questioned. This is due to there being potential limited opportunities for this as many sites have already been delivered. Therefore, it is considered that this assessment of the windfall allowance is not in line with paragraph 75 of the NPPF as it is considered that with the evidence provided, that there will be a reliable source of supply is not compelling.

8. If these windfall sites did not come forward within the plan period, it would mean that the housing need of 48,195 would not be met as only 46,046 homes would be delivered. Therefore, it is considered that additional smaller sites, such as Land South of Shelford Road, Fulbourn should be allocated. This site is available and deliverable to support the delivery of housing in Greater Cambridge.

Strategic Sites
9. It is considered that there is an over-reliance of delivery of housing on strategic sites. The evidence report Greater Cambridge Housing Delivery Study Addendum (2025 update), outlines the lead-in times of strategic sites (200 dwellings and above) to be 8-9 year from allocation to first completions, whilst for non-strategic site (less than 200 dwellings) 3-6 years.

10. Within the new housing allocations 12,550 are provided on strategic sites varying in size from 1,000 to 3,950 dwellings. As outlined lead-in times of these sites are 8-9 years. There are often delays on strategic sites of this size due site specific constraints that can cause issues, or external factors like the Government’s announcement that it will not be funding the Cambridge Waste Water Treatment Plant which has impacted the delivery of the North East Cambridge site.

11. Therefore, it is considered that additional smaller sites are allocated within the plan such as at Land South of Shelford Road, Fulbourn which is in a sustainable location that can be delivered in the early plan period to help combat any potential delays that may arise with the strategic sites.

12. The edge of Cambridge is also identified within this policy as a sustainable location for homes and jobs, due to access to existing jobs and services. Fulbourn is located on the edge of Cambridge, with good links to local facilities, services and employment opportunities.

13. Moreover, the proposed transport strategy within this policy is informed by the location of existing and committed public transport schemes. Improving transport links is supported. The committed Walking/Cycling links that are located across Cambridge are supported. The committed walking/cycling link to Fulbourn, further supports it as a sustainable location with links to the centre of Cambridge and train stations to support the reduction of reliance on private cars. It is therefore considered that additional allocations should be made in Fulbourn as it is located in a sustainable location on the edge of Cambridge. Sites such as Land South of Shelford Road, Fulbourn should be allocated as it is in a sustainable location that has good links to Cambridge and will support the delivery of the Vision whilst meeting local housing need.

1. The following representations are made in response to the Draft Greater Cambridge Local Plan Regulation 18 Consultation (December 2025 – January 2026) on behalf of Miller Homes. These representations are made in respect of their land interest at Land South of Shelford Road, Fulbourn which is referenced as site 40501 / 115137 in the Greater Cambridge Strategic Housing and Economic Land Availability Assessment (HELAA) – October 2025.

2. The Settlement Hierarchy groups settlements into categories that reflect their scale, characteristics and sustainability to ensure development is located in the most sustainable places.

3. Fulbourn sits in the Minor rural centres category. It is considered that this should be reviewed, so that it is included in the Rural Centre category. This is based on the number of facilities and good links to Cambridge City Centre through public transport and walking/cycling routes, at a similar scale to those located in the settlements identified as Rural Centres including Great Shelford and Stapleford, Histon and Impington, and Sawston.

4. Furthermore, Fulbourn has good access to a secondary school with links to The Netherall School; employment opportunities with Fulbourn hospital and Peterhouse Technology Park to the west as well as links into Cambridge City; and a variety of services and facilities in the village centre including a health centre, primary schools, pre-schools, food store library and recreational ground. These aspects fall under the definition of a Rural Centre, supporting Fulbourn to be considered within this category.

1. The following representations are made in response to the Draft Greater Cambridge Local Plan Regulation 18 Consultation (December 2025 – January 2026) on behalf of Miller Homes. These representations are made in respect of their land interest at Land South of Shelford Road, Fulbourn which is referenced as site 40501 / 115137 in the Greater Cambridge Strategic Housing and Economic Land Availability Assessment (HELAA) – October 2025.

2. It is considered that Fulbourn’s development extent should be reassessed to include the allocation of Land South of Shelford Road, Fulbourn. This is due to the site being able to provide housing sustainably offering a choice of housing from the strategic sites. Fulbourn also has a variety of local facilities and services, employment opportunities and good transport links to Cambridge City Centre, making it appropriate for additional growth. The site will help complete the village edge, helping to have a clear, logical defined development extent.

1. The following representations are made in response to the Draft Greater Cambridge Local Plan Regulation 18 Consultation (December 2025 – January 2026) on behalf of Miller Homes. These representations are made in respect of their land interest at Land South of Shelford Road, Fulbourn which is referenced as site 40501 / 115137 in the Greater Cambridge Strategic Housing and Economic Land Availability Assessment (HELAA) – October 2025.

2. Policy S/GB and supporting evidence in the Green Belt Assessment (2021), concludes that there is no requirement to release the green belt as it is considered that ‘exceptional circumstances’ are not in place.

3. Paragraph 148 of the NPPF states that when reviewing green belt boundaries, the need to promote sustainable patterns of development should determine whether a site’s location is appropriate. When reviewing the new site allocations, it is considered that these do not present sustainable patterns of development, due to the proposal to deliver new strategic sites beyond the green belt. This means that these sites will not be located near Cambridge Centre. This could lead to the potential over reliance on the private car to access services, facilities and employment, therefore not being in compliance with paragraph 110 and 115 of the NPPF. The Plan’s Green Belt Study predates the NPPF 2024, and therefore does not make an assessment of potential grey belt land. This should be rectified before the next stage of the Plan.

4. The Sustainability Appraisal 2025 identifies the potential impacts of development ‘jumping’ the green belt, as some elements of development will be provided in locations that are less well related to existing services, facilities and jobs, which may result in increases in vehicle travel.

5. Furthermore, it is argued that Land South of Shelford Road, Fulbourn is Grey belt, as defined in the NPPF in line with paragraph 143. The release of this land would not lead to neighbouring towns merging nor impact the setting and special character of historic towns. Therefore, it should be allocated to support the delivery of smaller sites in Greater Cambridge and released from the green belt.

1. The following representations are made in response to the Draft Greater Cambridge Local Plan Regulation 18 Consultation (December 2025 – January 2026) on behalf of Miller Homes. These representations are made in respect of their land interest at Land South of Shelford Road, Fulbourn which is referenced as site 40501 / 115137 in the Greater Cambridge Strategic Housing and Economic Land Availability Assessment (HELAA) – October 2025.

2. Representations for Landscape and Visual Issues prepared by Pegasus Group accompanies this representation in Appendix 1. This responds to comments raised in the HELAA (2025) regarding landscape concerns about the development of the site impacting the landscape character of the area and on key views to and from the village of Fulbourn. The above is disputed and is reviewed in detail in the appended representations and ‘Screened Zone of Theoretical Visibility Plan’ within this appended report.

3. Development around the edge of Cambridge should come with improved green and natural spaces which are accessible for everyone, as part of an expanded network of green infrastructure across the area.

4. Fulbourn, is it located on the edge of Cambridge and should have new site allocations. This is due to its sustainable location with local services and facilities such as good access to a secondary school; employment opportunities at Fulbourn hospital and Peterhouse Technology Park; sustainable transport links into Cambridge City centre; and a variety of services and facilities in the village centre including a health centre, primary schools, pre-schools, food store, library and recreational ground.

5. Land South of Shelford Road, Fulbourn will provide improved green and natural spaces that will be accessible to all supporting the aim of site allocations on the edge of Cambridge.

6. It is noted that the Greater Cambridge Strategic Housing and Economic Land Availability Assessment (HELAA – October 2025) assessed the Land South of Shelford Road, Fulbourn (Reference: 40501 / 115137). The HELAA raised concerns about the development of the site impacting the landscape character of the area and on key views to and from the village of Fulbourn, this is view is disputed. A review of the Landscape Sensitivity Assessment has been undertaken and is included in appended ‘Representations (Landscape and Visual Issues)’ (Appendix 1). This assessment includes a set of views of Land South of Shelford Road, Fulbourn from the local highways and PRoWs, as well as a Screened Zone of Theoretical Visibility plan. These assessments conclude that the overwhelming majority of the nearby visual receptors and those in the wider countryside would not be affected or effects would be limited were the site at Land South of Shelford Road, Fulbourn to be allocated, supporting it as an appropriate site for development.

7. The site is also assessed within the Greater Cambridge Landscape Sensitivity Assessment (November 2021) as part of a larger Assessment Unit FUL05 of medium sensitivity to residential and mix-use developments. This assessment identifies that with medium landscape sensitivity any landscape character effects of the development of Land South of Shelford Road, Fulbourn Site would be moderated and therefore appropriate for allocation as an Edge of Cambridge site.

8. Therefore, it is considered that Land South of Shelford Road, Fulbourn is an appropriate Edge of Cambridge allocation that would provide a variety and choice of housing in a sustainable location.

1. The following representations are made in response to the Draft Greater Cambridge Local Plan Regulation 18 Consultation (December 2025 – January 2026) on behalf of Miller Homes. These representations are made in respect of their land interest at Land South of Shelford Road, Fulbourn which is referenced as site 40501 / 115137 in the Greater Cambridge Strategic Housing and Economic Land Availability Assessment (HELAA) – October 2025.

2. The Vision for Greater Cambridge places emphasis on decreasing impact on the climate and environment, through reducing reliance on the private car to create thriving neighbourhoods with a variety of jobs and homes and supporting infrastructure that is needed.

3. It is considered that the Plan as it is currently presented does not fully meet the Vision. This is due to the over reliance of housing allocations that are strategic sites, totalling 12,550 dwellings (93%) whilst smaller sites total 913 (7%) of the 13,463 new allocations. The over-reliance on such large site leads to potential risk of having greater impacts on the environment due to the levels of land that are required to deliver them. In addition to this, through delivering housing on mainly larger strategic sites, there is a risk that the aim to provide a variety of housing will be missed, meaning a lack of choice of housing across the Greater Cambridge area.

4. Furthermore, as per the National Planning Policy Framework (NPPF 2024) paragraph 11a and 110, all plans should promote a sustainable pattern of development, in locations which are or can be made sustainable. It is considered that the allocation of new housing on strategic sites that are outside Cambridge Centre and beyond the green belt, is not sustainable. This is due to the potential over reliance on the private vehicle to be able to access services, facilities and employment opportunities. The Sustainability Appraisal 2025 identifies this a potential for concern of development ‘jumping’ the green belt, meaning some elements of development will be provided in locations that are less well related to existing services, facilities and jobs, which may result in increases in vehicle travel. Therefore, the Development strategy as proposed is not considered to meet the Plan’s Vision and the NPPF’s central premise of a sustainable pattern of development.

5. Sites such as that at Land South of Shelford Road, Fulbourn, which would deliver 150-160 dwellings should be allocated within the Plan in order to help provide a variety and choice of housing. This is in a sustainable location, due to being within a 12-minute walk to local facilities in Fulbourn village centre including pre-schools, primary school, pharmacy, heath centre, public houses, community centre and library. Fulbourn also benefits from an existing cycle path and frequent buses to Cambridge city centre. Miller Homes are aiming for a high level of sustainability, to reduce impacts on climate change. Creating a benchmark project for adopting to climate change and carbon neutrality by 2050, directly in line with the Council’s vision. The Site is also technically unconstrainted, deliverable and developable. Overall, supporting the delivery of the Vision for the local plan.

6. In addition to this, the land adjoining the site to the east, running along Cambridge Road, could also be identified within the plan to deliver further housing in Fulbourn with the option for the two parcels to link together to provide comprehensive development. This would further support creating a more natural edge to Fulbourn in a sustainable location.