Greater Cambridge Local Plan: Proposed Submission

Vision for Greater Cambridge

COMMENT

Ely Diocesan Board of Finance (EDBF) have promoted a number of sites for development for both housing and employment, including at Milton, Stapleford/Great Shelford, Waterbeach, Fulbourn, and Landbeach. The Vision for Greater Cambridge in the Reg.19 Proposed Submission Greater Cambridge Local Plan (draft GCLP) refers to increasing quality of life for communities, minimising carbon emissions, reducing car use, providing housing and jobs, supporting infrastructure, and increasing green spaces.

As set out in these representations, the proposed housing target, the development strategy and the selected allocations for draft GCLP are unlikely to fully deliver the Vision for Greater Cambridge. The housing requirement is not aligned with jobs growth, which would lead to more people commuting into Cambridge to work mostly by car. The development strategy is too focussed on the delivery of large strategic sites including an expanded Cambourne, existing new settlements at Northstowe, Waterbeach and Bourn Airfield, and a proposed new settlement at Grange Farm. The delivery timetable for infrastructure to support an expanded Cambourne and at Grange Farm is uncertain. For all of the large strategic site allocations the predicted housing delivery rates are unrealistically high, and the delivery of policy compliant levels of affordable housing is often not achieved. The development strategy avoids directing development to the larger and more sustainable villages, regardless of their sustainability credentials, existing services and facilities, accessibility by sustainable modes of transport, or affordable housing needs.

It is considered that the Vision for Greater Cambridge would only be fully delivered with a higher housing requirement, an amended development strategy, and additional development at the more sustainable villages.

Strategic Priorities

COMMENT

EDBF have promoted a number of sites for development for both housing and employment, including at Milton, Stapleford/Great Shelford, Waterbeach, Fulbourn, and Landbeach. The draft GCLP identifies seven strategic priorities relating to climate change, biodiversity and green spaces, wellbeing and social inclusion, great places, jobs, homes, and connectivity and infrastructure. As set out in these representations, the proposed housing target, the development strategy and the selected allocations for draft GCLP are unlikely to fully deliver the strategic priorities.

The housing requirement is not aligned with jobs growth, which would lead to more people commuting into Cambridge to work mostly by car. This outcome would not meet the climate change strategic priority. The development strategy is too focussed on the delivery of large strategic sites, where the timetable for the delivery of necessary infrastructure is uncertain in some cases, the predicted housing delivery rates are unrealistically high, and the delivery of policy compliant levels of affordable housing is often not achieved. It is considered that housing and affordable housing needs would not be met by a development strategy based on this approach, and would not meet the homes strategic priority. The development strategy avoids directing development to the larger and more sustainable villages, regardless of their sustainability credentials, existing services and facilities, accessibility by sustainable modes of transport, or affordable housing needs. This approach does not support the residents or services and facilities in those villages, and would not meet the great places, homes, connectivity and infrastructure strategic priorities. It is noted that some green infrastructure opportunity areas identified in draft GCLP, are unrelated to strategic development allocations that could support their delivery. In these circumstances those proposed green infrastructure opportunity areas are unlikely to be delivered, and this outcome would not meet the biodiversity and green spaces strategic priority.

It is considered that the strategic priorities for draft GCLP would only be fully delivered with a higher housing requirement, an amended development strategy, and additional development at the more sustainable villages including Milton, Stapleford/Great Shelford, Waterbeach, Fulbourn, and Landbeach.

Requested Change

The following changes to Policy S/JH are requested.

It is requested that the housing target is recalculated to include the previous commuting patterns adjustment, consistent with the adjustment made in the 2023 ‘Greater Cambridge Employment and Housing Evidence Update Employment Land, Economic Development and Relationship with Housing’ Report.

It is requested that the housing target includes some upward adjustments for growth ambitions, that reflect the Greater Cambridge City Deal and the Cambridgeshire and Peterborough Devolution Deal, the adopted Local Growth Plan of the Mayor for Peterborough & Cambridgeshire, and the Cambridge Growth Company.

It is requested that housing target include some upward adjustment to address affordable housing needs.

Consistent with the representations to Appendix C, a new policy is required in draft GCLP to ensure that the housing requirements for neighbourhood plan areas are delivered.

Policy S/JH: New Jobs and Homes

NOT SOUND – NOT JUSTIFIED AND NOT CONSISTENT WITH NATIONAL POLICY

OBJECT

Policy S/JH of draft GCLP sets out the targets for jobs and housing during the plan period from 2024 to 2045. The jobs target is 73,300 additional jobs, and the housing target is a minimum of 48,069 dwellings. The proposed housing target is derived from the national standard method figure for calculating local housing needs, which for Greater Cambridge is 2,289 dwellings per annum. In summary, the housing target is not consistent with national policy because upward adjustments for growth and affordable housing have not been considered.

It is noted that the job target is not aligned with the housing target. It is considered that a job target that is higher than the housing target would require potential employees to commute into Greater Cambridge to fill those jobs. This outcome would lead to an increase in in-commuting to Greater Cambridge. It is anticipated that most of the in-commuting would be by car, particularly if public transport options are not available or the delivery of transport infrastructure projects are subject to unconfirmed funding decisions and associated development.

The housing target identified in the 2023 ‘Greater Cambridge Employment and Housing Evidence Update Employment Land, Economic Development and Relationship with Housing’ Report was based on a Central Growth Scenario, the preferred 2011 Census commuting data, and included a 1:1 commuting patterns adjustment. This previous approach sought to better align the job and housing targets. The 2025 Greater Cambridge Employment and Housing Needs Update 2024-2045 Report does not include a similar commuting patterns adjustment, which is an inconsistent approach. The ‘Review of Economic Data, Context and Representations’ Report (Iceni Projects Ltd June 2026) does not explain why the previous commuting patterns adjustment is no longer included. It is requested that the housing target is recalculated to include the previous commuting patterns adjustment. This approach would be consistent with Paragraph 110 of the NPPF, which refers to limiting the need to travel.

Paragraph 61 of the NPPF confirms the Government’s objective to significantly boost the supply of housing, and to achieve this by ensuring that a sufficient amount and variety of land for housing is identified. Paragraph 62 expects the standard method to be used to determine the minimum number of houses needed. Paragraph 63 expects the size, type and tenure of housing needs of the community to be assessed and reflected in planning policies, including for example those with an affordable housing need. Paragraph 69 states in part that “The requirement may be higher than the identified housing need if, for example, it includes provision for neighbouring areas, or reflects growth ambitions linked to economic development or infrastructure investment”. Paragraph 008 (ID. 67 - Housing needs of different groups) in the Planning Practice Guidance states in part that “An increase in the total housing requirement included in the plan may need to be considered where it could help deliver the required number of affordable homes”. It should be noted that Paragraph 008 relates to the delivery of affordable housing, and is distinct from housing affordability which is a separate factor included in the standard method calculations. The housing target in Policy S/JH is based on the standard method only, with no adjustments for growth linked to economic development and infrastructure investment or to meet affordable housing needs, all of which are relevant to Greater Cambridge.

The Greater Cambridge City Deal recognised the relationship between housing and economic growth, and that the shortage of available and affordable housing within Greater Cambridge has had an impact on house prices, commuting patterns, and recruitment and retention of employees. The Cambridgeshire and Peterborough Devolution Deal included a commitment to deliver substantial economic growth and to double economic output during the next 25 years. The adopted Local Growth Plan of the Mayor for Peterborough & Cambridgeshire sets out two growth scenarios: a core scenario which doubles the economy by 2050; and an aspirational scenario which triples the economy by 2050. The National Infrastructure Commission, the Cambridge and Peterborough Combined Authority and the Greater Cambridge Greater Peterborough Enterprise Partnership have previously acknowledged and supported the economic growth potential of the Greater Cambridge area, and concluded that there is a need to substantially increase housing delivery in order to support that economic growth and address the significant housing affordability issues that exist. At present there is an imbalance between rates of economic growth and housing delivery in Greater Cambridge. The housing target in Policy S/JH ignores the commitments made in the Greater Cambridge City Deal and the Cambridgeshire and Peterborough Devolution Deal. It also ignores the findings of work undertaken by the National Infrastructure Commission, the Cambridge and Peterborough Combined Authority and the Greater Cambridge Greater Peterborough Enterprise Partnership.

In 2024 the Government established a Cambridge Growth Company to maximise Cambridge’s full economic potential and to deliver nationally significant growth. The Growth Company will seek to unlock and accelerate development for Cambridge, and to deliver the homes, jobs and infrastructure needed for the long-term and sustainable growth of the City. It will seek to deliver more ambitious levels of growth than are proposed in the emerging Greater Cambridge Local Plan. In order to deliver more ambitious levels of growth, the Growth Company will need to tackle some of the barriers to growth including water and transport infrastructure, traffic congestion, and housing affordability. It is acknowledged that draft GCLP does not need to take into account the levels of growth to be addressed by the Cambridge Growth Company. However, it does indicate that there are growth ambitions for Greater Cambridge and there should be some upward adjustment to the housing target in Policy S/JH to reflect this future growth during the plan period for draft GCLP.

There are a number of proposed and planned infrastructure projects in Greater Cambridge that should have been taken into account in deciding whether adjustments should be made to the housing target in Policy S/JH. The list of infrastructure projects includes East West Rail, Cambourne to Cambridge Busway, Cambridge South East Transport project, Waterbeach to Cambridge Busway, Cambridge Eastern Access project, and Cambridge South Station. In addition, the Greater Cambridge Partnership is delivering greenways to connect surrounding villages to Cambridge by walking and cycling. The funding for some of these projects have not been confirmed, but it is anticipated that they will need to be supported by associated development.

The 2025 ‘Housing Needs of Specific Groups in Cambridge and South Cambridgeshire’ Report identifies the housing needs of different groups, including the need for affordable housing. Chapter 7 of the Report deals with affordable housing need. The Report identifies an acute need for affordable housing in Greater Cambridge. It estimates an annual need for 1,083 affordable homes for households unable to buy or rent housing across Greater Cambridge, excluding those that can rent but not buy – see Paragraph 7.62 in the Report. It includes an analysis of the affordable housing need if those households already living in accommodation are excluded, which would be an affordable need for 425 homes per annum in Cambridge and 318 dwellings per annum in South Cambridgeshire – see Paragraph 7.63 in the Report. A combined figure for Greater Cambridge would be 743 affordable homes per year. It is acknowledged that the affordable housing data is complex, households needs will change over time, and the annual affordable housing needs should not be multiplied to generate a figure for the whole plan period. The Report concludes that no adjustments are required to the housing target for draft GCLP to address affordable housing needs. This cannot be correct. The annual monitoring data shows that affordable housing delivery in Greater Cambridge does fluctuate each year, but does show that c.500 affordable dwellings are provided on average each year, which is less than the current need. In addition, some the existing strategic sites are not able to deliver policy compliant levels of affordable housing (e.g. Northstowe and Waterbeach new settlements) because of the need to provide significant amounts of new infrastructure, and it is anticipated that the outcome would be the same for the proposed strategic sites at North Cambourne and Grange Farm. If affordable housing needs are to be met then a higher housing target and additional allocations should be identified in draft GCLP to address the shortfall in the delivery of affordable housing from the existing and proposed strategic sites. It is considered that the housing target in Policy S/JH should include some upward adjustment to address affordable housing needs. It should be noted that Paragraph 008 (ID.67 in the PPG) relates to the delivery of affordable housing, and is distinct from housing affordability which is a separate factor included in the standard method calculations.

The representations to Appendix C deal with the part of Policy S/JH that relates to the housing requirements for neighbourhood plan areas.

It is considered that the housing target in Policy S/JH is not sound, in that the proposed approach is not justified as an appropriate strategy, and is not consistent with national policy in terms of not including upward adjustments for growth and affordable housing (NPPF Paragraph 69 and PPG Paragraph 008 in ID.67).

Requested Change

The following changes to Policy S/JH are requested.

It is requested that the housing target is recalculated to include the previous commuting patterns adjustment, consistent with the adjustment made in the 2023 ‘Greater Cambridge Employment and Housing Evidence Update Employment Land, Economic Development and Relationship with Housing’ Report.

It is requested that the housing target includes some upward adjustments for growth ambitions, that reflect the Greater Cambridge City Deal and the Cambridgeshire and Peterborough Devolution Deal, the adopted Local Growth Plan of the Mayor for Peterborough & Cambridgeshire, and the Cambridge Growth Company.

It is requested that housing target include some upward adjustment to address affordable housing needs.

Consistent with the representations to Appendix C, a new policy is required in draft GCLP to ensure that the housing requirements for neighbourhood plan areas are delivered.

Requested Change

The requested changes to the development strategy in Policy S/DS are as follows.

It is requested that the housing delivery assumptions for all of the strategic sites are reassessed, taking into account realistic annual housing delivery rates and the delivery of critical infrastructure required for those sites.

It is requested that land is released from the Green Belt to meet development needs.

It is requested that additional allocations are made in the more sustainable villages, including at Rural Centres, Minor Rural Centres, and Group Villages.

Policy S/DS: Development Strategy

NOT SOUND – NOT JUSTIFIED AND NOT CONSISTENT WITH NATIONAL POLICY

OBJECT

Policy S/DS of draft GCLP sets out the development strategy. In summary, the development strategy comprises delivery at the following locations: sites within Cambridge; existing urban extensions on the edge of Cambridge; existing new settlements; proposed new settlements; housing and employment at employment sites in the rural southern cluster; proposed new strategic employment allocations; and, a limited number of sites at villages in the rural area. It is acknowledged that the principle of development at most of the strategic sites is already established through adopted development plan documents e.g. Eddington, Cambourne West, Northstowe, Waterbeach, Bourn Airfield, and Cambridge East. The proposed strategic sites at Cambourne North (related to the proposed East West Rail and new station for Cambourne) and proposed new settlement at Grange Farm (related to a new stop on the proposed Cambridge South East Transport project) are new strategic allocations for draft GCLP.

It is considered that there are a number of risks associated with the development strategy in Policy S/DS. It is proposed that 44% of the housing target would be delivered at new settlements. It is very reliant on the delivery of the existing strategic sites, but there is no evidence that delivery at these sites will increase above current rates. It is assumed that housing delivery at some of the strategic sites would be 300 dwellings per annum, but this rate has not been achieved at existing strategic sites in Greater Cambridge or delivered at these rates for a sustained period. The housing delivery rates at some of these strategic sites appear to be optimistic and not based on evidence from other similar developments, and in the case of Cambourne North does not take into account the close proximity of other strategic sites i.e. Cambourne West and Bourn Airfield. The delivery of the proposed strategic sites at Cambourne North and at Grange Farm are reliant on the delivery of transport projects that are not approved, and where funding and delivery timescales are uncertain. It is requested that the housing delivery assumptions for all of the strategic sites are reassessed.

Most of the existing new settlements will deliver less affordable housing than the normal policy requirement of 40%, mainly because of the need for these developments to also deliver significant levels of new transport and community infrastructure in initial phases. It is anticipated that affordable housing delivery at Cambourne North and at Grange Farm would also be reduced for the same reasons, and particularly during the initial stages of those developments. A reduction in the delivery of affordable housing in the initial stages of Cambourne North and Grange Farm would also affect the housing delivery rates overall because it would reduce the mix of available housing.

It is considered that exceptional circumstances exist to release land from the Green Belt, which are related to the significant need for housing and affordable housing in Greater Cambridge, the need to support economic growth, and to direct development to sustainable locations. It is requested that land is released from the Green Belt to meet development needs. The land promoted by EDBF at Fulbourn, Great Shelford and Stapleford, Landbeach, Milton, and Waterbeach are located within the Green Belt, but are sustainable in transport terms making them suitable locations for development. The land promoted by EDBF at these settlements could met the definition of grey belt land, making them suitable sites for the release of land from the Green Belt to meet development needs.

The Rural Centres and Minor Rural Centres are referred to as part of the development strategy but there are limited allocations in these categories of settlement. Group Villages have no role in the development strategy, and there are very limited allocations in this category of settlement. It is considered that the growth of the more sustainable villages should be part of the development strategy for draft GCLP, and particularly those villages that contain a very good range of services and facilities, are accessible by a range of modes of transport, and where there is an identified need for affordable housing for those with a local connection to the village. EDBF has promoted land for development at Fulbourn, Great Shelford and Stapleford, Landbeach, Milton, and Waterbeach, which are all sustainable locations for additional development.

Requested Change

The requested changes to the development strategy in Policy S/DS are as follows.

It is requested that the housing delivery assumptions for all of the strategic sites are reassessed, taking into account realistic annual housing delivery rates and the delivery of critical infrastructure required for those sites.

It is requested that land is released from the Green Belt to meet development needs.

It is requested that additional allocations are made in the more sustainable villages, including at Rural Centres, Minor Rural Centres, and Group Villages.

Requested Change

It is requested that a review is undertaken of the capacity of the more sustainable settlements in South Cambridgeshire, including Minor Rural Centres such as Fulbourn and Waterbeach and Group Villages such as Landbeach, to determine whether additional development can be accommodated within the existing development framework boundary, and whether the development threshold limits remain relevant if no sites are available. If the indicative maximum scheme size limits are no longer relevant they should be deleted.

If the capacity assessment identifies no suitable sites to meet identified affordable housing needs then additional allocations should be made on the edge of those villages.

Policy S/SH: Settlement Hierarchy

COMMENT

Policy S/SH of draft GCLP defines the settlement hierarchy. EDBF have promoted a number of sites for development for both housing and employment at Rural Centres, Minor Rural Centres and Group Villages, including at Fulbourn, Great Shelford and Stapleford, Landbeach, Milton, and Waterbeach. Great Shelford and Stapleford is defined as a Rural Centre, with no limits of the size of developments within the development extents of these villages. Fulbourn, Milton and Waterbeach are defined as Minor Rural Centres, which have an indicative maximum scheme size of 30 dwellings within the defined development extents of those villages. Landbeach is defined as a Group Village, which have an indicative maximum scheme size of 8 dwellings within the defined development extents of this village, or 15 dwellings on previously developed land.

EDBF agrees with the status of Fulbourn, Great Shelford and Stapleford, Landbeach, Milton, and Waterbeach in the settlement hierarchy, based on the range of services and facilities that these villages contain.

However, there has been no review of the capacity of settlements to accommodate additional development for draft GCLP, or whether the residential development threshold limits identified for Minor Rural Centres and Group Villages remain relevant if no sites are available. There appears to be limited opportunities for residential development within the development framework boundary of Fulbourn, Landbeach, and Waterbeach, and any development opportunities that do exist would be small scale and would not deliver affordable housing or provide any meaningful support to existing services and facilities. In these circumstances, the indicative maximum scheme size of 30 dwellings for Minor Rural Centres (as applies to Fulbourn and Waterbeach) and 8 dwellings for Group Villages (as applies to Landbeach) are irrelevant.

As set out in these representations, amendments should be made to the development strategy for draft GCLP, which directs development to the more sustainable villages to support existing services and facilities, deliver additional facilities, and meet identified affordable needs of villages.

Requested Change

It is requested that a review is undertaken of the capacity of the more sustainable settlements in South Cambridgeshire, including Minor Rural Centres such as Fulbourn and Waterbeach and Group Villages such as Landbeach, to determine whether additional development can be accommodated within the existing development framework boundary, and whether the development threshold limits remain relevant if no sites are available. If the indicative maximum scheme size limits are no longer relevant they should be deleted.

If the capacity assessment identifies no suitable sites to meet identified affordable housing needs then additional allocations should be made on the edge of those villages.

Policy S/DE: Defined Development Extents

COMMENT

Policy S/DE of draft GCLP set out the approach to development within and outside the defined development extents of villages. EDBF does not object to the principle of settlement boundaries being defined around villages. However, the existing defined settlement boundaries for most villages in South Cambridgeshire have remained largely unchanged since the Local Plan 2004. The settlement boundaries were adjusted in some cases to take into account allocations at some villages through the Site Specific Allocations DPD 2010 and the South Cambridgeshire Local Plan 2018.

EDBF have promoted a number of sites for development for both housing and employment at Rural Centres, Minor Rural Centres and Group Villages, including at Fulbourn, Great Shelford and Stapleford, Landbeach, Milton, and Waterbeach. The heritage assets (listed buildings and conservation areas), protected village amenity areas, local green space, and important countryside frontage designations will restrict the development opportunities within the settlement boundaries for these villages. The Green Belt will restrict development outside the settlement boundaries of these villages. Therefore, the currently defined development framework boundaries limit the opportunities for any development at these villages during the plan period for draft GCLP. As a result, the housing and affordable housing needs of these villages would not be met. There would be no support for existing services and facilities, or the delivery of additional facilities. Any community aspirations for open space, improvements to health facilities, and for additional green infrastructure would not be met.

It is acknowledged that draft GCLP has been prepared and will be examined against the February 2025 version of the NPPF, however the August 2026 version of the NPPF would be used to determine any future planning applications. The Glossary to the August 2026 NPPF defines settlements, which in part states: “Settlement: Includes cities, towns, villages and other predominantly built-up areas, including land which is allocated or has permission for development which will form part of the built-up area once the development is complete…”. There is land that is currently adjacent to Fulbourn that are occupied by buildings or where new residential development has been approved and is under construction, and as such would fall within the settlement definition e.g. land at Capital Park is an existing business park, and land at the former Ida Darwin Hospital site is being redevelopment for housing. It is considered that both of these sites should be included within the defined settlement boundaries; Capital Park within the settlement boundary of Cambridge and the former Id Darwin Hospital site within the settlement boundary of Fulbourn.

No changes are requested to Policy S/DE. However, as set out elsewhere in these representations, amendments should be made to the development strategy for draft GCLP, which directs development to the more sustainable villages, to support existing services and facilities, deliver additional facilities, and meets identified affordable needs of villages.

Requested Change

It is requested that Purpose 1c in Policy S/GB is amended to refer to towns and not communities. The amended text should be as follows: prevent towns in the environs of Cambridge from merging into one another and with the city.

Policy S/GB: The Cambridge Green Belt

NOT SOUND – NOT CONSISTENT WITH NATIONAL POLICY

OBJECT

Policy S/GB of draft GCLP sets out the Green Belt policy for Cambridge. Paragraph 143 of the NPPF sets out the five national purposes for Green Belts. The second purpose listed in Paragraph 143 states “b) to prevent neighbouring towns merging into one another;”. The third purpose for the Cambridge Green Belt in Policy S/GB states “1c. prevent communities in the environs of Cambridge from merging into one another and with the city”. Purpose 1c in Policy S/GB is inconsistent with the second purpose in NPPF Paragraph 143 i.e. it refers to communities and not towns. Consistency with national policy is one of the soundness tests for local plan policies. The reference to communities rather than towns could have implications for how inappropriate development in the Green Belt is assessed and the implementation of national grey belt policy at planning application stage in the future.

Paragraph 143 of the NPPF identifies the five purposes of the Green Belt. Paragraph 155 identifies land falling within the definition of grey belt as not inappropriate development in the Green Belt. The Glossary to the NPPF defines grey belt land as that which does not strongly contribute to the Green Belt purposes (a) - to check the unrestricted sprawl of large built-up areas, (b) - to prevent neighbouring towns merging into one another, and (d) - to preserve the setting and special character of historic towns. The national purposes of Green Belt relate to large built-up areas and towns, and not communities or villages. It is considered that Policy S/GB is ambiguous because it is inconsistent with Paragraphs 143 and 155 of the NPPF, which is likely to lead to confusion for decision-makers when applying national grey belt policy.

This matter is relevant for some of the sites promoted by EDBF, which the ‘Greater Cambridge Green Belt Assessment Review following changes to National Policy and Guidance’ Report (July 2026) identifies as potential grey belt land. The Report identifies the following sites as potential grey belt land: Land off Hinton Way, Stapleford; Land off Butt Lane, Milton - adjacent to Milton Park & Ride and the new Cambridgeshire Southern Police Station; Land off Glebe Road, Waterbeach; and Land off High Street, Landbeach.

Requested Change

It is requested that Purpose 1c in Policy S/GB is amended to refer to towns and not communities. The amended text should be as follows: prevent towns in the environs of Cambridge from merging into one another and with the city.

Requested Change

It is requested that land off Glebe Road in Waterbeach is allocated with the following policy requirements:

• Site Area of 5.29 Ha
• Capacity for approx. 160 dwellings, including affordable housing
• Retain trees and hedgerows at site boundary
• Provide new strategic landscape buffer at western boundary
• Provide green infrastructure and open space
• Include land for the proposed route of the Waterbeach Greenway

Policy S/RRA: Additional Allocation – Land off Glebe Road, Waterbeach (Site Ref. 40372)

NOT SOUND – NOT JUSTIFIED AND NOT CONSISTENT WITH NATIONAL POLICY

OBJECT

As set out elsewhere in these representations, it is considered that upward adjustments are required to the housing target, the development strategy should direct development to the more sustainable villages, and there are exceptional circumstances to release land from the Green Belt. All these factors indicate that additional allocations should be made in draft GCLP to meet development needs.

EDBF has promoted land off Glebe Road in Waterbeach for residential development. It is noted that the landowner of the adjacent land to the north has also promoted their land for residential development. A comprehensive development incorporating both sites could be delivered if they were allocated in draft GCLP. The route of proposed Waterbeach Greenway, a walking and cycling improvement project, includes routes from Denny End Road to Car Dyke Road through land owned by EDBF. A comprehensive development of both sites could support the delivery of this section of the Waterbeach Greenway.

The site assessment in the updated HELAA has identified mostly ‘green’ and ‘amber’ scores in terms of the suitability of the site to accommodate development. A ‘red’ score is identified for landscape impacts. It is considered that the site is relatively well contained in landscape terms, with an employment area to the north, residential areas to the south and east, and the A10 to the west. The promoted development would include landscaping and green infrastructure at the western boundary. The promoted development at the site would have no adverse impact on the compactness or setting of Cambridge and it would not lead to the merging of towns. The site makes a limited contribution to the purposes for including land within the Green Belt. It is considered that this site would fall within the definition of grey belt land i.e. it does not make a strong contribution to purposes (a), (b) or (d) of the Green Belt. The ‘Greater Cambridge Green Belt Assessment Review following changes to National Policy and Guidance’ Report (July 2026) identified all of the land between the A10 and the western edge of Waterbeach including land off Glebe Road as potential grey belt land. The promoted development would include open space and green infrastructure. The existing allotments could be re-provided elsewhere within the site.

The site is accessible to the services and facilities in Waterbeach by walking and cycling, and it is accessible to Cambridge and to employment opportunities by rail, bus and by bicycle. There is a railway station in Waterbeach, with services to Ely, Peterborough and Cambridge. The proposed Waterbeach to Cambridge Busway project and the proposed Waterbeach Greenway would deliver sustainable transport improvements in the near future. Waterbeach New Town would provide additional services and facilities and employment opportunities, which would be accessible from the site.

A flood risk assessment and drainage strategy, transport assessment, landscape appraisal, and ecological assessment would be prepared for the promoted development at planning application stage.

It is requested that this site is identified as an additional allocation in Policy S/RRA: Rest of Rural Area.

Requested Change

It is requested that land off Glebe Road in Waterbeach is allocated with the following policy requirements:

• Site Area of 5.29 Ha
• Capacity for approx. 160 dwellings, including affordable housing
• Retain trees and hedgerows at site boundary
• Provide new strategic landscape buffer at western boundary
• Provide green infrastructure and open space
• Include land for the proposed route of the Waterbeach Greenway

Requested Change

It is requested that land south of Fulbourn Old Drift, Fulbourn is allocated with the following policy requirements:

• Site Area of 10.88 Ha
• Development for employment uses
• Floor space and development capacity to be informed by landscape assessment
• Retain trees and hedgerows at site boundary
• Provide new strategic landscape buffer at eastern and southern boundaries
• Provide green infrastructure and open space

Policy S/RRA: Additional Allocation - Land south of Fulbourn Old Drift, Fulbourn (Site Ref. 40355)

NOT SOUND – NOT JUSTIFIED AND NOT CONSISTENT WITH NATIONAL POLICY

OBJECT

The land promoted by EDBF at land south of Fulbourn Old Drift is located adjacent to Capital Park, and is promoted for additional employment uses similar to those at Capital Park.

The assessment of the site in the updated HELAA has identified mostly ‘green’ and ‘amber’ scores in terms of the suitability of the site to accommodate development. A ‘red’ score is identified for landscape impacts. The promoted development would include strategic landscaping at the site boundary to reduce the impacts on the surrounding landscape; a similar approach is adopted at Capital Park. The site is located on the edge of Cambridge, and residential development is being delivered on land to the north at the former Ida Darwin Hospital site. There are regular bus services to Cambridge and Fulbourn, with bus stops on Fulbourn Old Drift and Cambridge Road close to the site. The Greater Cambridge Partnership is delivering a greenway (walking and cycling route) between Fulbourn and Cambridge. The site is a sustainable location for development in transport terms.

A flood risk assessment and drainage strategy, transport statement, landscape and visual impact assessment and landscape strategy, and ecological assessment would be prepared for the promoted development at planning application stage.

It is requested that this site is identified as an additional employment allocation in Policy S/RRA: Rest of Rural Area.

Requested Change

It is requested that land south of Fulbourn Old Drift, Fulbourn is allocated with the following policy requirements:

• Site Area of 10.88 Ha
• Development for employment uses
• Floor space and development capacity to be informed by landscape assessment
• Retain trees and hedgerows at site boundary
• Provide new strategic landscape buffer at eastern and southern boundaries
• Provide green infrastructure and open space

Requested Change

It is requested that land south of Cambridge Road and north of Shelford Road in Fulbourn is allocated with the following policy requirements:

• Site Area of c.18 Ha
• Capacity to be determined by heritage and landscape assessments
• Development for housing, including affordable housing and self/custom build plots
• Design of development to preserve key views and setting of the listed Windmill (Grade II)
• Retain trees and hedgerows at site boundary
• Provide new strategic landscape buffer at eastern boundary
• Provide open space and green infrastructure

Policy S/RRA: Additional Allocation - Land south of Cambridge Road and north of Shelford Road, Fulbourn (Site Ref. 40354)

NOT SOUND – NOT JUSTIFIED AND NOT CONSISTENT WITH NATIONAL POLICY

OBJECT

As set out elsewhere in these representations, it is considered that upward adjustments are required to the housing target, the development strategy should direct development to the more sustainable villages, and there are exceptional circumstances to release land from the Green Belt. All these factors indicate that additional allocations should be made in draft GCLP to meet development needs.

EDBF has promoted all of the land that it owns to the south of Cambridge Road and north of Shelford Road at Fulbourn (c.76 Ha), but the promoted development would be limited to the eastern field land immediately adjacent to Fulbourn (c.18 Ha). This approach would have less impact on the surrounding landscape and the heritage asset at the listed Windmill (Grade II). The promoted development would include landscaping and green infrastructure at the western boundary, which would provide a more attractive and defensible edge to Fulbourn in this location. The promoted development at the site would have no adverse impact on the compactness or setting of Cambridge and it would not lead to the merging of towns. The site makes a limited contribution to the purposes for including land within the Green Belt. The updated assessment of the site in the HELAA identified no other constraints to development.

There are regular bus services from Fulbourn to Cambridge. The Greater Cambridge Partnership is delivering a greenway (walking and cycling route) between Fulbourn and Cambridge. The site is a sustainable location for development in transport terms.

The promoted development could deliver additional services and facilities for Fulbourn.

It is requested that this site is identified as an additional allocation in Policy S/RRA: Rest of Rural Area.

Requested Change

It is requested that land south of Cambridge Road and north of Shelford Road in Fulbourn is allocated with the following policy requirements:

• Site Area of c.18 Ha
• Capacity to be determined by heritage and landscape assessments
• Development for housing, including affordable housing and self/custom build plots
• Design of development to preserve key views and setting of the listed Windmill (Grade II)
• Retain trees and hedgerows at site boundary
• Provide new strategic landscape buffer at eastern boundary
• Provide open space and green infrastructure