Greater Cambridge Local Plan: Proposed Submission

Vision for Greater Cambridge

COMMENT

Hill Residential Ltd (Hill) supports the overarching Vision for Greater Cambridge in the Reg.19 Proposed Submission Greater Cambridge Local Plan (draft GCLP), which seeks to improve quality of life, minimise carbon emissions, reduce car use, deliver homes and jobs, support infrastructure and enhance green spaces.

However, Hill remains concerned that the proposed housing requirement, development strategy and site allocations in the draft GCLP will not fully deliver this Vision. The housing target is not aligned with forecast jobs growth, increasing the likelihood of in-commuting and car-based travel. This undermines both climate and quality of life objectives. Hill made these comments at Reg.18 stage. Those previous concerns have not been taken into account, which means that the Vision will still not be delivered.

The strategy is heavily focused on large strategic sites and new settlements, many of which are reliant on uncertain infrastructure funding and optimistic build-out assumptions. By contrast, the draft GCLP fails to direct development to sustainable villages such as Hardwick, where Hill have promoted a site (Site Ref. 40414), which have existing services, good public transport accessibility, and identified local housing needs. The recently approved Cambourne to Cambridge Busway, located to the north of, and directly accessible from, the promoted site, further increases the transport related sustainability credentials of the site and Hardwick.

The Vision would be better realised through a higher housing requirement, a more balanced and resilient development strategy, and additional growth at the more sustainable villages.

Strategic Priorities

COMMENT

The draft GCLP identifies strategic priorities relating to climate change, biodiversity, wellbeing, place-making, jobs, homes, and infrastructure. As drafted, Hill remains concerned that these priorities are unlikely to be achieved given the preferred housing target, development strategy, and selected allocations.

The misalignment between the jobs and housing targets risks increased commuting and carbon emissions, which would be contrary to climate objectives. There is an over reliance on large strategic sites, which creates risks for housing delivery and has historically resulted in reduced affordable housing outputs, and undermines the homes priority. Hill made similar comments at Reg.18 stage, but no changes to policies have been made, which means that the strategic priorities will still not be delivered.

The exclusion of sustainable villages such as Hardwick from the development strategy weakens the place-making, connectivity and the viability of local services priorities. The development strategy and settlement hierarchy in draft GCLP ignores the fact that some villages in Greater Cambridge, such as Hardwick, are well-related to the employment and services on the edge of Cambridge and are accessible by planned transport projects including the approved Cambourne to Cambridge Busway and the Comberton Greenway.

A more flexible approach would have allocated sites in these more sustainable villages. The settlement hierarchy is too rigidly applied, with the result that the development potential at highly accessible and sustainable locations, such as Hardwick, is overlooked. In addition, several of the proposed green infrastructure opportunity areas are not aligned with development that could support their delivery, which undermines the biodiversity and green spaces priority.

An increased housing requirement and a revised strategy that includes growth in sustainable villages such as Hardwick would better support the strategic priorities of draft GCLP.

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 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 in close proximity to transport infrastructure, including Hardwick.

Policy S/JH: New Jobs and Homes

NOT SOUND – NOT JUSTIFIED AND NOT CONSISTENT WITH NATIONAL POLICY

OBJECT

Policy S/JH proposes provision for 73,300 jobs and a minimum of 48,069 dwellings over the plan period, derived solely from the standard method for calculating housing need. This represents a minimum figure of 2,289 dwellings per annum, marginally reduced since the Reg. 18 consultation in January 2026. In our view, this remains inconsistent with national policy as it does not include upward adjustments to reflect Greater Cambridge’s economic growth ambitions, commuting patterns or affordable housing needs. Hill and others raised the same concerns about Policy S/JH at Reg.18 stage, but those concerns have been ignored.

The 2023 Greater Cambridge Employment and Housing Evidence Update applied a 1:1 commuting adjustment to better align jobs and housing. This approach has been omitted from the 2025 Employment and Housing Needs Update without adequate justification, resulting in a clear imbalance between jobs and homes. Hill made the same comment at Reg.18 stage. The Review of Economic Data, Context and Representations Report 2026 does not explain why the previous commuting patterns adjustment is no longer included. The housing target should be recalculated to include the previous commuting patterns adjustment, which is an approach that would be consistent with national policy to limit the need to travel.

National policy allows (and in some circumstances expects) housing requirements to exceed the standard method where this supports economic growth or affordable housing delivery. The Greater Cambridge City Deal, the Cambridgeshire and Peterborough Devolution Deal and the Mayor’s adopted Local Growth Plan all point to ambitious growth objectives which require increased housing provision. The recently established Greater Cambridge Development Corporation will seek to maximise Cambridge’s full economic potential and to deliver nationally significant growth. These growth ambitions for Greater Cambridge support an upward adjustment to the housing target.

The 2025 Housing Needs of Specific Groups Report identifies a substantial affordable housing shortfall across Greater Cambridge. Average annual delivery falls well below identified need, and strategic sites have consistently under-delivered affordable housing due to infrastructure costs. The delivery of affordable housing is distinct from housing affordability, which is a separate factor already included in the national housing figures. The housing target in Policy S/JH should include some upward adjustment to address affordable housing needs.

The Sustainability Appraisal assesses only the preferred housing target and fails to test reasonable alternatives, including a higher housing requirement that aligns with jobs growth and affordable housing need.

As currently drafted, in our view the housing target in Policy S/JH would be unsound. It would not be justified because it does not assess all reasonable alternatives. It would not be effective because it is not deliverable. It would not be consistent with national policy because appropriate adjustments to the standard method figure are not made.

Requested Change

Recalculate the housing requirement to include a commuting patterns adjustment consistent with the 2023 evidence base.

Apply upward adjustments to reflect economic growth ambitions and identified affordable housing needs.

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 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 in close proximity to transport infrastructure, including Hardwick.

Policy S/DS: Development Strategy

NOT SOUND – NOT JUSTIFIED AND NOT CONSISTENT WITH NATIONAL POLICY

OBJECT

Policy S/DS of the draft GCLP sets out the development strategy. In summary, as highlighted previously at Reg.18 stage, the development strategy relies heavily on large strategic sites, new settlements and windfall development. Those previous concerns about the soundness of draft GCLP have not been taken into account. We maintain therefore, that Policy S/DS is not positively prepared, justified, effective or consistent with national policy. Our representations to the Reg.18 stage have not been adequately considered. Accordingly, we reaffirm our concerns below.
Approximately 44% of housing delivery is expected from new settlements, based on optimistic assumptions regarding delivery rates and infrastructure provision.
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 the draft GCLP.
The development strategy also assumes a significant amount of housing from windfall sites that are currently unknown and where delivery is uncertain. It is not certain that past windfall delivery rates will be achieved in the future. It is not clear where windfall sites will be delivered. There would be greater certainty about housing delivery if additional sites were allocated. This approach would provide more control to the Councils.
Given the above, there are several risks associated with the development strategy in Policy S/DS. It is very reliant on the delivery of the existing strategic sites. Whilst Hill supports the development of strategic sites and is keen to see efforts maximised to bring these forward, there is no evidence that delivery at these sites will increase above current rates, particularly given challenging market conditions and absorption rates. The draft GCLP assumes 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.
Furthermore, the delivery of the proposed strategic sites at Cambourne North and at Grange Farm is reliant on the delivery of transport projects that are not approved at the time of the Regulation 19 consultation, and where funding and delivery timescales are uncertain. In contrast, the Cambourne to Cambridge Busway has recently been approved, and there is funding to deliver this transport project. Hardwick will sit at the midway point on the Busway, whilst the promoted site itself is to be located close to future bus stops. The settlement will therefore have a functional relationship with the Busway, which will provide sustainable opportunities for additional growth.
If the strategic sites do not deliver as predicted, this will lead to a housing land supply shortfall and the presumption in favour of sustainable development being applied to planning applications for housing. In these circumstances, the Councils will lose control of when and where housing is delivered. It is therefore requested that the housing delivery assumptions for all the strategic sites are reassessed. It is likely that when delivery assumptions are reassessed additional allocations will need to be identified in draft GCLP to meet the housing target. By ignoring settlements in close proximity to committed transport infrastructure, the plan is missing an opportunity to deliver sustainable growth in well connected locations.
Affordable housing delivery at existing and proposed strategic sites has been consistently below policy requirements, which is a pattern that is likely to continue at Cambourne North and Grange Farm, at least initially given the scale of upfront costs associated with delivering large sites. 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. Hill raised the same concerns about the delivery of affordable housing at Reg.18 stage. In contrast the promoted development at land east of Cambridge Road in Hardwick would provide policy compliant levels of affordable housing, which for a Green Belt release site would be 50%. Added to which the promoted site can be delivered in the early part of the plan period whilst the larger, more complicated strategic sites are being prepared.
It is anticipated in the draft GCLP that approximately 6,660 dwellings would be delivered from windfall sites. The assumption about windfalls lack certainty, particularly given constrained settlement boundaries that are not being amended. There would be greater certainty about housing delivery if additional sites were allocated in the draft GCLP, including at the more sustainable villages such as Hardwick, rather than from unknown and uncertain windfall sites.
Paragraph 145 of the NPPF allows Green Belt boundaries to be altered through the plan-making process provided exceptional circumstances exist. It is considered that exceptional circumstances exist to release land from the Green Belt given the significant need for housing and affordable housing in Greater Cambridge, the need to support economic growth, and the overarching requirement to direct development to sustainable locations.
As set out in the representations to Policy S/JH, the housing target for the draft GCLP should be subject to upward adjustments to support economic growth and affordable housing delivery. Furthermore, the delivery of housing at the strategic allocations would potentially be lower than currently predicted, leading to a shortfall against the housing target.
For all these reasons land should be released from the Green Belt in the draft GCLP. Paragraph 148 of the NPPF seeks to ensure that when land is released from the Green Belt the priority is for previously developed land, followed by grey belt, and then other Green Belt locations.


Hill has promoted land east of Cambridge Road in Hardwick (Site Ref. 40414) for a mixed-use development including residential, employment, retail, health services, community uses, and open space and green infrastructure, including a country park. There are limited upfront infrastructure costs and no land assembly is required for the promoted development, which means it can be delivered in the early part of the plan period and while the strategic sites are being planned.
It is accessible by a range of modes of transport, including bus services from St Neots Road. It is directly adjacent to the approved Cambourne to Cambridge Busway. The existing bus stop locations on St Neots Road would be retained for the Busway and are in close proximity to the promoted site. The Cambourne to Cambridge Busway has the added benefit of connecting with a proposed railway station at Cambourne on the East West Rail project. The approved Busway will therefore significantly increase the connectivity of Hardwick. This represents a clear opportunity to deliver sustainable growth at Hardwick on a well-connected site, which will in turn support this new piece of transport infrastructure.
The proposed Comberton Greenway (for walking and cycling) includes a route from Main Street in Hardwick that would provide connections to the University’s West Cambridge site and into Cambridge City Centre. There is an identified need for affordable housing in Hardwick for those with a local connection to the village.
For the reasons set out above, and as detailed in the March 2025 update to the call for sites submission, the site to the east of Hardwick (Site Ref: 40414) is considered to meet the definition of grey belt land and the promoted development would be capable of meeting the ‘Golden Rules’ as stipulated by Paragraph 157 of the NPPF. Sites such as Hardwick should therefore play a role in the wider Development Strategy for Greater Cambridge in line with Paragraph 148 of the NPPF.
As currently drafted, the development strategy in Policy S/DS would be unsound. It is not effective because it is not deliverable. It is not consistent with national policy because it is not sustainable, it does not meet development needs, it does not assess grey belt land, and it does not release land from the Green Belt to meet development needs.
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 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 in close proximity to transport infrastructure, including Hardwick.

Requested Change

Recalculate the housing requirement to include a commuting patterns adjustment consistent with the 2023 evidence base.
Apply upward adjustments to reflect economic growth ambitions and identified affordable housing needs.

Policy S/JH: New Jobs and Homes

NOT SOUND – NOT JUSTIFIED AND NOT CONSISTENT WITH NATIONAL POLICY

OBJECT

Policy S/JH proposes provision for 73,300 jobs and a minimum of 48,069 dwellings over the plan period, derived solely from the standard method for calculating housing need. This represents a minimum figure of 2,289 dwellings per annum, marginally reduced since the Reg. 18 consultation in January 2026. In our view, this remains inconsistent with national policy as it does not include upward adjustments to reflect Greater Cambridge’s economic growth ambitions, commuting patterns or affordable housing needs. Hill and others raised the same concerns about Policy S/JH at Reg.18 stage, but those concerns have been ignored.
The 2023 Greater Cambridge Employment and Housing Evidence Update applied a 1:1 commuting adjustment to better align jobs and housing. This approach has been omitted from the 2025 Employment and Housing Needs Update without adequate justification, resulting in a clear imbalance between jobs and homes. Hill made the same comment at Reg.18 stage. The Review of Economic Data, Context and Representations Report 2026 does not explain why the previous commuting patterns adjustment is no longer included. The housing target should be recalculated to include the previous commuting patterns adjustment, which is an approach that would be consistent with national policy to limit the need to travel.
National policy allows (and in some circumstances expects) housing requirements to exceed the standard method where this supports economic growth or affordable housing delivery. The Greater Cambridge City Deal, the Cambridgeshire and Peterborough Devolution Deal and the Mayor’s adopted Local Growth Plan all point to ambitious growth objectives which require increased housing provision. The recently established Greater Cambridge Development Corporation will seek to maximise Cambridge’s full economic potential and to deliver nationally significant growth. These growth ambitions for Greater Cambridge support an upward adjustment to the housing target.
The 2025 Housing Needs of Specific Groups Report identifies a substantial affordable housing shortfall across Greater Cambridge. Average annual delivery falls well below identified need, and strategic sites have consistently under-delivered affordable housing due to infrastructure costs. The delivery of affordable housing is distinct from housing affordability, which is a separate factor already included in the national housing figures. The housing target in Policy S/JH should include some upward adjustment to address affordable housing needs.
The Sustainability Appraisal assesses only the preferred housing target and fails to test reasonable alternatives, including a higher housing requirement that aligns with jobs growth and affordable housing need.
As currently drafted, in our view the housing target in Policy S/JH would be unsound. It would not be justified because it does not assess all reasonable alternatives. It would not be effective because it is not deliverable. It would not be consistent with national policy because appropriate adjustments to the standard method figure are not made.
Requested Change

Recalculate the housing requirement to include a commuting patterns adjustment consistent with the 2023 evidence base.
Apply upward adjustments to reflect economic growth ambitions and identified affordable housing needs.

Requested Change

It is requested that a review is undertaken of the capacity of the more sustainable settlements in South Cambridgeshire, including Group Villages such as Hardwick, 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 the draft GCLP defines the settlement hierarchy. Hardwick, where Hill have promoted Site Ref. 40414 for residential development, is defined as a Group Village. Group Villages have an indicative maximum scheme size of 8 dwellings within the defined development extents of those villages, or a maximum of 15 dwellings on previously developed land.
Hardwick contains a good range of services and facilities including a primary school and nursery, small convenience store with a post office, village hall, restaurant, a range of small businesses, and an outdoor sport and recreation area. It is currently accessible by a range of modes of transport, including bus services from St Neots Road. It is on the route for the Cambourne to Cambridge Busway, which will include bus stops within the site now being promoted, on St Neots Road. The Cambourne to Cambridge Busway would connect with a proposed railway station at Cambourne on the East West Rail project. The proposed Comberton Greenway (for walking and cycling) includes a route from Main Street in Hardwick that would provide connections to the University’s Cambridge West site and into Cambridge City Centre. Hardwick is therefore a highly sustainable location, capable of supporting further development with accessible public transport links to Cambridge.
Whilst it is not directly contested that Hardwick is defined as a Group Village, it is apparent that there has been no review of the capacity of the settlement to accommodate additional development during the forthcoming plan period, or whether the development threshold limit remains relevant to Hardwick if no sites are available within the existing defined development extent. Hill raised this same concern at Reg.18 stage.
The development strategy and settlement hierarchy in draft GCLP ignores the fact that some villages in Greater Cambridge, such as Hardwick, are well-related to the employment and services on the edge of Cambridge and are accessible by planned transport projects including the approved Cambourne to Cambridge Busway and the Comberton Greenway. A more flexible approach would have allocated sites in these more sustainable villages.
The more recent housing developments in the village are located outside of the development framework boundary and exceed the maximum scheme size limit for this category of village. There appears to be no major residential development opportunities within the development framework boundary of Hardwick, 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 8 dwellings for Group Village is irrelevant to Hardwick.
As set out in these representations, amendments should be made to the development strategy for the draft GCLP, which directs development to the more sustainable villages including Hardwick 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 Group Villages such as Hardwick, 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 sets out the approach to development within and outside the defined development extents of villages. Hill 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, including Hardwick, have remained largely unchanged since the Local Plan 2004 (with the exception of some allocations made via the Site Specific Allocations DPD in 2010 and the subsequent Local Plan in 2018). In Hardwick, heritage assets, protected village amenity areas, and important countryside frontage designations restrict development opportunities within the settlement boundary, and the Green Belt restricts development outside the settlement boundary.
The currently defined development framework boundary for Hardwick means that limited development would take place in this village. The housing and affordable housing needs would not be met. There would be no support for existing services and facilities, or the delivery of improved and additional facilities for the benefit of existing and future residents. Hill made the same comments at Reg.18 stage.
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 the draft GCLP, which allocates land for development at the more sustainable villages including Hardwick to support existing services and facilities, deliver additional facilities, and to meet 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 the draft GCLP sets out the Green Belt policy for Cambridge.
Purpose 1c in Policy S/GB is inconsistent with the second purpose in NPPF Paragraph 143 in that 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 Green Belt and grey belt policy is applied for applications in the future. Hill raised the same concern at Reg.18 stage, but Policy S/GB has not been changed in the draft GCLP.
In addition, as outlined in the March 2025 update to the call for sites submission, it is considered that the land east of Cambridge Road in Hardwick (Site Ref. 40414) would meet the definition for grey belt land, as set out in Chapter 13 and Annex 2 of the NPPF and in Section Id.64: Green Belts of the Planning Practice Guidance. Hill notes the findings at paragraphs 2.85 to 2.91 of the ‘Greater Cambridge Green Belt Assessment - Response to comments from Site Submissions Update and Draft Local Plan Consultation prepared by LUC, June 2026’ but disagrees with the assessment. For the reasons set out in the Green Belt Review prepared on behalf of Hill by Tor & Co, March 2025, the site does not strongly contribute towards Green Belt purposes (a), (b), or (d). Given the nature of the promoted site, its relationship with the existing village and degree of physical separation from Cambridge, development would not lead to the unrestricted sprawl of a large built-up area, it would not result in the coalescence of neighbouring towns, and it would not affect the setting and special character of a historic town (which seems to be the main area of reliance for rejecting the site in the LUC report). Hill respectfully disagree with the findings of the LUC report for the reasons set out in the earlier Tor report. The site is not designated as a protected area, other than being within the Green Belt.
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 at east of Cambridge Road in Hardwick is allocated with the following policy requirements:
• Site Area of 26.8 Ha
• Capacity for approx. 400 dwellings, including affordable housing
• 1,500sqm of employment floor space
• Local centre to include retail, community and health services
• Provide country park
• Provide strategic landscaping at eastern and southern boundaries

Policy S/RRA: Additional Allocation - Land east of Cambridge Road, Hardwick (Site Ref. 40414)

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 wider 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 the draft GCLP to meet development needs.
Hill has promoted land east of Cambridge Road in Hardwick (Site Ref. 40414) for a mixed-used development including residential development since 2019. Hill has engaged with all stages of the emerging GCLP process, has discussed the site with the Parish Council, and undertaken public consultation events.
The assessment of the site in the updated HELAA identified ‘green’ and ‘amber’ scores for most site suitability criteria. The assessment identified ‘red’ scores for landscape and archaeology.
As highlighted previously, an updated Landscape and Visual Appraisal was included with the updated call for sites submission in March 2025. The Appraisal shows that the local pattern of topography, vegetation and development limit the extent to which the site is visible in the landscape.
The site itself is not covered by any form of landscape designation. The views of the site are largely restricted to locations within 1km of the site boundary. The pattern of landform, the landscape structure, and the viewing distance, significantly reduces the degree of visual effect in available views from the wider landscape. The Appraisal identifies mitigation measures for the promoted development to reduce the impact on the existing landscape. These measures include a new landscape edge on the eastern and southern boundaries, which could consist of a country park, parkland trees, woodland structure planting, and grassland. Along with the retention of the majority of field boundary vegetations, these measures will retain the open nature of the landscape.
It is concluded in the Appraisal that with effective mitigation, there is no overriding landscape or visual effect that should preclude development of the site.
The updated comments on archaeology in the HELAA refer to an extensive settlement of Iron Age date, and that further information is required to determine the suitability of this site for development. A review of the updated comments has been undertaken by GHC Archaeology and Heritage to assess the appropriate score for archaeology. The letter from GHC Archaeology and Heritage was submitted with previous representations. It is concluded in the letter that the results of the geophysical survey and trial trench evaluation are largely consistent with the initial assessment but provide a greater understanding of the date of the remains. The identified archaeology is of interest but is not exceptional for the locality in terms of date, preservation or potential to add to regional research objectives. The archaeological remains could be subject to excavation and recording prior to development, if preservation in situ is not possible or desirable. The score for archaeology has been revised in the updated HELAA back to the original finding of ‘amber’ i.e. impact can be mitigated, which is agreed.
An updated Green Belt Assessment was included with the updated call for sites submission in March 2025. It was concluded in the updated Assessment that the site does not contribute to the Cambridge Green Belt purpose 1 (preserve the unique character of Cambridge as a compact, dynamic city with a thriving historic centre), and it makes a relatively limited contribution to purpose 2 (maintain and enhance the quality of its setting) and purpose 3 (prevent communities in the environs of Cambridge from merging into one another and with the city). Therefore, the site makes a limited contribution to the Green Belt purposes and could be released to meet development needs. Furthermore, if the site does not strongly contribute towards Green Belt purposes (a - to check the unrestricted sprawl of large built-up areas), (b - to prevent neighbouring towns merging into one another), or (d - to preserve the setting and special character of historic towns) it would fall within the definition of grey belt land. As outlined elsewhere in our representations, we respectfully disagree with the findings at paragraphs 2.85 to 2.91 of the ‘Greater Cambridge Green Belt Assessment - Response to comments from Site Submissions Update and Draft Local Plan Consultation prepared by LUC, June 2026’. The assessment appears flawed and to fundamentally rely upon an approach that predates Government clarifications regarding the status of settlements and how matters of setting and coalescence should be considered.
As required by Paragraph 156 of the NPPF, land released from the Cambridge Green Belt would be required to provide 50% affordable housing. The promoted development can deliver the required amount of affordable housing.
Hardwick contains a good range of services and facilities. The promoted development would deliver additional facilities, including a local centre, community facilities, open space and a country park. The local centre could accommodate health services (doctor’s surgery, pharmacy, dentist), which would meet the aspirations of Hardwick Parish Council for these services to be provided within the village.
The site is currently accessible by a range of modes of transport, including bus services from St Neots Road. The approved Cambourne to Cambridge Busway and the Comberton Greenway would make Hardwick more accessible by sustainable modes of transport in the near future. The promoted site is directly adjacent to the Busway, and the bus stops for the Busway on St Neots Road are in close proximity of the site.
The site is in a single ownership, and land assembly is not required in advance of development. Hill are a trusted house builder with a strong track record of delivering successful developments in Hardwick and the wider Cambridgeshire area. Their involvement is further evidence of the site’s deliverability. There is limited land remediation required at the site. There is limited upfront infrastructure required for the promoted development. The promoted development would deliver affordable housing.
All these factors mean that the promoted development could be delivered quickly, and in the short to medium term. The delivery of such sites would help to maintain a sufficient and robust housing land supply in Greater Cambridge until the larger strategic sites start to deliver.
It is requested that the land east of Cambridge Road in Hardwick (Site Ref. 40414) is identified as an additional allocation in Policy S/RRA: Rest of Rural Area. Hill made this same request at Reg.18 stage.

Requested Change
It is requested that land at east of Cambridge Road in Hardwick is allocated with the following policy requirements:
• Site Area of 26.8 Ha
• Capacity for approx. 400 dwellings, including affordable housing
• 1,500sqm of employment floor space
• Local centre to include retail, community and health services
• Provide country park
• Provide strategic landscaping at eastern and southern boundaries

Policy BG/GI: Green and Blue Infrastructure

COMMENT

Hill supports the objectives of Policies BG/GI, WS/NC and I/ST. However, delivery of green infrastructure and community facilities in and around Hardwick is unlikely without associated development.
Hill has promoted land east of Cambridge Road in Hardwick for a mixed-use development. Policy BG/GI identifies a green infrastructure strategic initiative at No.7 West Cambridge GI Buffer – Coton Corridor, which is located to the east of Hardwick and to the M11 corridor on the western edge of Cambridge. The site promoted by Hill would be adjacent to this green infrastructure strategic initiative and would provide a country park including green infrastructure if this site was allocated in the draft GCLP.
It should be noted that there are no allocations identified in the draft GCLP for Hardwick or the other villages to the west of Cambridge that could make financial contributions towards the proposed green infrastructure strategic initiative at No.7 West Cambridge GI Buffer – Coton Corridor. It is not clear how this initiative would be delivered effectively in the absence of related development. Hill raised the same concern at Reg.18 stage, but no changes have been made in the draft GCLP.
No changes are requested to Policy BG/GI. However, as set out elsewhere in these representations, amendments should be made to the development strategy for the draft GCLP, which directs development to the more sustainable villages including Hardwick. This approach could support the delivery of green infrastructure at Hardwick and contribute towards the green infrastructure strategic initiative at No.7 West Cambridge GI Buffer – Coton Corridor.