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Draft Greater Cambridge Local Plan for consultation
Policy S/DS: Development strategy
Representation ID: 204102
Received: 30/01/2026
Respondent: G W Balaam & Son
Agent: CODE Development Planners Ltd
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
The Development Strategy identified within Policy S/DS is not positively prepared, justified, effective and is not in accordance with the suite of national planning policies contained within the NPPF. The allocation of development appears to be disproportionately weighted towards larger strategic sites within the urban area and neglects the provision of medium and smaller allocations which are important to maintain a supply and delivery of needed housing in the short and medium term due to the uncertainty of if and/or when these strategic sites will come forward and the lack of alternative options to deliver expressed housing need, there is a need for ‘small’ and ‘medium’ sized sites to come forward to ensure the plan is effective and deliverable across the plan period. The site at land north of Bartlow Road is considered to be suitable, available and deliverable in the short term to contribute the housing supply of Cambridge and include a provision of much-needed affordable housing for the area. Based on the current Development Strategy, much of the provision of affordable housing will be backloaded to the later years of the plan period restricting the ability of GCSP to address the affordable housing need of the district in the short term.
CODE contends that in order for the Regulation 18 Greater Cambridge Local Plan (GCLP) to meet the tests of soundness, GCSP should revisit their Development Strategy to identify site allocations across the Rural and Minor Rural Centres to ensure an effective distribution of growth on small and medium sites can be delivered in the early years of the plan period. Sites such as land north of Bartlow Road, Linton should be allocated for development to reflect their suitable, available and deliverable nature as reflected in the HELAA 2025.
3.1 The Development Strategy identified within Policy S/DS is not positively prepared, justified, effective
and is not in accordance with the suite of national planning policies contained within the NPPF. The
allocation of development appears to be disproportionately weighted towards larger strategic sites within
the urban area and neglects the provision of medium and smaller allocations which are important to
maintain a supply and delivery of needed housing in the short and medium term.
3.2 The NPPF is clear in paragraph 72 that policy-making authorities should “identify a sufficient supply and
mix of sites” to provide deliverable sites across the plan period. Paragraph 73 of the NPPF highlights
the “important contribution” small and medium sized sites can make in meeting the housing requirement
of an area due to their ability to be delivered quickly. The NPPF encourages plan-making authorities to
identify at least 10% of their housing requirement on sites no greater than one hectare to support this
important contribution and Small and Medium Enterprise (SME) housebuilders.
3.3 However, the Development Strategy contained within Policy S/DS focuses on the creation and extension
of new settlements and strategic sites, with smaller scale development limited to only Melbourn, Duxford
and Caldecote. This is not in accordance with the provisions of paragraph 73 of the NPPF and this
approach is not justified within the Sustainability Appraisal (SA). The Development Strategy Topic Paper(December 2025) notes that this 10% small sites requirement can only be met over the plan period
through the assumed windfall allowance within the settlement boundaries of Rural Centres and Minor
Rural Centres. However, based on the defined extents of settlements within the plan area, CODE
queries the likelihood of the extent of development to be accommodated within existing settlement
boundaries. This does not demonstrate a positively prepared approach to secure the delivery of
development for SME housebuilders through the identification of site allocations
3.4 CODE query the strategy to deliver these homes set out in Policy S/DS. The strategy places significant
reliance on large strategic sites coming forward later in the plan period at Cambridge East, Eddington,
Cambourne North and Grange Farm for a combined total of 11,550 dwellings.
3.5 Previous experience with settlement extensions and new settlements indicates that due to their large
and strategic nature, they are often constrained, heavily opposed and reliant on the delivery of key
infrastructure which causes further delays to anticipated trajectories. CODE is concerned that GCSP’s
ability to demonstrate a five-year housing land supply within the short-medium term could be significantly
impacted by the over reliance on strategic sites without sufficient flexibility to uplift housing delivery in
the early years of the plan period. This is exemplified within the supporting text at 2.41 in the case of
the North East Cambridge allocation, where delivery is under threat due to changes in funding to the
relocation of the Cambridge Waste Water Treatment Plant. While this loss of dwellings is accounted for
within the Development Strategy, it highlights the inherent risk of the delivery of other larger site
allocations particularly in relation to infrastructure capacity in the context of increasing water scarcity
issues around the Cambridge Urban Area.
3.6 As such, due to the uncertainty of if and/or when these strategic sites will come forward and the lack of
alternative options to deliver expressed housing need, there is a need for ‘small’ and ‘medium’ sized
sites to come forward to ensure the plan is effective and deliverable across the plan period. The site at
land north of Bartlow Road is considered to be suitable, available and deliverable in the short term to
contribute the housing supply of Cambridge and include a provision of much-needed affordable housing
for the area. Based on the current Development Strategy, much of the provision of affordable housing
will be backloaded to the later years of the plan period restricting the ability of GCSP to address the
affordable housing need of the district in the short term. According to the Local Authority Housing
Statistics data returns (2024-2025), there are 1,956 households on the housing waiting list for South
Cambridge District which emphasises the need to deliver affordable housing in the immediacy.
3.7 Therefore, CODE contends that in order for the Regulation 18 Greater Cambridge Local Plan (GCLP)
to meet the tests of soundness, GCSP should revisit their Development Strategy to identify site
allocations across the Rural and Minor Rural Centres to ensure an effective distribution of growth on
small and medium sites can be delivered in the early years of the plan period. Sites such as land north
of Bartlow Road, Linton should be allocated for development to reflect their suitable, available and
deliverable nature as reflected in the HELAA 2025.
Object
Draft Greater Cambridge Local Plan for consultation
Policy S/SH: Settlement hierarchy
Representation ID: 204103
Received: 30/01/2026
Respondent: G W Balaam & Son
Agent: CODE Development Planners Ltd
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
CODE query the identification of Linton as a Minor Rural Centre within the settlement hierarchy and
consider the hierarchy to be wholly inconsistent with the distribution of growth set out within the
Development Strategy.
GCSP should revisit the allocations outlined within the Development Strategy
and instead allocate a proportionate amount of development to appropriate and sustainable sites in
accordance with the provisions and recommended quantum in the Settlement Hierarchy. This can be
achieved through allocating proportionate development on sites such as land north of Bartlow Road, Linton to ensure the ongoing vitality of the settlement and be in accordance with national planning policy to strengthen local communities.
4.1CODE query the identification of Linton as a Minor Rural Centre within the settlement hierarchy and
consider the hierarchy to be wholly inconsistent with the distribution of growth set out within the
Development Strategy.
4.2 As set out above, Linton is identified as a ‘Minor Rural Centre’ in Policy S/SH. Paragraph 2.126 notes
that Minor Rural Centres have a “lower level of services, facilities and employment than rural centres,
but a greater level than most other settlements in Greater Cambridge and often perform a role in terms
of providing services and facilities for a small rural hinterland.” Paragraph 2.127 supports development
of up to 30 dwellings as larger scale windfall development within the existing settlement boundary.
4.3 Land north of Bartlow Road, Linton is located outside, but directly adjacent to the settlement boundary
of Linton fronting development to the west of the site and therefore does not benefit from this policy
provision set out within the GCLP. Further the approval and construction of development (reference
S/1963/15/OL), the site is felt to well defined and located to ‘round off’ development in Linton. The village
benefits from a range of services and facilities including:
• Primary School
• GP surgery and pharmacy
• Frequent bus service between Cambridge and Haverhill
• Library
• Post office
• Dentist
• Bank
• Community facilities
• A range of over 20 shops and services
4.4 The site is well related to these services by sustainable transport methods and the site is of an
appropriate and proportionate scale to accommodate up to 30 dwellings in accordance with the policy
wording.
4.5 This is reflected within the supporting evidence base of the GCLP and the Settlement Hierarchy Study
Update (2025) which recognises Linton as the highest scoring Minor Rural Centre against the
sustainability criteria with a total of 16 points and identified as a “service centre” within paragraph 3.19
of the Settlement Hierarchy Study Update 2025. Despite this positive assessment, the study considers
Linton to not be comparable with settlements in the Rural Centre grouping due to a lower number of
services and facilities. This assertion does not appear to be supported by the assessment of Rural
Centres within the study, with Great Shelford and Stapleford (classified as a Rural Centre) also scoring
16 points against the sustainability criteria. As such, there is considered to be limited justification for the classification of Linton as a Minor Rural Centre and CODE recommends that the settlement hierarchy
is revisited to upgrade the classification of Linton to a Rural Centre.
4.6
In any event, the settlement hierarchy indicated in Policy S/SH is wholly inconsistent with the
Development Strategy and distribution of growth outlined in Policy S/DS. The allocation of housing within
Rural Centres and Minor Rural Centres is not reflective of the settlement hierarchy with no residential
housing allocations identified within the Rural Centres and only Melbourn receiving allocations within
the Minor Rural Centres. Furthermore, Group Villages Duxford and Caldecote, which sit below Linton in
the settlement hierarchy, have received allocations for 60 and 65 dwellings respectively. This is despite
GCSP noting in paragraph 2.129 that “Group villages are generally less sustainable locations for new
development than Rural centres and Minor rural centres” where development should only comprise of
scheme sizes of circa eight dwellings (or up to 15 dwellings in exceptional circumstances).
4.7 The stark contrast in allocations between Rural Centres, Minor Rural Centres and Group Villages is not
reflective of the settlement hierarchy or the direction of growth outlined within the Development Strategy.
This distribution of growth to Group Villages appears to lack justification and ignores the sustainability
of settlements in a higher order of the settlement hierarchy with higher sustainability credentials such
as Linton. As such, this has resulted in an insufficient quantum of development to be identified in order
to support and maintain the vitality of existing facilities and services within the village.
4.8 Paragraph 83 of the NPPF seeks to support sustainable development in rural areas where it will enhance
or maintain the vitality of rural communities for villages to grow and thrive. The Development Strategy
adopted by GCSP fails to secure the self-containment of Linton to the detriment of the existing services
in the community and the overall approach to allocations undermines the Settlement Hierarchy set out
in Policy S/SH.
4.9 In order to remedy this, GCSP should revisit the allocations outlined within the Development Strategy
and instead allocate a proportionate amount of development to appropriate and sustainable sites in
accordance with the provisions and recommended quantum in the Settlement Hierarchy. This can be
achieved through allocating proportionate development on sites such as land north of Bartlow Road and
south of Horseheath Road, Linton to ensure the ongoing vitality of the settlement and be in accordance
with national planning policy to strengthen local communities.
Comment
Draft Greater Cambridge Local Plan for consultation
Policy S/JH: New jobs and homes
Representation ID: 204105
Received: 30/01/2026
Respondent: G W Balaam & Son
Agent: CODE Development Planners Ltd
In summary, while CODE are broadly supportive of the approach taken by the GCLP in Policy S/JH
(New jobs and homes) to meet their local housing needs in full over the plan period, there are key
concerns raised in relation to Development Strategy and distribution of growth across Greater
Cambridge alongside the assessment of the site at north of Bartlow Road, Linton within the HELAA. In order to remedy this, CODE considers that the Greater Cambridge Shared Planning Service (GCSP)
should revisit the site allocations and distribution of growth across the Rural Centres and Minor Rural
Centres to identify additional smaller site allocations, such as the site at land north of Bartlow Road,
Linton.
1.1 These representations have been prepared by CODE Development Planners (hereafter referred to as
‘CODE’) on behalf of G W Balaam & Son who are promoting the site at land north of Bartlow Road,
Linton for residential development in the region of 15 dwellings.
1.2 The site is approximately 0.35ha and is located on the immediate southeastern edge of the village of
Linton. Residential development is located directly adjacent to the west of the site which has recently
been built out following grant of planning permission (reference S/1963/15/OL).
1.3 The site has been assessed within the 2025 Housing and Employment Land Availability Assessment
(HELAA) as site reference ‘40044’. CODE have previously promoted the site through previous Call for
Sites exercises to challenge the ‘red’ suitability rating within the 2021 iteration of the HELAA in light of
the material changes to the site’s suitability for development.
1.4 In summary, while CODE are broadly supportive of the approach taken by the GCLP in Policy S/JH
(New jobs and homes) to meet their local housing needs in full over the plan period, there are key
concerns raised in relation to Development Strategy and distribution of growth across Greater
Cambridge alongside the assessment of the site at north of Bartlow Road, Linton within the HELAA.
1.5 These representations consider that there is an over-reliance on larger strategic sites, which do not
afford sufficient flexibility to uplift housing delivery in the early years of the plan period in the likely event
of delays or the potential non-implementation of strategic sites. Flexible delivery across a range of sites
will also continue to be a requirement throughout the plan period, guarding against the vulnerability of
housing delivery on the larger strategic sites being delayed by any one or several reasons such as
market saturation, housebuilder business models or continuing delays in infrastructure provision.
1.6 Additionally, the lack of allocations within the Rural Centres and Minor Rural Centres fails to support the
ongoing sustainability and vitality of local settlements which is not considered to be effective in step with
the tests of soundness contained within paragraph 35 of the National Planning Policy Framework
(NPPF). The Development Strategy fails to recognise the sustainability credentials of the settlement of
Linton which benefits from a range of facilities and services alongside connectivity to public transport
opportunities within walking distance of the site on Bartlow Road.
1.7 In order to remedy this, CODE considers that the Greater Cambridge Shared Planning Service (GCSP)
should revisit the site allocations and distribution of growth across the Rural Centres and Minor Rural
Centres to identify additional smaller site allocations, such as the site at land north of Bartlow Road,
Linton. This will ensure that sufficient flexibility is provided within the housing supply to enable sites to
come forward quickly to address housing need in the short term while maintaining and enhancing the
vitality and viability of settlements such as Linton.
Object
Draft Greater Cambridge Local Plan for consultation
Policy S/SH: Settlement hierarchy
Representation ID: 204143
Received: 30/01/2026
Respondent: G W Balaam & Son
Agent: CODE Development Planners Ltd
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
CODE query the identification of Linton as a Minor Rural Centre within the settlement hierarchy and
consider the hierarchy to be wholly inconsistent with the distribution of growth set out within the
Development Strategy.
The Development Strategy adopted by GCSP fails to secure the self-containment of Linton to the detriment of the existing services in the community and the overall approach to allocations undermines the Settlement Hierarchy set out in Policy S/SH.
GCSP should revisit the allocations outlined within the Development Strategy
and instead allocate a proportionate amount of development to appropriate and sustainable sites in
accordance with the provisions and recommended quantum in the Settlement Hierarchy. This can be
achieved through allocating proportionate development on sites such as land south of Horseheath Road,
Linton to ensure the ongoing vitality of the settlement and be in accordance with national planning policy
to strengthen local communities.
CODE query the identification of Linton as a Minor Rural Centre within the settlement hierarchy and
consider the hierarchy to be wholly inconsistent with the distribution of growth set out within the
Development Strategy.
As set out above, Linton is identified as a ‘Minor Rural Centre’ in Policy S/SH. Paragraph 2.126 notes
that Minor Rural Centres have a “lower level of services, facilities and employment than rural centres,
but a greater level than most other settlements in Greater Cambridge and often perform a role in terms
of providing services and facilities for a small rural hinterland.” Paragraph 2.127 supports development
of up to 30 dwellings as larger scale windfall development within the existing settlement boundary.
Land south of Horseheath Road, Linton is located outside, but directly adjacent to the settlement
boundary of Linton fronting development on two sides to the east and south of the site and therefore
does not benefit from this policy provision set out within the GCLP. Further the approval and construction
of ‘The Pastures’ development, the site is felt to be well defined and located to ‘round off’ development
in Linton. The village benefits from a range of services and facilities including:
• Primary School
• GP surgery and pharmacy
• Frequent bus service between Cambridge and Haverhill
• Library
• Post office
• Dentist
• Bank
• Community facilities
• A range of over 20 shops and services
The site is well related to these services by sustainable transport methods, and the site is of an
appropriate and proportionate scale to accommodate up to 30 dwellings in accordance with the policy
wording.
This is reflected within the supporting evidence base of the GCLP and the Settlement Hierarchy Study
Update (2025) which recognises Linton as the highest scoring Minor Rural Centre against the
sustainability criteria with a total of 16 points and identified as a “service centre” within paragraph 3.19
of the Settlement Hierarchy Study Update 2025. Despite this positive assessment, the study considers
Linton to not be comparable with settlements in the Rural Centre grouping due to a lower number of
services and facilities. This assertion does not appear to be supported by the assessment of Rural
Centres within the study, with Great Shelford and Stapleford (classified as a Rural Centre) also scoring
16 points against the sustainability criteria. As such, there is considered to be limited justification for the
classification of Linton as a Minor Rural Centre and CODE recommends that the settlement hierarchy
is revisited to upgrade the classification of Linton to a Rural Centre.
In any event, the settlement hierarchy indicated in Policy S/SH is wholly inconsistent with the
Development Strategy and distribution of growth outlined in Policy S/DS. The allocation of housing within
Rural Centres and Minor Rural Centres is not reflective of the settlement hierarchy with no residential
housing allocations identified within the Rural Centres and only Melbourn receiving allocations within
the Minor Rural Centres. Furthermore, Group Villages Duxford and Caldecote, which sit below Linton in
the settlement hierarchy, have received allocations for 60 and 65 dwellings respectively. This is despite
GCSP noting in paragraph 2.129 that “Group villages are generally less sustainable locations for new
development than Rural centres and Minor rural centres” where development should only comprise of
scheme sizes of circa eight dwellings (or up to 15 dwellings in exceptional circumstances).
The stark contrast in allocations between Rural Centres, Minor Rural Centres and Group Villages is not
reflective of the settlement hierarchy or the direction of growth outlined within the Development Strategy.
This distribution of growth to Group Villages appears to lack justification and ignores the sustainability
of settlements in a higher order of the settlement hierarchy with higher sustainability credentials such
as Linton. As such, this has resulted in an insufficient quantum of development to be identified in order
to support and maintain the vitality of existing facilities and services within the village.
Paragraph 83 of the NPPF seeks to support sustainable development in rural areas where it will enhance
or maintain the vitality of rural communities for villages to grow and thrive. The Development Strategy
adopted by GCSP fails to secure the self-containment of Linton to the detriment of the existing services
in the community and the overall approach to allocations undermines the Settlement Hierarchy set out
in Policy S/SH.
In order to remedy this, GCSP should revisit the allocations outlined within the Development Strategy
and instead allocate a proportionate amount of development to appropriate and sustainable sites in
accordance with the provisions and recommended quantum in the Settlement Hierarchy. This can be
achieved through allocating proportionate development on sites such as land south of Horseheath Road,
Linton to ensure the ongoing vitality of the settlement and be in accordance with national planning policy
to strengthen local communities.
Object
Draft Greater Cambridge Local Plan for consultation
Policy S/DS: Development strategy
Representation ID: 204144
Received: 30/01/2026
Respondent: G W Balaam & Son
Agent: CODE Development Planners Ltd
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
The Development Strategy identified within Policy S/DS is not positively prepared, justified, effective
and is not in accordance with the suite of national planning policies contained within the NPPF. The
allocation of development appears to be disproportionately weighted towards larger strategic sites within
the urban area and neglects the provision of medium and smaller allocations which are important to
maintain a supply and delivery of needed housing in the short and medium term.
CODE contends that in order for the Regulation 18 Greater Cambridge Local Plan (GCLP)
to meet the tests of soundness, GCSP should revisit their Development Strategy to identify site
allocations across the Rural and Minor Rural Centres to ensure an effective distribution of growth on
small and medium sites can be delivered in the early years of the plan period. Sites such as land south
of Horseheath Road, Linton (40013) should be allocated for development to reflect their suitable, available and
deliverable nature as reflected in the HELAA 2025.
The Development Strategy identified within Policy S/DS is not positively prepared, justified, effective
and is not in accordance with the suite of national planning policies contained within the NPPF. The
allocation of development appears to be disproportionately weighted towards larger strategic sites within
the urban area and neglects the provision of medium and smaller allocations which are important to
maintain a supply and delivery of needed housing in the short and medium term.
The NPPF is clear in paragraph 72 that policy-making authorities should “identify a sufficient supply and
mix of sites” to provide deliverable sites across the plan period. Paragraph 73 of the NPPF highlights
the “important contribution” small and medium sized sites can make in meeting the housing requirement
of an area due to their ability to be delivered quickly. The NPPF encourages plan-making authorities to
identify at least 10% of their housing requirement on sites no greater than one hectare to support this
important contribution and Small and Medium Enterprise (SME) housebuilders.
However, the Development Strategy contained within Policy S/DS focuses on the creation and extension
of new settlements and strategic sites, with smaller scale development limited to only Melbourn, Duxford
and Caldecote. This is not in accordance with the provisions of paragraph 73 of the NPPF and this
approach is not justified within the Sustainability Appraisal (SA). The Development Strategy Topic Paper
(December 2025) notes that this 10% small sites requirement can only be met over the plan period
through the assumed windfall allowance within the settlement boundaries of Rural Centres and Minor
Rural Centres. However, based on the defined extents of settlements within the plan area, CODE
queries the likelihood of the extent of development to be accommodated within existing settlement
boundaries. This does not demonstrate a positively prepared approach to secure the delivery of
development for SME housebuilders through the identification of site allocations
CODE query the strategy to deliver these homes set out in Policy S/DS. The strategy places significant
reliance on large strategic sites coming forward later in the plan period at Cambridge East, Eddington,
Cambourne North and Grange Farm for a combined total of 11,550 dwellings.
Previous experience with settlement extensions and new settlements indicates that due to their large
and strategic nature, they are often constrained, heavily opposed and reliant on the delivery of key
infrastructure which causes further delays to anticipated trajectories. CODE is concerned that GCSP’s ability to demonstrate a five-year housing land supply within the short-medium term could be significantly
impacted by the over reliance on strategic sites without sufficient flexibility to uplift housing delivery in
the early years of the plan period. This is exemplified within the supporting text at 2.41 in the case of
the North East Cambridge allocation, where delivery is under threat due to changes in funding to the
relocation of the Cambridge Waste Water Treatment Plant. While this loss of dwellings is accounted for
within the Development Strategy, it highlights the inherent risk of the delivery of other larger site
allocations particularly in relation to infrastructure capacity in the context of increasing water scarcity
issues around the Cambridge Urban Area.
As such, due to the uncertainty of if and/or when these strategic sites will come forward and the lack of
alternative options to deliver expressed housing need, there is a need for ‘small’ and ‘medium’ sized
sites to come forward to ensure the plan is effective and deliverable across the plan period. The site at
land south of Horseheath Road is considered to be suitable, available and deliverable in the short term
to contribute the housing supply of Cambridge and include a provision of much-needed affordable
housing for the area. Based on the current Development Strategy, much of the provision of affordable
housing will be backloaded to the later years of the plan period restricting the ability of GCSP to address
the affordable housing need of the district in the short term. According to the Local Authority Housing
Statistics data returns (2024-2025), there are 1,956 households on the housing waiting list for South
Cambridge District which emphasises the need to deliver affordable housing in the immediacy.
Therefore, CODE contends that in order for the Regulation 18 Greater Cambridge Local Plan (GCLP)
to meet the tests of soundness, GCSP should revisit their Development Strategy to identify site
allocations across the Rural and Minor Rural Centres to ensure an effective distribution of growth on
small and medium sites can be delivered in the early years of the plan period. Sites such as land south
of Horseheath Road, Linton should be allocated for development to reflect their suitable, available and
deliverable nature as reflected in the HELAA 2025.
Comment
Draft Greater Cambridge Local Plan for consultation
Policy S/DS: Development strategy
Representation ID: 204145
Received: 30/01/2026
Respondent: G W Balaam & Son
Agent: CODE Development Planners Ltd
These representations consider that there is an over-reliance on larger strategic sites, which do not afford sufficient flexibility to uplift housing delivery in the early years of the plan period in the likely event of delays or the potential non-implementation of strategic sites. Flexible delivery across a range of sites will also continue to be a requirement throughout the plan period, guarding against the vulnerability of housing delivery on the larger strategic sites being delayed by any one or several reasons such as market saturation, housebuilder business models or continuing delays in infrastructure provision.
ODE are broadly supportive of the approach taken by the GCLP in Policy S/JH
(New jobs and homes) to meet their local housing needs in full over the plan period, there are key
concerns raised in relation to Development Strategy and distribution of growth across Greater
Cambridge. These representations consider that there is an over-reliance on larger strategic sites, which
do not afford sufficient flexibility to uplift housing delivery in the early years of the plan period in the likely
event of delays or the potential non-implementation of strategic sites. Flexible delivery across a range
of sites will also continue to be a requirement throughout the plan period, guarding against the
vulnerability of housing delivery on the larger strategic sites being delayed by any one or several reasons
such as market saturation, housebuilder business models or continuing delays in infrastructure
provision.
Additionally, the lack of allocations within the Rural Centres and Minor Rural Centres fails to support the
ongoing sustainability and vitality of local settlements which is not considered to be effective in step with
the tests of soundness contained within paragraph 35 of the National Planning Policy Framework
(NPPF). The Development Strategy fails to recognise the sustainability credentials of the settlement of Linton which benefits from a range of facilities and services alongside connectivity to public transport opportunities within walking distance of the site south of Horseheath Road.
In order to remedy this, CODE considers that the Greater Cambridge Shared Planning Service (GCSP)
should revisit the site allocations and distribution of growth across the Rural Centres and Minor Rural
Centres to identify additional smaller site allocations, such as the site at land south of Horseheath Road,
Linton. This will ensure that sufficient flexibility is provided within the housing supply to enable sites to
come forward quickly to address housing need in the short term while maintaining and enhancing the
vitality and viability of settlements such as Linton.
Comment
Draft Greater Cambridge Local Plan for consultation
SA
Representation ID: 211095
Received: 30/01/2026
Respondent: G W Balaam & Son
Agent: CODE Development Planners Ltd
The Development Strategy contained within Policy S/DS focuses on the creation and extension of new settlements and strategic sites, with smaller scale development limited to only Melbourn, Duxford and Caldecote.
This is not in accordance with the provisions of paragraph 73 of the NPPF and this approach is not justified within the Sustainability Appraisal (SA).
In order for the Regulation 18 Greater Cambridge Local Plan (GCLP) to meet the tests of soundness, GCSP should revisit their Development Strategy to identify site
allocations across the Rural and Minor Rural Centres to ensure an effective distribution of growth on small and medium sites can be delivered in the early years of the plan period. Sites such as land north of Bartlow Road, Linton should be allocated for development to reflect their suitable, available and deliverable nature as reflected in the HELAA 2025.
3.1 The Development Strategy identified within Policy S/DS is not positively prepared, justified, effective
and is not in accordance with the suite of national planning policies contained within the NPPF. The
allocation of development appears to be disproportionately weighted towards larger strategic sites within
the urban area and neglects the provision of medium and smaller allocations which are important to
maintain a supply and delivery of needed housing in the short and medium term.
3.2 The NPPF is clear in paragraph 72 that policy-making authorities should “identify a sufficient supply and
mix of sites” to provide deliverable sites across the plan period. Paragraph 73 of the NPPF highlights
the “important contribution” small and medium sized sites can make in meeting the housing requirement
of an area due to their ability to be delivered quickly. The NPPF encourages plan-making authorities to
identify at least 10% of their housing requirement on sites no greater than one hectare to support this
important contribution and Small and Medium Enterprise (SME) housebuilders.
3.3 However, the Development Strategy contained within Policy S/DS focuses on the creation and extension
of new settlements and strategic sites, with smaller scale development limited to only Melbourn, Duxford
and Caldecote. This is not in accordance with the provisions of paragraph 73 of the NPPF and this
approach is not justified within the Sustainability Appraisal (SA). The Development Strategy Topic Paper(December 2025) notes that this 10% small sites requirement can only be met over the plan period
through the assumed windfall allowance within the settlement boundaries of Rural Centres and Minor
Rural Centres. However, based on the defined extents of settlements within the plan area, CODE
queries the likelihood of the extent of development to be accommodated within existing settlement
boundaries. This does not demonstrate a positively prepared approach to secure the delivery of
development for SME housebuilders through the identification of site allocations
3.4 CODE query the strategy to deliver these homes set out in Policy S/DS. The strategy places significant
reliance on large strategic sites coming forward later in the plan period at Cambridge East, Eddington,
Cambourne North and Grange Farm for a combined total of 11,550 dwellings.
3.5 Previous experience with settlement extensions and new settlements indicates that due to their large
and strategic nature, they are often constrained, heavily opposed and reliant on the delivery of key
infrastructure which causes further delays to anticipated trajectories. CODE is concerned that GCSP’s
ability to demonstrate a five-year housing land supply within the short-medium term could be significantly
impacted by the over reliance on strategic sites without sufficient flexibility to uplift housing delivery in
the early years of the plan period. This is exemplified within the supporting text at 2.41 in the case of
the North East Cambridge allocation, where delivery is under threat due to changes in funding to the
relocation of the Cambridge Waste Water Treatment Plant. While this loss of dwellings is accounted for
within the Development Strategy, it highlights the inherent risk of the delivery of other larger site
allocations particularly in relation to infrastructure capacity in the context of increasing water scarcity
issues around the Cambridge Urban Area.
3.6 As such, due to the uncertainty of if and/or when these strategic sites will come forward and the lack of
alternative options to deliver expressed housing need, there is a need for ‘small’ and ‘medium’ sized
sites to come forward to ensure the plan is effective and deliverable across the plan period. The site at
land north of Bartlow Road is considered to be suitable, available and deliverable in the short term to
contribute the housing supply of Cambridge and include a provision of much-needed affordable housing
for the area. Based on the current Development Strategy, much of the provision of affordable housing
will be backloaded to the later years of the plan period restricting the ability of GCSP to address the
affordable housing need of the district in the short term. According to the Local Authority Housing
Statistics data returns (2024-2025), there are 1,956 households on the housing waiting list for South
Cambridge District which emphasises the need to deliver affordable housing in the immediacy.
3.7 Therefore, CODE contends that in order for the Regulation 18 Greater Cambridge Local Plan (GCLP)
to meet the tests of soundness, GCSP should revisit their Development Strategy to identify site
allocations across the Rural and Minor Rural Centres to ensure an effective distribution of growth on
small and medium sites can be delivered in the early years of the plan period. Sites such as land north
of Bartlow Road, Linton should be allocated for development to reflect their suitable, available and
deliverable nature as reflected in the HELAA 2025.