Draft Greater Cambridge Local Plan for consultation

Object

Representation ID: 208376

Received: 30/01/2026

Respondent: NIAB Trust

Agent: Ceres Property

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

It is argued that as the Standard Method figures broadly correlate with the Central (suggested most likely) job and housing projections, that adoption of these figures is appropriate. However, in accordance with the requirements of the NPPF this is not considered to be an appropriate strategy taking into account reasonable alternatives and other publicly available evidence. As it stands, Policy S/JH is not justified and the DLP should not be considered sound.

Comment

Representation ID: 208377

Received: 30/01/2026

Respondent: NIAB Trust

Agent: Ceres Property

In accordance with the requirements of paragraphs 25 and 26 of the NPPF, it is critical that the emerging DLP is aligned to the Local Growth Plan and the emerging Spatial Development Plan for Cambridgeshire. As a starting point, this should ensure that housing and employment growth is
substantially increased to align with the objectives for Cambridgeshire & Peterborough.

As set out above, delivering growth in Greater Cambridge is of national significance. In the past, employment growth rates have been stronger than official figures and have outstripped delivery of housebuilding and infrastructure. The government has confirmed its continued support for high levels of growth in Greater Cambridge. This ambitious level of growth is also supported by the Local Growth Plan and will be reflected in the Spatial Development Strategy, the DLP needs to be amended to properly reflect this.

Comment

Representation ID: 208378

Received: 30/01/2026

Respondent: NIAB Trust

Agent: Ceres Property

Paragraph 36 a) of the NPPF is clear that to be positively prepared, the Local Plan should, as a minimum, seek to meet the areas objectively assessed housing needs.’ The standard method housing requirement should be a minimum starting point for housing growth. Therefore, it is unclear why the Development Strategy Topic Paper identifies housing figures that are marginally below the standard method requirements for both housing and job growth as a ‘central growth’ figure. In reality, this is the absolute minimum level of growth that should be planned for and clearly is not in line with the growth ambitions set out at the national level or in the Local Growth Plan.

Object

Representation ID: 208379

Received: 30/01/2026

Respondent: NIAB Trust

Agent: Ceres Property

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The emerging Local Plan currently covers a plan period to 2045. The provision for 48,132 dwellings proposed over that period, therefore will deliver less than 50% of the government’s lower aspiration of delivering 100,000 dwellings in the Greater Cambridge Area by 2050 or less than 33% of the housing required using the higher figure of 150,000 dwellings. If the housing growth in the Local
Plan is continued on a pro rata basis using the 2,295 dwellings per annum for another 5 years, this would still only deliver 59,670 by 2050, still over 40,000 dwellings below the government’s lower growth scenario.

Based on this evidence, it is considered that the levels of job and housing growth targeted are not justified and are not an appropriate strategy taking into account the reasonable alternatives. A far more ambitious level of job and housing growth should be planned for. As it stands Policy S/JH is considered unsound and requires amendment.

Support

Representation ID: 208380

Received: 30/01/2026

Respondent: NIAB Trust

Agent: Ceres Property

Part 1 of Policy S/DS is supported. It is considered appropriate that development should be focused
within Cambridge City and on the outer edge of Cambridge, accounting for the global importance of
Cambridge as the focus for growth.

Object

Representation ID: 208381

Received: 30/01/2026

Respondent: NIAB Trust

Agent: Ceres Property

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Part 2 of Policy S/DS sets out a number of strategic scale allocations. It should be noted that a number of these have significant constraints which will likely result in significant delays to delivery. As a result, the proposed strategy is not appropriate and is considered to be unjustified.

Comment

Representation ID: 208382

Received: 30/01/2026

Respondent: NIAB Trust

Agent: Ceres Property

Additional smaller site allocations should be made to maintain housing and employment delivery if there are challenges with larger strategic sites. For example, Policy S/NEC: North East Cambridge identifies north-east Cambridge will deliver, inter alia, approximately 8,350 new homes (including around 5,500 homes on the existing Cambridge Waste Water Treatment Plant site (CWWTP)), up to 320,000 square metres of additional business floorspace and 27,300 square metres of industrial floorspace. In August 2025, the Government announced that it will not be funding the relocation of the CWWTP through the Housing Infrastructure Fund. Delivery of the development is subject to alternative funding being found to enable the relocation of the CWWTP, which means there is significant uncertainty as to whether, or when, the development might come forward.

Although this allocation is not objected to in principle, additional sites need to be allocated to avoid a situation where large sites like North-East Cambridge do not come forward for development in a reasonable timeframe.

Comment

Representation ID: 208383

Received: 30/01/2026

Respondent: NIAB Trust

Agent: Ceres Property

It is considered that the plan period should be extended to 2050. A longer plan period is considered to clearly be the most reasonable strategy, when considered against the alternatives. This amendment is required in order for the DLP to accord with national policy and for it to be justified.

Comment

Representation ID: 208384

Received: 30/01/2026

Respondent: NIAB Trust

Agent: Ceres Property

Page 155 of the Local Growth Plan is clear that to support a doubling of the economy by 2050 would require a minimum of 214,760 dwellings to be delivered in the County during this timetable. Whilst the Local Growth Plan does not define a District by District breakdown of housing figures, it is clear that Greater Cambridge, as a focus for growth within the area, should be responsible for a
substantial proportion of this housing delivery. On a pro-rata basis, if the 214,760 dwellings was delivered equally between the six local authority areas in Cambridgeshire & Peterborough, this would result in Greater Cambridge having a requirement to deliver a minimum of 71,586 dwellings between now and 2050. In reality, accounting for Cambridge’s role as the International Life-Science
and employment driver for the County, as well as the government’s Case for Cambridge, the growth within the Cambridge City and South Cambridgeshire administrative areas should be substantially higher.

Comment

Representation ID: 208385

Received: 30/01/2026

Respondent: NIAB Trust

Agent: Ceres Property

In Cambridgeshire and Peterborough, the Agri-Food & Tech sector employs 3,500 people across 115 companies, generating approximately £1billion in revenue. Agri-Food & Tech businesses benefit from excellent land quality for farming, world-renowned academic institutions, a strong supply chain in terms of international food processing, food packing, distribution and logistics, and world leading
R&D facilities.

The Local Growth Plan projection maps predict growth of the agri-food and tech sector by £1.2bn by 2050 and expect to see employment growth in this sector of 7,700, a 57% increase from now. Sustainable sites which can be delivered early in the plan period, such as NIAB’s sites at Park Farm, would support this ambitious level of growth in the agri-food and tech sector, and as such it is considered that they should be allocated in the DLP.