Greater Cambridge Local Plan: Proposed Submission

Modifications are required to the plan to address these concerns through the allocation of land at Mingle Lane. [see attachments]

Whilst the development strategy identifies a number of strategic sites it fails to identify growth in sustainable settlements, such as Great Shelford, in terms of sites
of a less strategic scale which are required for existing and future housing needs across many communities within the plan area. If any slippage occurs on these strategic sites, then it jeopardises the Councils’ ability to demonstrate a flexible and responsive supply of housing land over the duration of the plan period. Indeed, it is not considered that the Council is currently able to demonstrate a housing land supply at present.

6.1.3 Accordingly, modifications are required to the plan to address these concerns through the allocation of land at Mingle Lane.

4.3.1 Policy S/JH seeks to meet the objectively assessed needs in Greater Cambridge over the plan period 2024 – 2045 through the provision of a minimum 48,069 new homes meeting the needs for the total population, including affordable housing and specialist accommodation of specific groups. This equates to an annual need of 2,289 dwellings. This is a slight reduction in housing numbers by -126 dwellings from the previous Regulation 18 consultation.
4.3.2 There are no exceptional circumstances that would warrant a different approach other than the standard method being used as a starting point to determine the housing requirement for Greater Cambridge. However, these should be seen as the minimum housing requirement to plan for. In this regard, the jobs target is 73,300 additional jobs represents a centralist point of view which only matches jobs growth associated with the standard method figure based on a single baseline assessment using CE data.
Need for economic uplift
4.3.3 Iceni Projects undertook an Employment and Housing Needs update in 2025 which factors in a central and high level employment growth assumption comparable to the number of homes required. The Central Growth assumption requires the delivery of 2,292dpa and is broadly akin to the housing figure required by the Standard Method. It also provided forecasting for a Higher Growth scenario which suggested a requisite housing figure of 2,829dpa is required.
4.3.4 Whilst the report does caveat that the higher growth scenarios tested require continuous expansion with limited or no shocks or cyclical periods of growth, it does suggest that these could be achieved or exceeded, but it would require a step change in infrastructure investment, notably through transport infrastructure as well as wider services infrastructure.
4.3.5 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 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.
4.3.6 The Government is committed to the continued economic expansion and recognises it as a central component of the UK’s economy’s overall success with a particular focus on the devolution agenda and commitments made to significant infrastructure schemes such as A14 upgrade and East West Rail together with investment in research and development. On 23rd July 2026, the Government established the Greater Cambridge Development Corporation which will set out an ambitious plan for long-term sustainable growth in Greater Cambridge by coordinating the delivery of infrastructure, investment and strategic development.
4.3.7 Whilst it is accepted that the Local Plan will not be tested against the latest iteration of the Framework, Policy HO2 (3b) is clear that housing requirement figures should be higher than the overall figure identified in the local housing needs assessment where appropriate. This includes where a higher housing requirement is necessary to meet the needs of neighbouring areas, or to reflect growth ambitions linked to economic development or infrastructure investment.
4.3.8 The report prepared by Turley at set out at Appendix 1 demonstrates inadequacy of the Councils’ evidence base using a single baseline forecasting assumption. Paragraph 8 of the report identifies that it is entirely reasonable to note that OE envisage up to 8,480 jobs being created annually from 2023 – 2050, with at least 5,370 annual jobs even in the low scenario. The draft plan’s target of only 3,500 job per annum over a shorter period is pessimistic and out of kilter with the growth aspirations for Cambridge. Further, without increasing employment land there is likely to be an increase of private vehicles where some 84% of those community more than 10km to work in Greater Cambridge by car, compared to only 46% of those travelling shorter distances.
4.3.9 The report concludes that planning more positively for at least 2,828 homes per annum should help to improve the ability of housing stock aligned with economic growth and this should be retested through the evidence base.
4.3.10 Taking the Government’s commitment to the role that Greater Cambridgeshire will play in terms of both local and national economic growth it is considered that the plan’s aspirations fail to take account of the need to increase the housing requirement to support economic growth aspirations and should be reconsidered and land identified to meet this figure.

Need for affordable housing uplift
4.3.11 Greater Cambridgeshire is one of the most expensive places to live with house prices well in excess of average earnings. More housing is needed above the minimum local housing need figure generally to make the supply greater and housing generally more affordable. NL consider that there is a need for more housing in Greater Cambridge, namely, to address the current housing crisis that is seen at both a national and local level, providing affordable housing which is an acute issue in the area. The Governments Written Ministerial Statement (June 2024) states “increasing supply will be an essential part of improving affordability”.
4.3.12 Indeed, the headline figure taken from the latest Housing Needs Assessment (2025) confirms at paragraph 7.72 that there is a net affordable housing need of 1,636dpa across the plan area representing over 60% of the total housing requirement for all tenures. Paragraph 1.41 also clearly states: “It does need to be stressed that this report does not provide an affordable housing target; the amount of affordable housing delivered will be limited to the amount that can viably be provided. The evidence does, however, suggest that affordable housing delivery should be maximised where opportunities arise.” (emphasis added)
4.3.13 The PPG is clear that the total affordable housing need can be considered in the context of its likely delivery as a proportion of mixed market and affordable housing developments, taking into account the proposal percentage of affordable housing to be delivered by eligible market housing led developments and that an increase in the total housing figures included in the plan may need to be considered where it could help deliver the required number of affordable housing.
4.3.14 Whilst it would be difficult to deliver the full affordable housing need in terms of how many market homes would need to be delivered, given the ongoing shortage of affordable homes and implications for not delivering a sufficient number, it is considered that there is a strong case for an uplift to the housing requirement to assist in affordable housing delivery which will result in both social and economic benefits and help to rebalance the housing market, particularly when the Councils’ own evidence states every effort should be made to maximise delivery where possible.
Housing requirements for Neighbourhood Areas
4.3.15 Policy S/JH also sets out housing requirements for designated neighbourhood areas for which any additional or amended neighbourhood areas.
4.3.16 The methodology is calculated based on the overall housing requirement, the development strategy, the population of the neighbourhood area and its proportion of the Greater Cambridge population. It therefore proposes a housing requirement of 6,183 dwellings (-122 dwellings from Regulation 18 consultation).
4.3.17 In principle, NL support the Council in setting a housing figure for relevant neighbourhood areas. However, these should only be seen as a starting point for setting a housing requirement where there is a lack of evidence surrounding individual housing needs of neighbourhood plan areas. If a housing needs assessment has been undertaken as part of preparing a neighbourhood plan or a previous assessment of need then it should be this figure that the housing requirement is predicated on.
4.3.18 In this regard, the Stapleford and Great Shelford Neighbourhood Plan (SGSNP) wade made in October 2025 and covers a slightly different plan period of 2024- 2041. The Stapleford & Great Shelford Housing Needs Assessment prepared by AECOM (2023) confirms an affordable housing need of 348 homes for social and affordable rent and 300 homes for affordable home ownership over the period 2023 – 2043 and is therefore not too dissimilar to the period associated with the emerging Local Plan.
4.3.19 The SGSNP was prepared in the context that the GCLP would allocate Land at Mingle Lane to meet some of its housing needs due to its location in Green Belt. Indeed, this is reflected in South Cambridgeshire District Council’s response to the Neighbourhood Plan Regulation 16 consultation in which the Council recognises the neighbourhood area’s constraints and its ability to meet affordable housing needs. The response states at paragraph 10 that:
“The Neighbourhood Plan highlights that there is a high level of affordable housing need in the plan area, including from those with a local connection to the area. The response to meeting the needs of those with a local connection is usually to deliver rural exception sites for affordable housing, and the Neighbourhood Plan supports this, but any rural exception sites are unlikely to deliver the number of homes necessary to meet needs…Neighbourhood Plans cannot allocate sites within the Green Belt or remove land from the Green Belt in order to allocate sites. It is therefore considered acceptable for Neighbourhood Plans in this situation to specify that local connection criteria can be applied to a proportion of the new affordable homes on future Local Plan allocations and any windfall sites (that are not rural exception sites, and where affordable housing can be secured) outside of the development framework boundary”. (emphasis added)
The Greater Cambridge authorities took the decision to delete Land at Mingle Lane as a proposed allocation. Consequently, the GCLP provides no mechanism to even achieve the suggested housing requirement and more importantly the housing needs of the settlement. The Neighbourhood Plan is now unable to meet its housing needs and it is unlikely that any affordable housing will be delivered within the settlement. Even if the plan where to be reviewed the neighbourhood area is unable to allocate any meaningful growth unless land is released from the Green Belt to meet housing needs. Consequently, the community’s housing needs will go unaddressed and affordability pressures will increase. Therefore, Land at Mingle Lane will need to be reincluded in the plan to achieve the proposed housing requirement and should be reflected in Policy S/DS.

6.1.3 Accordingly, modifications are required to the plan to address these concerns through the allocation of land at Mingle Lane.

4.3.37 The settlement hierarchy seeks to direct development towards higher level services with Cambridge as a focal point for future development followed by the towns of Cambourne, Northstowe and Waterbeach.

4.3.38 NL support the identification of Great Shelford and Stapleford as a Rural Centre which is one the largest and most sustainable villages within Greater Cambridge. The settlements have access to a number of services including rail, primary education, employment opportunities, shops, and restaurants.

4.3.39 NL recognise the Councils’ approach that development should be directed towards higher order settlements. However, the PPG is clear that a wide range of settlements can play a role in delivering sustainable development in rural areas, so blanket polices restricting housing development needs to be supported by robust evidence of their appropriateness.

4.3.40 Whilst we agree with the placement of Great Shelford and Stapleford within the settlement hierarchy, it must be remembered that this area has excellent access to Cambridge which will improve as part of future infrastructure initiatives such as the CSET busway and the new Cambridge South Station of the Cambridge Biomedical Campus which is directly accessed from Shelford station. Given the recognition of the number of services and facilities available within the settlement and its position within the settlement hierarchy it is imperative that sufficient growth is directed toward this location through the reintroduction of Land at Mingle Lane as a proposed allocation to enable better distribution of growth across Greater Cambridge.

4.3.41 Whilst no strategic constraint to the amount of development or redevelopment is imposed to these areas, this only relates to development within existing built
limits. Consequently, there is a lack of flexibility in terms of land adjacent to settlement boundaries particularly in the context of Grey Belt land.

4.3.42 The changes to the Framework has introduced National Development Management Policy S5 which sets out the principle of development outside settlements where they are within a reasonable walking distance of a well-connected station and in instances where there is an evidenced unmet housing need and does not stipulate a cap on any future development.

4.3.43 Policy S/SH should be updated to reflect Government’s intention that allows development outside of existing development frameworks.

6.1.3 Accordingly, modifications are required to the plan to address these concerns through the allocation of land at Mingle Lane.

4.3.44 Policy S/DE seeks to define settlement boundaries for settlements located within Greater Cambridge. Whilst the policy stipulates what development can come forward this is limited to allocations within Made Neighbourhood Plans, rural exception sites and development which requires a countryside location i.e. horticulture, forestry etc.
4.3.45 As stated above, for Stapleford and Great Shelford, there are no sites within the defined development extent that would be capable of coming forward to meet the identified need nor would rural exception sites be capable of meeting their need given the Council’s response to the neighbourhood plan consultation.
4.3.46 The use of settlement boundaries should not preclude the ability of sustainable development opportunities from coming forward and should include a mechanism to ensure that development beyond settlement boundaries can come forward to respond to changes in circumstances over the plan period. Indeed, the reforms to the Framework have now introduced national development management Policy S5 which allows for development outside of defined development limits subject to the criteria attached to that policy. Whilst the Local Plan is being prepared in the context of the Framework 2024, the intention of Government is clear that the principle of development outside defined built up areas is acceptable subject to meeting the stipulations of Policy S5 of the Framework (2026).
4.3.47 Annex A of the Framework 2026 makes clear that development plan policies which are materially inconsistency with national decision-making policies in this Framework should be given very limited weight. The only exception to this is where they have been examined and adopted or made against this Framework. Consequently, even on adoption of the plan very limited weight will be applied to S/DE as it does not accord with the approach of the Framework 2026. Therefore, the policy should be updated to remove the limitations of development outside defined and to allow sustainable locations such as Great Shelford and Stapleford to grow to support existing services, facilities and deliver housing to meet identified needs of these villages.

6.1.3 Accordingly, modifications are required to the plan to address these concerns through the allocation of land at Mingle Lane.

4.3.48 Policy S/GB seeks to maintain the existing Cambridge Green Belt. The Councils have updated its Green Belt to identify what it considers Grey Belt sites.

4.3.49 The Councils assessment considers Land at Mingle Lane as well as wider land is provisional Grey Belt with a moderate contribution. The evidence prepared by CSA and submitted as part of the application for 110 dwellings considers that the site makes a weak/no contribution to the Green Belt. Given that the area assessed incorporates wider land, it is our opinion that Land at Mingle Lane provides a weak contribution to the Grey Belt overall and the assessment and inclusion of the site in the plan should be reconsidered.
4.3.50 Notwithstanding this, as made clear in our previous response to the Regulation 18 consultation, the PPG is clear that where local authorities seek to review and alter Green Belt boundaries it is expected that authorities identify Grey Belt land to inform this work and prioritise development in accordance with paragraphs 147 – 148 of the Framework (2024).
4.3.51 Where land is identified as grey belt land, any proposed development should be considered against the requirements of paragraph 155 of the Framework which now includes the Golden Rules set out at paragraph 156.
4.3.52 The Green Belt Assessment (2021) identifies the level of harm to the Green Belt of the site at Mingle Lane, Great Shelford, as ‘moderately high’. However, it scored as follows: [table pg.24 appendix]

4.3.53 Whilst the Council considers its contribution as moderately high in its previous Green Belt Assessment when assessed against individual purposes its highest contribution scored ‘moderate’. Furthermore, the overall conclusion of “Moderate High” doesn’t align with the conclusion reached for each criteria, which ranged from no contribution to moderate contribution.
4.3.54 The Green Belt Topic Paper notes judgments in Calverton and Keep Bourne End which find that exceptional circumstances is a matter of planning judgment. It is noted that the evidence paper accepts that these judgments pre-date the changes to national policy and do not consider the revised approach introduced by the Framework (2024) and concept of Grey Belt which is material consideration given the substantial change to Green Belt policy. The Development Strategy seeks to amend Green Belt boundaries at Cambridge Biomedical Campus and Babraham Research Campus. The Council confirm at paragraph 3.3 that the case for exceptional circumstances for these sites relate to site specific circumstances and unique economic factors. Whilst is it accepted that these sites may provide exceptional circumstances linked to economic growth it does not absolve the Councils that the Framework requires Grey Belt land to be prioritised over the release of land at other Green Belt locations.

4.3.55 It concludes at 4.1 that “on this basis, the preferred option development strategy meets our identified need for development such that NPPF paragraph 146 is not
The updated assessment relating to Land at Mingle Lane is limited to a single paragraph at paragraph 4.25 of the Green Belt assessment – Review following changes to National Policy and Guidance which considers “the partial containment of the parcel by urban development would be slightly increased but not enough to reduce the harm rating as this is still a fairly substantial area of land, the development of which would have some increased urbanising influence on open land to the north.” The parcel assessment includes wider land and does not appear that the Council have reviewed the full extent of the site ownership from what was submitted as part of the consultation.

4.3.57 Given the site meets the criteria for Grey Belt, is within walking distances to rail services and would provide significant market and affordable housing to meet the local community housing needs, it is considered there are exceptional circumstances to justify its release and it should therefore be reintroduced as an allocation to meet the needs of Great Shelford and Stapleford.

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

6.1.3 Accordingly, modifications are required to the plan to address these concerns through the allocation of land at Mingle Lane.

The policy states ‘flood risk from all sources will be managed using the sequential, risk-based approach taking into account the impacts of climate change…’. This policy requires updating to take account the latest guidance set out in the PPG that the sequential test no longer needs to be applied where a site specific FRA demonstrates that occupiers will remain safe from surface water flood risk for the lifetime of the development without increasing flood risk elsewhere.

6.1.3 Accordingly, modifications are required to the plan to address these concerns through the allocation of land at Mingle Lane.

4.3.60 The above policy requires all development to provide a minimum of 10% biodiversity net gain. It further states major development must provide a minimum 20% biodiversity net gain unless exempt under the Environment Act 2021 to be provided on-site where this is feasible and effective.
4.3.61 National Development Management Policy N2 makes clear that development proposals may incorporate biodiversity enhancements which exceed the statutory objective, but this should only be a requirement where it is set out in up-to-date development plan policies for specific site allocations. It further states decision makers should not give weight to other development plan policies which require biodiversity gains to go beyond the statutory framework.
4.3.62 Notwithstanding this, Table 9 of the updated Local Plan Viability Assessment (2026) considers affordable housing percentage relative to biodiversity net gain. However, it only considers affordable housing up to 40%. Given the Golden Rules this would increase affordable housing requirement to 50% which appears untested.
4.3.63 The PPG is clear that: “Plan-makers should not seek a higher percentage than the statutory objective of 10% biodiversity net gain, either on an area-wide or for specific allocations for development unless justified. To justify such policies they will need to be evidenced including as to local need for a higher percentage, local opportunities for a higher percentage and any impacts on viability for development. Consideration will also need to be given to how the policy will be implemented6.”
4.3.64 The Draft Local Plan Viability Assessment (2026) considers that the 20% threshold is viable. The evidence supporting the 20% threshold is based upon the DEFRA ‘Impact Assessment Biodiversity Net Gain and Local Nature Recovery Strategies IA No. RPC Reference No: RPC-4277(1)-DEFRA0EA and SQW report ‘Viability Assessment of Biodiversity Net Gain in Essex’ (August 2024). In this regard, the market in Essex is invariably different to Greater Cambridge and it is unclear what effects setting a 20% threshold will have on development viability in the local area. Further evidence is required to demonstrate a local need for the higher percentages and impacts on viability related to Great Cambridge market area is required to justify any increase above the statutory 10% threshold.

6.1.3 Accordingly, modifications are required to the plan to address these concerns through the allocation of land at Mingle Lane.

In principle, NL support the above policy which seeks to ensure development provides for a mix of on-site provision and/or financial contributions for off-site open space provision to meet the needs arising from new development. However, the accessible Green and Open Space standards are considered to be excessive and would not be effective use of land which could maximise housing delivery on a site and realise development density in line with the current thinking of Government.

6.1.3 Accordingly, modifications are required to the plan to address these concerns through the allocation of land at Mingle Lane.

NL support the principle behind this policy which seeks to promote health and wealth being by providing and enhancing accessibility to green spaces, open space and sport pitch and is designed to facilitate and encourage walking, wheeling and cycling that is accessible for all.

6.1.3 Accordingly, modifications are required to the plan to address these concerns through the allocation of land at Mingle Lane.

4.3.67 Policy GP/HD requires development to make efficient use of land through applying appropriate densities that reflect local character and context through a design-led approach.
4.3.68 NL largely support the proposed policy particularly in relation to criteria 5 which allows for higher density development in sustainable locations that are well served within 1,200m by existing or proposed high quality public transport such as the Cambridgeshire Guided Busway, a transport interchange or railway station. This allows for a locally relevant policy consistent with the approach of national policy which seeks to direct development towards locations that have access to sustainable modes of transport.