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3.3.1 The Draft Policy S/DS sets out the proposed strategy for the patterns, scale, and design quality of places in Greater Cambridge, for the plan period to 2045 and beyond.
3.3.2 The Cambridgeshire & Peterborough Independent Economic Review (CPIER), which was published in September 2018 around the time of the adoption of the current Cambridge Local Plan and South Cambridgeshire Local Plan.
3.3.3 The CPIER recommended a blended spatial strategy being the most appropriate form of development. It considered densification, dispersal, fringe growth, and growth along transport corridors.
3.3.4 While the CPIER report concluded that a dispersed approach should not be the main paradigm for development, it concluded a blended approach was the most appropriate options as none of the approaches on their own are likely to work. However, the balance of development set out in the Greater Cambridge Local Plan is unbalanced and the spatial strategy advance risks delivery of homes, particularly in the early part of the plan period.
3.3.5 The Councils are distributing 44% of growth across the Plan Period in new settlements, and 29% in major sites on the edge of Cambridge which are similar to new settlements (Figure 12 of the Local Plan). Combined, 73% of growth is allocated to major strategic sites.
3.3.6 The table below sets out the distribution of growth during the Plan Period across these new settlements and whether these have planning permission. Appendix 4 sets out the proposed housing trajectory of the new settlements which do not currently have extant consent during the emerging Local Plan timeframe.
Table 3.1: Delivery of new settlements during the emerging Plan Period
Settlement Number of Homes to be delivered in Plan Period Total number of dwellings Extant permission Percentage of homes delivered during Plan Period
Northstowe* 6,229 10,107 Yes 62%
Waterbeach New Town* 5,727 11,531 Yes 50%
Bourn Airfield 3,500 3,500 Yes 100%
North East Cambridge 3,950 8000 No 50%
Cambridge East 3,950 8,000 No 49%
Cambourne North 2,550 13,000 No 20%
Grange Farm New Settlement 2,550 6000 No 43%
*Northstowe has delivered 1,401 dwellings prior to this emerging Plan Period. Waterbeach New Town has delivered 556 dwellings prior this emerging Plan Period.
3.3.7 The delivery rates for these settlements are unrealistic, particularly regarding the new settlements which are yet to have been granted planning permission, which include:
• North East Cambridge;
• Cambridge East;
• Cambourne West; and
• Grange Farm.
3.3.8 In the latest ‘Start to Finish’ Report, undertaken by Lichfields in 2024 , it is demonstrated that sites comprising over 1,000 dwellings will take, on average, five years to obtain detailed planning permission and then a further 1.3-1.6 years to deliver the first dwelling.
3.3.9 Indeed, for sites over 2,000 dwellings, it states that the median timescale from validation of the first planning application to the completion of the first dwelling is 6.7 years.
3.3.10 The Councils’ Local Development Scheme anticipates that the emerging Local Plan will be submitted to the Secretary of State for examination in December 2026. In July 2024 (after their General Election win), the new Minister for Housing, Matthew Pennycook, wrote to the Planning Inspectorate and noted that the average length of time for the completion of examination had increased from 65 weeks on average in 2016 to 134 weeks on average in 2022 (approximately 2 ½ years) .
3.3.11 Therefore, if the Plan were submitted to the Secretary of State in December 2026, then the earliest that the Plan might be adopted is May 2029, using the data above. That would be equivalent to ‘Year 6’ (2029/2030) in the proposed housing trajectory.
3.3.12 If these new settlements were to be approved in Year 6 (2029/30), then the earliest that the first house might be delivered according to the Lichfields ‘Start to Finish’ is in Year 12 (2035/2036). It is unrealistic to conclude that the first dwellings will be delivered in North East Cambridge and Cambridge East in 2032/33, and in 2034/35 in Cambourne North and Grange Farm. All these sites have significant infrastructure requirements, while the main housing trajectory does not rely on Cambridge North East (following the Government’s recent announcement not to fund the relocation of the waste water treatment works from the existing site to Honey Hill), the delivery targets for the other three areas remain unrealistic. Cambourne North is reliant on East West Rail being delivered and a new railway station being brought forward at Cambourne, while Grange Farm is heavily reliant on the proposed CSET scheme.
3.3.13 The current housing trajectory figures are overly ambitious for large new settlements requiring significant new infrastructure requirements such as yet unbuilt or unfunded extensive dedicated busways, or major new railway such as East West Rail, particularly considering recent delivery rates both within Greater Cambridge and in other parts of the UK.
3.3.14 Therefore, to meet this shortfall, the Councils should focus on sites that can utilise existing infrastructure such as land at Station Fields, Foxton, Cambridgeshire adjoining existing settlements, especially ones that benefit from proximity to an existing railway station, and consequently therefore access to a large number of jobs, educational establishments, and other services using existing sustainable modes of transport.
3.3.15 The Councils’ housing trajectory is also reliant on the new settlements each delivering 350 dwellings per annum. This is equivalent to seven plots delivering 50 dwellings per annum, by several housebuilders.
3.3.16 The Lichfields ‘Start to Finish’ document sets out the housing completions of large sites. The table below sets out the average delivery of sites which are for over 5,000 dwellings across the years. The Annual Monitoring Report (2025) confirms this with Northstowe’s historic maximum in which only 278 in 2018/19, and only 92 homes were delivered in 2023/24. At Waterbeach, only 263 dwellings were completed in 2022/23, and the number of completions has declined since then.
Table 3.2: Table of average housing delivery on sites larger than 5,000 dwellings
Site Name No of Dwellings No of Years of Delivery Average Delivery (rounded)
Former Alconbury Weald, Huntingdon 5,000 2 208
Priors Hall, Northamptonshire 5,200 11 135
North West Preston 5,300 8 290
East Kettering SUE 5,500 6 133
Sherford, South Hams 5,500 7 119
South Ashford Garden Community 5,750 2 75
Houlton (Rugby Radio Station) 6,200 3 139
The Hamptons (Peterborough) 6,320 25 224
Ebbsfleet 15,000 14 255
3.3.17 The table above demonstrates that none of the new settlements assessed achieved, on average, 350 dwellings per annum. For Greater Cambridge to have so many of these type of sites in one area, is particularly problematic for delivery. Therefore, there should be a greater focus on delivering the required housing across sustainable settlements, which includes Foxton and the A10/London King’s Cross to Cambridge corridor which has been afforded very limited growth in the emerging Greater Cambridge Local Plan. The Site can help meet the needs of the emerging Local Plan, particularly on adoption of the Local Plan, and in the early part of the plan period.
3.3.18 We raise concerns about the principle of the development at Grange Farm, and we note that North East Cambridge may not be available due to the Government withdrawing funding for the wastewater treatment relocation.
3.3.19 Regarding Cambridge East (the existing Cambridge Airport), in October 2025, Marshall Group confirmed that they were not relocating to Cranfield Airport, in Bedfordshire, as it was considered “no longer affordable ”.
3.3.20 There is nothing in the news, which sets out when Marshall Group intends to vacate the Site. Therefore, we question whether the emerging Local Plan can be reliant on these dwellings during the Local Plan period.
3.3.21 With respect to Cambourne North, the delivery of the settlement extension is principally reliant on the proposed new station that will be delivered as part of East West Rail.
3.3.22 Although we acknowledges that in June 2025, as part of the spending review, the Government committed a further £2.5 billion for the continued delivery of East West Rail, there is far from certainty that this will be delivered. This Government is fully committed to the delivery of East West Rail but there are no guarantees that a future government would be as committed. In contrast, Station Fields benefits from an existing railway station and services to nearby towns and the city of Cambridge including the Cambridge Biomedical Campus.
3.3.23 Regarding Grange Farm, we are concerned that there is not sufficient infrastructure to deliver this Site, particularly as this will be a sustainable new town, located at the heart of the Rural Southern Cluster. Once again, the Local Plan is placing far too much emphasis on the delivery of new standalone new settlements, which experience demonstrates take a considerable time to deliver.
3.3.24 The Deliverability Paper that was submitted as part of the previous ‘call for sites’ application for Grange Farm, confirms that 3,560 dwellings (market and affordable) can be delivered during the emerging Local Plan period with the first dwellings being delivered in 2030.
3.3.25 The Councils’ housing trajectory states that only 2,550 dwellings can be delivered during the Plan Period. .
3.3.26 There is also a discrepancy between the number in the Housing Trajectory provided by the Council (up to 300 dwellings in 2040) and only 275 dwellings in the Housing Deliverability Note . Therefore, we have concerns that the Council will be able to deliver that number of dwellings across the Plan Period.
3.3.27 In order to help meet this shortfall, our client can provide a Site that is deliverable in the short term at a sustainable location, and does not rely on uncertain delivery of strategic infrastructure by third parties.
3.3.28 In total, as set out in Figure 12 of the emerging Local Plan above, new settlements will provide 44% of the total housing supply. Given the timings set out in the Lichfields ‘Start to Finish’ report, there is a severe risk of delay in delivering a significant number of Greater Cambridge’s housing sites, which will mean that the Councils will not be able to meet their housing needs across the Plan Period..
3.3.29 In order to avoid this scenario and to ensure as far as possible a plan-led system can be successfully implemented and delivered, the Site can help the Council deliver a consistent and deliverable supply of housing across the Plan Period to reduce the risk of the Council not being able to meet its housing needs, thereby attracting speculative development.
3.3.30 The Site at Stations Fields, Foxton is immediately deliverable and could contribute towards the Council’s increased housing needs to ensure that the required housing delivery numbers are maintained. Less reliance on large strategic scale sites and new settlements would help to ensure that in future Greater Cambridge is able to demonstrate a five-year supply of housing land. smaller and medium sized sites typically come forward quicker that new large settlements which require significant infrastructure to support them.
3.3.31 The Development Strategy of the draft Local Plan is underpinned by the Housing Trajectory set out in draft Appendix E. This anticipates that the local housing need (standard method) annual number of 2,309 is not achievable between 2024/25 and 2027/28, in 2031/32 or in the final four years of the plan period. For the years 2028/29 and 2029/30, anticipated completions are significantly higher, at 3,483 and 3,530 respectively. This results in a predicted number of completions for 2028-2033 of 14,427 units, which equates to a five-year supply of 5.32 years.
3.3.32 Analysis of the projected completions for individual sites suggests that the above anticipated completions numbers are based on estimates of completions on strategic sites for 2028/29 and 2029/30 are that are significantly above historic maximums and that do not consider the planning context of each site.
3.3.33 At North West Cambridge, completion of the final Phase 1 dwellings permitted under the 2013 outline consent (references: 11/1114/OUT and S/1886/11) is expected in 2028. The outline application for future phases is currently under consideration and is unlikely to be approved before late 2026, with reserved matters to follow. It is therefore implausible that 305 and 376 dwellings can be delivered in 2028/29 and 2029/30 respectively. A more reasonable assumption might be 100 per year, as the trajectory anticipates for most of the 2030s.
3.3.34 At Northstowe, the historic maximum annual delivery was in 2018/19, when 278 dwellings were completed. Only 92 dwellings were completed in 2023/2024 (on both Phase 1 and Phase 2). Phase 1 is now almost complete, and Phase 2 has 706 dwellings permitted. It is therefore implausible that 473 and 467 dwellings can be delivered in 2028/29 and 2029/30 respectively. A more reasonable assumption might be 300 per year, as the trajectory anticipates for 2030 onwards.
3.3.35 At Waterbeach New Town, 263 dwellings were completed in 2022/23, with completions declining since then. It is unlikely that 376 and 368 dwellings can be delivered in 2028/29 and 2029/30 respectively. A more reasonable assumption might be 300 per year, as the trajectory anticipate for 2030 onwards.
3.3.36 If the above reasonable adjustments are made to the housing trajectory in Appendix E, the number of predicted completions is reduced by 965 and the five-year supply for 2028-2033 falls to 4.96. Therefore, the Plan cannot be found ‘sound’ in line with paragraph 36 of the NPPF, 2024.
3.3.37 It is also noted that the housing trajectory relies on historically high delivery rates in 2028/29 and 2029/30 for four further major previously allocated strategic sites: North East Cambridge, Darwin Green, Cambridge East (Marleigh and Land north of Cherry Hinton), and Cambourne West.
3.3.38 Given historic experience of both general and site-specific causes of delays and reductions in delivery rates, notably the delivery of major infrastructure, it is not credible to assume that seven major strategic sites will all be able to deliver at historically exceptional rates.
3.3.39 In order to reduce reliance on uncertain major sites and increase the likelihood that overall completion rates will be close to or exceed standard method need over the first 5-10 years of the plan period, the draft Local Plan should make significant additional allocations for smaller developments close to existing settlements and that do not require enabling infrastructure investment.